ML20058N809

Pump & Valve IST Program Prairie Island Nuclear Generating Plant,Units 1 & 2 Northern States Power Co, TER

ML20058N809
Person / Time
Site:	Prairie Island
Issue date:	11/04/1993
From:	Deem R, Dibiasio A, Fresco A BROOKHAVEN NATIONAL LABORATORY, NEW BRUNSWICK LABORATORIES
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20058N786	List: ML20058N783 ML20058N802 ML20058N809
References
CON-FIN-L-2301 TAC-M86807, TAC-M86808, NUDOCS 9312220269
Download: ML20058N809 (55)

Text

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TECHNICAL EVALUATION REPORT:  !

Pump and Valve Inservice Testing Program Prairie Island Nuclear Ge'nerating Plant,1 Units 1 'and 2! '

Northem States Power Company? '"

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Docket Number: 50-282 and 306 '

TAC Number: M86807 and M86808-November 4,1993 t

Prepared by: 1 A. Fresco, R. Deem, and A. DiBiasio  :

Engineering Technology . Division - i Department of Advanced Technology.

Brookhaven National Laboratory Upton, New York 11973 Prepared for the:

Division of Engineering.

Office 'of Nuclear Reactor Regulation U._ S. Nuclear RegulatoryfCommission - ~ ,  ;

Washington, DC 20555L ,

FIN L-2301 Task' Assignmen't 6; ^

931222o269 9312oB PDR ADOCK oSOoo282 P PDR l

ABSTRACT This report presents the results of Brookhaven National Laboratory's evaluation of Prairie Island Nuclear Generating Plant, Units 1 and 2, ASME Section XI Pump and Valve Inservice Testing Program relief requests and deferred testing justifications.

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i TABLE OF CONTENTS i Abstract ........................................................ iii ;

i 1.0 thfTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 j

2.0 PUMP IST PROGRAM RELIEF REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 Vibration Relief Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 .

2.2 Hydraulic R elief Requests . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . S 3.0 VALVE !ST PROGRAM REUEF REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.1 Containment Sump Isolation Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.0 DEFERRED VALVE TESTING JUSTIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . 38  !

6.0 REFEREtCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 APPENDIX A ......................................................... A-1  ;

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. Technical Evaluation Report Pump and Valve Inservice Testing Program Prairie Island Nuclear Generating Plant >

Units 1 and 2

1.0 INTRODUCTION

Contained herein is the technical evaluation of ASME Section XI pump and vatve inservke testing (IST) program resef requests submitted by Northern States Power Company (NSP),

under 10 CFR Part 50 Set. tion 50.55a(a) and (f) for the Prairie Island Nuclear Generating Plant, Units 1 & 2. These riants are an early design 2-Loop Westinghouse Pressurized Water Reactor (PWR), which wera granted a commercial operating license in 1974.

in NSP's June 16,1993 letter to the USNRC, they submitted the third ten-year interval IST program update, to become effective December 16,1993 and December 21,1994 for Units 1 '

and 2, respectively. The licensee states that the revised program has been developed using ASME Section XI,1989 Edition. ASME Section XI,1989 Edition references ASME/ ANSI OMa- ,

1988 Parts 6 and 10 for pump and valve testing requirements. The licensee also states that positions in Generic Letter 89-04 would be utilized. Revision 2 of the third interval was sent to the NRC August 25,1993 and was used for this review. The licensee provided BNL additional information in letters dated August 24, September 24, and October 6,1993.

Title 10 of the Code of Federal Regulations, Q50.55a 1(f) requires that inservice testing of ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of 1 the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific relief I has been requested by the licensee and granted by the commission pursuant to 50.55a (a)(3)(i), (a)(3)(ii), or (f)(6)(i). Section 50.55a (f)(4)(iv) provides that inservice testing of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of $50.55a, subject to the limitations and modifications listed, and subject to Commission approval. The 1989 Edition is the latest edition currently referenced in the regulations.

Review of the relief requests was performed utilizing the Prairie Island Nuclear Plant FSAR, applicable plant specific P&lD's, Generic Letter 89-04, ' Guidance on Developing Acceptable inservice Testing Programs," the Minutes of the Public Meeting on Generic Letter 89-04, dated October 25,1989; and draft NUREG-1482 ' Guidelines For Inservice Testing Programs At Nuclear Power Plants." IST Program requirements apply only to component (i,e., pumps and valves) testing, and are not intended to provide a basis to change the licenue's current Technical Specifications for system test requirements.

Section 2 of this report presents the BNL evaluation of the five pump relief requeNs for Unit 1 and the three pump relief requests for Unit 2. Similar information is presented ;n Section 3 on the one valve relief request for Unit 1 and Unit 2. Section 4 contains the evaluation of NSP's justifications to defer valve testing to cold shutdowns or refueling outages. Section 5 summarizes the recommended actions for the licensee resulting from the relief request and deferred testing justification evaluations. BNL recommends that the licensee resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

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2.0 PUMP IST PROGRAM RELIEF REQUESTS in accordance with 10CFR50.55a, NSP has submitted five relief requests for Unit 1 and three relief requests for Unit 2 concerning pumps at the Prairie Island Plant which are subject to inservice testing under the requirements of ASME Section XI. These relief requests have been reviewed to verify their technical basis and determine their acceptability. Each relief request, and its associated technical evaluation is summarized in the succeeding subsections.

2.1 REUEF REQUESTS FROM CODE VIBRATION REQUIREMENTS 2.1.1 Unit 1 and Unit 2 Reliet Request No.1, Safety injection Pumps 11, 12, 21, 22; Containment Spray Pumps 11,12,21,22; Component Cooling Pumps 11, 12, 21, 22; Diesel Driven Cooling Water Pumps 12,22.

Relle/ Request: The licensee requests relief from ASME/ ANSI OMa-1988, Part 6. Table 3 which requires vibration alert limits for centrifugal pumps to be >2.5Vr to 6Vr or >0.325 in/sec.

Proposed Allemate Testing: Vibration reference values for these pumps will be set by using pump specific vibration histories. Individual alert limits will be established per the Code unless a value becomes >0.325 in/sec. In those cases, the alert limit will be set at Vr + 0.2 in/sec.

The licensee has also provided specific proposed alternative testing as follows:

Safety injection Pumps 11,12, 21,22 ' Alert limits at locations on each pump which are above Code value will be compared with alert limits on the pump which are within Code acceptable values. Subsequent data will then be evaluated based on pump vibration trending and history. In addition to quarterly miniflow test data, full flow vibration data will be taken and analyzed once per refueling."

Containment Spray Pumps 11,12,21,22

• Alert limits at locations on each pump which are above Code value will be compared with alert limits on the pump which are within Code acceptable values. Subsequent data will then be evaluated based on pump vibration trending and history.'

Component Cooling Pumps 11,12,21,22 - The limits on these pumps will be established based on evaluation of sensor location and pump flow.

Diesel Driven Cooling Water Pumps 12,22 - The limits on these pumps will be established based on evaluation of sensor location and pump flow. Additionally, pump speed will be held constant while taking vibration data during all tests for these pumps.

Licensee's Basis For Relief: The licenses states that: "All pumps have a detailed vibration history which is trended and available to the engineering staff. Operating history and availability of these pumps has been excellent with no failures. The pump manufacturers are in agreement that pump degradation can be monitored by trending vibration levels from a reference point properly established. Alternate acceptance criteria established as described above will give adequate indications of pump degradation."

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Pump specific basis for relief is as follows:

Safety injection Pumps 11,12,21,22 'The Code alert limits will not be met based on the  ;

higher vibration levels at minimum flow. The higher vibration levels are at higher frequencies which can be accounted for by intemal hydraulic forces (i.e., vane passing frequencies). Trending of vibration data at both minimum flow and full flow will adequately reflect changes in pump conditions.* ,

Containment Spray Pumps 11,12,21,22 'The Code alert limits will not be met based on the higher vibration levels at minimum flow. A second contributing factor is the effect of piping configuration. Trending of vibration data will adequately reflect changes in pump condition.'

Component Cooling Pumps 11,12,21,22 "The component cooling system resistance cannot be adjusted to achieve a standard reference point during a test. Per the Code, flow and pressure readings will be taken and compared to reference values. These reference values will be based on pump performance and history when it was in good mechanical condition. Certain vibration points are sensitive to flow conditions, particularly low flows. Vibration readings will be correlated to pressure / flow readings. The outboard pump bearing is very load sensitive and vibration varies by as much as 100%"

Diesel Cooling Water Pumps 12,22 ' Vibration values and limits are flow, speed and sensor location dependent. System resistance cannot be adjusted to achieve a standard reference point.

Per the Code, flow and pressure readings will be taken and compared to reference values. These reference values will be based on pump performance and history when it was in good mechanical condition. Vibration readings will be correlated to pressure / flow readings."

Evaluation: The licensee has proposed attemative alert levels to those specified in Table 3 of OMa-1989 Part 6 for various vibration measurements on the subject pumps. Table 3 -

provides the acceptance criteria to determine changes in pump bearing wear and other types of pump degradation that can affect the operational readiness of the component. When a pump's vibration level falls within the specified alert range, the test frequency for that pump is doubled (i.e., to once every one and one-half months) until the cause of the deviation is determined and the condition corrected. There are instances when, due to a system design (i.e.,

flowrate or piping configuration) or other unique equipment feature, a pump's vibration level at various locations and directions could be normally high. In these instances the pump would require testing every one and one-half months instead of the quarterly requirement due to small deviations from normal vibration levels. The licensee feels the alternative alert limits and testing specified are adequate in determining changes in the subject pumps' condition. In addition to setting the alert limit at Vr+0.2 in/sec., based on the relief request, we assume the licensee is also performing trending. Reference values should be established when the pump is known to be operating acceptably. As discussed in TER Section 2.2.1, when using pump curves, as for the cooling water pumps, appropriate vibration acceptance criteria should be developed for regions of the pump curve.

The licensee's proposed alert level for various vibration readings would be set above the

>0.325 in/sec. limit, and the possibility exists that a particular vibration reading could be within the proposed acceptable alert range but exceed the Code specified action limit (e.g., if Vr>5 in/sec.). This possibility was not accounted for in the licensee's relief request. The licensee should ensure that a pump is declared inoperable when vibration levels enter the code 3

required action range, regardless of the alert range.

In reviewing the basis for

• Alert" and ' Required Action

• absolute limits established for OM Part 6, the values of 0.325 in/sec for

• Alert' and 0.700 in/sec for ' Required Action' are consister>t with industry standards for acceptable and degraded conditions (reference NUREGJCP-0111, " Proceedings of the Symposium on Inservice Testing of Pumps and Valves,"

planned session paper ' Basis of the New Vibration Measurement Criteria and Requirements of Part 6'). Vibration levels in excess of 0.325 in/sec constitute very rough operation and are generally not considered by industry to be acceptable for axtended periods of operation. The licensee has not provided adequate justification for acceptmg these high vibration levels for an extended period of time. Immediate compliance with the Code would be burdensome due to the increased test frequency, without a compensating increase in quality and safety. Therefore, it is recommended that the licensee's alternative testing be authorized for an interim period in -

accordance with 10CFR50.55a(a)(3)(ii). However, the Code required ' Action level' in Table 3 of OMa-1989 Part 6 remains applicable. In the interim, the licensee should perform a comprehensive evaluation of why it is acceptable to run these pumps at such high vibration levels. This evaluation could include discussions with the specific pump vendors and contain conclusions based on spectral analysis, pump vibration histories, and length of time the pumps -

operate at high vibration in nc,r,al and during accident conditions. Based on the potential for pump degradation, the licensee should evaluate ways of reducing vibration levels to industry recommended limits. The licensee's evaluation should be available for NRC inspection at the plant and the conclusions should be discussed in the relief request.

2.1.2 Unit 1 and Unit 2 Relief Request No. 4, Diesel Driven Cooling Water Pumps (DDCWPs) 12,22; Motor Driven Cooling Water Pump (MDCWP) 121; Residual Heat Removal Pumps 11,12, 21, 22.

Relief Request; The licensee is requesting relief from ASME/ ANSI OMa-1988, Part 6, Paragraph 4.6.4(b) which requires vibration measurements on vertical line shaft pumps to be taken on the upper motor bearing housing in three orthogonal directions, one of which is the axial direction.

Proposed Altemate Testing: The licensee has proposed specific testing attematives as follows:

Diesel Driven Cooling Water Pumps 12,22

• Vibration measurements will be taken on the j right angle drive of the pumps in three orthogonal directions, one of which will be axial. One additional vibration measurement will be taken on the diesel engine."

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Motor Driven Cooling Water Pump 121 " Vibration measurements will be taken on the motor housing in three orthogonal directions, one of which is axial. The axial reading will be taken on the side of the housing, midway between the upper and lower bearing."

Residual Heat Removal Pumps 11,12,21,22 " Vibration measurements will be taken in two.

orthogonal directions using the two existing installed probes.'

Licensee's Basis for Relief: The licensee states the specific basis for relief is as follows:

Diesel Driven Cooling Water Pumps 12,22 'The driver for the DDCWP is a diesel engine coupled to a right angle drive. The pump bearing is inaccessible for vibration measurements.*

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. Motor Driven Cooling Water Pump 121 "The design of the MDCWP prevents' access to the i upper thrust bearing housing to take an axial vibration reading with a portable instrument t i- while the pump is running. A modification to add a permanent transducer would be costly with i L no commensurate additional benefit. To climb on top of the motor while it is running is a personnel hazard."  !

L Residual Heat Removal (RHR) Pumps 11,12,21,22 'The upper motor thrust bearing .l housing is inaccessible for an axial measurement. Portable instrumentation would be difficult  !

l- to use due to a domed cover over the pump housing which limits access and would tend to amplify any readings. The addition of a permanent probe would be costly with no commensurate benefit to safety

• t Evaluation: ASME/ ANSI OMa-1988 Part 6, Paragraph 4.6.4(b) specifies that the vibration i reading locations be on the upper motor bearing housing. Inaccessibility due to pump design  !

precludes the taking of required vibration measurements at certain Code specified locations on '

the subject pumps; therefore, it is impractical to meet the Code requirements. The pumps i would have to be redesigned or replaced to accommodate compliance with the Code. Since the thrust from the pump and driver in the case of the DDCWPs would be transmitted to the right I angle drive, the monitoring of vibration levels at this location will give an acceptable indication I of any pump degradation. In the case of the MDCWP, vibration measurements taken on the pump housing in three orthogonal directions, one being in the axial direction, will give an  ;

acceptable indication of any pump degradation. The axial vibration from the upper motor  :

thrust bearing would be transmitted to the motor housing. The RHR Pumps have permanently ,

installed radial probes that measure vibration in two orthogonal directions. Since a component  ;

of the axial vibration from the upper motor thrust bearing would also be picked up by these probes, and portable measurements of axial vibration are not practical because of personnel safety concerns, the existing monitoring capability with proper acceptance criteria would i provide an adequate indication of any pump degradation.

Therefore, based on the impracticality of complying with the Code and that the proposed  !

alternative provides reasonable assurance of the pumps' operational readiness, it is recommended that the licensee's request for relief be approved in accordance with 10CFR50.55a(f)(6)(i). When using temporary instruments, the licensee should ensure that the instruments are calibrated prior to use and are traceable to the inservice test records. l l

2.2 REUEF FROM CODE HYDRAUUC REQUIREMENTS 1

2.2.1 Unit 1 Relief Request No. 5, Diesel Driven Cooling Water Pumps 12,22; Motor Driven Cooling Water Pump 121.

Relief Request: The licensee is requesting relief from ASME/ ANSI OMa-1988, Part 6, Paragraph 5.2(b), which requires the resistance of the system to be varied until the flowrate or pressure equals the reference value, and Table 3b, which requires the differential pressure Alert range to be 0.93Pr to <0.95Pr and Required Action range to be <0.93Pr or >1.10Pr.

Proposed Attemate Testing: Pump noiv, suction and discharge pressure would be measured, then pump differential pressure plotted against flow to determine a ' point' on the pump curve.

This point is then compared to acceptare criteria. The acceptance range will be between 90%

and 103% of the pump curve. The Alert range will be from 80% to 90% or 103% to 106% of i

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4 the reference value. The required Action range will be for values <80% or >106% of referenco value on the pump curve. In a letter dated September 24,1993 from the licensee, intended to provide additional information and clarification on certain relief requests, the acceptance criteria for the diesel driven cooling water pumps was revised to a proposed range of 90.1% to 103.5%, a proposed alert range from 85.3% to 90.1% or 103.5% to 105%, and a required action range of <85.3% or >105% of reference value. The Deensee states that pump curves would be developed using the following methods:

A) Curves would be developed from data taken when the subject pumps were known to be operatmg properly, if one of the subject pumps is repaired or replaced, the respective curve would be revalidated or redrawn.

B) The reference points used to develop the curves for the subject pumps will be measured with instruments that meet Code accuracy requirements. A minimum of five points, including points close to design flow, will be used.

C) Acceptance criteria basis of the curves will not conflict with Technical Specifications or USAR operability criteria for flow rate and differential pressure.

Licensee's Basis for Relief The licensee states that: ' System design does not allow performance of hydraulic tests at specified reference points. Because of the numerous system loading combinations possible, it is not practical to reestablish the exact reference point for the pump test. Because a repeatable reference point cannot be reestabbshed for each test, the inaccuracies in determining the pumps' hydraulic conditions and code allowable variances in these conditions (flow and dp) compound the allowable ranges of operation when both flow and dp are compared together.'

Additionally, the licensee stated in the September 24,1993 letter that:

1)*The instrumentation has a loop accuracy of 2%. Using both pressure and flow data which contains a 2% in both terms compounds the inaccuracy when plotting the data on the pump l

curve."

2)*The system flow is not steady during the surveillance procedure. Flow fiuctuations cause the flow indicator to deflect while it is being read. Observed deflections of the needle is about 500 gpm. Normal practice is to record average indicated value '

3)*There are unmetered flow paths coming off the pump discharge before the flow indicator in particular, the automatic backwashing of screens and strainers can divert an unmetered flow of approximately 500 gpm. This causes an indicated pump flow lower than expected for the indicated discharge pressure.'

Evaluation: Although some designs do not facilitate setting hydraulic parameters at exact values because of limiting system characteristics, the Code does not address the use of pump curves. ,

The use of pump curves, however, is an acceptable attemative when it is impractical to test l

pumps using fixed reference values, provided the method is equivalent to the Code requirements I in Table 3b. It is impractical to test the cooling water pumps at fixed reference values because the system resistance is variable based on plant heat loads. Compliance with the Code would require a major redesign of the system. When preparing the pump curves, the licensee should ensure that if vibration levels vary significantly over the range of the pump conditions, a method for assigning appropriate vibration acceptance criteria should be devebred for regions of the pump curve.

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Therefore, it is recommended that relief be granted to use pump reference curves pursuant to 10CFR50.55a(f)(6)(i). The licensee has not, however, provided an adequate basis for using  !

less restrictive acceptance criteria than that coritained in Table 3b. Pending further clarification, the licensee must implement the Code acceptance criteria.

In the letter dated September 24,1993 from the licensee, it was stated that for these pumps "there are unmetered flow paths coming off the pump discharge before the flow indi:ator of approximately 500 gpm". The licensee should evaluate isolating the automatic backwashing during the short period of time required to perform the test and making an appropriate modification of the governing surveillance procedure. This will minimize the instrument reading fluctuations and facilitate compliance with OMa-1988 Part 6 Table 3b requirements.

The Code requires total flow through the pump to be raeasured. If full Code compliance is burdensome or impractical, the licensee should submit a request that would technical!y justify granting relief in accordance with 10CFR50.55a(a)(3)(ii) or 10CFR50.55a(f)(6)(i),

respectively.

2.2.2 Unit 1 Relief Request No.10, Containment Spray Pumps 11,12.

Relief Request: The licensee requests relief from ASME/ ANSI OMa-1988, Part 6, Paragraph 5.2 which requires measurement of flowrate on a quarterly basis.

Proposed Altemate Testing: The subject pumps will continue to be tested on a Code frequency i using the non-instrumented minimum flow line.

Licensee's Basis for Relief. The licensee states that: "The installation of a minimum flow line meter requires that Unit 1 to be at cold shutdown. The next refueling outage for Unit 1 is scheduled for 1994. The instrumentation will be installed at that time."

Evaluation: In Generic Letter 89-04, Position 9, the Staff determined that in cases where flow can only be established through a non-instrumented minimum flow path during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test of the pump at under full or substantial flow conditions, the increased interval is an acceptable alternative to the Code requirements provided that pump differential pressure, flow rate, and bearing-vibration measurements are taken during this testing and that quarterly testing also includes measuring at least pump differential pressure and vibration. The Containment Spray system currently does not have an instrumented test loop that could be used during any mode of power operation. The licensee has, however, committed to installing the necessary minimum flow l path instrumentation at the next refueling outage (March,1994),

immediate imposition of the Code requirements would be a hardship because installation of instrumentation would require placing the unit in a cold shutdown condition, without a ,

compensating increase in the level of safety, based on the short length of time between the j beginning of the next ten year interval (December.1993) and the scheduled refueling outage (March 1994). Therefore, based on the hardship without a compensating increase in quality and safety, it is recommended that the attemative be authorized for an interim period pursuant ,

to 10CFR50.55a(a)(3)(ii) until the necessary instrumentation is insta!!ed or through the '

next refueling outage, whichever is later.

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2.2.3 Unit 1 and Unit 2 Relief Request No. 2, Component Cooling Pumps 11,12,21,22. j l

Relief Request: The licensee is requesting relief from ASME/ ANSI OMa-1988, Part 6, Paragraph 4.6.1.1 and Table 1, which requires that flow instrumentation be accurate within 2% of full scale. l Proposed Alternate Testing: " Presently installed instrumentation is accurate to within 13%.

During each surveillance test the pump differential pressure vs. flow is compared to an acceptance curve based on Code criteria. To offset the higher instrument inaccuracy, the pump acceptance curves will be reduced by 1% of normal flow.'

Licensee's Basis for Relief: The licensee states that: 'The addition of a more accurate flowmeter would require a plant modification with little increase in safety *.

Evaluation: The NRC does not generally consider installation or replacement of instruments an undue burden, and compliance with later editions of the Code for instrumentation requirements is not considered a backfit (Minutes to the Public Meeting on Generic Letter 89-04, Question No. 105). If major modifications to the system (i.e., piping redesign or venturi / orifice replacement) are required, then limitations of practicality could provide a basis for relief.

The level of modification effort required to achieve full Code compliance was not, however, discussed by the licensee.

It is recommended that the licensee be required to comply with the Code instrument accuracy requirement. It would be a hardship to require immediate compliance, as this would require  ;

the shutdown of both Units to perform the necessary modifications. There would not be a compensating increase in the level of quality and safety in the interim, based on reducing the acceptance criteria by 1%, and measuring pump vibration and differential pressure. The alternative provides reasonable assurance of the pumps' operational readiness. Therefore, based on the hardship of complying with the Code without a compensating increase of quality and safety, it is recommended that the alternate testing be authorized for an interim period in accordance with 10CFR50.55a(a)(3)(ii). In the interim, the licensee should install instruments that comply with the Code'or provide additional information for long term relief that would justify an unusual hardship and demonstrate that the reduced acceptance criteria gives adequate information for monitoring degradation and taking corrective action. The licensee should note that the additional 1% of full scale inaccuracy may result in a reading inaccuracy of 3% (i.e.,1% X 3 X reference value, per $4.6.1.2(a)). One option for long term relief would be to reduce the acceptance criteria by 3% (i.e., the required action limits would be <0.93 Or and >1.07 Or for these centrifugal pumps), which would provide an equivalent level of quality and safety to the Code.

Additionally, the licensee states in the justification that an acceptance curve will be used.

Specific relief from the requirements of OMa-1988 Part 6, Paragraph 5.2b has not been requested. Relief is required to utilize pump curves, as the Code does not currently allow their ,

use. The licensee should prepare a relief request. The request should discuss the ,

impracticality of testing at a single reference point and should include the following elements for developing curves: i i

1.) Th'e data for developed reference curves is validated from when the pumps are known to be 3

operating acceptably.

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2.) Reference points used to develop or validate the curve are measured using instruments at least as accurate as required by the Code (This includes meeting the Code accuracy and range requirements).

3.) Reference curves are based on an adequate number of points, with a minimum of five.

4.) Data points are beyond the ' flat

• portion (Iow flow rate) of the curves in a range which includes or is as close as practicable to design basis flow rates.

5.) Acceptance criteria based on the curves does not conflict with Technical Specifications or Facility Safety Analysis Report operability criteria on the affected pumps for flow rate and differential pressure.

6.) If vibration levels vary significantly over the range of pump conditions, a method for assigning appropriate vibration acceptance criteria should be developed for regions of the pump curve.

7.) When the reference curve may have been affected by repair, replacement, or routine service, a new reference curve shall be determined or the previous curve revalidated by an inservice test.

'l 3.0 VALVE IST PROGRAM RELIEF REQUESTS In accordance with 10CFR50.55a, NSP has submitted one relief request for both Unit 1 and Unit 2 for valves at the Prairie Island Plant which are subject to inservice testing under the requirements of ASME Section XI. This relief request has been reviewed to verify its technical j basis and determine its acceptability.- The relief request, and its associated technical evaluation, is summarized in the succeeding subsection.  ;

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Unit 1 and Unit 2 Relief Request No. 3. Containment Sump Isolation Valves MV-32075, l MV 32076, MV-32178, and MV-32179 l

Relief Request: The licensee requests relief from ASME/ANSl OMa-1988, Part 10, Section 4.1, which requires valves with remote position indicators to be observed locally at least once '

every two years to verify valve operation is accurately indicated.

• Proposed Altemate Testing: System characteristics and/or visual observation, when possible, will be used to determine obturator movement. Leak testing of these valves in the closed position each refueling outage and visual verification when the enclosure covers are removed will be performed.  ;

i Licensee's Basis For Relief: The licensee states that: ' Valve' design does not allow for easy '

access to valves for inspection of position. Removing the valve cover would be a hardship with j no equivalent increase in safety.'

Evaluation:  !

ASME/ ANSI OMa-1988 Part 10 Paragraph 4.1 requires local verification that

'l valve positions are~ correctly indicated. Where practicable, local verification should be d

supplemented by other indications. Part 10 allows other indications, such as flow, to be used for verification of valve operation when local observation is not possible. ,

Each of the subject motor-operated valves is located in a pressure retaining enclosure which is part of the containment barrier. These enclosures are 8 ft. in length,3.5 ft. In diameter with flanged covers and are Class B pressure retaining vesse's as defined in the ASME Code Section til. This was verified by reviewing the licensee's SAP, mechanical drawings and flow diagrams.

Disassembly of these enclosures to verify correct ' salve position indication, although possible, is burdensome without a compensating increase ;n the level of quality or safety, since the licensee has proposed to use system characteristics and leak tests to verify correct valve position indication. This plus periodic inspection whenever the enclosure covers are removed would give adequate assurance that the subject valves positions are correctly indicated.

Therefore, based on the hardship without a compensating increase in quality and safety, it is recommended that the proposed alternative testing be authorized in accordance with 10CFR50.55a(a)(3)(ii).  ;

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. 4.0 VALVE TESTING DEFERRAL JUSTIFICATIONS i 8

Northern States Power has submitted justifications for deferring valve testing. These justifications document the impracticality of testing 142 valves in each unit quarterly, during  !

power operation, or cold shutdowns, as required by Section XI. These justifications were reviewed to verify their technical basis. In general, the licensee should provide more "

information in the justifications. The licensee should discuss why the testing itself is impractical, by assessing the problems associated with performing the test. <

As discussed in Generic Letter 91-18, it is not the intent of IST to cause unwarranted plant r shutdowns or to unnecessarily challenge other safety systems. Generally, those tests involving the potential for a plant trip, or damage to a system or component, or excessive personnel hazards are not considered practical. Removing one train for testing or entering a Technical -

Specification limiting condition of operation is not sufficient basis for not performing the required tests, unless the testing renders systems inoperable for extended periods of time (Reference Generic Letter 87-09). Other factors, such as the effect on plant safety and the difficulty of the test, may be considered.

Valves, whose failure in a non-conservative position during exercising would ,cause a loss of system function, such as non-redundant valves in lines (e.g., a single line from the RWST or accumulator discharge), or the RHR pump discharge crossover valves for plants whose licensing bases assumes that all four cold legs are being supplied by water from at least one ~

pump (Reference NRC Information Notice 87-01), should not be exercised during conditions when the system is required to be operable. Other valves may fall into this category under certain system configurations or plant operating modes, e.g., when one train of a redundant ECCS system is inoperable, non-redundant valves in the remaining train should not be cycled because their failure would cause a totalloss of system function or when one valve in a containment penetration is open and inoperable, the redundant valve should not be exercised during this system configuration.

• The Tables contained in the IST Program identify the function of the valves (i.e., open, closed, or both), test type (e.g., E for exercise), and test frequency. It is assumed that the test and frequency indicated in the Table apply to all the valve functions. The justifications, however, do not always address the impracticality of exercising in both directions. OM Part 10, 4.3.2.2 specifies that a check valve be exercised or examined in a manner which verifies obturator travel to the position required for the valve to fulfil its safety function. The licensee should review each justification and ensure that the test frequency is appropriate for both directions. While it may be impractical to stroke a valve open at power operation, it may be practical to perform a test to verify the valve's closure capability. In order to verify the closed function of check valves, OM Part 10 allows observation by a direct indicator, such as a position indicating device, by changes in system parameters, i.e., pressure, flowrate, level, temperature, by leak testing, or other positive means. It is not necessary to first open the valve before verifying the valve is closed. The justification should discuss why these observations cannot be made.

Additionally, for the majority of the deferral justifications, the licensee does not clearly state whether full stroke exercisino will be conducted at cold shutdowns or refueling outages. For example, in the justification for valve VC 8-2, the check valve downstream of regenerative heat exchanger 11 (Item No. A-7 in TER Table 4-1), the licensee states that 'The valves are 11 i

i

_ tested in accordance with the Code each cold shutdown.' The licensee has not clearly stated whether the cold shutdown testing involves full-stroke exercising or part-stroke exercising.

Another example is the justification for valves MV-32067 and MV-32069, the Unit 1 reactor vessel injection isolation motor-operated valves (item No. B-4). The licensee states that "The valves are cycled at cold shutdowns.' in the justification for MV-32121 and 32120, the component cooling water supply header isolation MOVs(Item No. F-1), the licensee states that

'The valves will be stroked each cold shutdown.' in the justification for CV-31740 and 31741, the Unit 1 containment instrument air isolation AOV (item No. H 1), the licensee states that 'The valves will be exercised at refueling shutdowns."

The ure of the words " tested", ' cycled', ' stroked', or " exercised" does not clearly state compliance with the Code requirements. For the purpose of the evaluation, BNL assumed that the test, cycle, stroke, or exercise constituted a full-stroke, unless otherwise stated. The licensee should clearly state in the justifications whether or not the valves will be part-stroke or full-stroke exercised at the applicable interval of plant operation, cold shutdown or refueling.

BNL's evaluation of each cold shutdown or refueling outage justification is provide in Table 4-

1. The Unit 2 valves and associated drawings are provided in brackets. Each justification is given an item number to aid with the discussions. The item number refers to the deferral notes provided in Appendix B and C of the IST Program (e.g., A-3). The anomalies associated with the specific justifications are provided in Section 5.10 of this TER.

1 l

l l

l I

l 12

{

Table 4.1 Deterred Testing Evalvellens-Prairie Island Nudear Geneesting Flont item Valve Identification Flow Disgram Ucensee's Justi6 cation for Deferring Valve Proposed Alternate Testing Evaluation of Dansee% Justi6 cation No. No. Exerdsing DEFERRAL NOTE A'

• The following valves will not be stroked on a quarterly basis for the following reasons?

A-1 AF-13 9,10, [11,12) NF-39222 Rev.

• Full stroking of the check valves open each "These valves are part it is impractical to full 4troke exerdse AF-141.3,[3,7) AFW AP, Unit 1 quarter is impractical since it requires sending stroked open quarterly" and these valves quarterly. The alternative Pumra discharge and Feedwater full flow to the steam generators and this causes full stroked open and ckned suctyn check vahes. provides partial 4troke exerddng open System thermal shocking of the Aux. Feedwater Unes (for AF-13-9, 10[11,12] during plant operation and ful!4troke as they enter the Steam Generator. AdditionaHy. only) eoch cold shutdown. exercising during cold shutdowns in

[NF-29223, Rev. this test does not address veri 6 cation of the acturdance with OMa 1988 Part 10 AN, Unit 2 check valve dosed. Verification that the check para. 4.3.2.2(b).

Feedwater valve closes can be done byimposing a pressure System) downstream of the check and measurement of the pressure. These complex tests are not warranted for the information reasved

• A2 AF-16-1,2, [3,4) NF-39222, Rev. *The valves cannot be partial or full stroked "Ihese valves are stroked it is impractical to partia!4troke AF-13-1,2,3,4J3,6,7,8) AP, Unit I quarterly since this causes thermal shocking of each cold shutdown to a exerdse of full 4troke exercise these AFW flow lines to Feedwater the aux feedwater lines as they enter the steam position required to perfornt valves open quarterly. The afternative steam generators deck System generator. its safety function. This is valves provides full 4troke exerdsing during accomplished by measuring cold shutdowns in arxordance with

[NF-29223, Rev. Stroking these vahes requires cyding of valves flow through the deck valve OMa-1988 Past 10 para. 4.3.2.2(c).

AN, Unit 2 which are required by Technical Speci6 cation to while the AFW pump is Feedwater be locked opened and the mispositioning of discharging to endi steam The licensee has not provided justi6-System] which causes a comprtmiise of the safety funo- generator.* cation for defening the quarterly tion of the system Such risk is not warranted reverse Dow test to verify the wafves' by the additional information obtained by *Also, testing to verify the closure capability, although the tables increasing the stroke interval of these valves." obturator travels to the seat in the Inservim Testing Program on cessation of flow each Manual (ISTTM) entitled *ASME cold shutdown, as schedule Section XI Valves Unit 1 [ Unit 2]",

permits.* herein after referred to as the Valve Program Tables, indicate that the stroke dosed test is also deferred to Gold Shutdown.

13

Table 4.1 (Cont'd)

Item Valve Identification ilt= Diagram Ucenwe's Justi5 cation for Deferring Valve Prcrowd Alternate Testing Evaluation of Densee's Justi6 cation No. No. Exercising A-3 CC-3-3,4; CC-5-1,2; NF 39245-1, " resting the valves closed on a quarterly basis is "These valves are full It is impractical to partial-stroke

[2CC-3-3,4); [2CC Rev. D, Unit I impractical ince it potentiany interrupts confing stroked open and tested to exercise or full 4troke exercise these 1,2]; Component Component water flow from the reactor coolant pumps verify the obturator travels valves closed quarterly. ne etternative cooling water return Cooling System (RCh) and thus affects plant reliaNiity.' to the seat on cessation of pmvides full 4troke czerdsing during line to CCW pumps flow each cold / refueling rold shutdowns in accwlance with suction check valves [NF 39246 1, shutdown.' OMa-1988 Part 10 para. 4.3.2.2(c).

Rev. D, Unit 2 Component ne licenace has not provided justi6 Goling Sptemj cation for deferring the quarterly flow test to verify that the valves stiche to the open position, although the Valve Program Tables indicate that the stroke open test is also deferred to Cold Shutdown.

A-4 FW4-1,2 [2FW-8-1,2) NF-39222. Rev. " Testing the valves quarterly is impractical since "These valves are tested to ne safety function of these valven is to Feedwater to steam AP, Unit I such testing requires a plant shutdcam." verify they close each close. During normal plant operation, Generator check valves Feedwater cold / refueling shutdown." the valves are normally fully open. It is System impractical to verify dosure of these CV-31098.31099 valves quarterfy.

[CV-31116,31117); [NF-29223, Rev.

Loops A & B Main AN, Unit 2 "Ihe alternative provides fu!I4troke 3 team Il e a d e r Feedwater exerdsing to the domed position during Isolation Valves System) cold shutdowns in accordance with OMa-1988 Part 10 para. 4.2.1.2(c) and RS-19-1,2 [RS 194,4l NF-39218. Rev. para. 4 3.2.2(c).

Steam GeneratorMain AX, Unit 1 Steam Outlet Stop Main, Auxiliary Check Valves Stearn & Steam Dump

[NF-39219, Rev.

AV, Unit 2 Main, Auxiliary Steam & Steam Dump]

14

4 Table 4.1 (Cont'd)

Item Valve IdentiDestion 11our Diagram Uwnsee's Justi6 cation for Deferring Valve Proposed Alternate Testing Evaluation of Uwnsee's Justi6 cation No. No. Exercising A-5 514-1,3 [2S14-1,3] X IIIAW-t-44, "It is impractical to stroke tha valves quarterly "With the reactor vessel it is impractical to partial- or full-

SI AccumulatorOutlet Rev. N, Unit I or at cold shutdown. Quarterly testing is head removed, these check stroke exercise these . valves open Occk to Gold Leg Safety injection prevented becauw (of) sptem design and cold valves are ful14troked. Each quarterty because the maximum operat.

System shutdown testing cannot be performed erupt valve is also veri 6cd to close ing pressure in the Acxumulators and 514-2 [2SI4-2) when the reactor vessel head is removed and the and back leaksge measured the shut-off head of the RIIR Sptem Check VaIye [X-IIIAW-1001- refueling poolis partially Doodedin preparation during refueling shutdown, pumps is less than the normal operat-Downstream of Occk 6. Rev. Q Unit for refueling.* and pl a n t atartup ing pressure in the Reactor Coolant 514-1[2514 1] 2 Safety operations? Svstem.

Injection 514-4 [2514 4] System] The licensee has not, however, provid-Check VaIye ed justi6 cation for not performing a Downstream of Oeck full 4troke open or at least a partial 514-3[2S14-3) stroke open test at cold shutdown, nor has the liamee justi6ed why verifying SI-9 3,4,5,6; the closure capability cannot be '

[251-9-3,4,5,6]; performed quarterly or during cnid O cck Valve From shutdown.

RIIR llent Exchanger to Reactor Vessel A4 51-9 1,2; SI-16-4,5 X IIIAW-1-44, *Ihe valves are not pressure isolation valves; "With the reador vessel it is impractical to part-stroke or full.

[2SI-9-1.2; 251-16-4,5) Rev. N, Unit I therefore, back leakage (testing) is not a Code head removed, these chedt stroke eserdse these valves open quer.

Cold leg Injection Safety Injection requirement It is imptactical to stroke valves valves are full stroked. Each te:Iy because the shut-off head of the Unes to Leops A & B System erwpt at refuehng shutdown when the reactor valve is also veri 6ed to close Safety Injection and RIIR pumps is

. Cold Leg Check head is removed." during refueling shutdown less than the normal operating pressure Valves [X-IllAW IO01- and plant s1artup of the Reactor Coolant System.

6. Rev. Q, Unit operations."

SI-16-7,6 [2SI-16-7,6] 2 Safety The liwnsee has not provided justi6-Reaetor Veesel Injection cation for not performing a full 4troke i Injection 1.ine to System) open or at least a partial stroke open Reactor Vessel Oeck test at cold shutdowns, nor has the Valves -

liannee provided juC6 cation for not verifying 'the cicsure capability quarterly, i

a 15 I

. _ _ _ m_..__ _ _ _ _ _ _ . _ . . - . _ _ _ . _ . _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ____ _ . . , .- - -. - - , - - -rw- - wm -w .c+w

Table 4.1 (Cont'd)

Item Valve Identification 11cw Diegram Umnsee's Justi5 cation for Deferring Valve Proposed Alternate Testing Evaluation of Ucemee : Justi5 cation '

No. No. Exerdsing A7 VC4-2 [2VC4-2); X-III AW-t-38, *Ihese valves are in piping which provides *The valves are tested in Itisimpracticat toexercise thene valves Check Va1ye Rev. P, Unit I charging flew to the reactor coolant system. accordana with the Oxle closed quarterly.

Downstream of Chemical & Interrupting flow to test the check valve would each cold shutdown."

Regenerative IlXs Volume Control require pladng excess Ictdown in service, "the alternative pre full 4troke System removing normal charging and implore (sic) a exerdsing during cold shutdowns in VC-171 [2VC-17-1] thermal cyde on the letdown system nozzles.* accordana with OMa-1988 Part 10 Bypass Oeck Valves [X-IIIAW-1001- para. 4.3.2.2(c).

Around Qarging Une 4, Rev. O, Unit CV-31328 [CV-31420) 2 Gemical &

Volume Control System]

A4 VC44,7; X-71.SW-1-38, "These valves are in piping which provides seal *Ihe valves are tert.ed in It is impractical to exerdse these valves

[2VC44,7); Rev. P, Unit 1 injection flow to the reactor coolant pumps and amordena with the Oxle closed quarterly. Furthermore, full-Occk Valves in Seal Chemical & it's impractical to verify the valves close on each refueling shutdown.*

injection lines to stroke exerdning the valves to verify Volume Control cessation of Gow sina such testing could result desure during cold shutdowns when Re a ctor Coolant System in seal failure. Possible foreign material entry Pumps the RCTs are running would require and excessive valve manipulations could damage stopping and restarting the ROs,

[X-IIIAW-1001- RO seats." thereby increasing wear and stress on 4, Rev. O, Unit pumps, number of cydes on plant 2 Gemical &

equipment, and extend the length of Volume Control cold shutdown outages.

System]

The licemee should, however, cxmsider testing these valves during cold shut-downs when the asnodated RCP is not running.

I 16 l

Tabk 4.1 (Cont'd)

Item Valve IdentiScation Ilcw Diagram Ucensee's Justification for Deferring Valve Propmed Alternate Testing &aluation of Ucensee's ksti5 cation No. No. Exerdsing Deferral Note B:

"Exerdsing these valves quarterly or at cold shutdown requires removal of safeguards equipment from service and excessive system or component manipulation to establish proper test conditions. His coupled with the ponsibility of errors in restorstinn of safeguards equipment or the ocrurrence oian event with abnormal sptem lineupe cmnd result in unsafe operation of the plant witich is not warranted for the type of testing to be amnmplished?

B-1 CV-31226,31255; X III AW-1-7, "These valves are in piping which provides let. " Valves mill be tested at cold it is impractical to full <troke exerdse

[CV-31230,31279] Rev. U, Unit I down flow to (sic) the reador crmlant sptem. shutdowns." the valves quarterly.

1 [2] RC Loop Reactor Coolant Interrup'ing flow to test these valves would Pressurizer Letdown System require pladng excess letdown in service, De alternative provides fullstroke une Isolation AOVs. removing normal charging and imposing a exerdsing during cold shutdmms in

[X-IIIAW-1001- thermal cyde on the letdown /diarging system accxndance with para. 4.2.1.2(c).

3, Rev. AB, Unit nozzles?

2 Reactor (botant System)

B-2 CV-31231,31232 X-It!A W -t-7, mese valves are stroked open and closed " Valves will be tested at cold it is impractical to fulI4troke exerdse

[CV-31233,31234) Rev. U, Unit I during cool down operation. Stroking these shutdowns? these valver quarterfy.

Pressurizer Outlet Reactor Coolant valves with the RCS at pressure eduses a Ims of AOVs to Pressurizer System one of the pressure boundaries cf the reactor De afternative providea full 4troke Relief Tank coolant system and during this stroking results in exerdsing during cold shutdowns in

[X-IIIAW 1001- a smallloss of RCiinventory? socordance with para. 4.2.1.2(c).

3. Rev. AD, Unit 2 Reactor Coolant System B-3 IIC-1-3,5 [21I01-3,5) NF-39251. Rev. " Valve cyding requires opening manual valves "These valves are stroked It is impractical to quarterly exerdee Instrument Air to I. Post LOCA required by Technical Sped 6 cation to be open and closed each cold valves IIC-13, 4, 3, 6 [2HC-13, 4, 5, Containment Supply Ilydrogem closed.* shutdown duringpost-IDCA 6) De alternative provides fulletroke Isolation Valves Control System - hydrogen control system exerdsing during cold shutdowns in Units 1 & 2 (* Dese valves are listed as EXCLUDED in valve cyding? accordance with para. 411.2(c).

IIG1-4,6 [211C 1-4,6] Revision 2 of the IST Program. Equivalent Unit Emergency Air to 2 valves SV 33992, 33993 are not listed in SV-33990,33991 [SV-33992,33993] are Containment ' Supply Appendix B Deferre' Notes. Ilewever, in an shown on the flow diagram as normally Isolation '/alves Odober 6,1993 letter to BNI the licensee open and vented to atmosphere. De provided a hand. written markup of the Revision licensee has not provided justi6 cation SV-33990J3991 2 Valve Program Tables which shows that the for not testing these valves cimed

[SV-33992.33993) valves are exerdsed at cold shutdowns and that quarterfy. De stated justi5 cation does Poet-L0CA the Unit 2 valves reference De.9 tral Note B.) not appear to be appropriate for these Cont alament 112 solenoid <perated valves.

Vent' 17

Table 4.1 (Cont'd)

F Item Valve IdentiScation Flow Diagram Ucensee's Justi5 cation for Defening Valve Proposed Alternate Testing Fvaluation of thee's Justi5 cation No. No. Exerdsing B-4 MV 32067 [MV- X-III AW-1-4 4, *Ihe valves prmide a pressure boundary "The valves are cyded at The NRC recognizes the risk of ex-32170), MV-32069 Rev. N, Unit I between RQ and SL Cyding the vanes with OD (Le, cold shutdowns).* erdsing premure leolation valves and

[MV-32172); Safety Injection RO at preneure cha!!enges Technical does not imme-d testing them R e a etor Veseei Sptem SpedGestion pressure Isolation valves.* while at power. He Prairie 1 stand injection MOVs Tedmical Sped 5 cations, howver, do

[X-IIIAW 1001- not identify these valves as pressure

6. Rev. O. Unit isolation valves. De tw chedt vatves 2 5efety downstream are the P!Vs. It does not Injeetion appear impractical to exerdse theme Sptem] normally dosed MOVs quarterly. The licensee should review the justi6 cation and revise, as appropriate.

B-3 MV-32202,32203 X-III AW-1-4 3, " Stroking these valves removes the miniDow "These valves are cyded at it is impractical to MI4troke exerde (MV-32204,32203] Rev. S, Unit I protection for the SI pumps, and therefore cold shutdowns.* these valves quarterfy. The alternative Safetyinjection Pumps Safety injection requires removal of both SI pumps from provides fulI<troke exerdsing du.ing Teet Line System service.*

cold shutdoums in accordana with Recirculation to para. 4.2.1.2(c).

RWSD [X-IIIAW-1001-7, Rev. R. Unit 2 Safety Injection Sptem]

B4 MV-32073 [32178), X-III AW-1-4 4, "The valves are the boundary between RIIR and "Ihese valves mill be cyded The valves are normally closed.

32076 [32179l, 32(T17 Rev. N, Unit 1 Containment Sump B. Cyding the valves at refueling shutdown." opening the valves during plant (32180], 32078 [32181] Safety injection contaminates the sump? operation would allow water from the Containment Sump B Sptem RIIR Sptem to beddlow into isolation MOVs Containment Sump B, thereby

[X IIIAW 1001- contaminating the sump. It is 6, Rev. O. Unit Imptactical to partwroke or Ml4troke 2 5afety exerdse these valves quarterfy or InjeetIon during cold shutdooms.

System]

The alternative provides full 4troke exerdsing during refueling outages in accxndance with OMa-1988 Part to para. 4.2.1.2(e).

18

- . . - . - - . . - - -.- ~ _ . - . . _ - - - _ - - - - _ _ _ _ - _ _ . - . _ - - - - - - - - - . - - - - - . - - -- au- - - - - -- -- - - - - - - r

Table 41 (Cont'd) ltem Valve Identificatien ~ 11cm Diagram Ucensee's Justi5 cation for Defening Valve Propo=ed Alternate Testing No. No. Exerdsing Evaluation of Ucemee's Justi6 cation B-7 MV-32098,32006 NF-39237. Rev. " Stroking these valves requires 'the une of The vahts are tested at It is impractical to fuhtroke exerdse

[MV-32108.32110} Y, Umts t A 2, electrical jumpers and closing breakers tequired refueling.

MV-32099,32097 Contalnment these vehes quarterly or at cold by Technical SpeciScations to be open. M V.

[M V-32109,32111] Internal Spray shutdooms. MV-32098,32W9,[32110, Containment sprmy Sptent 32@6 [MV-32108l and MV-32097 [MV-321W] 32111] are normally open providing Pumps Suction MOVs are interlotied with MV-32098 [MV-32110} and suction from the RWST while MV-MV-32009 (MV-321t ll to provide a continuous from R W5 T/ j 32 @ 6, 32W7 [32109, 32112] are suction for the G pumps. Testing these valves Cbrtainme,4 Sumps normally dosed providing suction from (which would require a Technical Sped 6 cation the Cbntainment Sumps.

change)is impractical except at refueling due to the need for excessive manipulation of safety. The alternative provides exerdsing at related equipment to perform the testing.*

refueling in sacrdance with para.

4.2.1.2(e).

B-8 MV-32162,32163 X-IllAW.1-43, " Stroking theme valves results in entering an " Valves will be tested at <vid

[MV 32190,32191] 5, As discussed in Section 4.0 of this Rev. Flow LCO as required by the Technical shutdown." TER, entering a LCO is ntA sullident St Pumps sudion Line Diagram Unit I speci6 cations. Safety function is to close to MOVs Safety Injection basis for not perfcfming the required isolate RWST during 51 redte mode. Other System tests.unless the testing rendern systems valves with similar funciens are locked dosed to inoperable for extended permos of prevent cyding during normal operation. See time. The licensee should evatuste

[X-IIIAW 1001- MV-32206, 2M [MV-32208, 209], below

• quarteriy testing within the Technical

7. Rev. R. Flow Diagram Unit 2 Sped 5 cation LCO of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or Safety injection further investigate the e ffects of testing, which may pivvide additional basis for System]

the deferral B-9 MV-322tM,32207 X-IIIAW-t 43, "The power supply to these vahes is required by "To comply with Technical

[MV-32208,32209] Rev. 5, Unit 1 Technical spedScation to be in the OFF As discussed in Section 10 of this 5pedfication valves will be TER, entering a LCO is not suflident RIIRIIcat Exchangers Safety Injection ponition. Cyding these valves requires turning cyded at cold shutdomn." basis for not performing the required to SI Pumps Suction System the power supply to the ON position?

MOVs tests,unless the testing renders systems inoperable for extended periods of

[X-lilAW 1001

7. Rev. R, Unit time. The licensee should evaluate quarterfy testing within the Technical 2 5afety InjeetIoa Sped 6 cation LCD of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or System] furtherimestigate the efTects of testing.

which may provide additional basis for the deferral.

19

Table 4.1 (Cont'd)

Item Valve IdentiScation Flow Diagram Utensee's Justi6 cation for Deferring Valve Propo=ed Alternate Testing Evaluation of Ucensee's Justi5 cation No. No. Exerdsing B-10 SV-37035,370% X 11I AW 1 7, " Stroking of these valves could cause a small loss

• Testing will be done at eoch it is impractical to part4troke or full.

[ S V-37091,37092) Rev. U, Unit 1 of coolant accident from the RCS..The refueling.* stroke ezerdse these valves quarterty or Pressurizer Vent Reactor Cbolant justi6 cation for testing at each refueling was during cold shutdowns.

Valves System included in NSPletter to the NRCdated July 6, 1981, and was agreed to by Lawrence Uvermore The alternative provides full 4troke SV-37037,370M [X-IIIAW-1001- National Laboratory Technical Evaluation exerdsing during refueling outages in

[SV-3 7093,37094 ) 3, Rev. AB, Unit Report (111R) Fetnuary 23, 1983. The TER nacrdance with OMa-19R8 Part 10 Reactor Vessel llend 2 Re actor was indoded as Enclosure 2 of the NRC SER para. 4.11.2(e).

Vent Valves Cholant System dated September 19, 1983.*

Sv.37039 [Sv 370941 Vent to PRT Valve SV-37040 [SV-37093]

Vent to Cbntainment Atnxwphere B-Il CV-31441,31444 X III AW.1-44, "Cyding these valves results in a loss in *Ihe valves will be full- It is impractical to part4troke or furt.

[CV-31511J1512) Rev. N. Unit I naumulator nitrogen inventory, or borated stroked in savedance with stroke exerdse these valves quarterty.

N2 SuppIy to Safety Injection water inventory." the Code at cold shutdown."

Acamulator AOVs Sptem The afternative provides fW14troke exerdsing during cold shutdowns in CV-31443,31446 [X-IIIAW 1001- accordance with OMa-1988 Part 10

[CV-313 55,31536) 6 Rev O. Unit para. 4.2.1.2(c).

Accumulators to RC 2 5afety Drain Tanks Isolation InjeetIon AOVs System]

20

T ble 4.1 (Cont'd)

Item Valve identincation Flow -Diegtum Ucenwe's Justi5 cation for Deferring valve Prcrosed Attemate Testing Evaluation ofIkensee's JustiGestion -

No. No. Exerdsing Deferral Note._C "The quarterly test of the RIIR pumpe redrculates the !!uld in the RIIR loop. He redrculation line returns to the suction line downstream of SI-7-1/51-7-2 (251-7-1/251-7-2)

Because there is no Dow path available other than this recirculation, there is no lots of inventory from this loop. This results in no Dow from the RWST and makes stroking SI 1/51-7-2 [251-7-1/251-7-2) impractical."

C1 51 7 1,2 [251-7 1,2] X-III AW-1 45, " Exercising these valves quarterly or at cold me valves will be exerdned Based on the burden of testing and the Check valves from Rev. S. Unit I shutdown requires transfer ofinventory from the each refueling shutdown." lack of a redrculation line back to the RWST to RIIR Pumps Safety injection RWST to waste or to the RCi and then to RWST,it is impractical to part4troke Suction System waste. The beneuts of this exerdse is deemed or full 4troke exercise these valves open not worth the effort." quarterly or during cold shutdowns.

[X-IIIAW-1001-7, Rev. R, Unit The alternative provides full 4troke 2 5afety exerdsing open during refueling Injection outages in sacrdan with OMa-1988 Systemj Part 10 para. 4.3.2.2(e).

The liwnsee has not provided justi6 cation for not verifying doeure capabinty quarterfy or during cdd shutdooms.

21

- +

Table 4.1 (Conn)

Item Valve IdentiGcation How Diagram Ucensee's Justi6 cation for Deferring Vale Proposed Alternate Testing Evaluation of Ucensee's Justi6 cation No. No. Exerdsing Deferrst Note D:

" Exercising these valves open at cold shutdown requires removal of safeguards equipment from service and excessive sptem or w,%,(nt manipulatkm in order to establish the proper tesi Mr ons. His coupla! with the possibility of errors in the restoration of safeguards equipment or the occurrence of an event with abnormal sptem line-ups could result in unsafe operation of the plant which is not warranted for the type of testing to be so:omplished. Sped 6cally;"

D-1 SI-101,2 [2514n-!J] X-It!AW-t 45, " Stroking these valves open at cold shutdown *These valves will tested in St Pumps Discharge it is not dear why these chedt valves Rev. S. Unit I requires opening valves which are dosed for accordance with the Onde at can not be at least partial-stmke tested Occk Valves Safety injection protection of the Reactor Onolant System refueling shutdown." quarterly or at cold shutdowns in Sptem against overpressurization. Testing valves doned conjunction with testing of the SI more than ona cach refueling cyde is pumps. Dese valv-s are upstream of

[X-IIIAW-1001- impractical."

the test line return to the RWST. He

7. Rev. R. Unit licensee should darify this matter.

2 Safety Injection Also, the licensee has not explained Sptem] why test procedures exmld not be devek> ped to prevent the posibility of errors in the restoration of safeguards equipment or the occurrena of an event arising from abnormal sptem l line.ups.

Deferral Note E:

"The following valve mill not be stroked on a quarterly basis for the following reasons;"

E-1 RII4-1[2RII4-1) X-IIIAW 1-31, %stallation of the valve is such that it cannot "The dose fundion of the It is not apparent why these valves are RIIR to Letdown Une Rev.1. Unit I be exerdsed open during nonnal plant valve is veri 6ed on a not exercised opa during t!e quarterly Bypass Occk Valves Residual IIcat operation. Isolation of the valve for exercising continuous basis by a high RITR pump test. De fiansee should Removal Sptem requires removal of the letdown line and one pressure alarm which sounds provide additional information why loop of the RIIR sptem from service." when back leakage occurs. they cannot be tested quarterly. Also, Dese valves will be tested in the Valve Program Table states that

[X-IIIAW-1001- accordance with the Code at the only safety function is to open.

8 Rev. L, Unit 2 Ocid Shutdown." He limnsee should revise the Valve Residual llent Program Tables if the valves are RemoyaI required to dose or be leak tight, as Sptem) the limnsee implies in the proposed alternate testing.

22

Table 4.I (Cont'd)

P Item Valve Identification Flow Diagram tjcensee's Justi6 cation for Deferring Valve Proposed Alternate Testing Evaluation ofIJcensee's Justi6 cation No. No. Exerdsing Deferral Note F:

"Ihe following valves will nc4 be tested on a quarterly basis for the following reasons:"

F-1 MV-32121.32120 N F 3924 3-1, "Exerdsing these valves during power operation "The valves will be stroked The liansee is implying that it is

[M V-32122,32129 Rev. D Unit I requires establishing an abnormal sptem lineup. each cold shutdown." impractical to part-stroke or full 4troke Cnmponent Cool;. 2 Co m po n e n t Should inadvertent isolation of the crms- exerdse these vatves quarterly because Water Supply llender 3 Cooling System cxmnected portions of the system occur (either ikw of Component Cooling Water to Isolation MOVs through operator error in est ablishing the lineup the Reactor Coolant pumps could be i [N F-39 2 4 6- 1, or from spurious signals from instrumentation in interrupted.

MV-32266,32267 Rev. D, Unit 2 the valve closure circuitry) comiderable damage

[MV-32268,32269) Component to the reactor coolant pumps and other reactor The li&nsee should esplain why test RCP CCW Inlet Cooling System) auxiliary eqQswat could result." prundures cxmid not be developed to Isolation MOVs prevent the inadvertent isolation of crms<onnected portions of the system through operator error in establishing the lineup or from spurious signals from instrumentation in the valve closure drcuitry or for any other reason.

F-2 CV-31330,31210 X IIIAW-1-38, "Cyding these excess letdown isolation valves "Ihe valves will be stroked It is impractical to part-stroke or full.

[CV-31422,31222] Rev. P Unit I introduces opets in the operation of charging, at O)1d Shutdown.' stroke exercise these valves quarterty.

I1 [21) Exceea Chemieal & seal injection and letdown systems. Possible Letdown II e a t Volume Control foreign material entry and system upets could The afternative prtwides full 4troked ExchangerInlet! Outlet System damage the RG seals.* excrdsing during cold shutdowns in IsusationAlt. Operated accordena with OMa-1988 Part to k alve. [X-IIIAW-1001- para. 4.2.1.2(c).

4. Rev. O, Unit 2 Gemical &

Volume Control System) i.

L _..

Table 4.1 (Coned) i Item Valve Identification Flow - Diagram Uwnsee's JustiBeation for Deferring' Valve No. Proposed Alternate Testing Evaluation of Ucenece's Justi6 cation No. Exerdsing Deferral Note 0:

%ese containment teolation valves are leak rate tested in accordana with 10 GR 50 Appendix J, and are dassi6ed TYPE A valvea. It is impractical to stroke these vahes quarterly for one or more of the following reasonc I

1.

Stroking the valves results in a loss of redundancy and requires logging equipment Out of Service and entering a limiting mndition of creration as required by the Technical Sped 6 cations.

2.

Requires plant manual operator action in response to design basis accidents. Administrative control over the guitioning of the valve is required and unnewssarify disrupt operations.

3. Oestes operational problems because of the conditions created by the stroking of a normal cren/or normal closed valve."

G-1 CV-31310,31311 NF-39602-1, %ese containment purge supply and exhaust "When they are used for Dese valves are normally closed. De I

{CV-31314.31315] Rev. AD, vahva are blind Danged out of service during containment integrity, the Inservice Purge valves are flanged off during normal ReactorBuilding operation.* valves are exerdned andleak plant operation by means of removal of Exhaust laolation Unit 1 tested prior to being plawd a piping section (spool piece). It Air Operated Valves Ventilation in service." appears from the referenced flow dingtams that even if the vehen were to CV-31633.31634 [NF-39602 2,

[CV-31635,31636] Rev. AF, be fbily cren during normal plant l

Inservia Purge Supply operation, the blank Danges would ReactorBuilding maintain containment integrity.

IsolationAir. Operated Unit 2 Valves

' Ventilation) Derefore, the valves do not arpear to perform a safety function during power operationc ne licerwee should evaluate if OMa-1988 Part 10, para.

4.2.1.7 applies. If so, jinsti6 cation la

- scrnrdance with para. 4.2.1.2 is not required. He use of para. 4.2.1.7 abould be dommented in the IST Pfogram.

i 24

Table 4.1 (Cont'd)

Item Valve Identification Flow Diagram Uwnsee's Justification for Deferring Valve Propmed Alternate Testing Evaluation ofIxemee's Justi6 cation No. No. Emerdsing 0-2 CV-31339 [CV-31430) X IIIAW-1-38, "Cyding these wntainment isolation valves

• stroke at Cold shutdown.* It is impractical to part4troke or full-Le t d own Line Rev. P, Unit I requires renwal of RC3 charging and letdown, strere exerdse these valves quarterly.

Containment Isolation Chemical & causes thermal cydes on system nozzles, and Airoperated Valves Volume Control introduas upsets in the operation of charging,  % s altenative provides fW14troke System seal injection and letdown systems

• cienssng during cold shutdooms in CV-31325,31325,31327 acumf anoe with OMa-1988 Part 10

[X-IllAW 1001- para. 4.2.1.2(c).

[ C V 313 4 7, 4 Rev. O, Unit 31348,31349] 2 Oiemical &

Istdown Une OriSu Volume Control IsolationAir-Operated System]

Valves 0-3 MV 32103,32103 NF-39237. Rev. *The C3 pump discharge MOVs are opened "These valves will be cyded It is impractical to parts troke or fbil-

[MV-32114,32116] Y, Units 1 & 2 only on 'P' signal, it! Containment Pressure. at Ontd Shutdown.* stroke exerdse these valves q=uterfy.

Containment Spray Co n t ain m e nt Here is no control switch to open/ dose this Pumps' Discharge Internal Spray MOV. Opening the discharge MOV using The alternative pnwides full 4troke MOVs System electrical jumpers with the suction valve open exerdsing during o,ld shutdowns in allows borated water to enter into the accordana with OMa-1988 Part 10 centainment spray header. At the condusion of para. 4.2.1.2(c).

such a test, the water needs to be drained to prevent formation of boric add crystals in the spray header. His operation requires the opening of a normally doned mntainment integrity valve. The use of electrical jumpers and exassive valve manipulation and resultant potential for errors make cyding the C3 pump discharge MOV on s quarterly basis impractical.

In addition, surveillana history shows these MOVs have never failed to operate after some 20 years of testing.*

23

Table 4.1 (Cont'd)

Item Valve Identification Flow Disgram Utensee's Justi6 cation for Deferring Valve Propo=ed Afternate Testing Evaluation of Danseek Justi5catiori No. No. Exerdsing 0-4 M V.32199.32166 X-IIIAW 1-38, "Cjding these seal water return containment "Ihese valves will be cyded It is impractical to part4troke or full-

{MV-32210,32194) Rev. P, Unit 1 isolation motor operated valves with RC5 each cold shutdown."

Re actor Coola nt stroke exerdse these valves quarterly.

Chemical & pressure causes the lifting of seal water return Pumps Seal Return Volume Control safety-relief valves.*

Inside/ Out:Ide The alternative provides full <troke System exerdsing during cold shutdowns in Containment CIVs accordanm with OMa.1988 Part 10

[X-IIIAW-1001- para. 4.2.1.2(c).

4, Rev. O, Unit 2 Gemical &

Volume Control Sptem]

O-5 RC-3-1 [2RC 3-1) X-III AW.1 7, "Cyding this two inch diameter. normally closed. "Ihe valves will be cyded Itisimpracticat toexerdse thoe valves Re a clor Makeup Rev. U, Unit I ched valve, located inside mntainment, closed each cold shutdown." dosed quarterly.

Water to Pressurizer Reactor Coolant requires adding RMU water to tie PRT, Relief Tank O eck System followed by venting and draining of piping and Valve The alternative provides exerdsing taking administrative control over during mid shutdowns in accordance

[X-IIIAW 1001 opening / dosing of centainment isolation valves."

with OMa-19tLB Part to para. 432.2(c).

3.Rev. AII. Unit 2 Reactor Coolant System 0-6 RC 5-1 [2RC-5-1] X.III AW. I .7, "Cyding this one inch diameter. normally dosed, "Ihe valves will be cyded It is impracticat to emerdse these valves Nitrogen Supply Une Rev. U, Unit I ched valve, located inside mntainment, dosed each mid shutdown.* closed quarterfy.

to Pressurizer Relief Reactor Coolant requires adding nitrogen to the PRT, followed Tank Occk Valve System by venting of piping and taking administrative *Ihe alternative provides eserdsing -

control over opening / dosing of mntainment during cold shutdowns in maxmlana

[X4 flaw-1001 isolation valves." with OMa-1988 Part 10 para.

3, Rev. AB, Unit 4.3.2.2(c).

2 Reactor Coolant System 26 l

f

Table 4.1 (Cont'd)

Item Valve Identification Flow ' Diagram Ucensee's Justi5 cation for Deferring Valve Propmed Alternate Testing Evaluation of Ucenseei Justi5 cation :

No. No. Exerdsing G7 VC-8-1 [2VC 8-1) X-IIIAW 1-38, *Cyding these valves interrupts charging and  % valves will be cyded lt is impracticat to erertime these valves Ontging Une Flow Rev. P, Unit I letdown Dow to/from the Reactor Golant each cold shutdown." quarterly.

Occk Valve Upstmem ChemicaI & Sptem, causing thermal gdes in piping of Regenerative IIent Volume Control nonles.*

Exchanger Sptem The alternative provides exerding during cold shutdowns in accordane with OMa-1988 Part 10 para. 4.2.1.2(c)

C%31198 [CV-31211] [X-IllAW-1001- and pare. 4.3.2.2(c).

Ostging line ' Air- 4 Rev. O, Unit Operated Valve 2 Gemical &

Upstream of VC4-1 Volume Control

[2VC.81] Sptem}

VG711 [2VG7-11] X-III AW-1-39, M a n u al Valve Rev. X. Unit 1 Downstream of C% Chemical &

31198 [CV-31211] Volume Control System

[X 1001-5, Rev.

T. Unit 2 Chemical &

Volume Control System]

O-8 VC14-1,2 [2VCl4- X-I!! AW-1-38, "Cyding these menual valves at power interrupts  % valves will be cyded at It is imptactical to exerdee these valves 1,2] Manual Valws for Rev. P Unit I seat injection to the operating reador coolant each cold shutdown." questetty.

Seal Water injemon Chemical & pumps.*

Filters to RCFs Volume Control The alternatin provides exerdsing System during cold shutocwns in acmrdane with OMa-1988 Part 10 para. 4.2.1.2(c).

[X-IIIAW-1001-4, Rev O, Unit 2 Gemical &

Volume Control Sptem]

27

Table 4.1 (Cent'd)

Item Valve Identification . Flow Ucensee's Justification for Deferring Vahe No. . Disgram Prop <wed Alternate Testing Evaluation of Ucensee's Justi6catkm No. Exerdsing Deferral Note II:

• Exercising these valves more frequently than refueling shutdown creates extensive operational prtMems. Sped 6cally:*

Il-1 CV-31740,31741 . NF-39244 Rev. "Cyding these valves willisolate aD instrument *Ihe vahts will be exerdsed It is imptactical to parteroke or M1-

[CV-3174 2,31743l AJ, Units 1 & 2 air in containment. This will cause all of the at refueling shutdoums.* stroke ererdse these valves qu arterly or Con t ain m e n t Instrument Air air. operated control valves to go to their failed during cold shutdowns.

Instrament air Piping position.'

IsolationAir. Operated Valves The altemative provides full 4troke exercising during refueling ou' ages in scoordance with oms-1988 Part 10 para. 4.2.1.2(e).

II-2 VC4-4,5 [2VC4-4,5) X-III AW-1-38, "Cyding these check vahres at power interrupts *Ihe valves will be cyfed These valves are in series with and Occk Valves in Seal Rev. P, Unit I seal injection to the reactor coolant pumps. each refueling shutdown.'

Injection IJnes to downstream of vahts VC 14-1/14-2 Chemical & Foreign material entry and valve manipulations ROs Volume Control [2VC 14-1/14-2). See Item No. G4 could cause RO seal damage following testing above and A4.

System . at cold shutdown."

The liwnsee should explain why these

[X-IIIAW-1001- valves cannot be exercised dosed at

4. Rev. O, Unit any cold shutdowns.

2 Gemical &

Volume Contret System]

1

. . - - . . ~ , . -- - . - . .-. . . _, _ _ _ _ _ _ _ _ _ _ - _ - _ - - - _ _ _ _ _ _ _ - - -

Table 4.1 (Cent'd) l Item Valve IdentiSation - Flow : Disgram Dansee's Justi5 cation for Deferring Valve Proposed Alternate Testing No. Evaluation of Uenace) Justi6catkm '

No. Enerdsing -

Deferral Note J:

"The following valves will not be stroked on a quarterly basis for the following reasons:"

J-l AF-131 [2AP 13-1] NF-39222. Rev. "This valve cannot be stroked open quarterly The liamee states that: It is Impractical to part4troke or M1-AFW Motor ' Driven AP, Unit I since this would result in thermal shodt to the "This valve will be full stroke esercise these valves open Pumps : 12 & 21 Feedwater Aux. Feedwater lines as they enter the Steam stroked each cold shutdown" quarterty.

Discharge Cross. System Generator. in addition, quarterly stroking and sho *Ihe valve is tested Cc mdk i Manual would require crus tying the Aux Feedwater dosed quarterly.* The afternative provides MI4troke Valves [NF-29223. Rev. Systems for both units." exerdsing during cold shutdowns in AN, Unit 2 Ilowever,the valve Program amordance with OMa-1988 Part 10 Feedwater Table indicates that the para. 4.2.1.2(c).

System] valves are exerdsed (both open and dosed) at Cold

' Shutdown. The hensee should clarif'y the two test directions.

J-2 MV-32023,32024 NF-39222. Rev. " Stroking these valves quarterfy is impracticle "These valves are MI It is impractical to part4troke er Ml-

[M V.32028,32029] AP - Unit 1 (sic). It would isolate all Feedwater Flow to an stroked eadicold shutdoum.* stroke cuerdse these valves quarterty.

Main Feedwater to Feedwater individual Steam Generator.* '

Steam Generators System The afternative -provides M14troke isolation MOVs esercising during cold shutdoums in

[NF-39223 Rev. accordance with OMa 1988 Part 10 AN, Unit 2 pera. 4.2.1.2(c).

Feedwater System) '

29

. .- . _ ,, _ _ _ . _ _ _ . _ _ _ . - . . _ . . . _ __m._ _ _ . .u _. . - - - . . _ . . . . . . _ - _ __ _ . . . . _ _ _ . _ - - .

Tame 41 (Cent'd)

Item Valve Identification Flow Diagram Ucensee's Justification for Defening Valve Preposed Alternate Testing Evaluation of Lacermee's Justi6catmo No. No. Exerdsing J-3 MV-32025,32027 N F-3 9 216 -2, *The purpose of these vehes is to provide a " Valves mill be stroked at  !-

It is impractical to part-stroke r

[MV-32026,32030] Rev. J, Unit 1 backup supply of makeup to the steam refueEng shutdown? stroke ererdse theae valvesqt ,e Auxiliary Feedwater Cooling Water generators. Normal supply is demineralized during cold shutdowns.

PumpsSuction Cboung nrbineBuilding water from the Condensate Storage Tanks Water Supply MOVs (Technical SpedScation lower volume limit of He alternative provides fWl4troke Category B [NF 39217-1, 100,000 gallons) with backup supply from the exerdsing during refueEng outages in Rev. II. Unit 2 river. aantdance with OMa-1988 Part 10 Gooling Water para. 411.2(e).

Turbine Dese valves receive no auto open signal Hey Building] are manually opened. Stroking the valves breaks one of the barriers between the demineralized water and the river water and increases the potential of river water to steam generator contamination."

Defenal Note K:

• Quarterly testing prohitsed by Plant Tedmical SpedScations. Rese valves will not be tested quartetty as they are intestal components of systems that are required to be nperable during unit operations."

K-1 CA-11-1 [2CA-11 1] NF-39252, :tev. "Ihis valve will not be tested quarterly as doing *These valves will be tested It appears that at least a partia!v Caustic Addition to I. Units 1 & 2 so requires isolating CA from both trains of CS, in somrdana with the Code exerdse could be performed in con-Containment Spray CausticAddition taking CS from service. Furthermore, testing at refueEng shutdown? juncien with the quarterly contain.

Pumps Oeck Valve System this valve at cold shutdown requires excessive ment sprey pump test, using the from Caustic Add valve manipulation,line evacuation, an external demineralized water !!ush connections Storage Tank source of pressurization and introduces the upstream of the valves. AdditionaDy, possibility of pump cavitation due to the the licenser fins not explained why the introduction of air into the system.* valves coald not be tested domed quarterly or during cold shutdowns sina there are test connections and isolation valves that would aDow leak testing. Helimnsee should review the justi6 cation, and revise. as appropriate.

30

4 Table 4.1 (Cont'd)

Item Valve Identification Flow . ' Diagram Ucensee's Justi6 cation for Deferring Valve No. Propowd Alternate Testing Evaluation of Liamee's Justi6 cation No. Exerdsing K-2 CC-14-5,6; CC 18-1,2 N F 39245 1, "Ihese valves and tMir assodsted piping supply "These valves are tested in It is impractical to exerdse these valves

[2CC-14-5,6; 2CC-18 Rev. D Unit 1 CC to the RCPs. The continuous Dow is an accordana with the Code at domed quarterly.

1,2) Component indication that she valves stroke open. The cold shutdown.*

Reactor Coolant CooEng System cessation of Dow required to close the valves Pump Bearing The alternative provides full <trtte would require dedaring the RQ"s outef- exerdsing during cold shutdowns in Coeling Water [N F.39246 1, service."

Supply / Return Oeck Rev. D, Unit 2 acoordance with OMa-1988 Part to Valws para. 4.3.2.2(c).

Co m po n e a t CoolingSystem]

CC41-1,2 [2CC 61-1.2) The licensee should revise the Valve Reactor Coolant Program Table to indicate that the Pumps Emergency valves are tested open quarterfy, as Bearing CooEngWater implied in the justi6 cation.

Supply Occi Valves K-3 RII-3-1,2 [2 Rib 3-1,2) X-I!!AW 1-31, "Ihese valves and their anodated piping provide *These valves will be tested it is imptactical toeserdse these valves RllR Pump Suction Rev.1, Unit I suction to the RIIR (pumps). As the RC51oop in acuerdana with the Code doned quarterfy or during cold from RCS Oeck Residual IIcat must remain dosed above C5D, these check at refueEng shutdown." shutdooms. During cold shutdown, the Valves Removal 5ystem valves cannot be stroked during power vales are open to allcw operation of operations. At OD, the cessation of Dow the RilR pumpe. To test either vale required to stroke these valves doeed would 2 dosed would require removing both

[X-IllAW 1001- require removing RHR from servia."

RIIR punpa from servia. Durbg 8, Rev. I, Unit 2 '

power operation, there are no Residual llent RemoyaI instruments or test connections that could be used to verify the dosed sy==] paition of these dect vales.

The alternative provides fWi<troke esercising domed during refueEng outages in socordena with OMa-1988 Part 10 para. 4.3.2.2(e).

"the Valve Program Table identi6es i only the dosed position as the safety function, the liawee should wrify that the valves do not serve a safety hcJuo in the open position.

31 3

b__ _ _ _ _ _ i_ __ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ __. _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ . . _ _ . . 4

, , - - - ~ ~ . . . - - , - ,- -

Table 4.1 (Cont'd)

Item VaM Identification Flow Diagram Ucensee) Justi5 cation for Deferring Valve Propcned Alternate Testing Evaluation of Uwnsee) Justi5 cation No. No. Exerdsing K-4 RS 13-1,2 [ MS.15-1.2] NF-39218 Rev. These valves *Will not be tested quarterly as "Ihese valves will be tested It appears thahhese valves will be full-Main Steam Supg4y AX, Unit I doing so would require a unit shutdrwn.* in accordana with the Code stroke exercised during the turbine From 5 team Main. Auxinary at cold shutdown." driven Auxiliery Feedwater pump Generators toTurbine Steam & Steam quarterfy test and that testing quarterly Driven Auxiliary Dump is, therefore, predical.

Feedwater Pump Oeck Valves [NF-39219 Rev. Aaxnding to the flow disgrams, there AV, Unit 2 are no test amnections between these Main, Auxiliary chedt valves and the normally open Steam & Steam MOVs MV-32016 and 32017 [MV-Dump) 32019 and 32020] upstream, so that it does nd appear that the va!ves could be tested ckned during operation. The licensee should, however, provide addi-tional information in the justi6 cation for both the open and doned direction.

K-5 SM-10wl [2SM-10-1] NF-39238, Rev. "Ihis vah is tied directly to the Reactor "This valve will be tested in it is ad apparent utsy excessve valve Sample Return Une X, Units 1 & 2 Coolant PumpSeal Water Return Une and the accordance with the Omfe at manipulations are required to test this Check Valve to SamplingSystem volume Control Tank (VCT). Testing of this Refueling Shutdown.* valve during cold shutdown. The Volume CbntrolTank. Reador Plant valve cannot be done quarterly because it liwnace should explain in grester detail requires removal of the seal water return line, what valve manipulations are irrvolved, and excessive valve manipulation makes it and why testing is impractical.

Impractical to test this valve at cold shutdown.*

32

Table 4.1 (Cont'd) ltem Valve Identificatica Mow Diagram Uwnsee's Justi5 cation for Defening Valve Propmed Alternate Testing Evaluation of Ucensee% Justi5 cation No. . No. Exerdsing K4 VC4-10 [2VC4-10] X-IllAW t 39,

• Testing these valves requires the removal of the *These valves will be tested The finnsee has not explained what Check Va1ye Rev. X Unit I boric add / reactor makeup water blender from in acxmrdance with the Ode required valve manipulations and Downstream of Chemical & service. Excessive valve manipulations and st refueling shutdoom." sptem alignments make fulletroke Volume Control Tank Volume Control sptem alignments are needed to conduct the exerdsing the valves closed at cold imel Control Valve 1- System test. The benefits of the exerdse are not shutdown impractical. The licensee LCV-112A [2-ILV- deemed worth the effort.* abould provide the information as 112A] [X-1001-3, Rev. described in Section 4.0 of this report T, Unit 2 regarding impracticality.

VC4-11 [2VC4-11] Chemical &

Boric Add Blender Vohrme Gntrol Suction Sptem]

Occk Va.Ne VC4-14 [2VC4-14]

Reactor Makeup Water to Oarging Pumps Suction Une Occk Valve K-7 VC4-3 [2VC4-3] 11 X-Ill AW-1 38, "This valve is the boundary valve between *This valve will be tested in itisimpracticat toeurdne these valves

[21) Regenerative IIcat Rev. P, Unit I auxiliary spray and the RCS pressurizer. It is acrordance with the Goe at dosed quarterly.

Exchanger Auxiliary Chemical & located in containment, Fun stroke testing the cold shutdoom."

Spray LIne to Volume Cbutral valve quarterly is not practical, and will produce The alternative provides lhl14troke Pressurizer Check System thermal cydes on the pressurizer spray nozzle.* exerdsing during cold shutdoums in Valve Dowmtream of aantdance with OMa-1988 Part 10 CV-31329 [CV 31421) [X-IIIAW-1001- para 4.3.2.2(c).

4 Rev. O. Unit 2 Gemical &

Volume Gntrol System]

33

l Teble 4.1 (Cent'd) l Item Valve IdentiDestion - Flow Diagram Ucensee's Justi6c.ation for Deferring Valve No. Pytyped Alternate Testing Evaluation of Unmee's Justi6 cation No. Exercising K -

V C 13-1 [2VG13-1] X-IIIAW 1-39, "Ihese valves will not be tested quarterly. The *Ihe valve will be tested at These va!ves are in lines which are BA Volume Control Tank Rev. X, Unit 1 valve /sptem manipulations required toinstall an refueling shutdown.* directly connected to the gas space of (VCI) Inlet O cck Chemical & external pressure sourm and pressure indication Valve Volume Control the Unit 1 & Unit 2 VCTs. The lines make quarterly testing impractical. The test System are the common header for the medium for VCl3-1 [2VC-13-lj is hydrogen flydrogen Supply Manifold and the and xenon from the VCT. Depressurizing the Nitrogen Supply Manifold. De

[X 1001-3, Rev. piping downstream of VC13-1 [2Vol3-1] Ilydrogen Supply Manifold appears to T. Unit 2 introduces industrial safety hazards not be normally supplying hydrogen to the Chemical & warranted for the testing to be acxxxnplished."

Volume Control VCT while the Nitrogen Supply Manifold is normally valved off.

Systemj The subject valves are the Grit valves in the lines upstream of the VCT. He licensee should clarify whether the subject valves are normally open or whether the valves are veri 6ed dosed at any time during plant operation.

The safety function of the valves la to actuate to the closed position.

K4B VC13-2 [2VC13-2) X-III AW-1-39, *Ihese valves will not be tested quarterly. The *Ihis valve will be tested in It is impractical to eserdse these valves Gemical Mixing Tank Rev. X, Unit 1 valve / system manipulations required toinstall en aaordance with the Code at closed quarterly.

Outlet une G eck Chemical & external pressure source and pressure indication cnid shutdcwn."

Valve to Gargmg Volume Qatrol make quarterly testing impractical The test The alternative provides ful1<troke Pumps 5uctionlicader System medium for VC-13 2 [2Vol3-2) is charging exerdsing during cold almtdowns in pump suction Duid. Depressurizing the piping accordance with OMa-1988 Part 10

[X-1001-3, Rev. domistream of VC13-2 [2VG13-2) requires para. 4.3.2.2(c).

T, Unit 2 opening two normally domed valves, installing a Chemical A pressure gauge and venting the normally dosed Volume Control Gemien1 Mixing Tank. This complex test is not System] warranted and is considered impractical.*

Table 4.1 (Cent'd)

Item Valve Identification flow Diagram Ucensee's Justification for Deferring Valve t No.

Propmed Alternate Testing Evaluation of Ucemee's Justi5 cation j No. Exerdsing t

Deferral Note I; t t

"Ihese valves will not be tested quarterly as the system manipulations required outweigh the value ofinformstion obtained through testing? {

I1 CC-23-1 [2CC 23-1] NF-39245-1 *Ihese valves will not be tested quarterly. "This valve will be tested in it is impracticat toexerdse these valves Exmss Letdown IIcet Rev. D, Unit 1 Doing so would require excessive valve amordance with the Cbde at dosed quarterly.

Erdianger 11 [21] Co m pon e n t manipulation to install an externsi pressure cold shutdown udng non.

Inlet une Occk Valve CooEng System sourx, isolate the excess letdown heat intrusiwe dIagnoetIc Category C 11 o attemative provides ful14troke exchanger, and drain the heat exchanger and methods." ex rdsing during cold shutdowns in <

[N F-392 4 6-1, assodated piping. Valve stroke indication would ,

acxxmlance with OMa-1988 Part to i Rev. D Unit 2 then require the addition of pressure para. 4.3.2.2(c).

Component instrumentstion. This work would be done in CooEng System] containment at power. Because this heat exchanger and assedated pipingis outef-service during normal unit operations and because there is a motor valve presiding redundant reverse Dow protection, this valve will be tested in acxxirdana with the Cbde at cold shutdown using non-intrusive diagnmtic methods.*

I2 C5-16,17 [G-47,46] NF-39237, Rev. *These valves will not be full 4troke tested *These valves are past. It is impractical to ful!4troke exercise Containment Spray Y, Units 1 & 2 quarterly or at cold shutdown. Stroking the stroked open quarterly Pumps Suction Gedt these valves open quarterly or during

_ Con t aiament valve open/ dosed requires opening the C5 pump during the running of the O cold shutdowns.

Valves Intemal Spray disdiarge motor valve and the addition of pump surveillance test and System borated water into the G piping, taking the Q will be full stroked in The alternative provides pert-stroke pump breaker out-of-service, draining c piping acxxyrdance with the Code on exerdsing during plant operation and and opening and dosing motoreperated valves a refueling basis.* fullstroke exerdsing during refueling using electrical jumpers. Also, testing these outages in amordanm with OMa-1983 valves requires opening manual containment Part to para. 4.3.2.2(e).

isolation valves Stroking more frequently is not warranted given the comples nature of the flowever, there are 2-inch Dush testing.*

connections immediately upstream and downstream of each check vahe.- The liarece should darify why these connections could not be used to verify the va!ves' dosure capability quarterly.

35

Table 4.1 (Cont'd)

Item Valve Identl5 cation l Flow - Diagram Ucensee's Justi6 cation for Deferring Valve Proposed Altemate Testing Evaluation of Uwnsee's Justi6catkm -

No. No. Exerdsing 1

1-3 CS-18,19 (CS-48,49] NF-39237, Rev. *These vahts will not be full 4troke tested "These valves mill be tested It is impractical to fulI4troke exerdee Containment Spray Y Units 1 & 2 quarterly or at cold shutdoom. Stroking the at refueling shutdown? '

these valves open quarterly or during Pump Discharge Cont ainme nt valve open/ dosed requires opening the O pump cold shutdoums.  :

Check Valves Internal Spray discharge motor valve and the addition of

• System borsted water into the C5 piping, taking the O De alternative prmides full 4troke  ;

pump breaker out-of-servia, draining CS piping exerdsing during refueling outsges in s and opening and dosing motor operated valves amordance with OMa-1988 Part 10 using electrical jumpers. Also, testing these para. 4.2.1.2(e) and para. 43.2.2(e). 4 valves requires opening manual containment j isolation valves? De liansee should explain why the  !

valves

• closure capability could not be veri 5ed quarterly as there are locked !

open manual valves, C5-9,10 [C5-39, j 40), immediately donmstream of these check valves, which could be dosed, j and a test connection is available '

between the manual valves and the chedt valves.

14 IIG2-1,2 [211G2-1.2] NF 39231, Rev. "These valves will not be tested quarterly. Hey "The valves will be tested in it is impractical to part stroke or full.

Instrument Air Supply L. Post LOCA are stroked open and dosed each cold / refueling accordance with the Code stroke emerdse these valves quarterly.

and Emergency Air 11ydrogen shutdown during POST-LOCA Ilydrogen for stroke at cold shutdoum

'I u p p I y to Controlsystem. Control System valve cyding and 10 CFR 50 and leak tightness at De alternative provides fbil4troke Containment Check Units 1 & 2 Appendin J Ieak testing. Quarterly testing refueEng shutdoom." exerdsing open and domed during cold V Ives would require entering containment at pouver, shutdoums in accordance with OMa-providing an external pressure sourm and 1988 Part 10 para. 43.2.2(c).

ackfitional pressure indication. He benefit of additional testing is not signi6 cant to warrant the extensive test procedure as these valves are not in service under normal unit operation minimizing the probability of degradation over time betaren refueling. A motor valve provides redundant reverse Dow protection to each chedt valve?

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Toble 4.1 (Cent'd)

Item Vahe Identification Flow Disgram Uansee's JustiScation for Deferring Valve No. Propmed Attemate Testing Evaluation of bcenace's Justi5 cation No. Exercising te$ RII-3-3,4 [2RIIJ-3,4) X IIIAW 1-31, " Testing to prtwide closure would require "Ihese valves are partially It is ia rpractical to fulI4troke exerdee R 11 R Pumpa Rev.1. Unit 1 entering an LCO by removing a train of RIIR stroked open quarterfy" and Discharge Check tW valves open quarterly due to the Residual liest from service, amnecting an external pressure ful14troke exerded open at Valves limited Dow capadty of the RIIR Rernoval 5ystem seura downstream of the valve, insta!!ing onid shutdown. pumps test redrculation line.

additional pressure indication, and entering into a confined space area. He amount of ne attemative provides part4tmke

{X-111AW-1001- additional information obtained by adding the exercising during plant operation and

8. Rev.1, Unit 2 dosure test to a preadure that already tests the full 4troke exerdsing during cold Residual liest open stroke does notjustify the extensive system RemoyaI shutdowns in accordana with OMa-manipulation required."

1988 Part 10 para. 4.3.2.2(b).

System]

1A CV-31381,31411 NF-39216 3, 'Ihese valves control the temperature of the CC

{ CV-31383,31384 } Rev. E. Unit 1 It is assumed based on the ne lia nnee should darify the system. De valves fail safe open on loss of air. justi6 cation that the valves frequency at stich the valves are full-(bmponent Cooling (boling Water . He vahes are cyded full open on a monthly are tyded full open from the Water 11 e a t A u 211i a r y stroke exerdwd and fai14afe tested i period to flush the cooling water side of the CC throttled postion on a Exdiangers Cooling and timed. A relief request is required Building heat exchangers Failing the valve from the monthly basis and fail 4afe Water Return AOVs if the frequency is not at cold close to open subjects the RC2' thermal barrier tested and stroke time tested shutdowns or refueling outages.

[NF-3 9217-2, to thermal cyde. nerefore, this test requires ewry three years.

Rev. D, Unit 2 tating the CC heat exchanger out of service and Cooling Water - entering an LCO. He valves are in the IAC The Valve Program Table, AuxiiIary Program and are serviad,inspeded, tested and however,indicatesexerdsing Duilding] overhauled on a three year period. Failing the at cold shutdowns.

vahe open on a quarterly period is not prudent use of resouras given the extensive testing and maintenance being performed on these valves and given their maintenance and operating history."

37

. _ _ _ _ _ _ _ __. _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . . . . _ . _ . _ _ _ _ ________._______..___________z-_ _ _ _ _ _ __ __ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _

5.0 IST PROGRAM RECOMMENDED ACTION ITEMS ASME Section XI inconsistencies, omissions, and required licensee actions identified during the review of the licensee's inservice Testing Program, Revision 2 of the third interval, are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report, and revise and resubmit the program, as appropriate.

5.1 The IST Program does not include a description of how components were selected or how testing requirements were identified for each component. The Tables contained in the IST Program only identify the Code required position indication verification (OM Part 10, 4.1) for passive valves and do not identify the fail-safe test (14.2.1.6). The Tables identify the function of the valves (i.e., open, closed, or both), test type (e.g., E for exercise), and test frequency. It is assumed that the test and frequency indicated in the ,

Table apply to all the valve functions, since generally there are not separate entries in the Table for each direction. However, when testing is deferred, the justifications do not always address the impracticality of exercising in both directions. The licensee should review the program and ensure that the test frequency is appropriate for both directions, and revise the justifications and Tables, as appropriate, to discuss both directions. Additionally, the licensee has stated that the program addresses Class 1,2, and 3 components. The licensee should describe what basis was used for classifying j components. The Prairie Island FSAR Section 12.2 describes component's safety classifications. A number of safety-related components are not included in the IST Program, such as the diesel fuel oil and air start systems. If safety systems are not classified as ASME Class 1,2, or 3, and are not included in the IST Program, the licensee i should ensure that they are tested commensurate with their importance to safety, as  ;

required by 10CFR50 Appendix A. '

The review performed for this TER did not include verification that all pumps and valves within the 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 information on the development of the program in the i IST Program. The program should describe the development process, such as a listing of  :

the documents used, the method of 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.

5.2 The IST Program's scope was reviewed for selected systems. The pumps and valves in the Auxiliary Feedwater Systems of both Units 1&2, and the Main Steam and Component Cooling Water System of Unit 1 were reviewed against OMa-1988, Part 10 requirements. The FSAR was used to determine if the specified valve categories and valve functions were consistent with the plants' safety analyses. The review results showed compliance with the Code, except for the following items. The licensee should review these items and make changes to the IST Program, where appropriate.

Additionally, the licensee should verify that there are not similar problems with the IST Program for other systems.

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38 I i

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5.2.1 No local verification of remote position indication is specified in the Tables for vatves other than passive valves. Power-operated valves generally have remote position indication (The flow diagrams supplied by the licensee do not indicate whether the valves have remote position indication). OMa-1988 Part 10 Paragraph 4.1 requires this to be performad every two years. The licensee should specify all the Code requirements in the IST Program.

5.2.2 AFW check valves CF-11-1, 2 for Unit #1 and 2CF-11-1, 2 for Unit #2 are specified as excluded from testing because they are used only for maintenance purposes. Review of the respective P&lD for these valves shows them providing a class boundary / isolation function. The licensee should verify that these check valves do not serve a safety-related function when chemicals are fed to the AFW system. .

5.2.3 Based on a review of the AFW P&lDs, it appears that valves AF-14-1,3 in Unit #1 and AF-14-5, 7 in Unit #2 provide protection against the potential loss of inventory (suction) to the auxiliary feedwater pumps, if these valves are not closed, cooling water supply could be diverted to the CST, instead of to the AFW pump suction. Additionally, Deferral Note A provides a justification for not verifying valve closure quarterly. The Tables contained in the licensees' submittal specifies that functionally, these valves are only required to actuate open. The licensee should verify the safety function of these valves and revise the Deferral note or program tables accordingly.

5.2.4 CCW check valves CC-29-1,2 for Unit #1 are tested to actuate open only, yet review of the respective PalD for these valves shows them providing a class boundary / isolation function and providing backflow protection. The licensee should verify that these valves do not require testing for both open and close functions.

5.2.5 All relief valves in the Unit #1 CCW system are excluded. A review of the respective ,

P&lDs indicates that these valves provide a surge and overpressure protection function. j The scope of the 1989 Edition of Section XI (OM Part 10 as defined in OM Part 1) l includes valves which provide overpressure protection for Code Class safety-related i systems. This includes pressure relief valves which may not typically perform a l

• safety related* function. The licensee should verify if the requirements of OM Part 1 apply to the relief valves in this system. Additionally, Note 3 in the IST Program, which i pertains to these valves, should be clarified. '

i 5.2.6 in the licensee's IST Program Tables for the Unit 1 Main Steam system, MV32016 and MV32017 are designated as passive valves, normally open. Review of the P&lD for this system appears to indicate the purpose of these valves is to provide isolation capability in the event of a piping break in line downstream of the check valves (RS-15-1 and 2),

which would allow simultaneous blowdown of both steam generators, since both steam l supply lines to the turbine driven AFW pumps come off of the main steam lines upstream of CV31098 and CV31099. Based on the above, the licensee should verify the functional i requirements of these valves.

5.2.7 CCW valves CV31432 and MV32088, which provide overflow and makeup capability to the Component Cooling Surge Tank, were not included in the licensees' submittal. The 39

licensee should verify that these valves do not provide a safety function and are not required to have their position indication verified, as required under OMa 1988 Part 10, Paragraph 4.1.

5.2.8 Additionally, CC-65-1, a 1' vacuum breaker, was not included. Vacuum breakers are,  ;

by the definition of " overpressure," required to be tested in accordance with OM Part1 to verify the open and close capability, set pressure, and performance of any pressure or position sensing accessories; and, if the valves are simple check vafves, full-stroke '

exercised in accordance with OM Partto 14.3.2. The licenses should ensure compliance with OM Parts 1 and 10.

5.2.9 Additionally, in the course of this review, the following documentation discrepancies were observed:

AFW Svstem 1

1.) For Unit #1, the position shown on flow diagram NF-39222 is not consistent with the normal position indicated on the tables contained in the IST program for AF32-1. AF32-2, '

AF18-13, AF18-14, AF18-15, AF18-4, CV31153, and CV31154.

2.) For Unit #2, the position shown on flow diagram NF-39223 is not consistent with the  !

normal posi6on indicated on the tables contained in the IST program for 2AF-18-13, and 2AF- l 18-14.

3.) in the tables contained in the IST program, the description for valve AF-26-9 states *22 AFWP," where it should read "21 AFWP'.

CCW System 1.) For Unit #1, the position shown on flow diagram NF-39245-1 is not consistent with the normal position indicated on the tables contained in the IST program for CC-1-15, CC-30-11, 12,19, CC-33-22, 47, 48, 49, 54, 55, 61, 64, and CC-68-1, 2, 3, 4. 5, 6, 7, 8..

2.) For Unit #1 on flow diagram NF-39245-1, CC-14-5 and CC-33 38 are not labeled. Valve CC-33-23 in the tables contained in the IST program is labeled as CC-33-21 and shown as closed on the flow diagram. Additionally, CC-33-26 is not drawn on the flow diagram.

3.) For Unit #1, the tables contained in the IST program for CC-81,2, CC-9-1,2, MV32115, and MV32117, the P&lD specified should be NF-39245-2. Additionally, for CC-8-1 and CC 2 under the valve function column it states 'see note 13', it should read 'see note 12'. There is j no note 13.

4.) For Unit #1, the fo!!owing manual valves do not appear in the tables contained in the IST l

program but are in the system; CC-16-2, CC-10-3, CC-21-4, CC-31-5, CC-34-42,43. It  !

is felt they should be listed for consistency, even though they may be excluded.

MS System 1.) For Unit #1, the position shown on flow diagram NF 39218 is not consistent with the normal position indicated on the tables contained in the IST program for MV32047.

40

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l 5.3 in evaluating the licensee's technical basis for Relief Request No.1, the Safety Evaluation, dated January 31,1984, for the second interval inservice Testing Program was factored into the review, with the licensee's Surveillance Procedures on pump vibration measurements. It was found that the same pump relief request was granted for ,

I the second IST interval, except that the request for the second interval also requested l relief from the Code specified required action limits. Omitting this criteria from the current relief request may be an oversight on the part of the licensee because it does create the potential anomaly stated in the PR-1 evaluation. The licensee should determine if this is the case.

Relief to use the alternate vibration alert ranges were recommended for an interim .

I period. In the interim, the licensee should perform a comprehensive evaluation of why it is acceptable to run these pumps at such high vibration levels. This evaluation should include discussions with the specific pump vendors and contain conclusions based on ,

spectral analysis and pump vibration histories. Based on the potential for pump ,

degradation, the licensee should evaluate ways of reducing vibration levels to industry recommended limits. The licensee's evaluation should be available for NRC inspection at the plant and the licensee should revise the relief request to include the conclusions of this evaluation. ,

5.4 in evaluating the licensee's technical basis for Relief Request No. 2, interim relief was recommended for the component cooling water pumps. In the interim, the licensee should comply with the Code instrument accuracy requirements or provide additional t information for long term relief that would justify an unusual hardship and demonstrate  ;

l that the reduced acceptance criteria gives adequate information for monitoring degradation and taking corrective action. The licensee should note that the additional 1%

of full scale inaccuracy may result in a reading inaccuracy of 3% (i.e.,1% X 3 X reference value, per 4.6.1.2(a)). One option for long term relief would be to reduce l the acceptance criteria by 3% (i.e., the required action limits would be <0.93 Or and '

l >1.07 Or for these centrifugal pumps), which would provide an equivalent level of

l. quality and safety to the Code. Additionally, the licensee states in the justification that an acceptance curve will be used. Specific relief from the requirements of OMa-1988 Part

, 6, Paragraph 5.2b has not been requested. Relief is required to utilize pump curves, as l

the Code does not current'y allow their use. The licensee should prepare a relief l request.

In a letter dated September 24,1993 from the licensee, it was stated that the approximate operating range for these pumps is 500 to 3750 gpm OMa-1988 Part 6 q Paragraph 4.6.1.2(a) states that the full scale instrument range shall not be greater than three times the reference value. The licensee should note that this requirement applies even for variable reference values. The licensee should ensure that Code l l

instrument range and accuracy are met for all points used on the reference curve.

5.5 in evaluating the licensee's technical basis for Relief Request No. 4, only the location and .

measurement capability aspects of the Code requirements were considered. The licensee i should evaluate if the alternate measurement locations for the diesel and motor driven  :

l 41 l

cooling water pumps are impacting the vibration level readings for these pumps, as discussed in Relief Request No.1.

5.6 It is recommended that relief be granted to use reference curves for the DDCW and MDCW pumps pursuant to 10CFR50.55a(f)(6)(i) (Relief Request No. 5). The licensee has not, however, provided an adequate basis for using less restrictive acceptance criteria than that contained in Table 3b. Therefore, pending further clarification, the licensee must implement the Code acceptance criteria. Additionally, when preparing pump curves, the licenses should ensure that if vibration levels vary significantly over the range of the pump conditions, a method for assigning appropriate vibration acceptance criteria should be developed for regions of the pump curve.

Additionally, in the licensee's letter dated September 24,1993, it was stated that for the diesel and motor driven cooling water pumps 'there are unmetered flow paths coming off the pump d:scharge before the flow indicator of approximately 500 gpm'. The licensee should evaluate isolating the automatic backwashing during the short period of time required to perform the test and making an appropriate modification of the governing surveillance procedure. This will minimize the instrument reading fluctuations and facilitate compliance with OMa-1988 Part 6, Table 3b requirements.

The Code requires total flow through the pump to be measured. If full Code compliance is burdensome or impractical, the licensee should submit a request that would technically justify granting relief in accordance with 10CFR50.55a(a)(3)(ii) or 10CFR50.55a(f)(6)(i), respectively, 5.7 11is recommended that testing the containment spray pumps with an uninstrumented flow path be authorized for an interim period until the necessary instrumentation is installed or through the next refueling outage, whichever is later. The licensee should ensure that when the containment spray pumps, referred to in Relief Request No.10, are being tested in a low flow condition, the flow is sufficient to prevent damage to the pumps (see NRC Bulletin 88-04, dated May 5,1988). The licensee has requested relief from the Code vibration alert ranges due to normally high vibration during minimum flow operation.

5.8 in the Valve Program Table, P&lD NF-39216 [NF-39217] is listed for numerous valves in the Cooling Water System. Some valves are referenced to P&lDs NF-39216-1, -2, -3, and -4 [NF 39217-1, -2, and -3). Other PalDS such as NF-39222 [NF-39223) have connections cross-referenced to NF-39216 [NF-39217). However, the licensee has stated verbally that P&lD NF-39216 [NF-39217] no longer exists and has been replaced by the corresponding P&lDs with the suffices (e.g., NF-39216-3). The licensee should revise both the Valve Program Table and any appropriate P&lDs to reference the proper P&lD numbers. Additionally, adding drawing coordinates to the IST Program would. assist both the licensee and NRC reviewers.

5.9 The IST Program pump tables indicates that the flowrate of the safety injection and auxiliary feedwater pumps is not being measured quarterly. There is no explanation or relief requests provided. The licensee should measure flowrate quarterly in accordance with the Code or provide a relief request.

42

5.10 Anomalies relating to the deferred testing justifications:

General in general, the licensee should provide more information in the justifications. Additionally, for the majority of the deferral justifications, the licensee does not clearly state whether full-stroke exercisino will be conducted at cold shutdowns or refueling outages. For example, in the justification for valve VC-8-2, the check valve downstream of regenerative heat exchanger 11 (Item No. A-7 in TER Table 4-1), the licenses states that 'The valves are tested in accordance with the Code each cold shutdown.' The licensee has not clearly stated whether the cold shutdown testing involves full-stroke exercising or part-stroke exercising.

The use of the word " tested', ' cycled', ' stroked', or ' exercised" does not clearly state ,

compliance with the Code requirements. For the purpose of the evaluation, BNL assumed that the test, cycle, stroke, or exercise constituted a full-stroke, unless otherwise stated. The licensee should clearly state in the justifications whether or not the valves will be part-stroke or full-stroke exercised at the applicable interval of plant operation, cold shutdown or refueling, item A-2 For valves AF-16-1,2 [3,4]; AF-15-1,2,3,4 [5,6,7,8]; the AFW flow lines to steam i generators check valves, the licensee has not provided justification for deferring the quarterly reverse flow test to verify the valves closure capability, although the tables in the Inservice '

Testing Program Manual (ISTPM) entitled 'ASME Section XI Valves Unit 1 [ Unit 2]", herein  ;

after referred to as the Valve Program Tables, indicate that the stroke closed test is also deferred to Cold Shutdown.

Item A-3 For valves CC-3-3, 4; CC-5-1, 2; [2CC-3-3, 4]; [2CC 5-1, 2]; the component cooling water return line to CCW pumps suction check valves, the licensee has not provided justification for deferring the quarterly flow test to verify that the valves stroke to the open position, although the Valve Program Tables indicate that the stroke open test is also deferred to Cold Shutdown.

Item A-5 For valves SI-61, 3 [2SI-6-1, 3], the Si accumulator outlet check to cold leg; SI-6-2 [2SI-6 2], check valve downstream of check SI-6-1 [2SI-6-1]; SI-6-4 [2SI-6-4], check valve downstream of check SI-6 3 [2SI 6-3]; and SI 9-3, 4, 5, 6; [2SI-9-3, 4, 5, 6]; check valve from RHR heat exchanger to reactor vessel; the licensee has not provided justification for not performing a full-stroke open or at least a partial stroke open test at cold shutdown, nor has the licensee justified why verifying the closure capability cannot be performed quarterly or during cold shutdown.

43

item A6 For valves SI 91, 2 SI-16-4, 5 [2SI-9-1, 2, 2SI-16-4, 5], the cold leg injection lines to loops A & B cold leg check valves; and SI-16-6,7 [2SI 16-6,7], the reactor vessel injection line to reactor vessel check valves, the licensee has not provided justification for not performing a full-stroke open or at least a partial stroke open test at cold shutdowns, nor has the licensee provided justification for not verifying the valves' closure capability quarterly or at cold shutdowns.

items A-8 and H-2 The licensee has not provided justification for not testing valves VC-8-4, 5, 6, 7 [2VC-8-4, 5,6,7], the RCP seal injection check valves, during cold shutdowns when the associated RCP is not running. The manual valves in this line are tested at cold shutdown (Item G-8).

Item B-3 Valves SV-33990, 33991 [SV-33992, 33993), the post-LOCA containment H2 vent normally open solenoid-operated valves, are shown on the flow diagram as normally open and vented to atmosphere. The licensee has not provided justification for not testing these valves closed quarterly. The stated justification does not appear to be appropriate for these solenoid-operated valves.

Also, these valves are listed as excluded and not subject to CS testing for both Unit 1 and Unit 2 in Revision 2 of the IST Program. Equivalent Unit 2 valves SV 33992,33993 are not listed in Appendix B Deferral Notes. However, in an October 6,1993 letter to BNL, the licensee provided a hand-written markup of the Revision 2 Valve Program Tables which shows that the valves are exercised at cold shutdowns and that the Unit 2 valves reference Deferral Note B. The licensee should formally revise the Valve Program Tables.

Item B-4  ;

For valves MV 32067, 23069 [MV-32170, 32172), the reactor vessel injection MOVs, the licensee should review the justification and revise, as appropriate. The NRC recognizes the risk i of exercising pressure isolation valves and does not recommend testing them while at power. l The Prairie Island Technical Specifications, however, do not identify these valves as pressure isolation valves. The two check valves downstream are the PlVs. It does not appear impractical to exercise these normally closed MOVs quarterfy.

Item B 8 and 9 As discussed in Section 4.0 of this TER, entering a LCO is not sufficient basis for not performing ,

the required tests, unless the testing renders svstems inoperable for extended periods of time, i The licensee should evaluate quarterly testing of valves MV-32162, 32163, 32206, 32207 l

[MV-32190, 32191, 322208, 322209), the Si pump suction MOVs, within the Technical )

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v Specification LCO of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or further investigate the effects of testing which may provide additional basis for the deferral.

Item C1 For valves SI-7-1, 2 [2SI-7-1, 2], the check valves from RWST to RHR pumps' suction, the licensee has not provided justification for not verifying the closure capability of these valves quarterly or during cold shutdowns, item D-1 For valves SI-10-1, 2 [2SI-10-1, 2], the Si pumps' discharge check valves, it is not clear why these check valves can not be at least partial-stroke tested quarterly or at cold shutdowns in conjunction with testing of the SI pumps. The licensee should clarify this matter. Also, the licensee has not explained why test procedures could not be developed to prevent the possibility of errors in the restoration of safeguards equipment or the occurrence of an event arising from abnormal system line-ups.

Item E-1 For valves RH-6-1 [2RH-6-1), the RHR to letdown line bypass check valves, the licenses should discuss why the valve is not partial or full-stroke exercised during the quarterly RHR pump tests. Also, the Valve Program Table states that the only safety function is to open. The license 9 should revise the IST program if the valves are required to close or be leak tight, as implied in the proposed alternate testing.

Item F-1 For valves MV-32121, 32120 [MV-32122, 32123), the component cooling water supply header isolation MOVs, and MV-32266, 32267_ [MV-32268, 32269], the RCP CCW inlet isolation MOVs, the licensee is implying that it is impractical to part-stroke or full-stroke exercise these valves quarterly because flow of Component Cooling Water to the Reactor Coolant pumps could be interrupted. The licensee should explain why test procedures could not be developed to prevent the inadvertent isolation of cross-connected portions of the system through operator error in establishing the lineup or from spurious signals from instrumentation in the valve closure circuitry or for any other reason.

Item G-1 Valves CV-31310, 31311 [CV-31314, 31315), the inservice purge exhaust isolation air-operated valves, and CV 31633, 31634 [CV-31635, 31636), the inservice purge supply isolation air-operated valves, are normally closed. These valves are flanged off during normal ,

plant operation by means of removal of a piping section (spool piece). It appears from the referenced flow diagrams that even if the valves were to be fully open during normal plant operation, the blank flanges would maintain containment integrity.

Therefore, the valves do not appear to perform a safety function during power operation. The 45

l-licensee should evaluate if OMa-1988 Part 10,14.2.1.7 applies. If so, justification in accordance with $4.2.1.2 is not required. The use of 4.2.1.7 should be dccumented in the IST program.

1 \

item J-1 For valves AF-13-1 [2AF-13-1), the AFW motor driven pumps discharge cross-connection  !

manual valves, the licensee states that: 'The valves will be full stroked each cold shutdown" and also 'The valve is tested closed quarterly.' However, the Valve Program Table indicates that the valves are exercised at Cold Shutdown. The licenses should clarify the Tables for the two test directior.5.

Item K-1 For valves CA-11-1 [2CA-11-1), the caustic addition to containment spray pumps check valves from caustic acid storage tank, it appears that at least a partial-open exercise could be performed in conjunction with the quarterly containment spray pump test, using the demineralized water flush connections upstream of the valves. Additionally, the licensee has not explained why the valves could not be tested closed quarterly or during cold shutdowns since there are test connections and isolation valves that would allow leak testing. The licensee should review the justification, and revise, as appropriate.

Item K-2 For valves CC-18-1, 2; CC-14-5, 6 [200-18-1, 2; 2CC-14-5, 6], tha reactor coolant pumps bearing cooling water supply / return check valves, and CC-61-1, 2 [20C-61-1, 2),

the reactor coolant pumps emergency bearing cooling water supply check valves, the licensee should revise the Valve Program Table to indicated that the valves are tested open quarterly, not at cold shutdown.

Item K-3 For valves RH-3-1,2 [2RH 3-1,2], the RHR pump suction line check valves, since the Valve Program Table identities only the closed position as the safety function, the licensee should verify that the valves do not serve a safety function in the open position.

Item K-4 For valves RS-15-1, 2 [2MS-15-1, 2], the main steam supply from steam generators to turbine driven auxiliary feedwater pump check valves, it appea's that these valves will be full-stroke exercised during the turbine driven Auxiliary Feedwater pmp r.uarterly test and that testing quarterly is, therefore, practical.

According to the flow diagrams, there are no test connections between these check valves and the normally open upstream MOVs, MV-32016 and 32017 [MV-32019 and 32020), so that it does not appear that the valves could be tested closed during operation. The licensee should, however, provide additional information in the justification for both the open and closed 46 l

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direction.

Item K-5 For valves SM-10-1 [2SM-10-1), the sample retum line check valve to volume control tank, it is sat apparent why excessive valve manipulations are required to test this valve during cold shutdown. The licensee should explain in greatet detail what valve manipulations are involved, and why testing is impractical.

Item K-6 i

I For valves VC-810 [2VC-810), the check valves downstream of volume control tank level control valve 1-LCV-112A [2-LCV-112A]; VC-8-11 [2VC-8-11], the boric acid blender suction check valves; and VC-8-14 [2VC-8-14], the reactor makeup water to charging pumps suction line check valves, the licensee has not explained what required valve manipulations and system alignments make full-stroke exercising the valves closed at cold shutdown impractical. ,

The licensee should provide the information as described in Section 4.0 of this report regarding impracticality.

l Item K-BA For valves VC-13-1 [2VC-13-1], the volume control tank (VCT) inlet check valves, the valves are the first valves in the lines upstream of the VCT. The licensee should clarify whether '

the subject valves are normally open or whether the valves are verified closed at any time 6 ring plant operation. The safety function of the valves is to actuate to the closed position.

Item L-2  !

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For valves CS-16,17 [CS-47,46), the containment spray pumps suction check valves, there are 2 inch flush connections immediately upstream end downstream of each check valve. The i

licensee should clerify why these connections could not be used to verify the closure capability l q u arterly. '

Item L-3 For valves CS-18,19 [CS-48,49), the containment spray pump discharge check valves, the licensee should explain why the valves' closure capability could not be verified quarterly as there are locked open manual valves CS-9,10 [CS-39,40] immediately downstream of these check valves which could be closed and a test connection available between the manual valves and  !

the check valves.

Item L-6 For valves CV 31381, 31411 [CV 31383, 31384), the component cooling water heat exchangers cooling water rerum AOVs, the licensee should clarify the frequency at which the  !

valves are full-stroke exercised and fail-safe tested and timed. A relief request is required if the frequency is not at cold shutdowns or refueling outages.

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6.0 REFERENCES

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1. NRC Regulatory Guide 1.147, *lnservice inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 9, April 1992. l

2. ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components,1989 Edition i

3. Prairie Island Technical Specifications.

4. ASME/ ANSI OMa-1988, Part 6, *lnservice Testing of Pumps in Light Water Reactor  ;

Power Plants." ,

5. ASME/ ANSI OMa-1988, Part 10, " Inservice Testing of Valves in Light-Water Reactor i Power Plants."

6.

10CFR50.55a

7. Standard Review Plan, NUREG 0800 Section 3.9.6, inservice Testing of Pumps and  ;

Valves, Rev. 2, July 1981.

8.  !'

NRC Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs,* April 3,1989. '

9. Minutes of the Public Meetings on Generic Letter 89-04, October 25,1989.

10. Supplement to the Minutes of the Public Meetings on Generic Letter 89-04, September 26, 1991.

11. NRC Bulletin 88-04, " Potential Safety-Related Pump Loss," May 5,1988. l

12. NUREG/CP-0111, " Proceedings of the Symposium on Inservice Testing of Pumps and i Valves,' held AuDust 1-3, 1989, Washington, D.C. '

13. " Submittal of the 3rd 10-Year Inservice Testing (IST) Program to the Requirements of l ASME Section XI," R. O. Anderson, NSP, to USNRC, June 16,1993. ,

14.

• Submittal of Revision 2 of the 3rd 10-Year Inservice Testing (IST) Program to the Requirements of ASME Section XI,* R. O. Anderson, NSP, to USNRC, August 25,1993.

15. " Review of IST Program Request for Relief," G. Miller, NSP, to A. DiBiasio, BNL, September 24, 1993.

l

16. Letter concerning BNL October 5,1993 Fax from G. Miller, NSP, to A.DiBiasio, BNL.

October 6,1993.

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17.

• Discovery that Certain Valves Should be subject to ASME Section XI Testing," R. O.

Anderson, NSP, to USNRC, July 26,1993 LER 93-07, Revision 1 attached. )

18. NRC Information Notice 87-01, *RHR Valve Misalignment Causes Degradation of ECCS in PWRs,' January 6,1987.

19. Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability,"  :

November 7,1991.

20. Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,* June 4,1987, i

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Appendix A: PRAIRIE ISLAND DRAWING LIST NF-39216-2, Rev. J, " Flow Diagram Unit 1 Cooling Water Turbine Building

• j i

NF-39216-3, Rev. E, ' Flow Diagram Unit 1 Cooling Water - Auxiliary Building

• i NF-39217-1, Rev. H, " Flow Diagram Unit 2 Cooling Water Turbine Building

• NF-39217 2, Rev. D, ' Flow Diagram Unit 2 Cooling Water - Auxiliary Building'NF-39218, ,

Rev. AX, " Flow Diagram Unit 1 Main, Auxiliary Steam & Steam Dump

• NF-39219 Rev. AV, ' Flow Diagram Unit 2 Main, Auxiliary Steam & Steam Dump' i NF-39222. Rev. AP, ' Flow Diagram Unit 1 Feedwater System" NF-39223, Rev. AN, " Flow Diagram Unit 2 Feedwater System' NF-39237 Rev. Y, " Flow Diagram Units 1 & 2 Containment internal Spray System' NF-39238, Rev. X, ' Flow Diagram Units 1 & 2 Sampling System Reactor Plant

• NF-39239, Rev. AK, " Flow Diagram Unit 1 Chemical Feed, Feedwater pump injection and gland seal piping" '

NF-39240, Rev. AB, " Flow Diagram Unit 2 Chemical Feed, Feedwater pump injection and gland seal piping" NF-39244, Rev. AJ, " Flow Diagram Units 1 & 2 Instrument Alr Piping *

• NF 39245-1, Rev. D. " Unit 1 Component Cooling System Flow Diagram' NF-39245-2, Rev. 8, " Unit 1 Component Cooling System Flow Diagram

• NF-39246-1, Rev. D, "Ur0 2 Component Cooling System Flow Diagram

• NF-39246-2, Rev. B, ' Uni'. 2 Component Cooling System Flow Diagram' NF-39251, Rev. L, 'F!ow Diagram - Post LOCA Hydrogen Control System - Units 1 & 2' NF-39252, Rev. L, ' Flow Diagram Units 1 & 2 Caustic Addition System" NF-39602-1, Rev. AD, ' Reactor Building Unit 1 Ventilation Flow Diagram' NF-39602 2, Rev. AF, Reactor Building Unit 2 Ventilation Flow Diagram' X-HIAW-1-7, Rev. U,

• Flow Diagram Unit 1 Reactor Coolant System' A-1

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X-HIAl' 1-31. Rev. L, " Flow Diagram Unit 1 Residual Heat Removal System'.  ;

X-HIAW-1-38, Rev. P, ' Flow Diagram Unit 1 Chemical & Volume Control System' ,

X-HIAW 1-39, Rev. X, " Flow Diagram Unit 1 Chemical & Volume Control System' ,

X-HIAW-1-44, Rev. N, " Flow Diagram Unit 1 Safety injection System

• f X-HIAW-1-45, Rev. S, " Flow Diagram Unit 1 Safety injection System" X-HIAW 1001-3, Rev. AB, ' Flow Diagram Unit 2 Reactor Coolant System" X-HIAW-1001-4, Rev. O, " Flow Diagram Unit 2 Chemical & Volume Control System" .

X-HIAW-1001-5, Rev. T, ' Flow Diagram Unit 2 Chemical & Volume Control System" !

X-HIAW-1001-6, Rev. O, " Flow Diagram Unit 2 Safety injection System"  ;

X-HIAW-1001-7, Rev. R, Flow Diagram Unit 2 Safety injection System" X-HIAW-1001-8, Rev. L, " Flow Diagram Unit 2 Residual Heat Removal Syster::'  !

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