ML20062A488
| ML20062A488 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/30/1982 |
| From: | Rockhold H EG&G, INC. |
| To: | Page J Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-6258 EGG-EA-5844, NUDOCS 8208040010 | |
| Download: ML20062A488 (27) | |
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This is an informal report intended for use as a preliminary or working document
-il Prepared for the U.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-761001570 -?
9 FIN No. A6258 g E Idaho 8208040010 820430 hk PDR RES 8208040010 PDR .-
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INTERIM REPORT Accession No _ . _ _ _
Report No. EGG-EA-5844 Contract Program or Project
Title:
Systems Engineering Support Subject of this Document:
Safety Evaluation Report, Pump and Valve Inservice Testing Program, Oyster Creek Nuclear Generating Station Type of Document:
Safety Evaluation Report Author (s):
H. C. Rockhold Date of Document:
April 1982 Responsibla NRC Individual and NRC Office or Division:
J. D. Page, Division of Engineering This document was prepared primarily for preliminary or internal use. It has not received full review and approval Since there may be substantive changes, this document should not be considered final EG&G Idaho, Inc idaho Falls. Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
Under DOE Contract No. DE-AC07 76lD01570 NRC FIN No. A6258 INTERIM REPORT
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ABSTRACT This EG&G Idaho, Inc. report presents the results of our evluation of the Oyster Creek Nuclear Generating Station Inservice Testing Program for safety-related pumps and valves.
FOREWORD This report is supplied as part of the " Systems Engineering Support" Program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Enigneering, by EG&G Idaho, Inc., Reliability and Statistics Branch.
The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20 19 01 09, FIN No. A6258.
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CONTENTS I. INTRODUCTION .................................................. 1 II. PUMP TESTING PROGRAM .......................................... 2
- 1. Safety-Related Pumps ...................................... 2 III. VALVE TESTING PROGRAM EVALUATION .............................. 4
- 1. General Considerations .................................... 4 1.1 Testing of Valves which Perform a Pressure Isolation Function ................................... 4 1.2 Stroke Testing of Check Valves ....................... 5 1.3 Test Frequency of Check Valves Tested at Cold Shutdowns ....................................... 5 1.4 Licensee Request for Relief to Test Valves at Cold Shutdowns .................................... 5 1.5 Safety-Related Valves ................................ 5 1.6 V al ve Tes ti ng at Co ld Shu tdowns . . . . . . . . . . . . . . . . . . . . . . 6 1.7 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs) . . . . . . . . . . . . . . 6 1.8 Application of Appendix J Testing to the IST Program .......................................... 6
- 2. Generic Rel ie f Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.1 Category A and A/C Valves ............................ 7
- 3. Core Spray System ......................................... 9 3.1 Category C Valves .................................... 9
- 4. Liquid Poison System ...................................... 10 4.1 C a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 5. Control Rod Drive Hydraulic System ........................ 11 5.1 C a t eg o ry B V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.2 Category C Valves .................................... 11
- 6. F e ed wa t e r Sy s t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.1 Category A/C Valves .................................. 12 12
- 7. M a i n S t e am Sys t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1 Category 8/C Valves .................................. 12 7.2 C a t eg o ry C V a l ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 iii
P. Closed Cooling Water System ............................... 13 C.1 Category A and A/C Valves ............................ 13 8.2 Category C Valves .................................... 14
- 9. Miscellaneous Systems ..................................... 14 9.1 Category A and A/C Valves ............................ 14 9.2 Category C Valves .................................... 15 IV. APPENDIX A .................................................... 17
- 1. Code Requirement--Valves .................................. 17 V. ATTACHMENT I .................................................. 18 VI. ATTACHMENT II ................................................. 19
- 1. Core Spray System ......................................... 19
- 2. Reactor Shutdown Cooling System ........................... 19
- 3. Control Rod Drive Hydraulic System . . . . . . . . . . . . . . . . . . . . . . . . 19
- 4. Clean-up Demineralizer System ............................. 20 VII. ATTACHMENT III ................................................ 21 iv
I. INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Jersey Central Power and Light Company (JCP&L) for its Oyster Creek Nuclear Generating Station.
The working session with JCP&L and Oyster Creek representatives was conducted on September 23 and 24,1980. The licensee resubmittal was received by EG&G Idaho, Inc., on October 13, 1981, and reviewed to verify compliance of proposed tests of safety-related Class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Pressure Vessel Code, Sec-tion XI, 1974 Edition, through the Summer of 1975 Addenda. JCP&L has also requested relief from the ASME Code from testing specified pumps and valves because of practical reasons. These requests have been evaluated individ-ually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.
The evaluation of the pump testing program and associated relief requests is contained in Section II; the evaluation of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.
A summary of valve-testing requirements is provided in Appendix A.
Appendix J exemption requests for Category A valves that should be reveiwed by the NRC are contained in Attachment I.
Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every three months are contained in Attachment II.
A listing of P& ids used for this review are contained in Attach-ment III.
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II. PUMP TESTING PROGRAM The IST program submitted by Oyster Creek was examined to verify that j Class 1, 2, and 3 safety-related pumps were included in the program and
, that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that all Class 1, 2, and 3 safety-related pumps were included in the IST program and, except for those
- pumps identified below for which specific relief from testing has been
! requested, the pump tests and frequency of testing comply with the code.
1 Each Oyster Creek basis for requesting relief from testing pumps and the EG&G evaluation of that request is summarized below. I
- 1. Safety-Related Pumps i
1.1 Relief Request Relief is requested from the requirements of Section XI to measure i
pump bearing temperatures in accordance with IWP-3300.
1.1.1 Code Requirement. IWP-3300 states bearing temperatures shall be measured during at least one inservice test each year. ~
1.1.2 Licensee's Basis for Requesting Relief. Vibration measurements taken on a quarterly basis are trended. Significant increases in these readings will necessitate further vibration measurement with the use of a real time spectrum analyzer to define the source of the increase. Use of i the real time analyzer is a method to determine mechanical condition.
Bearing temperature measurements therefore contribute a redundant measure of bearing condition and thus need not be performed. A yearly vibration
! frequency spectrum analysis will be performed on all pumps.
l 1.1.3 Evaluation. The licensee has demonstrated that the vibration measurements obtained by the proposed pump testing program would more accurately indicate the condition of the pump bearings than annual bearing temperature measurements. Therefore, we feel relief should be granted from the code specified method of pump testing. We feel the use of quarterly
, vibration measurements and annual use of the real time spectrum analyzer will adequately demonstrate pump mechanical condition and should predict pump f ailure.
l.2 Relief Request.
Relief is requested from the requirements of Section XI for performing j monthly inservice pump tests.
1.2.1 Code Requirement. IWP-3400 states an inservice test shall be
- run on each safety related pump, nominally each month during plant opera-
- tion.
1.2.2 Licensee's Basis for Requesting Relief. The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing I
their safety function. A monthly test provides such assurance; however, 2
monthly testing also requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would pro-vide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a revision to the code which requires a pump test frequency of nominally once every 3 months.
Pumps will be tested monthly by starting and measuring either flowrate or differential pressure. During a quarterly pump test all identified parameters shall be measured.
1.2.3 Evaluation. We agree with the licensee's basis for quarterly pump testing with monthly pump starts and measurement of either flowrate or differential pressure since this is in accordance with the current NRC posi-tion on pump testing. Therefore, we feel relief should be granted from the monthly pump testing requirements as specified in Section XI. We feel the licensee's proposed alternate test will adequately demonstrate proper operability and will be effective in discovering or predicting pump f ailure.
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III. VALVE TESTING PROGRAM EVALUATION The IST program submitted by Oyster Creek was examined to verify that all Class 1, 2, and 3 safety-related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that all Class 1, 2, and 3 safety-related valves were included in the IST program and, except for those valves identified below for which specific relief from testing nas been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guide-lines listed in Section 1. Also included in Section 1 is the NRC position and valve listings for the leak testing of valves that perform a pressure isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each Oyster Creek basis for requesting specific relief from testing valves and the EG&G evaluation of that request is summarized below and grouped according to each specific system.
- 1. General Considerations 1.1 Testing of Valves Which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high- and low-pressure systems prevent the low-pressure systems from experiencing pressures which exceed their design limit. In this role, the valves perform a pressure isolation function.
The NRC considers the redundant isolation provided by these valves to be important. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, EG&G and the NRC believe that some method, such as pressure monitoring, leak testing, radiography, or ultra-sonic testing, should be used to assure that the condition of each valve is satisfactory in maintaining this pressure isolation function.
If leak testing is selected as the appropriate method for achieving b this objective, the NRC and EG&G Idaho, Inc., believe that the following valves should be categorized as A or A/C and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:
NZ02-A V-31-5 NZ02-B V-31-2 NZ02-C B-2-72 NZ02-D V-2-71 V-20-40 V-2-73 V-20-21 V-2-74 V-20-15 V-16-62 V-20-41 The NRC and EG&G Idaho, Inc., have discussed this matter with the licensee and identified the valves listed above. The licensee agreed to consider testing and categorizing each of these valves with the appropriate 4 l
designation, depending on the testing method selected. Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC, for evaluation, the details of the testing method which clearly demonstrates the condition of each valve.
1.2 Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only limited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valve shall be partial stroked. Since disk position is not always observable, the NRC staff stated that verifica-tion of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement.
Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or greater than the design flow rate through the valve. The licensee agreed to conduct flow tests to satisfy the above position.
1.3 Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more of ten than once every three months for Category A and B valves and once every nine months for Category C valves. It is the NRC's position that the Code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold shutdowns to read, "In the case of frequent cold shutdowns, valve testing need not be performed more often than once every three (3) months for Category A, B, and C valves."
1.4 Licensee Request for Relief to Test Valves at Cold Shutdowns The Code permits valves to be tested at cold shutdowns, and the condi-tions under which this is permitted are noted in Appendix A. These valves are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis. It should be noted that the NRC differentiates, for valve testing purposes, between the cold-shutdown mode and the refuel-ing mode. That is, for testing purposes, the refueling mode is not con-sidered as a cold shutdown.
1.5 Safety-Related Valves j This review was limited to safety-related valves. Safety-related l valves are defined as those valves that are needed to mitigate the conse-
! quences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some 5
non-code class valves. It should be noted that the licensee may have included non-safety-related valves in their IST program as a decision on the licensee's part to expand the scope of their program.
1.6 Valve Testing at Cold Shutdowns Inservice valve testing at cold shutdowns is acceptable when the fol-lowing conditions are met:
- 1. It is understood that the licensee is to commence testing as soon as the cold-shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power.
- 2. Completion of all valve testing is not a prerequisite to return !
to power. !
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- 3. Any testing not completed at one cold shutdown should be performed .
during any subsequent cold shutdowns that may occur before refuel-
- ing to meet the code-specified testing frequency..
- 4. For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold-shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
! 1.7 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs)
All CIVs shall be classified as Category A valves. The Category A valve-leak rate test requirements of IWV-3420(a-e) have been superseded by 1 l Appendix J requirements for CIVs. The NRC has concluded that the appli- !
l cable leak-test procedures and requirements for CIVs are determined by )
10 CFR 50, Appendix J. Relief from Paragraph IWV-3420(a-e) for CIVs pre- '
i sents no safety problem since the intent of IWV-3420(a-e) is met by
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Appendix J requirements.
i The licensee shall comply with Sections f and g of IWV-3420 until relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C, Appendix J leak test is l performed. Based on the considerations discussed above, the NRC concludes that the alternate testing proposed above will give the reasonable assur-i ance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and
- security'of the public.
1.8 Application of Appendix J Testing to the IST Program l
The Appendix J review for this plant is a completely separate review i from the IST program review. However, the determinations made by that review are directly applicable to the IST program. Our review has deter-mined that the current IST program, as submitted by the licensee correctly reflects the NRC's interpretation of Section XI vis-a-vis Appendix J. The
- licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
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- 2. Generic Relief Requests 2.1 Category A and A/C Valves 2.1.1 Relief Request. Relief is requested from the leak testing requirements of Section XI for all Category A containment isolation valves.
2.1.1.1 Code Requirements. Refer to Section XI Paragraph IWV-3420.
2.1.1.2 Licensee's Basis for Requesting Relief. The low pres-sure seat leak test required by IWV-3420 is redundant to the seat leak test required by 10CFR50, Appendix J, Type C for valves performing a containment isolation function. Performing two separate tests would provide no addi-tional useful data. As an alternate, the seat leak test required by 10CFR50, Appendix J, Type C will be performed, in lieu of the low pressure Section XI IWV-3420 seat leak test. The high pressure seat leak test required for pressure isolation valves will still be performed in accordance with IWV-3420.
2.1.1.3 Evaluation. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J (refer to Section 1.7 of this reporH .
Therefore, we feel relief should be granted from the requirements of 5ec-tion VI, Paragraph IWV-3420 for containment isolation valves. We feel the licensee's proposed alternate test of leak testing per Appendix J will '
adequately demonstrate the leak tight integrity of *hese valves.
2.1.2 Relief Request. Relief is requested from the requirements of Paragraph IWV-3410(c)(3) for all valves that are tested on a cold shutdown or refueling frequency.
2.1.2.1 Code Requirement. Paragraph IWV-3410(c)(3) requires that if an unacceptable increase in stroke time is observed, the valve test frequency shall be increased to once per month until corrective action is taken.
2.1.2.2 Licensee's Basis for Requesting Relief. Valves are tested on a cold shutdown or refueling frequency because there is a defined basis for not testing on a quarterly frequency during power operation (e.g.,
the plant is put in an unsafe condition, system design does not permit test-ing). Accordingly, the basis for not testing these valves quarterly would also apply to monthly testing. As an alternate, the test frequency will remain unchanged. The requirements contained in the Oyster Creek Technical Specifications will govern plant operations regarding out of service valves.
2.1.2.3 Evaluation. The licensee has demonstrated that the plant's Technical Specifications have limiting conditions for operation which identify systems and components out of service and the operational considerations for those conditions. Therefore, we feel relief should be granted from the requirements of Paragraph IWV-3410(c)(3) of Section XI for all valves that are identified for exercising during cold shutdown or refueling outages.
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2.1.3 Relief Request. Relief is requested from the requirements of Section XI, Paragraph IWV-3410(f) for testing of valves in systems out of service.
2.1.3.1 Code Requirement. Paragraph IWV-3410(f) requires all valves in systems out of service to be exercised immediately prior to the return of the system to service.
2.1.3.2 Licensee's Basis for Requesting Relief. The Limiting Condition' for Operation presently contained in the Oyster Creek Technical Specifi ations along with the Oyster Creek Plant Procedures adequately cover all such situations. As an alternate, the requirements contained in the Oyster Creek Technical Specifications and Plant Procedures will govern plant operation in such situations.
2.1.3.3 Evaluation. We agree with the licensee's basis and feel the plant's Technical Specifications more adequetely determine what equip-ment needs to be tested when a system is returned to service. Therefore, we feel relief should be granted from the requirements of Section XI, Para-graph IWV-3410(f) .
2.1.4 Relief Request. Relief is requested from the requirements of Paragraph IWV T 3410(g) of Section XI.
2.1.4.1 Code Requirement. IWV-3410(g) states when corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup.
2.1.4.2 Licensee's Basis for Requesting Relief. The Limiting Conditions for Operation presently contained in the Oyster Creek Technical Specifications along with the Oyster Creek Plant Procedures adequately cover the situation of out of service valves and plant operations. The requirements contained in the Oyster Creek Technical Specifications and Plant Procedures will govern plant operation regarding out of service valves.
2.1.4.3 Evaluation. We agree with the licensee's basis and feel the plant Technical Specifications adequately determine what equipment /
systems must be in operation prior to plant startup and during power opera-tion. Therefore, we feel relief should be granted from the requirements of Section XI, Paragraph IWV-3410(g).
2.1.5 Relief Request. Relief is requested from the exercising and leak testing requirements of Section XI for the excess flow check valves listed below.
V-130-5 V-1-184 V-37-70 V-37-16 V-130-26 V-1-185 V-37-71 V-37-17 V-130-3 V-37-7 V-37-72 V-37-27 V-130-4 V-37-8 V-37-73 V-37-28 V-130-21A V-37-18 V-37-74 V-37-38 V-130-1 V-37-19 V-37-75 V-37-39 1 V-130-2A V-37-39 V- 14-49 V-37-49 i 8
V-130-28 V-37-30 V-14-50 V-37-50 V-130-6A V-37-40 V-14-52 V-130-9 V-130-6B V-37-41 V-14-53 V-130-10 V-130-7 V-37-51 V-14-55 V-20-172 V-130-8 V-37-52 V-14-56 V-20-173 V-130-21B V-37-66 V-14-54 V-37-59 V-1-180 V-37-68 V-37-5 V-1-181 V-37-69 V-37-6 2.1.5 .1 Code Requirement. Refer to Appendix A.
2 .1.5 . 2 Licensee's Basis for Requesting Relief. Instrumentation lines connected to the reactor coolant pressure boundary and which pene-trate primary containment are designed in accordance with USNRC Regulatory Guide 1.11 which permits a flow restricting orifice inside containment and an excess flow check valve outside containment for isolation. This design configuration does not permit valve exercising or local seat leak tests to be performed. These excess flow check valves are demonstrated to be func-tional (i.e., close with differential pressure across the valve) during the refueling outage as required by Plant Procedure 604.3.008.
2.1.5.3 Evaluation. The licensee has demonstrated that the excess flow check valve design configuration does not permit exercising during power operation. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these small check valves. We feel the licensee's proposed alternate test of verifing proper valve opera-tion (closure) during refueling outages when the instrumentation is avail-able for testing will adequately demonstrate the ability of the valves to perform their safety related functions.
- 3. Core Spray System 3.1 Category C Valves 3.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V20-60 and V20-61, fire protection system to core spray check valves.
3.1.1.1 Code Requirement. Refer to Appendix A.
3.1.1.2 Licensee's Basis for Requesting Relief. V20-60 and V20-61 are category C normally shut check valves. These valves cannot be exercised open during power operation or cold shutdown since initiating flow through these valves could result in putting fire protection system water into the reactor. These valves will be full stroke exercised during refueling outages.
3.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation or cold shutdown could result in injecting sea water from the fire protection system through the core spray system into the reactor. Injection of this water could result in degrada-tion of the reactor coolant system (i.e. cloride stress corrosion). There-fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate 9
test of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve operability.
3.1.2 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V20-88 and V20-89, fire protection system to core spray check valves.
3.1.2.1 Code Requirement. Refer to Appendix A.
3.1.2.2 Licensee's Basis for Requesting Relief. These valves are normally shut check valves. These valves cannot be exercised open during power operation or cold shutdown since initiating flow through these valves could result in putting fire protection system water into the reactor. These valves will be full stroke exercised during refueling outages.
3.1.2.3 Evaluation. The licensee has demonstrated that exercising these valves during power operation or cold shutdown could result in injecting sea water from the fire protection system through the core spray system into the reactor. Injection of this water could result in degrada-tion of the reactor coolant system (i.e. cloride stress corrosion). There-fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these _ valves during refueling outages will adequately demonstrate proper valve operability.
- 4. Liquid Poison System ,
4.1 Category C Valves 4.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V19-16 and Vl9-20, poison system to the reactor vessel check valves.
4.1.1.1 Code Requirement. Refer to Appendix A.
4.1.1.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation since flow thru these valves requires pumping highly concentrated sodium pentaborate into the RCS, causing plant shutdown. Performing this test during cold shutdowns requires flushing the poison system for up to 3 days, possibly causing a delay in startup. These valves will be full stroke exercised during the liquid poison system full flow injection test at refueling.
4.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these check valves during power operation would require injecting highly concentrated sodium pentaborate into the RCS causing reactor shut-down. Additionally, during cold shutdowns injection of the sodium penta- c borate into the RCS would cause extensive chemical and radioactive waste generation since all this chemical would have to be flushed from the RCS prior to reactor operation. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel 10 1
the licensee's proposed alternate test of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve operab il ity.
- 5. Control Rod Drive Hydraulic System 5.1 Category B Valves 5.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves CV-126 and CV-127 (137 valves each),
scram inlet / outlet control valves.
5.1.1.1 Code Requirement. Refer to Appendix A.
5.1.1.2 Licensee's Basis for Requesting Relief. CV-126 and 127 cannot be exercised during power operation since exercising these valves scrams the associated control rod. Withdrawl of this rod at power could cause fuel damage to the core. Per Technical Specification requirements, a sample of 8 of these valves (137 of each) are tested during cold shutdown if the sample has not been tested in the previous 6 months. All valves are tested at refueling.
5.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves would cause the associated control rod to scram which could result in reactor fuel damage if performed during power eperation.
Therefore, we feel relief should be granted from the exercising require-ments of Section XI for these valves. We feel the licensee's proposed alternate of testing these valves per Technical Specifications will adequately demonstrate proper valve operability.
5.2 Category C Valves 5.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves 108 (137 valves), scram water to scram discharge volume check valves.
5.2.1.1 Code Requirement. Refer to Appendix A.
5.2.1.2 Licensee's Basis for Requesting Relief. These valves (137) can only be verified open during the actual scram testing. Per Tech-nical Specification requirements, a sample of 8 of the 137 valves are tested during cold shutdown if the sample has not been tested in the pre-vious 6 months. All valves are tested at refueling.
5.2.1.3 Evaluation. The licensee has demonstrated that the only method of verifying valve opening is actual scraming of the associated con-trol rod and scram testing of individual control rods during power operation could result in fuel damage. We feel the plant's current Technical Specifi-cation requirements will adequately demonstrate proper valve operability therefore we feel relief should be granted from the exercising requirements of Section XI for these valves. All these valves will be full stroke exercised at least each refueling outage.
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- 6. Feedwater System 6.1 Category A/C Valves 6.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V2-71, V2-72, V2-73 and V2-74, main feedwater to reactor isolation valves.
6.1.1.1 Code Requirement. Refer to Appendix A.
6.1.1.2 Licensee's Basis for Requesting Relief. Exercising these veilves during power operation would require isolation of the feed-water system, which results in plant shutdown. Two of these valves are inaccessible during cold shutdown when the containment atmosphere is inerted. These valves will be verified shut (which is their safety related position) during their Seat Leak Test each refueling outage.
6.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would result in isolation of the feedwater to the reactor resulting in plant shutdown. Therefore we feel relief should be granted from the exercising requirements of Seclion XI for these valves. We feel the licensee's proposed alternate test of verifica-tion of valve closure during the leak rate testing performed during each refueling outage will adequately demonstrate proper valve operability.
- 7. Main Steam System 7.1 Category B/C Valves 7.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves NR-108A, NR-108B, NR-108C, NR-108D and NR-108E, ADS / reactor safety valves.
7.1.1.1 Code Requirements. Refer to Appendix A.
7.1.1.2 Licensee's Basis for Requesting Relief. Exercising these relief valves during power operation or cold shutdown would simulate a small-break transient, subjecting the RCS to large and unnecessary shocks.
In addition, in keeping with the views put forth in NUREG 0737,Section II.K.3.16 concerning reducing challenges to safety and relief valves, these valves should be tested at a reduced frequency. As an i alternate, these valves will be full stroke exercised during startup following a refueling outage, i.e., on a refueling outage frequency.
7 .1.1. 3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would appear to be a loss of cool-ant accident to the engineered safety features systems and would result in injecting relatively cold water into the RCS resulting in severe thermal transients to the piping and components. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these v alves . We feel the licensee s proposed alternate test of exercising these ADS / relief valves during startup following refueling outages will adequately demonstrate proper valve operability.
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7.2 Category C Valves 7.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves Vl-178, Vl-179, V1-180 and Vl-181, ADS discharge headers vacuum breakers.
7.2.1.1 Code Requirement. Refer to Appendix A.
7.2.1.2 Licensee's Basis for Requesting Relief. These valves are located inside the drywell and are not accessible while the containment is inerted. These valves will be exercised at refueling, when conditions allow access to the drywell, i .e., when the containment is de-inerted.
7.2.1.3 Evaluation. The licensee has demonstrated that since these valves are located inside containment, they are not accessible for manual exercising. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these valves during refueling outages when the containment is de-inerted will adequately demonstrate proper valve operability.
- 8. Closed Cooling Water System 8.1 Category A and A/C Valves .
8.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V5-147, V5-166 and V5-167, closed cooling water containment isolation valves.
8.1.1.1 Code Requirement. Refer to Appendix A.
8.1.1.2 Licensee's Basis for Requesting Relief. Full stroke exercising of these valves isolates cooling water flow to the recirculation pumps. Isolation of cooling water during normal plant operation can cause possible damage to these pumps, thus requiring plant shutdown. During cold shutdown these valves will be full stroke exercised providing all recircu-lation pumps are t,2rned off. The recirculation pumps will not be secured to perform testing. These valves will be full stroke exercised at least on a refueling outage frequency.
8.1.1. 3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would isolate cooling water flow to the reactor recirculation pumps which could result in pump damage requiring plant shutdown for repairs. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these valves during cold shutdown, providing all reactor recirculation pump are turned off, and during refueling outages will adequately demonstrate proper valve operability.
8.1.2 Relief Request. Relief is requested from the exercising requirements of Section XI for valve V5-165, closed cooling water contain-ment isolation check valve.
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8.1.2.1 Code Requirement. Refer to Appendix A.
8.1.2.2 Licensee's Basis for Requesting Relief. The only method available to verify that this valve shuts (which is its safety related function) is via the Seat Leak Test performed during refueling outages. As an alternate, this valve will be exercised during the Seat Leak Test at refuel ing.
8.1.2.3 Evaluation. The licensee has demonstrated that the only currently available means of verifying closure of this check valve is via leak testing. Therefore, we feel relief should be granted from the exer-cising requirements of Section XI for this check valve. We feel the licensee's proposed alternate test of verifying valve closure during refueling outages when the Appendix J leak rate testing is parformed will adequately demonstrate proper valve operability.
8.2 Category C Valves 8.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V-5-153 and V-5-154, closed cooling water pumps discharge check valves.
8.2.1.1 Code Requirement. Refer to Appendix A.
8.2.1.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised shut during power operation since both CCW pumps are required for heat removal during months of high service water temperature or during periods of RBCCW high heat loads. Exercising these valves would require shutting down one of these pumps. As an alternate, V5-153/154 will be exercised during cold shutdown only on those occasions when one CCW pump can handle the heat removal load. These valves will be exercised at least each refueling outage.
8.2.1.3 Evaluation. The licensee has demonstrated that these check valves cannot be exercised during power operation since both CCW pump are required for heat removal during periods of high service water temper-ature or high RBCCW system heat loads. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these check valves. We feel the licensee's proposed alternate test of full stroke exercising these check valves during cold shutdown providing the heat removal capabilities of the system can be accomplished with one CCW pump.
These valves will be full stroke exercised at a minimum of each refueling outage.
- 9. Miscellaneous Systens 9.1 Category A and A/C Valves 9.1.1 Relief Request. Relief is requested from the exercising and leak testing requirements of Section XI for valves V31-2 and V31-5, reactor head cooling containment isolation valves.
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9.l.1.1 Code Requirement. Refer to Appendix A.
9.1.1.2 Licensee's Basis for Requesting Relief. 'These passive i valves are not required to open to fulfill their safety related function, thus they need not be stroked open. No valve full stroke exercise test j will be performed. Position of valves will be verified closed during valve l ineu p. As an alternative to the Section XI Leak Test an Appendix J, Type A Leak Test will be performed on the combination.
9.1.1. 3 Evaluation. The licensee has demonstrated that these valves are normally closed passive containment isolation valves. There-fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. Additionally, we feel the leak testing performed per Appendix J is a suitable alternative to the Section XI leak testing requirements (see Paragraph 1.8 of Section III of this report).
9.1.2 Relief Request. Relief is requested from the exercising requirements of Section XI for valve V16-84, relief valve V16-76 discharge from reactor water cleanup system to torus check valve.
9 .1. 2.1 Code Requirement. Refer to Appendix A.
a i 9.1.2.2 Licensee's Basis for Requesting Relief. Operation of this valve is not verifiable except during the annual Type A test. This valve is functionally tested in the closed position during the 10CFR50 Appendix J, Type A test conducted during refueling.
9.1.2.3 Evaluation. The licensee has demonstrated that the only way to verify valve closure (its safety related position) is by leak rate testing and this valve is normally leak rate tested during the Appendix J Type A leak tests performed during refueling outages. Therefore, we feel relief should be granted from the exercising requirements of Section XI for 4 this valve. We feel the licensee's proposed alternate test of verifying valve closure during each refueling outage will adequately demonstrate proper valve operability.
4 9.2 Category C Valves
- f 9.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V3-62 and V3-63, service water pumps discharge check valves.
9.2.1.1 Code Requirement. Refer to Appendix A.
9.2.1.2 Licensee's Basis for Requesting Relief. V3-62 and V3-63 i cannot be exercised quarterly since both service water pumps are typically l required to handle the heat removal load during months of high service water temperature or during periods of RBCCW-high heat loads. As an alternate, these valves will be exercised on a cold shutdown frequency only on those occasions when one service water pump can handle the heat removal load.
These valves will be exercised at least each refueling outage.
) 9.2.1.3 Evaluation. The licensee has demonstrated during months
< of high service water temperatures and during periods of high RBCCW heat 15
loads, both service water pumps are typically required to be operating.
Therefore, we feel relief should be granted from the exercising require-ments of Section XI for these valves. We feel the licensee's proposed alternate test of exercising these check valves during cold shutdowns when one service water pump can supply the flow required for adequate system heat removal and during each refueling outage will adequately demonstrate proper valve operability.
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IV. APPENDIX A
- 1. Code Requirement--Valves Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code (which discussed full stroke and partial stroke requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). IWV-3520(a) (which discusses full stroke and partial stroke requirements) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above cases of exceptions, the Code permits the valves to be tested at cold shutdown where:
- 1. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
- 2. It is not practical to observe the operation of the valves (with failsafe actuators) upon loss of actuator power.
Subsection IWV-3410(c) requires all Category A and B power-operated valves to be stroke-tine tested to the nearest second or 10% of the maximum allowable owner-specified time.
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i V. ATTACHMENT I The following is a list of valves that we feel should be reviewed by the NRC to determine if these valves meet the Appendix J criterion for containment isolation. If any of these valves are determined to be Appendix J valves then they should be included in the IST program and categorized A, A/C or A/E as applicable.
V-15-27 CRD Hydraulics to the reactor vessel V-15-28 CRD Hydraulics to the reactor vessel i
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1 VI. ATTACHMENT II
'i The following are Category A, B, and C valves that meet the require-ments of the ASME Code,Section XI, and are not full stroke exercised every three months during plant operation. These valves are specifically identi- '
i fied by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG&G has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible, due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are j
located.
- 1. Core Spray System 1.1 Category A/C Valves i NZO2-A, NZ02-B, NZ02-C and NZ02-D, core spray to reactor check valves, cannot be exercised during power operation since the core spray pumps 2 cannot develop sufficient discharge head to pump into the RCS. Addition-I ally, zero differential pressure must exist across the valves for the valve test operators to move the valve discs. These valves will be full stroke exercised during cold shutdowns and refueling outages using the valve test operator s.
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- 2. Reactor Shutdown Cooling System i
2.1 Category B Valves V 1, V- 17-2, V- 17-3, V 19, V- 17-54, V- 17-55, V- 17-56, an d V-17-57, shutdown cooling system isolations from the RCS, cannot be exercised during power operation since opening these valves could result in an overpressurization of the low pressure shutdown cooling system. Addi-tionally, valves V-17-19 and V-17-54 are interlocked to remain closed when j the reactor coolant temperature is greater than 350 F. These valves will be full stroke exercised during cold shutdowns and refueling outages.
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- 3. Control Rod Drive Hydraulic System 3.1 Category B Valves j V-15-119, V-15-120 and V-15-121, scram discharge volume vent and drain j valves, cannot be exercised during power operation since valve failure in the closed position could increase the scram insertion times to greater than acceptable limits. These valves will be full stroke exercised during cold shutdowns and refueling outages.
! 3.2 Category C Valves 1
i V alves 106 (137 valves), scram accumulator charging line stop check l valves, cannot be exercised during power operation since this would require depressurizing the scram charging header which could result in delayed J
i 19 I
recharging of the accumulators if a scram occurred. These valves will be exercised during cold shutdowns and refueling outages.
V-15-27 and V-15-28, control rod drive hydraulic system to reactor vessel check valves, cannot be exercised shut during power operation since the CRD hydraulic system must remain operable during power operation.
These valves will be exercised during cold shutdown when recirculation system tenperature and pressure permit safe inspection. These valves will be exercised at least on a refueling outage frequency.
- 4. Clean-Up Demineralizer System 4.1 Category A Valves V-16-1, V-16-2 and V-16-14, clean-up demineralizer system isolation valves, cannot be exercised during power operation since stopping and restarting this system would result in thermal transients on the RCS piping and components. These valves will be full stroke exercised during cold shutdowns and refueling outages.
4.2 Category A/C Valves V-16-62, clean-up demineralizer system return to reactor coolant sys-tem check valve, cannot be exercised shut during power operation since s stopping and restarting the flow through this system would result in ther-mal transients on the RCS piping and components. This valve will be verified shut during cold shutdowns (with pressure gage at sample station) and refueling outages (via leak testing).
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VII. ATTACHMENT III Below is a list of drawings and P&ID's utilized during the course of this review.
Drawing System Number Revision Isolation Condenser JCP- 19418 0 Poison JC P- 19419 0 Containment Spray JCP-19420 0 Reactor Recirculation JCP-19421 0 Core Spray JCP-19422 0 Main Steam JCP-19423 0 Condensate Transfer System JCP- 19424 0 Fire Protection JCP-19425 0 Misc. Class 1 and 2 System Penetrating Cont. JCP- 19426 0 Service and Emergency Service Water JCP-19427 0 Closed Cooling Water JCP- 19428 0 Hydraulic Control Unit JCP- 19429 0 Fuel Pool Cooling JCP-19430 0 21