ML20064H027
| ML20064H027 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/04/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20064H016 | List: |
| References | |
| TAC-53456, TAC-53457, NUDOCS 8301120482 | |
| Download: ML20064H027 (74) | |
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,'g UNITEO STATES l'
NUCLEAR REGULATORY COMMISSION a
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INSERVICE TESTING PROGRAM SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR' REACTOR REGULATION SUPPORTING AMENDMENT NO. 60 TO FACILITY OPERATING LICENSE NO. DPR-42 AND AMEN 0 MENT NO. 54 TO FACILITY OPERATING LICENSE NO. DPR-60 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND UNIT NOS. 1 & 2 DOCKET NOS.
50-282 AND 50-306 l
TABLE OF CONTENTS Page No.
- 1. 0 Introduction 1-1
1.1 Background
1-1 1.2 Discussion 1-2
- 2. 0 Pump Testing Program Evaluation 2-1 3.0 Valve Testing Program Evaluation 31 3.1 General Consideration 3-1 3.2 Specific Relief Requests 3-2 4.0 Conclusions 3 48 Appendix A (Affected Components Relief Request No. 57) 1 l
1 IST Program SER 8301120402 830104 PDR ADOCK 05000282 P
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1.0 INTRODUCTION
1.1 Backaround The revision to 10 CFR 50.55a, published in February 1976, required that Inservice Inspection and Testing (ISI/IST) Programs be updated to meet the requirements to the extent practical of the Edition and Addenda of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code
- incorporated in the Regulation by reference in paragraph (b).
This updating of the programs'was required to be done periodically, i.e., every forty months for inservice inspection and twenty months for inservice testing, to reflect the new requirements of the later editions of Section XI.
As specified in the February 1976 revision, for plants with Operating Licenses -
issued prior to March 1, 1976, the Regulations became effective after September 1, 1976, at the start of the next regular 40-month inspection period.
The initial inservice examinations conducted during the first 40-month period, and the initial inservice tests of pumps and valves conducted during the first 20-month period were to comply with the requirements in editions of Section XI and addenda in effect no more than 6 months prior to the date of start of facility commercial operation.
The Regulation recognized that the requirements of the later editions and addenda of the Section XI may not be practical to implement at facilities because of limitations of design, geometry, and materials of construction of components and systems.
It therefore permitted determinations of impractical examination or testing requirements to be evaluated and relief granted provided health and safety of the public were not endangered giving due consideration of the burden placed on the licensee if the ' requirements were
- Hereinafter referred to asSection XI.
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imposed. The Regulation also allows the Commission to require the licensee to follow an augmented inspection or testing program for which it deems that added assurance of structural or system reliability is necessary.
The revision to 10 CFR 50.55a, effective November 1, 1979, modified the time interval for updating ISI/IST programs and incorporated by reference a later edition and addenda of Section XI.
The updating intervals for inservice examinations and for inservice testing of pumps and valves were extended from 40 months and 20 months, respectively, to 120 months in order to be consistent with intervals as defined in Section XI.
Inservice examinations and inservice tests conducted during the initial 120-month interval are to comply with the requirements of the latest edition and addenda of Section XI, incorporated by reference in the Regulation, in effect 12 months prior to the date of issuance of the operating license.
For plants with Operating Licenses issued prior to March 1,1976, the provisions of the November 1,1979 revision are effective after September 1, 1976 at the start of the next one-third of the 120-month interval.
During the one-third of an interval and throughout the remainder of the interval, inservice examinations and inservice testing of pumps and valves shall comply with the latest edition and addenda of Section XI, incorporated by reference in the Regulation, on the date 12 months prior to the start of that one-third of an interval.
1.2 Discussion Our letter dated April 28, 1976 to Northern States Power (the licensee) called attention to the February 1976 revision to 10 CFR 50.55a and requested that we be notified of the dates that the next 40-month inspection period would begin.
In addition, our letter pointed out that the revised regulations require inservice inspection and testing to be performed in accordance with the examination and testing requirements set forth in Section XI and addenda thereto.
A review of the 1974 edition of ASME Section XI indicated that conflicts may occur between these requirements and the Technical Specifica-tions presently in eff.ect for the licensee's facility. To avoid these and
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. future conflicts, the licensee was advised, in accordance with 10 CFR 50.55a(g)(5)(ii) to apply to the Commission for amendment of the facility Technical Specifications. Further, any such conflicting Technical Specifi-cations should be replaced with a reference to 10 CFR 50.55a.
Sample language for such Technical Specification changes was provided.
The licensee was further advised that if it was determined that conformance with certain Section XI inservice inspection and testing requirements were impracticable, the licensee should submit information to support the deter-minations in accordance with 10 CFR 50.55a(g)(5)(ii) and (iv). The determinations should separately identify the specific Section XI requirement that is impracticable for each affected component. We indicated that the staff would evaluate each determination, and, if appropriate, grant relief pursuant to 10 CFR 50.55a(g)(6)(i).
The licensee was also advised that, as required by the revised regul.ations, requests for amendment of Technical Specifications and information to support determinations that conformance with certain Section XI requirements was impracticable were to be submitted at least 6 months prior to the start of the inspection period during which the provisions would become applicable for the facility.
By application transmitted by letters dated October 15, 1976 for Unit 1 and October 12, 1977 for Unit 2 the licensee requested changes to the Technical Specifications (TSs) appended to Facility Operating License Nos. DPR-42 and DPR-60 for the Prairie Island Nuclear Generating Plant Unit Nos. I and 2, respectively.
In addition to approving the modified IST program, these amendments would revise the TSs to incorporate the provisions of the approved program.
The Commission by letter dated November 14, 1980 issued Amendments No. 43^and
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37 revising the Technical Specification Inservice Inspection Program for components to meet the requirements of 10 CFR 50.55a.
This safety evaluation covers the pump and valve testing phase of the program known as Inservice Testing Program (IST).
By letters dated February 1, 1978, September 15, 1978, 1-3 IST Program SER
June 8, 1979, April 17, 1980, September 3, 1980, July 31, 1981 and December 23, 1981, the licensee submitted a complete revised IST program upon which we have based this review.
The licensee has determined that certain code requirements cannot be implemented at the facil4ty because of component or system design, geometry or material of construction.
Pursuant to 10 CFR 50.55a(g)(6)(1) the requested reliefs from the code requirements have been evaluated and our determinations to grant or deny the requests are documented below.
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2.0 PUMP TESTING PROGRAM EVALUATION
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2.1 The Licensee's Request for Relief from Measuring Pump Bearing Temperature Pursuant to-Section XI IWP3110, 3210 and 4310 (Relief Request No. 1)
Affected Components Safety Injection Pumps 51,12,21and22,ComponentCoolingPumps 11, 12, 21, and 22, Containment Spray Pumps 11, 12, 21, and 22, Diesel Driven Cooling Water Pumps 12 and 22, Residual Heat Removal Pumps 11, 12, 21, and 22, Control Room Chill Water Pumps 121, and 122.
Code Requirement The bearing temperature of all centrifugal pump bearings and main shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in temperature of bearing.
Measurements shall be made one per year.
Licensee's Basis for Relief There is no instrumentation installed to measure lube oil or bearing temperature.
Meaningful temperature data can be determined only with extensive equipment modifications (being able to monitor bearing metal temperature).
As the data is required only once a year these modifications are not' warranted.
Simpler modifications (such as measuring lube oil temperature or bearing housing temperature) would not provide data to any great degree of accuracy or relia-bility and using this data to judge the operability of the pump could cause operational problems in complying with limiting conditions for operation.
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Evaluation The licensee has shown that the design of these pumps does not permit meaningful measurement of bearing temperature' trend by lube oil or bearing housing. The licensee has agreed to measuring vibration velocity of these pumps monthly.
Because the frequency of measurement of this parameter and the code requirement to compare this parameter to reference values, it is judged that bearing degradation will be indicated sooner with vibration velocity measurements than bearing temperature.
Conclusion Based on the above evaluation, we agree with the licensee that measuring the bearing temperature is impractical.
The staff concludes that deletion of the bearing temperature measurement will not significantly decrease the capability of determining the pumps' mechanical condition or the plants' margin of safety.
Thus, this relief does not endanger public health and safety.
Therefore, relief from this requirement may be granted.
2.2 The Licensee's Request for Relief from Measuring Pumo Shaft Vibration Amplitude Pursuant to Section XI IWP-3110,-3210 and-4500 (Relief Request No. 2 Affected Components Same as those listed in 2.1 and Auxiliary Feedwater Pumps 11, 12, 21, and 22.
Code Requirement Vibration amplitude shall be measured during each inservice test, nominally at monthly intervals.
Licensee's Basis for Relief The vibration amplitude is considered inferior to vibration velocity manura-ments as a method of determining machine condition.
Evaluation The licensee has used ASME Publication 67-PEM-14, Vibration Tolerance for Industry and the base line vibration data established during the initial plant startup, as guides for establishing alert and required action ranges.
The alert and action ranges which the licensee has been applying since the ASME Section XI Code became effective are as follows:
Vibration Velocity Ranges Alert Range Action Range Vr <.1 in/sec Va >.20 in/sec Vm >.3 in/sec
.8 in/sec < Vr >.1 in/sec Va > Vr +.20 in/sec Vm > Vr +.3 in/sec Vm >_ 1.1 in/sec Vr >.8 in/sec where:
Vr is the measured vibration velocity in in/sec during pump testing.
Va is the alert range in in/sec when the licensee increases the surveillance frequency.
Vm is the action range in in/sec when the licensee declares the pump inoperable.
Notes:
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Vr >.8 in/sec are never exceeded at the Prairie Island Nuclear Generating Plants.
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Vibration values are unfiltered.
The test frequency will be as specified by IWP-3000. This relief request is under review by the staff in tnat further justification is required from the licensee.
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l 2.3 The Licensee's Request for Relief from Instrumentation Accuracy Requirements in Section XI IWP 4110 (Relief Request No. 3)
Affected Components Component Cooling pumps 11, 12, 21, and 22, Diesel Driven Cooling Water 12 and 22.
Code Requirements Flow instrumentation shall be accurate to within i 2%.
Licensee's Basis The presently installed flow instrumentation has a repeatability of i 12%.
Presently installed instrumentation is accurate enough to detect a change of mechanical or hydraulic condition.
Evaluation Both the diesel driven cooling water and component cooling systems'have over 100%
excess pumping capacity based on flow requirements during all operating modes (i.e. cold shutdown, hot standby, DBA, etc.).
In addition, the licensee is measuring pump differential' pressure, vibration velocity and rotative speed. Given the system excess pumping capacity and other parameters that are measured for.these pumps, the licensee concludes that the ability to detect a change of the mechanical or hydraulic condition is ensured. This relief request is under review by the staff in that further justification is reauired from the licensee,
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2.4 The Licensee's Request for Relief from Verifying Pump Operational Readiness as Required in Section XI IWP1000 (Relief Request No. 4)
Affected Compor,ents Diesel driven cooling water pump fuel oil transfer pumps 121 and 222; diesel generator fuel oil transfer pumps 121, 122, 123 and 124.
l Code Requirement The hydraulic and mechanical condition of a pump relative to a previous con-dition can be determined by attempting to duplicate by testing which establishes a set of reference parameters.
To detect change in hydraulic condition
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rotative speed, flowrate and differential pressure are measured, and to detect change in mechanical condition, vibration amplitude and bearing temperature are measured.
Licensee's Basis for Relief A performance test on the diesel driven cooling water or diesel generator fuel oil transfer pumps conducted in accordance with Section XI requirements are impractical and unnecessary for the following reasons:
(1) The fuel oil transfer pumps are submerged in approximately 10 feet of diesel oil and are not equipped with instrumentation for measuring bearing temperature or rotor vibration, j
(2) Pump discharge pressure is very low, approximately.2 psig, because of low l
1 resistance in the discharge line.
l (3) There are two fuel oil transfer pumps for each diesel engine.
Failure of one transfer pump will cause an alarm requiring manual start of the redundant transfer pump.
Between the failure of one pump and the start of the second pump there is in excess of five hours of supply of fuel oil in the day tank at the diesel engine.
(4) Each fuel oil transfer pump is test run at least once each month to verify the pump can supply adequate fuel to the diesel engine day tank.
(5) A flow rate of the transfer pumps requires draining and refilling the diesel day tank.
Such draining and refilling requires opening and closing categor[y "E'i valves. As an alternate test, an annual flow rate test of the transfer pumps will be performed when the diesel is out of service.
I Evaluation The licensee has committed to functionally test these pumps once per month and perform an annual flow rate test when the diesel is out of service for preventative maintenance.
In addition, the licensee has shown that the fuel transfer system has redundant pumps, five hours of reserve fuel in the e'/ent of r
a single pump failure and a malfunction alarm. Since the diesel driven cooling water and diesel generator fuel oil transfer pumps have malfunction alarms, fuel reserves, and redundancy, the licensee has judged that depletion of fuel oil in the day tank supplying fuel oil to diesel engines is unlikely. This relief request is under review by the staff in that additional justification i
is required from the licensee.
2.5 The Licensee's Relief Request from Locating Vibration Sensor Prescribed by Section XI IWP4510 and IWP4400 (Relief Request No. 23)
Affected Components Diesel Driven Cooling Water Pumps 12 and 22 l
Code Requirement IWP-4400 requires that the rotative speed of the pump shaft be measured for all pumps other than pumps directly coupled to motor drivers.
IWP-4510 requires that vibration be, measured on a bearing housing or its structural support.
Licensee's Basis for Relief The pump and pump shaf t, are not accessible to allow measurement of these parameters at this location.
Evaluation The design of the pump prevents direct access to pump and pump shaft for 4
measurement or vibration velocity and rotative speed. The licensee has agreed to measure these parameters using sensors placed on the diesel pump shaft at right angle drive unit and is part of the IST procedures.
Conclusion The staff considers that the licensee's alternate test procedure meets the intent of Section XI Code IWP-4400 and IWP-4510. On this basis relief may be granted from the sensor location requirements of the Section XI Code.
i 2.6 The Licensee's Relief Request from Determining the Pump Hydraulic Conditions as Required by Section XI IWP-3100-2 (Relief Request No. 24)
Affected Components Diesel driven cooling water pumps 12 and 22.
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Code Requirement The code requires measurement of inlet pressure, differential pressure and/or flow-rate and speed. The measurement of these parameters must meet the acceptable, alert, and. required action ranges outlined in IWP-3100-2.
Licensee's Basis for Relief The acceptance curve for the diesel driven cooling water pump is based upon Due to the large fluctuations in manufacturer's pump characteristics curve.
the cooling water flow and the inaccuracies of the instrumentation, the code recommended action range has been expanded. The range has been expanded from 90% (required by the Code) to 80% for the low value and from 103% (required by the Code) to 106% for the high value. Testing has demonstrated that the excess capacity of the cooling water system will allow the diesel cooling water pump to perform its safety function at the expanded ranges.
System design plus the varying cooling water loads do not allow performance of hydraulic tests at specific reference points as required by IWP-3110.
Because of the numerous system loading combinations possible it is not practical and is dangerous to plant operations to establish a specific reference point for the pump tests.
Evaluation This relief request is under review by the staff in that further justification from the licensee is required.
2.7 The Licensee's Relief Request from the Instrumentation Sensitivity Requirements for Measurina Flow Pursuant to Section XI IWP-4114 (Relief Request No. 25)
Affected Components Diesel Driven Cooling Water Pumps 12 and 22.
Code Requirement IWP4114 requires that flow measuring instrumentation meet the fluctuation requirement of 2%.
Licensee's. Basis for Relief Thepresentlyinstalledflowinstrumentationhasafkuctuation+4%whichis accurate enough to detect changes of mechanical or hydraulic conditions that would connote pump deterioration.
Evaluation and Conclusion Both diesel driven cooling water pumps have low flow alarms to alert the opera-tor of potential problems with the pumps.
In addition, the licensee measures pump differential pressure vibration velocity and rotative speeds. Given_the system low flow alarms and other parameters that are monitored, the licensee i
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has taken adequate measures to ensure detection of potential pump malfunction, j
On this basis we conclude that relief from the code may be granted which will not result in a reduction in the margin of safety.
2.8 The Licensee's Relief Request from Pressure Gauge Sensing Location as Required by IWP4200 (Relief Request No. 26)
Affected Components Diesel Driven Cooling Water Pumps 12 and 22.
Code Requirement i
Pressure taps shall be located in a section of the flow path that is expected to have reasonably stab,le flow as close as practical to the pump.
In addition, if a gauge line is such that the presence or absence of a liquid could produce a difference of more than 1/4% in the indicated measurement, means shall be provided to assure the presence or absence of liquid.
Licensee's Basis for Relief The pressure gauge tap location is close to elbows and a valve which cause turbulance thus preventing conformance with IWP-4212.
In addition, the gauge line does not conform with IWP-4210.
However, the errors introduced will not prevent us from measuring a pressure which will indicate a degradation in pump condition.
Evaluation Although the pressure tap locations do not meet the Section XI Code requirements, the pressure errors associated with the existing location'are minuscule as compared to the pressure drop that is being measured across the pump (i.e.,
approximately 100 psi is the pressure across the pump during testing vs.:1 or 2 psi pressure due to taps locations). In addition, any errors introduced because of these pressure tap locations are reasonably constant for periodic testing from which the accumulative data over time is use'd to determine any degraded condition of the pump. On this basis we agree with the licensee that such errors due to pressure tap locations will not prevent adequate pressure measurements to indicate degradation in pump performance.
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C'onclusion Based on the above evaluation, we conclude that the public health and safety will not be enhanced by modifying the system to meet the code. On this basis we conclude that relief from the c' ode may be granted.
2.9 The Licensee's Relief Request from Full Scale Instrument Range as Required by Section XI IWP4111 (Relief Request No. 33).
A,ffected Components Auxiliary Feedwater Pumps 11, 12, 21 and 22.
Code Requirement The full scale range of the instrument shall not be greater than four times the reference value.
Licensee's Basis for Relief The suction pressure gauge on the Auxiliary Feedwater Pump has a range of 0-150 psig.
The reference value can vary between 10 and 80 psig depending upon the sourde of water to the pump.
Normal source is 10 psig when the pump is tested.
Evaluation The normal source of water for the auxiliary feedwater pumps is the condensate storage tanks.
However, during a design basis accident, the auxiliary feedwater pumps take water from the cooling water system. The condensate storage tanks provide an inlet pressure of 10 psig and the cooling water provides an inlet pressure of 80 psig.
In order to allow measurement of inlet pressure from both sources, the full scale range of the instrument exceeds requirements of IWP-4111. To redesign the system to allow dual measurement capabilities would be an undue burden on 2-11 IST Program SER
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the licensee without significant increase in safety. The suction pressure gauge is used to measure the AP across the pump which is applied in deter-mining the adequacy of the pump characteristic.
Since the AP across the auxiliary feedwater pumps is approximately 1000 psi, the existing instrumen-tation accuracy is adequate for determining changes in the pump characteristics that would indicate.a. pump malfunction.
Conclusion We agree with the licensee that to modify the system is an undue burden and impractical and the level of plant safety will not be enhanced by redesign to meet the pressure gauge requirement of IWP 4111.
In addition, the public health and safety will not be enhanced by modifying the system to meet the code. On this basis we conclude that relief from the code may be granted.
2.10 The Licensee's Relief Request from Measurements of Pump Inlet Pressure as Prescribed by Section XI IWP-3110 and 3210 (Relief Request No. 40).
Affected Components Diesel Driven Cooling Water Pumps 12 and 22.
Code Requirement Inlet pressure shall be measured during each inservice test nominally once each month.
Licensee's Basis for Relief The pump suction is located in the cooling water intake and suction pressure indication is not available.
w Evaluation The licensee has proposed using the inlet bay level to determine inlet pressure.
This calculated value will then be used to determine the differential pressure of the pump.
The staff agrees that'the alternate testing program proposed by the licensee is adequate to determine both inlet pressure and differential pressure for the diesel driven cooling water pumps.
Conclusion Based on the above evaluation, we conclude that the alternate testing program is an acceptable alternative for measuring the pump inlet pressure and relief from the code does not endanger public health and safety. Therefore relief from this requirement may be granted.
i 3.0 VALVE TESTING PROGRAM EVALUATION
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3.1 General Conside' rations i
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3.1.1 Category A; Valves l
(1) All containment isolation valves are category "A" and shall be included in the inservice test program. Containment isolation valves prevent radioactive liquid and air from escaping the containment through lines i
which penetrate it.
As such, an important aspect of these valves is to form a leakage limiting barrier. Therefore, for the purpose of 10 CFR 50.55a(g), these valves have to be classified as category A valves.
(2) All category "A" valves shall be leak tested to Section XI requirements i
as required by 10 CFR 50.55a(g).
In general:
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For category A. valves that communicate only with containment atmosphere, Appendix J testing is sufficient to meet Section XI requirements.
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For category A valves that communicate with the primary coolant system, the leak test shall be performed at system functional j
pressure differential.
Exceptions to testing at system functional pressure differential are stated in Section XI and in this safety evaluation as noted in item 3.2.1.
The basis for testing at system
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functional differintial pressure is that these Containment Isolation Valves are relied upon to isolate primary coolant system for a i
loss-of-coolant accident outside containment.
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Containment isolation valves that are passive are relieved from t
quarterly stroke and stroke timing requirements of Section XI.
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The licensee has agreed to' include valves in the Appendix J testing program as j
category "A" valves in the Section XI valve testing program.
3.1.2 Cold Shutdown Testing Inservice valve testing at cold shutdown is defined as:
Valve testing should commence 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 plant is ready to return to power. Any testing not completed at the end of one cold shutdown should be performed during the subsequent cold shutdowns to meet the code specified testing frequency.
This point was discussed with the licensee and the licensee agreed to comply with the NRC position on cold shutdown valve testing.
3.2 Specific Relief Request's on the Inservice Inspection and Testing for Valves 3.2.1 The Licensee's Relief Request from Inservice Testing Category "A" Valves Performing a Pres;,ure Isolation Function IWV3420 (Relief Request No. 59)
Table 1 Affected components performing pressure isolation function Unit 1 Unit 2 32164 RH Suct FR LP A HL 32192 RH Suct Fr Lp A HC 32165 RH Suct FR LP A HL 32193 RH Suct Fr Lp A HC 32230 RH Su.ct FR LP B HL 32232 RH Suct Fr LLp B HC 32231 RH Suct FR LP B HL 32233 RH Suct Fr LLp B HC 32066 RH Rtn to CL 32169 RH Rt.n to CL SI-6-1 12 ACC Disch Check 25I-6-1 22 ACC Disch Check l
SI-6-2 11 ACC Disch Check 2SI-6-2 22 ACC Disch Check SI-6-3 11 ACC Disch Check 25I-6-3 21 ACC Disch Check SI-6-4 11 ACC Disch Check 2SI-6-4 21 ACC Disch Check SI-9-1 SI to LP B CL Check 2SI-9-1 SI to Lp B CL Check
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SI-9-2 SI to LP A CL Check 251-9-2 SI to Lp A CL Check 3-2 IST Program SER
o 51-9-3 Lo Head SI to Rx Vessel Check 2SI-9-3 Lo Head SI to Rx Vessel Check SI-9-4 Lo Head SI to Rx Vessel Check 251-9-4 Lo Head SI to Rx Vessel Check 51-9-5 Lo Head SI to Rx Vessel Check 251-9-5 Lo Head SI to Rx Vessel Check j
SI-9-6 Lo Head SI to Rx Vessel Check 2SI-9-6 Lo Head SI to Rx Vessel Check SI-16-4 SI to LP B CL Check 2SI-16-4 SI to Lp B CC Check SI-16-5 SI to LP A CL Check 2SI-16-5 SI to Lp A CC Check
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SI-16-6 SI to Rx Vessel Check 2SI-16-6 SI to Rx Vessel Check l
SI-16-7 SI to Rx Vessel Check 2SI-16-7 SI to Rx Vessel Check 31447 ACC After Check Test Valve 31459 ACC After Check Test Valve 31449 ACC After Check Test Valve 31461 ACC After Check Test Valve Code Requirement The code requires that valve seat leakage be measured by draining the line downstream of valve or by measuring the feed rate to maintain pressure IWV3420(d).
Licensee's Basis for Relief At our request, the licensee has submitted a listing of valves that perform a pressure boundary between the reactor coolant system and those systems having a design pressure below the reactor coolant system operating pressure. These valves are listed above for Units 1 and 2.
The licensee considered leak testing of these valves in accordance with IWV3420 of the applicable edition of the Section XI Code and prepared alternate testing methods for only those valves that because of the plant design and conditions during refueling outage, 1
cannot be tested by methods specified in IWV3420(d) of the Section XI Code.
f Therefore, all of the above valves listed in Table 1 are tested in accordance with IWV3420 except for those valves listed in Table 2 below. The licensee is requesting relief from the test methods specified in IWV3420(d) of the Section XI code regarding the leak rate measurement of the valve during the pressure testing. This alternate testing method gives an adequate assurance of the valves' ability to perform their intended function. The alternate test method applies to those isolation valves having pressure contact with the 3-3 IST Program SER
low pressure system that cannot be readily drained in order to measure leak rates as prescribed by IWV3420(d). The valves that fall into this category and for which relief is being requested are shown in Table 2.
Table 2
- Unit 1 Unit 2 32165 32193 32231 32233 SI6-1 2SI6-1 SI6-3 2SI6-3 32066 32169 Evaluation There are several systems connected to the reactor coolant pressure boundary that have design pressures below the reactor coolant system operating pressure. We have required that valves forming the interface between high and low pressure systems have sufficient redundancy to assure that the low pressure systems are not subjected to pressures which exceed their design limits.
In this role, the valves are performing a pressure isolation function.
It is our view that the redundancy provided by these valves regarding their pressure isolation function is important. We consider it necessary to provide assurance that the condition of these valves is adequate to maintain system integrity.
For this reason we believe that some methods, such as leak testing, should be used to assure their pressure isolation function.
The pipe lines connecting the reactor coolant systems at the Prairie Island Nuclear Generating Plant for Unit Nos. 1 and 2 with the low pressure systems contain at least two isolation valves in series, so that both valves must fail before the high pressure of the reactor coolant system is exposed to the low pressure systems.
In all cases the first valve isolating the reactor coolant system pressure is leak tested according to the requirements of Section XI IW3420 including measuring the leak rate as specified in IW3420(d).
I addition, the second redundant valves are also exposed to'the high pressure of the reactor system during testing but the licensee has requested relief from measuring the leak rate required by IWV3420(d) for these redundant second valves (listed in Table 2).that are exposed to pressure of the low pressure systems. In order to measure the leak rate across these second redundant valves acc'ording to the code, the low pressure systems must be drained which because of system design and system conditions during a typical refueling outage is impractical. As an alternate method for measuring the leak rate, the licensee proposes to monitor the pressure rise in the low pressure systems and monitor accumulator level changes during the leak testing period to measure the leak rate. The licensee's method of leak testing indicates that the inboard valves (i.ei RCS side valves) are first tested followed by leak testing the outboard valves (i.e. valve adjacent to low pressure systems). Based on our review, we requested the licensee to reverse the order at which these valves are leak tested in order to minimize valve operation after leak testing the inboard valves. This tratter has been dis-cussed with and agreed to by the licensee.
In addition, the licensee has agreed to apply the same leak rate criteria for the valves listed in Table 2 as that required by the technical specification (Section 4.3) for the primary coolant system isolation valves.
In the case where two check valves are in series with one motor operated valve which form the isolation barrier between the reactor coolant system and the low pressure systems, the Technical Specification requires the licensee to leak test this configuration more frequently than is required by the Section XI code. For these cases the licensee is to periodic leak test both check valves prior to resuming power operation after each time the plant is placed in the cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more if testing has not been accomplishedin the preceding 9 months and prior to' returning the valve to service after maintenance repair or replacement work is performed.
The licensee also performs a daily reactor coolant inventory analysis which serves as a leak test of the pressure isolation function of the first valves as a group that isolate the reactor coolant system from the low pressure systems.
The estimated error in this analysis is approximately 0.1 gallon per 3-5 IST Program SER l
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minute (GPM) due to the measuring instruments.
Typical leakage rates average from 0.1 to 0.5 GPM in each unit.
The Prairie Island Technical Specifications require the licensee to identify uncontrolled leaks that exceed 1.0 GPM i
within four hours or the reactor must be brought to hot shutdown and if the leak is not identified _within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the reactor is to be brought to cold shutdown. When the leakage sources are identified the licensee may continue to operate the reactor provided that results of an evaluation indicate that the operation can continue in a safe manner.
If however the leakage source exceeds 10 GPM the licensee must shut down the reactor and take corrective action.
Conclusion Based on the above evaluation, we have concluded that the licensee does have sufficient redundancy in the interconnecting lines to assure protection of the low pressure systems from the high operating pressure of the reactor coolant system.
In addition we consider that the licensee is providing reasonable assurance that the conditions of the high pressure isolation valves are adequately monitored to assure that system integrity is maintained.
Such assurance is based on the requirements imposed by the Technical Specifications and the periodic testing imposed by the Section XI Code as interpreted by the licensee.
On this basis the staff concludes the alternate test methods will give reasonable assurance that the valves will maintain the pressure isolation function as intended by the code and therefore relief may be granted.
In granting this relief we also conclude that the plant safety margin is not reduced and it does not endanger public health and safety.
1 3.2.2 The Licensee's Relief Request from Inservice Testing of Check Valve Exercising IWV3520(b)(2) (Relief Request No. 5)
Affected components Unit 1 Unit 2 SI-6-1 12 Accumulator Outlet Check 2SI-6-1 22 Accumulator Outlet Check SI-6-2 12 Accumulator Outlet Check 251-6-2 22 Accumulator Outlet Check SI-6-3 11 Accumulator Outlet Check 251-6-3 21 Accumulator Outlet Check SI-6-4 11 Accumulator 0'utlet Check 25I-6-4 21 Accumulator Outlet Check SI-9-1 Loop B Cold Leg Inj Check 251-9-1 Loop B Cold Leg Inj Check l
51-9-2 Loop A Cold Leg Inj Check 25I-9-2 Loop A Cold Leg Inj Check SI-9-3 RHR Exch to RV Check 251-9-3 RHR Exch to RV Check SI-9-4 RHR Exch to RV Check 251-9-4 RHR Exch to RV Check 51-9-5 RHR Exch to RV Check 251-9-5 RHR Exch to RV Check SI-9-6 RHR Exch to RV Check 2SI-9-6 RHR Exch to RV Check RH-3-3 12 RHR Pmp Dsch Check 2RH-3-3 22 RHR Pmp Dsch Check RH.-3-4 11 RHR Pmp Dsch Check 2RH-3-4 21 RHR Pmp Dsch Check SI-10-1 11 SI Pmp Dsch Check 2SI-10-1 21 SI Pmp Dsch Check SI-10-2 12 SI Pmp Dsch Check 251-10-2 22 SI Pmp Dsch Check SI-7-1 RWST to RHR Pmp Suct Check 251-7-1 RWST to RHR Pmp Suct Check SI-7-2 RWST to RHR Pmp Suct Check 251-7-2 RWST to RHR Pmp Suct Cneck CW-18-1 02 Dies Gen Cool Wat Sply Check 2CA-11-1 Caus Add to 21 & 22 CS Pmp CW-18-4 D1 Dies Gen Cool Wat Sply Check AF-15-12 22 Aux Fd Pmp Csch Check CA-11-1 Caus Add to 11 & 12 CS Pmp AF-15-11 21 Aux Fd Pmp Dsch Check ZH-2-1 121 Ch1 Wat Pmp Check 2MS-15-1 22 SG to 22 Aux Fd Pmp Check ZH-2-2 122 Chi Wat Pmp Check 2MS-15-2 21 SG to 22 Aux Fd Pmp Check AF-15-9 11 Aux Fd Pmp Dsch Check AF-15-10 12 Aux Fd Pmp Dsch Check RS-15-1 12 SG to 11 Aux Fd Pump Check RS-15-2 11 SG to 11 Aux Fd Pmp Check 3-7 IST Program SER
t
-l CS-18 11 Cont Spray Disch Check CS-48 21 Cont Spray Disch Check CS-19 12 Cont Spray Disch Check CS-49 22 Cont Spray Disch Check AF-15-1 Aux Fd to Sta Gen 11 Check-AF-15-7 Aux Fd to Stm Gen 21 Check AF-15-2 Aux Fd to Sta Gen 12 Check AF-15-6 Aux Fd to Sta Gen 22 Check AF-15-3 Aux Fd to Stm' Gen 11 Check,
AF-15-8 Aux Fd to Stm Gen 21 Check AF-15-4 Aux Fd to Stm Gen 12 Check AF-15-5 Aux Fd to Stm Gen 22 Check AF-16-1 Aux Fd to 11 Stm Gen Check AF-16-4 Aux Fd to 21 Stm Gen Check AF-16-2 Aux Fd to 12 Stm Gen Check AF-16-3 Aux Fd to 22 Stm Gen Check ZH-23-1 Lp A Chi Wat Sply Hdr X-Conn Zh-23-2 Lp B Chi Wat Sply Hdr X-Conn DCWP FO XFR Pmp Cks (2)
Code Requirements 4
Check valves will be exercised at least once every 3 months (IWV3520(a)) and check valve operability during exercising shall prove that the disk moves promptly away from the seat by measuring the change in pressure differential across the valve (IWV3520(b)(2)).
(1) Valves SI6-1, 2, 3, and 4: 2SI6-1, 2, 3, and 4 Licensee's Basis for Relief Stroking of the check valves during plant operation is not possible since flow through the check valve results in boration of the reactor coolant system.
Part stroking of the valves during each cold shutdown requires draining of the pressurizer and opening valves wh_ich are normally closed to prevent primary system overpressurization.
Evaluation and Consideration l
These valves cannot be exercised during normal operation, since it will disrupt the normal pressure control of the primary system including primary 3-8 IST Program SER
o water chemistry control. In addition, these valves cannot be exercised during cold shutdown since by doing so could over pressurize the reactor coolant system during cold conditions.
During refueling operation, with the Reactor Vessel Head removed, a flow pathfromthere'fuelingwaterstoragetank,throughthesafetyinjection
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The pump and through these accumulator check valves will be established.
flow rate through each valve will be measured and used as a baseline for The test is a partial stroke of the check valves.
subsequent flow tests.
However, adequate flow is passed through the check valves during stroke testing to assure that the valves open to a position which will allow 100%
of safety analyses flow under postulated accident condition. The licensee proposed to measure the rate of level change in the accumulators as a means of measuring flow through the valves during stroke testing. We agree with the licensee that these valves can be exercised by flow testing and exercising can only be performed during refueling outages because of plant conditions.
We have judged that exercising these valves other than during a refueling outage is imoractical and if attempted, the plant could be put into a less safe condition. In addition, we find that the public health and safety is not endangered by this proposed relief and on this basis the relief may be granted.
(2) Valves SI-7-1 and 2, 51-10-1 and 2: SI 9-1, -2,
-3,
-4, -5 and -6: 2SI-7-1 and 2, 251-10-1 and 2: 25-19-1,
-2,
-3,
-4,
-5, and -6 Licensee's Basis for Relief These valves cannot be exercised during normal plant operation nor during cold shutdown.
In addition pressure drop across these valves cannot be measured since proper instrumentation is not available.
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Evaluation and Conclusions These valves cannot be exercised during normal operation, since it will disrupt the normal pressure coritrol of the primary system including primary water chemistry control.
In addition, these valves cannot be exercised during'c~old shutdown sinc.e by doing so could over pressurize the reactor coolant system during cold conditions.
As an alternative, the licensee proposes to establish a flow path similar to "(1)" above during each refueling outage and the valves-will be exercised to show operability by measuring the flow rate passing through the valves.
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The flow is initiated by the safety injection pumps and measured by the existing flow measuring devices. Adequate flow passes through the valves during stroke testing to assure that the valves open to a position that will allow 100% of the safety analysis flow under postulated accident conditions.
We agreed with the licensee that these valves can be exercised by flow testing and exercising can only be performed during refueling outages because of plant conditions. We have judged that exercising these valves other than during a refueling outage is impractical and if attempted, the plant could be put into a less safe condition. We conclude that the public health and safety is not endangered by this proposed relief and on this basis relief may be granted.
(3) Valves RH3-3 and 4; 2RH3-3 and 4 Licensee's Basis for Relief l
l The code requires these valves to be, exercised by full stroking once every three months.
Full stroking of these valves can be achieved only when the reactor is in cold shutdown and Residual Heat Removal (RHR) system is in service.
.o Evaluations and Conclusion These valves are located on the RHR pump discharge line.
Full stroke exercising of these valves during normal plant operation would require injecting flow into the primary coolant system which is impossible, since the primary coolant system pressure is at much higher pressure than the pressure of RHR system.
However, these valves are partially stroked each month when the RHR pumps are run on minimum recirculation flow. The valves are full stroked each cold shutdown when the RHR system is used to cool down the reactor coolant system. We conclude that the public health and safety is not endangered by this proposed relief and on this basis relief may be granted.
(4) Valves CW18-1 and 4
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These valves are full stroked at a minimum of once each month when the diesel generator is run for surveillance testing.
Relief from fullstroking these valves is not necessary since the licensee is meeting the requirements of the Section XI Code (IWV3520(a)(b)).
(5) Valves CA-11-1, 2CA11-1 1
Licensee's Basis for Relief P
The check valve is part stroked each cold shutdown by running demineralized water through the check valve to a floor drain. The valve cannot be full i
stroked because flow is limited by the size of floor drain (3/8" valve).
l The valve cannot be partially stroked quarterly since this would remove j
the redundant supply of caustic solution to the containment spray pumps.
Evaluation and Conclusion i
These valves are located on the caustic addition line to the containment spray pumps.
Full stroke testing would require feeding solution in caustic' addition standpipes through the containment spray pumps and I
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cleaning solution from pumps after the test. The performance of such a test is not considered practical nor would the test. result in a significant increase in safety of the plant.
As an alternate Ineans of testing, the licensee has proposed part stroking these valves each cold shutdown.
In addition, to assure the valve operability, the licensee has proposed to inspect the valve internal parts during the first refueling outage for each unit after the issuing date of this amendment. The inspection of the valve internals will be repeated during each refueling outage so long as the inspections reveal defective valve parts. The 1-icensee also proposed that if the inspections 'show that the internal valve parts are adequate to perform their intended function, then the inspection interval will be lengthened to every 5th refueling outage. In addition, if inspection during any of the 5th re-fueling outages show defective valve parts, the inspection interval will revert back to each refueling outage so long as the inspections reveal defective valve parts. We find the licensee's proposal for inspectiog the valve internals every refueling outage acceptable. We have however deferred our decision lengthening the inspection interval beyond every refueling outage until a technical basis can be established.
In order to resolve this matter the licensee has agreed to furnish the staff the inspection results of the initial valve inspection so that an adequate inspection interval can then be established. On this basis we agree that the alternate testing procedure and valve inspections will adequately demonstrate valve operability. On this basis we conclude that the public health and safety is not endangered by the proposed relief and therefore the relief may be granted.
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(6) Valves ZH23-1 and 2; ZH 2-1 and 2 full flow through these valves is verified continuously or at least monthly when the chilled water pump is in operation.
Failure of the
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valve to stroke'to the position required for the system to perform its function would cause a system malfunction and initiate alarms. Verifying full flow is judged as a positive means of confirming that the disk moves away from the seat. We conclude that relief from full stroking these valves as prescribed by IWV3520(a)(b) of the Section XI code may be granted.
(7) Valves AF15-9 and 10; AF15-11 and 12 These valves are stroked to a position required for the system to fulfill its safety function. Adequate flow is measured through the valve on a monthly interval to assure a proper stroke function. Relief for full stroking as crescribed by the requirements of Section XI Code IWV3520(a)(b) for these valves may be aranted since the valves are stroked to a position for the system to fulfill its safety function.
(8) Valves AF16-1 and 2; AF15-1, 2, 3 and 4; AF16-3 and 4; AF 15-5, 6, 7, and 8 Licensee's Basis for Relief These valves are stroked each refueling shutdown to a position required for the system to perform its safety function.
This is accomplished by 3 '13 IST Program SER i
measuring flow through the check valves while the auxiliary feedwater pump is discharging to each steam generator.
The valves cannot be partial or full stroked quarterly sinc'e this causes thermal shocking of the auxiliary feedwate_r lines as they enter the steam generator'.
Stroking these valves requires cycling of category E valves, the mispositioning of which causes a compromise of the safety function of the system.
Such risk is not warranted by increasing the stroke interval of these valves.
Evaluation and Conclusion These valves are full stroked during each refueling out' age when the auxiliary feedwater pumps are tested.
Flow through these valves to the steam generator is measured..In addition, these valves are cycled each time the plant is brought to cold shutdown and each time the plant is taken out of cold shutdown so there is no need to exercise these valves during cold shutdown. The staff agrees that measuring flow through these valves is sufficient to confirm that the disk has, moved away from the seat.
In addition we agree with the licensee that an undue safety risk would exist if the stroke interval is increased. On this basis we conclude that relief from the Section XI Code may be granted.
(9) Valves RS15-1 and 2; 2MS15-1 and 2 Licensee's Basis for Relief These valves are open prior to going to cold shutdown to a position required for the system to fulfill its safety functions. Sufficient steam passes through the checks to allow the turbine-driven auxiliary feedwater pump to discharge safeguard flow.
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Evaluation and Conclusion These check valves are located on the steam line to the steam-driven auxiliary feedwater pump. During the monthly surveillance test run of the turbine driven auxiliary feedwater pump, these valves pass sufficient steam for the pump and turbine to pass their periodic test.
If these valves fail to operate properly, the monthly pump test would detect the failure.
j We, therefore, agree that the monthly, and the cold shutdown period test of the auxiliary feedwater pump is an adequate alternative means of verifying the operqtional readiness of these valves. On this basis we conclude that relief from the Section XI Code may be granted.
(10) Valves CS18 and 19; CS48 and 49 Licensee's Basis for Relief These valves are part stroked during cold shutdown and refueling outages by measuring water discharging from a vent valve upstream of the check valve.
The valve cannot be stroked quarterly since this requires taking a containment spray pump out of service.
Evaluation and Conclusion Due to the piping configurations, check valves CS-18, CS-19, CS-48 and CS-49 cannot be stroked without spraying large amounts of water into the reactor containment.
These valves can only be part stroked using vent lines during cold shutdown and refueling outages.
The licensee has demonstrated that full stroking these valves is impractical, and that part stroking during cold shutdown and during each refueling outage offer some assurance on the operability of the valve. However, to fur-ther assure valve operability, the licensee has proposed to inspect the valve internal parts during the first refueling outage for each unit 3-15 IST Program SER
after the issuing date of this amendment. The inspection of the valve internals will be repeated during each refueling outage so long as the inspections reveal defective valve parts. The licensee also proposed that, if the inspections show that the internal parts are. adequate to perform their intended function, then the inspection intervalwillbelengthenedtoehery5threfuelingoutage.
In addition,
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if inspections during any of the 5th refueling outages show defective valve parts, the inspection interval will revert back to each refueling outage so~long as the inspections reveal defective valve parts. We find the licensee's proposal for inspecting the valve internals every refueling outage acceptable. We have however deferred our decision on lengthening the inspection interval beyond'every refueling outage until a technical basis can be established. In order to resolve this matter the licensee has agreed to furnish the staff the inspection results of the initial valve inspection so that an adequate inspection interval can be established. On this basis we conclude that relief from the Section XI Code may be granted.
(11) Valves DCW and DG (Fuel Oil Transfer Pump Check Valves)
These valves open to a position required for the system to perform its safety function monthly.
Should a check valve fail to exercise, the system would malfunction and an alarm condition would result.
The exercise test is performed at least monthly during transfer of oil from the fuel oil storage tanks'to the diesel engine day tanks. The licensee is meeting the requirements of the Section XI Code.
Since these valves are exercised monthly to an open positicn required for the system to perform its intended safety function, relief from the code may be granted.
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o 3.2.3 The Licensee's Relief Request from Check-Valve Exercising Durina Cold Shutdowns IWV3520(b) (Relief Request No. 7)
Affected components Unit 1 Unit 2 SI-6-1 12 Accumulator Gutlet Check 2SI-6-1 22 Accumulator Outlet Check SI-6-2 12 Accumulator Outlet Check 2SI-6-2 22 Accumulator Outlet Check SI-6-3 11 Accumulator Outlet Check 25I-6-3 21 Accumulator Outlet Check SI-6-4 11 Accumulatoc Outlet Check 2SI-6-4 21 Accumulator Outlet Check i
SI-9-1 Loop B Cold Leg Inj Check 25I-9-1 Loop B Cold Leg Inj Check i
SI-9-2 Loop A Cold Leg Inj Check 2SI-9-2 Loop A Cold Leg Inj Check SI-9-3 RHR Exch to RV Check 251-9-3.RHR Exch to RV Check SI-9-4 RHR Exch to RV Check 2SI-9-4 RHR Exch to RV Check SI-9-5 RHR Exch to RV Check 2SI-9-5 RHR Exch to RV Check SI-9-6 RHR Exch to RV Check 2SI-9-6 RHR Exch to RV Check SI-16-4 Loop B Cold Leg Inj Check 251-16-4 Loop B Cold Leg Inj Check SI-16-5 Loop A Cold Leg Inj Check 25I-16-6 Loop A Cold Leg Inj Check SI-16-6 RV Inj Line Check 2SI-16-5 RV Inj Line Check SI-16-7 RV Inj Line Check 2SI-16-7 RV Inj Line Check Code Requirement The code requires that if check valve exercising (full stroking) is not practical j
during plant operation, then the vhlves should be part stroke exercised during
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plant operation and full stroke exercised during cold shutdown (IWV3520(b)).
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s Relief Request No. 7 is addressed as part of Relief Request Nc. 5 hich appears in this SER as items 3.2.2(1) and (2). Based on the safety evaluation ofs items 3.2.2(1) and (2), we conclude the ralief may.be granted which also applies to this relief request.
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The Licensee s Relief Request from Valve Exercisinc/ at Cold
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3.2.4 Shutdown IWV3520(b) (Relief Request No. 8)
S*
,s Affected components
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Unit,2-Unit 1 MV-32074 Saf Inj RV Inj Isol MV-32177 Saf Inj P,V'Inj;Isol MV-32075 11 Cntmt Smp B Isol Al MV.-32178 21 Cntmt Smp B Isol Al
'j MV-32076 11 Cntmt Smp B Isol A2 is-32179 -21 Cntk.t'Smp B'-15o1 A2 MV-32077 11 Cntmt Sump B Isol B1 MV-3218021MbtmtSmpBIsolB1 MV-32078 11 Cntmt Smp B Isol B2 MV-32181 21 Cntat Smp B Isol 82
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MV-32067 Saf Inj RV Inj Isol MV-32170 Saf Inj RV,Inj Isol
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MV-32069 Saf Inj RV Inj Isol A MV-32172 Saf Inj RV'Inj Isol A MV-32162 11 Saf Inj Pmp Suct Isol MV-32190 21 Saf Inj Pmp Suct Isol MV-32163 12 Saf Inj Pmp Suct Isol MV-32'191>22 Saf Inj Pmp Suct Isol MV-32206 RHR Exch to 11 Saf Inj Pmp MV-32208 RHR Exch to 21 Saf Inj Pmp MV-32207 RHR Exch to 12 Saf Inj Pmp MV-32209 RHR'Exch to 22 Saf Inj Pmp MV-32202 Saf Inj Test to 11 RWST A MV-32204 Saf Inj Test to 21 RWST A MV-32203 Saf Inj Test to 11 RWST B MV-32205 Saf Inj Test to 21 RWST B' MV-32096 11 Cntmt Spr Pump Suct from RHR Exch MV-32108 21 Cntmt'Spr Pump Suct from RHR Exch MV-32097 12 Cntmt Spr Pump Suct from RHR Exch MV-32109 22 Cntmt Spr Pump Suct from RHR Exch MV-32103 11 Cntmt Spr Pmp Disch MV-32114 21 Cntmt Spr Pmp Disch MV-32105 12 Cntmt Spr Pmp Disch MV-32116 22 Cntmt Spr Pmp Disch MV-32098 11 Cntat Spr Pmp Suct from RWST MV-32110 21 Cntmt Spr Pmp Suct from RWST MV-32099 12 Cntmt Spr Pmp Suct from RWST MV-32111.22 Cntmt Spr Pmp Suct frcm RWST 3-18 IST Program SER.
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e Code Requirements v
s.
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Valvr:s shall be ex'ercksed' at least[ once every 3 months to the position required s
to fc41 fill-their function unless such operation is not practical during plant operht'iciIWV3410(a),,_(b).
'(1) Valvas MV32074 and MV32177 Lii:ensee's Basis for RelMf Thes'e valves are'raquired to be closed for overpressurization protection ofthetReactorCcolantSyste'mduringcoldshutdownand,therefore,are i
no't stfoked each cold shutdoin. The valves are not stroked quarterly sinceithevalyesaretolbeintheopenpositionfornormalsystemoperation.
Evaluation and Concl'usion-s These valves are cated. cn the reactor vessel injection line and are requ' ired to'be open_during normal operation to allow the safety injection syste;n to.cperate properly.
During a cold shutdown these valves are
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required to be closed'to protect the reactor coolant system from over-pressurization. ~'Since operation of these valves during normal operation or cold shutdown could place -the plant in an unsafe condition, the staff agrees that.duti~to systect design these valves can only be exercised du. ring refueling outages _which is required by the licensee's existing
' program-On this basis we conclude that the public health and safety is not endangered by the proposed relief and therefore the relief may be granted.
(2) Valves MV 32075, 76, 77 and 78; MV32178, 79, 80, and 81 Licensee's Basis for Relief Stroking these valves requires removal of both safety injection pumps l
from service since there is'no minimum flow protection for the pump.
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3 Evaluation and Conclusion These valves are located on the containment sump line and serve a dual purpose.
During initial LOCA' conditions, these valves are closed to provide containment isolation. During the recirculation phase, these valves open to provide emergency core cooling recirculation. The above valves contain interlocks associated with valves MV-32204 and MV-32205, g
which isolate the nonsafety-related portion of the Safety Injection d
i System test line.
Bypassing the interlocks between the valves on the containment sump and MV-32204 and MV-32205 removes the:sninimum flow j
protection for the. safety injection pumps. We, therefore, agree with the
.-j licensee that due to plant design these valves will be cycled during refueling. On this basis we conclude that relief from this code requirement for these valves may be granted.
(3) Valves MV32067 and 069; MV32170 and 172 I
Licensee's Basis for Relief 5
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These valves are normally closed.
Emergency procedures call for these q
valves to open following a loss of coolant accident to provide an additional j
flow path to the reactor vessel for safety injection flow (through the p
upper plenum region injection nozzles).
A potential operator error could lead to spurious signal of safety injection which will result in thermal 3
shock to the reactor vessel when these valves are cycled during normal r
operation.
Evaluation and Conclusion
=
{i We agree with the licensee that exercising these valves during normal j
i operation would place the plant in a less safe condition during the valve exercising operation, and therefore this requirement is impractical for these valves.
However, after discussing this matter with the licensee, he has' agreed to full stroke exercise these valves during cold shutdown conditions and during the refueling outages.
On this basis we conclude e
that the relief may be granted.
(4) Valves MV32162 and 163; MV32190 and 191 Licensee's Basis for Relief These valves are normally open and they are closed when the ECCS system is lined up for recirculation phase to permit the SI pump suctions to be supplied with recirculated water from the RHR pumps.
If one valve were to stick closed during testing, one SI pump would become inoperable.
During the test, it would be necessary to deenergize the associated SI pump to prevent damage in the. event of a spurious actuation signal while the suction valve was closed.
Evaluation and Conclusion We agreewith the licenses that cycling these valves during normal plant operation.would place the plant in a less safe condition, since during the cyciing operation, the valve removes one of the two safety injection pumps from potential service.
The present IST program requires the licensde to cycle these valves during each refueling outage.
However the licer,See has committed to exercising these valves during cold shutdown and durinc each refueling outage. On this basis we conclude that relief from the code requirement for cycling these valves during norrral operation may be granted.
(5) Valves MV32206, 32396, 097 and 32207; MV32208, 108, 109 and 209 Licensee's Basis for Relief
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During initial staget Ef-injection phase of ECCS operation, Safety Injection (SI) pumps inject cor.c.entrated boric acid from boric acid tanks.
Suction valves to boric acid tanks open automatically on an SI signal.
valves to RHR heat exchangers must remain closed to permit boric acid tanks to be drawn down.
If these valves were open, SI' pumps would be supplied frca the refueling water storage t,an_k and not from the boric acid tank and initial injection of concentrated boric acid would not occur.
Evaluation and Conclusion For proper operation of the safety injection system, these valves are required to be locked closed by Plant Technical Specifications during power operation.
If valves were cycled during cold shutdown, the RHR system would inject into the SI system. We agree with the licensee that if these valves are cycled during normal operation or cold shutdown, the plant would be placed in a less safe condition due to system design.
Thus we find cycling these valves during refueling outages is acceptable.
On this basis we conclude that relief from the code requirement of cycling these valves more often than each refueling outage may' be oranted.
(6) Valves MV32202 and 203; MV32204 and 205 Licensee's Basis for Relief Exercising these valves removes the mini flow protection on the safety injection pumps, therefore, taking both safety injection pumps out of service and placing the plant in a less safe condition.
Evaluation and Conclusion s
These valves are located on the safety injection test line and are interlocked with containment sump valves MV-32178, MV-32179, MV-32180 MV-32181, MV-32075, MV-32076, MV-32077 and MV-32078 to ensure pro-per isolation of the nonsafety-related portion of the test line.
Strnkinn these valves during normal plant Operation would re*OVe the minimum flow nrotectinn lino from service and Dlace the plant 3-22 IST Program SER
o in an unsafe condition. We agree with the licensee that exercising these valves during normal operation would place the plant in a less safe condition during the exercising operation and therefore this requirement is impractical. However afte'r discussing this matter with the licensee, he has agreed to_ full stroke these valves during cold shutdown and during refueling outages. On this basis we conclude that the licensee is meeting the intent of the code and therefore relief from exercising these valves as required by the code may be granted.
(7) Valve MV32103 and 105; MV32114 and 116 Licensee's Basis for Relief MV-32103 and MV-32105 (MV-32114 and MV-32116 in. Unit No. 2) are normally closed valves which receive automatic opening signals on containment high-high pressure. These valves can be exercised only by disconnecting the controls through the use of electrical jumpers and by removing the associated containment spray pump form service by requiring the closure of a Category E valve.
Evaluation and Conclusion Exercising these valves during normal operation will place the plant in a less safe condition and the only practical frequency for exercising these valves is during cold shutdown or refueling outages. Placing electrical jumpers on controls during plant operation is not a prudent operating practice. However, the licensee has committed to exercise these valves during cold shutdown and during each refueling outage. On this basis we agree with the licensee.that based on the system design, exercising these valves during cold shutdown and refueling outages is acceptable. Therefore relief from the code requirement regarding exercising these valves during normal operation may be 1
i granted.
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(8) Valves MV32098 and 99 and MV32110 and 111 Licensee's Basis for Relief Exercising these -valves requires the use of electrical jumpers and closing electrical breakerswhich are required to be opened by the Technical Specifications. Testing these valves would interrupt suction flow for the containment spray pump which must be continuously supplied which is also a Technical Specification requirement. Testing these valves is impractical except at refueling outages.
Evaluation and Conclusion Based on our review of the containment spray system and its associated controls, we agree with the licensee's basis for relief.
In addition, if exercising these valves by the code is followed, the licensee would place the plant in an unsafe condition since the licensee would be removing a safety related system from service which is a Technical Specification violation.
Exercising these valves during refueling outages is the only prac-tical time during which these valves can be exercised. On this basis we have l
judged that exercising these valves during refueling outages is acceptable.
Therefore relief from the code requirement regarding exercising these valves other than the refueling outages may be granted.
3.2.5 The Licensee's Relief Request from Stroke Time Power Operated Valves IWV3410(c) (Relief Request No. 9)
Affected components Unit 1 Unit 2
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l SV-33133 Clg Water to 121 Safeguards Travel Scrn SV-33992 21 Post LOCA H Containment Vent 2
Containment Vent SV-33134 Cig Water to 122 Safeguards Travel Scrn SV-33993 22 Post LOCA H2 SV-3346412 DC1 Water Pump Air Motor SV A CV-31683 21 TD Aux Fd Pmp 011 Cir Wtr_Init SV-3346512 DC1 Water Pump Air Motor SV B CV-31684 22 TD Aux Fd Pmp Oil Cir Wtr Init SV-33466 22 0C1 Water Pump Air Motor SV A i
SV-33467 22 DC1 Water Pump Air Motor SV B CV-31954 D1 Diesel Generator Air Start A CV-31955 D1 Diesel Generator Air Start B CV-31956 D2 Diesel Generator Air Start A '
CV-31957 D2 Diesel Generator Air Start B SV-33990 11 Post LOCA H2 Containment Vent '
SV-33991 12 Post LOCA H2 Containment Vent CV-31423 12 DC1 Water Pump Jckt Clr Outlet CV-31457 22 DC1 Water Pump Jckt Clr Outlet CV-31682 12 TD Aux Fd Pmp 011 Clr C1g Wtr Init CV-31681 11 TD Aux Fd Pmp 011 tir C1g Wtr Init SV-33728 121 Cont Room Water Chlr Mtr Cir SV-33766 122 Cont Room Water Chlr Mtr Clr Code Requirement The stroke time of all power operated valves shall be measured to the nearest second or 10% of the maximum allowable time, whichever is less, IVW3410(c)(2).
Licensee's Basis for Relief All the valves in this Request for Relief have a operating time of less than one second.
A valve failure except for valves SV-33990, SV-33991, SV-33992 and SV-33993 is detected quickly by associated equipment parameters. The equipment requiring proper operation of these valves are tested on a monthly basis. These monthly tests check the valve operation necessary to support the equipment. Parameters such as low pressure, high temperature, or failure to start would indicated to the operator that a problem exists. The fast valve operation, the inaccessible valve stem in some cases, and the assoicated equipment parameters being moni-tored to indicate valve malfunction makes it impractical and unnecessary to l
check these valves' stroke time as required by IWV-3410(c).
The valves SV-33990, SV-33991, SV-33992 and SV-33993 do not have associated equipment parameter for detection of failure. These valves operate whenever 3-25 IST Program SER
a.-
a its associated motor operated valve is opened to provide a flow path for makeup air to containment when feeding and bleeding to remove hydrogen. These motor operated valves were exe:npted from testing because they are containment isolation valves and tested per Appendix J.
The motor operated valve numbers are MV-32274, MV-32276, MV-32293 and MV-32295.
j Evaluation and Conclusion All of the affected valves have stroke times of approximately one second or less which are considered fast acting valves.
In addition failure of these valves to open will be made known to the operator by either alarms, rise in j
motor bearing temperature, or changes in hydraulic conditions of system. All of the above listed valves related to safety are required by the Technical i
Specifications to be functionally checked on a monthly basis. This relief request is under review by the staff in that additional justification is required from the licensee.
]
3.2.6 The Licensee's Relief Request from Valve Exercisino (IW3410(d))
(Relief Request No. 10)
I Affected components i
J Unit 1 Unit 2 CV31652 CV31654 CV31653 CV31655 l
Code Requirement Valves that operate at a frequency which would satisfy the exercising require-ments of IW-3410 provided that the observations required for testing are analyzed and recorded at intervals no greater than IW-3410(a) are exempt from testing requirements of IW-3410.
Licensee's Basis for Rel,ig These valves operate at a frequency greater than required by IW-3410(a). Any malfunction is immediately known because of associated alarms.
Evaluation and Conclusien The system is continuously monitored and the valves are exercised at a greater frequency than what is prescribed by the code. In addition, the licensee has committed to performing observations described by IWV 3410(d), analyzing the results during operation and record the results at least once every 3 months.
The licensee is therefore, meeting the code requirements for these valves and relief is not required.
3.2.7 The Licensee's Relief Request from Valve Exercisina IWV3520(a)(b)
(Relief Request No. 11)
Affected components Unit 1 Unit 2 SI-7-1 RWST to RHR Pmp Suct Check 251-7-1 RWST to RHR Pmp Suct Check SI-7-2 RWST to RHR Pmp Suct Check 2SI-7-2 RWST to RHR Pmp Suct Check Code Requirement Check valves shall be exercised once every 3 months (IWV3520(a)) or during cold shutdown (IWV3520(b)).
Licensee's Basis for Relief Exercising these valves at cold shutdown requires removal of one loop of RHR system frora service and reduces system redundance.
Evaluation and Conclusion Cycling these valves requires operation of the RHR system. During power opera-tion, these valves cannot be cycled because they cannot overcome RCS pressure.
The valves cannot be cycled during cold shutdown because of an increase possi-bility of overpressurizing the RHR system and the removal of one redundant loop of the RHR system from service. Based on this evaluation, we agree with the licensee that because of the system design, these valves can only be l
tested during the refueling outage. Therefore we conclude that relief from the code to ejercise these valves other than when the plant is in a refueling outage may be granted.
m.
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i 3.2.8 The Licensee's Relief Request from Valve Exercisino Frequency IWV3520(b)
(Relief Request No. 12)
Affected components Unit 1 Unit 2 SI-10-1 11 SI Pump Discharge Check 251-10-1 21 SI Pump Discharge Check SI-10-2 12 SI Pump Discharge Check 2SI-10-1 22 SI Pump Discharge Check AF-15-1 Aux Feed to Steam Generator 11 Check AF-15-7 Aux Feed to Steam Generator 21 Check AF-15-2 Aux Feed to Steam Generator 12 Check AF-15-6 Aux Feed to Steam Generator 22 Check AF-15-3 Aux Feed to Steam Generator 11 Check AF-15-8 Aux Feed to Steam Generator 21 Check AF-15-4 Aux Feed to Steam Generator 12 Check AF-15-5 Aux Feed to Steam Generator 22 Check AF-16-1 Aux Feed to 11 Steam Generator Check AF-16-4 Aux Feed to 21 Steam Generator Check AF-16-2 Aux Feed to 12 Steam Generator Check AF-16-3 Aux Feed to 22 Steam Generator Check Code Requirements Check valves shall be exercised at least once every 3 months (IWV3520(a)) or during cold shutdown (IWV3520(b)).
(1) Valves SI-10-1 and 10-2; 2SI-10-1 and 10-2 Licensee's Basis for Relief Exercising these valves at cold shutdown requires removal of safeguards equipment from service and excessive system or component manipulation in order to establish the proper test conditions. Th,is coupled with the possiblity of errors in the restoration of safeguards equipment or the occurrence of an event with abnormal system line-ups could result in
\\
unsafe operation of the plant which is not warranted for the type of' testing to be accomplished.
Evaluation and Conclusion These check valves are located on the discharge side of the safety injection pumps.
Exercising these valves during power operation requires 3-28 IST Program SER
manually opening and closing of SI-20-16 and 2SI-20-16. In addition, l
exercising these valves during cold shutdown requires open valves which must be closed to protect the. reactor system against overpressurization as required by the Technical Specification for the protection of the minimum fracture toughness (PTndt) under Appendix G of 10 CFR Part 50.
On this basis if-these valves were tested during cold shutdown, the plant would be placed in an unsafe condition. We conclude therefore that these valves can only be tested during refueling outages in order to maintain an adequate level of safety.
Thus relief from the code to exercise these valves at refueling outages may be granted.
(2) Valves AF15-1,
-2,~-3 and -4; AF16-1 and -2; AF15-5,
-6,
-7 and -8; i
AF16-3 and 4 I
The exercising requirements of the Code IW3520(b) for these valves are addressed under item 3.2.2 part 8 which concludes that relief may be f
granted.
3.2.9 The Licensee's Relief Request for Verifying the Relief Valve Setpoint (IW3510a) (Relief Request No.13)
Affected components i
Unit 1 Unit 2 RH8-1 RHR Pump Suct. Relief 2RH8-1 RHR Pump Suct. Relief Code Requirements l
Relief valves shall be tested at the end of each time period as defined in Table IW-3510-1.
Normally the number of valves shall be:
l 1
l l
I i
o Time period Number of valves to be tested Startup through first refueling Minimum of N 1/60 total valves 2
in this category First refueling,_
Additional valves to make cumulative testing at least N 1/60 x total through second refueling
, valves in this category 2
Second refueling through Additional valves to make cumulative third refueling testing at least N /60 x total 3
valves in this category etc.
etc.
Licensee's Basis for Relief Isolation and removal of this valve, or testing in place, to verify the setpoint of the valve will remove both loops of the RHR system from service.
The valve will be tested whenever the core is unloaded.
Evaluation The RHR system is necessary for safe plant operation during all modes of reactor operation except when the reactor core is unloaded. We agree with the licensee that due to system design this valve be tested only when the reactor core is unloaded.
This occurs once every 10 years. On this basis we conclude that relief from the code for these valves may De granted.
3.2.10 The Licensee's Relief Request for Valve Exercising IWV3520(b)
{3eliefRequestNo.14)
Affected components Unit 1 Unit 2 RH6-1 Ltdn line check-2RH6-1 Ltdn Line Check 1
s~
I Code Requirement Check valves shall be exercised at least once every 3 months (IWV3520a) or during cold shutdown (IWV3520b).
Licensee's Basis for Relief Installation of the valves is such that it cannot be adequately exercised during normal plant operation.
Isolation of the valves for exercising requires removal of letdown line and one loop of RHR system from service.
Evaluation and Conclusion Isolation of these valves for testing would remove the letdown line and one loop of RHR system from service.
Removing the letdown line from service would remove control of the reactor coolant chemistry. Maintaining primary water chemistry is important from the standpoint of protecting sensitive materials throughout the On this reactor coolant system, including the cladding of the fuel assemblies.
basis, we conclude that testing this line during plant operation or during cold shutdown is impractical. We therefore agree with the licensee that these valves On this basis we conclude will be exercised only during each refueling outage.
relief from the code requirement may be granted.
3.2.11 Licensee's Relief Request from Verifyina Remote Position Indication IWV-3300 (Relief Request No. 16)
Affected components Unit 1 Unit 2 MV-32075 11 Containment Sump B Isolation Valve Al MV-32178 Containment Sump B Isolation Valve MV-32076 11 Containment Sump B Isolation Valve A2 MV-32179 Containment Sump B Isolation Valve Code Requirement All valves with remote position indicators, which during plant operation are inaccessible for direct observation, shall be visually observed at the same (or greater) frequency as scheduled refueling outages but not less than once every two years.
--.x.
O Licensee's Basis for Relief i
The valves are enclosed by valve enclosures which are part of the containment barrier.
It is not considered practical to disassemble these enclosures to verify correct position indication.
Proper positioning will be verified by exercised tests (timing) and leak rate tests.
Evaluation and Conclusion Since the valve closures are part of the containment boundary the disassembly of these closures would. place the plant in an unsafe condition. The licensee has proposed to check the position indicators by indirect methods; the closed position indication will be checked during Appendix J 1eak testing and the open position indication will be verified during stroke testing.
In addition, the licensee's program requires that an accurate remote position indication which l
are required by the code is verified during maintenance whenever disassembly of the valve enclosures is required. On this basis we agree with the licensee that the alternative of valve exercising and leak test gives an adequate indica-f tion of valve stem position. On this basis we conclude that relief from the code requirement for these valves may be granted.
3.2.12 Licensee's Relief Request from Torque Delivery to the Valves
[
Disk IWV3520(b)(2) (Relief Request No. 17) i Affected components l
Unit 1 Unit 2 Vacuum Breaker t Caustic Addition 2CA-7-1 Vacuum Breaker at Caustic Addition CA-7-1 a
Standpipe Standpipe CA-7-2 Vacuum Bf6& kerat Caustic Addition 2CA-7-2 Vacuum Breaker at Caustic Addition i
Standpipe Standpipe
/
CC-65-1 11 Component Cooling Surge Tank Vacuum 2CC-65-1 21 Component Cooling Surge Tank Vacuum Breaker Breaker l
We have determined that the above listed valves are not required to safely shut down the plant or to mitigate the consequences of an accident. Therefore we do not require these valves to be part of the licensee's IST program.
On this basis relief from the Code is not required.
~
3.2.13 Licensee's Relief Request from Full Stroke Time IWV3410(c)(1)
(Relief Request No. 18)
Affected components Unit 1
~
Unit 2 CV-31941 11 Cntmt Spray Suct from Caus CV-31939 21 Cntat Spray Suct from Caus Standpipe Isolation Standpipe Isolation CV-31938 12 Cntat Spray Suct from Caus CV-31940 22 Cntet Spray Suct from Caus Standpipe Isolation Standpipe Isolation CV-31838 121/122 Control Room Wtr. Chiller CV-31230 Reac C1nt Loop Pzr Ltdn Line Inlet Xover Isolation CV-31837 121/122 Control Room Wtr. Chiller CV-31279 Reac Cint Loop Pzr Ltdn Line In;et Xover Isolation CV-31226 1 Reac Cint Loop Prz Ltdn Line Isolation CV-31255 1 Reac Cint Loop Prz Ltdn Line Isolation Code Requirement The limiting value of full stroke time shall be specified by the owner.
Licensee's Basis There is no manufacturing information available to. establish reasonable stroke times for these valves. The valves were exercised as required and stroke time data were obtained during the first 20-month phase of plant operation. This data provides the basis for establishing the limiting values of stroke time. These values have been factored into the exercise test procedures since the time of the first 20-month program update.
_,,o__
,em Evaluation and Conclusion The licensee declares the valve inoperable when measured stroke times do not _
agree with the base line data obtained during the first 20-month phase of plant operation. In addition, the stroke times of all of these control valves affect the controllin'g'pirameters such as flow, temperature or pressure.
These parameters are periodically monitored by the operator which results in
~
checking the stroke time of the control valves, if these parameters are observed to be controlled improperly.
The staff agrees with the licensee that the alternative approach for measuring the stroke times of these valves are acceptable and, therefore, relief from
~
requirements of IWV-3410(c)(1) for these valves may be granted.
3.2.14 Licensee's Relief Request from Valve Exercising at Cold Shutdown (IWV3410(b)(1)) (Relief Request No. 21)
Affected components Unit 1 Unit 2 MV-32121 12 Component Cooling HT Exhcanger MV-32123 22 Component Cooling HT Exchanger Outlet Outlet MV-32120 11 Component Cooling HT Exhcanger MV-32122 21 Component Cooling HT Exchanger Outlet Outlet MV-32266 11/12 RCP Component Cooling Inlet MV-32268 21/22 RCP Component Cooling Inlet Isol A Isol A MV-32267 11/12 RCP Component Cooling Inlet MV-32269 21/22 RCP Component Cooling Inlet Isol B Isol B Code Requirement Valves shall be exercised to the extent required to fulfill their function'at least once every 3 months unless such operation is impractical during normal plant operation.
1 i
t f
s Licensee's Basis for Relief i
Exercising these valves at power or cold shutdown requires establishing an abnormal system lineup.
Should inadvertent isolation of the cross connected portions of the system occur ('either through operator error in establishing the lineup or from spurious signals from instrumentation in the valve closure circuitry) considerable damage to the reactor coolant pumps and other reactor auxiliary equipment could result.
Evaluation and Conclusion Isolation of these valv.u for exercising would require removing from service or possible damage to the following equipment:
o Reactor Coolant Pump o
Letdown Heat Exchanger o
Seal Water Heat Exchanger o
Boric Acid Evaporator The present test program requires these valves to be exercised during each refueling outage.
Considering the consequences of removing from service or possible damage to equipment, we agree that due to system design, exercising
!.hese valves as prescribed by code is impractical and that they should be tested only during each refueling outage. On this basis we conclude that relief fror,the code may be granted.
m e
3.2.15 ' Licensee's Relief Request from Stroke Time Valves (IWV3410(c)
(Relief Request No. 22)
Affected components Unit 1 Unit 2 Vent to Annulus CV-31973 11 Post LOCA H Vent to Annulus CV31924 21 Post LOCA H2 2
Vent to Annulus CV-31929 12 Post LOCA H Vent to Annulus CV-31930 22 Post LOCA H2 2
Code Requirements Stroke time for power operated valves shall be measured in ac'cordance with IWV3410(c).
Licensee's Basis for Relief The valves have operator dependent stroke times.
The valves are normally locked closed.
Evaluation and Conclusion Stroke timing for these valves is impractical since these valves are control valves where the stroke timing varies as a function of the input control signal to the valves.
However, the licensee has committed to exercise these valves to the full stroke position and ensure that the valve can perform its This throttling function throughout the full range of valve disc travel.
relief is under review by the staff in that further justification is required from the licensee.
{
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3.2.16 The Licensee's Relief Request from Valve Exercisino as Required by IWV3520 (Relief Request No. 27 Affected components Unit 1 Unit 2 AF-14-1 11 Aux Fd Pop Suct Check AF-14-7 21 Aux Fd Pop Suct Check AF-14-312 Aux Fd Pmp Suct Check AF-14-5 22 Aux Fd Pop Suct Check CC-3-3 Return Line to 11 Comp Cool 2CC-3-3 Return Line to 21 Comp Cool Pump Check Pump Check CC-3-4 Return Line to 12 C'omp Cool 2CC-3-4 Return Line to 22 Comp Cool Pump Check Pump Check VC-8-2 Charging Ln Check Dwnstra 2VC-8-2 Charging Line Check Dwnstra Regen HK Regen HK VC-17-1 Charging Ln CV-31328 Bypass Check 2VC-17-1 Charging in CV-31420 Bypass Check F-8-1 FW to 11 Steam Generator Check 2FW-8-1 FW to 21 Steam Generator Check F-8-2 FW to 12 Steam Generator Check 2FW-8-2 FW to 22 Steam Generator Check Code Requirement Check valves normally open during plant operation whose function is to prevent reverse flow shall be tested in a manner that proves that the disk travels promptly to the seat upon cessation of flow.
(1) Valves AF14-1 and 3; AF14-7 and -5 Licensee's Basis for Relief These are normally open check valves. Verification of valve closure requires taking one of the opposite units auxiliary feedwater pumps o,ut of service and draining approximately 200 feet of 8-in. pipe. Taking one of the unit's auxiliary feedwater pumps out of service requires reposi-tioning of valves, which if not performed properly, could result in a violation of the plant's Technical Specification.
/
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._..___m.._-
6 Evaluation and Conclusion Exercising these valves during normal operation would result in injecting low purity water from the cooling water supply in the secondary system which would disrupt,the secondary water chemistry. This is detrimental to sensitive materials in the secondary system (i.e. steam generator andcondensertubes,etc.). The safety-related function of these check valves is to open allowing flow from the condensate storage tank to auxiliat-y feedwater pump. Therefore, these valves should not be stroked ~
during normal plant operation. The exercising function of these valves is verified by the, operation of the auxiliary feedwater system each time the plant is brought to cold shutdown and each time the plant is taken out of cold shutdown. These valves are backed up Dy motor operated valves (i.e. MV32333 and MV32335 for Unit No. I and MV32336 and MV32345 for Unit No. 2) so that if the check valves fail to operate then the motor operated valves can be closed manually to assure an adequate supply of auxiliary feedwater to the steam generators.
In addition, the licensee agreed to exercise the motor operated valves during cold shutdown and during each refueling outage. Therefore, due to system design and the licensee's commitment to test the motor operated valves we conclude that relief from requirements of IWV-3520(b)(1) may be granted.
(2) Valve CC-3-3 and 3-4; 2CC3-3 and 4 Licensee's Basis for Relief The valves are normally open check valves. Verification of valve closure requires isolation of the listed equipment and draining of long sections of piping.
(1) Waste Gas compressor return lines (2) Steam generator blowdown panel l
l (3) Seal water heat exchanger 3-38 IST Program SER u
A.
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..A
c.
(4) Letdown heat exchanger (5) Reactor coolant pumps (6) Excess letdown-heat exchanger Evaluation and Conclusion These valves are in series with butterfly valves (i.e., CC-1-9 and CC-1-10) and are normally open to allow return flow to the component cooling pumps.
If the check valves fail to close, the butterfly valves can always be manually closed to perform the isolation function and the butterfly valves are exercised during each refueling outage. The check valves should not be stroked during normal operation since during stroking, cooling water flow would be reduced to vital components required for normal plant opera-tion. In addition the licensee has shown that isolating these valves would be an undue burden without a significant increase in safety. On this basis we conclude that relief from the code requirement for these valves may be granted.
(3) Valves VC-8-2 and VC17-1: 2VC8-2 and 17-1 Licensee's Basis for Relief These are normally open check valves.
Verification of closure requires removal of boric acid flow path to the core and draining approximately 150 ft of piping. The drainage operation requires entrance to a high radiation zone (100 mr/hr).
Evaluation and Conclusion Valve VC-8-2 is a check valve downstream of the regenerative heat exchanger; valve VC-17-1 is the bypass check valve for CV-31328 downstream of the regenerative heat exchanger. These are normally open valves whose safety-3-39 IST Program SER
l related function is to close isolating a failure in the charging line.
Exercising these valves during power operation or cold shutdown is incractical because such exercising would remove the letdown line from service and re, quire draining 150 feet of piping in a high radiation zone.
In addition isolating these valves during power operation would disrupt j
water chemistry control that would lead to a violation of the Technical Specifications. Exercising these valves during power operation or cold shutdown is judged by the staff as being unsafe. The licensee did however On this agree to exercise these valves during each refueling cycle.
basis we concludt.that relief from the code requirement for exer-cising these valves during normal operation or cold shutdown may be granted.
(4) Valves FW8-1 and 2: 2FW8-1 and 2 Licensee's Basis for-Relief i
Stroking these valves requires operation of the auxiliary feedwater pumps and draining approximately 300-400 feet of 16 in. pipe.
Such an effort i
is not warranted to verify the check valve closure.
Evaluation and Conclusion i
These valves are located on the feedwater injection line to the stream generators and function to prevent back flow and overpressurization of the electric feedwater pumps when the auxiliary feedwater pumps are operating. Plant Technical Specifications require that full flow from the auxiliary feedwater pumps be demonstrated each year.
During this test, should these check valves fail to close, the resulting l
o
.. - l In backflow into the main feedwater lines would be immediately known.
adddition these valves are exercised each time the unit is brought to The cold shutdown and each time the unit is taken out of cold shutdown.
staff agrees with the licensee that due to system design exercising these In addition, the valves quarterly or at cold shutdown is impractical.
staff concludes that the yearly full flow test of the auxiliary feedwater pumps is sufficient to verify the operational readiness of these valves.
On this basis we conclude the licensee relief from the code reouireme for exercising these valves may be granted.
3.2.17 The Licensee's Relief Request from Valve Exercisino as Required by IWV3520(b) (Relief Request No. 32)
Affected components j
Unit 1 Unit 2 CS-18 Cntmt Spray Pump 11 Discharge Check CS-48 Cntmt Spray Pump 21 Discharge Check CS-19 Cntmt Spray Pump 12 Discharge Check CS-49 Cntmt Spray Pump 22 Discharge Check Relief Request No. 32 is addressed as part of Relief Request No. 5 (Item 3.2.2(10)) of this SER) which is concerned with check valves exercising once every 3 months for the above listed valves. The licensee requested that Relief Request No. 32 be deleted from the IST Program. We find this request acceptable since valves CS-18, -19 for Unit No. 1 and CS-48, -49 for Unit No. 2 are addressed in this SER under Item 3.2.2(10).
3.2.18 The Licensee's Relief Request for Valve Exercisina (IWV3410)
(Relief Request No. 34)
Affected components Unit 1 Unit 2 CV-31768 122 Cont Rm A/C Chl Water Return CV-31767 101 SWGR Room Fan Coil Train A CV-31786 121 Cont Rm A/C Chi Water Return CV-31755 22 SWGR Room Fan Coil Train B CV-31759 122 N Relay Room Fan Coil Trn B CV-31756 25 SWGR Room Fan Coil Train A CV-31760 121 N Relay Room Fan Coil Trn A CV-31757 16 SWGR Room Fan Coil Train B CV-31761 122 S Relay Room Fan Coil Trn B CV-31758 15 SWGR Room Fan Coil Train A CV-31762 121 S Relay Room Fan Coil Trn A CV-31751 22 RHR Room Fan Coil Train B CV-31764 202 SWGR Room Fan Coil Train B CV-31752 21 RHR Pit Fan Coil Unit Train A CV-31765 201 SWGR Room Fan Coil Train A CV-31753 12 RHR Pit Fan Coil Unit Train B CV-31766 102 SWGR Room Fan Coil Train B CV-31754 11 RHR Pit Fan Coil Unit Train A We have determined that the above listed valves are not required to safely shut down the plant or to mitigate the consequences of an accident. Therefore we do not require these valves to be part of licensee's IST program. On this basis relief from the code is not required.
3.2.19 The Licensee's Relief Request from Valve Exercisina (IWV3410(b)(1)
(Relief Request No. 35)
Affected components l
Unit 1 Unit 2' CV-31226 Reac Cool Lp Prz Ltdn Ln Iso CV-31230 Reac Cool Lp Prz Ltdn Ln Iso CV-31255 Reac Cool Lp Prz Ltdn Ln Iso CV-31279 Reac Cool Lp Prz Ltdn Ln, Iso Code Requirements These valves shall be exercised at least once every three months during normal plant operation or during cold shutdown if valve exercising is impractical during normal plant operations.
e e
Licensee's Basis for Relief Extensive operational problems are created in exercising these valves during normal operations or during cold shutdown as the letdown line must be removed from service.
Exercising these valves other than during refueling outage is impractical.
'~
Evaluation and Conclusion These valves are located on the letdown 11.e from the reactor.
The letdown line allows reactor coolant to flow to the chemical volume control system for control of reactor cooiant chemistry. Considering the consequence of removing the letdown line from service (i.e., removing control of reactor coolant chemistry), the NRC staff agrees with the licensee's basis.
Therefore, due to system design', relief from exercising this valve during normal operation and cold shutdown may be granted.
3.2.20 The Licensee's Relief Request from Check Valve Exercising IWV3520(b)
(Relief Request No. 39)
Affected components Unit 1 Unit 2 VC-8-6 12 RCP Seal Line Check 2VC-8-6 22 RCP Seal Line Check VC-8-7 11 RCP Seal Line Check 2VC-8-7 21 RCP Seal Line Check Code Requirements These check valves shall be exercised at least once every three months during normal plant operation or during cold shutdown if valve exercising is impractical during normal plant operations.
e
'O Licensee's Basis for Relief Installation of these valves is such that they cannot be adequately exercised during normal plant operation or during cold shutdown.
Isolation of these valves for exercising requires removal of the RCP seal injection line from service.
Evaluation The seal injection water minimizes the out-leakage of the primary system water into the pump seal cavity. Testing these valves would remove the RCP seal injection line from service impacting on primary water chemistry control. We agree with the licensee that exercising these valves other than during refueling outage is impractical.
On this basis due to system design, relief from exercising these valves during normal plant operations or during cold shutdown may be granted.
3.2.21 The Licensee's Relief on Stroke Time for Control Valve IWV3410C (Relief Request No. 53)
Affected components Unit 1 Unit 2 CV 31381 Clg Wtr From 11 Comp C1g Ht Exch CV-31383 Clg Wtr from 21 Comp C1g Ht Exch CV 31411 Clg Wtr From 12 Comp Clg Ht Exch CV-31584 C1g Wtr from 22 Comp Cig Ht Exch CV 31785 122 Cont Rm Chlr Cdsr Cool Wtr Out1 CV 31769 121 Cont Rm Chlr Cdsr Cool Wtr Out1 Code Requirement The limiting value of full stroke time of each power-operated valve shall be specified by the owner.
The stroke time of all power-operated valves shall be measured to'the, nearest second or 10% of the maximum allowable stroke time, whichever is less.
o e
Licensee's Basis for Relief The processes with which these CV (control valves) interface are under continuous monitoring.
Failure of'a valve to function properly is immediately known.
Evaluation and Conclusion These valves are in regular use.
The valves are designed to provide a throttling function for the associated equipment. The licensee has shown that the processes controlled by these valves are continuously monitored and proposes that valve operability be based on satisfactory performance of associated equipment.
This relief request is under review by the staff in that further justification is required from the licensee.
3.2.22 The Licensee's Relief Request from Valve Exercising Frequency (IWV3410)
(Relief Request No. 57)
Code. Requirement These valves shall be exercised at least once every three months during normal plant operation or during cold shutdown if valve exercising is impractical during normal plant operation.
3.2.22a Affected components Unit 1 Unit 2 (Shown in Appendix A of this SER.)
%h[
'o l
Licensee's Basis for Relief These valves will be exercised each refueling shutdown at the same time a leak rate test of these valves is perfof'med.
Verifying valve closure is not warranted at intervals _more often than at the time when leak testing is Performed, since leak tightness is paramount to proper functioning of the valves.
Evaluation and Conclusion These valves perform the containment isolation function during normal plant operation and are not required to change position during accident conditions.
To assure leak tightness throughout the operating cycle, these valves are used only when absolutely necessary. The licensee cannot assure the high degree of containment integrity if thes valves are exercised asl required by the code since sealant quality of the valves may change by repeated use. Therefore such valve exercising during normal plant operation and during cold shutdown would put the plant in a less safe condition. We agree with the licensee that valve exercising may be limited to refueling outages since the valves are passive valves during accident conditions and because of system design. On this basis code relief from valve exercising may be granted.
3.2.22b Affected Components Unit 1 Unit 2 CV-31318 PRT Sample to GA CV-31926 Post LOCA to GA Isol CV-31319 PRT Sample to GA CV-31928' Post LOCA to GA Isol CV-31339 Lt Down Cntmt Isol CV-31643 Air Sample FR RD Cntmt'Isol CV-31325 Lt Down Orifice Isol CV-31642 Air Sample FR RD Cntmt Isol CV-31326 Lt Down Orifice Isol CV-31303 Przr Stm Space Sample Valve A CV-31327 Lt Down Orifice Isol CV-31304 Przr Stm Space Sample Valve B i
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Unit 1 Unit 2 CV-31092 Air Sample to RD Cntmt Isol CV-31305 Przr Liq Space Sample Valve A CV-31022 Air Sample to RD Cntmt Isol CV-31306 Przr Liq Space Sample Valve B
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CV-31019 Air Sample to RD Cntmt Isol,
CV-31307 RCS Hot Leg Sample Valve A CV-31750 Air Sample to RD Cntmt Isol CV-31308 RCS Hot Leg Sample Valve B CV-31296 Przr Stm Space Sample Valve A CV-31430 Lt Down Cntmt Isol CV-31297 Przr Stm Space Sample Valve B CV-31347 Lt Down Orifice Isol CV-31298 Przr Liq Space Sample Valve A CV-31348 Lt Down Orifice Isol CV-31299 Przr Liq Space Sample Valve B CV-31349 Lt Down Orifice 15o1 CV-31300 RCS Hot Leg Sample Valve A CV-31129 Air Sample to RD Cntmt isol CV-31301 RCS Hot Leg Sample Valve B CV-31644 Air Sample to RD Cntmt Isol CV-31925 Post LOCA to GA Isol CV-31344 Prt Sample to CA CV-31927 Post LOCA to GA Isol CV-31345 Prt Sample to GA Licensee Basis for Relief The licensee proposed to exercise these valves during cold shutdown and during each refuel'ing cycle. These valves cannot be exercised during power operation since the leak tightness capability of the valve could be jeopar-dized as.the result of the exercising test. These valves perform dual func-tions which are to maintain containment integrity during plant operation and are required to open to perform a safety function.
Evaluation and Conclusion These valves perform the containment isolation function during normal plant operation when leak tightness must be assured. The licensee has however committed to exercise these valves during cold shutdown as well as during each refueling outage. We agree with the licensee that exercising these valves during normal operation could result in putting the plant in a less safe condition. We have judged that exercising these valves during cold shutdown and during each refueling outage assures that the valves will perform their safety function. On this basis code relief from exercising these valves during normal operation may be granted.
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3.2.22e Affected Components t
Unit 1 CV-31740 1 Cntmt Inst Air Isol Valve A
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CV-31741 1 Cntmt Ins't' Air Isol Valve. B i
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CV-31743 1 Cntmt Inst Air Isol Valve B Licensee Basis for Relief These valves will be exercised each refueling shutdown at the same time a
-leak rate test of the valve is performed. Verifying valve closure at intervals more often than test of the leak tightness of the valve is not warranted, sin,ce i
leak tightness is paramount to the proper functioning of the valve.
Evaluation and Conclusion These valves are normally opened but are required to close,~ isolating'the' containment and later to open to perform a safety function.
Exercising these valves during normal operation or during cold shutdown will isolate instrument air supply causing all of the air operatet valves in containment to fail.
We agree with the licensee that such a 4351ent will place the plant in an unsafe condition even during co'4 9.td. as. We have judged that these valves can be exercised only during re> ~_ hn,
.etages. On this basis code relief from exercising these valves during normal operation and during cold shutdown may be granted.
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3.2.23 The Licensee's ielief Request from Valve Exercising IWV3410 (Relief Request ~t'4o. 58) 1
'l Affected components Unit l' Unit 2 CS-1111-Cntet Spray Pusps 1;o RWST Recirc CS-4121 Cntat Spray Pump to RWST Recirc CS-1212 Cntat Spray Pumps'to RWST Recirc CS-42 22 Cntmt Spray Pump to RWST Recirc We have determined that the above listed valves are not required to safely shut down the plant or mitigate the consequences of an accident.
Therefore we do not require these valves to be part of the licensee's IST program. On this basis relief from the code is not required.
3.2.24 The Licensee's Relief Request from Valve Exercising Frequency (IWV3520)
(Relief Request No. 61)
Affected components 4
Unit 1 E'
CLG Water to 22 AFWP 32030 CLG Water to 12 AFWP 32027 CLG Water to 21 AFWP 32026
' ' CLG Water to 11 AFWP 32025 Coc.'e Requirements These valves shall be exercised at least once every three months during normal plant operation or during cold shutdown if valve exercising is impractical.-
't during normal plant operations.
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s Licensee's Basis for Relief The purpose of these valves is to provide a backup supply of makeup to the steam generators.
Normal supply is demineralized water from the condensate storage tanks (Technical Specification lower volume limit of 100,000 gallons).
. with backup supply from the river.
These valves receive no auto open signal. They are manually opened.
Stroking the valves breaks one of the barriers between the demineralized water and the chemically contaminated,, river water.
Evaluation and Conclusion These valves are in a system which provides backup water supply from e
contaminated river water to the steam generators.
Exercising these valves once every three months could result in disrupting the secondary water chemistry which is detrimental to the protection of the steam generator tubes.
The licensee proposes, as an alternative, to stroke these valves during each cold shutdown provided that flushing to remove contaminated river water can be achisved. We agree with the licensee's alternative exercising frequency provided that, if flushing cannot be performed during cold shutdown, then these valves are to be exercised during each refueling outage. The licensee has agreed to modify his proposed alternative on the valve exercising freouency so that valve exercising will be done during each refueling outage if such exercising cannot be performed during cold shutdown. We have judged that based on the system design and the alternative exercising frequency for these valves as agreed upon by the licensee is acceptable. On this basis, we conclude that relief from the code on the exercising frequency for these valves may be nranted.
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(Relief Request No. 62)
Affected components Unit 1 Unit 2 MV-32064 React Vsl Inj Fr RHR MV-32167 React Vsl Inj Fr RHR MV-32065 React Vsl Inj Fr RHR MV-32168 React Vs1 Inj Fr RHR Code Requirement IWV3520 Normally closed valves should be exercised at least once every three months, except those valves that cannot operate during normal plant operations shall be exercised during cold shutdown.
Licensee's Basis for Relief These valves are normally closed and are opened automatically upon receipt of an SI signal. These valves can be opened during normal plant operations but in a closed position they afford an additional degree of protection for the low pressure residual heat removal system (RHR).
1 During periodic exercising of these valves, both valves would have 'to be stuck open a significant amount to threaten RHR piping with overpressurization.
While this possibility is remote, the licensee will revise the valve testing program to eliminate this potential hazard by scheduling tests during cold shutdown outages when the reactor coolant system is depressurized and cooled down.
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l Evaluation and Conclusion We agree with the licensee that these valves should be exercised only when the reactor system pressure is below the design pressure of the RHR system that is during cold shutdown thus eleminating the possiblity of over pressurizing the RHR system. Alth'ough'these valves can be operated during normal plant operation, it is not the intent of the code to place a plant system in a less safe condition when scheduling the valve exercising frequency. Thus the code allows such flexibility in scheduling the valve exercising frequency for i
the reasons given by the licensee in his basis.
Therefore, the licensee is meeting the code requirements and relief is not necessary.
3.2.26 The Licensee's Relief Request from Valve Exercising Frequency (IWV3510a)
(Relief Request No. 65)
Affected components Unit 1 Unit 2 VC-24-1 Vct Relief 2VC-24-1 VCT Relief Code Requirement The code requires that the setpoint of these relief valves be verified once i
every five years.
Evaluation and Conclusion These relief valves are located on the volume control tank which is part of the waste gas holdup system. We have determined that these valves are not required to safely shutdown the plant or mitigate the consequence of an accident.
Therefore we do not require these valves to be part of the licensee's IST program. On this basis relief from the code is not required.
However, we i
recommend that.the licensee select a time within a five year period when the volume control tank is in an operating condition conducive to verifying the setpoints of these relief valves.
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V 4.0 Conclusion Based on our review, we have concluded that the proposed IST Program conforms l
to the 1974 Section XI of the ASME B&PV Code through the Summer 1975 Addenda to the extent practical for the facility. Our review consists of completing our safety evaluation of all items identified by the licensee in his IST program requiring relief from the ASME Section XI Code.
The review resulted in identifying items which are complete because (1) the licensee has met the
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code requirements, (2) items fall outside our criterion for the IST program for which relief is not required, or (3) the staff granted the relief request.
For items where the licensee's justification for the relief request was not adequate, the licensee changed his IST program so that the relief. request was found receptable to us.
Based on this safety evaluation, we are granting this l
relief based on our review of the information submitted to support the deter-mination that ASME code requirements would be impractical for the facility.
I We have given due consideration to the burden that could result if thes'e requirements were imposed on the facility. We have concluded that the granting of this relief is authorized by law, will not endanger life or property or the common defense and security and is in the public interest considering the f
burden on the licensee if the relief were not granted.
The licensee has agreed to review his IST program and modify it accordingly as j
it may result from any future modifications to the safety related systems or components. The 1Jcensee has further agreed that any changes to the IST program that would result from these future modifications will meet the ASME Code requirements for IST or that he will request appropriai.e relief. On the basis of this review we find the licensee's IST program acceptable and it is approved. Therefore, we determined that by approving the modified IST program the amendments revising the TSs incorporates the provisions of the approved program.
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6 We have determined that this action does not authorize a change in effluent j
types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that this action ' involves an action which is insignificant from the standpoint o.f_ environmental impact and pursuant to 10 CFR Section 51.5(d)(4) that an environmental impact sta'tement or negative declara-tion and environment impact appraisal need not be prepared in co'nnection with this amendment action.
We have concluded, based on the considerations discussed above, that (1) because this action does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a signi-ficant decrease in'a safety margin, this action does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this action will not be inimical to the common defense and security or to the health and safety of the public.
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Safety Evaluation Report IST Program Appendix A Prairie Island Nuclear Generating Plant Units Nos 1 and 2 Affected Components (Relief Request No. 57-3.2.22a)
(A) Unit 1 RC-3-1 RMU Water to PRT CV-31436 RCDT Pop Disch Cntat Isol
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RC-5-1 PRT N2 Support Isol CV-31437 RCDT Pmp Disch Cntet Isol CV-31321 RMU Water to PRT Isol CV-31434 RCDT to VH Cntat Isol CV-31221 PRT N2 Supply Isol CV-31435 RCDT to VH Cntat Isol MV-32073 1 REAC SAF INJ Cold Leg Isol CV-31545 RCDT to GA Cntet Isol 2 Supply to ACC Cntat Isol CV-31546 RCDT to GA Cntmt Isol CV-31440 N CV-31242 N2 Supply Line to ACC HCV CV-31438 Sump A Disch Cntat Isol CV-31441 N2 Supply to 11 ACC Isol CV-31439 Sump A Disch Cntat Isol CV-31444 N2 Supply to 12 ACC Isol CS-18 11 Cntat Spray Pop Disch Check VC-8-4 12 RCP Seal Inj Check CS-19 12 Cntat Spray Pop Disch Check VC-8-5 11 RCP Seal Inj Check CV-31569 Cntmt Purge Exh Isol,B VC-14-1 12 RCP Seal Inj Throttle Viv CV-31570 Cntmt Purge Exh Isol A VC-14-2 11 RCP Seal Inj Throttle Viv Cv-31312 Cntmt Purge Supply Isol B MV-32199 Seal Return Cntmt Isol CV-31313 Cntat Purge Supply Isol A MV-32166 Seal Return Cntat Isol CV-31310 Inservice Purge Exh Isol B VC-8-1 Chg Line Cntmt Check CV-31311 Inservice Purge Exh Isol A VC-7-11 Chg Line RCV Isol CV-31633 Inservice Purge Supply Isol B VC-7-10 Chg Line HCV Bypass CV-31634 Inserv' ice Purge Supply Isol A CV-31198 Chg Line HCV HC-2-1 Inst & Emerg Air to Inside Cntet Vessel HC-2-2 Inst & Emerg Air to Inside Cntet Vessel l
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(B) Unit 2 CV-31574 Cntat Purge Exh Isol_ B -
2VC-7-11 Chg Line HCV Isol CV-31575 Cntat Purge Exh Isol A 2VC-7-10 Chg Line HCV Bypass CV-31316 Cntat Purge Supply Isol B CV-31211 Chg Line HCV CV-31317 Cntat Purge Supply Isol A CV-31735 RCDT Pump Disch Cntat Isol CV-31314 Inservice Purge Exh Isol B CV-31736 RCDT Pump Disch Cntet Isol CV-31315 Inservice Purge Exh Isol A CV-31733 RCDT to VH Cntat Isol CV-31635 Inservice Purge Supply Isol B CV-31734 RCDT to VH Cntat Isol CV-31636 Inservice Purge Supply Isol A CV-31731 RCDT to GA Cntet Isol CS-48
- 22 Cntat Spray Pump Disch Check CV-31732 RCDT to GA Cntat Isol CS-49
- 21 Cntat Spray Pump Disch Check CV-31619 Sump A Disch Cntat Isol 2HC-2-1 Inst & Emerg Air to Inside Cntat Vessel CV-31620 Sump A Disch Cntat Isol 2HC-2-2 Inst & Emerg Air to Inside Cntat Vessel 2RC-3-1 RMU Water to PRT CV-32176 2 Reac SAF Inj Cold Leg Isol 2RC-5-1 PRT N2 Supply Isol CV-31554 N Supply to ACC Cntmt Isolg CV-31342 RMU Water To Prt Isol.
2 CV-31244 N Supply Line to ACC HCV CV-31209 Prt N2 Supply Isol.
2 2 Supply to 11 ACC Isol 2VC-8-4 12 RCP Seal Inj Check CV-31511 N 2 Supply to 12 ACC Isol 2VC-8-5 11 RCP Seal Inj Check CV-31512 N MV-32210 Seal Return Cntmt Isol 2VC-14-1 12 RCP Seal Inj Throttle Viv MV-32194 Seal Return Cntmt Isol 2VC-14-2 11 RCP Seal Inj Throttle Viv 2VC-8-1 Chg Line Cntmt Check I
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