ML20076F270
| ML20076F270 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/30/1994 |
| From: | Jennifer Davis, Dibiasio A, Fresco J BROOKHAVEN NATIONAL LABORATORY |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17352A850 | List: |
| References | |
| CON-FIN-L-2301 TAC-M88721, TAC-M88761, NUDOCS 9410140161 | |
| Download: ML20076F270 (81) | |
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I TECHNICAL EVALUATION REPORT:-
i Turkey Point Nuclear Power Plant, Units 3 and 4 j
Florida Power and Light Company.
l Pump and Valve Inservice Testing Program --
Revision 0. Third Ten-Year Interval j
Docket Numbers: f50-250ind 251':
TAC Numbers:: : M88761 and 88721L i
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. Prepared by:,....
A. Fresco,- J.F. Davis and At M..DiBiasioj Engineering Technology Division:-
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. Department of Advanced; Technology.
i Brookhaven Nati6nal Laboratory; j
Upton,-New York L11973'.
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t Prepared for-Division of Engineering 1.
j 1 Office of Nuclear Reactor Regulation:
- .U.~ S. Nuclear Regulatory Cammission.
1 Washington, DC 20555 FIN L-2301, Task Assignment 12 September 1994 k o M DB91 1/P) i l
ABSTRACT 1
This report presents the results of Brookhaven National Laboratory's evaluation of the relief requests,
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cold shutdown and refueling outage justifications and, for selected systems, a review of the scope of the Turkey Point Nuclear Power Plant, Units 3 and 4, ASME Section XI Pump and Valve Inservice Testing Program.
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TABLE OF CONTENTS Eags ABSTRACT iii
1.0 INTRODUCTION
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2.0 PUMP IST PROGRAM RELIEF REQUESTS 3
2.1
- Relief Request No. PR-1, Boric Acid Pumps 3
2.2 Relief Request No. PR-2, RHR Pumps.......................
4 2.3 Relief Request No. PR-3, RHR Pumps.......................
5 2.4 Relief Request No. PR-4 Generic Relief......................
7 3.0 VALVE IST PROGRAM RELIEF REQUESTS 9
3.1 Relief Request No. VR-2, SI Check Valves.....................
9 4.0 DEFERRED TESTING JUSTIFICATIONS.........................
13 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS........
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6.0 REFERENCES
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APPENDIX A: LIST OF REFERENCE DRAWINGS.......................
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LIST OF TABLES Eagg 4.1
" Cold Shutdown Justification Evaluations"....
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" Refueling Outage Justification Evaluation"........
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Technical Evaluation Report Turkey Point Nuclear Power Plant Units 3 & 4 Pump and Valve Inservice Testing Progress i
'Ibird Ten Year Program Revision 0
1.0 INTRODUCTION
Contained herein is a Technical Evaluation report (TER) of Revision 0 of the ASME Section XI Third Ten Year Program for pump and valve inservice testing (IST) submitted to the U.S. NRC by l
. Florida Power & Light Company for its Turkey Point Nuclear Power Plant, Units 3 and 4 on January 12,1994 (Ref.1). The program for this third ten year interval is based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code,1989 Edition (Ref. 2)..The 1989 I
Edition of Section XI provides that the rules for inservice testing of pumps and valves are as specified in ASME/ ANSI OMa-1988 Part 6 and 10 (Refs. 3,4), respectively.
This program revision supersedes all previous submittals. The Turkey Point Nuclear Units 3.and 4 are Westinghouse Pressurized Water Reactors (PWRs) which began commercial operation on
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February 22,1974 for Unit 3 and April 15,1974 for Unit 4. The third ten year inspection interval is defined for Unit 3 as beginning February 22,1994 and ending February 21,2004, and for Unit 4 l
as beginning April 15,1994 and ending April 14, 2004.
i Title 10 of the Code of Federal Regulations, 650.55a 1(f) (Ref. 5) requires that inservice testing of -
I ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific relief has been requested by the licensee and granted by the commission pursuant to 550.55a 1(a)(3)(i),
l (a)(3)(ii), or (f)(6)(i). Florida Power & Light has requested relief from certain ASME Section XI i
testing requirements. A review of the relief requests was performed using Section 3.9.6 of the Standard Review Plan (Ref. 6); Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," (Ref 7), and the Minutes of the Public Meeting on Generic Letter 89-04, dated October 25,1989 and September 26,1991 (Refs. 8 and 9); and Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants," (Ref.10). The IST Program requirements apply only to component (i.e., pumps and valves) testing and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements.
The licensee, in the January 12,1994 submittal of the Third Ten Year IST Program, states in
' that no NRC action is required for six of the seven relief requests. As discussed in Question 70 of the Minutes of the Public Meetings concerning Generic Letter 89-04, requests are subject to review by the NRC at each ten-year update to assure consistency with current NRC regulatory positions.
i The review performed for this TER did not include verification that all pumps and valves within the i
scope of 10 CFR 50.55a and Section XI are contained in the IST Program, and did not ensure that all applicable testing requirements have been identified.
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Section 2.0 of this report presents the evaluation of four pump relief requests. One pump relief request (PR-5) was evaluated separately by the NRC (Ref.11). Section 3.0 presents the evaluation of one of the two valve relief requests (VR-2). The other relief request was authorized by Generic Letter 89-04 and was not specifically evaluated in this Technical Evaluation Report (i.e., VR-1).
However, any anomalies associated with the relief request are addressed in Section 5 of the report.
The evaluation of the 32 Cold Shutdown Justifications and the 26 Refueling Outage Justifications is presented in Section 4.0, with reference to Table 1 for the Cold Shutdown Justifications and Table 2 for the Refueling Outage Justifications. Section 5.0 summarizes the actions required of the licensee resulting from the TER evaluations of the relief requests and the deferral justifications while Section 6.0 lists the references.
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2.0 PUMP RELIEF REQUESTS In accordance with {50.55a, Florida Power & Light Company has submitted five relief requests for pumps at the Turkey Point Nuclear Units 3 & 4 which are subject to inservice testing under the requirements of OMa-1988 Part 6. One of the relief requests, PR-5, was reviewed separately by the NRC by letter dated May 19, 1994. The other four relief requests have been reviewed tb verify their technical basis and determine their acceptability. The relief requests, along with the Technical Evaluation by BNL, are summarized below.
2.1 Relief Recuest No. PR-1. Boric Acid Transfer Pumps ReliefRequest: The licensee has requested relief, for the Boric Acid Transfer Pumps *-P203 A&B, from the requirements of OMa-1988 Part 6,15.2(d) that an inservice test shall be conducted with the pump operating at specified test reference conditions. Pressure, flow rate and vibration shall be determined and compared with corresponding reference values.
Alternate Testing: During quarterly testing of these pumps, differential pressure and vibration measurements will be taken utilizing the fixed resistance flowpath and evaluated in accordance with Table 3 of OMa-1988 Part 6. At each reactor refueling these pumps will be tested and all appropriate measurements taken in accordance with Paragraph 5.2. This satisfies the requirements of NRC Generic Letter 89-04, Position 9.
Licensee's Basisfor Relief: The licensee states that: "The normal test loops for these pumps consist of fixed resistance circuits sized to limit flow but with no flow measuring devices installed. Since the system resistance is fixed and can be assumed to be a constant, pump degradation can be monitored by comparing successive measurements of pump differential pressure.
An alternative test circuit is available in which pump flowrate can be measured, however it requires injection of highly concentrated boric acid solution into the reactor coolant system. During plant operation, this is not practical since it would adversely effect reactor power level and create a potential plant transient. If injection were to be performed during cold shutdown periods the result would be excessive boration of the reactor coolant system and associated potential difficulties during the subsequent plant startup. This is especially significant near the end of core life."
Evaluation: Generic Letter 89-04, Position 9 (Ref. 7), states that an inservice pump test requires that the pump parameters shown in ASME Section XI, Table IWP-3100-1 (or correspondingly OMa-1988 Part 6. Table 2) be measured and evaluated to determine pump condition and detect degradation.
Pump differential pressure and flow rate are two parameters that are measured and evaluated together to determine pump hydraulic performance.
In cases where flow can only be established through a non-instrumented minimum-flow path during quarterly pump testing and a path exists at cold shutdown or refueling outages to perforr. a test of the pump under full or substantial flow conditions, the NRC has determined that increased interval is an acceptable alternative to the Code requirements provided that pump differential pressure, flow rate, and bearing vibration measurements be taken during this testing, and that quarterly testing also measuring at least pump differential pressure and vibration be continued. Data from both of these 3
i testing frequencies should be trended, as required by IWP-6000 {or correspondingly OMa-1988 Part 6,17.3(0}. Specifically, Part 6,17.3(0 states that: "The Owner shall maintain a record of each test which shall include the following:...(0 comparisons with allowable ranges of values and analysis of deviations."
It is impractical for the licensee to use the instrumented flow path for quarterly or cold shutdown testing due to the injection of boric acid. If the Code requirements were imposed on the licensee, power fluctuations and transients would occur during operation and cold shutdowns would be extended. Since the alternate proposed by the licensee provides reasonable assurance of operational readiness and based on the impracticality of complying with the Code requirements, and the burden on the licensee if the Code requirements were imposed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(f)(6)(i).
2.2 Relief Reauest No. PR-2. Residual Heat Removal Pumns ReliefRequest: The licensee has requested relief for the Residual Heat Removal Pumps *-P210 A&B, from the requirements of OMa-1988 Part 6,15.2(b), which state that the resistance of the system shall be varied until the flowrate equals the reference value. Alternatively, the flowrate nuy be varied until the differential pressure equals the reference value.
Alternate Testing: During quarterly testing of the RHR pumps, a fixed-resistance test circuit will be used and pump differential pressure and flowrate will be determined and compared to their respective reference values per Paragraph 5.2(c).
During testing performed at cold shutdown or refueling, pump differential pressure, flowrate, and vibration will be recorded and evaluated per Paragraph 5.2(b). Testing during cold shutdowns will be on a frequency determined by intervals between shutdowns. For intervals of 3 months or longer, testing will be conducted at each shutdown.
Licensee's Basisfor Relief. The licensee states that: *During quarterly testing of the RHR Pumps, flow is routed through a minimum flow recirculation line leading to the suction of the pump being tested. This recirculation flowpath is capable of passing a flowrate somewhat less than 10 percent of that at the pump design operating point. A flow instrument is installed in this recirculation piping, however there is concern regarding the practice of throttling under muumum flow conditions with the potential for causing pump damage. In addition, hydraulic pump test data at or near a pump's shutoff head provides little information as to the mechanical condition of a pump.
NRC Generic Letter 89-04, Position 9, (Reference 2.7) allows elimination of minimum flow test line flowrate measurements providing inservice tests are performed during cold shndowns or refueling under full or substantial flow conditions where pump flowrate is recorded and evaluated. The proposed alternate testing is consistent with this philosophy and the intent of this position.
These pumps are standby pumps and little degradation is expected with respect to hydraulic performance during operational periods when the pumps are idle. Thus, the alternate testing will provide adequate monitoring of these pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation."
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Evaluation: Generic Letter 89-04, Position 9 (Ref. 7), states that an inservice pump test requires that the pump parameters shown in ASME Section XI, Table IWP-3100-1 (or correspondingly OMa-1988 Part 6, Table 2) be measured and evaluated to determine pump condition and detect degradation.
Pump differential pressure and flow rate are two parameters that are measured and evaluated together to determine pump hydraulic performance.
In cases where flow can only be established through a non-instmmented minimum-flow path during quarterly pump testing and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the NRC has determined that increased interval is an acceptable alternative to the Code requirements provided that pump differential pressure, flow rate, and bearing vibration measurements be taken during this testing, and that quarterly testing also measuring at least pump differential pressure and vibration be continued. Data from both of these testing frequencies should be trended, as required by IWP-6000 {or correspondingly OMa-1988 Part 6,17.3(f)}. Specifically, Part 6,17.3(f) states that: "The Owner shall maintain a record of each test which shall include the following:...(f) comparisons with allowable ranges of values and analysis of deviations."
The licensee is measuring pump flow rate and differential pressure quarterly us:ng a fixed-resistance test circuit. According to the Pump Program Tables, the licensee is also measuring vibration quarterly. The licensee is measuring pump flowrate (Ref.1), vibration, and differential pressure also at cold shutdowns or refueling outages. Based on the potential damage to the pumps when throttling the muumum flow rate, testing in accordance with the Code is impractical. The alternate testing proposed by the licensee provides reasonable assurance of operational readiness. Based on the impracticality of complying with the Code requirements and the burden on the licensee if the Code requirements were imposed, it is recommended that relief be granted for the alternative use of OMa-1988, Part 6,15.2(c) pursuant to 10 CFR 50.55a(f)(6)(i).
In any future revision of this request, the licensee should indicate that vibration is being measured quarterly.
2.3 Relief Reauest No. PR-3. Residual Heat Removal Pumps ReliefRequest: The licensee has requested relief, for the Residual Heat Removal Pumps *-P210 A&B, from the requirements of OMa-1988 Part 6,14.6.1.2(a), that the full-scale range of each analog instrument shall be not greater than three times the reference value.
Alternate Testing: When measuring the suction and discharge pressures of the RHR pumps, in lieu of satisfying the specified instrument range requirement of 14.6.1.2.(a), the instrutnents used for measuring pressure will meet the following specifications:
Accuracy: t0.25 percent of Full Scale (or better)
Range: Compound Gauge: 1st revolution 0-300 psig.
2nd revolution 300-600 psig. (or better) 5
licensee's Basisfor Relief: The licensee states that: "The installed suction and discharge pressure gauges of the RHR pumps are sized to accommodate the pressure range of 4 to 600 psig expected under standby and cold shutdown testing conditions (instrument range is 0-600 psig). As a result, the instrument range exceeds the Code requirement since, under some test conditions, the pump suction and/or discharge pressures can be considerably less than 200 psig, or 1/3 times the pressure gauge range.
In this particular case, the specification for the installed gauges is as follows:
Range: Compound gauge: 1st revolution 0-300 psig; 2nd revolution 300-600 psig.
Accuracy: i0.25 percent of full scale ( 1.5 psig)
Suction Pressure Suction pressure measurements are used primarily to derive the pump differential pressure through calculation. The accuracy of the suction pressure measurement normally has little or no effect on the results of this calculation since, generally, the pump discharge pressure exceeds the suction pressure by 2 or 3 orders of magnitude. When determming pump differential pressure (Dp), where typically RHR Pump Dp is approxhnately 100 psig (discharge and suction pressures approximately 120 and 20 psig, respectively) the maxhnum effect of suction pressure inaccuracy is il.5 psig, or 1.5 percent of the calculated Dp. This compares reasonably with the maximum allowable accuracy (per Code) of the suction pressure gauge of i2 percent of 60 psig, or il.2 psig.
Discharee Pressure Discharge pressu e measurements are also used to derive the pump differential pressure through calculation. When determmmg pump differential pressure (Dp), where typically RHR Pump Dp is approximately 100 psig, (discharge and suction pressures approximately 120 and 20 psig.,
respectively) the maximum effect of the discharge pressure inaccuracy is il.5 psig, or 1.5 percent of the calculated Dp. This is considered to be negligible when compared to the maximum allowable accuracy (per Code) of the discharge pressure gauge of i2 percent of 360 psig, or 7.2 psig.
Combination Based on the inaccuracies of the suction and discharge pressure gauges ( 1.5 psig), the largest possible error in the differential pressure calculation is 3 psig (assuming a conservative simple arithmetical method). Thus the maxunum inaccuracy is approximately three times better (5.4 psig) than the " allowable" combined Code inaccuracy of 8.4 psig."
Evaluation: In Draft NUREG-1482 Section 5.5.1 (Ref.10), the NRC notes that the Code (i.e.,
OMa-1988 Part 6,14.6.1.2) requires each analog instrument to have a full-scale range 3 times the reference value or less. The Code (i.e., Table 1) requires an accuracy for analog instruments of l
i2% of full-scale and i2% of total loop accuracy for a combination of instruments.
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When the range of a permanently installed analog instrument is greater than 3 times the reference value but the accuracy of the instrument is more conservative than the Code requirement, the NRC may grant relief when the combination of range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements.
The licensee's proposed alternctive testing is to use pressure gauges for pump suction and pump discharge pressures having a range of 0 to 600 psig. Under some test conditions, this range exceeds 3 times the reference value, since under some test conditions the pump suction and/or discharge pressure can be considerably less than 200 psig. However, the maximum inaccuracy of the suction pressure and the discharge pressure instruments individually is il.5%. The maximum inaccuracy of the combination of suction and discharge pressure readings is only i5.4 psig, which is less than 65% of the allowable combined Code inaccuracy for differential pressure readings of 6% of readings or i8.4 psig.
Therefore, the combination of range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements. The relief requested by the licensee provides an acceptable level of quality and safety and it is recommended that the alternate be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
2.4 Pump Relief Recuest No. PR-4. Generic Relief ReliefRequest: The licensee has requested relief, for all pumps in the program, from the requirements of OMa-1988 Part 6,14.6.2.1 that if the presence or absence of liquid in a gage line could produce a difference of more than 0.25% in the indicated value of the measured pressure, means shall be provided to ensure or determine the presence or absence of liquid as required for the static correction.
Alternate Testing: If the presence or absence of liquid in a gage line used for sensing pump suction pressure could produce a difference of more than 0.25% in the calculated value of the pump differential pressure, means shall be provided to ensure or determine the presence or absence of liquid as required for the static correction used.
Licensee's Basisfor Requesting Relief: The licensee states that: "When this requirement is applied where measured pressures are at relatively low levels, e.g., suction pressure, the 0.25% limit many times results in complicated venting procedures and related health physics risks associated with the disposal of radioactive contaminated water with no commensurate improvement of test reliability.
Normally, the only quantitative use of suction pressure measurements, where significant accuracy is required, is in determining pump differential pressure or head. In most cases the pump discharge pressure exceeds the suction pressure by at least a factor of five (5). This being the case, a.25%
error introduced into the suction pressure measurement results in an error of.05 % in the differential pressure calculation. This is insignificant in light of the potential 6% error allowance applied to both the suction and discharge pressure instruments (Paragrap't 4.6.1.1)."
Evaluation: The requirement to account for the presence or absence of liquid in pressure sensing lines is intended to ensure that accurate pressure measurements are obtained. Pump suction pressure itself is not required to determine pump performance, and there are no acceptance criteria for it.
This is recognized in ASME/ ANSI OMa-1988, Part 6, which eliminates pump suction pressure 7
measurement as a requirement, it was included in Section XI to help the licensee recognize that adequate suction pressure is required for proper pump operation. Its only quantitative use is in calculating pump differential pressure, if it cannot be measured directly. Therefore, the error in suction pressure measurement is only important to the calculated value of differential pressure. The licensee's alternative for accounting for liquid in the gage lines is acceptable since it meets the intent of the Code. However, it must be proceduralized properly to ensure that the accuracy of differential pressure measurements meets the Code requirements.
Since the licensee's proposed alternative provides an acceptable level of quality and safety, it is recommended that relief be authorized pursuant to 10 CFR 550.55(a)(3)(i) with provisions. The licensee should ensure that the calculation of pump differential pressure is proceduralized properly to account for liquid in the pressure sensing gage lines so that the accuracy of the final value meets Code requirements.
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3.0 VALVE RELIEF REQUESTS In accordance with 950.55a, Florida Power & Light Company has submitted two relief requests for specific valves at the Turkey Point Nuclear Power Plant Units 3 & 4 which are subject to inservice testing under the requirements of ASME Section XI. These relief requests have been reviewed to verify their technical basis and determine their acceptability. The first relief request, VR-1, is authorized by Generic Letter 89-04. The other relief request, VR-2, is reviewed and evaluated below.
3.1 Relief Recuest No. VR-2, Safety inlection System Check Valves ReliefRequest: The licensee has requested relief, for the Safety Injection System check valves 3-0873 A&B (4-0873 A&B) and 3-0874 A&B (4-0874 A&B), from the requirements of OMa-1988 Part 10,14.3.2 that check valves shall be exercised nominally every 3 months.
Alternate Testing: Valve closure testing will conform to the requirements of Turkey Point Technical Specification, Section 4.4.6.2.2.
(The requirements of Technical Specification 4.4.6.2.2 are as follows:
Each Reactor Coolant System Pressure Isolation Valve specified in Table 3.4-1 shall be demonstrated OPERABLE by verifying leakage to be within its limit:
At least once every 18 months; Prior to entering Mode 2 whenever the plant has been in cold shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months; Prior to returning a valve to service following maintenance, repair, or replacement work on the valve; and Following valve actuation due to automatic or manual action or flow through the valve:
- 1. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and
- 2. Prior to entering Mode 2 by verifying valve leakrate.)
Licensee's Basisfor Relief. The licensee states tha*: "Since these are simple-acting check valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leak test. Performance of such a test at each cold shutdown would constitute an unreasonable burden on the plant staff. The Technical Specifications, Section 4.4.6.2.2, establishes a more appropriate frequency for leak testing based on their pressure isolation function. The Technical Specification requirements are adequate to confirm valve operability in the closed position."
Emluation: All of the subject valves are two inch check valves located inside containment. Check valves 3-0873 A&B and 4-0873 A&B open to provide flowpaths for borated water injection from the SIS pumps to each of the RCS cold legs. They close to provide isolation of the Safety Injection System from the RCS high pressure. Check valves 3-0874 A&B and 4-0874 A&B open to provide 9
flowpaths for borated water injection from the SIS pumps to "A" and "B" RCS hot legs. They close to provide isolation of the safety injection system from the RCS high pressure.
Section XI requires that check valves performing a safety function in the closed position be exercised to that position, and allows for the licensee to verify the exercise by visually observing the valve, recording an electrical signal initiated by a position-indicating device, observing the appropriate pressure indication in the system, performing seat leakage testing, or using other positive means.
These valves do not have remote position indication and are located inside reactor containment. The only practical means of verifying valve closure is by performing a seat leakage test. To perform a seat leakage test during power operation or during every cold shutdowns would require personnel entry inside the containment, resulting in additional radiation exposure to personnel and subjecting personnel to safety hazards.
The proposed alternative requires leak testing every refueling outage (since the valves are exercised open at refueling outages per Refueling Outage Justifications ROJ-SI-l and 2), following maintenance, following actuation, and at some cold shutdowns.
Therefore, based on the impracticality of performing a seat leakage test during power operation or during every cold shutdown, the proposed alternative provides seat leakage testing to verify valve closure during refuelings and some cold shutdowns in accordance with the Code, and is acceptable pursuant to OMa-1988, Part 10,14.3.2.2(c) and (e).
Although the Technical Specification is adequate to verify closure, if they are used in lieu of the Code's leakage testing requirements (i.e.,14.2.2.3) the licensee should note that in Generic Letter 89-04, Position 4, the NRC describes concerns with the adequacy of testing PIVs. The leak rate testing specified in a plant's Technical Specifications is considered adequate to meet the intent of IWV-3420 and OMa-1988, Part 1014.2.2.3. As noted in Position 4, the licensee should ensure that each PIV is leak tested individually. Furthermore, such testing should be conducted at the differential pressure required by the Code, or the measured leakage should be adjusted as provided by the Code.
The licensee may consider the leakage testing performed to meet the Technical Specification requirements to also meet the IST requirements if the intent of the Code is met, e.g., leakage limits are established, corrective actions taken as required, and valves are individually leak tested.
However, the licensee should ensure that the test differential pressure specified in the Technical Specifications, if applicable, is essentially equivalent to the " function maximum pressure differential," or that the measured leakage is adjusted to the " function maximum pressure differential" in accordance with the formula specified in the Code, i.e. IWV-3423(e) or OM-10, 14.2.2.3(b)(4).
While other aspects of the Technical Specifications have been reviewed and determined by the NRC to be acceptable, the licensee should ensure that any testing requirements that are not specifically detailed in the Technical Specifications are imposed on the PlVs to comply with the leakage testing requirements of the IST Program. The major difference between Technical Specification and IST l
requirements relates to the acceptance criteria specified in some licensees' Technical Specifications l
between a nominal leakage limit and an upper limit. If this is allowed by the Technical Specifications, then this is considered acceptable for acceptance criteria for the IST Program.
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In the specific case of Turkey Point, Technical Specification 3.3.6.2 does specify an upper leakage limit for PIVs. Therefore, the Technical Specification leakage limits are acceptable as acceptance criteria for the IST Program. However, the licensee must ensure that the pressure differential requirements of OM-10,14.2.2.3 as discussed above are met.
Additionally, several apparent inconsistencies were noted during the review of this relief request.
Specifically, all of the valves identified in the relief request are listed as Reactor Coolant System Pressure Isolation Valves (PlVs) in Table 3.4-1 of the Technical Specifications (Ref.15). It appears that the licensee inadvertently has omitted valves 3-0873C and 4-0873C from the relief request, not only because these valves provide an analogous function to 3-0873 A&B and 4-0873 A&B, but also because they are listed in the Valve Program Tables as being subject to Valve Relief Request VR-2 for exercising closed, and they are listed in Table 3.4-1 of the Technical Specifications as Reactor Coolant System Pressure Isolation Valves.
Furthermore, the_N51ve Program Tables indicate that the SIS Cold Leg Injection check valves 3-E 0875A thru C and 4 0875A thru C are subject to Valve Relief Request VR-2 for exercising closed, and are also lined in Table 3.4-1 of the Technical Specifications, yet these valves are not included in the request.
The Valve Program Tables indicate that SIS Cold Leg Injection check valves 3-0876A thru C, also PIVs listed on Table 3.4-1 of the Technical Specifications, are exercised closed per an unspecified relief request. It appears that the intended relief request is VR-2.
Check valves 3-0876 D&E and 4-0876 D&E on the Alternate Low Head Safety Injection lines from the Residual Heat Removal (RHR) heat exchangers, also listed on Table 3.4-1 of the Technical Specifications, have neither an exercise open nor an exercise close test listed in the Valve Program Tables. Only a seat leakage test for PIVs at refueling outages is specified. Although the licensee may consider 3-0876 D&E and 4-0876 D&E as passive valves because they are isolated upstream by normally closed MOV-3-872 and MOV-4-872, the licensee should verify whether these valves perform a safety function in the open position and whether an exercise closed test, which may be satisfied by the seat leakage test, is also required.
The licensee should note that the NRC considers check valves, and other automatic valves designed to close without operator action after an accident and for which flow is not blocked, as " active" valves which would be classified as such in the IST Program. Similar criteria can be applied to the opening function of a check valve. The flow through a check valve in a system is " blocked" by a flange closure in the line, a locked closed valve other than a check valve, or some other means of precluding flow through the system. A valve is " positively held in place" if it has an operator or other auxiliary device to maintain the disk in an open or closed position. Even though the licensee may have considered these valves passive from a single failure criterion, they must open to perform a safety function, and they should be considered active for testing purposes.
In summary, the licensee could convert this request into a deferral justification and should include valves:
3-0873C and 4-0873C 3-0875A thru C and 4-0875A thru C.
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e The licensee should also verify whether:
Cold Leg Injection check valves 3-0876A thru C should be included in the request, Valves 3-0876 D&E and 4-0876 D&E on the Alternate Low Head Safety Injection lines from the Residual Heat Removal (RHR) heat exchangers perform a safety function in the open j
position and whether a quarterly exercise closed test is also required. The licensee should aise review whether these valves are active rather than passive valves.
the pressure differential requirements of OM-10,14.2.2.3 for seat leakage testing are met by j
the Technical Specification required testing for PIVs.
If the licensee determines that the proposed leak rate testing in the Technical Specifications are not adequate to meet the Code requirements for leak rate testing (i.e.,14.2.2.3), a relief request should be prepared and submitted for review.
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4.0 DEFERRED TESTING JUSTIFICATIONS Florida Power & Light Co. has submitted 32 Cold Shutdown Justifications and 26 Refueling Outage Justifications which document the. impracticality of testing valves quarterly, during operation, as required by OMa-1988, Part 10. These justifications were reviewed to verify their technical basis.
Generally, those tests involving a plant trip, damage to a system or component, or excessive personnel hazards are not considered practical. Removing one train for testing or entering a limiting condition of operation is not sufficient basis alone for not performing the required tests, unless some other justification is provided such as that the testing renders systems inoperable for extended periods of time. As discussed in Generic Letter 91-18, it is not the intent of IST to cause unwarranted plant shutdowns or to unnecessarily challenge other safety systems. Other factors, such as the effect on plant safety or risk and the difficulty of the test may be considered.
In some of the Cold Shutdown Justifications (CSJs), the licensee has not provided sufficient information as to the time av;.ilable before damage to equipment would occur following closure of a valve, or failure in the closed position. The licensee should provide additional information in the basis to justify why the plant could not achieve a normal shutdown in the event that a valve failed in the closed position. In other cases, the licensee's basis for deferring testing is that testing could place the plant in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Limiting Condition of Operation (LCO) action statement. As discussed above, this is not a sufficient basis for not performing the required tests.
For several of the Refueling Outage Justifications (ROJs) relating to the Safety Injection System, che licensee should revise the justifications to clarify whether the full-stroke open test is conducted at the maximum required accident flow rate as discussed in Generic Letter 89-04, Position 1. If a reduced flow rate is used, a positive means for verifying the valves open to the full-stroke position is required. Such means for verification must meet all of the six criteria identified in Position 1. Draft NUREG-1482, Section 4.1.2, further discusses the use of nonintrusive techniques as a means for verifying valve position and states the acceptability of sample testing.
BNL's evaluation of each Cold Shutdown Justification and Refueling Outage Justification is provided in Tables 4-1 and 4-2, respectively. Each justification has been given an item number to aid with the discussions. The anomalies associated with the specific justifications are presented in Paragraph 5.5 and 5.6 of this TER.
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Table 4.1 Turkey Point Units 3 and 4 Cold Shutdown Justification Evaluation Item Valve Drawing
' Licensee's Justification Proposed Alternate No.
Identification '
No.
For Deferred Testing Testing COMPONENT COOLING WATER CC-1 MOV-3-0626 and MOV-5613(4)-M-3030-5(4),
"These valves are required to be open to Exercise to closed position with 4-0626, 3" motor operated Rev. 5, " Component ensure continued cooling of reactor coolant stroke time measured during cold gate valves, MOV-3-0716 Cooling Water System pump auxiliary componerts including the shutdown with the reactor coolant A&B, MOV-3-0730, and (Sheet 5)"
controlled seal leakage system, the pump system cooled down and vented.
MOV-4-0716 A&B, seals, and the main drive motors. Cicsing MOV-4-0730, 6* motor these valves during pump operation could Position indication verification every operated gate valves, Cat.
result in degradation of the RCP seals and 2 years.
B, Component Cooling motors, eventually resulting in potential Water Supply / Return RCP damage and subsequent plant Isolation Valves, normally shutdown."
open Evaluation: These valves are normally open in the flow paths to the thermal barrier cooling coil and the upper and lower bearing oil cooling. Upon receip of a high-high contairiment pressure signal thev valves close. These valves fail as is upon loss of power.
Closing these valves for testing could significantly heat the motors and the pump seals. It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly because this could challenge the integrity of the RCP seals and/or exceed the design temperatures for other auxiliary components in the thermal barrier and cause the motors to be tripped due to high beanng oil temperature. In Draft NUREG-1482,13.1.1.4 states that Reactor Coolant pumps need not be stopped for cold shutdown testing. The NRC recommends that affected valves be tested during plant outages when RC pumps are stopped for a sufficient period of time and on a refueling outage schedule, but not more than once every 92 days.
The alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Preposed Alternate No.
Identification No.
For Deferred Testing Testing CC-2 MOV-3-1417, 5613(4)-M-3030-5(4),
"These valves provide normal cooling to the Exercise to closed position with MOV-3-1418, and Rev. 5. " Component normal containment coolers, control rod stroke time measured at cold MOV-4-1417, Cooling Water System drive mechanism coolers, and the primaty shutdown.
MOV-4-1418,10" motor (Sheet 5)"
shield cooling coils. Exercising any of these operated gate valves, Cat.
valves during plant operation at power could Position indication verification every B, Component Cooling cause overheating of the associated 2 years.
Containment components. Should any one of these valves Supply / Return Isolation fail to reopen after closure serious damage Valves, normally open to equipment could occur necessitating an immediate plant shutdown and cooldown."
Evaluation: These valves are the supply and return valves to the normal containment coolers, control rod drive mechanism coolers, and the primary shield wall coils. Upon receipt of a safety injection signal these valves close. These valves fail as is upon loss of power.
It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly because with the plant at power damage due to overheating could occur to the control rod drive mechanisms fan motors, shield wall, and containment cooler fan motors. The alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
e 15
a Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing CC-3 3-0738, 4-0738, 3" check 5613(4)-M-3030-5(4),
"These valves are simple check valves Exercise to the closed position at valve, Cat. C, Rev. 5, " Component located inside the containment building with cold shutdowns.
Excess Letdown Heat Cooling Water System no external or remote position inthcation; Exchanger CCW Supply (Sheet 5)"
thus the only practical method of Check Valves, normally determining disc position is via a backflow closed or backleakage test. During the performance of such a test, a considerable length of piping (and potentially the heat exchanger) is drained. Since the CCW water is treated with a chemical corrosion inhibitor, this would create a significant waste disposal problem, whereby performance of this test on a quarterly basis would prove to be an unwarranted burden on the plant staff.'
Evaluation: This check valve closes to protect against backflow of CCW flow through the excess letdown heat exchanger.
It is impractical to test these valves quarterly because both the valves and test connections are located inside containment and an excessive length of time would be required to setup the testing. This may result in increased personnel exposure and delay plant operations.
The alternative provides exercising to the closed position during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification.
No.
For Deferred Testing l
Testing REACTOR COOLANT SYSTEM RC-1 PCV-3-0455C, 5613(4)-M-3G41-2, Rev.
" Exercising these valves at power has the Fail safe test at cold shutdowns.
PCV-3-0456, and 12 " Reactor Coolant potential for causing seat damage that could Exercise to closed and open PCV-4-0455C, System (Sheet 2)"
result in unacceptable RCS leakage.
positions with stroke time measured PCV-4-0456, 2" air Cons,quently, this could necessitate isolation at cold shutdowns.
operated globe valves, of the affected PORV(s)."
Cat. B, Position indication verification every Power-Operated Relief 2 years.
Valves, normally closed Evaluation: It is impractical to part-stroke or full-stroke exercise these valves to the open position quarterly because this could result in a loss of coolant accident. Generic Letter 90-06 states that stroke testing of the PORVs should not be performed during power operation due to the risk associated with challenging these valves in this condition.
The alternative provides full-stroke exercising to the open and closed position and fail safe testing at cold shutdowns in accordance with OMa-1988 Part 10, 14.2.1.2(c) and 14.2.1.6.
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Table 4.1 (Cont'd)
Item Valve Drawing -
. Licensee's Justification Proposed Attemate No.
Identification No.
For Deferred Testing Testing RC-2 SV-3-6318 A&B, 5613(4)-M-3041-2, Rev.
- These valves are administratively Exercise to open position with stroke SV-3-6611, SV-6612, and 12 " Reactor Coolant controlled in the key-locked closed position time measured during cold shutdown SV-4-6318 A&B, System (Sheet 2)"
to prevent inadvertent operation. Since with the reactor coolant system SV-4-6611, SV-4-6612, these are Class I isolation valves for the cooled down and vented.
l' solenoid operated globe reactor coolant system, failure of a valve to valves, Cat. B, Reactor close or leakage following closure could Position indication verification every Coolant System Vents, result in a loss of coolant in excess of the 2 years.
locked closed limits imposed by the Plant Technical Specifications. Furthermore, failure of the valve to indicate a return to the fully closed position following exercising, could likely result in a containment entry at power or a plant shutdown."
Evaluation: These are the Reactor Vessel Head Vent Valves.
It is impractical to exercise these reactor head vent valves to the open position qu,arterly because these valves are administratively controlled in the key-locked closed position to prevent inadvertent operation, and prevent the possibility of a loss of coolant accident in excess of the limits imposed by the Plant Technical Specifications.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
I Item Valve Drawing
' Licensee's Justification Proposed Alternate No.
Identification '
No.
' For Deferred Testing Testing CIIEMICAL & VOLUME CONTROL SYNmM CV-1 CV-3-0204, and 5613(4)-M-3047-1, Rev.
" Closing these valves during operation Fail safe test at cold shutdowns.
CV-4-0204, 2" air 8, " Chemical and would result in undesirable pressurizer level Exercise to closed position with operated globe valve, Cat.
Volume Control System or CVCS system transients with the potential stroke time measured at cold A,
Charging and Letdown for a plant trip. If a valve failed to reopen, shutdowns.
Letdown Line Outboard (Sheet 1)"
then an expedited plant shutdown would be Isolation Valves, normally required."
Seat leakrate test per 10 CFR 50, open. Also, containment App. J every 2 years, Position isolation valves for indication verification every 2 years.
penetration P-14 Evaluation: These valves are in series with, and redundant to, the 3 air-operated valves located inside containment on the letdown line. Upon receipt of a safety injection signal these valves close.
Exercising these containment isolation valves during operation quarterly would introduce upsets in the operation of the letdown, charging and seal injection subsystems. If the closure of the valve lasts too long, or fails in that position, the, pressurizer level would be affected with the' likelihood of a Unit trip.
It is impractical to part-stroke or full-stroke these valves closed quarterly because of the resulting RCS transients that can challenge the reactor protection system.
The alternative provides for full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing
- Licensee's Justincation Proposed Alternate No.
Identification No.
For Deferred Testing Testing CV-2 3-0357, and 5613(4)-M-3047-2, Rev.
" Exercising these check valves during Exercise to open position at cold 4-0357, 4" check valve, 12, " Chemical and operation would require injection of RWST shutdowns.
Cat. C, Volume Control System borated water into the reactor coolant RWST Discharge Valves, Charging and Iztdown system. This would, in turn, result in normally closed (Sheet 2)"
boration of the reactor coolant system with an adverse reaction in reactor power and the potential of a power transient."
Evaluation: These valves are in the line from the Refueling Water Storage Tank to the charging pump suction header, and open to provide a backup for emergency boration. The charging pump in operation continues flow during a LOCA because it does not receive a safety injection signal. The charging pumps would draw suction from the RWST via the safety injection line. Hence, it is required to be f>dl-stroke exercised to the open position.
If tested during power operation, the RCS pressure prevents the charging pump from reaching full injection flow. Flow would have to be drawn from the RWST through check valve 3(4)-0357, which in turn would result in an incTease in boron concentration in the RCS and a power transient.
The alternative provides full-stroke exercising to the open position at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Prop Jed Alternate No.
Identification No.
For Deferred Testing Testing CV-3 IICV-3-0121, and 5613(4)-M-3047-2, Rev.
"These valves provide the primary flow path Fail safe test and exctrise to open IICV-4-0121, 3* air 12, " Chemical and to the RCS via the Charging Pumps.
position at cold shutdowns.
operated globe valve, Cat.
Volume Control System Measuring valve opening stroke time would B,
Charging and letdown first necessitate valve closure. Closing these Charging Line Flow (Sheet 2)"
valves during operation could result in Control Valves, normally oscillations in RCP seal injection flow and open undesirable pressurizer level transients with the potential for a plant trip."
Evaluation: Tase are the flow control valves in the charging line from the chzuging pumps to the non-regenerative (or letdown) heat exchanger. They are open during nocual operation and emergency boration. In s LOCA, the letdown and seal water lines are isolated but the charging pump in operation continues flow. IIence, in a LOCA, the charging line flow control valves remain open. In addition, the emergency boration flow must pass through this valve and seal water injection line.
It is impractical to part-stroke or fill-stroke exercise these valves to the open or closed position quarterly because this action could cause a pressurizer level transient and possible plant trip.
The alternative provides bil-stroke exercising to the open position :1 cold shutdowns in accordance with OMc-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Deferird Testing Testing CV-4 LCV-3-01ISB, and 5613(4)-M-3047-2, Rev.
" Opening these valves during operation Exercise to open position with stroke LCV-4-01ISB, 4" air
- 12. "Che*nical and would result in injection of RWST borated time measured at cold shutdowns.
operated butterfly valve, Volume Control System water intc the reactor coolant system. This Cat. B, Chargirg and letdown would, in turn, result in boration of the Position indication verification every RWST Outlet Valves, (Sheet 2)*
reactor coolant system with an adverse 2 years.
normally closed reaction in reactor power and the potential for a power transient."
Evaluation: Hese valves are in the line from the Refueling Water Storage Tank to the charging pump suction header. These valves open as a backup for emergency boration. He charging pump in operation continues flow during a IDCA because it does not receive a safety injection signal. The charging pumps would draw suction from the RWST via the safety injection line.
If tested during power operation, the RCS pressure prevents the charging pump from reaching full injection flow. Flow would have to be drawn from the RWST through level control valve 3(4)-0115B, which in turn would result in an increase in boron concentration in the RCS and a power transient.
The alternative provides full-stroke exercising to the open position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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i Table 4.1 (Cont'd)
Item Valve Drawing -
Licensee's Justification Proposed Altensate No.
" Identification No.
For Deferred Testing Testing.
CV-5 LCV-3-Oll5C, and 5613(4)-M-3047-2, Rev.
" Closing these valves during operation Exercise to closed position with LCV-4-01ISC, 4" motor 12, " Chemical and would necessitate configuring the Charging stroke time measured at cold operated gate valve, Cat.
Volume Control System Pump suction from the VCT to the RWST shutdowns.
B, Charging and Letdown in order to maintain charging flow.
Volume Control Tank (Sheet 2)"
Injection of RWST borated water into the Position indication verification every Outlet Valves, normally RCS would result in over boration with an 2 years.
open adverse reaction in reactor power level and a potential for a reactor power transient."
Evaluation: These valves are located between the cutlet of the VCT and the charging pumps. These valves fail as is upon loss of power. Upon receipt of a safety injection signal these valves close to isolate the VCT.
It is impractical to part-stroke or full-stroke exercise these valves closed quarterly because of potential for a reactor power transient due to overboration of the j
RCS as a result of the need to align the charging pumps' suction to the RWST to maintain charging flow and prevent loss of pump net positive suction head (NPSil).
The alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing
. Ilcensee's Justification Proposed Alternate No.
Identification -
No.
For Deferred Testing
. Testing CV-6 MOV-3-0381, 5613(4)-ht-3047-3, Rev.
- Exercising these valves to the closed Exercise to closed position with MOV-3-6386, and 10,
- Chemical and position when the reactor coolant pumps stroke time measured during cold MOV-4-0381, Volume Control System (RCP's) are in operation would interrupt shutdowns with the reactor coolant MOV-4-6386, 3* motor Seal Water injection to flow from the RCP seals and may result in system cooled down and vented.
operated gate valves, Cat.
RCP (Sheet 3)*
damage to the pumps' seals."
A. RCP Seal Water Seat leakrate test per 10 CFR 50, Return isolation Valves, App. J every 2 years. Position normally open between indication verification every 2 years.
penetration P-25 Evaluation: Upon receipt of a safety injection signal these valves close.
It is impractical to exercise these valves to the closed position quarterly because this action could damage the reactor coolant pump (RCP) seals. In Draft NUREG-1482.13.1.1.4 states that RCPs need not be stopped for cold shutdown testing. The NRC recommends that affected valves be tested and cause a loss of cooling flow during plant outages when RCPs ate stopped for a sufficient period of time and on a refueling outage schedule, but not more than once every 92 days.
The alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
. For Deferred Testing
. Testing RESIDUAL IIEAT REMOVAL SYSTEM RH-1 3-0753 A&D, and 5613(4)-M-3050-1, Rev.
"The only flow path available for full-flow Partial exercise to the open position 4-0753 A&B,10* check 8, " Residual Heat exercising these valves to the open position quarterly (during plant operation).
valves, Cat. C, Residual Removal System (Sheet requires pumping from each RHR pump to Heat Removal (RHR) 1)*
the reactor coolant system. The residual Exercise to the open and closed Pump Discharge Check heat removal system is designed and positions at cold shutdowns.
Valves, normally closed interlocked so as to make it impossible to pump to the reactor coolant system at elevated pressures. Note that these valves will be partial-stroke exercised open on a quarterly basis via the minimum flow test lines."
Evaluation: These check valves open to permit flow from the RHR pumps during normal shutdown and also during a large LOCA. These valves are required to close to protect the RHR pumps from reverse flow.
It is impractical to quarterly full-stroke exercise these valves open quarterly because the RHP, pumps cannot develop sufficient discharge pressure to inject into the RCS.
The alternative provides part-stroke exercising to the open position quarterly and full-stroke exercising to the open position at cold shutdowns in accordance with OMa-1988, Part 10,14.3.2.2(b).
Ilowever, the licensee has provided no information as to why the valves cannot be verified closed quarterly, because based upon review of the P&lD these check valves are outside containment and there appear to be available test connections and, as discussed in GL 89-04 Position 3 (Ref. 7), verification of closure may be achieved by a leak test, even if no leakage limits apply, and verifying closure capability does not require exercising the valve open first.
l The licensee should revise and resubmit this deferral to discuss the impracticality of verifying closure of these valves quarterly.
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Table 4.1 (Cont'd) i i
Item Valve Drawing Licensee's Justification Proposed Alternate l
No.
Identification No.
For Deferred Testing Testing Ril-2 MOV-3-0750, 5613(4)-M-3050-1, Rev.
- Rese valves are provided with electrical Exercise to closed and open MOV-3-0751, and
- 8. " Residual IIcat interlocks that prevent opening when aay positions with stroke time measured MOV-4-0750, Removal System (Sheet one of the following conditions exists (in the at cold shutdowns.
MOV-4-0751,14* motor 1)*
corresponding unit):
operated gate valves, Cat.
- Reactor coolant system pressure exceeds Seat leakrate test for pressure A. RIIR Supply from the 525 psig; isolation valves and position Reactor Coolant System
- MOV *-862 A or B is open; or indication verification every 2 years.
Isolation
- MOV *-863 A or B is open.
Valves, locked closed his precludes exercising these valves in any other plant condition than cold shutdown."
Evaluation: It is impractical to full-stroke exercise these valves open or closed quarterly because these valves are pressure isolation valves which protect the RilR system from RCS pressure [and the potential for an inter-system LDCA (ISLOCA)].
De alternative provides full' stroke exercising to the open and closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
Ril-3 MOV-3-0862 A&B, 5613(4)-M-3050-1, Rev.
- Exercising and failure of either of these Exercise to closed position with MOV-4-0862 A&B,14" 8, " Residual Heat valves in the closed position during testing stroke time measured at cold motor operated gate Removal System (Sheet will isolate both unit's shutdowns.
valves, Cat. B, RIIR 1)"
residual heat removal pumps from the Pump Suction Isolation respective refueling water storage tank Position indication verification every Valves, locked open rendering them inoperable and losing all 2 years.
capability oflow-pressure safety injection."
Evaluation: Thesc valves provide double isolation for the Residual Heat Removal pump suction from the Refueling Water Storage Tank, it is impractical to full-stroke exercise 4'se valves quarterly since closure of either of these valves would render both trains of RIIR pumps, which are also the Low Pressure Safety injection Pumps, inoperable.
The alternative provides full-stroke exercising to the open and closed positions at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd)
Itern Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Defemd Testing -
Testing RII-4 MOV-3-0863 A&B, 5613(4)-M-3050-1, Rev.
" Failure of either of these valves in the open Exercise to open position with stroke MOV-4-0863 A&B, 8*
8, " Residual licat position during testing will open a time measured at cold shutdowns.
motor operated gate Removal System (Sheet recirculation path from the discharge of the valves, Cat. B, Safety 1)"
RIIR beat exchangers to the RWST or Position indication verification every injection Pump suction of the RIIR pumps. In the event of a 2 years.
Recirculation Phase safety injection signal, this would result in Suction Stop Valves, diverting flow from the injection flow path locked closed and thus adversely impact the effectiveness of the LP safety injection system function."
Evaluation: These locked closed valves are opened in the recirculation phase of a IJOCA to provide a suction source for the high head safety injection pumps and containment spray pumps while the RWST isolation valves are closed.
These valves if opened during operation would develop a circular flow path from the RWST to RilR pumps and RIIR heat exchangers through the valves with a return to the RI{R pumps. In addition to the possibility of a safety injection signal that would adversely impact the effectiveness of the LP safety injection system, there is also the burden of draining the circular test loop after testing. Therefore it is impractical to test these valves quarterly.
The alternative provides full-stroke exercising to the open position at cold shutdowns in accordance with OMA-1988 Part 10,14.2.1.2(c).
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Table 4.1 (Cont'd) -
I Item Valve.
. Drawing IJcensee's Justification Pavposed Alternate No, Identification.
. No.
For Desemd Testing T*=eks -
CONTAINMENT PURGE SYSTEM CP-1 POV-3-2600, 5613(4)-M-3053-1, Rev.
"Due to the history of these valves with Fail safe test and exercise to closed POV-3-2602, and 8 " Containment Purge respect to operational-related seat leakage, position with stroke time measured i
POV-4-2600, System and Ps.skm the plant staff has imposed restnctions on at cold shutdowns.
POV-4-2602, 48" and 54" Cooling System (Sheet their operation whereby unnecessary cycling air operated butterfly 1)"
of the va ves is to be avoided and additional Seat leakrate test per 10 CFR 50, valves, Cat. A, leak tests are performed based on cycling App. J and, Position indication Containment Building frequency. 'Ihus, it is undesirable to cycle verification every 2 years.
Purge Supply / Exhaust these valves more often than is absolutely Outboard Isolation' necenaary. In addition, typically these Valves, normally closed valves are closed (their safety-related position) dunng plant operation and are usually opened only for containment ventilation during shutdown penods."
Evaluation: It is impractical to part-stroke or full-stroke exercise these valves quanctly because of their large size, 48 inches and 54 inches in diameter, and potential for damage as a result of frequent cycling, and their required normally closed position during plant operation.
The alternative provides full-stroke exercising to the closed position at cold shutdown in accordance with OMa-1988 Part 10,14.2.1.2(c) and fait safe testing at cold shutdowns in wh with 14.2.1.6 and 14.2.1.1.
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing CP-2 POV-3-2601, 5613(4)-M-3053-1, Rev.
"Due to the history of these valves with Fail safe test and exercise to closed POV-3-2603, and 8, " Containment Purge respect to operational-related seat leakage, position with stroke time measured POV-4-2601, System and Penetration the plant staff has imposed restrictions on at cold shutdowns.
POV-4-2603, 48* and 54*
Cooling System (Sheet their operation whereby unnecessary cycling air operated butterfly I)*
of the valves is to be avoided and additional Seat leakrate test per 10 CFR 50, valves, Cat. A, leak tests are performed based on cycling App. J, and, Position indication Containment Building frequency. Thus, it is undesirable to cycle verification every 2 years.
Purge Supply / Exhaust these valves more often than is absolutely Inboard Isolation necessary. In addition, typically these valves Valves, normally closed are closed (their safety-related position) during plant operation and are usually opened only for containment ventilation during shutdown periods."
Evaluation: It is impractical to part-stroke or full-stroke exercise these valves quarterly because of their large size,48 inches and 54 inches in diameter, and potential for damage as a result of frequent cycling, and their required normally closed position during plant operation.
The alternative provides full-stroke exercising to the closed position at cold shutdown in accordance with OMa-1988 Part 10,14.2.1.2(c) and fail safe testing at cold shutdowns in accordance with 14.2.1.6 and 14.2.1.1.
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Table 4.1 (Cont'd)
Item Valve Drawing Ucensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing SAFETY INJECTION SYSTEM SI-l MOV-0878 A&B, 4" 5613(4)-M-3062-1, Rev.
"The Turkey Point plant design takes credit Exercise to closed position with motor operated gate 6, " Safety Injection for the added redundancy of the shared stroke time measured at cold valves, Cat. B, SIS Pump System (Sheet 1)"
safety injection systems and the capability shutdowns.
Discharge Unit Cross-Tie, of mamtnining four (4) pumps capable of normally open taking suction from either refueling water Position indication verification every storage tank. De plant Technical 2 years.
Specifications require three of the four pumps to be operable during single unit power operation, and all four pumps to be operable during dual unit power operation, when Tavg is greater than 380 deg.F. Failure of either one of these valves to reopen while testing would reduce the capability of the safety injection system to respond to a LOCA in the operating unit (s) and place the plants in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO action statement."
Evaluation: It is not apparent from the Turkey Point UFSAR, Appendix A, paragraph on " Sharing of the fligh IIcad Safety Injection Pumps" under what circumstances these normally open valves would be required to close, nor whether these valves would be required to reopen following closure.
De possibility of entering an LCO is not a sufficient basis for not performing the required testing, unless the testing renders systems inoperable for an extended period of time. He licensee should full-stroke exercise these valves closed quarterly within the Technical Specification time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or provide justification that it is impractical to perform the testing during power operation.
He licensee should also verify whether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
30
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I Table 4.1 (Cont'd) l Item Valve Drawing Ucensee's Justification Proposed Alternate l
No.
Identification No.
. For Defemd Testing Testing SI-2 MOV-3-0856 A&B, and, 5613(4)-M-3062-1, Rev.
- Exercising or failure of either of these Exercise to closed position with MOV-4-0856 A&B,2*
6, " Safety injection valves in the closed po',ition during testing stroke time measured at cold motor operated globe System (Sheet 1)*
will prohibit flow thrrogh the minimum shutdowns.
valves, Cat. B, SI and CS flow recirculation lires for the associated Minimum Flow Une safety injection and contamment spray Position indication verification every Isolation Valves, normally pumps. Due to the probability of damage 2 years.
open should these pumps be staned and operated in this condition (no flow), exercising of these valves will only be performed during cold shutd)wn periods when these pumps are not required to be operable."
Evaluation: These valves isolate the containment spray recirculation line and the Accumulator test line to the RWST as well as the safety injection pump recirculation test line. In addition the failure of either of these valves removes the miniflow protection of the safety injection pumps.
It is impractical to pan-stroke or full-stroke exercise these valves to the closed position quanerly because of potential pump damage to the safety injection or containment spray pumps.
'Ihe alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Pan 10,14.2.1.2(c).
Ilowever, the licensee has only specified an exercise closed test in the Valve Program Tables. It appears that these valves may have a safety function in the open position as well to provide minimum flow. The licensee should review the safety function of these valves and revise the program accordingly.
8 31
I l
Table 4.1 (Cont'd) l Itern Valve Drawing Ucensee's Justification Proposed Alternate l
No.
Identification -
No.
. For Deferred Testing Testing I
SI-3 MOV-3-864 A&B, and 5613(4)-M-3062-1, Rev.
" Failure of these valves in the closed Exercise to the closed position with l
MOV-4-864 A&B,16" 6, " Safety Inj:ction position isolates the associated RWST stroke time measured at cold motor operated gate Systein (Shces 1)"
rendering the associated safety injection and shutdowns.
l valves, Cat. B, contatnment spray systems inoperable.
RWST Outlet Isolation Thus, closing any of these valves while the Position indication verification every Valves, locked open associated unit is not in a cold shutdown or 2 years.
refueling mode is considered imprudent."
Evaluation: These valves provide double isolation to the high head safety injecuon system and the RHR/LHS1 system. Testing these valves during normal operation would render both the high and low head safety injecuon systems inoperable. 'Ihese valves are closed either during a normal plant shutdown to prevent injection of the RWST inventory into the RCS or in the recirculation phase of a LOCA.
It is impractical to full-stroke exercise these valves closed quarterly because closure of either of these valves would render both trains of the safety injection system inoperable.
The alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
The licensee should also verify whether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
8 32 j
'.6 Table 4.1 (Cont'd)
Item Valve
' Drawing IJeensee's Jastl5 cation Proposed Alternate No.
Identification..
No.-
.For Deferred Testing Testing SI-4 MOV-3-866 A&B, and 5613(4)-M-3062-1, Rev.
" Opening either of these valves while the Exercise to' closed and open MOV-4-866 A&B, 2" 6, " Safety Injection RCS is at operating pressure subjects the Si positions with stroke time measured motor operated globe System (Sheet 1)"
system to a situation where the only at cold shutdowns.
valves, Cat. B, isolation between the RCS and SI systems is Hot leg Safety Injection established by a single check valve.
Position indication verification every.
(SI) Isolation Valves, Because of this, opemng these 2 years.
locked closed with motor-operated valves while the RCS is at breakers open pressures above 600 psig is considered to be imprudent."
Evaluation: These valves isolate safety injection flow to the hot legs and are opened if needed during the recirculation phase of a LOCA.
1 It is potentially unsafe to full-stroke exercise these valves open during normal operation because only a single check valve would remain to isolate the SI System from full RCS pressure.
i The alternative provides full-stroke exercising to the closed and open positions at cold shutdowns in accordance with OMa-1988 Pan 10,14.2.1.2(c).
~
i
}
l i
33
Table 4.1 (Cont'd)
Item Valve Drawing Ucensee's Justification Proposed Alternate No.
Identification No.
For Deferral Testing Testing SI-5 3-0876A, and 5613/4-M-3064-1, Rev.
"The only flow path available for full-flow Exercise to open position at cold 4-0876A, 8" cbd valve,
- 9. " Safety Injection exercising these valves is via the RilR shutdowns.
Cat. A&C, Accumulator System pumps to the reactor coolant system. The Imw-head Safety Inside Containment" residual heat removal system is designed and Exercise to the closed position at Injection /RIIR Injection interlocked to preclude injection into the
- other" test frequency (no relief Check Valves, normally reactor coolant system at elevated pressures.
request is referenced in the Valve closed, pressure isolation Program Tables).
valves Verifying closure of these valves would require establishing a test boundary which Seat leakrate test for pressure could only be obtained via isolation of the isolation valves every 2 years.
RWST, thereby rendering the Low IIcad Safety Injection System capability inoperative."
Evaluation: These check valves are in the RIIR/LIISI line and actuate after MOV-3-0744A opens to provide a flow path to the RCS cold legs.
It is impractical to part-stroke or full-stroke exercise these check valves to the open position quarterly because of the RilR interlock with the RCS plus the fact.
that the R11R pumps can not develop sufficient pressure to overcome the RCS pressure.
The licensee's alternative provides full-stroke exercising to the open position at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
It is not evident what the reference is for the "other" test frequency concerning closure testing. No relief request is referenced in the Program Table. Since these are pressure isolation valves, it appears that these valves should have been included in VR-2. The licensee should refer to the evaluation for VR-2. The licensee should revise this deferral justification accordingly.
8 34
Table 4.1 (Cont'd)
Item Valve Drawing Ucensee's Justification Proposed Altemate No.
Identi!Ication No.
For Deferred Testing Testing SI-6 3-0876 B&C. and (5613/4-M-3064-1)
" Verifying closure of these valves would Partial-stroke test to open position at 4-0876 B&C, 8* check 5613/4-M-3064-1, Rev.
require establishing a test boundary which cold shutdowns.
valves, Cat. A&C, 9 " Safety injection could only be obtained via isolation of the Low-Head Safety Accumulator System RWST, thereby rendering the Low Head Exercise to open position at each Injection /RHR injection Inside Containment" Safety Injection System inoperative."
refueling outage.
Check Valves, normally closed, pressure isolation Exercise to the closed position at valves "other" test frequency. (No relief request is referenced in the Valve Program Tables).
Seat leakrate test for pressure isolation valves every 2 years.
Evaluation: These check valves are in the RHR/LHSI line and activate after MOV-3-0744A and MOV-3-0744B open to provide a flow path to the RCS cold legs.
The part-stroke exercising open at cold shutdowns and full-stroke exercising open at refueling outages was separately presented by the licensee as a Refueling Outage Justification. The licensee should refer to the evaluation for ROJ-SI-4.
It is not evident what the reference is for the "other" test frequency concerning closure testing. No relief request is referenced in the Program Table. Since these are pressure isolation valves, it appears that these valves should have been included in VR-2. The licensee should refer to the evaluation for VR-2. The licensee should revise this deferral justification accordingly.
l l
35 l
l
Tab!e 4.1 (Cont'd)
Item Valve Drawing Ucensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing SI-7 3-0875 A,B,&C, and (5613/4-M-3064-1)
" Verifying closure of these valves during Panial-stroke test to open position at 4-0875 A,B,&C,10" 5613/4-M-3064-1, Rev.
power operation would require establishing a cold shutdowns.
check valves, Cat. A&C, 9, " Safety Injection test boundary which could only be obtained SIS Cold Irg Injection Accumulator System via isolation or de-pressurization of the SIS Exercise to open position at each Check Valves, normally Inside Containment" Accumulators, and is therefore considered reactor refueling outage, closed, pressure isolation imprudent."
valves Exercise to closed position at "other" test frequency (no relief request is referenced in the Valve Program Tables).
Seat leakrate test for pressure isolation valves every 2 years.
Evaluation: These are the primary pressure isolation valves for safety injection into each cold leg.
The part-stroke exercising open at cold shutdowns and full-stroke exercising open.at refueling outages was separately presented by the licensee as a Refueling Outage Justification. The licensee should refer to the evaluation for ROJ-SI-5.
It is not evident what the reference is for the "other" test frequency concerning closure testing. No relief request is referenced in the Program Table. Since these are pressure isolation valves, it appears that these valves should have been included in VR-2. The licensee should refer to the evaluation for VR-2. The licensee should revise this deferral justification accordingly.
36
~
Table 4.1 (Cont'd)
Item Valve Drawing
- IJcensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing SI.8 MOV-3-0744 A&B, and 5613/4-M-3064-1, Rev.
" Opening these valves while the RCS is at Exercise to the open and closed MOV-4-0744 A&B,10"
- 9. " Safety Injection operating pressure results in a situation positions with stroke time measured motor operated gate Accumulator System where the only isolation between the RCS at cold shutdowns.
valves, Cat. B, inside Containment" and RHR systems is established by two RHR/IAw-Head Cold Irg check valves. Failure of these check valves Position indication verification every Injection Isolation Valves, to seat could subject the RHR system to 2 years.
nornvJly closed pressures above its design pressure.
Therefore, opening these motor-operated valves while the RCS is at pressures above 600 psig is considered imprudent."
Evaluation: These valves open on a safety injection signal to provide a flow path to the RCS cold legs. Rese valves are not pressure isolation valves. The two downstream check valves are the pressure isolation valves.
It is potentially unsafe to part-stroke or full-stroke exercise these motor operated valves to the open position during normal operation because only two check valves would remain to isolate the SI System from the RCS pressure.
De alternative provides full-stroke exercising to the open and closed positions at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
l l
37 i
i i
Table 4.1 (Cont'd)
Item Valve Drawing
- Licensee's Justl5 cation Proposed Alternate No.
Identification No.
For Deferred Testing Testing SI-9 MOV-3-0865A thru 5613/4-M-3064-1, Rev.
"During plant operation these valves are Exercise to the closed position with MOV-3-0865C, and 9, " Safety injection required to be locked open to ensure stroke time measured at cold MOV-4-0865A thru Accum11ator System availability of the safety injection shutdowm.
MOV-4-0865C,10" motor Inside Containment" accumulators. Intentionally isolating an operated gate valves, Cat.
accumulator during operation is considered Position indication verification every B, Safety Injection to be imprudent. Furthermore, if a valve 2 years.
Accumulator Isolation were to fail in the closed position during Valves, locked open, testing, a plant shutdown would be breakers open required."
Evaluation: These are the St Accumulators' outlet isolation valves.
It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly because these valves are locked open with their breakers open during power operation.
The licensee's alternative of full-stroke exercising to the closed position at cold shutdowns is in accordance with OMa-1988 Part 10,14.2.1.2(c).
E i
38
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Defened Testing Testing MAIN STEAh! SYSTEM MS-1 3-10-0004 thru 3-10-0006, 5613(4)-M-3072-1, Rev.
"During plant operation at power, closure of Exercise to closed position but and 4-10-0004 thru 15, " Main Steam System any one of these valves is not practical as it stroke time not measured at cold 4-10-0006, 26* stop check (Sheet 1)*
would require isolating a stean generator shutdowns.
valves, non-Code, Cat. C, which would result in a severe transient on Main Steam Non-Return the steam and reactor systems and result in a inspection at least once per 10 year Valves, normally open probable plant trip.*
inspection interval.
Evaluation: These valves are not included within the ISI class boundaries and are exempt from the requirements of the Code but have been included in the Program to ensure that inservice testing is adequate to demonstrate their continued operability. Since these are not Code Category valves, no evaluation is required.
MS-2 CV-3-1606 thru 5613(4)-M-3072-1, Rev.
" Opening these valves during power Fail safe test, and exercise to the CV-3-1608, and 15, " Main Steam System operadon would result in unacceptable open and closed positions with CV-4-1606 thru (Sheet 1)*
power transients unless the valves are stroke time measured, at cold CV-4-1608, 6* air isolated prior to opening. Isolation of one shutdowns.
operated globe valves, of these lines will reduce the related plant Cat. B, capability to limit a pressure transient and Main Steam line prevent lifting of a safety valve in the event Atmospheric Steam Dump of such an occurrence."
Valves, normally closed Evaluation: It is impractical to exercise these valves open during normal operation because of power transients due to loss of steam and a possible plant trip.
The licensee's alternative provides for full-stroke exercising to the open and closed position and fail safe testing at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c) and 14.2.1.6.
e f
I 39 l
l l
1
Table 4.1 (Cont'd)
Item.
Valve Drawing Ucensee's Justification Proposed Altentate t
No.
Identification
. No.-
For Defertui Testing Testing MS-3 POV-3-2604, 5613(4)-M-3072-1, Rev.
"During plant operation at power, closure of Exercise to the closed position with POV-3-2605, 15, " Main Steam System any one of these valves is not practical as it stroke time measured at cold j
POV-3-2606, and (Sheet 1)"
would require isolating a steam generator shutdowns.
POV-4-2604, which would result in a severe transient on POV-4-2605, the steam and reactor systems and result in a Position indication verification every POV-4-2606, 26" air plant trip."
2 years.
operated, power assisted
- check valves, Cat. B&C, j Main Steam Isolation l Valves, normally open b
Evaluation: These are the normally open Main Steam Isolation Valves (MSIVs).
It is impractical to full-stroke exercise these valves closed during normal operation because of power transients due to loss of steam which will result in plant trip. However, de licensee has not provided a basis for not partial-stroke exercising these valves closed quarterly.
The licensee sho:ald revise and resubmit this justification to discuss the impracticality of partial-stroke exercising these valves closed quarterly.
0 40
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
IdentlGcation No.
For Deferred Testing Testing FEEDWATER SYSTEM FW-1 FCV-3-0478, 5613(4)-M-3074-3, Rev.
" Testing of these valves to the closed Fail safe test, and exercise to closed FCV-3-0488,
- 10. "Feedwater System position during plant operation above 20%
position with stroke time measured FCV-3-0498, and (Sheet 3)*
reactor power would result in severe steam at cold shutdowns.
FCV-4-0478, generator level transients and a plant trip."
FCV-4-0488, Position indication verification every FCV-4-0498,12" air 2 years.
operated globe valves, Cat. B, Main Feedwater Flow Control Valves, normally open Evaluation: These are the normally open Main Feedwater Flow Control Valves.
It is impractical to full-stroke exercise these valves to the closed position quarterly because they control the flow of feedwater to the steam generators and closure would result in loss of steam generator level control and a plant trip. Ilowever, the licensee has not provided a basis for not partial-stroke exercising these valves closed quarterly.
The licensee should revise and resubmit this justification to discuss the impracticalit; oi' partial-stake exercising these valves closed quarterly.
41
Table 4.1 (Cont'd)
Item Valve Drawing IJcensee's Jnstification Proposed Alternate No.
Identlilcation No.
For Deferred Testing Testing FW-2 FCV-3-0479, 5613(4)-M-3074-3, Rev.
" Opening these normally closed valves in Fail safe test, and exercise to closed FCV-3-0489, 10, *Feedwater System order to exercise them to the closed position position with stroke time measured FCV-3-0499, and (Sheet 3)*
would result in possible steam generator at cold shutdowns.
FCV-4-0479, level transients with the potential of a plant FCV-4-0489, trip. In addition, testing requires installation Position indication verification every FCV-4-0499, 4" air of electrical jumpers in various safeguard 2 years.
operated globe valves, relay racks which provides the potential for Cat. B, an inadvertent plant trip. These valves are Main Feedwater normally closed and remain so except for Regulating Valve Bypass low-power periods associated with startup Valves, normally closed and shutdown."
Evaluation: These are the normally closed Main Feedwater Regulating Valve Bypass Valves.
These valves are only used for startup and normal shutdown. It is impractical to test these valves to the open position at power because of the potential of a plant trip resulting from steam generator level changes and the test setup which requires installation of jumpers in various safeguard relay racks.
The licensee's alternative provides for full-stroke exercising with stroke time measured to the closed position and fail safe testing at cold shutdowTis in accordance with OMa-1988 Part 10,14.2.1.2(c),14.2.1.4, and 14.2.1.6.
4 42
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed Alternate No.
Identification No.
For Deferred Testing Testing AUXILIARY FEEDWATER SYSTEM AF-1 3-10-0381, 3-10-0382, 5613(4)-M-3075-1, Rev.
" Verification of closure capability for these Exercise to the closed position at 3-10-0383, and 6, " Auxiliary Feedwater valves requires isolation of the respective cold shutdowns.
4-10-0381, 4-10-0382, System Steam to steam supply line from its associated steam 4-10-0383, 4" check Auxiliary Feedwater generator and performing a backflow test.
Exercise to open position quarterly valves, Cat. C, Aux.
Pump Turbines (Sheet Considering the importance of the auxiliary (during plant operation).
Feedwater Steam Supply 1)*
feedwater system and the undesirability of Non-Return Valves, altering system lineups while the plant is normally closed operating, it would be imprudent to perform such a test at plant conditions other than cold shutdown."
Evaluation: These normally closed valves are in the steam supply to the three auxiliary steam driven turbines.
Flow diagrams (5613(4)-M-3075-1) and (5610(4)-M-3075-1) show that these valves can be full-stoke exercised open during the Turbine Driven Auxiliary Feedwater Pump quarterly test and therefore, testing quarterly is practical. However, verifying closure does require isolation to make use of the test connections around these check valves. 'Ihere are 3 (100%) steam driven pumpi for both Units. Only one auxiliary feedwater pump is needed per Unit.
Taking one out of service leaves two to serve both Units. The possibility of entering an LCO is not a sufficient basis for not performing the required testing unless the testing renders systems inoperable for an extended period of time.
The licensee should exercise these valves closed quarterly or revise and resubmit the deferral request to demonstrate that quarterly testing is impractical.
E 43
Table 4.2 Turkey Point Units 3 and 4 Refueling Outage Justification Evaluation item Valve Drawing Ltcensee's Justification Proposed No.
Identification No.
For Deferred Testing.
Afternate Testing PLANT SERVICE AIR SYSTEM SA-1 3-404205 5610-M-3013-1, Rev. 5, "These are simple check vahes with no external Per the Valve Program Tables, (4-40-0205)
" Instrument Air System means of position indication, :hus the only these valves are exercised 2 in. normally closed Service Air Distribution practical means of verifying closum i" by closed at Refueling Outages and Service Air From Units 1&2" performing a leaktest or backflow test. Ti:is would seat Icakage tested every 2 Containment Isolation, require entry into the containment building and years under Appendix J.
Cat. A/C, Check thus is impractical to perform Valves during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown."
Evaluation: These valves provide containment isolation for the Service Air System to Units 3 & 4 ring headers inside containment. It is impractical to full-stroke exercise these valves to the closed position quarterly because the valves are located inside containment and an extensive test set-up would be required to perform a seat leakage test.
llowever, the licensee has not provided justification as the why a reverse seat leakage test could not be performed during cold shutdowns. In its submittal of the Inservice Testing Program for the St. Lucie Unit 2 plant, Revision 2, September 15, 1992, the licensee indicated that analogous valve V-181270 in the Service Air System is full-stroke exercised to the closed position during those cold shutdowns in which the section of the Service Air system inside containment is in service. Therefore, the licensee should full-stroke exercise the subject valve {3-40-0205 (4-40-0205)} to the closed position during those cold shutdowns when the Service Air system header inside containment is in service or revise this justification to justify deferring full-stroke exercising the subject valves to the closed position during refueling outages.
I
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing COMPONENT COOLING WATER SYSTEM CC-1 3-0721 A, B & C (5613 (4)-M-3030-5(4),
"These piston check valves are located inside the Per the Valve Program Tables, (4-0721A, B, & C)
Rev. 5, " Component containment building with no external or remote these valves are exercised to CCW Supply to RCP Cooling Water System
- position indication; thus the only practical method the closed position at refueling Thermal Barrier of verifying closure is via a backflow or outages.
Cooling Coil 1.5 in.
backleakage test. Performance of such a test during normally open, Cat. C, shutdowns would require draining a considerable check valves length of piping.
Since the CCW water is treated with a chemical corrosion inhibitor, this would create a significant waste disposal problem, which would prove to be an unwarranted burden on the plant staff."
Evaluation: These valves are located inside containment. Hey are normally open and must close to prevent reverse flow of CCW through the Reactor Coolant Pumps' (RCPs) thermal barrier cooling coils.
These valves do not have remote position indication. It is impractical to full-stroke exercise these valves during power operation because it would interrupt CCW flow to the RCP thermal barrier cooling coils, which could damage the RCP seals. He licensee proposes to verify cloeure of these valves by a reverse flow or backleakage test during refueling outages. In Draft NUREG-1482,13.1.1.4 states that RCPs need not be stopped for cold shutdown testing. The NRC recommends that affected valves be tested during plant outages when RCPs are stopped for a sufficient period of time and on a refueling outage schedule, but not more than once every 92 days. OM-10 allows the test interval to be extended to refueling outages v, hen the tests cannot be practically performed during power operation or cold shutdown outages.
He proposed alternative provides exercising to the closed position during refueling outages in accordance with OMa-1988 Part 1014.3.2.2(e).
Ilowever, the licensee should revise this deferral request to conform to the guidance provided in Draft NUREG-1482,13.1.1.4.
45
Table 4.2 (Cont'd)
' Item
' Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing.
RESIDUAL HEAT REMOVAL SYSTEM q
RH-1 3-2052 (5613(4).M-3050-1),
"These valves are located between the containment Per the Valve Program Tables, (4-2052)
Rev. 5, " Residual Heat recirculation sump and the innermost containment -
these valves are full-stroke Containment Spray Removal System" isolation valve located outside containment. The exercised open during refueling Suction Relief only feasible method of exercising these valves to
- outages, Discharge 1 in.
the open position is to induce flow in the line via
- t normally closed Cat. C an alternate medium such as air or water. Opening '
Check Valves the drain connection valve during power operation would constitute a breach of containment integrity and therefore is considered imprudent. "Ihe i
injection of air or water into this system during cold shutdowns could ultimately result (in) airborne contamination or drainage to the containment sump, thereby creating a significant clean-up effort which would prove to be an unwarranted burden on the plant staff."
i e
i 46 v
w-m -
t-
, --., ~
w y-
.--r--
w
-w,-.
+a
...w--.
- u-..-
mc-s..
v-,i m
m
=
r s
Table 4.2 (Cont'd)
Item Valve Drawing
'Lidensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing Evaluation: These valves are on lines which discharge into the RHR South Recirculaton sump lines leading to the RHR Pump A suction header, the sumps being located inside containment. He lines discharge, at a point outside containment, into the RHR South Recirculation lines upstream of the normally closed RHR isolation valves which are located outside containment. There are no isolation valves inside containment leading from the recirculation sumps.
These valves do not have remote position indication. It is impractical to part-stroke or full-stroke open these valves during power operation because this would require opening a drein connection, and such opening of a drain connection would constitute a breach of containment integrity. It is impractical to part-stroke or full-stroke exercise these valves during cold shutdowns because this would require the injection of air or water into this system which could ultimately result in airborne contamination or drainage to the containment sump, thereby creating a significant clean-up effort which would prove to be an unwarranted burden on the plant staff.
He proposed alternative provides 'ull-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10 14.3.2.2(c).
8 47
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing NITkOGEN AND HYDROGEN SYSTEM NII-I 3-0518 5610-M-3065-1, Rev.
"'Ibese are simple check valves with no external Per the Valve Program Tables, (4-0518) 11 " Nitrogen and means of position indication, thus the only these valves are exercised Nitrogen Supply to Hydrogen Systems practical means of verifying closure is by closed at refueling outages and PRT Containment Nitrogen Supply" performing a leaktest or backflow test. This would seat leakage tested every 2 Isolation 0.75 in. Cat.
require entry into the containment building and years under Appendix L A/C, normally closed thus is impractical to perform during plant Check Valves operation and would be an unreasonable burden on the plant staff to perform at cold shutdown."
NH-2 3-0519 5610-M-3065-1, Rev.
"These valves are normally closed with the valve Per the Valve Program Tables, (4-0519) 11,
- Nitrogen and operating shaft for 3-0519 (stop check) in the open these valves are exercised Nitrogen Supply to Hydrogen Systems position. The only effective method of verifying closed at refueling outages and PR r Containment Nitrogen Supply" closure of these valves is to perform a reverse flow seat leakage tested every 2 Isolation 0.75 in. Cat.
(leak test). This would require entry into the years under Appendix J.
A/C, normally closed containment building and thus is impractical to Stop Check Valves perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown."
l l
48 l
l
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing
)
l Evaluation: (NH-1 and NH-2). Both valves 3-0518 (4-0518) and 3-0519 (4-0519) are located inside containment and in series in lines leading to the Pressurizer Relief Tanks (PRT).
These valves do not have remote position indication. The licensee states that tb: only practical or effective method of verifying closure of these valves is by performing a seat leakage test. In accordance with OM-10,14.3.2.4(a), s-:at leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Izak te. sting these valves during cold shutdowns would be l
burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
1 i
49
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Mentification No.
For Deferred Testing Alternate Testing AUXILIARY FEEDWATER SYSTEM AF-1 AFWU-3-0017 5610-M-3075-2, Rev. 5,
" Full-stroke exercising of these valves would Per the Valve Program Tables, (AFWU-4-0016)
" Auxiliary Feedwater require simultaneous operation of all three tliese valves are part-stroke AFW Pump Bearing System - Auxiliary auxiliary feedwater pumps. Operation in such a exercised open quarterly and Cooling Water Return 2 Feedwater Pumps" mode during a test is not practical nor desirable.
disassembled and inspected at in., Cat. C, normally refueling outages.
closed Check Valves It is unlikely that the 8-18 gpm developed by one operating auxiliary feedwater pump is sufficient to fully open these valves. Thus, the use of non-intrusive methods of verifying full stroke is impractical."
? Evaluation: The AFW system consists of three 100% capacity turbine-driven pumps shared between Units 3 and 4. Any one pump can be aligned ;o
' either unit. The check valves, AFWU-3-0017 (AFW U-4-0016), are in a header which returns the bearing cooling water for all three AFW pumps to the Condensate Storage Tank of either Unit 3 or Unit 4.
It is impractical to full-stroke exercise these valves quarterly because this would require simultaneous operation of all three AFW pumps to develop sufficient flow to reach full-stroke opening. OMa-1988, Part 10,14.3.2.4(c) specifies that as an alternative to testing valve obturator movement in accordance with 14.3.2.4(a) or (b), disassembly every refueling outage to verify operability of check valves may be used. Generic letter 89-04, Position 2 states that valve disassembly and inspection can be used as a positive means of verifying closure capability, and unat, if possible, p-nial stroking quarterly or during cold shutdowns, or after reassembly must be performed.
The proposed alternative provides for disassembly and inspection of each valve at refueling outages in accordance with OMa-1988, Part 10,14.3.2.4(c) and part-stroke exercised open quarterly in accordance with Generic Ixtter 89-04, Position 2.
0 50
Table 4.2 (Cont'd)
I Item Valve Drawing Ucensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing -
INSTRUMENT AIR SYSTEM I A-1 3-40-0336 5613(4)-M-3013-7, Rev.
"These valves are simple check valves with no Per the Valve Program Tables, (4-40-0336) 2, " Instrument Air external means of position indication, thus the only these valves are exercised Instrument Air Supply System Inside practical means of verifying closure is by closed at refueling outages and Containment Isolation 2 Containment" performing a leaktest or backflow test. This would seat leakage tested every 2 in., Cat. A/C, normally require entry into the containment building and years under Appendix J.
open Check Valves thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown."
lA-2 3-40-340A 5613(4)-M-3013-7, Rev.
"Stop-check valve 3-40-340A is normally closed Per the Valve Program Tables, (4-40-340A) 2, " Instrument Air with the valve operating shaft in the open direction these valves are exercised Instrument Air Supply System inside while 4 340A is a simple, nosmally closed, closed at refueling outages and Containment Isolation 2 Containment" check valve. The only effective method of seat leakage tested every 2 in., Cat. A/C, normally verifying closure of either of these valves is to years under Appendix J.
open Check Valves perform a reverse flow (leak test). This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdowns."
f 51
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Altemate Testing Evaluation: (IA-1 and IA-2). These valves are located inside containment and in series on the 2 in. header which supplies Instrument Air to air-operated devices inside the containment, with valve 40-336 upstream of valve 40-440A.
These valves do not have rempte position indication. The licensee states that the only practical or effective method of verifying closure of these valves is by performing a seat leakage test. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Leak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
i e
52 i
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing PRIMARY MAKEUP WATER SYSifEM PM-1 3-10-0567 5613(4)-M-3020-2, Rev.
"These are simple check valves with no external Per the Valve Program Tables.
(4-10-0567)
- 9. " Primary Makeup means of position indication, thus the only these valves are exercised Primary Makeup Water Water System" mtical means of verifying closure is by closed at refueling outages and Containment Isolation 2 performing a leaktest or backflow test. This would seat leakage tested every 2 in., Cat. A/C, normally require a considerable effort, including bleeding years under Appendix J.
closed Check Valves down the pressure in the primary water supply system, which is undesirable during plant operation and would be an unreasonable burden on the plant
=taff to perform at cold shutdown.
In addition, these valves are normally closed during plant operation with the inboard manual valves (*-10-0582) also closed. Thus, in effect, they are passive valves and essentially, need not be exercised."
Evaluation: These check valves open to supply primary makeup water to the RCS, which is not a safety-related function. and are normally closed during plant operation.
l These valves do not have remote position indication. The licensee states that the only practical or effective method of verifying closure of these valves is by performing a seat leakage test. In accordance with OM-10,14.3.1.4(a), seat leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Irak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
53
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CIIEMICAL & VOLUME CONTROL SYSTEM CV-1 3-0397 A&B 5610-M-3046-1, "During plant operation the boric acid pumps are Per the Valve Program Tables, 4-0397 C&D Rev. II, " Chemical and tested via a recirculation flowpath that is not ther,e valves are part-stroke Boric Acid Transfer Volume Control System-provided with flow indication. At cold shutdown ex rcised open quarterly and Pump Discharge 2 in.,
Boric Acid System" conditions, the pumps can be aligned to the suction a exercised closed quarterly.
Cat. C, normally closed of the charging pumps and thus through an These valves are full-stroke Check Valves instrumented line. However, testing these valves in exercised open at refueling this manner would result in the introduction of outages.
highly concentrated boric acid solution to the RCS, and thus cause considerable operational difficulty during the ensuing startup. This would be especially true near the end of core life (EOL)."
Evaluation: These valves must open to provide flow from the Boric Acid Transfer pumps' discharge to the Units 3 & 4 Boric Acid Blenders.
Full-stroke exercising of these valves to the open position cannot be verified quarterly because there is no means for flow indication on the recirculation test lines from the discharge of the Boric Acid Transfer pumps. It is impractical to full-stroke exercise these valves to the open position during cold shutdowns because to measure the valve flow through an instrumented line would require aligning the flow to the suction of the Charging pumps, which in turn would result in the injection into the RCS of highly concentrated boric acid. Introduction of highly concentrated boric acid into the RCS during cold shutdowns could extend the shutdown.
The proposed alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10 14.3.2.2(c).
i 54
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CV-2 3-0312C 5613(4)-M-3047-2, Rev.
"These are simple check valves with no external Per the Valve Program Tables, (4-0312C)
- 12. " Chemical and means of position indication, thus the only these valves are full-stroke Charging Header Volume Control System practical means of verifying closure is by exercised open quarterly and Containment Isolation 3 Charging and letdown" performing a leaktest or backflow test. During exercised closed every 2 years.
in., Cat. C, normally plant operation, the valves are normally open open Check Valves supplying charging water to the reactor coolant system. Interruption of this flow during operation could result in a CVCS flow imbalance and a possible plant trip as a result of pressurizer level fluctuations. Performing leaktests of these valves involves a considerable effort such that testing at each cold shutdown outage would constitute an unreasonable burden on the plant staff."
Evaluation: These valves are in the header supplying normal charging flow to the RCS from the reciprocating charging pumps. These valves are inboard containment isolation valves.
It is impractical to full-stroke exercise these valves closed quarterly because interrupting the normal charging flow to the RCS during plant operation could result in a CVCS flow imbalance and a possible plant trip as a result of pressurizer level fluctuations.
The licensee states that the only practical or effective method of verifying closure of these valves is by performing a seat leakage test. These valves do not have remote position indication. In the Valve Program Tables, the licensee states that these valves are exercised to the closed position every 2 years. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Leak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
55
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CV-3 3-0351 5613(4)-M-3047-2, Rev.
" Testing these valves requires the introduction of Per the Valve Program Tables, CV-3 (4-0351) 12, " Chemical and highly concentrated boric acid solution from the these valves are full-stroke Emergency Boration 2 Volume Control System boric acid tanks to the suction of the charging exercised open at refueling in., Cat. C, normally Charging and letdown" pumps. This, in turn, would result in the addition outages.
closed Check Valves of excess boron to the RCS which adversely affects plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. During cold shutdown, the additional boric acid introduced into the RCS would cause considerable operational difficulty during the ensuing startup."
Evaluation: These valves open to provide emergency boration flow to the RCS.
It is impractical to part-stroke or full-stroke open these valves quarterly because this would introduce highly concentrated boric acid solution from the boric acid tanks to the suction of the charging pumps. This, in turn, would result,in the addition of excess boron to the RCS which adversely affects plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. It is impractical to part-stroke or full-stroke exercise these valves open during cold shutdowns because this would require injection into the RCS of highly concentrated boric acid. Introduction of higPy concentrated boric acid into the RCS during cold shutdowns could extend the shutdown.
The proposed alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10 14.3.2.2(e).
f 56
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CV-4 3-0298A thru 3-0298C 5613(4)-M-3047-3, Rev.
"These are simple check valves with no external Per the Valve Program Tables.
(4-0298A thru
- 10. " Chemical and means of position indication, thus the only these valves are exercised 4-0298C)
Volume Control System practical means of verifying closure is by closed at refueling outages.
RCP Seal Water Seal Water Injection into performing a leaktest or backflow test. During Containment Isolation 2 RCP*
plant operation, the valves are normally opened in., Cat. C, normally supplying seal water to the RCP's. Intermption of open Check Valves this flow during pump operation could result in RCP seal failure. Performing leaktests of these valves involves a considerable effort such that testing at each cold shutdown outage would consdtute an unreasonable burden on the plant staff.*
Evaluation: These valves are normally open to provide seal water injection flow to the Reactor Coolant pumps. These valves are inboard containment isolation valves.
i It is impractical to part-stroke or full-stroke exercise these valves closed quarterly because this would interrupt flow to the RCP seals during pump operation, possibly causing RCP seal failure.
The licensee states that the only practical or effective method of verifying closure of these valves is by performing a seat leakage test. These valves do not have remote position indication. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during power operation because this would require entry inside conta:nment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Irak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test seaup, which would require substantial manhours and radiation expcsure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.}.2.4(a).
57
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing SAFETY INJECTION SYSTEM SI-I 3-0879 A&B 5613(4)-M-3062-1, Rev.
" Full stroke exercising of these valves would Per the Valve Program Tables, (4-0879 C&D)
- 6. " Safety Injection require operating each safety injection pump at these valves are part-stroke Safety injection Pump System" nominal accident flowrate. At power operation the exercised open and exercised Discharge 3 in., Cat C, only flowpath available for such operation would closed quanerly. They are full-normally closed Check necessitate injecting into the reactor coolant system stroke exercised open at Valves since the full flow recirculation path is located refueling outages.
upstream of the pump discharge check valves.
During cold shutdown conditions, injection via the SIS pumps is precluded by operational restrictions related to low-temperature over-pressurization protection concerns and Turkey Point Technical Specifications, Section 3.4.9.3."
Evaluation: These valves open to allow SI flow from the SI pumps during a SI Actuation. These valves are on the discharge lines of the Safety h1jection pumps A & B downstream of the full flow recirculation test lines for the SI pumps.
It is impractical to full-stroke exercise these valves to the open position quarterly because the valves are downstream of the full flow recirculation test line and would require injection at the nominal accident flow rate into the RCS during power operation. At power operation, the SI pumps cannot develop sufficient discharge pressure to overcome RCS pressure. During cold shutdowns. Technical Specification 3.4.9.3 requires that the high pressure SI flow paths to the RCS shall be isolated.
The alternative provides part-stroke exercising to the open position quarterly and full-stroke exer.-.ng to the open position during refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(b) and (e).
0 58
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justificatin Proposed No.
Identification No.
For Deferred Testing Alternate Testing SI-2 3-0874 A&B 5613(4)-M-3062-1, Rev.
" Exercising these valves (open) requires operating Per the Valve Program Tables, (4-0874 A&B)
- 6. " Safety injection a safety injection pump and injecting into the these valves are full-stroke Safety injection System" reactor coolant system. At power operation this is exercised open at refueling Hot-Leg injection 2 in.,
not possible because the SIS pumps cannot develop outages (and exercised closed Cat. C, normally closed sufficient discharge pressure to overcome reactor as per VR-2, and seat leak rate Check Valves coolant system pressure. During normal cold tested for pressure isolation shutdown conditions, injection via the SIS pumps function at refueling outages).
is precluded by operational restrictions related to low-temperature over-pressurization protection concerns and Technical Specifications."
Evaluation: These valves open t6 allow Si flow into the RCS during the Hot Leg recirculation phase following a LOCA. These valves are PIVs on the SIS hot leg injection lines to the RCS. ney are located inside containment and are downstream of the normally closed SIS motor-operated isolation valves.
It is impractical to part-stroke or full-stroke exercise these valves open quarterly because these valves are located downstream of the full flow recirculation test line and would require injection at the nominal accident flow rate into the RCS during power operation. At power operation, the SI pumps cannot develop sufficient discharge pressure to overcome RCS pressure. During cold shutdowns Technical Specification 3.4.9.3 requires that the high pressure SI flow paths to the RCS shall be isolated.
The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(e).
8 59 i
1 I
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing SI-3 3-0873A thru 3-0873C 5613(4)-M-3064-1, Rev.
" Full stroke exercising of these valves would Per the Valve Program Tables, (4-0873A thru 9, " Safety Injection require operating a safety injection pump at these valves are full-stroke 4-0873C)
System Accumulator nominal accident flowrate and injecting into the exercised open during refueling SIS Cold leg Branch Inside Containment" reactor coolant system. At power operation this is outages (and exercised closed Injection Line 2 in.,
not possibic because the safety injection pumps can per VR-2 and seat leak rate Cat. A/C, normally not develop sufficient discharge pressure to tested for pressure isolation closed Check Valves overcome reactor coolant system pressure. During function at refueling outages).
normal cold shutdown conditions, injection via the safety injection pumps is precluded by operational restrictions related to low-temperature over-pressurization protection concerns."
Evaluation: These valves are containment isolation valves on the SIS cold leg branch injection lines to the RCS which open to allow flow upon an SI actuation signal. They are located inside containment and are downstream of normally closed SIS mote.-operated isolation valves outside containment.
It is impractical to part-stroke or full-stroke exercise these valves open quarterly because these valves are located downstream of the full flow recirculation test line and would require injection at the nominal accident flow rate into the RCS during power operation. At power operation, the SI pumps cannot develop sufficient discharge pressure to overcome RCS pressure. During cold shutdowns, Technical Specification 3.4.9.3 requires that the high pressure SI flow paths to the RCS shall be isolated.
The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(e).
t h
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testiag Alternate Testing SI-4 34876 B&C 5613(4)-M-3064-1, Rev.
'Since no recirculation path exists, exercising these Per the Valve Program Tables, (4-0876 B&C) 9, " Safety Injection valves requires operating an RHR pump and these valves are part-stroke IAw Head Injection System Accumulator injecting into the reactor coolant system. At power exercised open during cold Line 8 in., Cat. A/C, Inside Containment
- operation this is not possible due to system design shutdowns nl full-stroke normally closed Check pressure and interlocks that prevent operation of exercised open at refueling Valves the RHR system in cooldown alignment when RCS outages (and exercised closed pressure exceeds $15 psig.
per an unspecified relief request and seat leak rate tested for During normal cold shutdown conditions, injection pressure isolation function at via the RHR pumps is practical and these valves refueling outages).
can be full-stroke exercised. Since they have no position indicators and are installed such that the only lineup available causes them to form a parallel path, full accident flow through each valve cannot be confirmed and thus full stroke verification by simple means is not possible.
Employing non-obtmsive methods for verifying full stroke would require extensive preparations including containment entry, insulation removal, erection of scaffolding, etc. and thus is not practical during cold shutdown periods."
9 61
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
- For Deferred Testing Alternate Testing Evaluation: These valves are PIVs on the low pressure SI lines from the LPSI/RIIR pumps to the RCS ce!d legs u> ops B and C, and must open upon depressurization of the RCS following a SI actuation. They are located inside containment and are downstream of normally closed SIS motor-operated isolation valves inside containment.
It is impractical to part-stroke or full-stroke exercise these valves open quarterly because these valves are located downstream of the recirculation test lines for the RIIR pumps, and the RHR pumps cannot develop sufficient discharge pressure to inject into the RCS, and interlocks are in effect which prevent operation of the RHR system in cooldown alignment when RCS pressure exceeds SIS PSIG.
It is impractical to full-stroke exercise these valves open during cold shutdowns because, although full-stroke exercising is possible by injection via the RIIR pumps into the RCS, the valves have no position indicators and are installed such that the only lineup available causes them to form a parallel path. Therefore, verification of full stroke at full accident flow rate by simple means is not possible. It is impractical to employ nonintrusive methods to verify full stroke because such methods would require extensive preparations such as entry into containment, removal of insulation and erection of scaffolding.
The proposed alternative provides part-stroke exercising to the open position during cold shutdowns and full-stroke exercising at refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(d).
e 62
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification-Proposed No.
Identification No.
For Deferred Testing Alternate Testing SI-5 3-0875A thru 3-0875C 5613(4)-M-3064-!, Rev.
" Partial-flow testing of these valves requires Per the Valve Pror, ram Tables, (4-0875A thru 9, " Safety Injection injecting fluid into the RCS. At power operation these valves are part-stroke 4-0875C)
System Accumulator this is not possible because nei*her the RIIR or the exercised open at cold SIS Cold leg Injection Inside Containment" SIS pumps can develop sufficient discharge shutdowns ana full-stroke 10 in., Cat. A/C, pressure to overcome reactor coolant system exercised open during refueling normally closed Check pressure. During normal cold shutdown outages (ar>J exercised closed Valves conditioris, however, injection via the RIIR pumps per VR-2 and seat leak rate can be accomplished.
tested for pressure isolation function at refueling outages).
With respect to full stroke exercising of these valves to the open position, in order to satisfy the requirements of Generic letter 89-04, a demonstration of the maximum accident flow must be performed or some other indication of full-stroke of the obturator must be provided. For these valves the maxrmum accident flowTate is defined as that flowrate resulting from a fully pressurized SIS accumulator injecting into a de-pressurized RCS loop. Achieving this flowrate during power operation is not practical due to limitations associated with the reactor coolant system pressure.
It has been demonstrated, by past testing, that these valves can be opened by blowdown from a partially pressurized (100 psi) accumulator to the associated RCS loop. Performing such a test 63
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing SI-5 during plant operation is not possible due to the Cont'd limitations associated with reactor coolant system pressure.
The extensive preparations (including insulation temoval, erection of scaffolding, etc.) required to perform such a test make it impractical to perform during cold shutdown periods."
b 8
64
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing Evaluation: These valves are pressure isolation valves on the SIS cold leg injection lines to the RCS. They are located inside containment and are downstream of normally closed SIS motor-operated isolation valves inside containment. The valves may be supplied by flow from the SI or LPSI/RHR pumps or the SI Accumulators.
It is impractica! to part-stroke or full-stroke exercise these valves open quarterly because these valves are located downstream of the recirculation test lines for botl'. the SI and RHR pumps, neither the Si nor RHR pumps can develop sufficient discharge pressure to inject into the RCS.
Also, the maximum accident flow rate is the flow rate resulting from a fully pressurized SIS accumulator injecting into a depressurized RCS loop. This flow rate cannet be achieved during power operation because the high RCS pressure also would prevent injection into the RCS. The licensee states that from past testing, it has been demonstrated that these valves can be full-stroke opened by blowdown from a partially pressurized (~ 100 PSIG) accumulator to the associated RCS loop.
It is also impractical to perforni such a test during power operation because the high RCS pressure again would prevent injection into the RCS. It is impractical to perform such a test during cold shutdowns because the extensive preparations such as removal of insulation and erection of scaffolding would delay plant startup. However, during normal cold shutdown periods, part-stroke exercising to the open position is possible by injection into the RCS through operation of the RHR pumps.
The proposed alternative provides part-stroke exercising to the open position during cold shutdowns and full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 1014.3.2.2(d), provided that the full-stroke exercising open test is conducted at the maximum required accident flow rate.
It appears that the licensee is proposing performing a reduced pressure flow test as a means of full-stroke exercising the valves open. It is not evident how a reduced pressure flow test alone will verify that the valves are full-stroke exercised open. 'The licensee should indicate whether the full-stroke open test is conducted at the maximum required accident flow rate as discussed in Generic Letter 89-04, Position 1. If a reduced flow rate is used, a positive means for verifying the valves open to the full-stroke position is required. Such means for verification must meet all of the six criteria identified in Position 1. Draft NUREG-1482, Section 4.1.2, fiarther discusses the use of nonintrusive techniques as a means for verifying valve position and the acceptability of sample testing.
The licensee should revise this justification to clarify the testing method, since it does not appear to comply with Generic I.ctter 89-04,' Position 1.
65
O Table 4.2 (Cont'd)
Item Valve Drawing
' Licensee's Justification Proposed No.
Identification No.
For Deferred Testing _
Alternate Testing SI-6 3-0875 D-F 5613(4)-M-3064-1, Rev.
" Full stroke exercising of these valves to the open Per the Valve Program Tables, (4-0875 D-F) 9, " Safety Injection position, based on the maximum accident flowrate these valves are full-stroke SI Accumulator System Accumulator resulting from SIS accumulator injection to a exercised open and exercised Discharge 10 in., Cat.
Inside Containment" de-pressurized RCS loop, is not practical due to closed at refueling outages.
C, normally closed limitations associated with the effects of such a test Check Valves on system components.
It has been demonstrated, by past testing, that these valves can be fully opened by blowdown from a partially pressurized (100 psig.)
accumulator to the associated RCS loop.
Performing such a test during plant operation is not possible due to the limited pressure capability of the Si tanks. During cold shutdown periods the extensive preparations required to perform an accumulator discharge test make it impractical.
The only practical means of verifying closure involves performing a leakage test. Performance of such a test would necessitate closure of the upstream motor operated valve or de-pressurization of the associated SIS accumulator, which is not practical during power operation and would constitute an unwarranted burden on plant staff during cold shutdowns."
i
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing Evaluation: These valves open to provide Si accumulator flow into the RCS during a depressurization of the RCS. The valves must close upon any repressurization of the RCS following any accident sufficient to cause the accumulators to discharge into the RCS.
It is impractical to part-stroke or full-stroke exercise these valves open quarterly at the maximum required accident flow rate. The maximum required accident flow rate is the flow rate resulting from a fully pressurized SIS accumulator injecting into a depressurized RCS loop. This flow rate cannot be achieved during power operation because the high RCS pressure also would prevent injection into the RCS. The licensee states that from past testing, it has been demonstrated that these valves can be full-stroke opened by blowdown from a partially pressurized (~ 100 PSIG) accumulator to the associated RCS loop.
It is also impractical to perform such a test during power operation because the high RCS pressure again would prevent injection into the RCS. It is impractical to perform such a test during cold shutdowns because the extensive preparations such as removal of insulation and erection of scaffolding would delay plant startup.
During normal cold shutdown periods, part-stroke exercising to the open position is not possible by injection into the RCS through operation of the RIIR pumps, since the only sources of flow for these valves are the accumulators.
The proposed alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10 14.3.2.2(e), provided that the full-stroke exercising open test is conducted at the maximum required accident flow rate.
It appears that the licensee is proposing performing a reduced pressure flow test as a means of full-stroke exercising the valves open. It is not evident how a reduced pressure flow test alone will verify that the valves are full-stroke exercised open. 'Ihe licensee should indicate whether the full-stroke open test is conducted at the maximum required accident flow rate as discussed in Generic Letter 89-04, Position 1. If a reduced flow rate is used, a l
positive means for verifying the valves open to the full-stroke position is required. Such means for verification must meet all of the six criteria identified in Position 1. Draft NUREG-1482, Section 4.1.2, further discusses the use of nonintrusive techniques as a means for verifying valve position and states the acceptability of sample testing. The licensee should revise this justification to clarify the testing method.
'The licensee states that the only practical means of verifying closure of these valves is by performing a leakage test. These valves do not*have remote l position indication.accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifyin It is impractical to verify the closure capability of these valves quarterly because,the valves are located inside containment. In j
67
Table 4.2 (Cont'd)
Item Valve Drawing Ucensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing during power cperation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. leak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substarilal manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
SI-7 3-0945E 5613(4)-M-3064-1, Rev.
"These are check valves with no external means of Per the Valve Program Tables, (4-0945E) 9, " Safety Injection position indication, thus the only practical means these valves are exercised Safety Injection System Accumulator of verifying closure is by performing a leaktest or closed at refueling outages and Nitregen Supply 1 in.,
inside Containment" backflow test. This would require entry into the seat leak tested for containment Cat. A/C, normally containment building and thus is impractical to isolation function every 2 years closed Check Valve perform during plant operation and would be an under Appendix J.
unreasonable burden on the plant staff to perform at cold shutdown."
Evaluation: These are normally closed valves located inside containment which supply nitrogen to pressurize the SI accumulators inside containment.
They are required to remain closed for containment isolation during a LOCA.
It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly since containment entry would be required. These valves do not have remote position indication. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure.
It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Irak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and l
could extend the shutdown.
l The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
0 68 l
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CONTAINMENT SPRAY SYSTEM CS-1 3-0890 A&B 5613(4)-M-3068-1, Rev.
"Since these are simple-acting check valves with Per the Valve Program Tables, (4-0890 A&B) 8, " Containment Spray no provision for determining disc position, the these valves are exercised Containment Spray System" only practical means of verifying closure involves closed and seat leak rate tested Pump Discharge 6 in.,
performing a leakrest. Performance of such a test for containment isolation Cat. A/C, normally would require considerable effort, including function every 2 years under closed Check Valves isolation and draining of the containment spray Appendix J (and disassembled piping, system reconfiguration, hooking up and and inspected and part-stroke disconnectmg leak testing equipment, and exercised open under VR-1).
pressurizing the downstream piping with air or nitrogen while venting the upstream piping. Such a test is not practical during plant operation and could result in delays in the return to power operation during cold shutdown periods to the extent that it would be an unreasonable burden on the plant staff. These valves remain closed at all times except during an MHA in which the contamment spray system operates for containment cooling and de-pressurization."
s 69
O Table 4.2 (Cont'd) ltem Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing Evaluation: Bese valves open during a Maximum Hypothetical Accident (MHA) in which the containment spray system operates for containment cooling and de-pressurization and close for containment isolation. These valves are located outside containment on the discharge lines from the Containment Spray pumps downstream from the pumps' recirculation test lines.
As noted, these valves are located outside containment but lack remote position indication. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. The licensee states that to perform a seat leakage test during power operation would require an extensive test setup involving draining the Containment Spray piping. Since these valves are located downstream of normally closed motor-operated isolation valves on the CS pumps' discharge lines, it is not clear why draining of the CS piping is required because it appears that the piping segment containing the check valves is normally drained and full of air because they lead to the CS spray headers inside containment. Nevertheless, since the valves are normally closed and are required to remain closed during a IDCA except if the CS is required to operate, performance of the seat leakage testing during power operation would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. To perform the seat leakage testing during cold shutdowns could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages, the test interval not to exceed 2 years, in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
I 70
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Justification Proposed No.
Identification No.
For Deferred Testing Alternate Testing CONTAINMENT POST-ACCIDENT EVALUATION CA-1 3-11-0003 5613(4)-M-3094-1, Rev.
- These are simple check valves with no external Per the Valve Program Tables, (4-11-0003) 10, " Containment Post means of position indication, thus the only these valves are exercised Containment Accident Evaluation practical means of verifying closure is by closed at refueling outages and Atmosphere Sample System" performing a leaktest or backflow test. This would seat leak rate tested for Return Isolation 1 in.,
require entry into the containment building and containment isolation function Cat. A/C, normally thus is impractical to perform during plant every 2 years under Appendix open Check Valves operation and would be an unreasonable burden on J.
[
the plant staff to perform at cold shutdown."
Evaluation: These val es are located inside containment and must close for containment isolation.
It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly since containment entry would be required. These valves do not have remote position indication. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure.
It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Irak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.1.2(e) and 4.3.2.4(a).
s 71
Table 4.2 (Cont'd)
Item Valve Drawing Licensee's Instification Proposed No.
Identificatiort No.
For Deferred Testing Alternate Testing BREATIIING AIR SYSTEM BA-1 3-BA-0201 5613(4)-M-3101-1, Rev.
"These are simple check valves with no external Per the Valve Program Tables, (4-BA-0201) 1, " Breathing Air System means of position indication, thus the only these valves are exercised Breathing Air Supply Distribution" practical means of verifying closure is by closed at refueling outages and Containment Isolation performing a leaktest or backflow test. This would seat leak rate tested for 2.5 in., Cat. A/C, require entry into the containment building and containment isolation furction normally closed Check thus is impractical to perform during plant every 2 years under Appendix Valves operation and would be an unreasonable burden on J.
the plant staff to perform at cold shutdown."
Evaluation: These valves are located inside connmment and must close for containment isolation.
It is impractical to part-stroke or full-stroke exercise these valves to the closed position quarterly since containment entry would be required. nese valves do not have remote position indication. In accordance with OM-10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure.
It is impractical to perform a seat leakage test during power operation because this would require entry inside containment. Access for testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Leak testing these valves during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and could extend the shutdown.
The alternative provides exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e) and 4.3.2.4(a).
72
s 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS Inconsistencies, omissions, and required licensee actions identified during the review of the licensee's third interval Inservice Testing Program are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report.
5.1 The IST Program's scope was reviewed for selected systems. The pumps and valvesin the Component Cooling Water, Residual Heat Removal, and Safety Injection Systems were reviewed against the requirements of Section XI and the regulations. The review results showed compliance with the Code, except for the following items. The licensee should review these items and make changes to the IST Program, where appropriate. Additionally, the licensee should verify that there are not similar problems with the IST Program for other systems.
A. General Several relief valves are not in the IST Program. For example, on P&ID 5613-M-3030-2, RV-3-747A & B, the relief valves on the bypass lines around the normally closed CCW outlet isolation valves MOV-3-749 A & B from the RHR Heat Exchangers, are not in the Program. Also other relief valves on this drawing are not in the Program.
The Code requires testing of all relief valves installed in systems that perform a function to achieve or maintain safe shutdown conditions or in mitigating an accident. An inquiry has been submitted to the ASME to clarify the Code requirements concerning thermal relief valves which are only required to function when components, e.g. heat exchangers, are isolated. The licensee should review the basis for excluding those relief valves from the IST Program and ensure that the basis agrees with the Code interpretation when published.
B. Component Cooling Water System 1.
The licensee should verify that there are no Category A isolation valves for the component cooling water (CCW) system, as none are listed in the Program.
2.
Control valve RCV-3-609 (P&ID 5613-M-3030-1 @ C7), on 4"-AC-153R, the CCW Surge Tank outlet line to the Waste Disposal System, appears to be normally or intermittently open, and is designated to fail closed, is not in the Program. The licensee should review the function of this valve and revise the Program as i
necessary.
3.
Control valve TCV-3-144 (P&ID 5613-M-3030-2 @ DS) is not in the Program. The P&lD indicates that it is actually Out of Service but is required to Fail Open.
4.
Six inch check valve 3-0717, P&ID 5613-M-3030-5 @ E3) normally open, and appears to have a safety related function to close as a Containment Isolation Valve for Penetration P-03 to isolate CCW flow to the Reactor Coolant Pumps, is not in 73
s the Program. The licensee should review the function of this valve and revise the Program as necessary.
C.
Residual Heat Removal System 1.
Air-operated, fail open butterfly valve, HCV-3-0758 (P&ID 5613-M-3050-1 @ C5) from the RHR heat exchanger to the normal RHR/ low head injection to the RCS cold legs is not in the program. The licensee should review the function of this valve and revise the Program as necessary.
D.
Safety Iniection System 1.
On page 84 of the valve table (for Unit 3), check valve 3-0875C, has been designated Category C but because it is a pressure isolation valve it should be designated A/C. (See also Table 3.4-1 of Technical Specifications).
2.
The licensee should verify why check valves,3-0875D,3-0875E, and 3-0875F (P&ID 5613-M-3064-1), have not been classified as pressure isolation valves while the other branching check valves have been so classified.
5.2 In Pump Relief Request PR-4 for all pumps in the IST program, the licensee should ensure that the calculation of pump differential pressure is proceduralized properly to account for liquid in the pressure sensing gage lines so that the accuracy of the final value meets Code requirements.
5.3 In any future revision of Pump Relief Request PR-2 for the Residual Heat Removal Pumps, the licensee should also indicate that vibration is being measured quarterly.
5.4 In Valve Relief Request VR-2 for check valves in the Safety Injection System which are pressure isolation valves (PIVs), in which the licensee wants to perform a seat leakage test verification of valve closure in accordance with the frequencies specified in Technical Specification 4.4.6.2.2, the licensee could convert this request into a deferral justification and include valves:
3-0873C and 4-0873C, 3-0875A thru C and 4-0875A thru C.
The licensee should also verify whether:
Cold Leg Injection check valves 3-0876A thru C should be included in the request.
Valves 3-0876 D&E and 4-0876 D&E on the Alternate Low Head Safety injection lines from the Residual Heat Removal (RHR) heat exchangers perfenn a safety function in the open position and whether an exercise closed test is also required.
The licensee should also review whether these valves are active, rather than passive.
The pressure differential requirements of OM-10,14.2.2.3 for seat leakage testing are met by the Technical Specification required testing for PIVs.
74
s If the licensee determines that the proposed leak rate testing in the Technical Specifications is not adequate to meet the Code requirements for leak rate testing (i.e., OM-1014.2.2.3), a relief request should be prepared and submitted for review.
5.5 The licensee has submitted 32 Cold Shutdown Justifications (CSJ) which docum6nt the impracticality of testing valves quarterly, during operation, as required by OMa-1988, Part
- 10. The following deferrals require further action by the licensee:
In CSJ-RH-1 for the Residual Heat Removal (RHR) pumps' discharge check valves 3-0753 A&B and 4-0753 A&B, the licensee has provided no information as to why the valves cannot be verified closed quarterly, because there appear to be available test connections and, as discussed in GL 89-04 Position 3 (Ref. 7), verification of closure may be achieved by a leak test, even if no leakage limits apply. The licensee should revise and resubmit this deferral to discuss any impracticality of verifying closure of these valves quarterly.
In CSJ-SI-1, for the SIS Pump Discharge Unit Cross-Tie, normally open motor operated gate valves MOV-0878 A&B, it is not apparent from the Turkey Point UFSAR, Appendix A, paragraph on " Sharing of the High Head Safety Injection Pumps" under what circumstances these normally open valves would be required to close, nor whether these valves would be required to reopen following closure. The possibility of entering an LCO is not a sufficient basis for not performmg the required testing, unless the testing renders systems inoperable for an extended period of time. The licensee should full-stroke exercise these valves closed quarterly within the Technical Specification time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or provide justification that it is impractical to perform the testing during power operation. The licensee should also verify whether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
In CSJ-SI-2, for the SI and CS Minimum Flow Line Isolation Valves, normally open motor operated globe valves, MOV-3-0856 A&B, and MOV-4 0856 A&B, the licensee has only specified an exercise closed test in the Valve Program Tables. It appears that these valves have a safety function in the open position as well. The licensee should review the safety function of these valves and revise the program accordingly.
In CSJ-SI-3 for the locked open RWST Outlet Isolation Valves, motor operated gate valves MOV-3-864 A&B and MOV-4-864 A&B, the licensee should also verify whether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
In CSJ-SI-5, CSJ-SI-6, and CSJ-SI-7, for SIS check valves which are pressure isolation valves, the licensee refers in the Valve Program Tables to an "other relief request" regarding exercis'a; to the closed position. It is not evident what the reference is for the "other relief request" concerning closure testing. Since these are pressure isolation valves, it appears that these valves should have been included in Valve Relief Request VR-2. The licensee should refer to the evaluation for VR-2, 75
~
~ _-.. -.
In CSJ-AF-1 for the normally closed, Auxiliary Feedwater Steam Supply Non-return check valves on the inlet to the AFW steam-driven pump turbines, Flow diagrams -
(5613(4)-M-3075-1) and (5610(4)-M-3075-1) indicate that these valves can be full-
. stoke exercised open during the Turbine Driven Auxiliary Feedwater Pump quarterly test and therefore, testing quarterly appears practical. However, verifying closure does require isolation to make use of the test connections around these check valves.
There are 3 (100%) steam driven pumps for both Units. Only one auxiliary feedwater pump is needed per Unit. Taking one out of service leaves two to serve i
both Units. 'Ihe possibility of entering an LCO is not a sufficient basis for not performing the required testing unless the testing renders systems inoperable for an.
extended period of time. The licensee should exercise these valves closed quarterly l
or revise the deferral to demonstrate that quarterly testing is impractical.
5.6 The licensee has submitted 26 Refueling Outage Justifications (ROJ) which document the impracticality of testing valves quarterly, during operation, as required by OMa-1988, Part
- 10. The following deferrals require further action by the licensee:
In ROJ-SA-1 for the normally closed Service Air containment isolation check valves 3-40-0205 (4-40-0205), the licensee has not provided justification as to why a reverse seat leakage test could not be performed during cold shutdowns. In its submittal of the Inservice Testing Program for the St. Lucie Unit 2 plant, Revision 2, September 15,1992, the licensee indicated that analogous valve V-181270 in the Service Air System is full-stroke exercised to the closed position during those cold i
shutdowns in which the section of the Service Air system inside containment is in service. Therefore, the licensee should full-stroke exercise the subject valves {3 i 0205 (4-40-0205)} to the closed position during those cold shutdowns when the Service Air system header inside containment is in service or revise this justification i
to ju' tify deferring full-stroke exercising the subject valves to the closed position s
r during refueling outages.-
In the following ROJs there is no seat leakage testing for containment isolation function every 2 years under Appendix J prescribed in the Valve Program Tables.
The licensee should verify whether seat leakage testing under Appendix J is being performed:
1
-In ROJ-CV-2 for the normally open Charging Header containment isolation check
.I valves 3-0312C (4-0312C), and
-in ROJ-CV-4 for the normally open RCP Seal Water containment isolation check valves 3-0298A thru 3-0298C (4-0298A thru 4-0298C).
In the following ROJs, the proposed alternative provides part-stroke exercising to the -
open position during cold shutdowns and full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 1014.3.2.2(d), provided that the full-stroke exercising open test is conducted at the maximum required accident flow rate. It appears that the licensee is proposing to perform a reduced pressure flow test as a means of full-stroke exercising the valves open. It is not evident how a reduced pressure flow test alone will verify that the valves are full-76
e l
stroke exercised open. The licensee should indicate whether the full-stroke opt.n test I
is conducted at the maximum required accident flow rate as discussed in Generic i
Letter 89-04, Position 1. If a reduced flow rate is used, a positive means for verifying the valves open to the full-stroke position is required. Such means for i
verification must meet all of the six criteria identified in Position 1. Draft NUREG-l 1482, Section 4.1.2, further discusses the use of norJntmsive technique (as a means i
for verifying valve position and the acceptability of sample testing. The licensee should revise the following justifications to clarify the testing method, since they currently do not appear to comply with Generic letter 8944, Position 1:
l
-In ROJ-SI-5 for the normally closed SIS Cold Leg Injection oneck valves 3-0875A thru 3-0875C (4-0875A thru 4-0875C), and
-In ROJ-SI-6 for the normally closed SIS Accumulator Discharge check valves 3-0875 D-F (4-0875 D-F).
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6.0 REFERENCES
1.
Third Ten-Year Inservice Testing (IST) Program: Revision 0, Turkey Point Units 3 and 4, T.F. Plunkett, Florida Power & Light Company, to USNRC, January 12, 1994.
2.
ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection,1989 Edition.
3.
ASME/ ANSI OMa-1988, Pan 6, " Inservice Testing of Pumps in Light-Water Reactor Power Plants" 4.
ASME/ ANSI OMa-1988, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants".
5.
Title 10, Code of Federal Regulations, Section 50.55a, Codes and Standards.
6.
Standard Review Ac, NUREG-0800, Section 3.9.6, Inservice Testing of Pumps and Valves, Rev. 2, July 1992.
7.
NRC Generic Letter 8944, " Guidance on Developing Acceptable Inservice Testing Programs", April 3,1989.
8.
Minutes of the Public Meetings on Generic Letter 8944, October 25,1989.
9.
Supplement to the Minutes of the Public Meetings on Generic Letter 89-04, September 26, 1991.
10.
Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants", P.
Campbell, November 1993.
I 1.
NRC Letter to Mr. J.H. Goldberg, Florida Power & Light Co., from Mr. H.N. Berkow,
" Turkey Point Units 3 and 4 - Relief Request Concerning Vibration Measuring Instrumentation (TAC Nos. M88761 and M88721)", with accompanying Safety Evaluation, May 19,1994.
12.
NRC Safety Evaluation, Turkey Point Units 3 and 4, IST Program Plan, August 20,'1992, l
13.
1988 Final Safety Analysis Report (FSAR) for Turkey Point Units 3 and 4.
14.
1990 Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4.
15.
Technint XpM2mions, Turkey Point Units 3 and 4.
78 i
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s 4
Appendix A Turkey Point Nuclear Power Plant Units 3 & 4 - List of Reference Drawings Flow diagram Dwg.No.
System Revision *
$613(4)-M-3030-5(4)
Component Cooling Water Rev. 5
~
System (Sheet 5) 5613(4)-M-3041-2 Reactor Coolant System (Sheet Rev.12 2) 5613(4)-M-3047-1 Chemical and Volume Control Rev. 8 System Charging and Letdown (Sheet 1) 5613(4)-M-3047-2 Chemical and Volume Control Rev.12 System Charging and letdown (Sheet 2) 5613(4)-M-3047-3 Chemical and Volume Control Rev.10 System Seal Water Injection to RCP (Sheet 3) 5613(4)-M-3050-1 Residual Heat Removal System Rev. 8 (Sheet 1) 5613(4)-M-3053-1 Comamment Purge System and Rev. 8 Penetration Cooling System (Sheet 1) 5613(4)-M-3062-1 Safety Injection System (Sheet Rev. 6 1) 5613(4)-M-3064-1 Safety Injection Accumulator Rev. 9 System inside Comamment 5613(4)-M-3072-1 Main Steam System (Sheet 1)
Rev.15 5613(4)-M-3074-3 Feedwater System (Sheet 3)
Rev.10 5613(4)-M-3075-1 Auxiliary Feedwater System Rev. 6 Steam to Auxiliary Feedwater Pump Turbines (Sheet 1) 5610-M-3013-1 Ins:Jument Air System Service Rev. 5 Air Distribution From Units 1&2 5613 (4)-M-3030-5(4)
Component Cooling Water Rev. 5 System 5613(4)-M-3050-1 Residual Heat Removal Syvq Rev. 5 1
e
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e s
Appendix A (Cont'd)
Flow diagram Dwg.No.
System Revision
~
Nitrogen Supply
$610-M-3075-2 Auxiliary Feedwater System -
Rev. 5 Auxiliary Feedwater Pumps 5613(4)-M-3013-7 Instmment Air System Inside Rev. 2 Containment 5613(4)-M-3020-2 Primary Makeup Water System
'Aev. 9 5610-M E46-1 Chemical and Volume Control Rev.11 System-Boric Acid System 5613(4)-M-3047-2 Chemical and Volume Control Rev.12 System Charging and 12tdown 5613(4)-M-3047-3 Chemical and Volume Control Rev.10 System Seal Water Injection into RCP 5613(4)-M-3062-1 Safety Injection System Rev. 6 5613(4)-M-3064-1 Safety Injection System Rev. 9 Accumulator Inside Containment 5613(4)-M-3068-1 Containment Spray System Rev. 8 5613(4)-M-3094-1 Containment Post Accident Rev.10 Evaluation System 5613(4)-M-3101-1 Breathing Air System Rev. 1 Distribution 5613(4)-M-3019-1 Intake Cooling Water Pumps Rev.11
- Unit 3 tevision numbers only.
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