ML20076K941
| ML20076K941 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 09/30/1994 |
| From: | Jennifer Davis, Dibiasio A, Fresco A, Grove E BROOKHAVEN NATIONAL LABORATORY |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20076K856 | List: |
| References | |
| CON-FIN-L-2301 TAC-M88528, TAC-M88529, NUDOCS 9411020197 | |
| Download: ML20076K941 (117) | |
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,-. s TECHNICAL EVALUATION REPORT r Pump and Valve Inservice Testing Program McGuire Nuclear Station, Units l'& 2 Duke Power Company -
Docket Ntunters: 50-369 & 50-370.-
TAC Number: M-88528 (Unit-1);
- M-88529 (Unit 2) L w Prepared by:
A. DiBiasio, Ji Davis, A. Fresco, .
~ and E. Grove ,
Engineering Technology Divis. ion -
Department of Advanced Technology 4 Brookhaven National Laboratoryi Upton, New York :11973 ;
l Prepared for the: i Division of Engineering l Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission !
Washington, DC 20555 l FIN L-2301, Task Assignment 11-l l
September 1994 -
l 9411020197 DR 941021 ADOCK 05000369 ,
PDR .
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l ABSTRACT )
l This report presents the rc 11ts of Brookhaven National Laboratory's evaluation of McGuire Nuclear Station's, Units 1 and 2, ASME Section XI Pump and Valve Inservice Testing Program relief requests.
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TABLE OF CONTENTS ABSTRACT .................................. ............. iii .
1.0 INTRO D UCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 PUMP IST PROGRAM RELIEF REQUESTS ...................... 3 2.1 Generic Pump Relief Requests ........... ................ 3 2.2 Auxiliary Feedwater System . . . . . . . . . . . . . . ............... 5 2.3 Emergency Diesel Generator Fuel Oil Transfer System . . . . . . . . . . . . . 6 2.4 Component Cooling Water System . . . . . . . . . . . . . . . . . . . . . . . . . 8 ,
2.5 Residual Heat Removal System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.6 Safety Injection System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 2.7 Chemical and Volume Control System . . . . . . . . . . . . . . . . . . . . . . . 15 2.8 Nuclear Service Water System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 3.0 VALVE IST PROGRAM RELIEF REQUESTS .............. .. 19 i 3.1 Containment Spray System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.2 Nuclear Service Water System ............................ 21 3.3 Diesel Generator Starting Air System . . . . . . . . . . . . . . . . . . . . . . . . 22 3.4 Diesel Generator Room Sump System . . . . . . . . . . . . . . . . . . . . . . . . 24 4.0 DEFERRED TESTING JUSTIFICATIONS . . . . . . . . . . . . . . . . . . .. . . 25 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS . . . . . . . . . . . . . . ... 102
6.0 REFERENCES
. ,, . . . . . . . . . . . . . . . . . . . . . . ................. 107 APPENDIX A: McGuire Nuclear Station Unit I and 2 Flow Diagrams . . . . . . . . . . . . . A-1 l
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Technical Evaluation Report Pump and Valve Inservice Testing Program McGuire Nuclear Station
1.0 INTRODUCTION
Contained herein is a technical evaluation of the ASME Section XI pump and valve inservice testing (IST) program relief requests submitted by Duke Power Company for its McGuire Nuclear Station, Units 1 and 2. The McGuire Nuclear Station Units are Westinghouse Pressurized Water Reactors (PWR) with Ice Condenser containments. Unit I began commercial operation in December 1981, and Unit 2 began commercial operation in March 1984.
Duke Power Company submitted Revision 20 for Unit 1 and Revision 15 for Unit 2 of the Inservice Testing Program, Second Ten Year Interval on January 6,1994 (Ref.1). The second ten year interval extends from December 1,1992 to December 1,2002 for Unit I and from March 1,1994 to March 1,2004 for Unit 2. In a letter dated January 6,1994 Duke Power Company has informed the NRC that it is revising the IST programs for both O' nit 1 and Unit 2 in accordance with 10CFR50.55a(f)(4) (Ref. 2). The licensee states that this program complies with the 1989 Edition of the ASME Section XI Code (Ref. 3,4), except where specific relief is requested. The program revisions supersede all previous submittals. The licensee also submitted a response to the October 12,1993 Safety Evaluation for Unit I regarding Revision 19 of the Inservice Testing Program, on February 24,1994. This response discusses modifications made to the diesel generator sump pumps, and, licensee action taken on pump and valve relief requests with the adoption of OMa-1988 Parts 6 and 10. For Unit 2, a revised relief request reflecting the revised schedule for completing modifications to the diesel generator control ah valves was submitted to the NRC on August 24, 1993.
Title 10 of the Code of Federal Regulations, $50.55a T(f) requires that inservice testing of 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,(Ref. 5,6), except where specific relief has been requested by the licensee and granted by the commission pursuant to $50.55a T(a)(3)(i),
(a)(3)(ii), or (f)(6)(i). Section 50.55a T(f)(4)(iv) provic'.es that inservice testing of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of 650.55a, subject to the limitations and modifications listed, and subject to Commission approval.
D2ke Power has requested relief from certain ASME Section XI testing requirements. A review of the relief requests was performed utilizing the Standard Review Plan, Section 3.9.6; Generic Letter (GL) 89-G4, " Guidance on Developing Acceptable Inservice Testing Programs;" and the Minutes of the Public Meeting on GL 89-04, dated October 25,1989; and Draft NUREG-1482 (Ref. 7, 8, 9, 10,11). The IST Program requirements apply only to component (i.e., pump and valve) testing and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements.
Section 2 of this report presents the eight pump relief requests and Brookhaven National Laboratory's (BNL) evaluation. Similar information is presented in Section 3 for the four relief requests for the ;
valve testing program. A review of the ninety-five valve cold shutdown and refueling outage 1
justifications for deferral testing was performed and details of this review are contained in Section 4.
Relief requests that are authorized by GL 89-04 are not specifically evaluated in this Technical .
Evaluation Report. However, any anomalies associated with these relief requests are addressed in Section 5 of this report.
Section 5 also summarizes the recommended actions for the licensee resulting from the relief request review and deferred testing evaluations. BNL recommends that the licensee resolve these items in accordance with th: evaluations, conclusions, and guidelines presented in this report.
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2.0 PUMP IST PROGRAM RELIEF REQUESTS In accordance with $50.55a, Duke Power Company has submitted eight relief requests for pumps at the McGuire Station which are subject to inservice testing under the requirements of OMa-1988 Part
- 6. These relief requests have been reviewed to verify their technical basis and determine their acceptability. The relief requests, along with the technical evaluation by BNL, are summarized below.
2.1 Generic Pump Relief Reauests 2.1.1 Pmnp Rehef Request 1.3.1 ReliefRequest: The licensee requests relief from the pump vibration acceptance criteria requirements of OMa-1988 Part 6,16.1 and the vibration accuracy requirements of 14.6.1 for all pumps in the IST program.
Proposed Alternate Testing: The licensee's proposed alternate testing is as follows: .
- 1) In lieu of the vibration acceptance criteria specified in OMa-1988 Part 6,16.1, Table 3a, the following ranges shall be used. These ranges are based on current vibration standards (vibration severity charts):
l Acceptable Range Alert Range Required Action !
Range i For all pumps when 0 to 0.19 in/sec > 0.19 to 0.45 in/see > 0.45 in/sec Vrs0.075 in/sec For centrifugal s2.5 Vr >2.5 Vr to 6 Vr or > 6 Vr or pumps, when > 0.325 to 0.70 in/sec > 0.70 in/sec Vr> 0.075 in/sec i For reciprocating s2.5 Vr > 2.5 Vr to 6 Vr > 6 Vr l pumps, when '
Vr > 0.075 in/sec For internal gear s2.5 Vr >2.5 Vr to 6 Vr < 6 Vr i positive displacement pumps, Vr > 0.075 in/sec j
- 2) In lieu of the vibration instrument accuracy requirements of OMa-1988 Part 6,14.6.1, Table 1, j the loop accuracy of vibration measurements will be i6.56% of reading. This accuracy is based on ;
the Root Sum of Squares method and includes the accuracy of the vibration probe ( 5.0%) and the ,
accuracy of the calibration instrument (i4.25%). This accuracy is the best that can be reasonably !
obtained from the state of the art instrumentation used. J 3
Licensee's Basisfor Relief: The licensee states that:
- 1) " Experience has shown that smooth operating pumps (Vrs0.075 in/sec) often fall in the alert range of vibration measurement when compared to the acceptance criteria given in Part 6, Table 3a.
The Table included with this relief request allows for acceptable ranges of vibration measurement for this classification of pumps. This proposal provides an acceptable level of quality and safety given the minimum limits."
- 2) " Vibration measurement instrumentation currently in use is digital instrumentation. Using our present instrumentation and accounting for all instrumentation uncertainties in the calibration process, the requirement of iS% instrument accuracy cannot be achieved."
Evaluation:
- 1) As stated in the Basis, the licensee hs requested generic relief for all pumps in the IST Program from the vibration limits specified in OMa-1988 Part 6,15.2(d) for smooth operating pumps (Vrs.075 in./sec.). The Code does not prescribe limits for smooth-operating pumps, and as, stated by the licensee, these pumps often fall within the alert and required action ranges when compared to the current Code requirements. This may result in unnecessary additional testing and maintenance.
Although the licensee's proposed absolute limits for smooth-operating pumps may be less conservative than the Code required relative acceptance criteria (i.e., based un multiples of a reference vibration), the licensee's proposed limits for the alert and required action levels for smooth-operating pumps are more restrictive than the present Code absolute requirements for centrifugal pumps, and provide for reasonable assurance as to the pumps ability to operate as required, while not unnecessarily entering the alert and required action ranges. Based on the alternative providing an acceptable level of quality and safety, it is recommended that the alternative be authorized in accordance with $50.55a 1(a)(3)(i).
The licensee has specified acceptance criteria for internal gear positive displacement pumps. The currently does not specify vibration acceptance criteria for this pump type. The 1994 Addenda oi une OM Code, however, clarifies in a note to Table 3 that the acceptance criteria for centrifugal ,
and vertical line shaft pumps should also apply to positive displacement pumps except reciprocating. )
The licensee should consider revising their program to comply with the intent of the Code.
- 2) OMa-1988 Part 6, Section 4.6.1.1, Table 1 requires a vibration instrument accuracy of 5% of full-scale. As stated by the licensee, the currently installed instrumentation meetc the Code specified accuracy of i5%; however, when the accuracy of the calibration instrument is accounted for, the ,
l resulting accuracy is i6.56%.
The licensee has not addressed, as identified in the October 12,1993 Safety Evaluation (SE) (Ref. !
12), the possibility of using outside calibration laboratories to obtain instrumentation accuracies that would meet the Code requirements. Digital vibration instrumentation is available that can meet the i accuracy range of 5% over the calibrated range. Such instrumentation is being used at other nuclear power plants such as the Seabrook Station (letter from Richard Wessman, NRR to Ted Feigenbaum, New Hampshire Yankee, June 28,1991; subject: "Seabrook Station Relief from IST Range Requirement for Digital Vibration Instmments").
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Although the installation of instmmentation is generally not considered burdensome by the NRC, the accuracy obtainable with the existing instrumentation would not seriously impact the level of safety provided by the tests. To require the licensee to replace the existing instrumentation to comply with the 5% accuracy requirements would result in a hardship without a compensating increase in the level of quality and safety. However, the instrument accuracy should be addressed in the analysis and evaluation of pump test data, with the acceptance criteria adjusted to account for inaccuracies, if necessary. The licensee should consider the repeatability of the measurements. If the measurements are not sufficiently repeatable to justify the use of the Code allowable ranges to permit detection of degradation, the alert and required action values of Table I should be reduced by 1.56%. The licensee also should investigate the possibility of using other calibration techniques to meet the accuracy requirements of the Code.
Based upon the fact that the installed instrumentation will provide an acceptable level of safety, and that requiring the licensee to change all the vibration instmments to comply with the Code would present a hardship without a compensating increase in the level of quality or safety, it is recommended that the proposed alternate be authorized in accordance with 550.55a (a)(3)(ii) for one year or until the next refueling outage, whichever is longer. In the interim period, the licens.ee should investigate the availability of vibration instruments which satisfy the Code accuracy requirements, or the availability of other calibration laboratories as previously recommended in the October 12,1993 SE (Ref.12) which the licensee has not addressed to date.
2.2 Auxiliary Feedwater (AITV) System 2.2.1 Pump Relief Request 1.4.1, A and B AFW Pumps, Unit Turbine Driverr AFW Pump (Note: CA is designator for Auxiliary Feedwater)
ReliefRequest: The licensee requests relief from OMa-1988, Part 6,14.6.1.2(a) which requires that the full scale range of the instrument shall be three times the reference value or less for AIAV pump suction gauge.
Proposed Alternate Testing: The currently installed pro 9ess instrumentation will be used to measure the auxiliary feedwater pumps suction pressure for the two motor operated and single turbine driven l' pumps which have a range of 5 times the reference value.
l Licensee's Basisfor Relief: The licensee states that: "The installed process instrumentation for the ~
l CA pump suction gauge is a 0-100 psig,0.5% accuracy. Typical values for the CA suction pressure during the CA pump testing is 20-25 psig; therefore, the process gauge does not meet the three times criteria. The accuracy of the process gauge (0.5%) is well below the requirements specified in Table l 1 for pressure instrument accuracy (2%). The actual reading error at test pressure due to the process instrument accuracy is 2.5% (0.5 X 100/20). If a 0-60 psig test instrument is used (which meets the three times criteria) arx! it has an accuracy of 2%, then the reading error would be 6% (2 X 60/20).
When the requirements of 14.6.1.2(a) and Table 1 are combined, the actual instmment error introduced into the test is less than the Code allowable (2.5% versus 6%). Using the process l instrument for suction pressure data does not degrade the quality of the test and meets the intent of the instrumentation requirements of the Code; just not the specific range requirements of 14.6.1.2(a). "
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I Evaluation: The licensee has requested relief from the full scale range requirements for the analog l gauge used to measure suction pressure for the AFW pump. OMa-1988, Part 6,14.6.1.2 requires that the range for this instrument be three times the reference value or loss.
As discussed in Draft NUREG-1482 (Ref.11), Section 5.5.1, relief may be granted when the combination of the range and the accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements. As stated by the licensee, the accuracy of the pressure instrument is 0.5%, which is greater than the Code specified accuracy of i2% (OM Part 6, 14.6.1.1 Table 1). The combination of the expanded instrument range and reading accuracy for the installed instrumentation provides a higher reading accuracy ( 2.5%) than the Code allowable i6%.
Based upon the use of the installed pressure instruments providing an acceptable level of quality and safety, it is recommended that the proposed alternate be authorized pursuant to f50.55a 1(a)(3)(i). In the event these instmments are replaced the new instruments should comply with the Code range and accuracy requirements.
2.3 Emergency Diesel Generator (EDG) Fuel Oil Transfer System .
2.3.1 Pump Relief Request 1.4.2, A and B EDG Fuel Oil Transfer Ihnnps ReliefRequest: The licensee requests relief from measuring the EDG fuel oil transfer pump discharge pressure in accordance with OMa-1988 Part 6,15.2(d). Relief is also requested from the acceptance criteria requirements specified in 16.1, Table 3b for flow measurement.
Proposed Alternate Testing: Pumps will be tested by measuring level rise in the Fuel Oil Day Tank over time and converting the results to a flow in gallons per minute. This method provides a flow rate that meets the instrument accuracy requirements of 2% (Table 1). "The test flow rate (Q) will be compared to acceptance criteria established in accordance with Table 3b except the acceptable range has been widened on the high side and the High Alert Value has been increased. As a result, the High Required Action Range has also been increased. The increased acceptance criteria band is to allow for instrument fluctuations." The new limits ate:
Acceptable Range: 0.94 Qr to 1.07 Qr Low Alert Range: 0.90 Qr to 0.94 Qr High Alert Range: 1.07 Qr to 1.10 Qr Low Required Action Range: < 0.90 Qr High Required Action Range: > 1.10 Qr In addition, monthly Diesel Generator starting and loading (as required by McGuire Technical Specifications) will assess the hydraulic condition of the subject auxiliary pumps and demonstrate the capability of the individual components to perform their design function. Discharge pressure will not be measured.
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Iicensee's Basisfor Relieft The licensee states that: "The characteristics of these pumps and system configuration are such that the comparison of discharge pressure to the acceptance criteria in the Code places the pumps in constant alert range. Additionally, the flow rate evaluation is based on pump performance and derived such that the pump is not constantly in the alert range.
The D/G Fuel Oil Transfer Pumps are internal gear positive displacement pumps. The performance curve for these pumps is relatively flat. Capacity of these pumps is independent of discharge pressure when operating properly and below the cracking pressure of the pump internal relief valve.
Since discharge pressure can be affected by the differential pressure of the filters downstream of the pumps and other normal operating conditions associated with these pumps, discharge pressure will be monitored for information purposes, but it will not compared to any acceptance criteria. If the discharge pressure were to be compared to the acceptance criteria, due to previously stated reasons, these pumps would be constantly in the alert range.
These pumps tre designed to produce a flow rate of 22 gpm. The requirements of the Diesel Generator are approximately 6 gpm. Five vibration points are monitored and trended on the Fuel Oil Transfer Pumps. Acceptance criteria for the vibration points is calculated based on Relief Request 1.3.1. Vibration data is trended on a quarterly basis similar to the flow test results. Any degradation in the performance of the Fuel Oil Transfer pumps will first appear in the vibration data.
Also, the Fuel Oil Transfer pumps are conservatively designed in the discharge pressure that can be obtained. The capabilities of the pump are not challenged during the quarterly test with respect to discharge pressure. System limitations restrict the discharge pressure to less than or equal to 55 psig; however, the Fuel Oil Transfer pumps could easily pump against 150 psig.
Since the pumps are installed with considerable safety margin with respect to flow and discharge pressure, the most prudent data to use for trending for pump degradation would be the velocity vibration data By trending the five velocity vibration data points, the acceptability of the widened High Alert and Required Action ranges for flow are justified. The flow ensures system operability is met and the pump internal relief valve is not lifting prematurely while the vibration test ensures an adequate trending program is in place to ensure continued operability during testing intervals.
The D/G Fuel Oil Storage Tank is the suction for the Fuel Oil Transfer pumps and is monitored to maintain level as required by McGuire Technical Specifications. This level ensures adequate NPSH; therefore, a suction pressure reading is not required."
Evaluation: The fuel oil transfer pumps are small pumps with one horsepower driver motors as identified in the FSAR (Ref.13). OMa-1988, Part 6,15.2(d) requires that the (discharge) pressure of positive displacement pumps be determined and compared to the reference values given in 16.1, Table 3b. The licensee intends to monitor the EDG fuel oil transfer pumps discharge pressure for information purposes only, and not compare it to any Code reference values. The licensee's rationale is that system limitations restrict the discharge pressure to less than or equal to 55 psig, but that the pumps could mily pump against 150 psig. Since the transfer pumps are positive displacement type pumps, for a given speed, the pump flow rate is essentially constant and independent of pump discharge pressure. Fluctuations in the discharge pressure could be indicative of degradation or an impending safety concern. The licensee has not suggested any attematives such as using multiple reference values depending on system conditions, e.g., reference values as a function of downstream pressure differential. The licensee has not demonstrated the hardship or 7
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impracticality in meeting the Code requirements, and therefore, pending such demonstration by the licensee, it is recommended that this relief request relating to the discharge pressure be denied.
i OMa-1988 Part 6,15.2(d) also requires that the flow rate of positive displacement pumps be !
determined and be compared to the reference values given in 16.1, Table 3b. However,14.6.5 l requires the use of a flow rate or quantity meter to be installed in the pump test circuit. The licensee )
intends to measure flow rate by measuring the level rise in the Fuel Oil Day Tank over time (i.e., l during test) and converting the results to a flow in gallons per minute. The accuracy of this method, !
according to the licensee, meets the i2% requirement of 14.6.1.1, Table 1 for flow rate. The i licensee should have specifically requested relief for measuring flow rate in this manner because it l does not literally meet 14.6.5. However, the method meets the intent of 14.6.5. Based upon this l alternative providing an acceptable level of quality and safety for measuring flow rate it is recommended that it be authcrized pursuant to f50.55a 1(a)(3)(i). The licensee should ensure that ,
this method is described in a procedure and meets the quality assurance requtrements. ;
1 The licensee seeks to compare the measured flow rate to acceptance criteria other than that specified in Table 3b. The Low Required Action Range has been widened from <.93 to <.90 while the High Required Action Range is the same. In addition, a High Alert Range which is no longer required in Table 3b, and, a different Low Alert Range is specified. As discussed in Draft NUREG-1482 (Ref.11), Sction 5.6, OMa-1988 Part 6 does not allow the expansion of ranges for pump )
acceptance criteria. There are provisions for the licensee to review the test results and, if justified, I establish new reference values as discussed in 14.5. Although the pumps may be over-sized for the I application (and an internal gear positive displacement pump (pdp) may have different characteristics I than other pdp's) it is not clear from the licensee's description what the basis is for the expanded 1 range and why such an expanded range will not exclude pump degrading conditions. The basis for I acceptable pump performance would pertain to the pump and not the system. Therefore, pending such demonstration by the licensee, it is recommended that this relief request relating to flow rate acceptance criteria be denied.
Although the licensee plans to measure pump flow rate, the primary means of detecting pump degradation will be to monitor and trend five vibration velocity points on the pumps. Acceptance criteria for the vibration points is calculated based on Relief Request 1.3.1. The vibration data are trended on a quarterly basis. Section 2.1.1 of this TER evaluates the acceptability of this relief request.
2.4 Component Cooline Water (CCW) System 2.4.1 Pump Relief Request 1.4.3, Component Cooling Water Pumps A1, A2, B1, and B2 Licensee's Relief Request: The licensee requests relief frem OMa-1988, Part 6,14.6.1.2(a) which requires that the full scale range of the hstrument shall be three times the reference value or less for the component cooling water pump succion gauge.
Proposed Alternate Testing: The currently installed process instrumentation will be used to measure CCW pump suction pressure for the A1, A2, B1 and B2 CCW pumps which have an installed range of 4 times the reference value.
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Licensee's Basisfor Relief: The licensee states that: "The installed process instrumentation for the component cooling water pump suction gauge is a 0-60 PSIG,0.5% accuracy. Typical values for the component cooling water suction pressure during the CCW pump testing is 15-20 psig; therefore, the process gauge does not meet the three times criteria. The accuracy of the process gauge (0.5%) is well below the requirements specified in Table 1 for pressure instrument accuracy (2%). The actual reading error at test pressure due to the process instrument accuracy is 2% (0.5 X 60/15). If a 0-45 PSIG test instrument is used (which meets the three times criteria) and it has an accuracy of 2%, then the reading error would be 6% (2 X 45/15). When the requirements of Section 4.6.1.2(a) and Table 1 are combined, the actual instrument error introduced into the test is less than the Code allowable (2% versus 6%). Using the process instrument for suction pressure data does not degrade the quality of the test and meets the intent of the instrumentation requirements of the Code; just not the specific range requirements of Section 4.6.1.2(a)."
Evaluation: 'The licensee has requested relief from the full scale range requirements for the analog gauge used to measure suction pressure for the component cooling water pump. OMa-1988, Part 6, 14.6.1.2 requires that the range for this instrument be three times the reference value or less. As stated by the licensee, the instrument currently used has a rsnge of four times the reference value.
The four component cooling water pumps per Unit are low pressure and large flow (150 psig, 3500 gpm) horizontal cennifugal pumps, driven by 200 hp induction motors. :
As discussed in Draft . ' REG-1482 (Ref.11), Section 5.5.1, "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, relief may be granted when the combination of the range and the accuracy yields a reading at least equivalent to the reading achieved from instruments ,
that meet the Code requirements." As stated by the licensee, the accuracy of the pressure instrument l is 0.5%, which is better than the Code specified accuracy of i2% (OM Part 6,14.6.1.1 Table 1). )
The combination of the expanded instmment range and reading accuracy for the installed j instrumentation provides a higher reading accuracy (i2%) than the Code allowable i6%. l Based upon the use of the installed pressure instruments providing an acceptable level of quality and safety, it is recommended that the alternative be authorized pursuant to $50.55a 1(a)(3)(i). In the event these instruments are replaced, the new instruments should have ranges in compliance with the Code.
2.5 Residual Heat Removal System 2.5.1 Pump Relief Request 1.4.4, Residual Heat Removal Pumps A and B J
I Licensee's Relief Request: The licensee requests relief from the quarterly testing requirements using I reference values as specified in OMa-1988, Part 6,15.2(b) for the RHR pumps. In addition the licensee is also seeking relief for the instrument range requirements per OMa-1988, Part 6,14.6.1.
Proposed Alternate Testing: The Residual Heat Removal pumps will be tested according to the following program:
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Ouarterly The Residual Heat Removal pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrumentation range requirements of Section 4.6.1.2(a) will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications. The instrument used to measure vibrations will meet the requirements specified in Relief Request 1.3.1. The test loop used in the test has a flow measuring orifice installed; however, the system resistance cannot be adjusted with the associated throttling valve without invalidating the Residual Heat Removal system flow balance (a Tech Spec balance of flow to all four cold legs.)
Therefore, flow through this loop will be recorded for information only.
B_pfueling Outane During each refueling outage. a Code pump test - including velocity vibration measurements - will be performed at a test point in the stable region of the performance curve. .
As an alternative to repeat testing at a single test point in the stable region, a reference curve may be obtained with applicable acceptance curves plotted. Using this technique, the full flow test point (also in the stable region of the pump curve) will be bound by flow points obtained in the development of the reference curve. The data obtained is then evaluated against acceptance criteria and Chapter 15 basis acceptance curves to verify pump operability. Wh n baseline vibration data varies significantly over the pump head curve, vibration acceptance criteria will be developed for flow regions of the head curve.
The test method selected will depend on plant refueling conditions, maintenance performed on the pump, and the quantity of pump data required. Either method selected will ensure that the pump is tested in the full flow region of the head curve and that system operability is verified. Each test methodology is consistent with the intent of Code requirements and GL 89-04.
Licensee' Basisfor Relief: The licensee states that:
- 1) "When testing these pumps on line, the only flow path available is through the miniflow control i valve in the line, which yields a test point back on the head curve. As stated in GL 8944, minimum l flow lines are not designed for pump testing purposes. The test point for monitoring pump performance for degradation should be in a more stable region on the pump performance curve. ,
Also, the amount of time the pump is run at miniflow should be minimized. !
- 2) Also, range requirements will be waived for the quarterly test. The purpose of the quarterly test is to ver; / Tech Spec requirements are met and to obtain vibration data for trending. The -
instrumente an used for the quarterly Residual Heat Removal Pump test will meet accuracy requirements for assuring Residual Heat Removal Pump operability per Technical Specifications." !
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Evaluation: The licensee has requested relief from the quarterly testing requirements which require measurement of flow rate and the pressure instrument range requirements for the RHR pumps A and B. The two RilR pumps per Unit are vertical line shaft centrifugal pumps, low pressure and large flow (600 psig, 3000 gpm), driven by 400 hp induction motors.
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In lieu of the quarterly flow test at the reference value, as specified in OMa-1988, Part 6,15.2(b),
the licensee is proposing to demonstrate pump operability through a quarterly minimum flow test, measuring pump differential pressure and vibration, and a full flow test during refueling outages.
Due to difficulty in throttling flow during the quarterly minimum flow test, the licensee is proposing to monitor flow for information only.
The RHR is used to remove residual and sensible heat from the reactor core and reduce RCS temperature during cold shutdowns and refueling outages. A review of the RHR system flow ,
diagram, MC-1561-1.0, shows that there is a 2 inch bypass loop installed around the pumps. The !
licensee states it would be difficult to throttle the flow in this minimum recirculation line without l I
upsetting the RHR flow balance. As discussed in Question 48 of the Public Meetings held on GL 89-04 (Ref. 9), the NRC considers minimum flow tests to produce data of marginal value in providing assurance of a pump's operability. A full flow test, during refueling outages or cold shutdowns, is more desirable. Deferring tests to cold shutdowns or refuelings is permissible per staff Position 9 of GL 89-04 provided pump differential pressure, flow rate, and bearing vibration e measurements are taken during this testing and that quarterly testing is continued that measures at least pump differential pressure and vibration. It is impractical to perform a full flow test on.these ,
l pumps quarterly during normal plant operation since this system is in standby and the RHR pump pressure cannot overcome the RCS pressure. ;
The licensee has also requested relief from the instrument full range requirement, as specified in !
OMa-1988, Part 6,14.6.1 for the differential pressure and vibration measurements during the quarterly test. The licensee states in the Basis that the instrumentation used during the Tech. Spec.
testing will meet the accuracy requirements for assuring RHR pump operability per the Tech. Specs.,
but has provided no specific information regarding the range or accuracy. In the previous safety evaluation (Ref.12) of this request, relief was not recommended, and the licensee was requested to provide further information. This information has still not been provided. Therefore, relief cannot be recommended. The purpose of the IST tests is to ensure the operability of the component to perform as required. Without further specific information, there is no assurance that the accuracy of the specific attributes monitored will be adequate to detect degradation, as required by the Code.
Although not specifically requested, the licensee appears to be requesting permission to use alternative testing to be able to perform the refueling tests using reference values or pump curves, depending on plant refueling conditions, maintenance performed, and the quantity of data required.
As discussed in both Draft NUREG-1482 (Ref.11), Section 5.2, and the previous SE (Ref.12), the use of pump curves for reference values of flow rate and differential pressure is acceptable if the licensee clearly demonstrates the impracticality of establishing a fixed set of reference values. The licensee has not provided sufficient information to demonstrate the impracticality of establishing a fixed set of reference values during cold shutdowns or refueling outages for the RHR pumps.
However, the primary choice of performing a Code pump test - including velocity vibration measurements - at a test point in the stable region of the performance curve is acceptable.
Additionally, the seven elements discussed in Draft NUREG-1482 (Ref.11), Section 5.2 must also be included in the relief request.
In conclusion, the licensee's request to defer the quarterly flow testing for the RHR pumps is in accordance with Position 9 of GL 89-04, and relief is granted pursuant to $50.55a 1(f)(6)(i) based on the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility, it is 11
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i recommended that the licensee consider the practicality of performing the full flow test during cold shutdowns as well as refuelings as a means of gaining more performance data. 1 1
The licensee has not provided sufficient information regarding the range and accuracy of the ;
instruments which will be used during these tests. An assessment as to the acceptability of these l instruments cannot be made, nor can any assurance be provided that they are sensitive enough to detect pump degradation and ensure operability. Therefore, relief cannot be recommended. The licensee should perform the full flow test using reference values, during refueling outages (and also consider testing at cold shutdowns), and compare these values to the limits contained in OMa-1988 Part 6. Pump differemial pressure and vibration should continue to be monitored quarterly during pump minimum recirculation flow testing, and action taken as per the requirements of the Code as well as the Technical Specifications. The licensee should revise the relief request in accordance with Section 5.2 of Draft NUREG-1482 (Ref.11) if the use of pump curves is desired.
2.6 Safety infection System 2.6.1 Pump Relief Request 1.4.5, Safety Injection Pumps A and B .
Licensee's Relief Request: The licensee requests relief from the quarterly testing requirements using reference values as specified in OMa-1988, Part 6,15.2(b) for the Safety Injection Pumps. In addition the licensee is also seeking relief for the instrument range requirements per OMa-1988, Part 6,14.6.1.
Proposed Alternate Testing: The Safety Injection Pumps will be tested according to the following program:
Ouarterly The Safety Injection pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrumentation range requirements of Section 4.6.1.2(a) will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications. The instrument used to measure vibrations will meet the requirements specified in Relief Request 1.3.1.
The test loop has a flow measuring orifice installed; however, there is no means provided to vary the system resistance to set either the flow or differential pressure. Therefore, flow through this loop will be recorded for information only.
Refueline Outace During each refueling outage, a Code pump test - including velocity vibration measurements - will be performed at a test point in the stable region of the performance curve.
As an alternative to repeat testing at a single point in the stable region, a reference curve may be obtained with applicable acceptance curves plotted. Using this technique, the full flow test point (also in the stable region of the pump curve) will be bound by flow points obtained in the development of the reference curve. The data obtained is then evaluated against acceptance criteria i i
and Chapter 15 basis acceptance curves to verify pump operability. When baseline vibration data 12 l
varies significantly over the pump head curve, vibration acceptance criteria will be developed for flow regions of the head curve.
The test method selected will depend on plant refueling conditions, maintenance performed on the pump, and the quantity of pump data required. Each method selected will ensure that the pump is tested in the full flow region of the head curve and that system operability is verified. Each test methodology is consistent with the intent of Code requirements and GL 89-04.
Licensee' Basisfor Relief: The licensee states that:
- 1) "When testing these pumps on line, the only flow path available is through the miniflow line which has a flow restricting orifice. The orifice yields a test point back on the head curve. As stated in GL 89-04, minimum flow lines are not designed for pump testing purposes. The test point for monitoring pump performance for degradation should be in a more stable region on the pump performance curve. Also, the amount of time the pump is run at miniflow should be minimized.
- 2) Also, range requirements will be waived for the quarterly test. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly Safety Injection Pump test will meet accuracy requirements for assuring Safety Injection Pump operability per Technical Specifications."
Evaluation: The licensee has requested relief from the quarterly testing requirements which require measurement of flow rate and the pressure instrument range requirements for the Safety Injection Pumps A and B. The two SI pumps per Unit are multistage centrifugal pumps, intermediate pressure and flow (1700 psig,425 gpm), driven by 400 hp induction motors.
In lieu of the quarterly flow test at the reference value, as specified in OMa-1988, Part 6,15.2(b),
the licensee is proposing to demonstrate pump operability through a minimum flow test quarterly, measuring pump differential pressure and vibration, and a full flow test during refueling outages.
Despite the presence of a fixed orifice the recirculation line does not have a means of throttling flow and, consequently, the licensee is proposing to monitor flow for information only.
The Safety Injection System is utilized as the intermediate pressure, intermediate volume of the emergency core cooling system and during normal operation is aligned to take suction from the refueling water storage tank (in the event of an intermediate or large break LOCA). A review of the SI system flow diagram, MC-1562-3.0, shows that there is a 1 1/2 inch bypass loop installed around the pumps to the refueling water storage tank. As discussed in Question 48 of the Public Meetings held on GL 89-04 (Ref. 9), the NRC considers minimum flow tests to produce data of marg' mal value in providing assurance of a pump's operability. A full flow test, during refueling outages or cold shutdowns, is more desirable. Deferring tests to cold shutdowns or refuelings is permissible per staff Position 9 of GL 89-04 provided pump differential pressure, flow rate, and bearing vibration measurements are taken during this testing and that quarterly testing also measuring at least pump differential pressure and vibration is continued. It is impractical to perform a full flow test on these pumps quarterly during normal plant operation since this system is in standby with the RCS pressure greater than the SI pump capability.
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The licensee has also requested relief from the instrument full range requirement as specified in OMa-1988, Part 6,14.6.1 for the differential pressure and vibration measurements during the quarterly test. The licensee states in the Basis that the instrumentation used during the Tech. Spec.
testing will meet the accuracy requirements for assuring SI pump operability per the Tech. Specs.,
but has provided no specific information regarding the range or accuracy. In the previous safety evaluation (Ref.12) of this request, relief was not recommended, and the licensee was requested to provide further information. This information has still not been provided and until it is, relief cannot be recommended. The purpose of the IST tests is to ensure the operability of the component to perform as required. Without further specific information, there is no assurance that the accuracy of the specific attributes monitored will be adequate to detect degradation.
Although not specifically requested, the licensee appears to be requesting permission to use alternative testing to be able to perform the refueling tests using reference values or pump curves, depending on plant refueling conditions, maintenance performed, and the quantity of data required.
As discussed in both Draft NUREG-1482 (Ref.11), Section 5.2, and the previous SE (Ref.12), the use of pump curves for reference values of flow rate and differential pressure is acceptable if the licensee clearly demonstrates the impracticality of establishing a fixed set of reference values, The licensee has provided no information on the impracticality of establishing a fixed set of reference values during cold shutdowns or refueling outages for the Safety injection Pumps. However, the primary choice of performing a Code pump test - including velocity vibration measurements - at a test point in the stable region of the performance curve is acceptable. Additionally, the seven elements discussed in Section 5.2 of Draft NUREG-1482 (Ref.11) must be included in the relief request.
In conclusion, the licensee's request to defer the quarterly flow testing for the SI pumps is in accordance with Position 9 of GL 89-04, and relief is granted pursuant to $50.55a 1(f)(6)(i) based on i
the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility. It is recommended that the licensee consider the practicality of performing the full flow test during cold shutdowns as well as refuelings as a means of gaining more performance data. l 1
The licensee has not provided sufficient information regarding the range and accuracy of the instruments which will be used during these tests. Therefore, an assessment as to the acceptability of ,
these instruments cannot be made, nor can any assurance be provided that they are sensitive enough I to detect pump degradation and ensure operability. Therefore, relief cannot be recommended. The !
licensee should perform the full flow test using reference values, during refueling outages (and as j recommended at cold shutdowns), and compare these values to the limits contained in OMa-1988 .
Part 6, Pump differential pressure and vibration should continue to be monitored quarterly during pump minimum recirculation flow testing, and action taken as per the requirements of the Code as well as the Technical Specifications. The licensee should revise this relief request in accordance with Section 5.2 of Draft NUREG-1482 (Ref.11) if the use of pump curves is desired.
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2.7 Chemical and Volume Control System 2.7.1 Pump Relief Reauest 1.4.6. Centrifugal Charging Pmnos A and B Ilcensee's Relief Request: The licensee requests relief from the quarterly testing requirements using reference values as specified in OMa-1988, Part 6,15.2(b) for the Centrifugal Charging Pumps. In addition the licensee is also seeking relief for the instrument range requirements per OMa-1988, Part 6, 14.6.1.
Proposed Alternate Testing: The Centrifugal Charging Pumps will be tested according to the following program:
Ouarterly The Centrifugal Charging pumps will be tested quarterly to verify Technical Specifications are met.
The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrumentation range requirements of Section 4.6.1.2(a) will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications.
The instrument used to measure vibrations will meet the requirements specified in Relief Request 1.3.1. The flow through the miniflow line to the Volume Control Tank will be assumed to be constant at the orifice design conditions (60 gpm).
Refueline Outace During each refueling outage, a Code pump test - including velocity vibration measurements - will be performed at a test point in the stable region of the performance curve.
As an alternative to repeat testing at a single point in the stable region, a reference curve may be obtained with applicable acceptance curves plotted. Using this technique, the full flow test point (also in the stable region of the pump curve) will be bound by flow points obtained in the development of the reference curve. The data obtained is then evaluated against acceptance criteria and Chapter 15 basis acceptance curves to verify pump operability. When baseline vibration data varies significantly over the pump head curve, vibration acceptance criteria will be developed for flow regions of the head curve.
The test method selected will depend on plant refueling conditions, maintenance performed on the pump, and the quantity of pump data required. Each method however will ensure that the pump is tested in the full flow region of the head curve and that system operability is verified. Each test methodology is consistent with the intent of Code requirements and GL 89-04.
Licensee' Basis for Relief: The licensee states that:
- 1) "When testing these pumps on line, the only fiow path available is through a combination of the normal charging line and the miniflow line to the Volume Control Tank. This test yields a test point back on the head curve. As stated in Generic Letter 89-04, mimmum flow lines are not designed for pump testing purposes. The test point for monitoring pump performance for degradation should be 15
in a more stable region on the pump performance curve. Also, the miniflow is not instrumented for flow. The flow through the line is assumed to be at the flow rate corresponding to the orifice design conditions.
- 2) Also, range requirements will be waived for the quarterly test. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly Centrifugal Charging Pump test will meet accuracy requirements for assuring Centrifugal Charging Pump operability per Technical Specifications."
Evaluation: The licensee has requested relief from the quarterly testing requirements which require the measurement of flow rate and the pressure instrument range requirements for the Centrifugal Charging Pumps A and B. The two centrifugal charging pumps per Unit are horizontal centrifugal pumps, high pressure and low flow (2800 psig,150 gpm), driven by 600 hp induction motors.
In lieu of the quarterly flow test at the reference value as specified in OMa-1988, Part 6,15.2(b), the licensee is proposing to demonstrate pump operability through a minimum flow test quarterly, measuring pump differential pressure and vibration, and a full flow test during refueling outages.
There is no means to measure the minimum flow to obtain the total flow rate during the quarterly test. The licensee has determined that installation of a flow element on the minimum flow line is not cost effective at this time (Ref.14).
The Centrifugal Charging Pumps of the CVCS are used in the high head safety injection system of the emergency core cooling system providing high pressure, low volume refueling water from the refueling water storage tank. During normal operation one of these two pumps, or the reciprocating charging pump, will provide charging flow to the reactor coolant system. A review of the CVCS flow diagram, MC-1554-2.0, shows that there is a 2 inch recirculation loop leading from the common discharge of the pumps which then passes through the Seal Water Heat Exchanger and ultimately returns to the Volume Control Tank. As discussed in Question 48 of the Public Meetings held on GL 89-04 (Ref. 9), the NRC considers minimum flow tests to produce data of marginal value in providing assurance of a pump's operability. A full flow test, during refueling outages or cold shutdowns, is more desirable. Deferring tests to cold shutdowns or refuelings is permissible per staff Position 9 of GL 89-04 provided pump differential pressure, flow rate, and bearing vibration measurements are taken during this testing and that quarterly testing also measuring at least pump differential pressure and vibration is continued. For its Zion Nuclear Generating Station, Commonwealth Edison (Ref.15) performs the quarterly test during normal operation by taking manual control of normal makeup and maintaining the pressurizer level constant. This flow rate becomes the reference value but may be 60% of the high head design value. Although the licensee has chosen to perform the Code pump test at refueling outages, this other scheme may be beneficial.
The licensee has also requested relief from the instrument full range requirement as specified in OMa-1988, Part 6,14,6.1 for the differential pressure and vibration measurements during the quarterly test. The licensee states in the Basis that the instrumentation used during the Te-h. Spec.
testing will meet the accuracy requirements for assuring Centrifugal Charging Pump operability per the Tech. Specs., but has provided no specific information regarding the range or accuracy. In the previaus safety evaluation (Ref.12) of this request, relief was not recommended, and the licensee was requested to provide further information. This information has still not been provided and until it is, relief cannot be recommended. The purpose of the IST tests is to ensure the operability of the 16
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component to perform as required. Without further specific information, there is no assurance that the accuracy of the specific attributes monitored will be adequate to detect degradation.
Although not specifically requested, the licensee appears to be requesting permission to use alternative testing to be able to perform the refueling tests using reference values or pump curves, depending on plant refueling conditions, maintenance performed, and the quantity of data required.
As discussed in both Draft NUREG-1482 (Ref.11), Section 5.2, and the previous SE (Ref.12), the use of pump curves for reference values of flow ra:e and differential pressure is acceptable if the licensee clearly demonstrates the impracticality of establishing a fixed set of reference values. The licensee has provided no information on the impracticality of establishing a fixed set of reference values during normal operation, cold shutdowns, or refueling outages for the Centrifugal Charging Pumps. However, the primary choice of performing a Code pump test - including velocity vibration measurements - at a test point in the stable region of the performance curve is acceptable.
Additionally, the seven elements discussed in Section 5.2 of Draft NUREG-1482 (Ref.11) must be included in tl e relief request.
In conclusion, the licensee's request to defer the quarterly flow testing for the Centrifugal Charging Pumps is in accordance with Position 9 of GL 89-04, and relief is granted pursuant to 650.55a 1(f)(6)(i) based on the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility. It is reconunended that the licensee consider the practicality of performing the full flow test during cold shutdowns as well as refuelings as a means of gaining more performance data.
The licensee has not provided sufficient information regarding the range and accuracy of the instrume. ts which will be used during these tests. An assessment as to the acceptability of these i instruments cannot be made, nor can any assurance be provided that they are sensitive enough to detect pump degradation and ensure operability. Therefore, relief cannot be recommended. The licensee should perform the full flow test using reference values, during refueling outages (and as recommended at cold shutdowns), and compare these values to the limits contained in OMa-1988 i Part 6. Pump differential pressure and vibration should continue to be monitored quarterly during pump minimum recirculation flow testing, and action taken as per the requirements of the Code as well as the Technical Specifications. The .ticensee should revise this relief request in accordance with Section 5.2 of Draft NUREG-1482 (Ref.11) if the use of pump curves is desired.
2.8 Nuclear Service Water System 2.8.1 Pump Relief Request 1.4.7, Nuclear Service Water Pumps A and B ReliefRequest: The licensee requests relief from Section 4.6.1.6 which requires the frequency j response range of the vibration measuring transducers to be from one-third mmtmum pump shaft rotational speed tc
- least 1000 Hz.
Proposed Alternate Testing: In lieu of Section 4.6.1.6, the vibration instrumentation will be calibrated over a range of 10 to 1000 Hz. Accuracy of measurement within this range is addressed in )
Relief Request 1.3.1.
Licensee's Basisfor Relief: The licensee states that: "The Nuclear Service Water pumps are ,
designed to operate at 1185 rpm. This speed yields a frequency of 19.75 Hz (1185/60). The 1
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l vibration instrumentation used cannot be calibrated to the required one-third muumum shaft speed of 6.58 Hz (19.75/3). This calibration range (i.e.,10 to 10,000 Hz.) encompasses most of the noise contributors, and repeatability within this range is very good."
Evaluation: The two Nuclear Service Water pumps per Unit are horizontal centrifugal pumps, low head and very large flow (17,500 gpm at 130 ft.), driven by 1000 hp induction motors of medium speed. Nominal synchronous speed (no load speed) of the motor is 1200 rpm for a six pole, 3 phase, induction motor with a full load speed of 1185 rpm. The lower frequency of 1/3 shaft rotational speed is 6.58 Hz. The lower frequency at 1/2 shaft rotational speed is 9.88 Hz. The full speed frequency is 20 Hz (i.e.,1200/60 at no load). Under the previous requirement, i.e.,Section XI,1IWP-4520(b), the frequency range of 9.88 to 20 Hz could be met with the vibration instruments identified with only a very small chance of missing a lower range frequency. Under OMa-1988, Part 6, Section 4.6, however, the requirement lowers the low frequency end and significantly extends the high frequency end. As discussed in Mr. J. Zudan's paper describing the differences between OM-Pan 6 and Section XI in NUREG/CP-Olli (Ref.16), the basis for this change is that "this range of frequencies will more accurately envelope all potential noise contributors." The lower limit of the range is to allow detection of problems such as bearing oil whirl and looseness of bearings. The licensee should evaluate whether the Service Water pumps are susceptible to degradation mechanisms that result in increased vibration levels at frequencies below 10 Hz.
The licensee's Catawba Nuclear StNon also requested relief for its Nuclear Service Water pumps, which had a slower full load speed of 710 rpm, which corresponds to a low end frequency of 3.94 Hz (at 1/3 rotational shaft speed). At the Catawba plant, the Licensee's CSI model 2110 instmment used foi vibration monitoring was equipped with analog integration circuits and other upgrades to lessen instrument susceptibility to field problems with low frequency measurements. It provided the l capability of obtaining repeatability of results at frequencies as low as 3 Hz. The licensee cautioned however, that the equipment available for calibration at Duke Power's standards lab would not support calibration of instruments at frequencies less than 10 Hz. The licensee stated that instrumentation for vibration measurements were in place and well established but believes a disruption in the program would be expensive and the ascertainment or improvement of accuracy would have negligible impact on the effectiveness of the. pump vibration monitoring. !
Instmmentation and calibration services do exist that can detect pump vibrations at very low speeds with a 1/3 minimum pump shaft rotational speed corresponding to 2 Hz. In the licensee's case the l question becomes one of being able to calibrate the instrument with the existing calibration equipment l and standards that have been developed at some cost. Instruments such as those used at the Catawba Station are acceptable to the NRC. Catawba Nuclear station was granted relief pursuant to $50.55a 1(a)(3)(i) and (ii). (Catawba Safety Evaluation dated January 16,1992) (Ref.17). l If the licensee commits to using similar instruments at McGuire Nuclear Station as it did at Catawba l Nuclear Station, then this alternative would provide an acceptable level of quality and safety and ,
imposition of compliance would result in an undue burden on the licensee without a compensating l increase in the level of quality and safety. It would be recommended that relief be granted pursuant j to $50.55a 1(a)(3)(i) and (ii) provided, as discussed in the October 12,1993 SE (Ref.12), the licensee revises the relief request to discuss the accuracy and repeatability of the instruments.
Additionally, the licensee should evaluate whether the pumps are susceptible to degradation mechanisms which result in incre. sed frequencies less than 10 Hz. and provide this information in the relief request.
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3.0 VALVE IST PROGRAM RELIEF REQUFETS l
in accordance with $50.55a, Duke Power Company has submitted four relief requests for specific valves at the McGuire Station that are subject to inservice testing under the requirements of ASME Section XI. These relief requests have been reviewed to verify their technical basis and determine their acceptability. Each relief request that is not authorized by Generic Letter 89 94 is summartzed below, along with the technical evaluation by BNL.
3.1 Containment Spray Systern 3.1.1 Valve Relief Request RR-NS1, Containment Spray (NS) Pump Check Valves ReliefRequest: The licensee has requested relief from full-stroke open exercising of the Containment Spray Pump Check Valves, NS-13,16, 30,33,41, and 46, quanerly as required by OMa-1988, Part 10, 14.3.2.1.
Proposed Alternate Testing: In lieu of quarterly exercising the licensee proposes to ,
disassemble / inspect all six valves on a frequency of once every four refueling outages (i.e., once every 6 years at present). A partial stroke test using air flow will be performed after reassembly.
Subsequent partial stroke tests will be performed within the four refueling outage interval but not every refueling outage.
Licensee's Basisfor Relief: The licensee states: "This valve population is verified to full stroke open by sample disassembly (refer to Jusiification of Deferrals 1-MC-NS2 and 2-MC-NS2). There are currently two separate subgroups within this population of valves. Group I contains the 2 valves associated with RilR discharge flow and group 2 contains the 4 valves associated with NS pump discharge flow. The present disassembly schedule inspects one valve from each group every refueling outage. During the four year history of disassembly, there have been no indications of wear, corrosion or degradation to the internal components. This is attributed to the fact that this population of valves is not subjected to flow, unless containment spray is initiated through the spray nozzles. Except for the spray nozzles there is no flow loop downstream of these check valves.
Due to the restricted access of this valve population, disassembly of any valve requires scaffolding to be erected on top of the polar crane. Tools, equipment, parts, electrical power and air lines must also be transported to the work location. Requirements of 29CFR 1910.28,29CFR 1926.452, ANSI A10.8-1977 and Duke Power's scaffolding program place workers at risk during the erection of scaffolding, and to a lesser degree, during the disassembly / reassembly execution. This concern for personnel safety is also coupled with the fact that these check valves are cover hung, swing check valves. This type of valve does not allow the technician to visually or physically verify exact seat realignment during reassembly. It is therefore possible, though unlikely, to degrade the condition of these valves by excessive disassembles.
The partial stroke test will not be performed each outage as scaffolding and polar crane use time is required for it also. This schedule of disassembly is to begin during EOC9 for both Units. All si7 valves will be disassembled and inspected. A partial stroke will be performed after reassembly. The valves will not be disassembled again until EOCl3 (for both Units)."
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Evaluation: Containment Spray pump discharge check va:ves NS-13,16,30,33,41, and 46 are eight inch, Category C, normally closed check valves. These valves open upon initiation of fim from the containment spray pumps through the spray headers. OMa-1988, Part 10,14.3.2.1 specifies that check valves will be exercised quarterly to their safety positions. This testing may be deferred to cold shutdowns or refueling outages if quarterly testing is not practical.
As st ted by licensee in the Basis, and confirmed through a review of flow diagram, MC-1563-1.0, testing these valves with flow would require initiation of containment spray, which is not practical.
As described in Section 6.5.4 of the McGuire UFSAR (Ref 13), air is used to test the containment spray header valves. Generic letter 89-04, Position 2 allows for check valve grouping and disassembly and inspection as an alternative to full-flow testing. Specific requirements are provided limiting the size of the sample group, sampling frequency, and corrective action should valve degradation be found.
The licensee is proposing to perform a one time disassembly and visual inspection for these six check valves, then perform no additional tests for a six year period, when each valve would be disassembled and inspected again. The licensee, in the Basis, states that this proposed schedule is primarily based upon the personnel and logistic hardships encountered during the inspection process.
In the response to Questions 12 and 19 contained in the Minutes of the Public Mectings held on GL 89-04 (Ref. 9), the NRC recognized that the provisions of Position 2 may have a significant impact upon outage time. The existence of " extreme hardship" that would allow an extension of the disassembly schedule is dependant upon particular plant circumste.nces. Examples cited include the need to off-load the reactor core, or the need to operate at mid-level of the reactor coolant loops. It does not appear that election of scaffolding solely would be considered an extreme hardship given these examples.
The basic concern with the licensee's approach relates to confidence in ensuring continued ope ability of the valves. The staff considers the sampling aspect of a staggered sequence to provide assurance of the continued operability of the valves that are not inspected during any given refueling outage l provided that at least one valve in th: grouping is disassembled and inspected. The licensee has not i provided information on the required review of industry. experience regarding the same type of valves j used in similar service. As stated in Position 2, extension of the valve disassembly / inspection ;
interval to one valve every other refueling outage or expansion of the group size above four valves I should only be considered in cases of extreme hardship where the extension is supported by actual ,
results from previous testing, end industry experience. The licensee's testing experience for the past I 4 years has shown no indications of wear, corrosion, or degradation to the internal components.
Another concern that should be addressed relates to the common cause failure rate and the basic event (i.e., failure to open) failure rate. The common cause failure rate may be greater for a grouping of six check valves of 6 years duration between disassembly versus the staggered sequence.
It may turn out that the common cause failure rate is quite small and can be neglected. However, the licensee is obligated under Position 2 to review industry experience regarding the same type of valve used in similar service. Additionally, the significance of the loss of benefits of sampling should be l addressed. One method for assessing this signiricance could be to identify the basic event failure rate and the common cause failure rate for the two schemes, and the corresponding difference in unavailability of the containment spray system and Level Il containment failure frequency. If the common cause failure rate proves to be high the licensee should reevaluate the relief request. Partial 20
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l stroke testing in the succeeding four refueling outage interval could help alleviate concerns about j common cause failures. The licensee should also address the partial stroke testing schedule in its evaluation.
The primary intent of disassembling and inspecting one valve each outage is to provide some degree of assurance that the valve has not degraded and will perform as required. The licensee's proposal to l perform no inspections for a six year period does not provide similar assurance. Proper operation of I these check valves is essential in ensuring the proper operation of the containment spray system in i order to mitigate the consequences of an accident. The difficulties described by the licensee do not meet the examples of extreme hardship as provided by the NRC. The licensee should evaluate the burden of inspecting the valves versus the benefit from performing the inspections. Without an evaluation of the effect upon plant safety, industry experience, and a more detailed explanation of the burden, authorization of the licensee's alternate i.ispection schedule cannot be recommended.
Numerous other PWR licensees perform inspections of the containment spray valves in accordance i with GL 89-04. The licensee should continue to perform the inspections in accordance with GL 89- I 04 Position 2.
As an alternative, the licensee may consider the use of non-intrusive techniques for these valves. As discussed in Draft NUREG-1482 (Ref. I1), Section 4.1.2, such techniques are permissible per the Code and provide indirect indications of proper check valve functioning. As discussed, these techniques. when used in conjunction with flow tests, may be used on a sampling basis to verify full-stroke opening, and as such, provide an alternative to disassembly and inspection. Such techniques, in conjunction with the testing performed on these valves with air, could provide indication of valve operability, while minimizing the difficulty encountered during visual inspections and reassembly.
3.2 Nuclear Service Water System 3.2.1 Valve Relief Request RR-RNI, Nuclear Service Water to Containment Spray Heat Exchanger Check Valves l
ReliefRequest: The licensee has requested relief from fyll-stroke close exercising of the Nuclear Service Water to Containment Spray Check Valves, RN-994 and RN-1006, in accordance with OMa- 1 1988, Part 10,14.3.2.1 and 14.3.2.2. l Proposed Alternate Testing: These check valves will be exercised closed on a yearly frequency during the nuclear service water system (RN) flow balance. ]
Licensee's Basisfor Relief The licensee states: " Testing these valves for closure requires passing the design flow through the containment spray heat exchanger. These heat exchangers are placed in wet-layup to maintain the heat exchanger integrity. Nuclear service water cools these heat exchangers and they have experienced corrosion from this raw water. Under wet lay-up conditions, the chemistry of the water on the raw water side of the heat exchanger is controlled and maintained for longer life of the heat exchangers. Testing these check valves would severely change the ;
chemistry in the wet lay-up state which would result in higher corrosion risk and major cost impact." 1 Evaluation: Check valves RN-994 and RN-1006 are 1 inch, Category C, check valves that are normally open when the wet layup recirculation pump is in operation. As shown in nuclear service water flow diagrams, MC-1574-3.1 and MC-1574-2.1, these check valves provide a safety function 21 i
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l in the closed direction for the nuclear service water (RN) system integrity during a seismic event in the event the non-Code piping fails.
It is impractical to test these check valves on a quarterly basis because of the potential for heat )
exchanger corrosion by having the chemical protection swept away during the test. OMa-1988, Pan 10,14.3.2.2(e) states that if exercising is not practicable during power operation or cold shutdowns, it may be limited to full-stroke exercising during refueling outages. The licensee's proposal to exercise these valves closed on a yearly frequency, during the nuclear service water system flow balance, exceeds this requirement. Based upon the fact that the annual testing of these valves providing an acceptable level of quality and safety, it is recommended that the alternative be authorized pursuant to $50.55a 1(a)(3)(i). i 3.3 Diesel Generator Startitur Air System ;
3.3.1 Valve Relief Request RR-VG1, Diesel Generator Control Air Solenoid Valves ReliefRequest: The licensee has requested relief from stroke time exercising the control air to the diesel generator valves (VGSV5160, 5161, 5162, 5163, 5170, 5171, 5172, 5173), in accordance with OMa-1988, Part 10,14.2.
Proposed Alternate Testing: Design Bases Document MCS-1609.VG-00-0001 paragraph 20.4.3.1 ,
states that these valves shall be tested by the diesel stan tests. These tests are performed monthly, ;
and a failure of any one of these valves would result in a failure of the diesel start test. The monthly l diesel stan test will continue to be performed, and during the refueling outages mentioned below, the function of these class B valves will be changed such that they are no longer subject to OMa-1988, Part 10,14.2 requirements.
Licensee's Basisfor Relief: The licensee states: Direct observation of these valves is impossible.
These valves are automatically opened when the diesel generator is staned. Similar valves (the starting air solenoid valves) are tested with acoustic emission monitoring. Limitations on available acoustic equipment prevents its use on these valves. Additionally, these valves are scheduled to be modified in function during refueling outages 1EOC9 Unit 1, and,2EOC9 Unit 2 (i.e., August 1994 and November 1994, respectively). Their new function will not be within the scope of the IST program. To comply with the requirements of Section 4.2 would impose a cost burden of additional acoustic monitoring equipment for the quarterly timing. Due to the short time before these valves are modified, no adverse trends could be developed from the quarterly testing."
Evaluation: The purpose of these solenoid operated valves is to supply control air to the Diesel Generator air / oil booster cylinder, the intercooler temperature controller, and the run/ shutdown cylinder.Section XI and OMa-1988 Part 10 require the measurement of valve stroke times as a means of monitoring valve degradation. The diesel control air header solenoid valves are enclosed and have no position indication. There are no design provisions that allow for measuring the stroke times of these valves by conventional methods. The licensee has stated that " Limitations on available acoustic equipment prevents its use on these valves" and that it would be burdensome to obtain additional acoustic monitoring equipment. The licensee's position is that another means of indirect indication of valve disk movement can be obtained from the monthly diesel start test.
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If any one of these valves fails to perform its intended function, it would result in a failure of the diesel to start. Conversely, a successful start of the diesel would indirectly indicate that the valve disk properly moved. As such, the proper movement of the valve disk is indirectly verified on at least a monthly basis. However, there is no measurement of degradation or trending over time. A successful start is a yes no test but does not provide time information to give an indication of degradation. If the diesel start times can be correlated to these valves' stroke times, there would be ,
better information on degradation. I As discussed in the initial relief request that was submitted by a Duke Power letter dated July 8, 1992, the valves in question were not initially included within the scope of the IST program. This eversight was identified as a result of the Design Basis Document upgrade program. During the upcoming refueling outages (EOC-9 for both Units), the valves in question will be modified. The modification would result in deleting the valves from the scope of the IST program, apparently under 10 CFR 50.59. The licensee has not provided information that would explain the basis for removing these valves from the IST program. This basis should be available for review by the NRC during subsequent inspections. For Unit 2, a revised relief request reflecting the revised schedule for completing the modification (EOC-9 refueling outage) was provided by a Duke Power letter dated August 24,1993. The October 12,1992 submittal provided the revised relief request which updated the Unit I revised schedule for completing the modification (from EOC-8 to EOC-9 refueling outage). The reason for the delay in completing the modification is attributed to less diesel down time during the outage due to the increased concern with shutdown risk management. This revision will allow the modifications to be planned within allowable outage windows.
As noted, NRC approval of this relief request was originally provided by a letter dated September l 25, 1992, in which the NRC advised that a relief request be submitted in the event the modifications i were not completed during the 1993 refueling outages for the two Units. The October 12,1992 IST l l
program submit.al for Unit 1 provided the request for relief for the Unit I valves, while for Unit 2 a relief request was submitted by an August 24,1993 Duke letter. (Ref.14 briefly summarizes the ;
history of this relief request). '
The previous SE (Ref.12) stated that "The licensee has revised the request by rescheduling the i modification to the next refueling outage, however, the licensee has not provided an explanation of i the burden of utilizing acoustic equipment as requested in the previous SE. Therefore, without an expanded explanation of the burden of complying with the Code, relief cannot be recommended." In its letter to the Staff of February 24,1994 (Ref.14), the licensee went into more detail as to why the i diesel start test was an acceptable alternative but is apparently reluctant to discuss any further the i burden imposed by utilizing acoustic equipment. However, given the limited length of time that relief is required, and the level of safety afforded by the monthly diesel test, interim relief is recommended until EOC-9. If the licensee does not delete these valves from the program in EOC-9, and relief is still required, the licensee must provide a means for detecting valve degradation (e.g.,
trending diesel start times as discussed above) and resubmit this relief request.
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3.4 Diesel Generator Room Sump System 3.4.1 Valve Relief Request RR-WNI, Diesel Jenerator Room Sump Pump Discharge Valves ReliefRequest: The licensee has requested relief from full-stroke exercising the diesel generator room sump pump discharge valves (WN-3,5, 7,11,13, and 15) open and closed, quarterly in accordance with OMa-1988, Part 10,14.3.2.1.
Proposed Alternate Testing: These valves will be verified to fully cycle with the pump tests every two years.
Iicensee's Basisfor Relief: The licensee states: "These valves are tested with pump operation. The pumps are considered to be dry sump pumps (reference OMa-1988, Part 6,15.5) and are tested on a two year frequency."
Evaluation: These diesel generator sump pump discharge valves are 2 in. or 6 in. simple swing check valves. These valves isolate parallel pump flow losses. WN-3,5,11, and 13, open to allow pump flow and close to isolate opposite pump flow losses. WN-7 and 15 close to isolate non-safety-related pumps from safety-related pumps. There are no test connections that would allow stroke exercising the valves open or closed quarterly. The only method available to test these valves is to run the sump pumps. The licensee requested relief to test these discharge valves every two years, which is consistent with Part 6 for the sump pump test frequency.
OMa-1988, Part 10,14.3.2.2(e) states that if exercising is not practicable during power operation or cold shutdowns, it may be limited to full-stroke exercising during refueling outages. Some utilities have gone to a two year refueling outage cycle.
The licensee would have to fill the sump and run the pumps quarterly, solely to exercise these valves in accordance with the Code. Based on the required test setup, it would be a hardship, considering l OMa-1988, Part 6,15.5 only requires the licensee to run the pumps once every two years.
Based upon the impracticability of testing these valves quarterly in accordance with the Code, the licensee's proposal to test these valves every two years in conjunction with sump pump tests provides a reasonable alternative. It is recommended that relief be granted pursuant to $50.55a T(f)(6)(i). 1 i
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4.0 DEFERRED TESTING JUSTIFICATIONS Duke Power has submitted ninety-five deferraljustifications that document the impracticality of testing valves quarterly, during operation, as required by Section XI. These justifications were reviewed to verify their technical basis. The results of this review are documented in Table 4.1. In general, the licensee should pmvide more information and discuss why the testing itself is impractical, by assessing the problems associated with performing the test. 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 for not performing the required tests, unless the testing renders systems inoperable for extended periods of time. As discussed in GL 91-18 (Ref.19), 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 and the difficulty of the test may be considered.
The licensee states in numerous justifications that the testing cannot be performed because of consequences if the valve failed during testing. The licensee should not b se the justification simply on an assumed failure, unless the failure could cause a loss of a safety system function or the.
probability and risk associated with a test induced failure warrants it. For example, the NRC staff has concluded that quarterly testing of PORVs is impractical because PORVs have shown a high probability of causing a small LOCA by sticking open. Typical valves, whose failure in a non-conservative position during exercising would cause a loss of system function, include all non-redundant valves in lines such as a single line from the RWST or accumulator discharge, or the RHR pump discharge crossover valves for plants whose licensing bases assumes that all four cold legs are being supplied by water from at least one pump (Reference NRC Information Notice 87-01). Other valves may fall into this category under certain system configurations or plant operating modes, e.g.,
when one train of a redundant ECCS system is inoperable, non-redundant valves in the remaming train should not be cycled because their failure would cause a total loss of system function.
However, when assessing the practicality of testing a valve, the licensee should not consider both a design basis accident and a single failure in the other train, as described in LER 90-22, Revision 1 (Docket 50-369).
The ninety-five deferraljustifications have been tabulated. Twenty-six of these were reviewed in the previous safety evaluation and additional information was requested but has not been received as of this date. Six of the deferrals should have been relief requests.
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~
Table 4.1 McGuire Justification of Deferrals, Unit 1 (and 2)
Posed Item ' Valve . Drawingi Licensee's Justification .
~
Memate .
No. - Identification 7 No. _ For Deferred T<. sting -
Testmg -
AUXILIARY FEEDWATER SYSTEM (CA) 1(2)-MC-CA1 1(2)CA-37, 1(2)CA-41, 1(2)CA-45, MC-1592-1.0, Rev. 19, " Full stroke testing these valves Valves will be full stroke exer-1(2)CA-49, 1(2)CA-53, 1(2)CA-57, (MC-2592-1.0, Rev. 0) would unnecessarily thermal cised at cold shutdown. Closure 1(2)CA-61,1(2)CA-65, 4" check valves,
- F1o w Diagram of shock the steam generators and will be verified quarterly.
Cat. C, Auxiliary Feedwater Supply to Auxiliary Feedwater System feedwater piping."
Steam Generators, normally closed (CA)"
Evaluation: These check valves are located in the supply lines to the steam generators. It is impractical to part-stroke or full-stroke exercise these valves open quarterly because this would result in the flow of cold Auxiliary Feedwater flow into the steam generators, possibly resulting in thermal stress and shock on the nozzle connections.
The alternative provides full-stroke exercising open at cold shutdowns in accordance with OMa-1988 / art 10,14.3.2.2(c).
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_ _ _ - ~ .
Table 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Alternate No. Identification No. - For Deferred Testing Testmg 1(2)-MC-CA2 1(2)CA-165,1(2)CA-166, 8" check valves, MC-1592-1.1, Rev. 14, 'Neither full nor partial flow can At least one of these two valves Cat. C, Nuclear Service Water to Auxiliary (MC-2592-1.1, Rev. 1), be put through these valves will be disassembled and full Feedwater " Flow Diagram of without contaminating the stroked during each refueling Auxiliary Feedwater (CA)* Auxiliary Feedwater System with outage, and both valves will raw water. No means exist for have been disassembled and full alternate testing techniques using stroked after two consecutive air or any other medium. No refueling outages. Failure of means exist to test for proper one valve to properly full stroke closure without contaminating the during a refueling outage will Auxiliary Feedwater System with result in the remaining valves raw water. These valves will not being disassembled and full be tested during cold shutdown stroked during that outage.
because sample disassembly is Sample disassembly will also be required." used to verify proper closure of valves.
Evaluation: These valves are in the Nuclear Service Water (RN) supply to the steam generators. The RN system is only used if there is low suction pressure from the normally aligned sources of feedwater to the auxiliary.feedwater (CA) pumps. Ilence, the RN supply is a backup supply. If, during CA operation, the suction pressure drops below a preset pressure for three seconds the downstream motor operated valves open allowing RN flow through the check valves (which must open).
It is impractical to part-stroke or full-stroke exercise these valves open quarterly or during cold shutdowns because this would result in contaminating the Auxiliary Feedwater System with raw service water. To verify closure of these valves by leak testing during power operation or cold shutdowns also would require that the EMOs immediately downstream be open, thereby contaminating the Auxiliary Feedwater System with raw service water. A review of P&lD MC-1592-1.1 verifies that there is no means to either full or partial stroke these valves with flow without service water flow to the Auxiliary Feed vater pumps.
The licensee's proposed alternative testing is to sample disassemble at least one of these two valves and verify full stroke open and closed (manually) during refueling outages. The licensee's proposed alternative testing by sample disassembly is in accordance with Generic Letter 89-04, Position 2.
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Table 4.1 (Cont'd)
Item Valve - Drawing ' . Licensee's Justification Posed
- temate No. Identification No, For Deferred Testing Testmg 1(2)-MC-CA3 1(2)CA-8,1(2)CA-10,1(2)CA-12, 8" check MC-1592-1.1, Rev. 14, "These valves cannot be tested to Valves will be sample valves, Cat. C, Auxiliary Feedwater Pump (MC-2592-1.1, Rev. 1), close without contaminating the disassem' led during refueling Suction check valves, normally closed "F1ow Diagram of Auxiliary Feedwater System with outages to verify valve closure Auxiliary Feedwater (CA)* raw water. These valves will not capability. 1(2)CA-8 is be tested during cold shutdown disassembled every refueling because sample disassembly is outage,1(2)CA-10 and 1(2)CA-required." 12 every other refueling outage on a staggered basis.
Evaluation: These valves open to allow the normal auxiliary feedwater supply to the Auxiliary Feedwater (CA) pumps and close when the alternate Nuclear Service Water (RN) source is the supply to the pumps. This deferral and the previous deferral go together.
The licensee's proposed alternative testing is to sample disassemble at least one of these two valves and verify full stroke open and verify closure during refueling outages. The licensee has classified this alternative testing and frequency as a deferral when in fact it should be a relief request. The licensee should revise the IST program and include this as a relief request.
Ilowever, the licensee's proposed alternative testing by sample disassembly is in accordance with Generic Letter 89-04, Position 2 and a relief request should be submitted. -
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Trble 4.1 (Cont'd)
Drawing Posed Item Valve . Licensee's Justification No. Identification: . No. For Deferred Testing
. Testmg FEEDWATER SYSTEM (CF) 1(2)-MC-CFI 1(2)CF-26AB, 1(2)CF-28AB, 1(2)CF- MC-1591-1.1, Rev. 14, " Closure of these valves would Valves will be cycled and timed 30AB,1(2)CF-35 AB,12" electric-hydraulic (MC-2591-1.1, Rev. 0) isolate the Steam Generator during cold shutdown.
actuated gate valves, Cat. B, Main "F1ow Diagram of feedwater which could result in a Feedwater Isolation valves, normally open Feedwater System (CF)" severe transient in the Steam Generator, resulting in a Unit trip."
Evaluation: These valves are normally open and provide Main Feedwater to the steam generators main feedwater nozzles, and, close to (1) provide main feedwater isolation to prevent over pressurization of containment following a feedwater or main steam line break, (2) preclude blowdown of all steam generators following a feedwater or main steam line break, and (3) provide containment isolation following a LOCA or similar accident.
It is impractical to part-stroke or full-stroke exercise these valves closed quanerly because closure of these valves would result in a loss of steam generator level control and a possibly result in a plant trip. These valves also provide a containment isolation function and the licensee has not addressed the test requirements which in this case would be a seat leak rate test in accordance with 10CFR50, Appendix J.
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). Ilowever, the licensee has not addressed containment isolation testing. The licensee should revise and resubmit this deferral.
1(2)-MC-CF2 1(2)CF-17AB, 1(2)CF-20AB, 1(2)CF- MC-1591-1.1, Rev. 14 " Closure of these valves would Valves will be cycled and timed i 23AB, 1(2)CF-32AB, 18" air operated (MC-2591-1.1, Rev. 0) isolate the Steam Generator during cold shutdown.
globe valves, Cat. B, Main Feedwater "F1ow Diagram of feedwater which could result in a l
Control Valves to - Steam Generators, Feedwater System (CF)" severe transient in the Steam normally open Generator, resulting in a Unit trip."
i Evaluation: These valves control the flow of Feedwater to the Steam Generators.
It is impractical to either part-stroke or full-stroke exercise these valves closed quarterly because closure of these valves would result in a loss feedwater flow to the steam generator which would result in water level control problems and a possible plant trip. .
The alternative provides full-stroke exercising to the closed position and stroke timing during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
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l ., - _ - . _ .--_ _ _ . _ ._
Table 4.1 (Cont'd)
Posed -
Item Valve Drawing Licensee's Justification Mernate No, Identification . No. For Deferred Testing Testmg 1(2)-MC-CF3 1(2)CF-126B,1(2)CF-127B,1(2)CF-128B, 1.1MC-1591-1.1, Rev.14, " Cycling valves during power Valves will be cycled and timed 1(2)CF-129B, Main Feedwater Startup (MC-2591-1.1, Rev. 0) operation could induce unwanted during cold shutdown.
Isolation Valves, 6 in. normally closed " Flow Diagram of transients in the steam motor-operated gate valves, Cat. B Feedwater System (CF)" generators. This would result in an increase in flow to the main feedwater nozzles causing vibrationsin the preheater section of the steam generators."
Evaluation: These valves open in a preheater bypass line to supply startup feedwater to the steam generators through the Auxiliary Feedwater nozzles. Upon reaching about 17% flow at low load the flow is directed to the main feedwater nozzle via the preheater. With the electric-hydraulic valves closed these valves must provide the same safety functions of(1) provide main feedwater isolation to prevent over pressurization of containment following a feedwater or main steam line break, (2) preclude blowdown of all steam generators following a feedwater or main steam line break, and (3) provide containment isolation following a LOCA or similar accident.
It is impractical to exercise these valves open during power operation because this could induce transient conditions in the steam generators resulting in an increased flow of feedwater to the Feedwate, nozzles and in vibrations in the preheater section of the steam generators. These valves also provide a containment isolation function and the licensee has not addressed the test requirements which in this case would be a seat leak rate test in accordance with 10CFR50, Appendix L 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). However, the licensee has not addressed containment isolation testing. The licensee should revise and resubmit this deferral.
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Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification Mernate No. Identification No. For Deferred Testing Testing 1(2)-MC-CF4 1(2)CF-104AB, 1(2)CF-105AB, 1(2)CF- MC-1591-1.1, Rev. 14 " Closing this valve during Valves will be cycled and timed 106AB,1(2)CF-107AB, 6" air operated (MC-2591-1.1, Rev. 0) operation could result in loss of during cold shutdown.
valves, Cat. B, Main Feedwater Flow
- F1ow Diagram of Steam Generator level control Tempering Control Valves to Steam Feedwater System (CF)" and result in a Unit trip."
Generators Evaluation: ( This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.1). The Steam Generator Tempering Flow Valves are in a 6 in. bypass line around an 18 in line containing the main feedwater control valves, with one 18 in. line leading to each steam generator. The licensee is implying that quarterly testing would be performed when the valves are open. According to the McGuire FSAR, Section 7.7.1.7 on steam generator water level control, a secondary automatic control system is provided for operation at low power which uses the steam generator water level and nuclear power signals to position the bypass valve, which is the same as the tempering valve. Switchover from the bypass feedwater control system, which is operating at low power, to the main feedwater control system is initiated by the operator at approximately 17% power.
While the flow diagram, MC-1591-1.1, Rev.14. (MC-2591-1.1, Rev. 0), " Flow Diagram of Feedwater System (CF)," shows the tempering valves to be normally open, it is not likely that the valves would be open above 17% power. Even if the valves are open, it does not seem likely that isolating the flow from the 6 in. bypass line would cause a feedwater transient.
The licensee should clarify the operation of these tempering valves and the conditions under which quarterly testing is assumed to be performed.
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Trble 4.1 (Cont'd)
Item Valve Licensee's Justification Powd Draw ng' I' " *
No, Identification - No. For Deferred Testing Testmg 1(2)-MC-CF5 1(2)CF-152, 1(2)CF-154, 1(2)CF-156, MC-1591-1.1, Rev. 14 "During normal operation, there Valves will be full stroke 1(2)CF-158, 2" check valves, Cat. C, (MC-2591-1.1, Rev. 0) is ccnstant flow through these exercised at cold shutdown, tempering circuits to auxiliary feedwater
- F1ow Diagram of valves to keep the auxiliary nozzles, normally open Feedwater System (CF)" feedwater nozzles tempered.
Testing these valves would require supplying the Steam Generators with cold water and thus thermally shocking these nozzles."
Evaluation: These normally open check valves provide safety functions in both open and closed positions. When open tempering flow is provided to the steam generator Auxiliary Feedwater nozzles. The valves close to form a pressure boundary when the Auxiliary Feedwater System is in operation.
It is impractical to full-stroke exercise these valves closed quarterly during plant operation because this would require operation of the Auxiliary Feedwater System and thereby supply the steam generators with cold water and imposing thermal stresses on the Auxiliary Feedwater nozzles.
The alternative proposed by the licensee to full-stroke exercise these check valves at cold shutdowns is in accordance with OMa-1988 Part 10, T4.3.2.2(c). The licensee should ensure that this full-stroke exercising is for both the open and closed positions, n i
{
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Ttble 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification ternate No. Identification No. - For Deferred Testing Testmg REFUELING WATER SYSTEM (FW) 1(2)-MC-FW1 1(2)FW-27A,14" motor operated MC-1571-1.0, Rev. 16, " Closure of this valve during Valve will be cycled and gate valve, Cat. B, Refueling (MC-2571-1.0, Rev.10), normal power operation would timed during cold shutdown.
Water Storage Tank (RWST) " Flow Diagram of render all low pressure supply isolation valve to Residual Refueling Water System injection inoperable. This Heat Removal (RIIR) pumps (FW)" valve is opened and power suction header, normally open removed above Mode 4 per with power removed Tech Spec. 4.5.2."
Evaluation: This valve isolates the supply of water from the RWST to the suction of the low Pressure Injection (LPI)/RIIR pumps.
It is impractical to full-stroke exercise this valve closed during power operation because this would isolate both trains of LPI, rendering it unavailable if needed. In addition, the reactor coolant system pressure would prevent full flow testing of these valves because it is higher than the RilR pump pressure.
The alternative provides full-stroke exercising to the open and closed positimts during cold shutdowns in accordance with OMa-1988 Part 10, 14.2.1.2(c). The licensee should ensure that this full-stroke testing is for Mn the open and closed directions.
1(2)-MC-FW2 1(2)FW-28,10" check valve, Cat. MC-157i-1.0, Rev. 16, " Valve cannot be full stroked Valve will be full stroke C, Refueling Water Storage Tank (MC-2571-1.0, Rev.10), during power operation since exercised at cold shutdown.
(RWST) supply check valve to " Flow Diagram of the only full flow path is into Residual Heat Removal (RHR) Refueling Water System the RCS by the Residual Heat pumps suction header, normally (FW)" Removal pumps. These pumps closed cannot overcome RCS system pressure."
Evaluation: This valve opens to allow LPI flow to the RHR pumps and closes to prevent reverse flow to the RWST. It is in line and just downstream of isolation valve 1(2)FW-27A.
It is impractical to full stroke exercise this valve open and closed quarterly during power operation because the only full flow path through this valve is into the Reactor Coolant System (RCS) by the RllR pumps. The RHR pumps cannot overcome the RCS pressure. The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 1014.3.2.2(c}.
This check valve is also in the RHR (ND) test line and must partially open for the RHR pump quarterly testing. It appears that this valve can be part-stroke exercised to the open position quarterly in conjunction with the RHR pump testing.
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Ts.ble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justificat on No. Identification No. For Deferred Testing TW-INSTRUh1ENT AIR SYSTEM (IA) 1(2)-M C- 1(2)lA-5260,1(2)lA-5270,1(2)lA- MC-1499-IAl, Rev. O. "These valves cannot be practically Valves will be verified closed by leak IAI 5280,1(2)lA-5290,1(2)lA-5300, (MC-2499-IAl, Rev. 0), tested during operation due to the test performed in accordance with 10 1(2)lA-5310,1(2)lA-5320,1(2)lA- " Instrument Detail, design of the system." CFR 50 Appendix J at a six month 5330,1(2)lA-5340,1(2)lA-5350, Upper /1.ower Personnel frequency per Tech Spec 4.6.1.3.d.
1(2)lA-5360,1(2)lA-5370,1(2)lA- Air Inks, Inflatable 5380,1(2)lA-5390,1" Instrument Seals Control Air System air check valves, Cat. A&C (IA)"
Evaluation: Valves 1(2)lA-5260, 5270, 5280, 5290, 5300, 5310, 5320 and 5330 prevent loss of instrument air from the receiver tari on each personnel airlock door in the event of loss of instrument air supply to the door seals. These check valves form a pressure boundary for the inflatable seals. Valves 1(2)lA-5340 and 5350 provide the inside containment isolation barrier in the event of a break on the flexible hose connection on the air supply to the door seals. The outside solenoid isolation valves are 1(2)lA-5080 and 5160. The check valves are on the auxiliary building side of the airlocks. Valves 1(2)lA-5360, 5370,5380 and 5390 provide double isolation on the reactor building side of the airlocks for the pressure relief line.
A review of Drawing No. MC-1499-IAI confirms that there are no test connections which could be used to verify valve operability. The licensee's frequency of testing of 6 months is dictated by technical specifications if quarterly testing cannot be met. OMa-1988 Part 10,14.3.2.2 allows full-stroke exercising that is not practical during operation to be deferred to cold shutdowns or refueling outages. In this case, full-stroke exercising to the closed position is verified by seat leak testing in accordance with Tech Spec 4.6.1.3.d. The licensee should additionally implement all related requirements of 14.3.2.2, which includes Part 10,14.2.2.3(c) and (f).
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7 Table 4.1 (Cont'd) p sed Item Valve Drawing Licensee's Justification Alternate No. Identification No. For Deferred Testing Testmg COh1PONENT COOLING SYSTEM (KC) 1(2)-h1C- 1(2)KC-424B. 1(2)KC-425A, 8" hic-1573-3.1, Rev. 7, " Failure of either of these valves in Valves will be cycled and stroke timed kcl motor operated butterfly valves, (h1C-2573-3.1, Rev. 5) the closed position during testing during cold shutdown.
Cat. A, Component Cooling
- Flo w Diagram of would inhibit the normal flow path Water return isolation valves from Component Cooling from the reactor coolant pump motor RCP motor coolers thru System (KC)" coolers. This action could result in Penetration hi-320, normally open damage to the pumps."
Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.15). As shown on flow diagram htC-1573-3.1, Rev. 7, (MC-2573-3.1, Rev. 5) " Flow Diagram of Component Cooling System (KC)," 1(2)KC-424B and 1(2)KC-425A are installed in series in a line returning Component Cooling Water flow from inside the containment to the CCW return header outside and, as a result, isolate containment penetration hl-320. The licensee states that " Failure of either of these valves in the closed position during testing would inhibit the normal flow path from the reactor coolant pump motor coolers. This action could result in damage to the pumps." The valves appear also to isolate the flow from the reactor vessel suppon coolers, and by referring to MC-1573-3.0, Rev.10, (h1C-2573-3.0, Rev. 7) rrom a review of the flow diagrams, it appears that the valves close also to isolate the reactor coolant pump thermal barrier heat exchangers. The licensee has not provided any information concerning the time available before such consequences would result following failure of the valves in the closed position.
Testing should not be performed if the RCP or RCP seals could be damaged, resulting in an unisolatable LOCA. Ilowever, the licensee should provide further information in the CSJ basis to justify why the plant could not achieve a normal shutdown in the event that the valves fail closed during testing and clarify the function of these valves. The licensee should revise and resubmit this justification.
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Table 4.1 (Cont'd) I Licensee's Justification Posed Item -Valve ' Drawing '
. Mternate No. Identification . No. For Deferred Testing Testag .
1(2)-MC- 1(2)KC-338B, 8" motor operated hic-1573-3.1, Rev. 7 " Failure of this valve in the closed Valves will be cycled and stroke timed KC2 butterfly valve, Cat. A. (MC-2573-3.1, Rev. 5) position during testing would inhibit during cold shutdown.
Component Cooling Water supply " Flow Diagram of flow to the reactor vessel support to RCP motor coolers outboard Component Cooling coolers. This action could result in isolation valve off Containment System (KC)" damage to the reactor vessel."
Penetration M-327, normally open Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.16). As shown on flow diagram MC-1573-3.1, Rev. 7, (MC-2573-3.1, Rev. 5) " Flow Diagram of Component Cooling Water System (KC)," this valve is located outside containment in a line supplying Component Cooling Water to the reactor vessel support coolers and, as a resuk, provides isolation for containment penetration M-327. The licensee states that failure of this valve in the closed position during testing would inhibit flow to the reactor vessel support coolers, and that this action could result in damage to the reactor vessel.
The licensee has not provided any information concerning the time available before such consequences would result following failure of the valve 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 *.he event that 1(2)KC-338B failed closed during testing. The licensee should revise and resubmit thisjustification.
36
. - _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ __ _ -- ,.. . . - , . . - ~ - .
Tr.ble 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Al ae No. Identification No. For Defermi Testing ,,
1(2)-MC- 1(2)KC-332B, 1(2)KC-333A, 3" MC-1573-3.1, Rev. 7 " Failure of one of these valves in the Valve will be cycled and stroke timed KC3 air operated diaphragm valves, (MC-2573-3.1, Rev. 5) closed posicon during testing would during cold shutdown.
Cat. A, Component Cooling " Flow Diagram of inhibit flow through the reactor Water discharge isolation valves Component Cocling coolant drain tank heat exchanger.
from Reactor Coolant Drain Tank System (KC)" No alternate flow path for cooling IIcat Exchanger thru Containment water to the heat exchanger exists.
Penetration M-355, normally open Without flow to the heat exchanger, the drain tank would become over pressurized and steam would be released."
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.17). (Joint evaluation with 1(2)-MC-KC4 below).
As shown on flow diagram MC-1573-3.1, Rev. 7, (MC-2573-3.1, Rev. 5) " Flow Diagram of Component Cooling Water System (KC)," valves 1(2)KC-332B and 1(2)KC-333A are air-operated valves located in the Component Cooling Water outlet line from the Reactor Coolant Drain Tank Heat Exchanger (RCDTIIX) and, as a result, provide isolation for containment penetration M-355. Also as shown on MC-1573-3.1 (MC-2573-3.1), AOV 1(2)KC-320A is located on the CCW supply line to the RCDTIIX and provides isolation for containment penetration M-376. The licensee states that failure of one of these valves in the closed position during testing would inhibit flow through the RCDTIIX, and that no alternate flow path for cooling water to the RCDTIIX exists. Without flow to the RCDTilX, the Reactor Coolant Drain Tank would become overpressurized and steam would be released.
The licensee has not provided any information concerning the time available before such consequences would result following failure of one of the valves 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 one of these valves failed closed during testing.
1(2)2-MC- 1(2)KC-320A, 3" air operated MC-1573-3.1, Rev. 7, " Failure of this valve in the closed Valve will be cycled and stroke timed KC4 diaphragm valve, Cat. A, (MC-2573-3.1, Rev. 5) position during testing would inhibit during cold shutdown.
Component Cooling Water supply " Flow Diagram of flow through the reactor coolant to Reactor Coolant Drain Tank Component Cooling drain tank heat exchanger. No Heat Exchanger outboard isolation System (KC)" alternate flow path for cooling warer valve off Containment Penetration to the heat exchanger exists.
M-376, normally open Without flow to the heat exchanger, the drain tank would become over pressurized and steam 'would be released."
Evaluation: See evaluation for KC3 above.
37
Toble 4.1 (Cont'd)
Posed Item Valve Drawing Licensce's Justification Alternate No. Identification No. For Deferrvd Testing Testing 1(2)-htC- 1(2)KC-280,1* stop check valve, htC-1573-3.1, Rev. 7, "This valve cannot be practically Valve will be verified closed by leak KC5 Cat. A&C, Containment Penetra- (h1C-2573-3.1, Rev. 5) tested during operation due to the test performed in accordance with tion hi-355 stop check valve, " Flow Diagram of design of the system." 10CFR50 Appendix J at refueling normally closed Component Cooling outage frequency.
System (KC)"
Evaluation: This stop check valve provides containment isolation and thermal overpressurization protection of the line between 1(2)KC-333A on penetration hi-355. This valve is normally closed but would be required to open to provide the thermal overpressurization protection function. The licensee states that the valve cannot be practically tested during operation due to the design of the system and the valve will be verified closed by leak testing under Appendix J.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access for testing presents a personnel hazard due to high radiation levels and proximity to high energy systems. Irak testing this valve 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 the potential for extending the shutdowns.
Ohta-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages.
Full-stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(e) and (f).
Ilowever, although the licensee has described a safety function in the open position for these valves of providing thermal overpressurization protection for the containment penetration, the deferral does not specify any full-stroke or part-stroke exercise open test for these valves. The licensee should full-stroke exercise these valves open during cold shutdowns or revise the deferral to provide justification accordingly.
t I
l
\ .
i l
! 38 l
Tchle 4.1 (Cont'd)
Posed -
Item Valve Drawing Licensee's Justification ternate No. Identification No, . For Deferred Testing Testing 1(2)-M C- 1(2)KC-322,4" stop check valve, MC-1573-3.1, Rev. 7, "This valve cannot be practically Valve will be verified closed by leak KC6 Cat. A&C, Containment (MC-2573-3.1, Rev. 5) tested duting operation due to the test performed in accordance with Penetration M-376 Isolation stop " Flow Diagram of design of the system." 10CFR50 Appendix J at refueling check valve, normally open Component Cooling outage frequency.
System (KC)"
Evaluation: This valve is the inboard CIV upstream of the RCDTHX located inside containment.
It is impractical to test this valve quanctly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel hazard due to high radiation levels and proximity to high energy systems. I.cak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages.
Full-stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(c) and (f).
9 39
Table 4.1 (Cont d)
Drawing Licensee's Justification Posed Item Valve Alternate -
No. Identification No. For Deferred Testing Testmg 1(2)-MC- 1(2)KC-279,1" check valve, Cat. MC-1573-3.1, Rev. 7, "The system design does not provide Valve will be verified by leak test KC7 A&C, Containment Penetration M- (MC-2573-3.1, Rev. 5) a means of verifying valve closure performance in accordance with 320 Isolation check valve, " Flow Diagram of upon flow reversal." 10CFR50 Appendix J at refueling normally closed Component Cooling outage frequency.
System (KC)"
Evaluation: This valve provides containment isolation and thermal overpressurization protection of the line between 1(2)KC-424B and 1(2)KC-425A on penetration M-320. This valve is normally closed but would be required to open to provide the thermal overpressurization protection function. The licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel hazard due to high radiation levels and proximity to high energy systems. Leak testing diis valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages.
Full-stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(e) and (f).
Ilowever, although the licensee has described a safety function in the open position for these valves of providing thermal overpressurization protection for the containment penetration, the deferral does not specify any full-stroke or part-stroke exercise open test for these valves. The licensee should full-stroke exercise these valves open during cold shutdowns or revise the deferral to provide justification accordingly.
40
Tr,ble 4.1 (Cont'd)
Item ' Valve - Drawing .' Licensee's Justification M"* ~
No. Identification No. For Deferred Testing Testag 4
1(2)-MC- 1(2)KC-340,1* check valve, Cat. MC-1573-3.1, Rev. 7, "The system design does not provide Valve will be verified closed by leak KC8 A&C, Containment Penetration M- (MC-2573-3.1, Rev. 5) a means of verifying valve closure test performed in accordance with 327 Isolation check valve, " Flow Diagram of upon flow reversal." 10CFR50 Appendix J at refueling normally open Component Cooling outage frequency.
System (KC)*
Evaluation: This valve is the inboard CIV for the CC flow to the RCP motor coolers and the Reactor Vessel Support Coolers and is normally open. The licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel hazard due to high radiation levels and proximity to high energy systems. Leak testing this valve during cold shutdowns would be burdensome to the licensee due to the need for containment entry and an extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdown OMa-1988 Part 10,14.3.2.2(e) allows full stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages.
Full. stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(c) and (f).
41
Ttble 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Altunate No. Identification No. For Deferred Testing Testmg 1(2)-MC- 1(2)KC-47,3/4" check valve, Cat. MC-1573-4.0, Rev. 10 "The system design does not provide Valve will be verified closed by leak KC9 A&C, Containment Penetration M- (MC-2573-4.0, Rev. 6) a means of verifying valve closure test perfonnance in accordance with 322 Isolation check valve, " Flow Diagram of upon flow reversal." 10CFR50 Appendix J at refueling normally closed Component Cooling outage frequency.
System (KC)"
Evaluation: This valve is normally closed. He licensee states that this valve provides containment isolation on penetration M-322. From a review of the flow diagram, it appears that this valve also provides thermal overpressurization for the penetration for the CC header to the CC drain tank. His valve is normally closed. The licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J. This valve is located inside containment. Herefore, it is impractical to full-stroke exercise this valve closed quarterly.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel hazard due to high radiation levels and proximity to high energy svstems. leak testing this valve 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 the potential for extending the shutdowTis.
OMa-1989 Part 10,14.3.2 2(e) allows full stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages.
Full-strome exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(e) and (f).
Ilowever, the licensee should verify whether this valve performs a safety function in the open position by providing thermal overpressurization protection for the containment penetration. The deferral does not specify any full-stroke or part-stroke exercise open test for these valves. Pending such verification, the licensee should full-stroke exercise these valves open during cold shutdowns or revise the deferral to provide justification accordingly.
42
Tr.ble 4.1 (Cont'd)
- Drawing'- Licensee's Justification - Posed Item Valve ~
I'" *I*'
No. Identification - 1 No. For Deferred Testing -
Testag i BORON RECYCLE SYSTEM (NB) 1 ( 2 )-M C- 1(2)NB-262, 1* stop check valve, Cat. M C-1556-3.0, Rev. 15, "The system design does not Valve will be verified closed by i
NBl A&C, Containment Penetration M-259 (MC-2556-3.0, Rev. 10) provide a means of verifying valve leak test performance in stop check valve, normally closed " Flow Diagram of Boron closure upon flow reversal." accordance with 10CFR50 Recycle System (NB)* Appendix J at refueling outage frequency.
Evaluation: This valve closes to prevent reverse flow on the line from the Reactor Makeup Water Storage Tank to the Excess Letdown Heat Exchanger. This valve is located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the v4ve will be verified closed by lak testing under Appendix J at refueling outages. This valve is normally closed since the line is isolated upstream and would only have flow when required for the Excess Ixtdown IIcat Exchanger.
It is imptictical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing '
presents a penennel safety hazard due to higher radiation levels and proximity to high systems. Leak testing this valve during cold shutdowns would be burdensotw to the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extendirg the shutdowns.
OMa-198F Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. Full-stroke ex:rcising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirerr,cnts which includes Pan 10,14.2.2.3(c) and (f).
43
Table 4.1 (Cont'd)
. Drawing Licensee's Justification Posed Item _ Valve No. Identification No. For Deferred Testing T
REAC10R COOLANT SYSTEM (NC) 1 ( 2)-M C- 1(2)NC-32B, 1(2)NC-34 A, 1(2)NC-36B, 3 " MC-1553-2.0, Rev. 19 "PORVs do not serve a safety Stroke time testing will be NCI air operated control valves, Cat. B, Reactor (MC-2553-2.0, Rev. 15) function when unit is at operating performed at cold shutdown and Coolant System (RCS) Pressurizer Power " Flow Diagram of Reactor temperature and pressure. PORVs in all cases prior to entering Operated Relief Valves (PORVs), normally Coolant System (NC)" protect the Reactor Coolant System LTOP conditions in accordance closed from over pressurization during with Generic I2tter 90-06.
LTOP condidons." Testing will not be required more often than once per quarter as defined in OMa-1988 Part 10, 4.2.1.1.
Evaluation: The RCS PORVs open to relieve pressure for the primary (RCG sycm.
In Generic Letter 90-06, the NRC staff included PORVs, valves in PORV control air systems, and block valves within the scope of a program covered by the ASME Section XI, Subsection IWV. Stroke testing of PORVs should only be performed during Mode 3 (IIOT STANDBY) or Mode 4 (HOT SilUTDOWN) and in all cases prior to establishing conditions where PORVs are used for low-temperature overpressure protection (LTOP). Stroke testing of the PORVs should not be performed during power operation. .
The alternative provides full-stroke exercising to the open and closed positions d.: ting cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.l(c), and in all cases prior to entering LTOP conditions in accordance with Generic letter 90-06 44
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification tentate No. Identification No, For Deferred Testing Testmg 1 ( 2)-M C- 1(2)NC-272AC, 1(2)NC-273 AC, 1(2)NC- MC-1553-2.1,. Rev. O, " Opening these valves at full Valve will be cycled and stroke NC2 274B.1(2)NC-275B,1" solenoid operated (M C-2 5 5 3-2.1. Rev. pressure could cause damage to the timed during cold shutdown.
globe valves, Cat. B Reactor Vessel IIcad incorrect /M-2553-2.0, valve seating surfaces. A reactor Vent Valves, normally closed Rev.15) " Flow Diagram of coolant leak could be caused."
Reactor Coolant System (NC)"
Evaluation: These are the Reactor Vessel llead Vent valves, which are normally closed.
It is impractical to exercise these valves to the open position quarterly because testing of these valves during power operation could jeopardize the integrity of the RCS pressure bou dary.
The alternative provides full-stroke exercising open and closed during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
Ilowever, the licensee has categorized these valves as Category B, and they a- not listed in Table 3.4-1 of the Technical Specifications as Pressure isolation Valves. The licensee should ensure that the categorization of these valves complies with the requirements of Generic Letter 89-04, Position 4, regarding Pressure Isolation Valves, and the additional guidance regarding Position 4 in Draft NUREG-1482 (Ref. I1).
45
Tr:ble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justi!! cation Po d No. Identification No. For Deferred Testing
^
+
T I ( 2)-M C- 1(2)NC-259, 1(2)NC-261, 3/4" check MC-1553-4.0, Rev. 10, "The system design does not Valves will be verified closed NC3 valves, Cat. A&C, Containment Penetration (MC-2553-4.0, Rev. 13) provide a means of verifying valve by leak test performed in M-361 and M-326 check valves, normally " Flow Diagram of Reactor closure upon flow reversal." accordance with 10CFR50 closed Coolant System (NC)" Appendix J at refueling outage frequency.
Evaluation: These valves provide containment isolation and thermal overpressurization protection of the line between 1(2)NC-195B and 1(2)NC-l%A on penetration M-361, and the line between 1(2)NC-141 and 1(2)NC-142 on penetration M-326 respectively. These valves are located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to higher radiation levels and proximity to high systems. l.cak testing this valve during cold shutdowns would be burdensome to the licensee due to the need for containment entry and an extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(c) and (f).
However, although the licensee has described a safety function in the open position for these valves of providing thermal overpressurization protection for the containment penetration, the deferral does not specify any full-stroke or part-stroke exercise open test for these valves. The licensee should full-stroke exercise these valves open during cold shutdowns or revise the deferral to provide justification accordingly.
46
Table 4.1 (Cont d)
Posed Item Valve Drawing Licensee's Justification Ahernate No. Identification No. For Deferred Testing Testmg RESIDUAL IIEAT REMOVAL SYSTEM (ND) 1 ( 2)- M C- 1(2)ND-1B, 1(2)ND-2AC, 14" motor MC-1561-1.0, Rev. 19 "These valves have an interlock Valve will be cycled and stroke NDI operated gate valves, Cat. A RIIR Pumps (MC-2561-1.0, Rev. 0) which prevents their opening when timed during cold shutdown.
suction isolation valves, 14 in. motor- " Flow Diagram of Residual the Reactor Coolant System Valve will be leak tested in operated gate valves, normally closed IIcat Removal Systera pressure is greater than 385 psig." accordance with Tech Spec (ND)" 4.4.6.2.2.
Evaluation: These valves open to provide suction for the Residual IIcat Removal pumps during normal cool down, and must remain closed during normal power operation to provide pressure boundary isolation for the Reactor Coolant System.
It is impractical to part-stroke or full-stroke exercise these valves during power operation. Tech Spec 4.4.6.2.2 specifies the circumstances and frequencies for leak testing these valves.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c) and leak testing in accordance with 14.2.2.3.
1(2)ND-58A, 8" motor operated gate valve, MC-1561-1.0, Rev. 19, " Opening this valve during Valve will be cycled and stroke 1(2)-MC-ND2 Cat. B, RIIR Pumps Discharge to (MC-2561-1.0, Rev. 0) operation would render both trains timed during cold shutdowm.
Centrifugal Charging Pumps and Safety " Flow Diagram of Residual of Residual IIeat Removal Injection Pumps Suction, normally closed IIcat Removal System inoperable."
(ND)"
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.2). Motor- operated valve, IND-58A (2ND-58A), is in an 8 in. line leading from the discharge of RIIR IIcat Exchanger I A (2A) to the suction of the Safety injection and Centrifugal Charging Pumps. The licensee states that opening this valve during operation would render both trains of RilR inoperable.
A review of the P&lD in'tates that there is an air-operated valve, IND29 (2ND29), downstream of the take-off point which could i e used to ensure that flow from RIIR Pump IB (2L could f supply all four legs of the Reactor Coolant System. The licensee should consider the practicality of using this valve.
The licensee should stroke time test these valves quarterly in accordance with OMa-1988, Part 10,14.2.1.1, or provide additional information in the basis to justify why opening 1(2)ND-58A renders both trains of RIIR inoperable. .
47
Tr_ble 4.1 (Cont'd)
Itern Valve - Drawing Licensee's JustiGcation .
" Alternate No. Identification . No. For Deferred Testing Testag 1 (2)-M C- 1(2)ND-15B, 1(2)ND-30A, 8* motor MC-1561-1,0, Rev. 19, "One of the ECCS safety analysis Valve will be cycled and stroke ND3 operated gate valves, Cat. B, RHR Heat (MC-2561-1.0, Rev. 0) assumptions is that each train of ND timed during cold shutdown.
Exchanger Outlet Crossover Block Valves, " Flow Diagram of Residual can supply flow to all four cold normally open Heat Removal System legs. If either of these valves failed (ND)" closed during testing then only two cold legs could be supplied by each train of ND. This would make both trains of ND inoperable.'
Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.5). The licensee is proposing to forego quarterly testing of these valves because "One of the ECCS safety analysis assurnptions is that each train of ND (RHR) can supply flow to all four cold legs. If either of these valves failed closed during testing, then only two cold legs could be supplied by each train of ND. This would make both trains of ND inoperable." IE Information Notice 87-01, "RilR Valve Misalign nent Causes Degradation of ECCS in PWRs," addresses inservice testing of crossover valves in RHR system. It appears that inadvertent closure of either one of these valves would violate the single failure criterion. However, these valves are not among the valves listed in the FSAR, Section 6.3.2.16, " Motor-Operated Valves and Controls," as having the power disconnected at motor control centers, nor are they identified in Technical Specification 4.5.2 as having the power removed. The licensee should provide additional information regarding the FSAR requirement that each train of RHR be able to supply flow to all four cold legs, or provide further explanation as to the basis for that statement.
1(2)-M C- 1(2)ND-70, 8" check valve, Cat. C, RilR MC-1561- 1.0, Rev. 19, " Valve cannot be full stroked Valve will be full stroke ND4 Pumps Discharge check valve to Centrifugal (MC-2'61-1.0, Rev. 0) during power operation since exercised at cold shutdown.
Charging & SI Pumps suction, normally " Fir : Diagram of Residual 1(2)ND-58A would have to be closed liett Removal System opened, rendering both trains of (ha)" ND inoperable. Additionally, the flow requirements to full stroke this valve cannot be achieved with the Reactor Coolant System pressurized."
Evaluation: See ND5 below.
48
._- . _ _ _ _ _ . . _ , _ . _ _ _ ~ . . ._ _ _ _ . . __ _ _- -
Treble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Posed temate No. Identification No. For Deferred Testing Testmg 1(2)-M C- 1(2)ND-71, 8" check valve, Cat. C, RHR MC-1561-1.0, Rev. 19, " Valve cannot be full stroked Valve will be full stroke NDS pumps discharge check valve to SI pumps (MC-2561-1.0, Rev. 0) during power operation since exercised at cold shutdown.
suction, normally closed " Flow Diagram of Residual 1(2)NI-136B would have to be Heat Removal System opened, rendering both trains of (ND)* ND inoperable. Additionally, the flow requirements to full stroke this valve cannot be achieved with the Reactor Coolant System pressurized."
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.3). Check valve 1(2)ND-71 is in an 8 in. line leading from RHR IIcat Exchanger IB(2B) to the suction of the Safety Injection and Centrifugal Charging Pumps. The licensee is proposing to forego quarterly testing of this valve because the " Valve cannot be full stroked during power operation since 1(2)NI-136B would have to be opened, rendering both trains of ND inoperable. Additionally, the flow requirements to full stroke this valve cannot be achieved with the Reactor Coolant System pressurized."
In LER 369/90-22, Revision 01, the licensee stated that cycling of valves INI-136B and 2NI-136B, RilR (ND) Heat Exchanger IB and 2B to Safety Injection (NI) pump IB and 2B, to the open position while at power operation could degrade RHR system operation in the event of a large Break Loss of Coolant Accident (LBLOCA). It appears that the licensee's logic was based on assuming a design basis event during the stroke test ambined with a worst case single failure. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would rend te entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing, as discussed above.
In addition, there is an air-operated valve, IND14, on the outlet of RHR Heat Exchanger IB which is downstream of the take-off connection leading to the SI and charging pumps which could be used to ensure that flow from RHR Pump 1 A could supply all four legs of the Reactor Coolant System. It appears that the valve could at least be partially stroked on a quarterly basis. The licensee should full-stroke exercise this valve open quarterly in accordance with OMa-1988, Part 10,14.3.2.1, or provide additional information in the basis to justify why opening valve INI-136B would render both trains of RHR inoperable.
49
Ttble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Pod exuate No. Identification No. For Defe Ted Testing Testmg 1 ( 2 )-M C- 1(2)ND-8, 1(2)ND-23, 8" check valves, MC-1561-1.0, Rev. 19 " Valves cannot be full stroke Valve will be full stroke ND6 Cat. C, RHR Pumps Discharge line check (MC-2561-1.0, Rev. 0) exercised during power operation exercisM at cold shutdown.
valves, normally closed " Flow Diagram of Residual since the only full flow path is into Valves will be partially stroked Heat Removal System the Reactor Coolant System and the quarterly. 'Ihe opposite train (ND)" ND pumps cannot overcome RCS valves will be tested closed pressure." quarterly except when the opposite train of ND is in service.
Evaluation: These are the RHR pumps' discharge line check valves.
It is impractical to full-stroke exercise these valves open or closed quarterly because the RHR pumps shutoff head cannot overcome the RCS pressure. These valves will be part-stroke exercised open quarterly during the RHR pump testing.
The alternative provides part-stroke exercising open during plant operation and full-stroke exercising to the open and closed positions during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(b).
50
Table 4.1 (Cont'd)
Pimposed Item Valve Drawing Licensee's Justification .
"* I
- No. Identification No. For Deferred Testing Testmg ICE CONDENSER REFRIGERATION SYSTEM (NF) 1(2)-M C- 1(2)NF-229,1* check valve, Cat. A&C, M-1558-4.0, Rev. 14, "The system design does not 1) Valve will be verified i NFl Containment Penetration M-373 Isolation (MC-2558-4.0, Rev. 9), provide a means of verifying valve closed by leak test check valve, normally open " Flow Diagram of Ice closure upon flow reversal.* performed in accordance Condenser Refrigeration with 10CFR50 Appendix J System (NF)* at refueling outage frequency.
- 2) Leak Rate testing of the valve willbe perfonned per Tech Spec 4.6.1.2.d.4.
Evaluation: This valve closes to provide containment isolation for penetration M-373 on the line from the glycol chiller packages. This valve is located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J at refueling outages. Tech Spec 4.6.1.2.d specifies the conditions for leakage testing of this valve.
It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to higher radiation levels and proximity to high systems. Irak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full stroke exercising that is not practical during opetation or cold shutdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is verified by seat 8-ak testing in accordance with 10CFR50 Appendix J provided the licensee implements all related requirements which includes Part 10,14.2.2.3(c) and (f).
l 51
Table 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Alternate No. Identification No. For Deferred Testing Testmg SAFETY INJECTION SYSTFAI (NI) 1(2)-MC-Nil 1(2)NI-9A, 1(2)NI-10B, 4* MC-1562-1.0, Rev. " Opening either of these valves during Valve will be cycled and stroke time ,
motor operated gate valves, 18, (MC-2562-1.0, operation would increase the charging flow during cold shutdowm.
Cat. B, Centrifugal Charging Rev. 15) " Flow into the Reactor Coolant System resulting in Pumps flow path to RCS cold Diagram of Safety an increase of pressure and a rapid change in legs, normally closed injection System the primary system boron concentration. This (NI) could create a transient and possible unit shutdown."
Evaluation: These valves isolate the flow path from the CCPs to the RCS cold legs. Upon receipt of a safety signal these valves open allowing flow to the cold legs and will remain open (if necessary) after transfer of the water source from the refueling water storage tank to the discharge of the RHR (ND) heat exchangers for high pressure recirculation.
It is impractical to part-stroke or full-stroke open either of these valves during power operation because this would increase the charging flow to the RCS, resulting in an increase in RCS pressure and boron concentration, which could cause a plant transient and unit shutdown.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
1(2)-MC-N12 1(2)NI-100B, 8* motor MC-1562-3.0, Rev. " Closing this valve during operation would Valve will be cycled and timed during operated gate valve, Cat. B, 12, (MC-2562-3.0, render both trains of Safety injection cold shutdown.
RWST to SI pumps suction Rev. 10) " Flow inoperable. 'Ihis valve is opened and power isolation, normally open Diagram of Safety removed above Mode 4 per Tech Spec 4.5.2."
Injection System (NI)"
Evaluation: This valve closes to isolate the flow path from the RWST to the SI pumps' common suction header. This valve is normally open with power removed at the breaker for Modes 1,2, and 3. When switching over to recirculation in the course of a LOCA the power must be restored to close the valve.
Derefore, it is impractical to exercise this valve during power operation since closure of this valve would disable both trains of Safety injection.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
52
Table 4.1 (Cont'd)
Item Valve ' Drawing Licensee's Justification Paed M"*'*~
No. Identification No. ' For Deferred Testing '
Testing -
1(2)-MC-NI3 1(2)NI-147A,1(2)NI-115B,2" MC-1562-3.0, Rev. " Closing either of these valve during power Valve will be cycled and timed during motor operated globe valve, 12, (MC-2562-3.0, operation renders both trains of Saf:ty cold shutdown.
Cat. B, miniflow line to Rev. 10) " Flow Injection inoperable. 2NI-147A is open with RWST, and 1 1/2" motor Diagram of Safety power removed above mode 4 per Tech Spec operated globe valve, Cat. B, Injection System 4.5.2."
from SI pump 1A to 1(2)NI- (NI)"
147A, normally open Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.6). The licensee is proposing to forego quarterly testing of these valves because " Closing either of these valves during power operation renders both trains of Safety Injection inoperable. Valve,1(2)NI-147A, is open with the power removed above Mode 4 per Tech Spec 4.5.2." While it is definitely tnie that closing valve 1(2)NI-147A renders both trains of Safety Injection inoperable, it is not immediately apparent from the flow diagram why closing valve 1(2)NI-115B would do so.
In LER 369/90-22, Revision 01, the licensee states that when valve INI-IISB is cycled to the closed position, a loss of Train B power would render Train A of the Safety injection system inoperable. This is because when a Safety Injection signal has occurred, and the Reactor Coolant System pressure is above the shutoff head for the Safety Injection pump, the Safety Injection pump would not have a flow path for time miniflow protection of the Train A Safety Injection pump. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would render the entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing.
With respect to valve 1(2)NI-147A, the alternative provides full-stroke exercising to the closed position during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c). However, the licensee should stroke time test valve 1(2)NI-115B quarterly or provide additional information in the basis to justify why closing this valve renders both trains of SI inoperable.
53
Tr.ble 4.1 (Cont'd) i Item Valve Drawing Licensee's Justification Posed No. Identification No. For Deferred Testing Altegate Testmg 1(2)-MC-N14 1(2)NI-121 A,1(2)NI-152B, 4" MC-1562-3.0, Rev. "These valves are closed with power removed Valve will be cycled and timed during motor operated gate valves, 12. (MC-2562-3.0, above Mode 4 per Tech Spec 4.5.2." cold shutdown.
Cat. B, Safety Injection System Rev. 10) " Flow Pump Discharge Isolation Diagram of Safety valves, normally closed Injection System (NI)"
Evalr.ation: These valves isolate Si flow to the RCS hot legs during injection phase and open during recirculation phase.
During Modes 1,2 and 3, these valves are closed with power removed at the breaker as per Tech Spec 4.5.2. Therefore, it is impractical to full-stroke exercise these valves during power operation.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OM Part 10,14.2.1.2(c).
1(2)-MC-N15 1(2)NI-162A, 4" motor MC-1562-3.1, Rev. "This valve is opened and power removed Valve will be cycled and timed during operated gate valve, Cat. B, 6, (MC-2562-3.1, above Mode 4 per Tech Spec 4.5.2." cold shutdown.
Safety Injection Header to RCS Rev. 4) " Flow Cold Irgs, normally open Diagram of Safety injection System (NI)"
Evaluation: This normally open valv e isolates Si flow to the RCS cold legs.
This valve is required to be in the open position by Tech Spec 4.5.2 with power removed for Modes 1, 2 and 3 operation. Therefore, it is impractical to exercise this valve during power oper.iion.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
54
Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification AII#'"*
No. Identification No, For Deferred Testing Testing 1(2)-MC-NI6 1(2)NI-103A, 6* motor MC-1562-3.0, Rev. " Closing this valve during power operations Valves will be cycled and timed during operated gate valve, Cat. B, 12, (MC-2562-3.0, degrades both trains of Chemical and Volume cold shutdown.
Safety Injection System Pumps
- Rev. 10) " Flow Control. "
suction header isolation valve, Diagram of Safety normally open Injection System (NI)"
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.7). Valve 1(2)N1-103A is an MOV which isolates flow from the Refueling Water Storage Tank to the suction of Safety Injection Pump 1 A (2A). The licensee is proposing to forego quarterly testing of this valve because
- Closing this valve during power operations degrades both trains of Chemical and Volume Control.* From a review of flow diagram MC-1562-3.0, Rev.12, (MC-2562-3.0, Rev.10), " Flow Diagram of Safety Injection System (NI)," there is no apparent reason why closure of this valve would degrade the CVCS. In addition, the licensee is quarterly testing the Safety Injection Pump Train B miniflow valve,1(2)NI-144A.
In LER 369/90-22 Revision 01, the licensee states that when valve 1(2)NI-103A is cycled to the closed position, a loss of Train A power would render Train B of the CVCS inoperable. During the Recirculation Phase of Safety Injection, the flow path of the Residual Heat Removal system Train B to the CVCS pump suction is through valve 1(2)NI-103A. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would render the entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing.
The licensee should stroke time test valve 1(2)NI-103A quarterly in accordance with OMa-1988, Part 10,14.2.1.1, or provide additional information in the basis to justify why closure of this valve would degrade the CVCS. l 1(2)-MC-NI7 1(2)NI-173A,1(2)NI-178B,8" MC-1562-3.1, Rev. "7hese valves are opened and power removed Valve will be cyc!cd and timed during motor operated gate valves, 6 (MC-2562-3.1, above Mode 4 per Tech Spec 4.5.2." cold shutdown.
Cat. B, RIIR system discharge Rev. 4) " Flow isolation valves to Safety Diagram of Safety Injection System, normally Injection System open (NI) "
Evaluation: These valves provide the flow path for the Residual Heat Removal to the RCS cold legs.
As per Technical Specification 4.5.2, these valves are required to be in the open position with power renioved during Modes 1,2 and 3 operation. Therefore, it is impractical to exercise these valves during power operation.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
55
Table 4.1 (Cont'd) posed Item Valve Drawing Licensee's Justification Mternate No. Identification No. For Deferred Testing _
Testmg 1(2)-MC-N18 1(2)NI-334B, 6" motor MC-1562-3.0, Rev. " Closing this valve during power operation Valve will be cycled and timed during operated gate valve, Cat. B, 12, (MC-2562-3.0, degrades both trains of Safety Injection." cold shutdown.
Isolation valve for RIIR recire. Rev. 10) " Flow flow to Safety Injection Diagram of Safety System, normally open Injection System (NI)"
Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.8). As shown on flow diagram MC-1562-3.0, Rev.12, " Flow Diagram of Safety Injection System (NI)," valve INI-334B is in an 8 in. line leading either from the outlet of RIIR Ileat Exchanger Train B to the suction cf Centrifugal Charging Pump Train B or, if flow is in the opposite direction, from RIIR Ileat Exchanger Train A to the suction of Safety Injection Pump Train B. The licensee states that closing this valve during power operation degrades both trains of Safety Injection. This valve is not on the list of valves in Section 4.5.2 of the Technical Specifications for which power to the valve operators has been removed. This seeming discrepancy should be clarified.
In LER 369/90-22, Revision 01, the licensee states that when valve INI-334B is cycled to the closed position, a loss of Train B power would render Train A of Safety Injection inoperable. During the Recirculation Phase of a Safety Injection, the flow path of Train A of RllR to the Safety Injection pump suction is through valve INI-334B. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would render the entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing. In the same line as this valve are two normally closed MOVs INI-332A and INI-333B, which are in parallel. The licensee states that opening these valves during power operations requires INI-334B to be closed to prevent aligning the Refueling Water Storage Tank to the suction of .he Centrifugal Charging pumps. Injecting RWST boron concentrated water in the Reactor Coolant System would induce a transient. Furthermore, the licensee states again that closing INI-334B degrades both trains of Safety Injection.
The McGuire FSAR, Table 6.3.2-3A, " Sequence of Operations: Injection to Cold Irg Recirculation," indicates in Step 12 that INI-332A or INI-333B must be opened to achieve Cold leg Recirculation. Section 3.5.2 of the Technical Specifications requires that two independent Emergency Core Cooling System (ECCS) subsystems shall be operable with each subsystem comprised of one each operable centrifugal charging pump, Safety Injection pump, RIIR heat exchanger, RilR pump and flow path capable of taking suction from the Refueling Water Storage Tank on a Safety Injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation. It appears that only the automatic transfer capability must be available at all times, and not the actual alignment.
Therefore, the licensee should stroke time test valves INI-334B, INI-332A and INI-333B quarterly in accordance with OMa-1988, Part 10,14.2.1.1, or provide additional information in the basis to justify why valve INI-334B cannot be closed for periodic testing. .
56
Table 4.1 (Cont d)
Posed Item Valve Drawing Licensee's Justification No. Identification No. For Deferred Testing Alte7te Testag 1(2)-MC-N19 1(2)NI-183B, 12" motor MC-1562-3.0, Rev. "This valve is closed and power removed Valve will be cycled and timed during operated gate valve, Cat. B, 12, (MC-2562-3.0, above Mode 4 per tech Spec 4.5.2." cold shutdown.
RIIR discharge to Safety Rev. 10) " Flow Injection System hot legs Diagram of Safety isolation valve, normally closed Injection System (NI)"
Evaluation: This valve isolates Residual IIcat Removal flow to the RCS hot legs.
As per Tech Spec 4.5.2, this valve is required to be in the closed position with power removed during Modes 1,2 and 3 operation. Therefore, it is impractical to exercise this valve during power operation.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c).
1(2)-MC-N110 1(2)NI-184B, 1(2)N1-185A, MC-1562-3.1, Rev. " Opening these valves during power operation Val'.e will be cycled and timed during 18" motor operated gate valve, 6, (MC-2562-3.1, would allow water to enter lower containment. cold shutdown.
Cat. B, Containment sump to Rev. 4) " Flow To prevent this, IFW-27A would have to be
, RIIR and containment spray Diagram of Safety closed, rendering both trains of Residual IIcat pump suction isolation valves, Injection System Removal inoperable. Voids in suction piping normally closed (NI)" would be created requiring fill and vent operations to prevent ECCS pump damage."
Evaluation: These valves provide flow paths from the Containment Sump to the Residual IIcat Removal Pump and the Containment Spray Pump suction.
Opening either of these valves during power operation would allow water to enter the lower containment from the Refueling Water Storage Tank through the RilR pumps' common suction line. To prevent this, Refueling Water valve 1(2)FW-27A, which isolates the outlet line of the RWST, would have to be closed, thereby rendering both trains of RIIR inoperable. Closure of 1(2)FW-27A would create voids in the suction piping for all of the ECCS pumps, which are supplied by the RWST. Fill and vent operations would be required to prevent ECCS pump damage. Therefore, it is impractical to exercise 1(2)N1-184B or 1(2)NI-185A during power operation.
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).
57
Table 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Al ae No. Identification No. For Deferred Testing 1(2)-MC-Nill 1(2)NI-332A,1(2)NI-333B,6* MC-1562-3.0, Rev. " Opening these valves during power Valve will be cycled and timed during motor operated gate valves, 12, (MC-2562-3.0, operations requires 1(2)NI-334B to be closed cold shutdown.
Cat. B, RHR recirc. isolation Rev. 10) " Flow to prevent aligning FWST to the suction of valves to Safety Injection Diagram of Safety the Centrifugal Charging Pumps. Injecting System, normally open Injection System FWST boron concentrated water into the (NI)" Reactor Coolant System would induce a transient. Closing 1(2)NI-334B degrades both trains of Safety Injection."
Evaluation: 'Ihese valves provide flow paths to the Centrifugal Charging Pumps and Safety Injection Pumps from Residual Heat Removal Pumps during the recirculation phase following a IDCA.
See Evaluation for 1(2)MC-NI8. The licensee should stroke time test valves 1(2)NI-334B,1(2)NI-332A, and 1(2)NI-333B quarterly in accordance with OMa-1988, Part 10,14.2.1.1, or provide additional information in the basis to justify why valve 1(2)NI-334B cannot be closed for periodic testing.
l(2)-MC-nil 2 1(2)NI-15,1(2)NI-17,1(2)NI- MC-1562-1.0, Rev. " Injection flow through these valves from the Valve will be ful'. stroke exercised at 19, 1(2)NI-21, 1(2)NI-347, 18, (MC-2562-1.0, Centrifugal Charging Pumps during power cold shutdowm.
1(2)NI-348, 1(~2)NI-349, Rev. 15) " Flow operations could result in unnecessary thermal 1(2)NI-354, 1% " check Diagram of Safety shock to the injection nozzles."
valves, Cat. C, Centrifugal Injection System Charging Pumps flowpath to (NI)"
RCS cold legs, normally closed Evaluation: These check valves open to allow flow to the RCS cold legs from the Centrifugal Charging Pumps during the injection and high pressure recirculation phases of a LOCA.
It is impractical to part-stroke or full-stroke exercise these check valves during power operation because flow through these check valves is isolated by normally closed valves MOVs 1(2)NI9A and 1(2) nil 0B to prevent flow from the Charging pumps from entering the RCS cold legs. Injecting flow through these check valves during power operation could result in unnecessary thermal shock to the RCS cold leg injection nozzles.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Pa[t 10,14.3.2.2(c).
58
Ttble 4.1 (Cont'd)
Item Valve Drawing Licensce's Justification Ped Alte m ate No. Identification No, For Deferred Testing Testing 1(2)-MC-Nil 3 1(2)NI-12, 3" check valve, MC-1562-1.0, Rev. " Injecting flow through this valve from the Valve will be full stroke exercised at Cat. C, CCPs to RCS cold legs 18, (MC-2562-1.0, Centrifugal Charging Pumps during power cold shutdown.
Rev. 15 " Flow operations could result in unnecessary thermal Diagram of Safety shock to the injection nozzles."
Injection System (NI)*
Evaluation: This check valve provides a flow path for the Centrifugal Charging Pumps to the RCS cold legs and is open during the injection and high pressure recirculation phases of a IDCA.
It is impractical to part-stroke or full-stroke exercise this check valve during power operation because flow through this valve is isolated by normally closed valves MOVs 1(2)N19A and 1(2)NIiOB to prevent flow irom the Charging pumps from entering the RCS cold legs. Injecting flow through these check valves during power operation could result in unnecessary thermal shock to the RCS cold leg injection nozzles.
The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
1(2)-MC-nil 4 1(2)NI-101, 8" check valve, MC-1562-3.0, Rev. " Valve cannot be full stroke tested during Valve will be full stroke exercised at Cat. C. RWST discharge check 12, (MC-2562-3.0, power operation since the Safety Injection cold shutdown. Valve will be partial valve to Safety Injection Rev. 10) " Flow Pumps cannot overcome Reactor Coolant stroked quarterly.
System pump suction, normally Diagram of Safety System pmssure. Closure cannot be verified closed Injection System quarterly since both trains of Residual Heat (NI)" Removal would be rendered inoperable."
Evaluation: This check valve opens to allow flow from the Refueling Water Storage Tank to the Safety Injection Pumps. The valve closes to provide suction pressure boundary for these pumps from tb Residual Heat Removal Pump discharge.
It is impractical to full-stroke exercise this valve to the closed position during power operation because this valve is immediately downstream of normally open MOV 1(2)N1100B which is on the single supply line from the Refueling Water Storage Tank to the SI pumps, so that closure of 1(2) nil 01 would also isolate both trains of SI pumps (see 1(2)-MC-NI2 for 1(2) nil 00B}. Although the licensee states that closure of this val ~ .ates both trains of RHR, it appears that both trains of SI would be rendered inoperable. It is impractical to full-stroke exercise this valve to the open positma quarterly because the SI pump discharge pressure cannot overcome the RCS pressure. ,
The alternative provides full-stroke exercising to the open and closed positions during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c). The licensee should clearly indicate that the full-stroke exercising during cold shutdowns includes full-stroke exercising to the open position as well.
59
Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification i No. Identification No. For Deferred Testing n
1(2) MC-Nil 5 1(2)NI-il6, 1(2)NI-148, 4" MC-1562-3.0, Rev. " Valve cannot be full or partial stroke tested Valves will be full stroke exercised at check valves, Cat. C, Safety 12. (MC-2562-3.0, during power operation since the Safety cold shutdown. Valves will be verified Injection System pump Rev. 10) " Flow Injection Pumps cannot overcome Reactor closed quarterly.
discharge check valves, Diagram of Safety Coolant System pressure."
normally closed Injection System (NI)"
Evaluation: The normally closed SI Pump discharge check valve opens to allow Safety Injection flow and closes to prevent opposite train flow losses.
It is impractical to full-stroke exercise these valves open quarterly because the SI pumps cannot overcome RCS pressure. A review of the flow diagram indicates that the valves cannot be part-stroke exercised quarterly during the SI pump test because the valves are located downstream of the SI pumps' minimum flow recirculation line return to the RWST.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
1(2)NI-124, 1(2)NI-128, MC-1562-3.0, Rev. " Valve cannot be full or partial stroke tested Valves will be full stroke exercised at 1(2)-MC-nil 6 1(2)NI-156, 1(2)NI-157, 12, (MC-2562-3.0, during power operation since the Safety cold shutdown. leak test in 1(2)NI-159, 1(2)NI-160, 2" Rev. 10) " Flow Injection Pumps cannot overcome Reactor accordance with Tech Spec 4.4.6.2.2.
check valves, Cat. A&C, Diagram of Safety Coolant System pressure."
Safety Injection System hotleg Injection System check valves, normally closed (NI)"
Evaluation: These valves are part of the Reactor Coolant System pressure boundary and open on flow from the Safety Injection Pumps to the RCS hot legs.
These valves are pressure isolation valves for the RCS. It is impractical to full-stroke exercise these valves open quarterly because the SI pumps cannot overcome RCS pressure. The valves cannot be part-stroke exercised quanerly during the SI pump test because the valves are located downstream of the SI pumps' minimum flow recirculation line return to the RWST.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c) and 14.2.2.3. It is impractical to verify closure during operation or cold shutdowns because these valves are located inside containment. Verifying valve closure would necessitate containment entry which could result in radiation exposure to plant personnel and delay plant startup due to test setup and performance. The licensees proposal to perform leak testing during refuelings in accordance with Technical Specification 4.4.6.2.2 is in acco'rdance with OMa-1988 Part 10,14.2.2.3(a) 60 l
i
Table 4.1 (Cont'd)
Valve Drawing . Licensee's Justification Posed Item Alternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-Nil 7 1(2)NI-165, 1(2)NI-167, MC-1562-3.1, Rev. " Valves cannot be full or partial stroke tested Valve will be full stroke exercised at 1(2)NI-169, 1(2)NI-171, 2" 6, (MC-2562-3.1, during power operations since the Safety cold shutdown. Irak test in check valves, Cat. A&C, Rev. 4) " Flow Injection Pumps cannot overcome Reactor accordance with Tech Spec 4.4.6.2.2.
Safety Injection System cold Diagram of Safety Coolant System pressure."
leg injection check valves, Injection System normally closed (NI)"
Evaluation: These valves are part of the Reactor Coolant System pressure boundary and open on flow from the Safety injection Pumps to the RCS cold legs.
These valves are pressure isolation valves for the RCS. It is impractical to full-stroke exercise these valves open quarterly because the Si pumps cannot overcome RCS pressure. The valves cannot be part-stroke exercised quarterly during the SI pump test because the valves are located downstream of the SI pumps' minimum flow recirculation line return to the RWST.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c) ud 14.2.2.3. It is impractical to verify closure during operation or cold shutdowns because these valves are located inside containment. Verifying valve closure would necessitate containment entry which could result in radiation exposure to plant personnel and delay plant startup due to test setup and performance. The licensees proposal to perform leak testing during refuelings in accordance with Technical Specification 4.4.6.2.2 is in accordance with OMa-1988 Part 10,14.2.2.3(a).
l I
61
Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification MI'#"*
No, Identification No, For Deferred Testing Testmg 1(2)-MC-N118 1(2)NI-175, 1(2)NI-176, MC-1562-3.1, Rev. " Valves cannot be full or partial stroke tested Valve will be full stroke exercised at 1(2)NI-180, 1(2)NI-181, 2" 6, (MC-2562-3.1, during power operation since the Residual cold shutdown. Leak test in check valves, Cat. A&C, RIIR Rev. 4) " Flow Heat Removal pumps cannot overcome accordance with Tech Spec 4.4.6.2.2.
discharge to Safety Injection Diagram of Safety Reactor Coolant System pressure."
cold leg check valves, normally Injection System closed (NI)"
Evaluation: These valves are part of the Reactor Coolant System pressure boundary and open on flow from the Residual Heat Removal Pumps to the RCS cold legs.
These valves are pressure isolation valves for the RCS. It is impractical to full-stroke exercise these valves open quarterly because the RHR pumps cannot overcome RCS pressure. The valves cannot be part-stroke exercised quarterly during the RllR pump test because the valves are located downstream of the RHR pumps' minimum flow recirculation line return to the RWST.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c) and 14.2.2.3. It is impractical to verify closure during operation or cold shutdowns because these valves are located inside containment. Verifying valve closure would necessitate containment entry which could result in radiation exposure to plant personnel and delay plant startup due to test setup and performance. The licensees proposal to perform leak testing during refuelings in accordance with Technical Specification 4.4.6.2.2 is in accordance with OMa-1988 Part 10,14.2.2.3(a).
62
Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification Alternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-Nil 9 1(2)NI-125, 1(2)N1-126, MC-1562-3.0, Rev. " Valve cannot be full or partial stroke tested Valve will be full stroke exercised at 1(2)NI-129,1(2)NI-134, 6, 8, 12, (MC-2562-3.0, during power operation since the Residual cold shutdown. Irak test in 12, inch check valves, Cat. Rev. 10) " Flow Ileat Removal pumps cannot overcome accordance with Tech Spec 4.4.6.2.2.
A&C, Safety injection System Diagram of Safety Reactor Coolant System pressure."
low head hot leg check valves, Injection System normally closed (NI)"
Evaluation: These valves open on flow from the Residual Heat Removal Pumps to the RCS hot legs. These valves are part of the Reactor Coolant System pressure boundary.
These valves are pressure isolation valves for the RCS. It is impractical to full-stroke exercise these valves open quarterly because the RHR pumps cannot overcome RCS pressure. He valves cannot be part-stroke exercised quarterly during the RHR pump test because the valves are located downstream of she RllR pumps
- minimum flow recirculation line return to the RWST.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OM.s-1988 Part 10,14.3.2.2(c) and 14.2.2.3. It is impractical to verify closure during operation or cold shutdowns because these valves air located inside containment. Verifying valve closure would necessitate containment entry which could result in radiation esposure to plant personnel and delay plant startup due to test setup and performance. The licensees proposal to perform leak testing during refuelings in accordance with Technical Specification 4.4.6.2.2 is in accordance with OMa-1988 Part 10,14.2.2.3(a).
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Table 4.1 (Cont'd)
Drawing' Posed Item Valve Licensee's Justification ernate No. Identification No. For Deferred Testing Testmg 1(2)-MC-N120 1(2)NI-136B, 8" motor MC-1562-3.0, Rev. " Opening this valve during power operation Valve will be cycled and timed during operated gate valve, Cat. B, 12 (MC-2562-3.0, renders both trains of Residual lleat Removal cold shutdown.
RIIR discharge to Safety Rev. 10)
- Flow inoperable."
Injection Pumps, normally Diagram of Safety closed Injection System (NI)"
Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.9). As shown on flow diagram MC-1562-3.0, Rev.12, (MC-2562-3.0, Rev.10), " Flow Diagram of Safety Injection System (NI)," valve INI-136B is in an 8 in. line leading to the suction header of both Safety injection pumps, which in turn leads to the suction header of the Centrifugal Charging pumps. The licensee states that opening this valve renders both trains of RIIR inoperable.
In LER 369/90-22, Revision 01, the licensee stated that cycling of valves INI-136B and 2NI-136B, RiiR (ND) IIeat Exchanger IB and 2B to Safety Injection (NI) pump IB and 2B, to the open position while at power operation could degrade RIIR system operauon in the event of a Large Break less of Coolant Accident (LBIDCA).
It appears that the licensee's logic was based on assuming a design basis event during the stroke test combined with a worst case single failure. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would render the entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing.
In addition, the 8 in line containing valve 1(2)NI-136B branches off from the outlet of RIIR IIcat Exchanger B upstream of an air-operated valve 1(2)ND14 which could be closed to ensure that flow from RIIR Pump Train A can be provided to all four loops of the Reactor Coolant System. The licensee should stroke time test valve 1(2)NI-136B quarterly in accordance with OMa-1988, Part 10,14.2.1.1, or provide additional information in the basis to justify why opening MOV 1(2)NI-136B would render both trains of RIIR inoperable.
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification ternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-N121 1(2)NI-48, 1" check valve, MC-1562-2.0, Rev. "The system design does not provide a means Valve will be verified closed by leak Cat. A&C, Safety Injection 14, (MC-2562-2.0, of verifying valve closure upon flow test performed in accordance with System containment penetration Rev. 10) " Flow reversal." 10CFR50 Appendix J at refueling isolation check valve, Diagram of Safety outage frequency.
normally closed Injection System (SI)"
Evaluation: This valve provides containment isolation on penetration M-330. It provides the inboard containment isolation for the nitrogen bulk storage line to the SI Accumulators. This valve is located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J at refueling outages. According to the flow diagram, this valve is normally closed since the line is isolated upst: tam and would only have flow when required for supplying nitrogen to the SI Accumulators.
Although the licensee has provided an inadequate basis, it is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Izak testing this valve during cold shutdowns would be burdensome to the licensee due to extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is verified by seat leakage testing in accordance with 10CFR50 Appendix J.
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Ttble 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve ' liermate No. Identification No. For Deferred Testing '
Testmg 1(2)-MC-N122 1(2)NI-59,1(2)NI-70,1(2)NI- MC-1562-2.0, Rev. " Valves cannot be full or partial stroked Valves will be full stroked at refueling 81, 1(2)NI-93, 10" check 14, (MC-2562-2.0, during power operation since the accumulator by disassembly on a sample basis. All valves, Cat. A&C, Safety Rev.10), MC-1562- pressure is ~600 psig and cannot overcome valves will be partial stroked at injection System Accumulator 2.1, Rev.12, (MC- RCS pressure. Valves will not be tested refueling. Partial stroke will not be injection check valves, 2562-2.1, Rev. 8) during cold shutdown since disassembly is performed at cold shutdown since Tech normally closed " Flow Diagram of required. Disassembly would render one train Spec 4.4.6.2.2 requires leak tcing Safety injection of RHR inoperable for an extended period of after initiating flow through these System (SI)" time." valves and does not require leak testing more often than once per nine months.
Valves will be verified closed by leak test performed in accordance with Tech Spec 4.4.6.2.2.
Evaluation: These valves form part of the Reactor Coolant pressure boundary and open on flow from the NI (Safety injection) cold leg accumulator to the Reactor Coolant System. These valves are located inside containment.
These valves are pressure isolation valves for the RCS. It is impractical to part-stroke or full-stroke exercise these valves open quarterly because the SI accumulator pressure cannot overcome RCS pressure. It is also impractical to full or partial-stroke exercise these valves every cold shutdown, as Tech Spec 4.4.6.2.2 requires leak testing after initiating flow through these valves and does not require leak testing more often than once per nine months. As discussed in Draft NUREG-1482 (Ref. I1), Section 4.1.3, the NRC has determined that implementation of an extension of the test frequency for those valves requiring a leak test is acceptable. The licensee's proposed alternative testing is to sample disassemble at least one of these valves and verify part stroke open and verify closure during refueling outages. The licensee has classified this alternative testing and frequency as a deferral when in fact it should be a relief request.
The licensee should convett this deferral into a relief request which meets all of the requirements for sample disassembly under Generic Ietter 89-04, Position 2.
In addition, the licensee should investigate the practicality of using non-intrusive testing techniques in lieu of valve disassembly and inspection.
l I 66
Table 4.1 (Cont'd) posed-Item Valve Drawing Licensee's Justification _
ternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-N123 1(2)NI-436, 1" check valve, MC-1562-2.1, Rev. "The system design does not provide a means Valve will be closed by leak test Cat. A&C, Safety injection 12, (MC-2562-2.1, of verifying valve closure upon flow performed in accordance with Systemcontainment penetration Rev. 8) " Flow reversal." 10CFR50 Appendix J at refueling isolation check valve, normally Diagram of Safety outage frequency.
closed Injection System (SI)"
Evaluation: This valve provides containment isolation and thermal overpressurization protection for penetration M-321. This valve provides one of the flow paths to fill SI Accumulators C & D. This valve is located inside containment.
Although the licensee has provided an inadequate basis, it is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Izak testing this valve during cold shutdowns would be burdensome to the licensee due to extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is verified by seat leakage testing in accordance with 10CFR50 Appendix J.
However, although the licensee has described a safety function in the open position for these valves of providing thermal overpressurization protection for the containment penetration, the deferral does not specify any full-stroke or part-stroke exercise open test for these valves. The licensee should full-stroke exercise these vahes open quarterly, or revise the deferral to provide justification accordingly.
67
Table 4.1 (Cont'd)
Posed Item ' Valve Drawing Licensee's Justification ernate No. Identification No. For Deferred Testing Testmg 1(2)-MC-NI24 1(2)NI-60,1(2)NI-71,1(2)NI- MC-1562-2.0, Rev. " Valves cannot be full or partial stroked Valves will be full stroked at refueling 82, 1(2)N1-94, 10" check 14, (MC-2562-2.0, during power operation since a driving head by disassembly on a sample basis. All valves, Cat. A&C, Safety Rev.10), MC-1562- which can overcome RCS pressure does not valves will be panial stroked at Injection System Accumulator 2.1, Rev.12. (MC- exist. Instrumentation is not present to refueling. Partial stroke will not be outlet check valves, normally 2562-2.1, Rev. 8) measure the flow through the individual performed at cold shutdown since Tech closed " Flow Diagram of valves. Valves will not be tested during cold Spec 4.4.6.2.2 requires leak testing Safety injection shutdown since disassembly is required. after initiating flow through these System (SI)" Disassembly would render one train of RIIR valves and does not require leak testing inoperable for an extended period of time." more often than once per nine months.
Valves will be verified closed by leak test performed in accordance with Tech Spec 4.4.6.2.2.
Evaluation: These valves form part of the Reactor Coolant pressure boundary and open on flow from the N1 (Safety Injection) cold leg accumulator to the Reactor Coolant System. These valves are located inside containment.
These valves are pressure isolation valves for the RCS. It is impractical to part-stroke or full-stroke exercise these valves open quarterly because the Si accumulator pressure cannot overcome RCS pressure. It is also imp sctical to full or partial-stroke exercise these valves every cold shutdown, as Tech Spec 4.4.6.2.2 requires leak testing after initiating flow through these valves and does not require leak testing more often than once per nine months. As discussed in Draft NUREG-1482 (Ref. I1), Section 4.1.3, the NRC has determined that implementation of an extension of the test frequency for those valves requiring a leak test is acceptable. The licensee's proposed alternative testing is to ample disassemble at least one of these valves and verify part stroke open and verify closure during refueling outages. The licensee has classified this alterirtive nsting and frequency as a deferral when in fact it should be a relief request.
The licensee should convert this deferral into a relief request M.:h meet all ci the requirements for sample disassembly under Generic Letter 89-04, Position 2.
In addition, the licensee should investigate the practicality of using non-intrusive testing techniques in lieu of valve disassembly and inspection.
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification .
hopod Alternate -
No. Identification No. For Deferred Testing Testing NUCLEAR SAMPLING SYSTEM (NM) 1(2)-MC-NM i 1(2)NM-420,1(2)NM- M C - 15 7 2 - 1. 0, "The system design does not provide a Valve will be verified closed by leak test 421, 3/4" check Rev.14, (MC-2572- means of verifying valve closure upon flow performed in accordance with 10CFR50 valves, Cat. A&C, 1.0, Rev.15), " Flow reversal." Appendix J at refueling outage frequency.
normally open diagram of Nuclear Sampling System (NM)*
Evaluation: These check valves provide containment isolation and thermal overpressurization protection for penetrations M-235 and M-309 respectively. These valves are located inside containment and the licensee states that the " system design does not provide a means of verifying valve closure upon flow reversal *,
and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is verified by seat leak testing in accordance with 10CFR50 Appendix J.
Ilowever, although the licensee has described a safety function in the open position for these valves of providing thermal overpressurization protection for the containment penetration, the deferral does not specify any full-stroke or part-stroke exercise open test for these valves. The licensee should full-stroke exercise these valves open quarterly, or revise the deferral to provide justification accordingly.
69
Table 4.1 (Cont'd)
Valve Drawing Licensee's Justification Posed Item , ternate No. Identification No. For Deferred Testing Testmg CONTAINMFEI' SPRAY SYSTEM (NS) 1(2)-MC-NSI 1(2)NS-38B, 1(2)NS- M C - 15 6 3 - 1. 0, ' Opening either of these valves during Valve will be cycled and timed during cold 43A, 8* motor Rev.18, (MC-2563- power operation renders both trains on shutdown.
operated gate valves, 1.0, Rev.15), " Flow Residual Heat Removal inoperable.*
Cat. B, RHR heat diagram of exchanger discharge to Containment Spray auxiliary spray header System (NS)*
isolation valves, normally closed Evaluation: Auxiliary Spray Nozzle header isolation. (This deferral was previously evaluated in the October 22,1993 Safety Evaluation Section 4.4). 'Ihe licensee is proposing to forego quarterly testing of these valves. As shown on flow diagram MC-1563-1.0, Rev.18, (MC-2563-1.0, Rev.15)
- Flow Diagram of Contaimnent Spray System (NS)," valves 1(2)NS-38B and 1(2)NS-43A are each on 8 in, lines leading from the outlets of RilR Heat Exchanger Train B and RHR Heat Exchanger Train A, respectively. The licensee states that opening either of these valves during power operation renders both trains of RHR inoperable. Valves 1(2)NS-38B and 1(2)NS-43A were cited in LER 369/90-22, Revision 1, as valves which, if cycled opened during testing, could render both trains of RHR inoperable when combined with a design basis event and a worst case single failure of the opposite train. On this basis, testing of any given train of Emergency Core Cooling System (ECCS) components would render the entire system inoperable when combined with a design basis event and a single failure of the opposite train. Such logic is not acceptable as a basis for foregoing quarterly testing. The licensee should revise this deferral to provide additional information in the basis tojustify why opening either valve 1(2)NS-38B or 1(2)NS-43A renders both trains of RHR inoperable.
70
Table .1.1 (Cont'd)
Proposed Itern Valve Drawing Licensee's Justificatica Alternate No. Identification No, ' For Deferred Testing TMing .
1(2)-MC-NS2 1(2)NS-13,1(2)NS-16, M C - 15 6 3 - 1. 0, " Full stroke exercising of these check Rese valves will be verified to fully cycle by 1(2)NS-30,1(2)NS-33, Rev.18, (MC-2563- valves is not practical since there is no sample disassembly at refueling outage. Relief 1(2)NS-41,1(2)NS-46, 1.0, Rev.15), " Flow external indicatiort of disk movement. Full is being requested on these valves (Relief 8" check valves, Cat. diagram of stroke exercising would require for the Request 1(2)-MC-RR-NSI). When relief is C, primary and Containment Spray pumps and spray nozzles to be activated granted, this Justificadon of Deferral will be auxiliary spray headers System (NS)" which would require a large scale cleanup deleted.
check valves, normally effort. Valves will not be tested during closed cold shutdown since sample disasse nbly is required."
Evaluation: As stated in Section 3.1.1 of this TER, these check valves open upon initiation of flow from containment spray pumps to provide flow to the spray headers. In Relief Request RR-NSI, the licensee indicates that sample disassembly of these check valves has been performed the past four years. The Safety Evaluation of June 21,1993 granted relief in accordance with Generic Letter 89-04, Position 2 for grouping of 4 valves, NS-13, NS-16, NS-30, and NS-33 to the primary header and 2 valves, NS-41 and NS-43 to the auxiliary header, in which one valve in each group is disassembled each refueling outage. He most recent relief request, RR-NSI, seeks to increase the grouping to all 6 valves but disassemble all valves every four refueling outages. This is not in accordance with Generic Letter 89-04, Position 2. Disassembly and inspection in lieu of flow testing is acceptable if all of the provisions of Generic letter 89-04, Position 2, are met. The licensee should disassemble and inspect one valve at each refueling outage. He licensee also should investigate the practicality of using non-intrusive testing techniques.
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Ttble 4.1 (Cont'd)
Posed Item . Valve Drawing Licensee's Justification
- "*I' No. Identification . - No, For Deferred Testing Testmg 1(2)-MC-NS3 1(2)NS-4,1(2)NS-21, M C - 15 6 3 - 1. 0, " Full stroke exercising with flow would Full stroke testing will be achieved by sample 12" check valves, Cat. Rev.18, (MC-2563- require for the pumps and spray nozzles to disassembly. At least one of these valves will C, RWST discharge 1.0, Rev.15), " Flow be activated which would require a large be disassembled during each refueling outage, check valves to diagram of scale cleanup effort. The system design and both valves will have been disassembled containment spray Containment Spray does not provide any indication for and full stroked after two consecutive outages.
pump suction, System (NS)" verifying closure upon flow reversal." Sample disassembly will also verify closure.
normally closed Failure of one valve to properly full stroke during a refueling outage will result in the remaining valve being disassembled and full stroked during that outage. Valves will be partial stroked quatterly.
Evaluation: Open to allow flow from the Refueling Water Storage Tank to the Containment Spray Pump suction. Close to prevent flow from the Cowtainment Recirculation Sump to the Refueling Water Storage Tank during post-LOCA recirculation.
The licensee's proposed alternative test method of sample disassembly for each valve every other refueling outage, including fully stroking the valve, and partial stroking of the valves quarterly is in accordance with Generic letter 89-(M Position 2.
It should be noted that the licensee has classified this alternative testing and frequency as a deferral when it should be a relief request. The licensee should resubmit this deferral as a relief request with the next revision of the program.
72
Tr.ble 4.1 (Cont"d)
Posed Item Valve Drawing Licensee's Justification
- No. Identification No. For Deferred Testing ,,f 1(2)NS-140, 1(2)NS- M C - 15 6 3 - 1. 0, " Full stroke exercising of these check Valves will be verified to full stroke open using 1(2)-MC-NS4 141,10* check valves, Rev.18, (MC-2563- valves is not practical since there i no sample disassembly every other refueling outage Cat A&C, 1.0, Rev.15), " Flow external indication of disk movement. Full on a staggered basis. Valves will be partial Containment Spray diagram of stroke exercising would require for the stroked quanerly. Valves will be leak tested at lischarge check valves Co itainment Spray pumps and spray nozzles to be activated refueling c"tages. Leak testing will also verify to primary spray System (NS)* which would require a large scale cleanup closure of these valves.
header, normally effort. Valves will not be tested during closed cold shutdown since sample disassembly is required.'
Evaluation: These valves open to allow Containment Spray to the spray ring headers and close to prevent column separation of water in the header after initial building spraydown and pump sha6nwn. During this time, the column of water in the vertical piping up to the spray rings could separate, creating a void in the system at sub-atmospheric prewn. Upon pump r start, the collapse of t!2is void would damage the piping system.
The licensee's proposed alternative tm method of sample disassembly for each valve every other refueling outage, including fully stroking the valve, and partial stroking of the valves quarterly 4 i:2 acordance with Generic Letter 89-04, Position 2. In addition the lice zee will be leak testing the valves in accordance with OM-10 each refueling outage.
'Ihe licensee has classified this alternative testing as a deferral when it should be a relief request. The licensee should resubmit this deferral as a relief request with the next revision of the program.
The licensee should note also that these valves are Dot shown on the flow diagrams for either unit. Check valves 83,84,85,86,87,88 are still shown for Unit 1, and check valves 110, Ill,112,113,114,115 are still shown for Unit 2. The licensee should ensure that the flow diagrams are updated to include the NS-140 and 141 valves and verify that the other valves are properly shown as required.
73
Tcble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification M
M ernate No. Identification No. For Deferred Testing Testmg CllEMICAL AND VOLUME CONTROL SYSTEM (NV) 1(2)-MC-NVi 1(2)N V -94 A C, M C - 15 5 4 - 1.1, " Closure of one of these valves during power Valve will be cycled and timed during 1(2)NV-95B, 4" motor Rev.9, (MC-2554- operation would inhibit normal seal water flow cold shutdown.
operated gate valves, 1.1, Rev.5), " Flow across the reactor coolant pump number I seal.
Cat. B, RCP seal diagram of Chemical His action could result in damage to the reactor water return flow & Volume Control coolant pump seals or the pump itself.*
isolation valves, System (NV)"
normally open Evaluation: (his defr:ral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.10). As shown on flow diagram MC-1554-1.1, Rev.
- 9. " Flow Diagram of Chemical & Volume Control System (NV),* valves INV-94A and 95B are in series in a single line conducting the seal water discharge from all four reactor coolant pumps to the seal water filter. These valves provide containment isolation for penetration M-256. The licensee states that " closure of one of these valves during power operation would inhibit normal seal water flow across the reactor coolant pump number 1 seal. His action could result in damage to the reactor coolant pump seals or the pump itself." .
Testing should not be performed if the RCP seals could be damaged, resulting in an unisolatable LOCA. However, the licensee should evaluate the amount of time the valve could be closed before seal damage would occur and provide additional information in the basis to justify why the plant could not achieve a normal shutdown in the event that the valves fail closed during testing.
1(2)-MC-NV2 1(2)NV-7B, 3" motor M C- 15 5 4 - 1. 2, " Failure of this valve in a closed position could Valve will be cycled and timed during operated globe valve, Rev.17, (MC-2554- result in loss of pressurizer level control and result cold shutdown.
Cat. B, normal 1.2, Rev.14), " Flow in unit shutdown."
letdown flow outboard diagram ofChemical i s 01a tio n ya1ye, & Volume Control normally open System (NV)*
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.11). As shown on flow diagram MC-1554-1.2, Rev.
17, (MC-2554-1.2, Rev.14)
- Flow Diagram of Chemical & Volume Control System (NV),* MOV 1(2)NV-7B is in the flow path for the normal CVCS letdown and provides containment isolation for penetration M-347. The licensee states that failure of this valve closed could result in loss of pressurizer level control and result in unit shutd on. The licensee has not provided sufficient information concerning the time available before such consequences would result following failure of the va'e ;; 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 evrat that 1(2)NV-7B failed closed during testing.
74
Trble 4.1 (Cont'd)
Item Valve Drawing . Licensee's Justification 5
Alternate No. Identification No. For Defernd Testing Testmg 1(2)-hibNV3 1(2)NV-21 A, 2* air hi C - 15 5 4 - 1. 2, " Opening this valve during power operations could Valve will be cycled and timed durir>g operated control valve, Rev.17, (h1C-2554- result in a reactor low pressure trip." cold shutdown.
Cat. B. pressurizer 1.2, Rev.14), " Flow auxiliary spray control diagram of Chemical valve, normally closed & Volume Control System (NV)*
Evaluation: 1(2)NV-21 A is an air operated control valve off the regenerative heat exchanger return which is normally closed during operation, it is impractical to pan-stroke or full stroke exercise this valve to the open position quarterly because this would cause a pressure transient in the reactor coolant system from the spray of cold water into the pressurizer, which in turn might cause a plant trip and impose thermal stresses on the pressurizer spray piping.
The alternative provides full stroke exercising to the open position at cold shutdowns in accordance with Ohta-;988 Part 10,14.2.1.2(c).
1(2)-hic-NV4 1(2) N V - 141 A , h1C-1554-2.0, " Closure of one of these valves during power Valve will be cycied and timed during 1(2)NV-142B, 4* Rev.17, (htC-2554- operation would isolate the suction for the cold shutdown.
motor operated gate 2.0, Rev.14), " Flow Centrifugal Charging Pumps. This action could valves, Cat. B, volume diagram ofChemical . result in damage to the pimps. Seal water to the control tank discharge & Volume Control Reactor Coolant pumps would be interrupted isolation valves, System (NV)* causing damage to the seals."
normally open Evaluation: Provides isolation for Charging Pump suction from Volume Control Tank upon receipt of a safety injection signal.
It is impractical to part-stroke or full stroke exercise either of these two valves to the closed position quarterly because this would likely result in damage to the charging pumps and reactor coolant pump seals, and undesirable pressurizer level transients and possible plant trip.
De alternative provides full stroke exercising at cold shutdowns in accordance with Ohta-1988 Part 10,14.2.1.2(c).
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Trble 4.1 (Cent'd)
Item Valve Drawing Licensee's Justification Alternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-NV5 1(2) N V-2 4 4 A, M C- 15 5 4-3. 0, "If one of these valves were to fail in the closed Valve will be cycled and timed during 1(2)NV-245B, 3" Rev.16, 'MC-2554- position while testing during power operation, cold shutdown.
motor operated gate 3.0, Rev.12;. " Flow normal and alternate charging would be lost. This valves Cat. B, normal diagram of Chemical could result in a loss of pressurizer level control charging line isolation & Volume Control and result in unit shutdown?
valves, normally open System (NV)"
Evaluation: (This deferral was previously evaluated in the October 22, 1993 Safety Evaluation, Section 4.12). As shown on flow diagram MC-1554-3.0, Rev.
16, (MC-2554-3.0, Rev.12), " Flow Diagram of Chemical & Volume Control System," 1(2)NV-244A and 1(2)NV-245B are in series in the CVCS charging flow path to the Regenerative IIcat Exchanger. He valves isolate charging flow to the Reactor Coolant System upon a Safety injection signal. The licensee states that if one of these valves were to fail in the closed position during power operation, normal and alternate charging would be lost and that this could result in a loss of pressurizer level control and unit shutdown. He licensee has not provided any information concerning the time available befcre such consequences would result following failure of the valves in the clos-d position. Also, the licensee has not discussed the reduced charging flow available through the Reactor Coolant Pump seal injection lines. He licensee should provide additional information in the basis to justify why the plant could not achieve a normal shutdowm in the event tha 1(2)NV-244A or 1(2)NV-245B failed closed during testing.
1(2)-MC-NV6 1(2) N V -2 21 A , M C- 15 5 4 - 3.1, " Opening these valves during power operation Valve will be cycled and timed during 1(2)NV-222B, 8" Rev.13, (MC-2554- allows the Charging Pumps to inject highly borated cold shutdown.
motor operated gate 3.1, Rev.10), " Flow water into the Reactor Coolant System which could valves, Cat. B, in diagram ofChemical result in a unit shutdown."
parallel lines from & Volume Control RWST to centrifugal System (NV)"
charging pump suction, normally closed
=
Evaluation: These valves open automatically upon receipt of a safety injection signal or low-low volume control tank level signal to allow the centrifugal charging pumps to take suction from the RWST.
Here are no means of isolating these MOV gate valves during normal operation for performing any quarterly testing. Hence cycling either of these valves open during normal operation will inject a high concentration of borated water into the reactor coolant system causing a rapid shutdown.
He alternative provides full stroke exercising to the open position during cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(c). (See deferrals 1(2)-
MC-NV10,1(2)-MC-NVil, and 1(2)-MC-NV15).
76
Tc.ble 4.1 (Cont'd)
Posed Item Valve Drawing Licensee's Justification m ate No. Identification No. For Defermi Testing Testmg 1(2)-MC-NV7 1(2)NV-264, 2* check M C - 15 5 4 - 3 ._1, "To full stroke exercise this valve during power Valve will be full stroke exercised at cold valve, Cat. C, in line Rev.13, (MC-2554- operations would inject more than 30 gpm of boric shutdowm.
frotr mric acid tank to 3.1, Rev.10), " Flow acid into the Reactor Coolant System creating a charging pump diagram of Chemical transient. To verify closure, residual boric acid suction, normally & Volume Control would be injected causing a transient."
closed System (NV)*
Evaluation: This check valve is in the emergency borate loop and is required to open after the emergency borate isolation valve (NV-265B) opens and the boric acid pumps start to provide a flow path from the Boric Acid Tank to the centrifugal charging pump suction. The valve closes to provide pump suction pressure boundary.
It is impractical to full stroke exercise to the open position quarterly because exercising the valve open and closed will create a reactivity decrease and subsequent plant transient to recover.
The alternative provides full stroke exercising to the open and closed positions at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
1(2)-MC-NV8 1 (2) N V - 15 0 B , M C- 15 5 4-2. O , *1f either valve were to fail closed while testing, the Valve will be cycled and timed during 1(2)NV-151 A, 2" Rev.17, (MC-2554 . Charging Pump miniflow protection line is isolated cold shutdown.
motor operated 2.0, Rev.14), " Flow possibly causing damage to the pump."
kerotest(globe) valves, diagram of Chemical Cat. B, miniflow line & Volume Control isolation valves, System (NV)*
normally open Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.13). As shown on flow diagram MC-1554-2.0, Rev.
17, " Flow Diagram of Chemical & Volume Control System (NV)," 1NV-150B and INV-151 A are in series in the common miniflow line from both centrifugal charging pumps to the Volume Control Tank. The valves provide isolation of the miniflow line to the Volume Control Tank. The licensee states that if either valve were to fait closed during testing, the Charging Pump miniflow line is isolated which could possibly damage the pumps. The licensee has not provided any information concerning the time available before such consequences would result following failure of the valves in the closed positirm._ considering that the charging pumps are normally in full flow operation during plant operation. The licensee should provide additional provide additional information in the basis.
77
Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification W
Mentate No. Identification No. For Deferred Testing Testmg 1(2)-MC-NW L H2)NV-26512, 2" h1C-1554-3.1, "If valve is opened during power operations, boric Valve will be cycled and timed during l motor operated globe Rev.13. (MC-2554- acid could be injected into the Reactor Coolant cold shutdown.
valve, Cat. B, isolation 3.1, Rev.10), " Flow System causing a transient."
valve in line from diagram of Chemical boric acid tank to & Volume Control charging pumps, System (NV)"
normally closed Evaluation: Since this valve is the isolation valve for emergency boration, it provides a flow path from the boric acid transfer pumps to the centrifugal charging pumps via check valve NV-264 (see 1(2)-MC-NV7 above).
With the boric acid pumps in operation or with the CVCS in automatic mode it is impractical to full stroke exercise to the open position quarterly because exercising the valve open and closed may cause plant transients.
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).
1 ( 2 )-M C- 1(2)NV-225, 1(2)NV- M C- 15 5 4 -3.1, " Valve cannot be full stroke exercised during power Valve will be full stroke exercised during NV10 231, 4" check valves, Rev.13 (MC-2554- operation since this would require an increase in cold shutdown, partial stroked with Cat. C, centrifugal 3.1, Rev.10), " Flow Reactor Coolant System boron concentration which normal use.
pumps discharge check diagram ofChemical could result in unit shutdown. Normal letdown is valves, normally open & Volume Control not sufficient to verify full stroke, this must be done System (NV)* when aligned to the RWST for suction."
Evaluation: This check valve opens to provide a discharge flow path for the centrifugal charging pump, and closes to prevent opposite train flow losses.
During power operation, the RCS pressure prevents the charging pump from reaching full injection flow conditions, and also suction would have to be drawn from the RWST (via check valve NV-223), which in turn would result in an increase in boron concentration in the RCS and a power transient.
The alternative provides part-stroke exercising open during plant operation and full-stroke exercising to the open and closed positions at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(b).
78
Trble 4.1 (Cont'd)
Druwing Licensee's Justification Posed Item . Valve Mternate No. Identification No. For Deferred Testing Testmg 1( 2 )- M C- 1(2)NV-223, 8" check M C- 15 5 4 - 3.1, " Testing this valve during power operations would Valve wiU be full stroke exercised at cold NV11 valve, Cat. C, in flow Rev.13, (MC-2554- require opening of either 2NV-221 A or 2NV-222B. shutdown.
line from RWST to 3.1, Rev.10),
- Flow Opening these valves during power operation could centrifugal charging diagram ofChemical result in a unit trip. See Justification #MC-NV6."
pumps, normally & Volume Control closed System (NV)"
Evaluation: his check valve opens to provide a flow path from the RWST to the centrifugal charging pumps, and closes upon cessation of pump operation.
The same considerations as for discharge check valves NV-225 and NV-231 are to be considered for this suction check valve. During power operation, the RCS pressure prevents the charging pump from reaching full injection flow conditions, and also suction would have to be drawn from the RWST (via check valve NV-223), which in turn would result in an increase in boron concentration in the RCS and a power transient.
He alternative provides full-stroke exercising to the open and closed positions at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
1 ( 2 )-M C- 1(2)NV-1046, 2* M C- 15 5 4 - 3. 0,
- Testing this valve during power operation would Valve will be full stroke exercised at colo NV12 check valve, Cat. C, Rev.16, (MC-2554- result in the addition of highly borated water into shutdown.
in recirc loop around 3.0, Rev.12), " Flow. the Reactor Coolant System causing a transient.'
positive displacement diagram ofChemical pump, normally closed & Volume Control System (NV)'
Evaluation: Valve 1(2)NV-1046 is part of the recirculation line around the positive displacement pump. This valve closes to provide a pump suction pressure boundary for the centrifugal charging pumps, and opens to protect the positive displacement pump from over-pressurization.
Because suction is being drawn from the Volume Control Tank it is not clear where the source of highly borated water is coming from. It appears that a portion of the loop is in use during the RCS hydrostatic test.
The licensee, however, has not provided sufficient information on the functions of the other valves in the loop to evaluate this deferral request. The licensec should resubmit this deferral with a system description that describes the source and pathway for the highly borated water.
79
Table 4.1 (Cont'd)
Item Valve . Drawing - Licensee's Justification M AII"*I*
No. Identification No.- : For Deferred Testing Testag 1 ( 2)-M C- 1(2)NV-261, 1(2)NV- M C- 15 5 4 -3.1, " Testing these valves requires 2NI-12 A to be Valve will be full stroke exercised at cold NV13 263, l' and 2* check Rev.13 (MC-2554- opened. This valve is closed with power mmoved shutdown.
valves, respectively, 3.1, Rev.10), " Flow above mode 4 per Tech Spec 4.5.2."
Cat. C, for. pressure diagram of Chemical isolation off the & Volume Control f
chemical mixing tank System (NV)*
and reactor makeup water storage tank, normally closed Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.14). As shown on flow diagram MC-1554-3.1, Rev.
13, (MC-2554-3.1, Rev.10), " Flow Diagram of Chemical & Volume Control System (NV)," 1(2)NV-261 and 1(2)NV-263 are check valves which prevent back flow to the Chemical Mixing Tank and the Reactor Makeup Water Storage Tank (RMWST) from the boric acid tank, respectively. The valves close to provide pump suction pressure isolation for the Centrifugal Charging pumps from the Chemical Mixing Tank and the RMWST. The licensee states that
- Testing these valves requires 1(2)NI-121A to be opened. This valve is closed with power removcal above Mode 4 per Tech Spec 4.5.2. Valve 1(2)NI-121 A appears on flow diagram MC-1562-3.0, Rev.12, (MC-2562-3.0, Rev.10) and is an isolation MOV for Reactor Coolant System Imops 2 and 3 Hot legs from the discharge of Safety Injection Pump 1A (2A). It is unclear what opening this valve has to do with testing 1(2)NV-261 or 1(2)NV-263. The licensee should clarify the basis.
t i
80
Tchle 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve Ahernate No. Identification No, For Deferred Testing Testmg 1 ( 2 )- M C - 1(2)NV-1002, 2" M C- 15 5 4 - 1. 3, "The system desiga does not provide a means of Valve will be verified closed by leak test NV14 check valve, Cat. Rev.4, (MC-2554- verifying valve closure upon flow reversal." performed in accordance with 10CFR50 A&C, inside 1.3, Rev.5), " Flow Appendix J at refueling outage frequency.
containment in standby diagram of Chemical makeup line, normally & Volume Control open System (NV)"
Evaluation: Provides containment isolation on penetration M-342. These valves are located inside containment and the hcensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to 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 10 the licensee due to the extensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shvdowns to be deferred to refueling outages. Full-stroke exercising to the closed position is provided by seat leak testing m accordance with 10CFR50 Appendix J.
1 ( 2 )- M C- 1(2)NV-143, 4" check MC-1554-2.0, Rev. "This valve is in the flow path from the Volume Valve will be full stroke exercised at cold NVIS valve, Cat. C. volume 17, (MC-2554-2.0, Control Tank to the Charging pumps. During shutdown.
control tank discharge Rev.14), " Flow normal system operation, this valve is open. To check valve, normally diagramofChemical verify this valve closes properly requires the open & Volume Control alignment from the RHR pumps, and would System (NV)* interrupt normal charging activities."
t l Evaluation: This valve closes to provide Centrift. gal Charging Pump suction pressure boundary during Recirculation alignment from RHR Pump discharge.
During power operation suction would have to be drawn from the RWST, 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 closed position at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c).
i 1
i 81
! Table 4.1 (Cont'd)
Item Valve - Drawing . Ucensee's'Justincation No. Identi5 cation . No. - For Deferred Testing M"*'*/
Testag.
FIRE PROTECTION SYSTEM (RF) 1-MC-RFI 1RF-823,4* check valve, Cat. M C- 15 99-2.2, "The system design does not provide a Valve will be verified closed by leak test A&C, Fire Pratection System Rev. 8 , " Flow means of verifying valve closure ugn performed in accordance with ' 10CFR50 Supply Header check valve, diagram of Fire flow reversal." Appendix J at refueling outage frequency, normally closed ProtectionSystem (RF) Units 1 &
2" Evaluation: This valve provides containment isolation on penetration M-353 for the Unit 1 Fire Protection supply header. His valve is located inside containment and the licensee states that the system design does not provide a means of verifying valve closum upon flow reversal, and the valve will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Leak testing this valve 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 the potential for extending the shutdowm.
De alternative provides full-stroke exercising at refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(e).
a 82
Ts.ble 4.1 (Cont'd) n____a.
l
"*"'~'
l Item Valve - Drawing - Licensee's Justification No. Identificatio, No. - For Deferred Testing -
Testing .
l l 2-MC-RFI 1RF-834,4" check valve, Cat. M C- 15 99-2. 2, "The system design does not provide a Valve will be verified closed by leak test A&C, Fire Protection Rev. 8 " Flow means of verifying valve closure upon performed in accordance with 10CFR50 l System Supply IIcader check diagram of Fire flow reversal." Appendix J at refueling outage frequency.
valve, normally closed ProtectionSystem l
(RF) Units 1 &
i 2" i Evaluation: This valve provides containment isolation on penetration M-353. Although this valve is designated as Unit 1 piping, it is located inside the Unit 2 containment and provides isolation for the Unit 2 Fire Protection supply header. This valve is located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J at refueling outages. ,
Although the licensee has provided an inadequate basis, it is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems. Irak testing this valve 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 the potential for extending the shutdowns.
The alternative provides full-stroke exercising at refueling outages in accordance with OMa-1988 Part 10,14.3.2.2(e).
r e
83
Tr.ble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification M Mernate No. Identification No, For Deferred Testing Testmg NUCLEAR SERVICE WATER SYSTEM (RN) 1 (2 )- M C- 1(2)RN-252B, 6" air operated M C- 15 74-4. 0, *1f one of these valves were to fail Valve will be cycled and stroke timed during RN1 diaphragm valve, Cat. A Rev. 16, (MC- closed during testing, isolation of cold shutdown.
(outboard), 1(2)RN-253A 6" 2574-4.0, Rev. cooling water to the motor coolers could motor operated diaphragm 9), *F1ow result in damage to the pumps."
valve, Cat A (inboard), Nen- Diagram of essential header supply to RCP Nuclear Setvice coolers isolation valves, Water System normally open (RN)*
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.18). As shown on flow diagram MC-1574-4.0, Rev.
16 (MC-2574-4.0, Rev. 9 ) " Flow Diagram of Nuclear Service Water System (RN)," valves 1(2)RN-252B and 1(2)RN-253A are in series in a line providing cooling water from the Nuclear Service Water non-essential header to all four reactor coolant pump motor air coolers. Valves 1(2)RN-276A and 1(2)RN-277B are in series in a line discharging cooling water flow from the same four reactor coolant pump motor air coolers. The former two valves provide containment isolation for penetration M-307, while the latter two valves provide containment isolation for penetration M-315. The licensee states that if one of these valves were to fait closed during testing, isolation of cooling water to the motor coolers could result in damage to the pumps. The licensee has not provided any information concerning the time available before such consequences would result following failure of the valve in the closed position. The licensee should provide additioeal information in the basis tojustify why the plant could not achieve a normal shutdown in the event that any of these valves failed closed during testing.
1(2)-MC- 1(2)RN-276A, 6* motor M C- 1574-4.0, *1f one of these valves were to fall Valve will be cycled and stroke timed during RN2 operated diaphragm valve, Cat. Rev. 16, (MC- closed during testing, isolation of cold shutdown.
A (inboard),1(2)RN-277B, 6* 2574-4.0, Rev. cooling water to the motor coolers could air-operated diaphragm valve, 9), *F1ow result in damage to the pumps."
Cat A(outboard), Non-essential Diagram of header return from RCP Nuclear Service coolers isolation valves, Water System normally open (RN)*
Evaluation: See evaluation for RN1 above.
l i
1 84
Ttble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Alternate No. Identification No. For Deferred Testing Testmg 1 (2 )-M C- 1(2)RN-42A, 10" motor M C- 15 7 4 -4. 0, " Closing this valve during power Valve will be cycled and stroke timed during RN3 operated butterfly valve, Cat. Rev. 16, (MC- operation isolates cooling water flow to cold shutdowm.
B, Non-essential header 2574-4.0, Rev. the Steam Generatcr Blowdown Heat isolation valve, normally open 9), "F1ow Exchanger. Failure in the closed diagram of position could result in damage to the Nuclear Setvice heat exchanger."
Water System (RN)*
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.19). As shown on flow diagram MC-1574-4.0, Rev.
16, (MC-2574-4.0, Rev. 9) " Flow Diagram of Nuclear Service Water System (RN)," 1(2)RN-42A is an MOV which isolates the Nuclear Service Water Train A non-essential header to the Steam Generator Blowdown Heat Exchanger and the Reciprocating Charging Pump oil coolers. Flow diagram MC-1574-1.0, Rev.
21, (MC-2574-4.0, Rev. 9) " Flow Diagram of Nuclear Service Water System (RN)," shows valves 1(2)RN-63B and 1(2)RN-64A to be in series in a line discharging cooling water flow from the Steam Generator Blowdown Heat Exchanger and the Reciprocating Charging Pump oil coolers. The licensee states that closing any of these valves during power operation isolates cooling water flow to the Steam Generator Blowdown Heat Exchanger, and that failure in the closed position could result in damage to the heat exchanger. The licensee has not provided any information concerning the time available before such consequences would result following failure of the valve 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 any of these valves failed closed during testing.
1 ( 2 )- M C- 1(2)RN-63B,1(2)RN-64A,10" M C- 15 74- 1.0, " Closing either of these valves during Valve will be cycled and stroke timed during RN4 motor operated butterfly Rev. 21, (MC- power operation isolates cooling water cold shutdonm.
valves, Cat. B, Non-essential 2574-1.0, Rev. flow to the Steam Generator Blowdown Header Supply isolation valves, 9), *F1ow Heat Exchanger. Failure in the closed normally open diagram of position could result in damage to the Nuclear Service heat exchanger."
Water System (RN)"
Evaluation: See Evaluation for RN3.
85
Tr_ble 4.1 (Cont'd)
Drawing Licensee's Justification Posed Item Valve t e ate No. Identification No. For Deferred Testing Testing 1 ( 2 )-M C- 1(2)RN-214, 4" check valve, M C- 15 74-3.0, " Valves cannot be full stroked at any This valve will be disassembled and full stroked RN5 Cat. C, Nuclear Service Water Rev. 33, (MC- time without putting raw water into the during each refueling outage until it is deleted Supply to Spent fuel Pool 2574-3.0, Rev. Spent Fuel Pool." from the system. The valve will be panial check valve, normally closed 22), "F1ow stroked quarterly.
Diagram of Nuclear Service Water System (RN)"
Evaluation: This valve must open to allow assured makeup supply from the Nuclear Service Water System to the Spent Fuel Pool. The closed function of this valve was tiiminated by modification MGMM-3676 (MGMM-3776). This valve is scheduled to be deleted from the system during 1(2)EOC9 refueling outage.
Until it is deleted, it will be included in the test program and tested as described above. IEOC9 (2EOC9) is scheduled for 19-Aug-94 (17-Nov-94).
The licensee states that this valve is partial stroked open quarterly. There are 1 in. connections upstream and downstream of this valve which it appears are used by the licensee to perform the partial stroke test. From a review of MC-1574-1.0, Rev. 21, (MC-2570-1.0, Rev.11), " Flow Diagram of Spent Fuel Cooling System (KF)", it is correct that this valve cannot be full-stroke exercised without flushing raw service water into the Spent Fuel Pool, which is impractical.
The proposed alternative of partial stroke exercising this valve open quarterly and disassembly and inspectica at each refueling outage until the valve has been removed from the system is in accordance with Generic Irtter 893J4, Position 2.
l l
l l
86
Ttble 4.1 (Cont'd)
Item Valve . Drawing Licensee's Justification ternate No. Identification No. For Deferred Testing Testmg 1(2)-MC- 1(2)RN-891, 1(2)RN-892, 2* M C- 15 74-2.0, "The system does not permit reverse These valves will be tested for closure via sample RN6 check valves, Cat. C, Return Rev. 33, (MC- flow testing as there is not sufficient disassembly at a refueling outage frequency (as line check valve from diesel 2574-2.0, Rev. pressure down stream of these check specified per GL 8941). The open function will generator cooling to Essential 21), "F1ow valves to verify closure. These check be verified with proper Diesel Generator IIcader, normally closed Diagram of valves discharge into the main RN operation as " Valves in Regular Use" and done Nuclear Service (Nuclear Service Water) discharge on a monthly frequency.
Water System header, and piping that large has little (RN)", MC-1574- back pressure."
3.0, Rev. 33 ,
(MC-2574-3.0, Rev. 22), " Flow Diagram of Nuclear Service Water System (RN)*
4 O
I I 87
Trmbla 4.1 (Cont'd)
Posed.
Item Valve Drawing Licensee's Justification No, Identification No. For Deferred Testing Testmg Evaluction: These vazves check flow from the Nuclear Service Water (RN) return line (from the Diesel Generator Cooling Water (KD) heat exchanger to the RN esserdal header) to maintain RN system integrity, during a seismic event. Rese valves open to allow Nuclear Service Water return from the Diesel Generator Stating Air (VG) coolers.
The licensee states that the open function will be verified with proper Diesel Generator operation as " Valves in Regular Use" and done on a monthly frequency.
Ilowever, OM Part 10,14.3.2.3 to which the licensee is referring states that " Check valves which operate in the course of plant operation at a frequency which would satisfy the exercising requirements of this Part need not be additionally tested provided that the observations otherwise required for testing are made and analyzed during such operation and are recorded on the plant records at intervals no greater than specified in para. 4.3.2.1." He licensee should specify whether the flow rate passing through the valve during the monthly diesel generator testing is sufficient to full-stroke or part-stroke exercise these valves.
The licensee stat" Aat the system does not perTnit reverse flow testing as there is not sufficient pressure downstream of these valves to verify closure, since these valves discL- into the main Nuclear Service Water header and piping "that large", i.e. through an 8 in. diameter and on to the 36 in. diameter RN header, "has little Ld pressure." Here are no valves on the 8 in. line which could be used to isolate the 2 in. check valves to perform reverse flow testing to verify closure. It would be necessary to isolate flow on the 36 in. main RN header. Ilowever, the licensee has not explained why testing of the 2 in. check valves could not be performed simultaneously with the quarterly stroke time test of 1(2)RN-197B which would isolate flow on the corresponding portion of the main RN header.
The licensee's proposed alternative testing is to sample disassemble at least one of these two valves (for each unit) to verify closure during refueling outages.
The licensee has classified this alternative testing and frequency as a deferral when in fact it should be a relief request.
Therefore, the licensee should revise this deferral to specify whether the part-stroke or full-stroke exercising of this valve is achieved by the monthly diesel generator testing and to describe the impracticality of verifying closure concurrently with stroke time testing of 1(2)RN-197B and any equivalent test for the "A" main RN header. If sample disassembly is still required to verify closure, the licensee should convert this deferral to a relief request.
Relief would be granted in accordance with GL 89-04, Position 2.
88
Trble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification No. Id.ntification No, For Deferred Testing Testm.g CONTAINMENT VEA'TILATION COOLING WATER SYSTEM (RV) 1(2)-MC- 1(2)RV-32A, 1(?)RV-33B, M C- 1604-3.0, " Failure of one of these valves in the Valve will be cycled and stroke timed during RV1 1(2)RV-76A,1(2)RV-77B,12' Rev. 18, (MC- closed position during testing would cold shutdown.
motor operated butterfly 2604-3.0, Rev. isolate cooling flow to the lower valves, Cat. A, Containment 15 ),
- F1ow Containment Ventilation Units causing Ventilation Cooling Water Diagram of an increase in lower containment supply and return isolation Coatainment temperature which could exceed Tech valves, normally open V e n t i1a tio n Spec limits."
Cooling Water System (RV)*
i Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.20). As shown in flow diagram MC-1604-3.0, Rev.
18, (MC-2604-3.0, Rev.15) " Flow Diagram of Containment Ventilation Cooling Water System (RV)," valves 1(2)RV-32A and 1(2)RV-33B are MOVs which isolate the Containment Ventilation Cooling Water to the Imwer Containment Ventilation Units I A, IB, IC and ID, (2A, 2B, 2C and 2D) and also isolate Penetration M-240 while valves 1(2)RV-76A and 1(2)RV-77B are MOVs which isolate the cooling water flow from the ventilation units, and also isolate Penetration M-279. The licensee states that failure of one of these valves in the closed position during testing would isolate cooling flow to the lower Containment Ventilation Units causing an increase in lower containment temperature which could exceed the Technical Specification limits. The licensee has not provided any information concerning the time available before such consequences would result following failure of the valve 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 any of these valves failed closed during testing.
89
l Ttble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Alternate No. Identification No, For Deferred Testing Testmg MAIN STEAM TO AUXILIARY EQUIPMENT (SA) 1(2)-MC-SAI 1(2)SA-5, 1(2)SA-6, 6" M C- 15 93 - 1. 2, " System configuration and design do not At least one of these two valves will be check valves, Cat. C, steam Rev.13, (M C- provide a suitable means to prove the valve disassembled and full stroked during each generators IB and IC check 2593-1.2, prevents reversal of flow. To test the close refueling outage, and both valves will have valves to turbine driven Rev.11),
- Flow function of this valve on line would risk been disassembled and full stroked after two auxiliary feedwater pump, diagram of Main personnel safety since high energy steam consecutive outages. Sample disassembly will normally closed Steam Supply to would be involved." verify closure. Failure of one valve to Aux. Equipment properly full stroke during a refueling outage System (SA)" will result in the renuining valve being disassembled and full stroked during that outage. Valves will be full stroked open quarterly.
Evaluation: These valves open to allow steam supply to tlx turbine driven Auxiliary Feedwater Pump and close to prevent cross connecting steam generators IB and IC.
Testing the close function of these valves would risk persontel safety due to high steam conditions during operation. The licensee's alternative is a disassembly / inspection plan during refueling outages which is in accordance with Generic Letter 89-04, Position 2. The licensee has classified this alternative testing and frequency as a deferral, when in fact it should be a relief request. y
Teble 4.1 (Cont'd)
Item Valve Drawing . Licensee's Justification ternate No.- : Identification No. For Deferred Testing Testing
'AIN STEAM SYSTEM (SM)
( )-MC-SMi 1(2)SM-1 AB,1(2)SM-3AB, M C- 15 93 - 1. 0, "These valves cannot be fully cycled closed These valves will be partially cycled closed 1(2)SM-5AB,1(2)SM-7AB, Rev.20, M C- during power operation since a unit shutdown while in Modes 1,2 and 3. These valves will 34" air operated globe 1593-1.3, would result." be cycled and timed during cold shutdowm.
valves, Cat. B, Main Steam Rev.20, (MC-Isolation Valves, normally 2593-1.0, Rev.
open 20 MC-2593-1.3, Rev.12),"
Flow diagram of -
Main Steam System (SM)*
Evaluation: These are the Main Steam Isolation Valves.
It is impractical to full-stroke exercise these valves closed quarterly because this would cause a transient and reac*or shutdown.
The alternative provides part-stroke exercising to the closed position in modes 1,2, and 3 and full-stroke cycling to closed position and timing at cold shutdowns in accordance w:th OMa-1988 Part 10,14.2.1.2(b).
l l 91 l
l
T:ible 4.1 (Cont'd) n-__,
Item Valve , . Drawing ' Licensee's Justification "&
For Deferred Testing
[Mtenuate- '
- No. Identification . Noi Testing .
BREATIIING AIR SYSTEM (VB) 1(2)-MC-VB1 1(2)VB-50, 2" check valve, MC-1605-3.1 "The system design does not provide a means Valve will be verified closed by leak test Cat. A&C, breathing air Rev. l l, (MC- of verifying valve closure upon flow performed in accordance with 10CFR50 supply inside containment, 7605-3.1, reversal." Appendix J at refueling outage frequency.
normally closed Rev.7)," Flow diagram of Breathing Air System (VB)"
Evaluation: Provides contamment isolation on penetration M-215. These valves are located inside containment and the licensee states that the system design does not provide a means of verifying valve closure upon flow seversal, ara the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
l_cak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising tiiat is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Alternate No. Identification No. For Deferred Testing Testmg DIESEL GENERATOR STARTING AIR SYSTEh! (VG) 1(2)-h1C-VG1 1(2)VG-17, 1(2)VG-18, h1C-1609-4.0, " Valve will be full stroke exercised with the A separate relief requested has been submitted 1(2)VG-19,1(2)VG-20, 3/4" Rev.18, (htC- diesel generator start on a single bank of for these valves. This relief request was check valves, Cat. C , in 2609-4.0, Rev.0), control air and performed at refueling outage submitted on August 24, 1993 as Docket No.
lines to air banks, normally " Flow diagram of frequency." 50-370. Relief Request 92-01.
closed Diesel Generator Starting Air System (VG)"
Evaluation: (This deferral was previously evaluated in the October 22,1993 Safety Evaluation, Section 4.21). As shown on flow diagram hic-1609-4.0, Rev.
18 (hfC-2609-4.0, Rev. 0) " Flow Diagram of Diesel Generator Starting Air System (VG)," valve 1(2)VG-17 is a 3/4 in check valve which prevents back flow to Starting Air Tank 1(2)Al, valve 1(2)VG-18 to Tank 1(2)A2, valve 1(2)VG-19 to Tank 1(2)B1, and valve 1(2)VG-20 to Tank 1(2)B2. When open, valves 1(2)VG-17 and 1(2)VG-18 provide a flow path for control air to Volume Tank 1 A (2A) and valves 1(2)VG-19 and 1(2)VG-20 to Volume Tank IB (2B). The licensee states that " Testing these valves requires the Diesel Generator to be started on a single bank of control air which is considered a degraded condition. This is not justified for quarterly starts." The licensee has not pointed to any violation of the Technical Specifications nor to any impracticality in performing the tests.
Testing the diesel generators with one bank of control air isolated is the only method available to assure that the valves perform their safety function. In fact, in a letter dated hiarch 28, 1992, the Arizona Public Service Company submitted to the NRC Special Report 3-SR-92-001 for Palo Verde Nuclear Generating Station Unit 3, Docket No. 50-530, which described the failure of a check valve in the diesel generator starting air system that was detected by isolating and depressurizing one bank of starting air for test purposes. After 15 seconds from the start signal, the diesel generator tripped on low lube oil pressure and never attained rated voltage and frequency. A 3/8 in. check valve in the opposite bank pneumatic controls was fouled with oil believed to be carryover from the starting air compressor and restricted flow in the forward direction, causing other components to perform unsatisfactorily. Based on the safety significance of these valves, the licensee should test the valves quarterly or provide further information.
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's JustiIication ternate No. Identification No, For Deferred Testing Testing INSTRUMENT AI!! SYSTEM (VI) 1(2)-MC-VII 1(2)VI-368, 1(2)VI-372, M C- 1605 - 1. 3, "All four valves are tested with PORV stroke Valve will be full stroke exercised at cold 1(2)VI-373,1(2)VI-374, 2* Re v . 9, (MC- timing. PORV's are tested on a cold shutdown.
check valves, Cat. C, 2605-1.3, Rev.7), shutdown frequency. Refer to Justification nitrogen supply lines check " Flow Diagram 1(2)-MC2-NC1."
valves to PORVs, normally ofInstrument Air closed System (VI)"
Evaluation: VI-368 and VI-373 must open to allow nitrogen to the PORV actuator. VI-372 and VI-374 must close to prevent loss of Nitrogen pressure if instrument air is lost.
Generic Ixtter 90-06 states, " Stroke testing of the PORVs should not be performed during power operation, due to the risk associated with challenging these valves in this condition." That statement is also applicable to the backup nitrogen supply to the instrument air supply. It is impractical to exercise these valves to the open and closed positions respectively because the primary supply must be defeated, and the PORVs would have to then be exercised open and timed and fail safe tested while the Unit was at power.
The alternative provides for testing the these backup uitrogen supply valves in conjunction with the PORVs at cold shutdowns in accordance with OMa-1988 Part 10,14.3.2.2(c). The licensee should ensure that the full-stroke exercising includes verification of both full-stroke open and fdl-stroke close capability of these valves.
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Table 4.1 (Cont d)
Item Valve Drawing Licensee's Justification Alternate No. Identification No.- For Deferred Testing Testtog 1(2)-MC-VI2 1(2)VI-124,1(2)VI-149, 2" M C- 1605 - 1. 2, "The system design does not provide a means Valve will be verified closed by leak test check valves, Cat. A&C, Rev.7C, (MC- of verifying valve closure upon flow performed in accordance with 10CFR50 inside containment supply 2605-1.2, reversal." Appendix J at refueling outage frequency.
check valves, normally open Rev.14), " Flow diagram of Instrument Air System (VI)"
Evaluation: These valves are located inside containment and provide containment isolation on penetrations M-317 and M-386 respectively. These valves are lccated inside containment and the licensee states the system does not provide a means of verifying closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or hing cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
Leak testing this valve during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require substantial manheurs and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
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Table 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Posed ernate No. Identification No. For Deferred Testing Testmg -
1(2)-MC-VI3 1(2)VI-40, 1(2)VI-161, 2" M C- 1605 - 1. 3, *The system design does not provide a means Valve will be verified closed by lead test check valves, Cat. A&C, Rev.9, (M C- of verifying valve closure upon flow performance in accordance with 10CFR50 inside containment isolation 2605-1.3, Rev.7), reversal." Appendix J at refueling outage frequency.
valves, normally open " Flow diagram of Instrument Air System (VI)*
Evaluation: Provides containment isolation on penetrations M-220 and M-359 respectively. These valves are located inside containment and the licensce states the system does not provide a means of verifying closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
Lea % testing this valve during cold shutdowns would be bmdensome to the licensee due to the ertensive test setup, which would require substantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
Table 4.1 (Cont'd)
Posed Item Valve Drawing Licensec's Justification Alternate No. Identification No, For Deferred Testing Testmg STATION AIR SYSTEM (VS) 1(2)-MC-VS1 1(2)VS-13, 2" check valve, MC-1605-2.2, "The system design does not provide a means Valve will be verified closed by leak test Cat. A&C, station air to Rev.5, (M C- of verifying valve closure upon flow performed in accordance with 10CFR50 various supplies isolation 2605-2.2, Rev.2), reversal." Appendix J at refueling outage frequency.
check valve, normally open " Flow diagram of Station Air System (NS)"
Evaluation: These valves are located inside containment and provides containment isolation on penetration M-219, and the licensee states the system does not provide a means of verifying closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is irnpractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
leak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
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Tsble 4.1 (Cont'd)
Item Valve Drawing ' Licensee's Justification Mternate No. Identification No. For Deferred Testing Testmg CONTAINMENT AIR RETURN & IIYDROGEN SKIMMER SYSTEM (VX) 1(2)-MC-VXI 1(2)VX-30, 2" check valve, M C- 15 5 7- 1, "The system design does not provide a means Valve will be verified closed by leak test inside containment, Cat. Rev.22, (MC- of verifying valve closure upon flow performed in accordance with 10CFR50 A&C, normally closed 2557-1, Rev.17), reversal." Appendix J at refueling outage frequency.
" Flow diagram of Containment Air Return Exchange
& IIydrogen Skimmer System (VX)*
Evaluation: Provides containment isolation on penetration M-325. 'Ihese valves are located inside containment and the licensee states the system does not provide a means of verifying closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
leak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
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Ttble 4.1 (Cont'd)
Item Valve Drawing Licensee's Justification Mernate No. Identification No. For Deferred Testing Testmg LIQUID WASTE RECYCLE SYSTEh! OVL) 1(2)-MC-WL1 1(2)WL-24, 1/2" check M C- 15 65 - 1.1, 'The system design does not provide a means Valve will be verified closed by leak test valve, Cat. A&C, inside Rev.12, (h1C- of verifying valve closure upon flow performed in accordance with 10CFR50 containment check valve off 2565-1.1, Rev.8), reversal." Appendix J at refueling outage frequency.
reactor coolant drain tank, " Flow diagram of normally closed Liquid Waste Recycle System OVL)*
Evaluation: Provides containment isolation and thermal over pressurization protection of line between WI-1B and WI 2A on penetration hi-375. These valves are located inside containment and the licensee states the system does not provide a means of verifying closure upon flow reversal, and the valves wSt be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee has provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
Leak testing this valve 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 the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
Tchla 4.1 (Cont'd)
Drawing Posed Item Valve - Licensee's Justification Mternate No. Identification No. For Deferred Testing Testmg 1(2)-MC-WL2 1(2)Wie385, 1" check M C- 15 65-7. 0, "The system design does not provide a means Valve will be verified closed by leak test valve, Cat. A&C,inside Rev.19, (MC- of verifying valve closure upon flow performed in accordance with 10CFR50 containment off ventilation 2565-7.0, reversal." Appendix J at refueling outage frequency.
unit drain tank, normally Rev.17), " Flow closed diagram of Liquid Waste Recycle System (WL)"
Evaluation: Provides containment isolation and thermal over pressurization protection of line between Wie322B and WI 321 A on penetration M-221. These valves are located inside containment and the licensee states the system does not provide a means of verifying closure upon flow reversal, and the valves will be verified closed by leak testing under Appendix J at refueling outages.
Although the licensee las provided an inadequate basis, it is impractical to test these valves quarterly or during cold shutdows because the valves and test connections are located inside c, .tainment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
Irak testing this valve 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 the potential for extending the shutdowm.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is ac eptable for using leak testing in accordance with 10CFR50 Appendix J.
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l Trble 4.1 (Cont'd) I 1
Posed Item Valve Drawing Licensee's Justification .
No. Identification No. For Deferred Testing Testing '
MAKEUP DEMINERALIZED WATER SYSTEM (YM) 1(2)-MC-YM1 1(2)YM-116, 2* check M C- 1601 -2. 4, The system design does not provide a mear.s Valve will be verified closed by leak test valve, Cat. A&C, makeup Rev.16, (MC- of verifying valve closure upon flow performed in accordance with 10CFR50 )
water check valve inside 2601-2.4, reversal. Appendix J at refueling outage frequency. j containment, rarmally open Rev.17), " Flow diagram of Makeup Demineralized Water System (YM)*
Evaluation: This valve is located inside containment an<1 provides containment isolation on penetration M-337, and the licensee stes the system design does not provide a means of verifying valve closure upon flow reversal, and the valve will be verified closed by leak testing under Appendix J at refueling outages.
Althcugh the licensee has provided an insdequate basis, it is impractical to test these valves quarterly or during cold shutdowns because the valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
leak testing this valve during cold shutdowns would be burdensome to the licensee due to the extensive test setup, which would require rubstantial manhours and radiation exposure to test personnel, and the potential for extending the shutdowns.
OMa-1988 Part 10,14.3.2.2(e) allows full-stroke exercising that is not practical during operation or cold shutdowns to be deferred to refueling outages. This deferral is acceptable for using leak testing in accordance with 10CFR50 Appendix J.
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5.0 IST PROGRAM RECOMMENDED ACTION ITEMS Inconsistencies, omissions, and required licensee actions identified during the review of the licensee's Inservice Testing Program, Revision 20 and 15 (Unit 1 and 2, respectively) of the second ten-year interval, are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report.
5.1 The IST Program does not include a description of: (a) how the components were selected, (b) how testing requirements were identified for each component, and, (c) the safety function of the valves. Additionally, the IST program tables do not specify the position indication verification required by the Code. The program should be revised to provide this information.
The review performed for this technical evaluation report (TER) did not include verification that all pumps ar.d valves within the scope of 10 CFR 50.55a and Section XI are contained in the IST Program, and did not ensure that all applicable testing requirements have been identified. The results of a limited review of six systems is given in 5.13 below. The program should describe the development process, such as a listing of the documents used, the method of the basis for -
categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59.
5.2 In pump Relief Request 1.3.1 the limnsee wants to continue to use the present vibration measurement instrumentation which cannot meet the iS% instrument accuracy because of instrumentation uncertainties in the calibration process. It is recommended that interim relief be granted in accordance with $50.55a 1(a)(3)(ii) for one year or until the next refueling outage, whichever is longer. In the interim period, the licensee should investigate the availability of vibration instruments which satisfy the Code accuracy requirements, or the availability of other calibration laboratories as previously recommended in the October 12,1993 SE (Ref.12), which the licensee has not addressed to date. (TER Section 2.1.1) 5.3 In pump Relief Request 1.4.2 the licensee neglected to specifically request relief from Part 6 14.6.5 for measuring the EDG fuel oil transfer pump flow rate by measuring the level rise in the Fuel Oil Day Tank. Based upon this alternative providing an acceptable level of quality and safety for measuring flow rate it is recommended that it be authorized pursuant to $50.55a T(a)(3)(i). The licensee, however, did not provide sufficient technical information on why the fuel oil transfer pumps should have a wider acceptance range tium that given in 16.1 Table 3b for internal gear positive displacement pumps. In addition the licensee did not demonstrate any hardship or impracticality in measuring the fuel oil transfer pumps discharge pressure. (TER Section 2.3.1) 5.4 In pump Relief Requests 1.4.4,1.4.5, and 1.4.6, for the Residual Heat Removal, Safety Injection, and Centrifugal Charging pumps the licensee appears to be requesting the option of alternative testing using reference values or pump curves depending on plant refueling conditions, maintenance performed, and quantity of data required in lieu of performing the test at specified reference values. As discussed in Draft NUREG-1482 (Ref.11), Section 5.2, the use of pump curves is acceptable if the licensee clearly demonstrates the impracticality of establishing a fixed set of reference values. The licensee should revise the request the request to discuss this impracticality and ensure that the IST program includes the seven elements discussed in Section 5.2. Additionally, without specific information on the test instrument range and accuracy, rdief from the Code's range 102
requirements is not recommended. The licensee should revise the request and provide this information as requested in the previous SE. (TER Sections 2.5.1, 2.6.1, 2.7.1) 5.5 In pump relief request 1.4.7 for the Nuclect Service Water pumps the licensee requested relief from measuring vibrational frequencies as low as 6.58 Hz because the vibration instrumentation currently in-place cannot be calibrated to that low a frequency. It is pointed out to the licensee that the Catawba Nuclear Station was granted relief when the licensee agreed to modify the CSI model 2110 vibration instrument with analog integration circuits and other upgrades to lessen instrument susceptibility to field problems with low frequency measurements. If the licensee commits to using similar instruments at McGuire Nuclear Station as it did at Catawba Nuclear Station, then this alternative would provide an acceptable level of quality and safety. The licensee would still need to revise the relief request to discuss the accuracy and repeatability of the instruments. Additionally the licensee should evaluate whether the pumps are stisceptible to degradation mechanisms which result in increased frequencies less than 10 Hz. and provide this information in the relief request. (TER Section 2.8.1) 5.6 In valve relief request RR-NSI the licensee proposes to regroup the 6 containment spray. check valves to the primary and auxiliary spray headers as one group of 6 and disassemble / inspect all the values every 4 refueling outages (which currently amounts to 6 years) inst. ad of disassembling / inspecting the 4 check valves to the pnmary header on a staggered basis over the 4 refueling outages and the 2 check valves to the auxiliary header every other refueling outage because of extreme hardship. The primary intent of disassembling and inspecting one valve each outage is to provide some degree of assurance that the valve has not degraded and will perform as required. The liceusee's proposal to perform no inspections for a six year period does not provide similar assurance. Proper operation of these check valves is essential in ensuring the proper operation of the containment spray system in order to mitigate the consequences of an accident. The difficulties described by the licensee do not meet the examples of extreme hardship as provided by the NRC.
The licensee should evaluate the burden of inspecting the valves versus the benefit from performing the inspections. Without an evaluation of the effect upon plant safety, industry experience, and a more detailed explanation of the burden, authorization of the licensee's alternate inspection schedule cannot be recommended. Numerous other PWR licensees perform inspections of contamment spray valves in accordance with GL 89-04. The licensee should continue to perform inspections in accordance with GL 89-04 Position 2. (TER Section 3.1.1) 5.7 in valve relief request RR-VG1 the licensee is seeking relief from stroke time exercising the control air solenoid valves to the diesel generators because of limitations on available acoustic equipment and a forthcoming modification that will remove these valves from IST requirements. The NRC previously approved this request on an interim basis until the modification was installed at the EOC8 outage. The modification was not installed and the licensee was asked to provide further explanation of the burden for not installing acoustic equipment in the previous Safety Evaluation (Ref.12). In its letter to the Staff of February 24,1994, the licensee went into more detail as to {
why the diesel start test should be an acceptable alternative but did not discuss any further the burden imposed by utilizing acoustic equipment. However, given the limited length of tinie that relief is required, and the level of safety afforded by the monthly diesel test, interim relief is recommended until EOC-9. If the licensee does not delete these valves from the program in EOC-9, and relief is still required, the licensee must provide a means for detecting valve degradation (e.g., trending diesel start times) and resubmie this relief request. (TER Section 3.3.1) 103 I
5.8 Ten of the ninety-five justification of deferrals for valves identify disassembly / inspection at refueling outages as the alternative testing. These deferrals should be resubmitted as valve relief requests under Position 2 of GL 89-04. Specifically, the following deferrals are involved:
1(2FMC-CA2 1(2FMC-NS2 1(2FMC-RN5 1(2FMC-CA3 1(2FMC-NS3 1(2FMC-RN6 1(2)-MC-N122 1(2FMC-NS4 1(2FMC-SA1 1(2FMC-N124 Deferral 1(2)-MC-RN6 is an open item pending submittal of additional information.
5.9 Twenty-six of the ninety-five justification of deferrals that were previously reviewed and documented in the October 12,1993 safety evaluation report requested additional information from the licensee. No additional information has been received to date and the status of those deferrals remain the same. The deferrals needing further information are :
1(2)-MC-CF4 1(2)-MC-NI20 1(2)-MC-NV8 .
1(2)-MC-KC1 1(2FMC-ND2 1(2)-MC-NV13 1(2FMC-KC2 1(2)-MC-ND3 '(2FMC-RN1 1(2)-MC-KC3 1(2)-MC-ND4 1(2)-MC-RN2 1(2FMC-KC4 1(2)-MC-ND5 1(2)-MC-RN3 1(2FMC-N13 1(2)-MC-NSI 1(2)-MC-RN4 1(2FMC-N16 1(2)-MC-NV1 1(2FMC-RV1 1(2)-MC-N18 1(2)-MC-NV2 1(2)-MC-VG1 1(2)-MC-Nill 1(2)-MC-NV5 5.10 Additional information is also requested for the following deferrals:
1(2)-MC-CFl: Containment isolation testing is not addressed.
1(2)-MC-CF3: Contaimnent isolation testing is not addressed.
1(2)-MC-KCS: Open testing is not discussed.
1(2)-MC-KC7: Open testing is not discussed.
1(2FMC-KC9: Open testing is ti.% discussed.
1(2)-MC-NC3: Open testing is not discussed.
1(2)-MC-NI23: Open testing is not discussed.
1(2)-MC-NMI: Open testing is not discussed.
1(2FMC-FW2: Clarify partial opening during quarterly RHR pump testing.
1(2)-MC-NV12: Because suction during normal operation is coming from the Volume Control Tank it is not clear where the source of highly borated water is coming from. This deferral needs clarification.
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l 5.11 Alternative is acceptable but an inadequate technical basis was presented for the following deferrals: .
l 1(2)-MC-KC5 1-MC-RF1 1(2)-MC-KC6 2-MC-RF1 1(2)-MC-KC7 1(2)-MC-VB1 !
1(2)-MC-KC7 1(2)-MC-VI2 l 1(2)-MC-KC8 1(2)-MC-VI3 !
1(2)-MC-NB1 1(2)-MC-VS1 1(2)-MC-NC3 1(2)-MC-VXI 1(2)-MC-NFl 1(2)-MC-WL1 ;
1(2)-MC-NI23 1(2)-MC-WL2 1(2)-MC-NMI 1(2)-MC-YM1 ;
1(2)-MC-NV14 5.12 The IST Program's scope was reviewed for six systems: (1) Chemical and Volume Control
[NV), (2) Refueling Water [PV), (3) Residual Heat Removal [ND], (4) Safety injection [NI], (5)
Containment Spray [NS], (6) Nuclear Service Water [RN]. References used in the review included the FSAR, PRA, and the respective flow diagrams. ;
- Chemical and Volume Control System (NV):
(1) On a safety injection signal the seal water return isolation valves close. The thermal over-pressurization check valve 1(2)NV% surrounding the inboard MOV isolation valve 1(2)NV94A,C, shown on flow diagrams MC-1554-1.1 and MC-2554-1.1, should close and isolate penetration M256. Hence, check valve 1(2)NV96 should be added to the program as a Cat A&C check valve.
(2) Pressure Relief Valve,1(2)NV220, off the reciprocating charging pump discharge, and ,
shown in flow diagrams, MC-1554-3.0 and MC-2554-3.0, should be in the program (Ref.13, page 9.3-28).
- Safety Injection System (NI): The Cold Leg Accumulators (CLAs) discharge isolation valves, 10 inch MOVs: 1(2)NI54A,1(2)N165B,1(2)N176A, and 1(2)N188B, shown in flow diagrams MC-1562-2.0, MC-1562-2.1, MC-2562-2.0, and MC-2562-2.1, which may be used to isolate the Accumulators from the rest of the system, should be in the program for position indication verification only.
- Residual Heat Removal System (ND): Air operated valves 1(2)ND14 and 1(2)ND29 fail open upon loss of instrument air. A stroke time test quarterly is shown in the valve table. A fail safe test should be added to the valve table.
- Nuclear Service Water System (RN): In general all AOVs in this system requiring support from the Instrument Air (VI) System fail to a safe position upon loss of instrument air. The corresponding safe positions for these valves should be identified and added to the valve table.
- No findings were found for the Refueling Water System and Containment Spray System. i 105 I
From this sampling the licensee should review its program to ensure that all safety-related valves, fail-safe testing, and position indication verification requirements are adequately identified in the valve table.
5.13 in Draft NUREG-1482 (Ref.11), page 3-19, an example is given for a refueling outage justification for the high head and intermediate head safety injection flow path check valves. For comparative purposes the applicable check valves for McGuire Nuclear Station are given in deferrals 1 (2)-M C-N V 10, 1 (2)-M C-NV i 1, 1 (2)-M C-NV 15, 1 (2)-M C-nil 2, 1 (2)-M C-NI 13, 1 (2)-MC-nil 4, 1(2)-MC-N115,1(2)-MC-16, and 1(2)-MC-nil 7. The licensee has requested deferrals to cold shutdowns for these check valves. Full flow testing at cold shutdown may require alignment to the RWST (FWST). If this is necessary it is recommended that the licensee evaluate the practical difficulties of dealing with substantial increases in boron concentration frora the RWST and the potential for over- pressurization when in cold shutdowns relative ta refueling outages (with the RV head removed). The licensee upon further review and evaluation of the burden in dealing with higher boron concentrations and/or over-pressurization during cold shutdowns may wish to consider a deferral request under OMa-1988 Part 10,14.3.2.2(e).
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6.0 REFERENCES
- 1. " Inservice Testing Plan (IST), Second Interval Plans for Units 1 and 2, Relief Request 94 01",
T.C. McMeekin, Duke Power, to USNRC, January 6,1994.
- 2. Title 10 Code of Federal Regulations, Section 55a, Codes and Standards.
- 3. NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1", Revision 9 April 1992.
- 4. ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection.
- 5. ASME/ ANSI OMa-1988, Part 6 " Inservice Testing of Pumps in Light-Water Reactor Power Plants".
- 6. ASME/ ANSI OMa-1988, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants" .
- 7. Standard Review Fian, NUREG-0800, Section 3.9.6, Inservice Testing of Pumps and Valves, Rev. 2, July 1992.
- 8. NRC Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs",
April 3,1989.
- 9. Minutes of the Public Meetings on Generic Letter 89-04, October 25,1989.
- 10. Supplement to the Minutes of the Public Meetings on Generic Letter 89-04, September 26, 1991.
- 11. Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants", P. Campbell, November 1993.
- 12. NRC Safety Evaluation, McGuire Nuclear Station Unit 1, IST Program Plan, October 12, 1993.
13.1988 Final Safety Analysis Report (FSAR) updated for McGuire Nuclear Station, June 22, 1989.
- 14. " Inservice Testing Plan (IST), Second Interval Plans for Unit 1, Response to NRC Safety Evaluation (SE), Relief Request 92 04", T. C. McMeekin, Duke Power, to USNRC, dated Febmary 24,1994.
- 15. Technical Evaluation Report, Zion Nuclear Generating Station IST Program, March 16, 1994.
- 16. NUREG/CP-0111, " Proceedings of the Symposium on Inservice Testing of Pumps and Valves, held August 1-3 1989, Washington, D.C.
107
l l
- 17. " Safety Evaluation (SE) of the Inservice Testing (IST) Program for a General Pump Relief Request, Catawba Nuclear Station, Units 1 and 2", James A. Norberg, NRC, to Robert E.~ )'
Martin, NRC, dated January 16, 1992.
- 18. McGuire Nuclear Station Probabilistic Risk Assessment 3 volumes, August 30,1991.
- 19. NRC Generic Letter 91-18 "Information to Licensee's Re;;arding Two NRC Inspection Manual Sections on Resolution of Degraded and Non-conforming Conditions on Operability," November 7, 1991.
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108
Appendix A: McGuire Nuclear Station Units 1 and 2 Flow Diagrams Flow diagrami Dwg.No. : System - Revision MC-1554-1.0 Chemical & Volume Control 14 i l
MC-1554-1.1 Chemical & Volume Control 9 :
1 MC-1554-1.2 Chemical & Volume Control 17 MC-1554-1.3 Chemical & Volume Control 4 j MC-1554-2.0 Chemical & Volume Control 17 MC-1554-3,0 Chemical & Volume Control 16 MC-1554-3.1 Chemical & Volume Control 13 ,
MC-1554-5.0 Chemical & Volume Control 15 ,
1 MC-1554-5.0 Chemical & Volume Control 15 MC-1554-5.0 Chemical & Volume Control 13B MC-2554-1.0 Chemical & Volume Control 8 MC-2554-1.1 Chemical & Volume Control 5 MC-2554-1.2 Chemicta & Volune Control 14 MC-2554 1.8 Chemical & Volume Control 5 MC-2554-2.0 Chemical & Volume Control 14 i
MC-2554-3.0 Chemical & Volume Control 12 MC-2554-3.1 Chemical & Volume Control 10 MC-2554-5.0 Chemical & Volume Control 7 ,
MC-1553-2.0 Reactor Coolant System 19 MC-15553-2.1 Reactor Coolant System 0 MC-1553-4.0 Reactor Coolant System 10 MC-1556-1.1 Boron Recycle System 14 MC-1556-3.0 Boron Recycle System 15 MC-1557-1 Containment Air Return Ex. 22 MC-1558-4.0 Ice Condenser Refrigeration 14 l MC-1561-1.0 Residual Heat Removal 19 l l
I A-1 !
l l
Appendix A: (Cont'd)
Flow diagram Dwg. No. . System . : Revision-MC-1562-1.0 Safety injection 18 MC-1562-2.0 Safety injection 14 MC-1562-2.1 Safety injection 12 MC-1562-3.0 Safety Injection 12 MC-1562-3.1 Safety Injection 6 MC-1563-1.0 Containment Spray 18 l MC-1564-1 Annulus Ventilation 26 MC-1565-1.0 Liquid Waste Recycle 20 MC-1565-1.1 Liquid Waste Recycle 12 MC-1565-7.0 Liquid Waste Recycle 19 MC-1567-2.0 Waste Gas 10 MC-1567-2.1 Waste Gas 8 MC-1568-1.0 Equipment Decontammation 10 MC-1570-1.0 Spent Fuel Cooling 13B MC-1570-1.0 Spent Fuel Cooling 13 MC-1571-1.0 Refueling Water System 16 MC-1572-1.0 Nuclear Sampling 14 MC-1572-1.1 Nuclear Sampling 4 MC-1572-3.0 Nuclear Sampling 14 MC-1573 1.0 Component Cooling 24 MC-1573-1.1 Component Cooling 14 MC-1573-2.0 Component Cooling 11 MC-1573-2.1 Component Cooling 4 MC-1573-2.2 Component Cooling 6 MC-1573-3.0 Component Cooling 10 MC-1573-3.1 Component Cooling 7 MC-1573-1.0 Component Cooling 10 A-2
Appendix A: (Cont'd)
Flow ' diagram
. Dwg. No. ' System Revision '
MC-1574-1.0 Nuclear Service Water 21 MC-1574-1.1 Nuclear Service Water 17 MC-1574-2.0 Nuclear Service Water 33 MC-1574-2.1 Nuclear Service Water 16 MC-1574-3.0 Nuclear Service Water 33 MC-1574-3.1 Nuclear Service Water 14 MC-1574-4.0 Nuclear Service Water 16 MC-1576-1 Containment Purge Ventilation 18 MC-15781.0 Control Area Ventilation 27 MC-1580-1.0 Steam Generator Blowdown Recycle 20 MC-1585-1.0 Containment Air Release & Addition 0 MC-1591-1.1 Feedwater 14 MC-1592-1.0 Auxiliary Feedwater 19 MC-15292-: .1 Auxiliary Feedwater 14 MC-1593-1.0 Main Steam System 20 MC-15393-1.2 Main Steam Supply to Aux. 13 Equipment MC-1593-1.3 Main Steam 11 MC-1599-2.2 Station Air 8 MC-1631-2.4 Makeup Demineralized Water 16 MC-1601-2.4 Makeup Demineralized Water llB MC-1604-3.0 Containment Ventilation Cooling 18 MC-1605-1.2 Instrument Air System 14 MC-1605-1.2 Instrument Air System 7 MC-1605-1.3 Instrument Air System 09 MC-1605 1.13 Instntment Air System 04 MC-1605-1.14 Instrument Air System 03 A-3
l Appendix A: (Cont'd)
Flow diagram Dwg.' No. - System Revision MC-1605-1.17 Instrument Air System 02 MC-1605-2.2 Station Air System 5 MC-1605-3.1 Breathing Air System 11 MC-1609-1.0 Diesel Generator Engine Cooling 18 Water MC-1609-1.0 Diesel Generator Engine Cooling 15A Water MC-1609-1.1 Diesel Generator Engine Cooling 11
~
MC-1609-1.1 Diesel Generator Engine Cooling 9A MC-1609-2.0 Diesel Generator Engine Lube Oil 15 MC-1609-2.0 Diesel Generator Engine Lube Oil 14A MC-1609-2.1 Diesel Generator Engine Lube Oil 11 MC-1609-2.1 Diesel Generator Engine Lube Oil 8A MC-1609-3.0 Diesel Generator Engine Lube Oil 21 MC-1609-3.0 Diesel Generator Engine Lube Oil 16A MC-16G9-3.1 Diesel Generator Engine IB Fuel Oil 12 MC-1609-3.1 Diesel Generator Engine IB Fuel Oil 7A MC-1609-4.0 Diesel Generator Starting Air ll A MC-1609-4.0 Diesel Generator Starting Air 18 MC-1609-7.0 Diesel Generator Room Sump Pump 10 MC-1609-7.0 Diesel Generator Room Sump Pump 10F MC-1618-1 Control Area Chilled Water 27 MC-1618-2 Control Area Chilled Water 11 MC-1618-4 Control Area Chilled Water 8 MC-1499-VG3 D.G. Pneumatic / Hydraulic Control 6 MC-1499-M17 Radiation Monitor 8 MCIC-1499-IA.01-01 Upper /IAwer Personnel Air IAcks 0 ;
MCID-1499-IA.01-01 Upper / Lower Personnel Air Locks 0 A-4 I
Appendix A: (Cont'd) 1 Flow diagram Dwg. No. . System . Revision MC-1499-NS.08 Containment Pressure Narrow Range 5 MC-1574-1.0 Nuclear Service Water 21 MC-1601-2.4 Makeup Demineralized Water 17 MCID-2499-VG.03 D.G. Pneumatic! Hydraulic Control 0 MCID-2499-VG.03.01 D.G. Pneumatic / Hydraulic Control 0 MCID-2499-NS.08 Containment Pressure Narrow Range 1 MC-2499-M17 Radiation Monitor 2E MF38 11 MCID-2499-IA.01-02 Upper / lower Personnel Air IAcks 0 Inflatable Seals Control Air MCID-2499-IA.0!-01 Upper / Lower Personnel Air Locks 0 Inflatable Seals Control Air MC-2553-2.0 Reactor Coolant 5 MC-2556-3.0 Boron Recycle 10 MC-2557-1 Containment Air Return Exchange 19 MC-2558-4.0 Ice Condenser Refrigeration 9 MCFD-2561-01.00 Residual Heat Removal 0 MC-2562-1.0 Safety Injection 15 MC-2562-2.0 Safety Injection 10 i MC-2562-2.1 Safety Injection 8 MC-2562-3.0 Safety Injection 10 MC-2562 3.0 Safety Injection 4 MC-2563-1.0 Containment Spray 16 MC-2564-1 Annular Ventilation System 20 MC-2565-1.0 Liquid Waste Recycle 19 l MC 2565-1.1 Liquid Waste Recycle 8 MC-2565-7.0 Liquid Waste Recycle 13 MC-2570-1.0 Spent Fuel Cooling 11 ;
1 MC-2571-1.0 Refueling Water 10 l
A-5 i i
l
Appendix At (Cont'd)
Flow diagram .
Dwg. No. . System . Revision -
MC-2572-1.0 Nuclear Sampling 13 MC-2572-1.1 Nuclear Sampling 4 MC-2572-1.1 Nuclear Sampling 4 MC-2572-3.0 Nuclear Sampling 13 MC-2573-1.0 Component Cooling 14 MC-2573-1.1 Component Cooling 5 MC-2573-2.0 Component Cooling 8 MC-2573-2.1 Component Cooling 3 MC-2573-3.0 Component Cooling 7 MC-2573-3.1 Component Cooling 5 MC-2573-4.0 Component Cooling 6 MC-2574-1.1 Nuclear Service Water 13 MC-2574-2.0 Nuclear Service Water 21 MC-2574-2.1 Nuclear Service Water 13 MC-2574-3.0 Nuclear S:rvice Water 22 MC-2574-3.1 Nuclear Service Water 13 MC-2574-4.0 Nuclear Service Water 9 MC-2576-1 Containment Purge 'lentilation 12 MC-2580-1.0 Steam Generator Blowdown Recycle 16 MC-2585-1.0 Containment Air Release and 6 Addition MCFD-2591-01.01 Feedwater 0 MCFD-2592-01.01 Auxiliary Feedwater 1 MC-2593-1.0 Main Steam 20 MC-2593-1.2 Main Steam 11 MC-2593-1.3 Main Steam 12 MC-2604-3.0 Containment Ventilation Cooling 15 Water A-6
)
I Appendix A: (Cont'd)
Flow diagram Dwg.No. System Revision MC-2650-1.13 Instrument Air System 01 MC-2605-1.2 Instrument Air System 14 l Instrument Air System 7 MC-2605-1.3 MC-2605-2.2 Station Air 2 j MC-2605 3.1 Breathing Air 7 f MCFD-2609-01.00 Diesel Generator Engine 0 MCFD-2609-01.01 Diesel Generator Engine O MCFD-2609-02.00 Diesel Generator Engine 0 MCFD-2609-02.01 Diesel Generator Engine O MCFD-2609-03.00 Diesel Generator Engine O MCFD-2609-03.01 Diesel Generator Engine O Diesel Generator Engine C MCFD-2609-04.00 MCFD-2609-07.00 Diesel Generator Engine O MCFD-2592-01.00 Auxiliary Feedwater 0 MCID-2499-IA.01-01 Upper / Lower Personnel Air Locks 0 Inflatable Seals Control Air l
l A-7 l t