ML20079A020
| ML20079A020 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/31/1990 |
| From: | Hartley R EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20079A025 | List: |
| References | |
| CON-FIN-A-6812 EGG-NTA-7967, EGG-NTA-7967-01, EGG-NTA-7967-1, GL-89-04, GL-89-4, NUDOCS 9008160066 | |
| Download: ML20079A020 (79) | |
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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGPAM HOPE CREEK GENERATING STATION Docket No. 50-354 R. S. Hartley Published August 1990 l Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission
. Washington, D.C. 20555 !
Under DOE Contract No. DE-AC07-761001570 FIN No. A6812 .
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l ABSTRACT f This EG&G Idaho, Inc., report presents the results of our evaluation of the Hope Creek Generating Station, Inservice Testing Program for j safety related pumps and valves. i PREFACE This report is supplied as part of the ' Review of Pump and Valve !
Inservice Testing Programs for Operating Reactors (!!!)" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., Regulatory and Technical Assistance Unit.
FIN No. A6812 B&R 920 19 05-02 0 Docket No. 50-354 TAC No. 65730 11
CONTENTS ABSTRACT .............................................................. ii PREFACE ............................................................... 11
- 1. INTRODUCTION ..................................................... 1
- 2. SCOPE ............................................................ 3
- 3. PUMP TESTING PROGRAM .......................'...................... 7 3.1 Mul t i pl e Sy s t ems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.1 Relief Request .................._................... 7 3.2 Standby liquid Control ..................................... 9 3.2.1 Relief Request ..................................... 9 3.3 Diesel fuel Oil Transfer ................................... 11 3.3.1 Relief Request ..................................... 11 3.4 High Pressure Coolant Injection ............................ 12 3.4.1 Relief Request ..................................... 12 3.4.2 Relief Request ..................................... 13 3.5 Reactor Core Isol ation Cooling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 3.5.1 Relief Request ..................................... 14 3.5.2 Relief Request ..................................... 16 3.6 Service Water .............................................. 17 3.6.1 Relief Request ..................................... 17
- 4. VALVE TESTING PROGRAM ............................................ 19 4.1 Mu l t i pl e Sy s t ems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 4.1.1 Cold Shutdown Testing .............................. 19 4.1.2 Power Operated Valve Corrective Action ............. 20 4.1.3 Containment I sol ation Valves . . . . . . . . . . . . . . . . . . . . . . . 22 ;
4.1.4 Exce s s Fl ow Check Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 '
4.1.5 Speci al L e a k Te s t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 4.1.6 Rapid Acting Valves ................................. 34 4.1.7 Modified Check Valve Testing ....................... 36 1,
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4.2 feedwater System ........................................... 39 4.2.1 Category A/C Valves ................................ 39 I i
4.3 Main Steam ................................................. 40 !
4.3.1 Category A Valves .................................. 40.
4.3.2 C a t ego ry A/C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 -
4.3.3 C a t ego ry B/C V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 4.3.4 Category C Valves .................................. 44 ,
4.4 Emergency Diesel Generator ................................. 46 4.4.1 Category B Valves .................................. 46 f 4.5 Standby liquid Control ..................................... 48 4.5.1 Category A/C Valves ................................ 48 4.6 Control Rod Drive .......................................... 50 4.6.1 C a t ego ry B V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 4.6.2 Category C Valves .................................. 52 4.7 Neutron Monitoring ......................................... 54 ,
4.7.1 Category A/C Valves ................................ 54 ,
4.8 Safety Auxiliaries Cooling ................................. 55 4.8.1 Category C Valves .................................. 55 4.9 Reactor Recirculation ...................................... 57 .
4.9.1 C a t ego ry A/ C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '57 APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS ....................... A-1 APPENDIX B- P&ID LISTING .............................................. B1 APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW ............ C-1 1
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i TECHNICAL EVALUATION REPORT :
PUMP AND VALVE INSERVICE TESTING PRNRAM f HOPE CREEK GENERATING STATION
- 1. INTRODUCTION
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i Contained herein is a technical evaluation of the pump and valve l inservice testing (IST) program submitted by the Public Service Electric and Gas Company (PSE&G) for its Hope Creek Generating Station. ,
By a letter dated September 21, 1987, PSE&G submitted Revision 1 of the IST program for Hope Creek Generating Station for their first 10 year interval, which commenced on December 20, 1986. A working meeting with NRC, EG&G Idaho, PSE&G, and Hope Creek representatives was conducted on June 29 and 30, 1988. The licensee's revised program, Revision 2 dated December 23, 1988, which supersedes all previous submittals, was reviewed to ,
verify compliance of proposed tests of Class 1, 2, and 3 safety related pumps and valves with the requirements of the ASME Boiler and Pressure ;
Vessel Code (the Code),Section XI,1983 Edition, through Summer of 1983 I Addenda. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER). Program changes involving additional or revised relief requests should be submitted to NRC under separate' cover in order to receive prompt attention, but should not be implemented prior to review and approval by NRC. Other IST program revisions should follow the guidance of Generic Letter No. 89 04, ' Guidance on Developing Acceptable Inservice Testing Programs.'
In their submittal PSE&G has requested relief from the ASME Code !
testing requirements for specific pumps and valves and these requests have been evaluated individually against the requirements of 10 CFR 50.55a. This review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/ Impact Statement titled ' Identification of Valves for Inclusion in Inservice Testing Programs". These IST Program testing requirements apply only to 1
component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requirements.
Section 2 of this report presents the scope of the review.
Section 3 of this report presents the PSE&G bases for requesting relief from the Section XI requirements for the Hope Creek Generating Station pump testing program and EG&G's evaluations and conclusions regarding these requests. Similar information is presented in Section 4 for the valve testing program.
Category A, B, and C valves which are exercised during cold shutdowns and refueling outages and meet the requirements of the ASME Code,Section XI, are discussed in Appendix A.
A listing of P& ids used for this review is contained in Appendix B.
Inconsistencies and omissions in the licensee's program noted during the course of this review are listed in Appendix C. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
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- 2. SCOPE , :
The EG&G Idaho review of the Hope Creek Generating Station inservice testing (IST) program for pumps and valves was begun in March of 1988. The initial program examined was Revision 1, dated September 21, 1987, which identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix 8.
The licensee's proposed IST program was reviewed by locating and highlighting the components on the appropriate system P& ids and determining ,
their function in the system. Then the licensee's proposed testing was evaluated to' determine if it was in compliance with the ASME Code,Section XI, requirements. During the course of this review, questions and comments were made relative to unclear or potential problem areas in the ,
licensee's IST program. These were transmitted to the licensee in the form of a request for additional information (RAI) which served as the agenda for the working meeting between the licensee, the NRC, and the EG&G reviewers.
Each pump and valve relief request was individually evaluated to determine if the licensee had demonstrated that (1)theCoderequirements are ' impractical for the identified system components, (2) the proposed i alternate testing provides an acceptable level of safety and quality, or (3) compliance would result in hardship or unusual difficulties without a compensating increase in the level of safety. Where the licensee's technical basis or alternate testing was insufficient or unclear, the licensee was requested to clarify the relief request. The system P&lD was also examined to determine whether the instrumentation necessary to make the identified measurements is available. If, based on the unavailability of adequate instrumentation' or the reviewers experience and system knowledge, it was determined that it may not be possible or practical to make the measurements identified in the licensee's'IST program, a question or comment was generated requesting clarification, l
l For pumps, it was verified that each of the seven inservice test quantities of Table IWP 3100 1 were indicated to be measured or observed. -
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For those test quantities that were not being measured or observed quarterly l
in accordance with-the Code, it was verified that a request for relief from the Code requirements had been submitted. If testing is not being performed I in accordance with the Code and a relief request had not been submitted, the l licensee was requested to explain the inconsistency in the RAI. ;
The review of the proposed testing of valves verified that all ,
appropriate ASME Code testing for each individual valve is identified to be performed as required. The proposed testing was evaluated to determined if all valves that were judged to be active Category A, B, and/or C, (other .
than safety and relief valves) are exercised quarterly in accordance with IW'V-3410 or -3520. If any active safety related valve is not full stroke i exercised quarterly as required, then the licensee's justification for the deviation, either in the form of a cold shutdown' justification or a relief request, was examined to determine its accuracy and adequacy. The proposed ,
alternate testing was also evaluated to determine if all testing is being performed that can reasonably be performed on each valve to bring its testing as close to compliance with the Code requirements as practical.
For valves with remote position indication, the reviewer confirmed that the valve remote position indication is identified to be verified in accordance with IWV 3300. The reviewer verified that the licensee had assigned limiting values of full stroke times for all power operated valves in the IST program,'as required by IWV 3413. For valves having a fail-safe actuator, the reviewer confirmed that the valve's fail-safe actuator is identified to be tested in accordance with IWV-3415.
l Each check valve was evaluated to determine if the proposed testing would verify its ability to perform its safety function (s). Extensive i system knowledge and experience with other similar facilities is employed to I determine whether 'the proposed tests would full-stroke the check valve disks l open or verify their reverse flow closure capability. If there was any doubt about the adequacy of the identified testing, questions were included in the RAI.
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Further evaluation was performed on all valves in the program to ,
determine that the i'entified testing could practically and safely be ;
conducted as described. If the licensee's ability to perform the testing ;
was in doubt, a question was formulated to alert the licensee to the suspected problem.
Safety related safety valves and relief valves, excluding those that perform only a thermal relief function, were confirmed to be included in the IST program and tested in accordance with IWV-3510. Safety-related explosively actuated valves were verified to be included in the IST program and tested in accordance with IWV 3610.
Once all the components in the licensee's IST program had been ]
identified on the P&lDs and evaluated as described above, the P&lDs were examined closely by at least two trained and experienced reviewers to I identify any additional pumps or valves that may perform a safety function which were not included in the licensee's program. The licensee was asked to reconcile any components that were identified by this process which were not included in the IST program. Also, the list of system', included in the l licensee's program was compared to'a system list in the traft Regulatory Guide and Value/ impact Statement titled, " Identification of Valves for inclusion in Inservice Testing Programs". Systems that tppear in the Draft Regulatory Guide list but not in the licensee's program wtre evaluated and, if appropriate, questions were added to the RAI.
Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions were included in the RAI to clarify those areas of doubt. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this TER.
At the completion of the review, the RAI was transmitted to the licensee. These questions were later used as the agenda for the working l- meeting with the licensee on June 29 and 30,1988. At the meeting, each l ,
question and comment was discussed in detail and resolved as follows: ,
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- a. The licensee agreed to make the necessary IST program corrections or changes to. satisfy the concerns of the NRC and their reviewers,
- b. The licensee provided additional information or clarification -
about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change is required. -
- c. The item remained open for the licensee to investigate further and propose a solution to the NRC.
- d. The item remained open for further investigation by the NRC.
- e. The item remained open for further investigation and discussion by both the NRC and the licensee.
The licensee responded to the RAI and the working meeting discussions in their program resubmittal, Revision 2, dated December 23, 1988. The program changes were identified and evaluated to determine whether they were acceptable and, if not, whether they contributed to the items that remained open from the meeting.
This TER is based on information contained in the submittals, and'on information obtained during the working meeting and conference calls which took place during the review process.
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- 3. PUMP TESTING PROGRAM :
The Hope Creek IST program submitted by Public Service Electric and Gas :
Company (PSE1G) was examined to verify that all pumps that are included in l the program are subjected to the periodic tests required by the ASME Code, !
Section XI, 1983 Edition through the Summer 1983 Addenda, the NRC ;
regulations, positions, and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief from testing has been ,
requested, these pumps are tested to the Code requirements, the NRC regulations, positions, and guidelines. Each PSE&G basis for requesting i relief from the pump testing requirements and the reviewer's evaluation of that request are summarized below and grouped according to system.
3.1 Multiple Systems 3.1.1 Relief Reauest <
The licensee has requested relief from the Section XI, Paragraphs IWP 4110 and -4120, requirements for instrument accuracy and full-scale range. The licensee has proposed to use these two requirements in unison, such that if any given instrument exceeds one of the two requirements, the other requirement will proportionally offset it in the opposing direction.
3.1.1.1 Licensee's Basis for Reouestina Relief. Control room and field instrumentation is available that could be used for Inservice' Testing, <
but the range would be exceeded. In most cases, this instrumentation will -
, be the same instrumentation relied upon by the operators during accident
! conditions. For example, one such instrument has a range of 3.15 times the reference value with an accuracy of .96% (less than half of the Code requirements). Likewise, control room and field instrumentation is available that could be used for Inservice Testing, but the accuracy would be exceeded. In most cases, this instrumentation will be the same
! instrumentation relied upon by the operators during accident conditions.
For example, the range of one of the instruments is 1.07 times the reference value but with an accuracy of +3.41% and -2.22% (at 5600 GPM).
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Each control room or field instrument that has a full scale range above the Code limitations, has had a proportionate increase in the instrument accuracy such that the incremental tolerance is equivalent or more !
conservative than the Code requirements. Similarly, each control room or ,
field instrument that has an instrument accuracy above the Code limitations, is coupled with a full-scale range proportionally less than the three time -
reference value such that the incremental tolerance is equivalent or more i conservative than the Code requirements. The use of this permanent control room or field instrumentation is beneficial in that it strengthens operator knowledge of correct system response during accident conditions which will improve operator response in the event of ac6ual use during an accident.
1 Use of permanent plant instrumentation for inservice pump testing also satisfies the requirements of subsubarticle IWP-4160, and eliminates the potential for errors introduced by mispositioned portable instrumentation The station calibration program will be utilized to maintain the instrument accuracy in accordance with the requirements of subsubarticle IWP 4140.
Alternate Testina: Use of control room or fleid instrumentation with full scale ranges greater than three times the reference value may be used provided the accuracy is at least proportionally increased. (i.e. If the range were doubled, the accuracy limit must be halved.)
Use of control room instrumentation with accuracy greater than 2% may be used provided the range limit is at least proportionally decreased.
(i.e. If the accuracy is doubled, the range limit must be halved.)
3.1.1.2 Evaluation.Section XI specifies instrument full-scale ranges and accuracies. These in turn help to ensure the quality of instrument readings taken for IST. The licensee has stated that some instruments used for (nservice testing do not meet one or the other of these specifications, however, the combination of the two will be equal to or more conservative than the Code requires. Although the licensee's proposed alternative is not equivalent to the Code requirements the resulting accuracy should provide adequate assurance of component operational readiness until the licensee submits additional information and the staff completes its review. Without i
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specific information on the affected pumps and the ranges and accuracies of .
the instraments being used the staff cannot complete its review.
Based on the determination that the licensee's proposal should provide )
adequate interim assurance of operationel readiness and considering the burden if the Code requirements were imposed relief may be granted for six months until this relief request review is completed. l 1
3.2 Standby Liouid Control 3.2.1 Relief Reauest The licensee has requested relief from the test frequency requirements of Section XI, Paragraph IWP 3400, for the standby liquid control (SLC) pumps, 1 BH AP-208 and 1 BH BP-208, and proposed to test these pumps during '
cold shutdowns or refueling outages.
3.2.1.1 Licensee's Basis For Reauestina Relief. The Technical Specifications Bases for the SLC system states that the minimum system parameters (82.4 GPM,13.6% concentration and natural boron equivalent) will ensure an equivalent injection capability that exceeds the ATWS Rule requirement. The stated minimum allowable pumping rate of 82.4 gallons per minute is met through the simultaneous operation of both pumps. (B3/41-5) .
The UFSAR Section 15.8.3.5 states that the SLC system is initiated automatically by RRCS (Redundant Reactivity Control System) logic when needed. It also states that simultaneous operation of two pumps at full '
capa' 'v allows adequate margin to bring the reactor to a subcritical sto - When the system is tested for surveillance, the adjustment of the systems manual valves are required as well as flushing the system to remove the boron solution. The surveillance tests place each loop of the system out of service for approximately nine hours. The flushing is required because, by design, parts of the system are not insulated, which would i result in the crystallization of the boron solution. The duration of the !
test is also a result of the system design, which does not include pressure 0
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, pulse suppression chambers. The lack of the chambers requires the test to )
I be conducted on a' fill and bleed basis to determine the achievement of the required flow rate. This type of testing is time consuming in setup,
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operation, and establishment.of normal system lineup. ,
During the test, the system cannot fulfill the statements rendered in ,
the Technical Specification and the UFSAR. In addition, the pump is unavailable since the system does not automatically realign in the event of .
1 an initiation signal. - '
1 Additionally, a Probabilistic Risk Assessment (PRA) was performed on I the SLC system and has shown that performing the pump inservice testing quarterly at power rather than at cold shutdowns and refuelings (twice per ;
cycle), results in a 73% increase in the SLC system unavailability. This j PRA is attached for review. Relief is therefore requested from this requirement.
i Alternate Testino: Test during cold shutdowns or refueling outages but not more often than every three months.
3.2.1.2 Evaluation. These pumps are in subsystems of the SLC system and function to inject chemical poison into the reactor vessel to shut ~down the reactor following an-anticipated transient without scram (ATWS). Hope r Creek Station Technical Specifications allow one SLC subsystem to be out of ,
service for 7 days prior to requiring the plant to be placed in hot
. shutdown. This implies that the unavailability from quarterly SLC pump a testing does not have a significant impact on overall plant safety.
The NRC is authorized by law to grant relief from the Code requirements when the licensee demonstrates either that their proposed alternatives would provide an acceptable level of quality and safety 10 CFR 50.55a(a)(3)(1),
that compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety (a)(3)(ii), or that
.the Code requirements are impractical (g)(6)(i). The proposed alternative, to extend the test interval of these pumps from quarterly to during cold-shutdowns or refueling outages, has not been shown to provide an acceptable -
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level'of quality and safety.- Although the licensee has provided information -
on the hardship that results from SLC pump testing the licensee has not '
demonstrated that there is not a compensating increase in safety. And lastly, whereas it may be inconvenient to test these pumps at the Code required frequency, due to system design and construction, it has not been shown to be impractical. Therefore, relief should not be' granted from the Code requirements.
3.3 Diesel Fuel Oil Transfer 3.3.1 Relief Reauest 'i The licensee has requested relief from the Section XI, Table IWP 3100-1, requirements to observe and record proper lubricant level or pressure for the diesel fuel oil transfer pumps listed below and proposed to' check and inspect the bearings during corrective maintenance activities, i
1-JE AP-401 1-JE-EP-401 1-JE-BP 401 1-JE-FP-401 1-JE CP-401 1-JE-GP-401 1-JE-DP-401 1-JE-HP-401 3.3.1.1 Licensee's Basis For Reauestina Relief. These pumps are equipped with pumped fluid lubricated graphite bearings. As such, the design of these pumps does not provide the means to observe either of these indicators in order to determine the lubricant adequacy on a 3 month frequency. . Relief is therefore requested from this Code requirement.
-j Alternate Testina: These intermittent duty pumps will have the bearings h checked and inspected during corrective maintenance activities.
3.3.1.2 Evaluation. Due to the design of these diesel fuel oil transfer pumps, it is impractical to observe or measure the lubricant level i or pressure quarterly. The licensee's proposal to inspect these pump bearings during corrective maintenance activities gives adequate assurance l
of operational readiness and provides a reasonable alternative to the Code- 1 requirements. To enable measurement or observation of pump lubricant level or' pressure would require significant system redesign and modification which would be expensive and burdensome to the licensee.
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Based on the determination that compliance with the Code requirements j
- is impracticable and considering.the licensee's proposed testing and the l burden on tht licensee if the Code requirements are imposed, relief should be granted as requested.
3.4 Hiah Pressure Coolant Iniection 3.4.1 Relief Reauest The licensee has requested relief from the Section XI, Paragraph i IWP 3500(b), requirements to run each pump until the bearing temperature stabilizes for the high pressure coolant injection and booster pumps,-
1 BJ-0P-204 and -217, and proposed no alternative.
3.4.1.1 Licensee's Basis For Reauestina Relief. This pump is a steam I turbine driven pump that exhaust into the suppression chamber. Running these pumps increases the temperature in the suppression chamber to the j maximum allowable of 105 degrees = F. (per T.S. 3.6.2.1.a.2.a) prior to l'
satisfying the Code minimum time for bearing temperature stabilization.
Running both available RHR pumps in the torus cooling mode in addition to running the torus water cleanup system cannot keep the suppression chamber ,
temperature below the limit for the required bearing temperature test duration.
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Alternate'Testina: None .
i 3.4.1.2 Evaluation. The steam exhausting out of the turbine which drives these pumps goes into the suppression chamber. Running these pumps causes the temperature to rise in the suppression chamber because of the hot steam entering the water. The cooling systems available to cool the suppression chamber water cannot maintain the temperature below Technical Specification requirements when these pumps are being run for long durations such as those required to stabilize bearing temperatures, therefore,_ this requirement is impracticable. In addition, industry experience has shown I L that bearing temperature measurements can be influenced by many factors .
l unrelated to bearing degradation such as, ambient temperature, fluid I L
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i-temperature, etc. Running'these pumps for an extended time (to stabilize '
y bearing temperatures) imposes a hardship on the licensee while not contributing, significantly.to the evaluation of pump operational readiness and plant safety'. The licensee's proposed testing should give adequate ;
assurance of operational readiness and provides a reasonable alternative to_ ,
-the Code requirements.
-Based on the determination that compliance with the Code requirements is impractical and considering the licensee's proposed testing and the burden on the licensee if these Code requirements are imposed, relief should be granted from the Code requirement to run these pumps until bearing temperatures stabilize,-as requested.
3.4.2 Relief Reauesi s
The licensee has requested relief from the Section XI, Table i
IWP-4110-1, required instrument accuracy (i2%) for th'e high_ pressure coolant injection pump flow instrument, 1-BJ-FIC-R600-E41, and proposed to use the existing permanent instrumentation, as is, with a +3.41 to -2.22% loop accuracy. .,
3.4.2.1 Licensee's Basis For Reauestina Relief. The following permanent instrumentation loops do not meet the Code requirements for acceptable instrumentation accuracy of Table IWP-4110-1,. but they will meet the conditions =for accuracy / range in; Generic' Pump Relief Request No.-l. ,
(Section 3.1.1. of this report.)
System and Reference _
Instrument Loop (T.S. ) flow Instrument Ranae Accuracy HPCI Flow 5600 GPM l-BJ-FIC-R600-E41 0-6000 GPM +3.41% -2.22%
However, the total loop accuracies have been calculated from the transmitters to the indicators. The loop accuracies do not meet the instrumentation accuracy requirements of the Code. Temporary field instruments are not a viable solution since the speed and flow or differential pressure must-be set at the reference value from the control room and the test duration is severely limited due to heat addition to the suppression pool.
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, -I These total.-loop accuracies do not significantly exceed the Cod,e limits and are sufficiently repeatable from test to test to allow for an evaluation !
of the pump hydraulic condition and for detection of pump degradation.
Relief-is therefore requested from this Code requirement. -
Alternate Testina: Use the existing above listed instrumentation. -
3.4.2.2 Evaluation. The Code requires an instrument accuracy of 2% i
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of full-scale range for flow rate measurement instruments and allows a' range j of up to 3 times the reference value. This could result in an instrument accurate to 16% (2%.X 3) of indicated flow rate at reference conditions, j The licensee has proposed to utilize a flow rate instrument with a full-scale range of 6000 GPM, which only slightly exceeds the test parameter reference value of 5600 GPM (full-scale equals 1.07 times reference) and which -is- accurate -to +3.41% and -2.22% of full- scale for the high pressure 1 coolant injection pump. This should result' in flow rate measurements accurate to +3.65% or -2.38% of indicated at reference conditions, which is more conservative than the 6% minimum accuracy allowed by tht combination of instrument full-scale range and accuracy specified in the Code and gives ]
adequate assurance of operability and provides a reasonable alternative to the Code requirements. Requiring installation of new flow rate instrumentation would constitute a hardship on the-licensee without a compensating increase in plant safety since it would be expensive and may .;
not provide better indication accuracy or readability.
Based on the determination that the licensee's proposed alternative provides a reasonable alternative to the Code requirements and considering the burden on the licensee if the Code requirements were imposed, relief j should be granted as requested.
3.5 Reactor Core Isolation Coolina 3.5.1 Relief Recuest The licensee has requested relief from the Section XI, Paragraph IWP-3500(b), requirement to run the reactor core isolation cooling pump, 14
1-BD-0P-203, until the pump bearing temperature stabilizes during-annual-bearing temperature measurement and proposed no alternative testing.
3.5.1.1 Licensee's Basis For Reauestina Relief. This pump is a steam turbine driven pump that exhausts into the suppression chamber. Running ;
this pump increases the temperature in the suppression chamber to the maximum allowable of 105 degrees F. (per T.S. 3.6.2.1.a.2.a) prior to satisfying the Code minimum time for bearing temperature stabilization.
Running both available RHR pumps in the torus cooling mode in addition to running the torus water cleanup system cannot keep the suppression chamber- ,
temperature below the limit for the required bearing temperature test duration. Relief is therefore requested for this requirement.
Alternate Testina: None 3.5.1.2 Evaluation. The steam exhausting out of the turbine which. '
drives this pump goes into the suppression chamber. Running'the pump causes the temperature to rise in the suppression chamber because of the hot steam entering the water. The cooling systems available to cool the suppression chamber water cannot maintain the temperature below that required by Technical Specification requirements when these pumps are being run for long durations such as those required to stabilize bearing temperatures, therefore, this requirement is impractical. In addition, industry experience has shown that bearing temperature measurements can be influenced- )
. by many factors unrelated to bearing degradation such as,. ambient i L
temperature, fluid temperature, etc. Running these pumps for an extended time (to stabilize bearing temperatures) imposes a hardship on the licensee while not contributing significantly to the evaluation of pump operational readiness and plant safety. The licensee's proposed testing should give adequate assurance of operational readiness and provides a reasonable alternative to the Code requirements. ,
g Based on the determination that compliance with the Code requirements is impracticable and considering the licensee's proposed testing and the l
burden on the-licensee if these Code requirements are imposed, relief should
- be granted from the Code requirement to run these pumps until bearing temperatures stabilize, as requested.
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3.5.2 Relief Reauest l The licensee has requested relief from the Section XI Table IWP-4110-1, required instrument accuracy ( 2%) for the reactor core t isolation cooling pump flow instrument,1-80 FI R600 E51, and proposed to <
use the existing permanent instrumentation, as is, with a +3.40 to -1.80% .;
loop accuracy.
3.5.2.1 Licensee's Basis For Reauestino Relief. The following permanent instrumentation loops do not meet the Code requirements for ,
acceptable instrumentation accuracy of. Table IWP-4110-1, but they will meet [
the conditions for accuracy / range -in Generic Pump Relief Request No. I. ,
(Section 3.1.1. of this report.)
System and Reference Instrument Loop (T,S.) flow Instrument Ranae Accuracy RCIC Flow 600 GPM l-BD-F1-R600-E51 0-700 GPM +3.40% -1.80%
However, the total loop accuracies have been calculated from the transmitters to the indicators. The loop accuracies do not meet the instrumentation accuracy requirements of the Code. Temporary field instruments are not a viable solution since the speed and flow or i differential pressure must be set at the reference value from the control room and the test duration is severely limited due to heat addition to the suppression pool. These total loop accuracies do not significantly exceed the Code limits and are sufficiently repeatable from test to' test to allow for an evaluation of the pump hydraulic condition and for detection of pump degradation. Relief is therefore requested from this Code requirements. l Alternate Testina: Use the existing above listed instrumentation.
'3.5.2.2 Evaluation. The Code requires an instrument accuracy of i2%
of full-scale range for flow rate measurement instruments and allows a range of up to 3 times the reference value. This could result in an instrument L accurate to 6% (2% X 3) of indicated flow rate at reference conditions. I l
(
- 1 16
1 The licensee has proposed to utilize their, installed flow rate instrument with a full scale range of 700 GPM, which only slightly exceeds the test parameter reference value of 600 GPM (full-scale equals 1.17 times reference) and which is accurate to +3.40% and -1.80% of full scale for the i reactor core isolation cooling pump. This should result in flow rate
~
measurements accurate to +3.97% or -2.1% of indicated at reference conditions, which is more conservative than the i6% minimum accuracy allowed !
by the combination of instrument full-scale range and accuracy-specified in the Code and gives adequate assurance of operational readiness and provides a reasonable alternative to the Code requirements. Requiring installation of new flow rate instrumentation would constitute a hardship on the licensee l without a compensating increase in plant safety since it~ would be expensive '
and-may not provide better indication accuracy or_ readability.
l Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements and considering the burden on the licensee if the Code requirements were imposed, relief should be i granted as requested. )
1 3.6 Service Water i
3.6.1 Relief Reauest I The licensee has requested relief from the Section XI, Paragraph. !
IWP-3100 requirement to measure inlet pressure of service water pumps, 1-EA-AP-502, 1-EA-BP-502, 1-EA-CP 502, and 1-EA-0P-502 and proposed to calculate the inlet pressure based on the level of water above the pump suction.
3.6.1.1 Licensee's Basis For Reauestina Relief. The inlet pressure for the service water pumps is calculated from the level of water in the l service water intake structure (SWIS). The service water pumps are submerged in the intake structure and do not have installed inlet pressure instrumentation. Calculating the inlet pressure using the water level above the pump suction yields equivalent information. Calculating the inlet pressure provides adequate information for calculating OP and still gives assurance of pump performance which meets the intent of the Code. Relief is therefore requested from this Code requirement.
17 e
o . .
Alternate Testina:. Calculate the pump inlet pressure based on measurement of water level above the pump suction.
3.6.1.2 Evaluation. These service water pumps are vertical submerged su, tion type with no intake piping or inlet pressure measurement ,
instrumentation and' direct measurement of pump -inlet pressure is '
impractical. To obtain dynamic pump inlet pressure measurement would require significant system design changes, which would be very burdensome to the licensee. Calculation of pump suction pressure based on the height of water above the suction point provides adequate information for evaluating pump operational readiness and presents a reasonable alternative to the Code i requirements. i Based on the determination that compliance with the Code requirements ,
is impractical, the licensee's proposal provides a reasonable alternative to
' the Code requirements, and giving due consideration to the burden on-the i licensee if the Code requirements are imposed, reli ef should be granted as requested.
i e
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,t
- . e.
3 ,
- 4. VALVE TESTING PROGRAM The Hope Creek Generating Station IST program submitted by PSE&G was examined to verify that _ all; valves that are included. in the program are subjected to the periodic tests required by the'ASME Code, Section~XI, 1983 Edition through the Summer 1983 Addenda, and the.NRC positions and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are '
tested to the Code requirements and the NRC positions and guidelines. Each
-PSE&G basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped
[ according to the system and valve Category. l L !
4.1 Multiole Systems 7
o 4.1.1 Cold Shutdown Testina L
L 4.1.1.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraphs IWV-3412, IWV-3415, and IWV 3522, requirements for testing all valves at cold shutdown that cannot practically be tested ;
quarterly. The licensee has proposed to comence testing of valves' that cannot be tested quarterly within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown and continue testing until either all testing is complete or until the start of Operational Condition 2. Testing will comence at the next cold shutdown where the last testing ended.
4.1.1.1.1 Licensee's Basis For Reauestina Relief--Unscheduled
- cold shutdown would result in the inservice test'ing activities being on the
. critical path to plant startup. Relief is therefore requested from these Code requirements.
L . Alternate Testina: Commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue s l testing until complete or ontil the start of Operational Condition 2.
Completion of all valve testing is not a prerequisite to return to power.
19
l Any testing not- completed at one shutdown will be performed during any I
, subsequent cold shutdowns that may occur before refueling to as closely as possible meet the Code specified test frequency. -Testing will'begin where the previous cold shutdown testing ended. ',
i i
For planned cold shutdowns where all the valves identified in the IST l
program for testing in cold shutdown mode will be completed, exception to l
r the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> requirement stated above may be taken, j 4.1.1.1.2 Evaluation -Due to the hardship that delaying a plant '
-startup places on a licensee, the NRC staff does not require licensees to j complete all testing identified for the cold shutdown frequency prior to startup of the plant from each cold shutdown. To require that all cold !
shutdown testing is completed prior to startup could result in delaying the l return to power, which would be burdensome to the licensee. . The licensee's 1 proposed alternate testing frequency, as stated above, is in agreement with.
previously. staff-approved alternatives on cold shutdown. testing and should l not have an adverse effect on the determination of component operational !
readiness. Therefore,-the licensee's proposal provides a reasonable- j alternative to the Code requirements. l i
t Based on the determination that the licensee's proposal provides a j reasonable alternative to the Code requirements-and considering the hardship- l that would be placed on the licensee without a compensating increase in
.f safety if the Code requirements were imposed, relief should be granted as ;
requested.
I i
.4.1.2 Power Ooerated Valve Corrective Action ;
l 4.1.2.1 Relief Reauest. The licensee has requested relief from the ;
Section XI, Paragraph IWV-3417(a), requirement to take corrective actions l for power operated valves based on comparing the most recent stroke time to l the previous stroke time and proposed to take corrective actions. based on .
L comparing the most recent stroke time to a current baseline value for that :
val ve. .
i l.
L O
L J
.- . s "1--
.4.1.2.1.l Licensee's Basis For Reauestina Relief--PSE&G has elected to use a more conservative approach of comparison of test results to -
the' current baseline time for ease of progrannatic and administrative ,
con't rol . Relief is therefore requested from this Code requirement.
Alternate Testino: If, for power operated valves, an increase'in stroke '
time of.25% or more from the current baseline for valves with full-stroke times greater than 10 sec., or 50% or more for valves with full stroke time ;
between 2 and 10 sec. is observed, the frequency shall be increased to once e each month until corrective action is taken, at which time the original test frequency shall be resumed. In any case, any abnormality or erratic action shall be reported.
4.1.2.1.2 Evaluation--Utilizing the trending criteria outlined in Section XI could allow significant increases in valve stroke times over several tests without requiring corrective action. .The licensee has proposed to assign limiting values of full-stroke times utilizing valve baseline stroke time data. This approach can be more conservative than the Code since it can facilitate valve repairs from stroke time variations less
- than those allowed by the Code.
The licensee has proposed to assign limiting values .of full-stroke' times to power operated valves as follows:
For valves with stroke times >2 seconds and <10 seconds the limit will be the baseline stroke time +50%. '
For valves' with stroke times >10 seconds the limit will be the ' baseline stroke time +25%.
Comparison of actual stroke times to baseline stroke times, rather than ,
trending, can allow for maintenance to be performed on these valves in many cases earlier than would be require'd by the Code and provides- an acceptable :
L level of safety and quality and a reasonable alternative to the Code requirements.
L
-21 L
c Based on the determination the licenste's. proposal provides a l reasonable : alternative to the Code requirements, relief should be granted as. !
requested. i 4.1.3 Containment' Isolation Valves a i
4.1.3.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3420, requirements to leak rate test the Category A containment isolation valves listed below with water. The licensee has proposed to leak rate test these. valves using 10 CFR 50, f Appendix J, . Type C,= leak rate test procedures and administrative leakage i limits.
V'alve Identification Valve Identification Valve Identification 1-BC-V206 1-BE-HV-F001A/B/C/D l-EE-HV 4652 1-BC-V260 1-BE-HV-F015A/B 1-EE-HV-4679 l-BC-HV-F004A/B/C/D l-BE-HV-F031A/B l-EE-HV 4680 1-BC-HV-F007A/B/C/D l-BD-SV-F019 1-EE-HV-4681 1-BC-HV-F010A/B' 1-BD-HV-F031 1-FC HV-F059 l-BC-HV-FollA/B 1-BJ-HV-F012 1-FC-HV-F060 1-BC-HV-F024A/B l-BJ-HV-F042 1-FC-HV-F062 1-FD-HV-F071 1-FD-V004 1-FC-V003' l-FD-HV-075 1-FC-V010 l
4.1.3.1.1 Licensee's Basis For Reauestiri Relief--These valves are tested in accordance with the Type C test requirements of 10CFR50, Appendix J; and HCGS : Technical Specification 4.6.1.2.h. Water is used as q
the test media, since-these valves would remain submerged under all postulated accident conditions. The Appendix J test meets all of the q requirements of IWV-3420 except IWV-3426 and IWV-3427. 'i Concerning IWV-3426, it is the collective function of these valves to l l isolate the primary containment in the event of an emergency, the. collective
- t. acceptance criteria-of 10CFR50, Appendix J (10 GPM) is more appropriate. -
- l. q 1
Concerning IWV-3427, it would cause undue burden and increase the j q duration of cold shutdowns if the testing frequency of valves 6 inches and larger were increased, due to the extensive preparations required to test l
22 l.
1
I
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.many.of these. valves. (Since many,are in ECCS, thislwould challenge the system due_ to . valve manipulation.) Also, projection of leakage rates using :,
3 or 4 tests is highly inaccurate criterion for valve repair. ?
Relief is therefore requested from these Code requirements.
Alternate Testina: These valves will be hydrostatically tested in accordance with the Type C test requirements of 10CFR50, Appendix J.-
Administrative limits have been established for the individual valves listed in this request for relief. Exceeding the administrative limits requires !
evaluation'for corrective action, as appropriate. !
4.1.3.1.2. Evaluation--NRC Generic letter No. 89-04 addresses L containment isolation valve testing in Position 10 and describes the testing that must be performed to obtain relief from the Code requirements. The leak test procedures and requirements for containment isolation valves l identified by 10 CFR 50, Appendix J, are essentially. equivalent to those contained in.Section XI,~ Paragraphs IWV-3421 through --3425. Appendix J, ;
P Type C, leak rate testing adequately determines leak-tight integrity of-these valves. Leak testing containment isolation vals ' in accordance with !
the requirements of both Appendix J and Section XI. Paraor , s IWV-3421 through -3425, is impractical since it would resui . nduplication of effort
, with little or no increase in quality or safety ..e would be a significant burden on the licensee. However, the 10 CFR 56 ippendix J, leak testing l- does.not trend or establish corrective actions cased on individual valve leakage rates as required by Paragraphs IWV-3426 and -3427.
Neither.the licensee's Technical Specification limits, the collective I criteria of Appendix J, nor proposed administrative limits has been shown'to provide adequate assurance of individual component operational readiness as .
.provided by Paragraph IWV-3426. The collective criteria of Appendix J have not been demonstrated more appropriate since those may allow a single valve to be significantly degraded. Technical Specification leakage rate limits are assigned to limit' site boundary radiation doses to within the limits of
, 10 CFR 100 during and following an accident and are not intended to evaluate degradation of single components. Those limits are not adequate to replace 4
23
4
'the'ASME Code specified limits, which are component oriented and designed to monitor and take corrective actions based on changes in component. ,
- performance.- The licensee's administrative limits, which when exceeded may initiate corrective action, have not been shown to be more conservative or +
L equivalent to the Code requirements. Therefore, the licensee must comply with the-requirements of Paragraph IWV-3426.
l ,
'The licensee has not demonstrated that the Paragraph IWV-3427(a) requirements are impractical. However, the NRC staff agrees the "
requirements of IWV-3427(b) may be very burdensome for containment isolation
~
valves 6 inches or larger. Therefore, the licensee must test the listed containment isolation valves to Appendix J, Type C, requirements and comply-with IWV-3426 and -3427(a) to obtain relief from the Code requirements.
Based on the determination that compliance with the Code requirements is impractical.and leak testing in accordance with 10 CFR S0, Appendix J, provides a reasonable alternative to the requirements of Paragraphs IWV-3421 through -3425 and considering the burden on the licensee of leak testing these valves.to both Section XI and Appendix J, relief should be granted from the requirements of Paragraphs IWV-3421 through -3425, provided the licensee complies with.the requirements of Paragraphs IWV-3426 and -3427(a),
Analysis of leakage Rates and Corrective Actions, as described in GL 89-04, Position 10.
4.1.3.2 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3420,-requirements to leak rate test the Category A containment isolation valves listed below using gas. The j licensee has proposed to leak rate test these vaives using 10 CFR 50, 3 Appendix J, Type C, leak rate test procedures and administrative leakage .
limits.
Valve Identification y.glyf identification Valve Identification I-AB- HV-F016 1-BB- V043 1-SE- V006 1-AB- HV-F019 1 V047 1-SE- HV-5161 J 1-AE- V003- 1-BB- SV-4310 1-SE- SV-J004A1 ;
l-AE- V007 1 B8- SV-4311 1-SE- SV-J004A2 l l-AE- HV-F074A 1-BE- HV-F005A 1-SE- SV-J004A3 l 1-AE- HV-F074B 1-BE- HV-F005B 1-SE- SV-J004A4 l 1-BC- HV-F008 1-BE- HV-F006A 1-SE- SV-J004A5 I
l 24 l
i Valve Identification LValve Identification Valve Identification-1-BC- HV F009 .1 BE- HV-F0068- 1 KG .V016-1-BC- HV-F015A 1-BE- HV'F039A 1-KG- V034 1 BC- HV-F015B- 1 BE HV-F039B l-GS- HV-4950 '
l BC- HV-F016A 1-BF- HV-3800A 1-GS- HV-4951 1 1-BC- HV-F016B l-BF- HV-3800B l-GS- HV-4952 i a 1 BC- HV F017A 1-BG HV-F001- 1-GS- HV-4955A' i
- 1-BC- HV F0178 1-BG- HV F004 1-GS- HV-4955B 1-BC :HV-F017C 1 SK- HV-4953 1-GS- HV-4956 1-BC- HV-F017D. 1-SK- HV 4957- 1-GS- HV-4958 1 1-BC- HV-F021A' l-SK- HV-4981 1-GS- HV-4959A 1-BC- BV-F021B l SK HV-5018 1-GS- HV-4959B l-BC- HV-F022- 1-FD- HV-F002 1-GS HV-4962 !
l-BC- HV-F023 1-FD HV-F003 1-GS HV-4963 1 1 80- HV-F027A 1 FD- HV-F079 l-GS- HV-4964 1-BC- HV-F027B' l-FD HV-F100 1-GS HV-4965A- 1 1-BC- HV-F041A 1 GB- HV 9531A1 1-GS HV-4965B 1 1-BC- HV-F041B l-GB- HV-9531A2 1-GS HV-4966A 1-BC- HV-F041C 1 GB- HV-9531A3 1-GS- HV-4966B :
1-BC- HV-F0410 1-GB HV-9531A4 1-GS- HV-4974 l l-BC- HV-F050A 1-GB- HV-953181 1-GS- HV-4978 1 BC- HV-F0508 1 GB HV-953182 1-GS- HV-4979 1-BC- HV-F122A 1-GB- HV-953183 1-GS- HV-4980 ;
l-BC- HV-F122B 1-GB- HV 953184 1-GS- HV-4983A 'l 1-BC- HV-F146A 1-GP- V001 1-GS HV-49838 I l-BC- HV-F146B l GP- V002 1-GS- HV-4984A l l-BC- HV-F146C 1-GP- V004 1-GS- HV-4984B 1-BC- HV-FI46D l-GP- V005 1-GS- HV-5019A.
1-HB- HV-F003 1-GP. V120 1-GS- HV-5019B l-HB- HV-F004 1-GP- V122 GS- HV-5022A 1 HB- HV-F019 l-KL- HV 5126A 1-GS- HV-5022B e l'-HB- HV-F020 1 KL- HV-5126B l-GS HV-5029 1 0-RC- SV-0643A 1-KL- HV-5147 1-GS- HV-5031-
- 0-RC- SV-0643B- 1-KL- HV-5148 1-GS HV-5050A 0-RC- SV-0707A 1-KL HV-5152A 1-GS- HV-5050B-
'0-RC- SV-0707B 1 KL- HV-51528 1-GS- HV-5052A i 0-RC- SV-072BA 1-KL- HV-5154 1-GS- HV-50528 .
0-RC- SV-0728B 1 KL- HV-5155 1-GS- HV-5053A' !
0-RC- SV 0729A 1 KL- HV-5162 1-GS- HV-5053B' 0 RC- SV-0729B 1-ED- HV-2553 1-GS- HV-5054A 0-RC- SV-0730A 1-ED- HV-2554 1-GS- HV-5054B 0 RC- SV-07308 1-ED- HV-2555 1-BH--V029 '
0-RC- SV-0731A 1-ED- HV-2556. 1-BH- HV-F006A 0-RC-'SV-0731B l-FC- HV-F007 1-BH- HV-F0068 0-RC- SV-8903A- 1-FC- HV-F008 1-KA- V038 '
0-RC- SV-8903B: 1-FC- HV-F076 1-KA- V039 1-BJ- HV-F006 1-FC- HV-F084 4.1.3.2.1 Licensee's Basis For Reauestina Relief--These valves are. tested in accordance with the Type C test requirements of 10CFR50, ,
Appendix J; and HCGS Technical- Specification 4.6.1.2.d., using' gas as the 4
25 e , , . . . . , . . . _ , _ . , , . , . . . . , . , ,.
_.~ __ _ .__ _ ._
L
. test media. This test meets all.of the requirements of IWV-3420 except
-IWV 3426 and IWV-3427.
Concerning IWV-3426, it is the collective function of these valves to >
isolate.the primary containment in the event of an emergency, the collective acceptance criteria of 10CFR50, Appendix J (0.6 La) is more appropriate, i
Relief valves that are 10CFR50, Appendix J tested are categorized A/C, but are not listed in this relief request to strictly comply with the provision of subsection IWV 3512; as required by the Jurisdiction. Relief ,
is therefore requested from these Code requirements.
Alternate Testina: These valves will be tested in accordance with the Type C test requirements of 10CFR50, Appendix J. Administrative limits have been established for the individual valves listed in this request for relief. Exceeding the administrative limits requires evaluation for corrective action, as appropriate.
l 4.1.3.2.2 Evaluation--NRC Generic Letter No. 89 04 addresses 4 containment isolation valve testing in Position.10 and describes the testing that must be performed to obtain relief from the Code requirements. The leak test procedures and requirements for containment isolation valves.
identified by 10 CFR 50, Appendix J, are essentially equivalent to those contained in Section XI, Paragraphs IWV-3421 through -3425. -Appendix J, Type C, leak rate' testing adequately determines leak-tight integrity of.
these valves. Leak testing containment isolation valves in accordance with the requirements of both Appendix J and Section XI, Paragraphs IWV-3421 through -3425, is impractical since it would result in duplication of effort with little or no increase in quality or safety and would be a significant burden on the licensee. However, the 10 CFR 50, Appendix J, leak testing does not trend or establish corrective actions based on individual valve leakage rates as required by Paragraphs IWV-3426 and -3427. .
Neither the licensee's Technical Specification limits, the collective criteria of Appendix J, nor proposed administrative limits has been shown to provide adequate assurance of individual component operational readiness as 26
. .- -i
-l' provided'by Paragraph IWV-3426.
The collective criteria of Appendix J have not been demonstrated more appropriate since those may allow a single valve to be- significantly degraded. Technical Specification leakage rate limits are assigned to limit site boundary radiation doses to within the limits of j 10 CFR' 100 during and following an accident and are not intended to evaluate degradation of single components. Those limits are not adequate to replace j the ASME Code specified limits, which are component oriented and designed to monitor and take corrective actions based on changes in component performance. The licensee's administrative limits, which when exceeded may-initiate corrective action, have not been shown to be more conservative or equivalent to the Code requirements. Therefore, the licensee must comply I with the requirements of Paragraph IWV-3426.
l Further, the licensee has not demonstrated that the Paragraph !
IWV 3427(a) requirements are impractical. Therefore, the licensee must test {
the listed containment isolation valves to Appendix J, Type C, requirements- l and comply with IWV-3426 and -3427(a) to obtain relief from the Code j requirements. '
1 Based on the determination that compliance with the Code requirements ;
is impractical and leak testing in accordance with 10 CFR 50, Appendix J, provides a reasonable alternative to the requirements of Paragraphs IWV-3421 through -3425 and considering the burden on the licensee of leak testing.
these valves to both Section XI and Appendix J, relief should be granted from the requirements of Paragraphs IWV 3421 through -3425, provided the ,
licensee complies with the requirements.of Paragraphs IWV-3426 and -3427(a),
Analysis of leakage Rates and Corrective Actions, as described in GL 89-04,
- Position 10. :
4.1.4 Excess Flow Check Valves 4.1,4.1 Relief Reauest. The licensee has requested relief from the ;
Section XI, Paragraph IWV-3521, requirements to exercise excess flow check 27
valves quarterly and proposed to exercise these check valves per HCGS Technical-Specifications 4.6.3.4 every 18 months. ,
l Valve Identification Valve Identification Valve Identification 1-BB- XV-3621. 'l-BB XV-3734A 1-AB- XV-3666A 1-88 XV 3649 1 XV-3734B l-AB- XV-3666B ,
1-BB- XV-3725 1 88- XV 3734C 1-AB XV-3666C 1 BB- XV-3726A 1 XV-3734D l-AB XV-3666D -
1-BB- XV-3726B l-BB XV-3737A 1-AB- XV-3667A 1 XV-3727A 1-88 XV-37378 1-AB- XV-36678 ,
1-BB- XV-3727B l BB- XV-3738A 1-AB XV 3667C 1-BB- XV-3728A 1-BB XV-37388. 1 AB- XV-36670 1-BB- XV-37288 1-BB- XV-3783 1-AB XV-3668A :
1 BB XV-3729A 1-BB XV-3785 1-AB- XV-36688 1-BB XV-3729B' l BB XV-3707 1-AB- XV 3668C 1-BB- XV-3730A 1 XV-3789 1-AB XV-36680 !
l-BB- XV-3730B l-BB- XV 3801A 1-AB- XV 3669A 1-BB XV-3731A 1-BB- XV 38018 1-AB-'XV-3669B l-BB- XV-3731B 1-BB- XV-3801C 1-AB XV-3669C 1-BB- XV-3732A 1-BB- XV-38010 1-AB- XV-36690 1-BB XV-3732B l-BB- XV-3802A 1-BC- XV-4411A 1-BB- XV-3732C 1-BB- XV-3802B 1-BC- XV-44118 1-BB XV-3732D l-BB XV-3802C 1-BC- XV-4411C -
1-BB- XV-3732E 1-BB XV-38020 1-BC- XV-44110 1 BB- XV-3732F 1 BB- XV-3803A 1-BC- XV-4429A 1-BB--XV-3732G l-BB- XV-3803B 1-BC- XV 44298 i c l-BB- XV-3732H 1-BB XV-3803C 1-BC-:XV-4429C ,
i 1-BB- XV-3732J 1-BB- XV-38030 1-BC- XV-4429D '
1-BB- XV-3732K 1-BB- XV-3804A 1-FC XV-4150A a 1-88 XV 3732L l-BB- XV-38048 1-FC- XV-41508 ,
1-BB- XV-3732M l-BB XV-3804C 1-FC- XV-41500 1-BB-~-XV-3732 1-BB--XV-3804D l-FC- XV-41500 L l BB- XV-3732P l-BB- XV-3820 1-BG- XV-3884B L l-BB- XV-3732R l-88 XV-3821 1-FD- XV-4800A L
l-BB- XV-3732S 1-BB- XV-3826 1-FD- XV-4800B L l-88 XV-3732T l-BB- XV-3827 1-FD- XV-4800C i' L l-BB- XV-3732U 1-BG XV-3882 1-FD- XV-48000
, 1-BB- XV-3732V l-BG- XV-3884A 1-BE- XV-F018A 1 BB- XV-3732W 1-BG- XV-38848 1-BE- XV-F018B l-BG- XV-3884C 1-BG XV-38840 i
4.1.4.1.1 Licensee's Basis For Reauestina Relief--These excess i
L . flow check valves cannot be exercised during power operations. Typically
.these valves are in instrument sensing lines that initiate logic circuits or process control parameters that are required during power operations and cold shutdown conditions. Testing of these valves at the 3 month frequency.
would either disable safety system initiation logic or unnecessarily challenge safety systems, t 28
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l l
Testing of these valves at cold shutdown conditions would similarly I either disable shutdown safety system initiation' logic or unnecessarily 1 challenge safety systems used for decay heat removal.
The operational readiness of these valves is adequately determined when :
tested in accordance with Technical Specification.4.6.3.4 on an 18 month frequency.
These excess flow check valves are not 10 CFR 50, Appendix J Type C, tested, nor do they have individual seat leakage acceptance criteria. The l
pressure boundary is tested as part of the 10 CFR 50 Appendix J, Type A test and therefore (sic - these valves) are categorized C to strictly comply with the provision of subsection IWV-3512; as required by the Jurisdiction.. ;
i Following,is an excerpt from NUREG 1048, titled " Safety Evaluation Report Related to the Operation of Hope Creek Generating Station,"
Supplement 5, Section 6.2.6 (5) Instrument Lines; to clarify the above statements:
i "The applicant requested an exemption (from Paragraph III.C.2(a) of Appendix J)'from the Type C test requirements for the. instrument lines, including suppression pool level and pressure instrumentation, drywell.
pressure instrumentation, drywell pressure instrumentation,- and those lines ~(
containing excess' flow check valves, on the basis that they are not capable of being Type C tested and their leak tightness is verified during the integrated (Type A) leak rate test. (Instrument integrity is verified but' the excess flow check valve is open & therefore not leak rate tested.)
l
'These instrument lines consist of small-diameter plping l'ocated _outside l
L the containment connected to a sealed instrument transducer, and are passive
- system. They are designed to withstand the pressure and temperature conditions following the onset of a LOCA. Certain instrument lines have a flow-restriction orifice inside the containment and an excess flow check valve outside the containment for containment isolation in the event of an
, instrument line break. The excess flow check valves are functionally tested -
to verify operability in accordance with the applicant's surveillance program, i
29 L ._ .- .
The NRC staff has reviewed the applicant's request for exemption under ;
the newly revised (50 FR 50764,, published December 12,1985) provisions of 10 CFR 50.12. Under these provisions, a finding must be made in accordance >
with (1) 10 CFR 50.12(a)(1) that the proposed exemption is' authorized by l law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security, and (1) 10 CFR 50.12(a)(2) that the proposed exemption involves special circumstances as defined in 10 CFR 50.12(a)(2)(1) through (vi). ,
The staff finds that special circumstances exist in accordance to 10CFR50.12(a)(2)(ii). The purpose of Appendix J to.10 CFR 50 is to ensure that containment leak tight integrity can be verified periodically j throughout the service lifetime so as to maintain containment leakage with (sic) the li: nits specified in the facility Technical Specifications. The .
I testing of instrument lines valves during the Type A test and the functional testing of the excess check valves to verify operability provide adequate assurance of leak. tightness. The staff finds that in accordance with 10 CFR 4 50.12(a)(2)(ii), applications of the regulation in this particular circumstance is not necessary to achieve the underlying purpot.e of the rule ;
as the applicant has verified the leak tightness of the instrument line <
-valves during the Type A test and will verify the operability of the excess flow check valves.
For these reasons, the staff finds that the proposed exemption'is 4 authorized by law, will- not present an undue risk to the public health and safety, and is consistent with the common defense and security.
Furtherinore, the staff finds that, in accordance with 10 CFR 50.12(a)(2)(ii), special circumstances are present.
The staff has reviewed the applicant's exemption request for the !
instrument lines. Because passive failure is required for a leakage path to be present on the instrument lines, the staff concludes an exemption from the Type C test is acceptable." Relief is therefore requested from this.
Code requirement. , c i
l-30 L
~ _ _ _ _ _ _ _ _ _ - _ _ .. . - - . .
- v. . . - . . -
4 Alternate Testina: These valves shall be functionally (exercised closed) accordance (sic) with HCGS Technical Specification 4.6.3.4 at a frequency of every 18 months. This functional testing otherwise meets IWV 35 M or exceeds the requirements of IWV-3520, and-IWV 3300. -!
-l 4.1.4.1.2 Evaluation -These are excess flow check valves on ]
instrument sensing lines which penetrate the primary containment building. I Their function is to close against excessive flow to perform a containment-isolation function. -It is impractical to exercise these valves during pbwer j operation because various instrument sensing lines must be disconnected thus removing multiple reactor instrumentation from service. Those instruments provide reactor protection and control signals and cannot be removed from service without possibly causing a reactor trip, which would be costly and {
burdensome to the licensee. Additionally, it is impractical to exercise these valves during cold shutdown because removal of multiple instruments from service could prevent operation of systems required for decay heat t removal.
The testing specified'in the Hope Creek Generating Station Technical- '
Specifications is a modified leak test which is performed once each 18 months. . The licensee's proposal to leak test these valves once each '
18 months in accordance with their Technical Specifications provides a ;
' reasonable alternative- to the Code requirements.
Based on the determination that compliance with the Code requirements is ' impractical and considering the licensee's proposed testing and the
-burden on the licensee if the Code. requirements were imposed, relief should be granted as requested.
4.1.5 Soecial Leak Test 1 4.1.5.1 Relief Reauest. The' licensee has requested relief-from the Section XI, Paragraph IWV-2426 and -3427, leak rate testing requirements for the following Category A 5 alves. The licensee has proposed to leak test these valves in groups ar. cording to Technical Specifications and upon exceeding their establi;hed administrative limits the valves will be evaluated to determine if corrective actions are necessary.
31
- 1 System Valve Identification -
Main steam system 1-AB-HV-3631A,-B,' C, 2.nd D i
Main steam system 1-AB HV-F022A, B, C,and D l Main steam system 1-AB HV F028A, B, C,'and D Main steam system 1-AB-HV-F067A, B, C, and D I Main steam system 1-AB HV F071 Feedwater system 1-AE-HV-F032A 4 Feedwater system 1-AE-HV-F032B Feedwater system 1-AE-HV-F039 Reactor core isolation cooling system 1-BD HV-F013 High pressure coolant. injection system 1-BJ HV-8278 Main steam isolation valve sealing system 1-KP-HV-5834A and B Main steam isolation valve sealing system 1-KP-HV-5835A and B Main steam isolation valve sealing system 1-KP-HV-5836A and B
-Main steam isolation valve sealing system 1-KP-HV-5837A'and B 4.1.5.1.1 Licensee's Basis For Reauestino Relief. These valves !
are tested in accordance with HCGS Technical Specifications 4.6.1.2.f and 4.6.1.2.g, respectively. These tests meet all of the requirements of. i IWV-3420, except for IWV-3426 and -3427.
Concerning IWV 3426, it is the function of these valves to establish seal boundaries' in order to isolate the primary containment in the event of an emergency. Additionally, most of these valves can only. be tested in groups simultaneously, therefore the collective acceptance criteria.is more appropriate. Concerning IWV-3427, it would cause undue burden and increase the duration of cold shutdowns if the. testing frequency.of valves 6 inches or larger were increased, due to the extensive preparations- required to test -
many of. these valves. Also projection of leakage rates using 3 or 4 tests is highly. inaccurate criterion for valve repair.
Relief is therefore requested from these Code requirements.
Alternate Testina: These valves will be tested in accordance with the >
requirements of HCGS Technical Specifications 4.6.1.2.f and 4.6.1.2.g as applicable. - Administrative limits have been established for the valves listed .in the request for relief. Exceeding the administrative limits requires evaluation for corrective action, as appropriate.
32
4.1.5.1.2 Evaluation.- It is not practicable to individually leak rate test most of these valves due to system designLor the lack of appropriate test taps. To facilitate individual leakage rate testing of these valves would require significant system redesign and would be very -
burdensome to the licensee.- The licensee has proposed to test these valves I per plant Technical. Specifications and stated this testing meets the ,
requirements of IWV-3421 through -3425. Also, the licensee has proposed to utilize assigned administrative leak rate limits.for the valves affected by this relief request. If these limits are exceeded an evaluation will be performed to determine if corrective action is appropriate, i
for valves that can be tested only in groups it is impractical to j analyze individual valve leakage rates or compare them to Owner specified q values, as requircd by IWV-3426 and -3427(a), since individual valve leakage ;
rates cannot be isolated. The licensee has established administrative leakage rate limits, however, their basis has not been provided and it is not certain the limits assigned will ensure corrective action is taken on a particular valve that has become degraded. Therefore, a determination cannot be made that these limits are reasonable for testing groups of _
valves, for cases where valves can be leakage rate tested only in groups trending of leakage rates may.not be practicable since the various valves --
may seat slightly different after each stroke. This would make valve performance projections based on trended-leakage values questionable, therefore, it is impractical to meet the requirements of IWY-3427(b)_for .I these valves. In those cases, a limiting leakage rate value assigned to the group as a whole may be more appropriate. However, this group limit must be l assigned considering not only the maximum leakage rate allowable through the group collectively, but also to ensure individual valve degradation is detected and corrective action is taken when necessary.
l This-relief request implies ("...most of these valves can only be tested in groups simultaneously...") that it includes valves that can
' practicably be tested individually. Those valves should 'be individually leak rate tested per the Code requirements. If those valves are also tested 33
'?
with other valves in groups their known leakage can be subtracted out to-better isolate and allow an evaluation of the other group valves' leak tight i integrity. This should give adequate assurance of valve operational readiness and provide a reasonable alternative to the Code requirements.
l Based on the detemination that compliance with-!WV-3426 and.-3427 is
-impracticable for the above listed valves' that can be tested only in groups I and considering the burden on the licensee if the Code requirements were ;
imposed, relief should be granted provided: (a). valves that can-be tested individu' ally-are tested in accordance with the Code requirements and (b) maximum group leakage rate limits assigned are reasonable so that corrective action is taken whenever the leak tight integrity of any group-tested valve "
is in question. ,
4.1.6 Rapid-Actina Valves 4.1.6.1 Relief Reauest. The licensee has requested relief from the ~!
Section XI, Paragraph IWV-3413, requirements to measure the stroke time of i the below listed rapid-actint, solenoid valves and proposed to full-stroks exercise and fail-safe test these valves quarterly. -
Valve Identification Valve Identification Valve Identification 1-BC SV-F074 1-EG-SV-2281-1 'l-KJ-SV-7534A-1-EA-SV-2235 1-EG-SV-2281-2 1-KJ-SV-7534B !
l-EA-SV-2237 .-1-EG-SV-2288-1 1-KJ-SV-7534C 1-EA-SV-2239 l-EG-SV-2288-2 1-KJ-SV-7534D 4.1.6.1.1 Licensee's Basis For Recuestina Relief--These valves are fast acting (or direct acting) solenoid valves that are not designed with any local or remote indication or other means to permit the stroke time test with any degree of accuracy or repeatability. Relief is therefore requested from this Code requirement.
Alternate Testina: These valves will be exercised in accordance wi IWV-3412 and fail' safe tested in accordance with IWV-3415.
4.1.6.1.2 Evaluation -These small rapid-acting solenoid v ..
are not equipped with a positive means to accurately time valve movement.
34
. ~ . . . - - -.
I They possess no electrical or mechanical valve position indication system and.the valves are fully encased making local visual timing of the valve t stroke impractical. System modifications would_ be necessary to directly- l
, measure the stroke times of these valves and would be expensive and
- burdensome to the licensee. These valves may be indirectly verified open or closed by monitoring system parameters in many cases,_but, accurate stroke timing of these valves using conventional techniques is difficult. The a
licensee's proposal to exercise and fail-safe test these valves quarterly gives some assurance of operability in the interim. However, it does not adequately evaluate changes in valve condition and does not present a reasonable long term alternative to the Code requirements. Some method for -
quantitatively evaluating changes in valve condition, such as stroke timing these valves, is essential for assessing their operational readiness. The licensee should actively pursue an alternate method for stroke time testing these valves. Methods employing magnetics, acoustics, ultrasonics, or other technologies-should be investigated for their suitability.
While the licensee is pursuing an alternate method for stroke time l testing these valves a method should be employed wherever practical to I verify valve operation via appropriate and- timely system response. For instance, valves 1-EG SV-2281-1 and 1-EG-SV-2281-2 are in-line with a pressurized nitrogen source. It may be practical to time the valve stroke by opening one of these valves and cycling the other (open and shut) while i observing evidence that the valve opens or shuts. This stroke time value l
l could then be compared to an assigned reasonable maximum stroke time limit ,
for a qualitative assessment of operability.
Based on the determination that complying with the Code requirements is impractical and considering the licensee's proposal and the burden on the licensee if the Code requirements were imposed, relief should be granted for an interim period of one year or until the next refueling outage, whichever is longer, while the licensee develops a method of measuring the stroke L times of these valves, provided the licensee verifies changes in valve L position within an appropriate time interval from actuation in the interim. l I
l 1 l 1 :
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35 l
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4.1.7. Modified Check Valve Testina 4.1.7.1 Relief Reauest. The' licensee has requested relief from the Section XI, Paragraph IWV-3522(b), requirements to measure torque delivered
- tofa check valve when full-stroke exercised using a mechanical exerciser. 1 The licensee has proposed to exercise the below listed modified testable check valves quarterly using a special procedure with an external manual
- lever without measuring torque.
1 Valve identification Valve Identification l 1
1-AP-V003 1 BE-V028 1 1-AP-V005 1-BE-V030 J 1-BC-V030 1-BE-V032 l 1-BC-V033 1-BE-V034 1-BC-V038 1-BJ-V006 1-BC V127 1 - BJ-V008 1-BC-V130 1-BJ-V015 1 BD-V002 1-FC-V003 :
1-BC-V004 1-FD-V004 4.1.7.1.1 Licensee's Basis For Reauestina Relief--These valves '
were originally designed as testable check valves, with the manual actuator-lever directly coupled to the disk by set screws-on the hinge point of the disk-to the hinge pin shaft, and through to the lever. -
Prior to plant operation, a modification was made to these valves by l our site engineering organization in conjunction with the valve manufacturer
! that removed the set screw, milled a recess in the disk at the hinge point, ,
and provided a dog which is secured onto the shaft. Additionally, a plate h was provided outside of the valve, which was bolted to the body of the valve-in a position that represented the neutral position of the manual-test :
lever.
This modification resolved the' initial problem where the ' shaft packing would tend to hold the valve in the open position whether flow was in the forward or reverse direction. The modification changed the testable feature nf the valve so that the disk was free to swing on the hinge pin (shaft) without rotating the shaft or moving the manual lever, providing the lever was lockwired in the neutral position.
F-e i 36 l
o
l
\
l This modification also permits the valve to be exercised without flow '
- by means of the manual lever.= This is accomplished by removal: of the -
lockwire, manually' moving the lever from the neutral position until the dog _ j meets with 'the disk, and-then to continue the rotation until the disk -is in .
L the open-position required to fulfill its function. The lever is then returned to the neutral position and lockwired back to-the plate with wires and seals. l 1
The requirement for measurement of torque or force is not applicable to -
these valves because they work as simple check valves when the lever is ]
lockwired in the neutral position. When the-lever is-used and the dog is 'l j
against the disk, there isn't any rotational movement between the disk hinge point and the hinge pin. The forces to be measured are shaft friction from l the packing gland, running friction between the shaft and its bearing. seat,_ l and the moment due to the weight of the disk; all of which do not affect the I ability of the disk to perform its function. The rotational movement between the disk hinge point and the hinge pin shaft is verified when the lever is: rotated from the neutral position to the point where the dog l contacts the disk, which demonstrates freedom of motion. l Our procedures require that the valve be declared inoperable and corrective action be initiated if the lever does not move freely when .
exercised. This position is conservative in that corrective action is initiated regardless of whether the lack of free movement is ultimately determined to be due to excessive friction in the packing gland, at the shaft seat, or relative motion between the shaft and disk. Positive
- movement of the disk to the ' position required to fulfill its function within the valve body is verified by continued rotation of the lever. Any degradation, mechanical binding, or obstruction within the valve would prohibit the lever arm from moving to its full stroke position. Excessive wear between the hinge pin and the disk hinge point could not be detected by force or torque measurements whether or not the valve was modified, and this will be checked when the valve is disassembled for maintenance.
37
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i 1 I
Relief is therefore requested ,' Dom the torque measurement requirements ]
because these measurements would not provide any measure of operational degradation for this type of valve as modified.
1 l
Alternate Testina: These valves will be exercised with the manual exerciser 1ever. Specifi test instructions have been developed for the performance of this test, and the operator training modules have been revised to incorporate the new modified check valve testing instructions. l Additionally, provisions have been made for a spare modified check valve to be available for training. The affected inservice testing procedures are I being revised to incorporate the new specific test instructions.
4.1.7.1.2 Evaluation Inservice testing is performed to detect component degradation and correct it prior to a failure which could prevent the component from fulfilling its safety function. This requires an >
objective testing methodology that is as free as possible from subjective ,
judgement and that adequately evaluates component operational readiness.
Using an objective method allows comparison of successive test results to those of previous tests to detect degradation. The alternate testing proposed by the licensee is neither objective nor positive. The test results are a subjective determination of the person performing the test and !
no data is present which could be compared to past tests. This was discussed during the working meeting of June 29 30, 1988.
The Code requires torque measurement when testing check valves without flow to provide data which can be compared from test to test. For these modified check valves, this may entail first measuring the force or torque applied to the lever while moving from the neutra1' position to the point of contact with the valve disk to determine the resistance due to the running i
friction between the hinge pin shaft and the seal and bearing surfaces, then measuring the force or torque through the valve stroke to-the full open position to determine whether there has been a change or deterioration in valve condition since previous tests.
{
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The proposed alternate testing does not obtain adequate information to evaluate these check valves' operational readiness and does not provide a l reasonable alternative to the Code requirements. Additionally, the Code j requirement to measure force or torque has not been demonstrated to be !
either impracticable or excessively burdensome to the licensee.
)
i Since the licensee has not demonstrated it is impracticable or l burdensome to measure force or torque while full-stroke exercising the I listed check valves and since the proposed alternative does not provide a j reasonable alternative to the Code requirements, relief should not be l granted, l l
4.2 Feedwater System j
4.2.1 Cateaory A/C Valves
- 4. 2'. l .1 Relief Recuest. The licensee has requested relief from the Section XI, Paragraph IWV-3521, test frequency requirements for the feedwater system check valves, 1 AE-V003 and V007, and proposed to full stroke exercise these check valves closed using Appendix J 1eak test procedures during refueling outages.
4.2.1.1.1 Licensee's Basis For Reauestina Relief- These valves F are, simple check valves with no position indication provided. The valves ,
cannot be exercised at power and it is not practical to verify these valves #
closed during cold shutdowns due to extensive preparations required to drain this 24 inch pipe to perform the closed verification. Relief is therefore requested from this Code requirement.
Alternate Testina: These valves will be verified to have stroked closed during refuelings following power operation during the performance of-Appendix J valve testing in accordance with Technical Specifications l '
4.6.1.2.d. Satisfactory completion of the Appendix J tests yields satisfactory evidence of valve closure (stroke) in accordance with l .
IWV-3522(a).
39
, t 4.2.1.1.2 Evaluation it is impractical to full stroke exercise .
these feedwater check valves during power operation since this would ;
interrupt feedwater. flow to the reactor possibly resulting in a reactor l scram. It is impractical to full stroke exercise these valves during cold shutdowns since it requires extensive system draining in addition to hooking up and disconnecting leak testing equipnent which would likely result in an
, extension of cold shutdown and would be very burdensome to the licensee. l Verifying valve closure during Appendix J 1eak testing at refueling outages provides adequate assurance of valve operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code requirements f
is impractical, the licensee's proposal provides a reasonable alternative to the Code requirements, and giving due consideration to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.
4.3 Main Steam 4.3.1 Cateoory A Valves 4.3.1.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3415, test frequency requirements to fail-safe test the inboard main steam isoiation valves, 1 AB HV F022A, F0228, F0220, and -F0220, and proposed to fail-safe test these valves at cold shutdowns when the containment is deinerted and each refueling outage.
4.3.1.1.1 Licensee's Basis For Reauestina Relief--These valves are located inside the primary containment which is inerted with an oxygen deficient atmosphere and therefore inaccessible during power operations.
Testing during cold shutdowns would require extensive preparations, including deinerting operations, system isolation, realignment for testing, and system restoration for testing, which is not practical. Relief is ,
therefore requested from this Code requirement.
p A 4 40
)
, a i
Alternate Testino: These valves will be fail-safe tested during cold I shutdowns when the containment is deinerted and during refueling outages, )
but' in no case at intervals less than 3 months, i
i 4.3.1.1.2 Evaluation--These main steam isolation valves are located inside the primary containment which is inerted with nitrogen during ;
power operation and during some cold shutdowns. Fail-safe testing these +
valves requires entry into containment. It is impractical to perform this test quarterly during power operation or during cold shutdowns when containment is inerted because of the personnel safety hazard posed by the oxygen deficient atmosphere. Purging and reinerting containment is costly .
and could result in delay of plant startup from cold shutdown which would be burdensome to the licensee. Fail safe testing these valves during cold shutdowns when containment is deinerted and at each refueling outage should give adequate assurance of these valves' operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code test frequency requirements is impractical and the licensee's proposal provides a reasonable alternative to the Code requirements and giving due consideration-to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.
4.3.2 Cateoory A/C Valves l
4.3.2.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3521, test frequency requirements to full-stroke exercise the listed main steam safety / relief valve accumulator check valves L and proposed to full stroke exercise those valves during cold shutdowns when the containment is deinerted and during refueling outages.
Valve Identification Valve Identification Valve Identification l l-AB V043 1 AB V044 1-AB-V045 l
1-AB V046 1-AB V047 1-AB-V048 L l AB-V049 l-AB V050 1-AB-V109 1 AB V110 1-AB Vlll 1-AB Vil2 l-AB-V113 1 AB Vil4 41
I 4.3.2.1.1 Licensee's Basis For Reauestina Relief -These valves are located inside the primary containment which is inerted with an oxygen j deficient atmosphere and therefore inaccessible during power operations. l Testing during cold shutdowns would require extensive preparations, !
including deinerting operations, system isolation, accumulator bleed down, l' realignment for testing, and system restoration for testing, which is not practical. Relief is therefore requested from this Code requirement.
Alternate Testino: These valves will be exercised open and closed during cold shutdowns when the containment is deinerted and during refueling outages, but in no case at intervals less than 3 months. Additionally, j credit for the exercised closed test will be taken during the 18 month leakage test performed in accordance with HCGS Safety Evaluation Report ;
(NVREG 1048) Supplement 4, Section 3.10,3
]
4.3.2.1.2 Evaluation -These main steam safety / relief valve accumulator check valves are located inside the primary containment which is inerted with nitrogen during power operation and during some cold shutdowns. Exercising these valves requires entry into containment. It is l impractical to perform this test quarterly during power operation or during l cold shutdowns when containment is inerted because of the personnel safety l
hazard posed by the oxygen deficient atmosphere. In addition, testing these valves requires significant system reconfiguration. Purging and reinerting containment is costly and could result in delay of plant startup from cold shutdown which would be burdensome to the licensee. Full-stroke exercising these valves during cold shutdowns when containment is deinerted and at each refueling outage should give adequate assurance of these valves' operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code test frequency requirements is impractical and the licensee's proposal provides a reasonable alternative to the Code requirements and giving due consideration to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.
42
+
t 4.3.3 Cateaory B/C Valves F
4.3.3.1 Relief Reauest. The licensee has requested relief from the '
i Section XI, Paragraphs IWV-3411 and 3413, test frequency, exercising, and stroke timing requirements for the automatic depressurization system (ADS) valves, 1-AB PSV-F013A, -F013B, F013C, -F0130, and -F013E, and proposed to :
exercise test these valves every 18 months in accordance with plant Technical '
Specifications.
4.3.3.1.1 Licensee's Basis For Reauestina Relief- These are instant acting pcwer operated safety and relief valves that are not instrumented for measurement of full stroke times. Exercising these valves during power operations causes thermal shock to the systems and places the reactor in an undesirable transient condition. These valves are tested in accordance with the surveillance requirements of HCGS Technical Specifications 4.5.1.d.2.b (ADS valves); or the requirements of HCGS Final Safety Analysis Report Question and Response 440.7; as applicable. Relief is therefore requested from these Code requirements.
Alternate Testina: These valves will be exercised tested every 18 months to the requirements of HCGS Technical Specification 4.5.1.d.2.b which specifies >
opening each ADS valve when the reactor steam dome pressure is adequate to perform the test as defined in HCGS FSAR Question and Response 440.7 which specifies the SRVs to be opened manually at 750 50 psig during each startup following refuelings, as applicable. Additionally, the SRVs are set pressure tested in accordance with HCGS Technical Specification 4.4.2.2 (1/2 each refueling outage) which exceeds the frequency requirements of IWV-3510.
4.3.3.1.2 Evaluation--These automatic depressurization system valves act both as power operated valves in response to a manual or automatic control signal and as safety relief valves. As a result, these valves should be tested to both the Category B and C requirements. Full-stroke exercising these valves requires reactor steam pressure and is impractical either quarterly during power operations or during cold 43
- . l shutdowns since it greatly increases the risk of creating a mini loss of coolant accident. NUREG 0626 " Generic Evaluation of Feedwater Transients and Small Break Loss of-Coolant Accidents in GE Designed ,
Operating Plants and Near Term Operating License Applications
- recommends reduction of challenges to relief valves to lessen the risk of Small Break LOCA (see also NUREG 0737, Section !!.K.3.16). The licensee's proposed test frequency of once each 18 months provides a reasonable alternative to the Code requirements.
Obtaining accurate stroke times for these valves is difficult and may require the installation of special test and timing equipment since these valves' stroke times are on the order of 100 milliseconds and there is no direct position indication. However, some method for quantitatively :
evaluating changes in valve condition, such as stroke timing these valves, is essential for assessing their operational readiness. Therefore, the '
licensee should actively pursue an alternate method for stroke time testing these valves. Methods employing magnetics, acoustics, ultrasonics, or other i technologies should be investigated for their suitability.
Based on the determination that complying with the Code frequency .
i requirements is impractical and considering the licensee's proposal and the burden on the licensee if the Code requirements were imposed, relief should be granted for an interim period of one year or until the next refueling outage, whichever is longer, while the licensee develops a method for l measuring the stroke times of these valves. ,
l 4.3.4 Cateoory C Valves 4.3.4.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3521, test frequency requirements for the inboard main steam isolation valve accumulator check valves,1 AB V051. V052,
-V053, and -V054, and proposed to full-stroke exercise these valves closed during cold shutdowns when the containment is deinerted and during refueling outages.
l 44
l l
l 4.3.4.1.1 Licensee's Basis For Reauestina Relief These valves )
are located inside the primary containment which is inerted with an oxygen f deficient atmosphere and therefore inaccessible during power operations.
l Testing during cold shutdowns would require extensive preparations, including deinerting operations, system isolation, accumulator bleed down, l realignment for testing, and system restoration for testing, which is not )
practical. Relief is therefore requested from this Code requirement. I Alternate Testino: These valves will be exercised open and closed during cold shutdowns when the containment is deinerted and during refueling l' outages, but in no case at intervals less than 3 months, 4.3.4.1.2 Evaluati a -These inboard main steam isolation valve accumulator check valves are located inside the primary containment which is !
inerted with nitrogen during power operation and during some cold shutdowns. Exercising .hese valves requires entry into containment. It is impractical to perfois this test quarterly during power operation or during '
cold shutdowns when containment is inerted because of the personnel safety '
hazard posed by the oxygen deficient atmosphere. In addition, testing these valves requires significant system reconfiguration. Purging and reinerting {
containment is costly and could result in delay of plant startup from cold shutdown which would be burdensome to the licensee. Full stroke exercising these valves during cold shutdowns when containment is deinerted and at each refueling outage should give adequate assurance of these valves' operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code test frequency requirements is impractical and the licensee's proposal provides a i reasonable alternative to the Code requirements and giving due consideration to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.
4 45
a i
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l 4.4 Emeraency Diesel Generator !
4.4.1 Cateaory B Valves !
4.4.1.1 Relief Reauest. The licensee has requested relief from the l Section XI, Paragraph IW 3300, -3413, and 3415 requirements to verify ,
position indication, stroke time, and fail-safe test the diesel generator lube oil reservoir makeup valves,1 KhSV 7534A, -75348 -7534C, and 75340, i and proposed to verify operability of these valves monthly during
, surveillance testing of the diesel without stroke timing, fail-safe testing
. or verifying remote position indication.
4.4.1.1.1 Licensee's Basis For Reauestina Relief -The lube oil ,
reservoir level is verified on a monthly (or more frequent) basis during the surveillance operability testing of the emergency diesel generator per HCGS Technical Specification 4.8.1.1.2. Specifically testing these valves would '
increase the level of the reservoir until a level change is observed by the instrumentation, and then require the manual draining of the sump back down ,
to waste barrels. Relief is therefore requested from these Code requirements, i
Alternate Testina: Operability is verified by satisfactory completion of the emergency diesel generator surveillance testing on a monthly or more frequent interval when tested pursuant to HCGS Technical Specification 4.8.1.1.2. Proper operation of the valves is verified by observation of adequate reservoir level, at the increased ' interval.
4.4.1.1.2 Evaluation -These small fast acting soienoid valves operate to maintain level in the diesel generator lube oil reservoir. They possess no electrical or mechanical valve position indication system and are fully encased making local visual timing of the valve stroke impractical.
Accurate stroke timing of these valves using conventional techniques is difficult, however, the licensee's proposal to verify that the valves are i operable based on sufficient oil reservoir level does not adequately evaluate changes in valve condition and does not present a reasonable long 46
term alternative to the Code requirements. Some methods for quantitatively - i evaluating changes in valve condition, such as stroke timing, and for ;
performing fail safe testing these valves are essential for assessing their operational readiness. Therefore, the licensee should actively pursue an alternate method for stroke time testing these valves. Methods employing magnetics, acoustics, ultrasonics, or other technologies should be !
investigated for their suitability.
Until a method of accurately stroke timing the.se valves is developed the licensee should ensure these valves exercise quarterly via appropriate [
and timely system response. This may require draining from the lube oil reservoir to initiate valve motion (if practicable) or taking other similar '
measures while observing system parameters to make a positive determination that valve motion was effected within an appropriate assigned time interval. ,
Based on the determination that complying with the Code requirements is ;
impractical and considering the licensee's proposal and the burden on the >
licensee if the Code requirements were imposed, relief should be granted for '
an interim period of one year or until the next refueling outage, whichever is longer, while the licensee develops a method of fail-safe testing and ,
measuring the stroke times of these valves, provided the licensee verifies changes in valve position within a suitable time interval from actuation quarterly during the' interim period.
4.4.1.2 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IW-3413(b), requirement to measure the full-stroke time of the emergency diesel generator (EDG) air start valves,1-KJ-7535A, 75358, -75350, -75350, -7536A, -7536B, -7536C, and -75360. The licensee has proposed to verify stroke time indirectly by the starting time of the diesel generator.
l 4.4.1.2.1 Licensee's Basis For Reauestina Relief--It is -
impractical to measure the stroke time of these valves. These valves do not
- j. have local or remote position indication. The safety function of these valves is to open to support the startup of its associated diesel in less 47
~ .,
,, - . - . - - - . . . . . . , .,,,.~n._.- ... , - , . . - - --- -n
h than 10 seconds. Successful startup of each emergency diesel generator is dependent upon the proper operation and speed of these valves. Measuring the startup time of each EDG is an indirect method of verifying the stroke time of these valves, allows for indication of valve degradation and meets the intent of the Code (i.e. operational readiness). Relief is therefore requested from this Code requirement. .
Alternate Testino: Stroke time testing of these valves will be indirectly ;
observed by verifying the startup times o.f the EDGs to be less than 10 ;
seconds by performing monthly (or more frequent) surveillance operability testing per HCGS Technical Specification 4.8.1.1.2.
4.4.1.2.2 Evaluation -The air start solenoid valves are small, -
rapid acting valves that are completely enclosed. They operate from an engine start control signal rather than a control switch and do not have remote position indication or any external means to determine valve position. Therefore, it is impractical to stroke time test these valves as-required by the Code. Since these valves must operate rapidly to start the diesel within the allowed time significant degradation or the failure of one l
of these valves to' function would be indicated by increased diesel generator start times and would cause an investigation into the cause of the failure.
The licensee's proposal to verify these valves operable monthly by confirmation of proper diesel start times provides adequate assurance of ,
- operational readiness and a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code requirements is impractical and the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.
4.5 Standby Liouid Control 4.5.1 Cateaory A/C Valves 4.5.1.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV 3521, test frequency requirement for the standby
, liquid control (SLC) injection header check valves,1-BH V029, 1
48
1 BH HV F006A, and F006B and proposed to exercise all these valves open every 18 months and valve 1-BH V029 closed every 24 months.
4.5.1.1.1 Licensee's Basis For Reauestina Relief--Exercising these stop check valves and simple check valve to the open position at {
either quarterly or at cold shutdown conditions is not possible without l establishing flow through the system by firing the explosive valves and j starting the system pumps. The motor operator will not exercise the stop check valves. Likewise, performance of the exercise closed test at power i operation would present the possibility of loss of containment integrity and reactor coolant inventory above the allowable identified leakage limits in >
the plant Technical Specifications as well as presenting a personal injury hazard to the test personnel should these valves fail to close when tested. ,
Relief is therefore requested from this Code requirement.
Alternate Testina: .These valves will be exercised open in conjunction with-the standby liquid control injection test at the frequency of once per 18 months per the requirements of HCGS Technical Specification 4.1.5.d.l. The operational readiness of these valves in the closed direction will be verified by satisfactory completion of the 10CFR50, Appendix J leakage test at the 24 month frequency, as specified in Technical Specification 4.6.1.2.d.
4.5.1.1.2 Evaluation--These check valves are in the common line to the nuclear boiler, downstream from the explosively actuated squib valves, it is impractical to full-stroke exercise these valves open with flow, either quarterly during operations or at cold shutdown. Initiation of '
system flow requires the firing of at least one squib valve, which destroys the valve. Further, the system contains highly borated water that would be introduced into the nuclear boiler system and cause a reactor shutdown during power operation. Extensive flushing must be performed on the system and all traces of the boron solution must be removed prior to initiating flow for exercising these valves. Performance of this testing during cold shutdowns would be burdensome to the licensee since this testing could result in an extension of the cold shutdown.
49
The licensee's proposal to full-stroke exercise these valves open at least once each 18 months by firing one of the squib valves and injecting into the reactor coolant system gives adequate assurance of operational readiness in the open direction and provides a reasonable alternative to the
' Code test frequency requirements. Valves 1-BH-F006A and -F006B are operated to the closed position quarterly using the motor operators. However, the only method available to verify the leak tight integrity of these valves, and the only practical method of verifying closure of valve 1 BH-V029, is leak testing. The licensee's proposal to verify these valves' closure capability during 10 CFR 50, Appendix J, leak testing at least once every 24 months gives adequate assurance of operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code requirements is impractical, the licensee's proposed testing provides a reasonable ;
alternative to the Code requirements, and giving due consideration to the burden on the licensee if the Code requirements were imp'osed, relief should i be granted as requested.
4.6 Control Rod Drive 4.6.1 Cateaory B Valves 4.6.1.1 Relief Reauest. The licensee has requested relief from the '
Section XI, Paragraphs IWV-3411 and 3413, requirements to full-stroke exercise and stroke time the control rod drive (CRD) scram valves, 1-BF-XV-126, and -127 (185 HCU's). The licensee has proposed to full-stroke exercise these valves during control rod scram insertion time testing per I plant Technical Specifications, i
4.6.1.1.1 Licensee's Basis For Reauestina Relief--Scraming of l the control rods would be required to exercise these valves. Relief is !
therefore requested from these Code requirements.
Alternate Testina: These valves are properly exercised during the rod scram timing tests on the control rods that is performed to satisfy the surveillance requirements of HCGS Technical Specification 4.1.3.2.a on all l
50 I 4
i control rods prior to exceeding 40% of rated thermal power following core alterations or after a reactor shutdown of greater than 120 days; and HCGS '
Technical Specification 4.1.3.2.c on 10% of the control rods, on a rotating .
basis, at least once per 120 days of power operation. Control rod scram
, timing will be used as an indirect measurement of valve stroke time.
Maximum stroke times will be as indicated in Technical Specification i 3.1.3.2. Degradation of these valves would be indicated by inadequate scram ,
times. Failure of rods to meet scram timing requirements will result in corrective action, i
4.6.1.1.2 [ valuation--These power operated valves must operate for rapid insertion (scram) of control rods and are tested during scram timing. It is impractical to stroke time these valves separately since they full-stroke in milliseconds, operate in pairs, and cannot be timed without installation of special timing and recording equipment. Technical -
Specifications specify the minimum time for rod insertion. Should either the scram insert valve, 1 BF-XV-126, or scram exhaust valve, 1 BF-XV-127, fail to operate in a timely manner the CRD(s) will not be able to meet the Technical Specification requirements and the licensee will take corrective action. These valves cannot be exercised without causing the associated control rod to scram and must operate properly so the associated control rod meets the scram insertion time limits. Verification of rod drop times within specification adequately ensures operational readiness of these valves and provides a reasonable alternative to the Code requirements. This testing is in accordance with NRC Generic Letter 89 04, ' Guidance on Developing Acceptable Inservice Testing Programs,' Attachment 1, Position 7.
The licensee has proposed an alternate exercising frequency the same as required by Technical Specifications which tests all control rods prior to thermal power exceeding 40% of rated thermal power following core alterations or after a reactor shutdown that is greater than 120 days and at least 10% of the control rods, on a rotating basis, at least once per 120 days of power operation. This exercising frequency tests these valves as frequently as practicable while reducing wear on the control rod drive mechanisms and the number of rapid reactivity transients to which the reactor core is exposed. This exercise frequency provides a reasonable alternative to the Code requirements and is in accordance with Generic
. Letter 89 04.
51
Since the licens'ee's proposed testing is in accordance with NRC Generic Letter No. 89 04, Attachment 1, Position 7, relief is granted from the Code ,
requirements as requested. .
l i
l 4.6.2 Cateaory C Valves '
4.6.2.1 Relief Reauest. The licensee has requested relief from the Section XI, Faragraph IW-3521, exercising frequency requirement for the control rod drive scram check valves,1-BF-Vll4 (185 HCU's) and proposed to full-stroke exercise these valves during control rod scram insertion time )
testing per HCGS Technical Specifications. I I
4.6.2.1.1 Licensee's Basis For Reauestino Relief -Scramming of the control rods would be required to exercise these valves. Relief is therefore requested from these Code requirements.
Alternate Testina: These valves are properly exercised during the rod scram timing tests on the control rods that is performed to satisfy the surveillance requirements of HCGS Technical Specification 4.1.3.2.a on all ,
control rods prior to exceeding 40% of rated thernal power following core alterations or after a reactor shutdown of greater than 120 days; and HCGS Technical Specification 4.1.3.2.c on 10% of the control rods, on a rotating basis, at least once per 120 days of power operation. Control rod scram timing will be used as an indirect measurement of valve stroke time.
Maximum stroke times will be as indicated in Technical Specification 3.1.3.2. Degradation of these valves would be indicated by inadequate scram times. Failure of rods to meet scram timing requirements will result in corrective action.
4.6.2.1.2 Evaluation--Check valve 1 BF Vll4 is located in the scram discharge line and must full-stroke open to allow the control rod to ,
scram in a timely manner. This is verified during control rod scram testing if the associated control rod meets the scram insertion time limits defined-in the Technical Specifications. It is impractical to exercise all these valves each quarter or during each cold shutdown since this would require scram testing all 185 control rods. The licensee has proposed an alternate 52
exercising frequency, the same as required by Technical Specifications, which tests all control rods prior to thermal power exceeding 40% of rated thermal power following core alterations or after a reactor shutdown that is greater than 120 days and at least 10% of the control rods, on a rotating basis, at least once per 120 days of power operation. Exercising these valves causes wear on the control rod drive mechanisms and exposes the reactor core to rapid reactivity transients, which is burdensome to the licensee. The proposed exercise frequency gives adequate assurance of operational readiness, provides a reasonable alternative to the Code requirements, and is in accordance with NRC Generic letter 89-04, Attachment 1 Position 7.
Since the licensee's proposed testing is in accordance with NRC Generic Letter No. 89 04, Attachment 1, Position 7, relief is granted from the Code !
requirements as requested.
4.6.2.2 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV-3521, exercising frequency requirements for the rod drive hydraulic control unit charging water check valves, 1-BF Vll5 (185 HCUs) and proposed to exercise these check valves at refueling outages.
4.6.2.2.1 Licensee's Basis For Recuestino Relief -These components.are not designed for verification of exercise testing during power operation's. Exercise testing these valves during cold shutdown cor.ditions would require extensive preparations.
Alternate Testina: These valves will be exercise tested during each refueling outage by securing both CRD pumps simultaneously, and verifying that each HCU accumulator alara does not annunciate for a period of 2 minutes. Additionally, planned Preventative Maintenance is performed on these components on a 10 year rotating basis.
4.6.2.2.2 Evaluation -The hydraulic control unit charging water header check valves, 1-BF-Vll5, close to maintain inventory in the accumulators on a loss of charging water pressure. It is impractical to exercise these valves closed during power operation or cold shutdown since this requires stopping the drive water pumps, depressurizing the charging 53
. J water header, and monitoring pressure in the accumulators, which is an extensive test. It would be burdensome to require the licensee to perform I this test each cold shutdown since this could result in delay in returning the plant to power operation. Also, in addition to charging water, this header supplies cooling to the control rod drives and to the reactor '
recirculation pumps. Loss of cooling water to the reactor recirculation pumps during power operation could result in a reactor scram. The closure
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ability of this valve is adequately demonstrated via the accumulator pressure decay test. The licensee's proposal to perfom this test each refueling outage should provide adequate assurance of operational readiness i and a reasonable alternative to the Code requirements and is in accordance with Generic Letter 89-04, Attachment 1, Position 7.
Since the licensee's proposed' testing is in accordance with NRC Generic Letter No. 89 04, relief is granted from the Code requirements as requested.
4.7 Neutron Monitorina 4.7.1 Cateoory A/C Valves 4.7.1.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IW 3521 exercising frequency requirements for the tip nitrogen purge check valve, 1-SE-V006, and proposed to full stroke exercise this check valve closed each cold shutdown when the containment is deinerted and each refueling outage.
4.7.1.1.1 Licensee's Basis For Reauestino Relief--This valve is
- located inside primary containment which is inerted with an oxygen deficient i atmosphere and is therefore inaccessible during power operation. Testing during cold shutdowns would require extensive preparations, including ,
deinerting, system isolation, alignment for testing and system restoration g
which is not practical. Relief is therefore requested for this Code l requirement.
l l Alternate Testina: This valve will be exercised closed during cold shutdowns when the containment is deinerted and during refueling outages, 1
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but in no case at intervals less than 3 months. Additionally, credit will j be taken for the exercising closed test every 2 years by satisfactory 1 performance of the 10CFR50, Appendix J, local leakage rate test.
4.7.1.1.2 Evaluation--It is impractical to exercise this tip nitrogen purge check valve quarterly during power operation or during cold shutdowns when the containment is inerted. This valve is located inside the l primary containment which is inert and presents a significant personnel 1 safety hazard due to the lack of oxygen. Purging the containment atmosphere to reduce nitrogen concentration prior to personnel entry,'and subsequent reinerting prior to plant power operations requires a great amount of liquid nitrogen and time. Deinerting the containment atmosphere during each cold I shutdown solely for performing IST would be costly and could delay returning the plant to power, which would be burdensome to the licensee. The licensee's proposal to exercise this valve closed during each cold shutdown when the containment is deinerted and during refueling outages should give adequate assurance of operational readiness and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code exercising frequency is impractical and considering the burden on the licensee if the Code requirements were imposed and since the proposed alternative provides a reasonable alternative to the Code requirements, relief should be granted as requested.
4.8 Safety Auxiliaries Coolina >
4.8.1 Cateaory C Valves 4.8.1.1 Relief Reauest. The licensee has requested relief from the Section XI, Paragraph IWV 3521, exercising frequency requirements for the turbine auxiliary cooling system to safety auxiliary cooling system isolation check valves 1-EG-V029 and -V031. The licensee has proposed to full-stroke exercise these check valves at each refueling outage. ,
55
_ . _ _ _ ___. _ . _ . _ . . ~ - . _ _ - _ _
4.8.1.1.1 Licensee's Basis For Recuestina Relief--These valves are in the return of the turbine auxiliary cooling subsystem (TACS) to the safety auxiliary cooling system (SACS). TACS supplies cooling water to the main turbine and main generator, the reactor feed pump turbine auxiliaries as well as other balance of plant components. Testing of these valves requires isolation of the TACS portion of the SACS which could result in a balance of plant component trip (e.g. main turbine trip due to high bearing oil temperature) causing an unnecessary plant transient with potential damage to those components. Additionally, testing these valves during cold shutdowns is not possible because of the extensive draining operations that must be performed in order to complete the exercise tests. Relief is therefore requested from this Code requirement.
Alternate Testino: These valves will be exercise tested to the requirements of IW 3520 at each refueling outage.
l 4,8.1.1.2 Evaluation--These check valves are in the interface between two important cooling systems. It is impractical to exercise these i valves quarterly at power due to the potential for lots of cooling to a l large number of important plant components, which could lead to major l-equipment damage or a plant shutdown. Exercising during cold shutdowns is also impractical since testing these valves requires extensive system draining and realignment and could result in an extension of the cold shutdown. It would be very burdensome to require the licensee to perform this testing at each cold shutdown. Exercising these check valves at refueling outages should give adequate assurance of operational readiness -
and provides a reasonable alternative to the Code requirements.
Based on the determination that compliance with the Code exercising frequency requirements is impractical and considering the burden on the
, licensee if the Code requirements were imposed and since the proposed alternate exercising frequency provides a reasonable alternative to the Code requirements, relief should be granted as requested.
56 N - . - - _ _ . . - . - - - - _ _ - _
- .. - - - . - . . -- - - ~.
4.9 Reactor Recirculation 4.9.1 Cateoory A/C Valves I 4.9.1.1 Relief Reauest. The licensee has requested relief from the ;
Section XI, Paragraph IWV-3521, exercising frequency requirements for the reactor recirculation pump seal purge water supply valves,1 BB V043 and V047 and proposed to full-stroke exercise these valves closed each cold ,
shutdown when the containment is deinerted and each refueling outage.
4.9.1.1.1 Licensee's Basis For Recuestino Relief These valves are located inside primary containment which is inerted with an oxygen deficient atmosphere and is therefore inaccessible during power operation.
Testing during cold shutdowns would require extensive preparations, i including ceinerting operations, system isolation, realignment for testing l and system restoration which is not practical. Relief is therefore requested for this Code requirement. l Alternate Testing: This valve will be exercised closed during cold shutdowns when the containment is deinerted and during refueling outages, but in no case at intervals less than 3 months.
4.9.1.1.2 Evaluation--It is impractical to exercise these valves quarterly during power operation or during cold shutdowns when the containment is inerted. They are located inside the primary containment which is inert and presents a significant personnel safety hazard due to the lack of oxygen. Purging the containment atmosphere to reduce nitrogen concentration prior to personnel entry, and subsequent reinerting prior to plant power operations, requires a great amount of liquid nitrogen and time. Deinerting the containment atmosphere during each cold shutdown '
solely for performing IST would be costly and could delay returning the plant to power, which would be burdensome to the licensee. The licensee's proposal to exercise these valves closed during 'ench cold shutdown when the containment is deinerted and during refueling outages should give adequate
, assurance of operational readiness and provides a reasonable alternative to the Code requirements.
57
l Based on the determination that' compliance wiu the Code exercising l frequency is impractical and considering the burden on the licensee if the Code requirements were imposed and since the proposed alternative provides a reasonable alternative to the Code requirements, relief should be granted as requested.
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APPENDIX A VALVES TESTED DURING COLD SHUTDOWN e
A-1
I APPENDIX A -
l VALVES TESTED OURING COLD SHUTDOWN I l
The following are Category A, B, and C valves that meet the exercising i requirements of the ASME Code,Section XI, and are not full stroke exercised j every 3 months during plant operation. These valves are specifically
]
identified by the owner and are full stroke exercised during cold shutdowns I and refueling outages. The staff has reviewed all valves in this appendix )
and agrees with the licensee that testing these valves during power !
operation is not practical due to the valve type, location, or system design. These valves should not be exercised during power operation. These valves are listed below and grouped according to their Code Category and j system in which they are located. i
- 1. MAIN STEAM AND DRAINS 1.1 Cateaory A Valves The main steam isolation valves (MSIV),1 AB HV 3631A, 3631B, -36310, ,
and 36310, are not designed to close during power operation against steam flow and valve / seat damage would occur if closed against flow. These valves are not designed for partial stroking. Closure of these valves during power '
operations would subject the plant to unnecessary transient with the
. potential for reactor scram. These valves will be full stroke exercised during cold shutdowns and refueling outages.
Exercise and stroke time testing of the inboard and outboard main steam isolation valves,1-AB-HV-F022A, -F022B, F0220, F0220, F028A, F028B, F0280, and, F0280, during power operation provides the potential for ;
reactor scram based on high steam flow of the other main steam lines, which will cause a MSIV isolation, followed by not-full open reactor protection system logic scram; or at a minimum, force a significant load reduction to permit testing. The fail-safe testing of the outboard MSIVs cannot be performed at the 3 month frequency because these valves are located in the steam tunnel, which is a high radiation area during power operation. Entry A3
,. ,,-v , - - - , , , ~, + , , , , , - , -n v - , -- , - , -
8 .
- into the steam tunnel during power operation also poses a personnel hazard from the high temperature environment. These valves will be full stroke exercised during cold shutdowns and refueling outages.
1.2 Cateoory C Valves The M51V accumulator check valves, 1-AB V055. -56, 57,-58, are located in the steam tunnel which is a high radiation area which is inaccessible during power operation. Entry into the steam tunnel during power operation also poses a personnel hazard from the high temperature .
environment. Isolation of these valves for testing will cause a MSIV closure, subjecting the plant to an unnecessary transient with a high probability for a reactor scram. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
I The location of excess flow check valves,1-AB XV 1072A and 1072B, would subject personnel to high radiation exposures as these valves are located within the turbine shielding enclosure very close to the main turbine casing. Valve manipulation would be required to reset these valves following testing. These valves will be full-stroke exercised during cold l shutdowns and refueling outages.
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- 2. FEEDWATER l
2.1 Cateoory A/C Valves Closure of the main feedwater check valves, 1-AE HV F032A and -F0328, during power operations would cause fluctuation in the feedwater flow to the reactor pressure vessel causing unnecessary transients including potential ,
reactor scram and reduction of power level. Resumption of flow following valve closure would potentially subject the reactor pressure vessel feedwater nozzles and piping to thermal shock. These valves will be full-stroke exercised during cc*d shutdowns and refueling outages.
Testable feedwater check valves, 1-AE-HV-F074A and -F074B, are equipped with pneumatic operators that provide an air assist to ensure closure upon -
A 4'
- m..
. i reversal of flow, but are not designed to provide the torque required to ?
close the valves against full or partial flow conditions. Closure of these :
main feedwater check valves during power operations would cause fluctuation in the feedwater flow to the reactor pressure vessel (RPV) causing unnecessary transients including potential reactor scram and reduction of l
power level. Resumption of flow following valve closure would potentially ;
subject the RPV feedwater nozzles and piping to thermal shock. The i operators do not open the valves because of the dogged hinge pin design. ,
Due to this design, assessment of operational readiness is not feasible by +
stroke time measurements. Additionally, these valves are located in the steam tunnel during power operation which is a high radiation area. Entry into the steam tunnel during power operation also poses a Tersonnel hazard due to the high temperature environment. These valves will be full stroke exercised during cold shutdowns and refueling outages. ;
3.1 Cateaory A Valves The residual heat removal (RHR) valves listed below, are pressure ;
isolation valves which are boundaries between system high/ low pressure interfaces. Testing these valves during power operation could expose low 4 pressure portions of these systems to a high pressure transient with the potential to damage the low pressure piping and/or components. These valves ,
are interlocked closed during power operation or whenever the reactor pressure is greater than 83 PSIG. (Reference UFSAR Section 7.6.1.2.2.)
These valves will be full stroke exercised during cold shutdowns and refueling outages.
1-BC- HV F008 1-BC- HV F009 l-BC- HV F015^ l BC- HV-F015B l BC- HV F017A 1 BC -HV-F017B l BC- HV-F017C 1 BC HV F017D 1 BC- HV F022 1-BC- HV F023 The RHR valves 1 BC-HV-122A and -122B and 1-BC-HV F146A, F1468,
-F146C, and -F1460 are pressure isolation valves which are boundaries between system high/ low pressure interfaces. Testing these valves during power operation could expose low pressure portions of these systems to a A5 t
high pressure transient with the. potential to damage the low pressure piping and/or components. (ReferenceUFSARpg.9A104). These valves will be , ,
full stroke exercised during cold shutdowns and refueling outages. l 3.2 Cateaory A/C Valves The RHR valves,1-BC HV-F041A, -F0418, -F041C, -F041D, and l 1 BC HV F050A and -F050B, are pressure isolation valves which are boundaries between system high/ low pressure interfaces. Testing these valves during '
power operation could expose low pressure portions of these systems to a ,
high pressure transient with the potential to damage the low pressure piping J and/or components. (ReferenceUFSARpg.9A-104). These valves will be l full-stroke exercised during cold shutdowns and refueling outages. ;
- 4. CORE SPRAY 4.1 Cateaory A Valves l
The core spray valves,1-BE-HV-F005A and -F005B, are pressure isolation valves which are boundaries between system high/ low pressure interfaces.
Testing these valves during power operation could expose low pressure portions of these systems to a high pressure transient with the potential to damage the low pressure piping and/or components. These. valves are ,
interlocked closed during power operation or whenever the reactor pressure is greater than 83 PSIG. (ReferenceUFSARSection7.6.1.2.2.) These valves will be full-stroke exercised during cold shutdowns and refueling outages.
The core spray valves 1 BE-HV-F039A and -F0398, are pressure isolation ,
l valves which are boundaries between system high/ low pressure interfaces.
L Testing these valves during power operation could expose low pressure i portions of these systems to a high pressure transient with the potential to damage the low pressure piping and/or components. (Reference UFSAR pg.
l 9A104.) These valves will be full-stroke exercised during cold shutdowns <
and refueling outages.
A-6
4.2 Cateoory A/C Valves .
l The core spray valves, 1 BE HV F006A and -F0068, are pressure isolation 4
valves which are boundaries between system high/ low pressure interfaces.
Testing these valves during power operation could expose low pressure portions of these systems to a high pressure transient with the potential to damage the low pressure piping and/or components.
(Reference UFSAR pg.
9A 104). These valves will be full-stroke exercised during cold shutdowns and refueling outages.
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- 5. REACTOR RECIRCULATION 5.1 Cateacry A Valves Testing the recirculation pump seal injection valves,1-BF-HV-3800A and
-38008, would require isolation of the reactor recirculation pump seal purge lines. Isolating these lines at power witc. the pumps running would ,
jeopardize the integrity of the seal with potential for unnecessary seal degradation or failure. These valves will be full stroke exercised during ,
cold shutdowns and refueling outages.
- 6. SERVICE WATER ;
6.1 Cateaory B Valves Valves 1-EA HV 2207 and 2346, supply service water to the reactor.
auxiliary cooling system (RACS). Testing these valves during power operation would disable both loops of RACS causing loss of cooling water to ,
the reactor recirculation pump motor air coolers, pump seal and the motor oil coolers, the reactor water cleanup (RWCU) system's non-regenerative heat exchangers, the. RWCU pump seal coolers, as well as the offgas system. All ,
of the above components are important to the safe operation of the plant.
These valves will be full-stroke exercised during cold shutdowns and refueling outages, l
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Valves 1-EA HV-2357A and 23578, discharge service water from their l respective loops to the cooling tower. Testing either of these valves ;
requires isolating its associated loop cooling loads. This is an i undesirable situation especially during summertime with warmer river water temperatures. Although the plant is capable of supplying accident cooling ,
loads with one loop of service water, it is felt that this poses an unnecessary challenge to the plant and safety-related equipment during power ,
operation. These valves will be full stroke exercised during cold shutdowns and refueling outages. *
- 7. REACTOR AUXILIARIES COOLING 7.1 Cateoorv A Valves Valves 1-ED HV-2553, -2554 -2555, and -2556, supply reactor auxiliary cooling system (RACS) to the reactor recirculation pump motor oil and seal coolers. Testing any one of these valves during power operation isolates RACS to both reactor recirculation pumps, which could expose these pumps either motor bearing and/or pump seal failure and cause unnecessary shutdown of the plant. These valves will be full stroke exercised during cold -
shutdowns and refueling outages. ;
7.2 Cateoory B Valves
- Valves 1-ED HV 2598 and -2599 are the RACS supply and return valves to ,
the offgas and radwaste systems. Testing either one of these valves would isolate the cooling water to both feedgas cooler condensers and the offgas refrigeration machine (glycol cooler) increasing the charcoal bed (absorber)
. inlet temperatures to a point where ignition of the charcoal could occur causing an unplanned gaseous radioactive release. These valves will be J full-stroke exercised during cold shutdowns :nd refueling outages.
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- 8. SAFETY AVXILIARIES COOLING 8.1 Cateaory B Valves Valves 1-EG-HV-2522E and -2522F are in the supply of the Safety Auxiliaries Cooling System (SACS) to the Turbine Auxiliary Cooling :
sub System (TACS). TACS supplies cooling water to the main turbine and main generator, the reactor feed pump turbine auxiliaries as well as other balance of plant components. Testing of these valves requires isolation of the TACS portion of the SACS system which could result in a balance of plant a component trip (e.g., main turbine trip due to high bearing oil temperature)- }
causing an unnecessary plant transient and with potential to damage those j components. These valves will be full stroke exercised during cold ,
shutdowns and refueling outages.
-9. MAIN STEAM SEALING SYSTEM 9.1 Cateaory A Valves 5 The main steam sealing system valves, 1-KP-HV-5834A, -58348, -5835A,
. -58358, 5836A, -58368, -5837A, and -5837B, are interlocked closed while i
L high pressure exists in the main steam lines. Testing these valves at power operation could result in overpressurizing the sections of line upstream of .i these valves, and requires placing the plant in an off normal condition by I;
requiring the defeating of the interlocking logic. These valves will be ,
full-stroke exercised during cold shutdowns and refueling outages. ;
- 10. CONTAINMENT INSTRUMENT GAS a '
-10.1 Cateaory A Valves -
Closure of the containment isolation valve,1-KL-HV-5148, isolates the primary containment instrument-gas system to containment. These valves are interlocked and both trains of. the system would be simultaneously removed l
from service. Isolation of the system for the 10 minutes it takes to l l l u
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perform the test (based on actual valve stroke times) increases the-
-. probability of the inboard MSIVs driving partially closed, which will scram the reactor based 'on the MSIV not-full open logic in the reactor protection system. These valves will be full stroke exercised during cold shutdowns 't and refueling. outages.
10.2 Cateaory B Valves Closure of the containment isolation valves,1-KL-HV-5160A, and -51608, ,
isolates the primary containment instrument gas system to containment.
These valves are interlocked and both trains of the system would be.
simultaneously removed from service. Isolation of the system for the 10;
-minutes it takes to perform the best (based on actual valve stroke times)
. increases the probability of the inboard MSIVs driving partially closed, i which will scram the reactor based on~the MSIV not-full-open logic in the !
reactor protection system. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
- 11. MULTIPLE SYSTEMS $
11.1 Cateaory C Valves t
The check valves listed below are located in the steam tunnel during power operation which is a high radiation area. Entry into the steam tunnel during power operation also poses a personnel hazard'due to the high i temperature environment. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
1 KP-V011 1-KP-V020 1-KL-V023 ;
l-KP-V017 1-KP V021 1-KL-V024 '
1-KP-V018 1-KP-V022 1-AE-V127-1 KP-V019- 1-KP-V023 1-AE-V128 L
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.i APPENDIX B t P&ID AND FIGURE LIST :(
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APPENDIX B ]
P&l0'AND FIGURE LIST I The P& ids listed below were used during the course of this review.
I System P&ID Shul Revision [
1 Main Steam M 01-l' 22 l Condensate & Refueling Water Storage M 08 0 1/2 12 Service Water M-10 1 1/3 7 Service Water M 10-1 2/3 14 Service Water M 10 1 3/3 13 Safety Auxiliaries Cooling, Rx. Bldg. M-ll-1 1/3- 8 Safety Auxiliaries Cooling, Rx. Bldg. M ll-1 2/3 14 Safety Auxiliaries Cooling, Rx. Bldg. M-ll-1 3/3 10 Safety Auxiliaries Cooling, Aux. Bldg. M 12-1 5 Reactor Auxil.iaries Cooling M-13-1 .
13 Compressed Air (Service) M-15 0 4/4 13 :
Breathing-Air M-15-1 11 Fire Protection M-22-0 1/7 15- '
Process. Sampling M-23-1 2/2- 5 ,
L Plant Leak Detection , M-25-1 1/3 3 >
Diesel Engine Auxiliaries M-30-1 1/3 10 Diesel Engine Auxiliaries M-30-1 2/3 9 Diesel Engine Auxiliaries M-30-1 3/3 18 Diesel Engine Starting Air 11872210 2 Post Accident Sampling M 38 0 1/2 2 i Post Accident Sampling M-38 0 2/2 5
!. Nuclear Boiler M 41-1 1/2~ 8 Nuclear Boiler M-41 1 2/2 13 '
Vessel. Instrumentation M-42-1 6 l Reactor Recirculation Pump- M-43-1 1/2 9 l Reactor Wtter Cleanup M 44-1 6
Control Rod'Orive Hyd - Part A M 46-1 .6 L- . Control Rod Drive Hyd.- Part B M 47-1 1/2 7 ,
L Standby ~ Liquid Control M-48 1 4 l - Reactor Core Isolation Cooling M-49-1 9 l RCIC Pump Turbine- .
M-50-1 9 J Residual Heat Removal M-51-1 1/2 10 Residual Heat Removal M-51-1 2/2 16 >
Core Spray M-52-1 10 fuel Pool Cooling & Torus Cleanup .M-53-1 1/2 10 Fuel Pool Cooling & Torus Cleanup M-53-1 2/2 15 L High Pressure Coolant Injection M-55-1 11 1.: HPCI Pump Turbine . M-56-1 8 Containment Atmospheric Control M-57-1 9 Containment Hydrogen Recombination M-58-1 2 I
S B-3 a i
System P&ID 1hgit Revision Primary Containment Instrument Gas M 59-1 1/2 6 Primary Containment Instrument Gas M 59-1 2/2 6-Primary Containment Leak Testing .M 60-1 6 Liquid Radwaste Collection M 61-1 -1/2 9
- Liquid Radwaste Collection M 61-1 2/2 10 Solid Radwaste Collection M-66-0 7-Main Steam Isolation-Valve Sealing M 72-1 10 Rx Bldg. and Drywell Chilled Water M 87-1 2/4- 7 Control Area Chilled Water M 90 1 1/3 7 Control Area Chilled Water. M 90-1 2/3 15 Control Area Chilled Water M-90-1 3/3- 12 I
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E APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW 1
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-t APPENDIX C IST PROGRAM ANOMALIES FOUND DURING THE REVIEW Inconsistencies and omissions.in the licensee's program noted during
, the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
- 1. Pump relief request P-1 (see section 3.2.1 of this report) requests relief from the quarterly testing interval for the standby liquid (
control (SLC) pumps and proposes to test these pumps at cold shutdowns.-
l or refueling outages. Since the licensee has not shown that their proposed alternatives would provide an acceptable level of quality and safety, that compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety, or i l
that the Code requirements are impractical. Relief should not be granted.
- 2. Valve relief request V-03 (see section 4.1.3.1 of this report) !
requests relief from the IWV-3420 requirements for containment isolation valves. The-licensee has proposed to leak rate test these '
valves using 10 CFR 50, Appendix J, Type C, leak rate test procedures ,
with assigned administrative leakage. limits. This relief request should be granted provided the licensee complies with the requirements of IWV-3426.~and -3427(a) for these valves.
- 3. Valve relief request V-04 (see section 4.1.3~.2 of this report) g requests relief from the IWV-3420 requirements for containment isolation valves. The licensee has proposed to leak rate test these L valves using 10 CFR 50, Appendix J, Type C, leak rate test procedures with assigned administrative leakage limits. This relief request should be granted provided the licensee complies with the requirements k .. , of IWV-3426 and -3427(a) for these valves.
L '- 4. Valve relief request Y-07 (see section 4.1.5.1 of this report) requests relief from the IWV-3426 and -3427 requirements for various .l containment isolation ' valves. The licensee has proposed to leak rate l
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. . . , i test these valves in groups per plant Technical' Specification leak i rate test _ procedures with assigned administrative leakage. limits. The identified groups contain valves whose leak tightness can be tested ,
individually.- This relief request should be granted provided; (a) valves that can be tested individually are tested in accordance with ,
the Code requirements and (b) maximum group leakage rate limits assigned are reasonable so that corrective action is taken whenever the leak tight integrity of any group-tested-valve is in question.
.+
- 5. . Valve relief request V-10 (see section 4.4.1.1 of this report) ,
requests relief from position indication verification, stroke timing, :
and fail-safe testing the diesel generator lube oil reservior make-up valves. The-licensee has not proposed a reasonable alternative' test.
Obtaining accurate stroke times for these valves is difficult. '
Therefore, interim relief should be granted for a period of one year 1 or until the next refueling outage, whichever is longer, provided the t
- l. licensee ensures that these valves stroke in a timely fashion +
quarterly.
- 6. Valve relief request V-ll (see section 4.1.6.1 of this report) requests relief from stroke timing various enclosed soleniod valves.
L The licensee has not proposed a reasonable alternative test, however, it may be practical to ensure some of these valves stroke against 4 reasonable limit by. observing evidence of valve motion such as system parameter changes. Therefore, interim relief should be granted for a
. period of one year or'until the next refueling outage, whichever is longer, provided the licensee assigns reasonable stroke time limits to-these valves wherever practical, and uses available system responses-
.to ensure these valves stroke within these limits, a
- 7. Valve relief request V-14 requests relief from Category A and B test requirements, however, the licensee has included in the request Category C valves.whose only function is that of pressure relief and a l which are receiving testing in accordance with the Code requirements i.e... relief vafve testing at least once every five years. Those '
valves, which are Category C only, may be deleted from this relief request. [
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- 8. Valve-relief request V-17 requests relief from measuring force or torque for ' testable check valves with operators installed. However, these valves can'be tested via the power operator and measurement of !
force or torque is not necessary.. The staff considers full-stroke exercising these valve'using the air operator to be in compliance with >
the Code providing the air operator strokes the valve to it's full open position. Therefore, this-relief request is not necessary. -
- 9. Valve relief request V-18 (see section '4.1.7.1 of this report) requests relief from measuring the torque delivered to a check valve
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when full-stroke exercising using a mechanical exerciser. The ,
proposed alternate testing'does not obtain adequate information to evaluate these check valves' operational readiness. Since the licensee has not demonstrated it is impracticable or burdensome to l measure force or torque while full-stroke exercising the listed check {
valves and since the proposed alternative does not provide a reasonable alternative to the Code requirements, relief should not be granted.
- 10. .The licensee has proposed to exercise SLC pump discharge check valves, 1-BH-V004 and -V005, during cold shutdowns. These valves are L exercised during testing of the SLC pumps. The licensee has proposed to extend the testing interval for the SLC pumps (see Appendix C, Item 1, of this report), however, this relief request has been A
! denied.. These valves should be tested quarterly during testing of the SLC pumps.
11._ Pump relief request General Pump I (see section 3.1.1 of this report)
L requests relief from the requirements of IWP-4110 and -4120 regarding instrument accuracy and full-scale range.and requests to use these two i h requirements in unison, such that if any given instrument exceeds one 1< .t L. of the two requirements, the other requirement will proportionally
's offset it'in the opposing direction.
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- Additional information is necessary for the staff to complete.its review of this relief request. The licensee.should provide.-
information to identify each affected pump, the parameter.being :
measured, the range and accuracy of the instrument, and the reference .,
value. = Also, if there is a specific problem with meeting the range !
requirement, such as an operating flow rate that is greater than three -
times- the reference flow rate, this problem should be described. ;
Relief should be granted for an interim period of six months until this ' relief request review is completed.
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