ML20085K111

Pump & Valve IST Program,Rev 14,Second Ten-Yr Interval

ML20085K111
Person / Time
Site:	Callaway
Issue date:	01/31/1995
From:	Jennifer Davis, Dibiasio A, Grove E BROOKHAVEN NATIONAL LABORATORY
To:
Shared Package
ML20085J978	List: ML20085K111
References
CON-FIN-L-2301 TAC-M90030, NUDOCS 9506230147
Download: ML20085K111 (73)

Text

.

\\

TECIINICAL EVALUATION REPORT Callaway Nuclear Plant Union Electric Company Pump and Valve Inservice Testing Program Revision 14, Second Ten-Year Interval Docket Number: 50-483 TAC Number: M-90030 Prepared by:

J. F. Davis, E. J. Grove, and A. M. DiBiasio Engineering Technology Division Department of Advanced Technology Brookhaven National Laboratory Upton, New York 11973 Prepared for:

Division of Engineering Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 FIN L-2301, Task Assignment 13 January 1995 9506230147 950602 PDR ADOCK 05000483 P

PDR

.i.

ABSTRACT

..This report presents the results of Brookhaven National Laboratory's evaluation of the pump and valve I

relief requests, cold shutdown and refueling outage justifications and, for selected systems, a review of 1:

the scope of the Callaway Nuclear Plant, ASME Section XI Pump and Valve Inservice Testing Program.

I i

l:

I l

iii o

.%I TABLE OF CONTENTS P.aga ABSTR ACT iii i

. l.0 INTRODUCTION 1

.2.0' PUMP R'ELIEF REQUESTS 2

2.1 Residual Heat Removal Pumps 2-2.2 Emergency Fuel Oil Transfer Pumps........................

-3

+

2.3 Centrifugal Charging Pumps 4-2.4 Auxiliary Feedwater Pumps........................

4-3.0 VALVE IST PROGRAM RELIEF REQUESTS.....................

6

.i 3.1 Generic Valve Relief Request 6

f 3.2 -

Emergency Core Cooling System (ECCS)..................

7 3.3 Standby Diesel Generator System..........................

8 4.0 DEFERRED TESTING JUSTIFICATIONS..........

10 5.0 IST PROGRAM ' RECOMMENDED ACTION ITEMS..................

65

6.0 REFERENCES

70 APPENDIX A: LIST OF REFERENCE.9RAWINGS............

A-1 I

i 4

I 1

1 V

1 i.

l

.e w

-,u.

LIST OF TABLES 4.1 "Justi5 cation of Deferrals" -

31 i

vi

Technical Evaluation Report Callaway Nuclear Plant Pump and Valve Inservice Testing Program Second Ten Year Program Revision 14 i

1.0 INTRODUCTION

Contained herein is a technical evaluation report (TER) of Revision 14 of the ASME Section XI Second Ten Year Program for pump and valve inservice testing (IST) submitted to the U.S. Nuclear Regulatory Commission (NRC) by Union Electric Company for its Callaway Nuclear Plant on July 14,1994 (Ref.1)._ The program for this second ten year interval is based on the requirements of I

Section XI of the ASME Boiler and Pressure Vessel Code,1989 Edition (Ref. 2). The 1989 Edition of Section XI provides that the rules for inservice testing of pumps and valves are as specified in ASME/ ANSI OMa-1988, Parts 6 and 10 (Refs. 3,4), respectively.

This program revision supersedes all previous submittals. The Callaway Nuclear Plant is a Westinghouse Pressurized Water Reactor (PWR) of the Standardized Nuclear Unit Power Plant System (SNUPPS) design which began commercial operation on December 19, 1984. The second ten year inspection interval is defined for the Callaway Nuclear Plant as beginning December 20, 1994 and ending December 19,-2004.

Title 10 of the Code of Federal Regulations, {50.55a j(f) (Ref. 5) requires that inservice testing of ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of the i

ASMI' Boiler and Pressure Vessel Code and applicable addenda, except where specific relief has i

been requested by the licensee and r, ranted by the Commission pursuant to $50.55a 1(a)(3)(i),

(a)(3)(ii), or (f)(6)(i). Union Electric Company has requested relief from certain ASME Section XI testing requirements. A review of the relief requests was performed using Section 3.9.6 of the Standard Review Plan (Ref. 6), Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," (Ref. 7), the Mieutes of the Public Meeting on Generic Letter 89-04, dated October 25,1989 and September 26, lW: (Refs. 8,9), and information in Draft NUREG-1482,

" Guidelines for Inservice Testing at Nuclear Power Plants," (Ref.10). The IST Program requirements apply only to component (i.e., pump and valve) testing and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements.

Because Section 50.55a does not apply to non-Code components, relief requests for such components do not require NRC approval and, therefore, are not included in this TER.

Section 2.0 of this report presents the evaluation of four of six pump relief requests submitted.

Section 3.0 presents the evaluations of.three of eight valve relief requests submitted. The two other pump and five other valve relief requests are authorized by Generic Letter 89-04 and, consequently, are not specifically evaluated in this Technical Evaluation Report. However, any anomalies associated with these relief requests are addressed in Section 5 of the report. The evaluation of 50 Justifications for deferral are presented in Section 4.0 in Table 4.1. Section 5.0 summarizes the 3

actions required of the licensee resulting from the TER evaluations of the relief requests, the deferral justifications, a systems review, and programmatic aspects while Section 6.0 lists the references.

1 1

2.0 PUMP RELIEF REQUESTS In accordance with 650.55a, Union Electric Company has submitted six relief requests for pumps at the Callaway Nuclear Plant which are subject to inservice testing under the requirements of OMa-1988, Part 6. All of these relief requests have been reviewed to verify their technical basis and determine their acceptability. Two of the requests are in accordance with Generic Letter 89-04 Position 9 and are not evaluated below (i.e., PO3 and PO9). Although, Callaway's IST Program was written to comply with the 1989 Edition of Section XI, which was not addressed in GL 89-04, the Code was not revised concerning pump testing frequency and the alternative discussed in Position 9 remains acceptable. The relief requests indicate that the guidance delineated in GL 89-04, Position 9, is followed. Therefore, these two relief requests are approved in accord with GL 89-04 pursuant to 10 CFR 50.55 a(g)(6)(i) [now 10 CFR 50.55a(f)(6)(i)]. The other four relief requests, along with the technical evaluation by BNL, are summarized below. The pumps evaluated are in the Residual Heat Removal, Emergency Fuel Oil, Chemical and Volume Control, and Auxiliary Feedwater systems.

2.1 Pump Relier Request #P01: ResidualIIeat Removal Pumps A and B ReliefRequest: Relief is requested from OMa-1988, Part 6,14.6.1.2(a) which requires that the full-scale range of each analog instrument shall not be greater than three times the reference value.

Proposed Alternate Testing The licensee's proposed alternate testing is to use the present permanently installed discharge pressere gauges.

Licensee's Basisfor Relief; The licensee states that: " Pump discharge pressure is compared to pump suction pressure to determine pump differential pressure. Reference values for discharge pressure for these pumps are between 200 psig and 300 psig. This would require a discharge pressure gauge of 0-600 psig maximum. The accuracy required for this gauge would be 2% of 600 psig which is i 12 psig. The permanent discharge pressure gauges we have installed are 0-700 psig with a tolerance less than 12 psig. Although the permanent instruments are above the maximum range limits they are within the accuracy requirements and are therefore suitable for the test."

Evaluation: The licensee has requested relief from the full scale range requirements for the analog gauges measuring discharge pressure for the residual heat removal pumps. OMa-1988, Part 6, i 4.6.1.2 requires that the range for this instrument be three times the reference value or less. The licensee's installed instrumentation has a range that is 31/3 times the reference value.

Relief may be granted when the combination of the range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., i 6% of reference value). As addressed by the licensee, the permanent discharge pressure gauges installed are 0-700 psig with a tolerance less than i 12 psig while a Code acceptable gauge would be 2% of 600 psig which is i 12 psig. The combination of the expanded instrument range and accuracy for the installed instrumentation meets the intent of the Code.

Based upon the use of the installed pressure instruments providing an acceptable level of quality and safety, it is recommended that the proposed alternate be authorized pursuant to 650.55a 1(a)(3)(i). In the event these instruments are replaced, the new instruments should comply with the Code range and accuracy requirements.

2 t

2.2 Pump Relief Request #P02: Emergency Fuel Oil System Transfer Pumps A and B ReliefRequest. Relief is requested from OMa-1988, Part 6,15.2(d) for measuring vibration on the emergency fuel oil system transfer pumps.

Preposed Alternate Testing: The licensee's proposed alternate testing is to only measure pump differential pressure and flow rate quarterly.

Licensee's Basisfor Relief The licensee states that: " Diesel generator fuel oil transfer pumps are submersible pumps. Vibration cannot be measured on the submersible pumps."

Evaluation: The function of the emergency fuel oil system transfer pumps A and B (PJE01 A and PJE018) is to provide fuel oil to the standby diesel generators. Each fuel oil transfer pump feeds its own day tank. The pumps, which sit at the bottom of the tank, are submerged in the diesel fuel oil storage tanks and are cooled and lubricated by the working fluid. Emergency fuel oil tank level and pump outlet pressure and day tank level are measured, and as surmised from P&lD M-22JEOl(Q)-7,

" Emergency Fuel Oil System", these measurements are used to determine differential pressure and flow rate. The licensee has classified these pumps as Code Class 3.

Both the pump and motor are submerged in the diesel oil and are not accessible for vibration measurements. The pump outlet piping is the only component available for vibration measurements.

However, taking vibration measurements on the outlet piping is unlikely to provide information that is indicative of pump mechanical condition because of the distance from the source and lack of any correlation. Changes in differential pressure and flow rate would be indicative of internal blockage.

However, external vibration that is indicative of bearing wear, is not accounted for.

Lack of instrumentation is generally not sufficient justification for not complying with the Code requirements. However, due to the location and design of the diesel fuel oil transfer pumps, it is impractical to measure vibration amplitude. A complete redesign of the diesel fuel oil transfer system would be required to meet the Code requirements. To require the licensee to make system modifications to allow the measurement of vibration amplitude would impose a hardship without a compensating increase in the level of quality and safety. However, the licensee must develop some plan to obtain data on bearing degradation.

It is recommended that the licensee investigate alternative schemes for determining bearing wear such as: (1) the institution of a maintenance program for these pumps which would include provisions to inspect the pump bearings and perform maintenance when the storage tanks are drained (e.g., once every ten years as recommended by Regulatory Guide 1.137) and the bearings are accessible; (2) the future installation of accelerometers on an appropriate pump location following draining of the tanks

. to obtain an acoustic signature of the pumps while submerged and correlate that to vibration amplitude; and, (3) any other scheme that would determine bearing wear.

In view of the foregoing, it is impractical to implement the Code requirements for the submerged pumps. Therefore, it is recommended that interim relief be granted in accordance with 10CFR50.55a(f)(6)(i), for a period of one year, or until the next refueling outage, whichever is later, on the basis of the impracticality of immediately imposing Code requirements. Measuring differential pressure and flow rate should provide assurance of the pumps operational readiness in the interim.. The licensee should subsequently revise and resubmit this relief request to indicate an 3

alternative course of action, such as the institution of a regular maintenance and spare parts program for these pumps which includes provisions to inspect the pump bearings and perform maintenance when the storage tanks are drained and the bearings are accessible.

2.3 Pump Relief Request #P06: Centrifugal Charging Pumps A and B ReliefRequest Relief is requested from the OMa-1988, Part 6,14.6.1.2(a) which requires that the full-scale range of each analog instrument shall not be greater than three times the reference value.

Proposed Alternate Testing The licensee's proposed alternate testing is to use the present permanently installed suction pressure gauges.

Licensee's Basisfor Relief The licensee states that: " Reference values for suction pressures for these pumps are between 30 psig and 40 psig. This would require suction pressure gauges of 0-90 psig maximum. The accuracy required for this gauge would be 2% of 90 psig which is i 1.8 psig.

The permanent suction pressure gauges we have installed are 0-150 psig i 1.0 psig. Although the permanent instruments are above the maximum range li. nits, they are within the accuracy requirements and are therefore suitable for the test."

Evaluation The licensee has requested relief from the full scale range requirements for the analog gauges measuring suction pressure for the centrifugal charging pumps. OMa-1988, Part 6,14.6.1.2 requires that the range for this instrument be three times the reference value or less. The licensee's installed instrumentation has a range that is five (5) times the reference value.

Relief may be granted when the combination of the range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., i 6% of reference value). As addressed by the licensee, the permanent suction pressure gauges installed are 0-150 psig i 1.0 psig (or reading accuracy of i 2.5%) while a Code acceptable gauge would be 2%

of 90 psig which is 1.8 psig. The combination of the expanded instrument range and accuracy for the installed instrumentation meets the intent of the Code.

Based upon the use of the installed pressure instruments providing an acceptable level of quality and safety, it is recommended that the proposed alternate be authorized pursuant to $50.55a 1(a)(3)(i). In the evert these instruments are replaced, the new instruments should comply with the Code range and accuracy requirements.

2.4 Pump Relier Request #P05: Motor Driven and Turbir.e Driven Auxiliary Feedwater Pumps I A, IB, and 2 Relief Request: Relief is requested from.the OMa-1988, Part 6,14.6.1.2(a) which requires that the full-scale range of each analog instrument shall not be greater than three times the reference value.

Proposed Alternate Testing: The licensee's proposed alternate testing is to vne the present permanently installed suction pressure gauges.

Licensee's Basisfor Relief: The licensee states that: "fut; %m pressure is compared to pump discharge pressure to determine pump differential pressure. Referer.ce values for suction pressures for these pumps are about 15 psig. This would require suction pressure gauges of 045 psig 4

0 maximum. The accuracy required for these gauges would be 2% of 45 psig which is i 0.9 psig.

The permanent suction pressure gauges we have installed are 0-60 psig i 0.t pug. Although the permanent instruments are above the maximum range limits, they are within the accuracy requirements and are therefore suitable for the test."

Evaluation / The licensee has requested relief from the full scale range requirements for the analog gauges measuring suction pressure for the auxiliary feedwater pumps. OMa-1988, Part 6, 4 4.6.1.2 requires that the range for this instrument be three times the reference value or less. The licensee's installed instrumentation has a range that is four (4) times the reference value.

Relief may be granted when the combination of the range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., i 6% of reference value). As addressed by the licensee, the permanent suction pressure gauges installed are 0-60 psig i 0.5 psig (or reading accuracy of i 3.3%) while a Code acceptable gauge would be 2%

of 45 psig which is 0.9 psig. The combination of the expanded instrument range and accuracy for the installed instrumentation meets the intent of the Code.

Based upon the use of the installed pressure instruments providing an acceptable level of quality and safety, it is recommended that the proposed alternate be authorized pursuant to 550.55a 1(a)(3)(i). In the event these instruments are replaced, the new instruments should comply with the Code range and accuracy requirements.

l l

)

l 5

l l

j 3,0 VALVES IST PROGRAM RELIEF REQUESTS In accordance with 550.55a, Union Electric Company has submitted eight (8) relief requests for valves at the Callaway Nuclear Plant which are subject to inservice testing under the requirements of OMa-1988, Part 10. Three (3) of these relief requests have been reviewed to verify their technical basis and determine their applicability. These relief requests, along with their technical evaluation by BNL, are summarized below. The other five (5) relief requests propose a sample disassembly and inspection program as discussed in NRC Generic Letter 89-04, Position 2, dated April 3,1989 and l

have not been specifically evaluated (i.e., EN-01, EN-02, EN-03, EP-02 and FC-01). Callaway's IST Program was written to comply with the 1989 Edition of Section XI. This edition references OMa-1988 Part 10 for valve testing. JiL89-04 does not address Part 10. Part 10, unlike earlier versions of Section XI, discusses disasembly and inspection in lieu of check valve exercising with i

l How. Part 10, however, does not discuss a sampling technique and requires that disassembly be performed each refueling outage. The NRC, as documented in GL 89-04 Position 2, recognized that disassembling all applicable valves each refueling outage may be burdensome and allowed grouping j

j of similar valves and a sampling plan such that one valve of the group is inspected each refueling

)

l outage, with any one valve disassembly not to exceed once every six years. The ASME Code I

Committees have since revised the OM Code to allow a sampling technique (i.e., in the 1994 Addenda). However, this code has not been endorsed by the NRC in 650.55a. The relief is granted in accord with GL 89-04, Position 2, pursuant to 10 CFR 50.55a(g)(6)(i) [now 10 CFR 50.55a(f)(6)(i)] provided the alternative is in compliance with all of the guidance delineated in Position 2. The relief requests indicate that the disassembly and inspection program is in compliance with such guidance, except that the valve grouping identified in EN-02 contains valves of different sizes and service conditions. Therefore, the licensee should revise relief request EN-02 and ensure that the information to support compliance with Position 2 guidance is documented in the IST program for all the requests, as GL 89-04 requests.

3.1 Generic Valve Relief Reauest 3.1.1 Valve Relief Request #V02: All Class A, B, C, Valves Exercised Only During Cold Shutdowns or Refueling Outages.

RelirfRequest The licensee requests relief from OMa-1988, Part 10,14.2.1.9 and j 4.3.2.6 I

concerning the determination of valve operability after corrective action is taken.

j Proposed Alternate Testing: The licensee states the following under the heading of function:

"When corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected prior to startup. A retest showing acceptable operation shall be run following any required corrective actiu before the valve is returned to service."

Licensee's Basisfor Relig The licensee states: "The Plant Technical Specifications provide the requirement and plant conditions necessary for plant startup. The test requirement will be satisfied before the valve is required for plant operability as defined in the Plant Technical Speci6 cations."

Evaluation: It appears that the reason for the licensee's request for relief relates to delaying plant startup to perform corrective action under the Code. Under the 1986 and earlier editions of Section XI, IWV-3417(b), there is a provision that states "When corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup" However, OMa-6

'l 1988, Part 10,14.2.1.9(c) and 14.3.2.6 omit that sentence and state " Prior to returning a repaired or replacement valve to service, a test demonstrating satisfactory operation shall be performed", and, "A retest show.ig acceptable performance shall be run fol!owing any required corrective action before the valee is returned to service", respectively. Therefore, there is no conflict between the plant Technical Specifications and OMa-1988, Part 10, and no NRC approval is required.

3.2 Emernency core Cooline sstem l

3.2.1 Valve Relief Request #V07: All ECCS Parallel-Path Inject 6n Check Valves with Headered Flow Rates j

ReliefRequest The licensee requests relief from OMa-1988, Part 10,14.3.2.4 for verifying full l

open obturator travel using the maximum required accident flow rates.

i Proposed Alternate Testing: The licensee's proposed alternate testing is as follows: "Non-intrusive techniques (NIT) will be used to verify the full open capabilities of these check valves unless an ECCS system flow balance is scheduled to be performed, as required by Technical Specification I

requirements, that demonstrates the check valves are capable of delivering design flow rates."

Licensee's Basisfor Relief The licensee States that: "These Emergency Core Cooling System injection line check valves are installed in parallel flow paths that have permanently installed instrumentation for total header flow rates but not individual branch line flow rates. Generic Letter 89-04 states that verification of total header flow rate might not identify a problem, developing or l

occurring, with an individual check valve in one of the parallel flow paths. An alternate method is I

therefore needed to demonstrate the full stroke capabilities of the check valves.

Each of the individual branch lines are equipped with provisions to install temporary flow instrumentation. However, installation of temporary instrumentation requires considerable manpower resources and would result in additional radiation exposure to plant personnel and an increased likelihood for contamination incidents due to the system breach required. Additionally, several of the check valves (e.g., BB8948A,B,C and D) can not be proven full open by measuring flow rates alone as they were sized for accident flow rates that are impractical to simulate for testing purposes or may jeopardize plant safety (e.g., full blowdown of a Safety Injection Accumulator).

The use of NIT methods are discussed in Generic Letter 89-04 NRC Staff Position I correspondence.

The NIT test equipment consists of accelerometers and data acquisition hardware which can record and detect the presence of an impact between the check valve disc and the backstop. The presence of this impact as flow is initiated through a valve demonstrates the full stroke capability of the check valves. The NIT test equipment will be calibrated to nationally recognized standards at a frequency not to exceed 18 months. Using NIT test methods not only provides an indication of the full stroke capabilities of the subject check valves, but it can also be used to trend the condition of the check valve internals for wear or other anomalies which is an objective of in-service testing programs."

Evaluation: The following ECCS injection check valves are identified in this relief request:

,BV0001,22,40,59 - Centrifugal charging pumps flow to cold legs.

BB8949A, B, C, D

- SI/RHR recirculation flow to hot legs.

EJ8841 A, B

- RHR/SI hot leg recirculation for loops 2 & 3.

7

EM V0001, 2, 3, 4

- SI pumps recirculation flow discharge to hot legs.

EPV0010, 20, 30, 40 - SI pumps injection flow to cold legs.

EP8818A, B, C, D

- RHR pumps injection to cold legs.

BB8948A, B, C, D

- SI, RHR, ACC common injection to cold legs.

All of these check valves are pressure isolation valves. [The only other ECCS injection check valves are the accumulator discharge injection check valves. These check valves are identified in relief request #EP-02 where the licensee has proposed using sample disassembly / inspection at refueling outages.]

The licensee has proposed that each valve will be individually tested by non-intrusive acoustical monitoring at each refueling or cold shutdown, as described in the following cold shutdown and refueling outage justifications. The column on the right gives the deferral justification number.

BBV000),22,40,59 - Centrifugal charging pumps flow to cold legs.

1. BB-04 BB8949A, D

- SI/RHR recirculation flow to hot legs 1 & 4.

1. BB-02 BB89498, C

- SI/RHR recirculation flow to hot legs 2 & 3.

1. BB-03 EJ8841 A, B

- RHR/SI hot leg recirculation for loops 2 & 3.

1. EJ-01 EM V0001, 2, 3, 4

- SI pumps recirculation flow discharge to hot legs. #EM-02 EPV0010,20, 30,40 - SI pumps injection flow to cold legs.

1. EP-03 EP8818A, B, C, D

- RHR pumps injection to cold legs.

1. EP-01 BB8948A, B, C, D

- SI, RHR, ACC common injection to cold legs.

1. BB-01 Justifications for deferral testing are separately evaluated in Section 4 of this TER.

In general, relief is not required for using a nonintrusive test (NIT) program, as discussed in Generic Letter 89-04, Position 1 since these techniques are considered "other positive means" in accordance with OM Part 10, paragraph 4.3.2.4(a). However, the licensee has added the proviso that NIT will not be performed if an ECCS system flow balance is scheduled to be performed, as required by Technical Specification requirements, that demonstrates the check valves are capable of delivering design flow rates. That proviso is acceptable because it is assumed that the licensee will install temporary flow instrumentation for the Tech Spec ECCS flow balance to measure full accident flow rates through each check valve. If that is not the case, the licensee should revise and resubmit this relief request.

3.3 Standby Diesel Generator System 3.3.1 Valve Relief Request #KJ-01: Starting Air Supply Pressure Control Valves ReliefRequest The licensee requests relief from OMa-1988, Part 10,14.2.1.4 for stroke time testing of the diesel generators starting air solenoid valves.

Proposed Alternate Testing: The licensee's proposed alternate testing is to measure diesel starting times and air tank pressure changes.

Licensee's Basisfor Relief: The licensee states that: "These are totally enclosed solenoid valves.

The valves are controlled by the start-stop switch for the diesel. Therefore, stroke time for the valves themselves cannot be measured. Valve stroke time affects diesel start time. Diesel start time 8

will be used to monitor valve performance. Maximum stroke time of 12 seconds will be used since this is the limit for diesel start time. Since both valves actuate when the diesel is started, changes in starting air tank pressures will be monitored to ensure approximately equal pressure decreases to verify both valves actuated properly "

Emluathat These valves (KJPV0001 A, B, and KJPV0101 A, B) open to provide starting air to the emergency diesel generators. The two starting air solenoid valves per diesel are in redundant and independent starting air trains. These valves are totally enclosed solenoid operated valves which have no externally visible indication of valve position. It is not possible to measure the stroke tienes of these solenoid operated valves because there is no way to determine when a valve receives a signal to open or when it reaches the open position. These solenoid valves are rapid acting valves which normally stroke almost instantly and when they do not operate promptly, they most commonly fail to operate at all. It can be indirectly verified that each valve has opened by monitoring the air pressure in the associated air start tank. Measuring the diesel start times gives an indication of possible valve degradation since any significant change in valve stroke time would result in longer diesel generator start times. The full-stroke times cannot be measured for these valves unless system modifications, such as replacing the diesel air start solenoid valves with valves that have valve disk position indication, are made to permit this testing, which would be burdensome for the licensee.

Compliance with the Code required testing method is impractical due to the system design. Based on the impracticality of complying with the Code required testing method and on the licensee's proposed alternate testing of measuring the diesel generator starting times and observing the starting air tank pressures to verify operation of the individual solenoid operated air start valves and to monitor their degradation, it is recommended that relief be granted from the Code requirements, in accordance with 10CFR50.55a(0(6)(i).

l 9

4.0 DEFERRED TESTING JUSTIFICATIONS Union Electric Company has submitted 50 justifications which document the impracticality of testing valves quarterly, during operation, as required by OMa-1988, Part 10. Of the 50 deferral requests, 30 deal with testing deferred to cold shutdowns and 20 deal with testing deferred to refueling outages. The justifications are listed in Table 4.1 and were reviewed to verify their technical basis.

Generally, those tests involving a plant trip, damage to a system or component, or excessive personnel hazards are not considered practical. Removing one train for testing, or entering into a limiting condition of operation is not sufficient basis alone for not performing required tests, unless some other justification is provided, such as that the testing renders systems inoperable for extended periods of time. As discussed in Generic Letter 91-18, it is not the intent ofIST to cause unwarranted plant shutdowns or to unnecessarily challenge other safety systems. Other factors, such as the effect on plant safety or risk, and the difficulty of the test may be considered.

The justifications shown in Table 4.1 have been grouped by systems or by piping and instrument drawing (P&lD) because in some cases more than one system is shown on the P&lD. The anomalies as ociated with the specific justifications are presented in section 5 of this TER.

10

Table 4.1 Callaway Nuclear Plant Justification of Deferrals l

l Item No.

Valve

. Drawing No.

Licensee's Proposed Alternate Identification Justification Testing.

i i

for Deferred Testing i

MAIN STEAM SYSTEM (AB)

AB-01 ABPV0001, 2, 3, 4 P & ID:

" Operating these valves during power Valve will be 8 inch air-operated globe M-22AB01(Q),

operation would cause a decrease in pressure exercised (full valves, Category B, Rev. 8, Main in the respective main steam header. This stroke) to the normally closed, Steam System would introduce a severe transient in the position required to Main steam atmospheric main steam header which is unacceptable fulfill its function, PORVs.

from an operational viewpoint."

stroke timed and fait safe actuation verified during cold shutdown.

Evaluation: These are the steam generators power operated relief valves which may be used to depressurize the secondary plant following a design basis accident event.

It is impractical to part-stroke or full-stroke exercise titese valves quarterly because opening these valves would cause a decrease in pressure and steam flow to the main turbine resulting in a severe transient and likely plant trip.

The alternative testing provides full-stroke exercising and fail safe testing at cold shutdowns in accordance with OMa-1988, Part 10, 14.2.1.2(c) and 14.2.1.6.

s 11

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing -

for Deferred Testing AB-02 ABHV0011,14,17, 20 P & ID:

" Closure of these valves during power This valve will be 28 inch air-operated gate M-22AB02(Q),

operation would introduce a severe transient partially stroked valves, Category B.

Rev. 6, Main in the main steam lines which is quarterly. In normally open, Steam System unacceptable from an operational viewpoint.

addition, valve will Main Steam Isolation Testing by isolating each main steam header be stroke timed (full Valves (MSIVs).

is also possible but would cause a power stroke) to the reduction which is also unacceptable from an position required to operational viewpoint."

fulfill its function at cold shutdown.

Emluation: These are the main steam isolation valves (MSIVs) which prevent uncontrolled blowdown from more than one steam generator. They are located outside of containment and downstream of the S/G PORVs and safety valves; are bi-directional, double disc, parallel slide gate valves.

It is impractical to full-stroke exercise these MSIVs closed quarterly because fu!!y closing any one of these valves intermpts the steam flow to the main turbine resulting in a severe transient and likely plant trip. Although it is possible to isolate each main steam header to perform a test, it would involve a power reduction for some period of time which would be a burden to the licensee. HoweVer, it is possible to part-stroke exercise these valves quarterly without causing a severe transient.

I The alternate testing provides part-stroke exercising closed quarterly and full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(b).

\\

o 12

~

+

w, Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

IJcensee's Proposed Alternate Identification Justification

. Testing for Deferred Testing FEEDWATER SYSTEM (AE)

AE-01 AEV0120,121,122,123 P & ID:

" Exercising these valves during power Each valve of this -

14 inch, Category C, M-22AE02(Q),

operation would require isolation of group will be seat normally open, Rev.17, feedwater to the steam generator which leak tested at Feedwater supply check Feedwater System would result in a severe transient in the refueling to prove -

valves to S/Gs.

steam generator, possibly causing a unit valve closure trip."

capabilities.

Emluation: These main feedwater header check valves are located inside containment and close to prevent blowdown of the steam generators following a feedwater pipe rupture either upstream or downstream of the check valves.

It is impractical to exercise these check valves quarterly because this would involve isolating feedwater flow to a steam generator which would result in loss of steam generator level control, a plant transient, and likely cause a plant trip. It is also impractical to leak test these valves during cold shutdowns because this would involve isolating and pressurizing the steam generators that could delay plant startup; and contaimnent entry may be necessary to verify closure. The licensee had previously opted to use a seat leakage alternate test with sample disassembly / inspection as a backup (Ref.16).

The alternative testing provides full-stroke exercising at reibeling outages in accordance with OMa-1988, Part 10, T 4.3.2.2(e).

13 om.-

w n,

,e n

.-.,n

<un s

-. ~.

x 1

g.,

^

.g:

1 m

Table 4.1 (Cont'd)

Iteen No.D

Valvel

- Drawing No. -

Urseme*'s 5 r

Pasposed AIIernmee J Identification

.-Justification Testing %

- for Deferred Testing -

AE-03 AEV0124,125,126,127 P & ID:

" Exercising these valves would result in.

Exercise check -

4 inch, Category C, M-22AE02(Q), -

feeding cold water into the steam generators.'

valve (full stroke) to normally closed, Rev.17, This is not_ desirable during power operation the position' Auxiliary feedwater supply Feedwater System since flow through these valves would required to fulfill its check valves to S/Gs.

unnecessarily thermally shock the steam function at cold -

generator feedwater nozzles."

shutdown.

Em/mation: These check valves open to pass flow from motor driven and turbine driven auxiliary feedwater pumps to steam generators following isolation of normal feedwater.

It is impractical to part-stroke or full-stroke exercise these check valves open quarterly because this would require establishing auxiliary-feedwater flow into the steam generators and this relatively cold water could thermal shock the feedwater piping and steam generator.

nozzles which could result in premature failure of those cconycnaas.

The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.3.2.2(c).

14.

--.M

.. m

=

m...

.m.

m mwm a

-2

_,.+m_

+ e, e w w - -v tr,s we.

~,

w.,,-a..-e-r-

we.

=$

.w'.

.,.,,w,

.s

.-,w.-

m

~~

c'.'.

N 4

Table 4.1 (Cont'd) -

Itena No.

Valve.

- Drawing No.t uren-e's.

Proposed Alterunte

. Identification Justification t Testing ~

ifor Defemd Testing AE-04 AEFV0039,40,41,42 P & ID:

" Closing these valves during power Valve _will be.

14 inch air-operated gate M-22AE02(Q),

operation is considered impractical from an partially stroked _

valves, Category B, Rev.17, operating viewpoint. Closure would isolate ~

quarterly. Valve normally open, Feedwater System feedwater to the steam generator which may will be exercised Steam generators feedwater result in a severe tr.:nsient in the steam _-

(full stroke) to the supply isolation valves.

generator, possible causing a unit trip."

position required to fulfill its function, stroke timed, and -

fail safe actuation verified at cold; shutdown.

Evaluation: These AOVs isolate main feedwater flow to the steam generators upon receipt of a feedwater isolation signal.

It is impractical to full-stroke exercise these AOVs quarterly because. closure would isolate'feedwater flow to a steam generator which-would cause loss of steam generator level control and a likely plant trip. However, it is practical to part-stroke exercise these valves quarterly.

The alternative testing provides part-stroke exercising closed ' quarterly and full-stroke exercising and fail safe testing at cold shutdowns in accordance with OMa-1988 Part 10,14.2.1.2(b) and 14.2.1.6.

j 15

. ~ ~.

..2

A Table 4.1 (Cont'd)

Item No.

Valve : __

' Drawing No.

Licerisee's.

Proposed Alternate Identification Justifkation

. Testing for Deferred Testing AUXILIARY FEEDWATER SYSTEM (AL)

AL-01 ALV0001, 0002, 0003,10 P & ID:

" Exercising these valves would result in Exercise' check

& 8 inch check valves, M-22AL01(Q),

feeding cold water into the steam generators.

valve (full stroke) to CST to AFW pumps Rev.15, This is not desirable during power operation the position

suction, Auxiliary since flow through these valves would required to fulfill its ALV0030, 0042, 0054, 6 Feedwater System unnecessarily thermally shock the steam function at cold

& 8 inch check valves, generator feedwater nozzles."

shutdown.

AFW pumps discharge, ALV0033, 0036, 0045, 0048,4 inch check valves from motor driven AFW pumps to S/Gs, ALV0057, 0062, 0067, 0072,4 inch check valves from turbine driven AFW pump to S/Gs.

Emluation: These check valves open on flow from the auxiliary feedwater pumps to provide flow to the Steam Generators. ALV0030,-

42,54 close to prevent reverse flow through parallel pumps.

It is impractical to full-stroke exercise these check valves open quanerly because this would require establishing auxiliary feedwater flow into the steam generators and this relatively cold water could thermal shock the auxiliary-feedwater piping and nozzle connections to the feedwater piping which could result in premature failure of those components.

The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10 T 4.3.2.2(c).

16

-a

-.=--.

---

-- =-..r--

-m-

~

e<

y r

I F

/

x Table 4.1 (Cont'd)

< Itema No.

Valvi' Drawing No.'

IJeensee'sa Proposed Alternate'

Identification Justification 1 Testing s

for Deferred Testing REACTOR COOLANT SYSTEM (BB)

BB-01 BB8948A, B, C, D 10 inch P&lD:

"These valves cannot be full or partial stroke Each check valve in Category A/C, normally M-22BB01 W,.

exercised during power operations since this group will be '

closed, Rev.15, Reactor safety injection pump discharge pressure verified to stroke to -

SI, RHR, & Accumulator Coolant System cannot overcome reactor coolant system its full open common injection check pressure.

position by.

valves to RCS cold legs.

determining that the Valves cannot be full stroke exercised with~

valve disc strikes its accident required flow during cold shutdown backseat using since the residual heat removal pumps cannot Acoustic '

j provide accident required flow rates through.

Monitoring.

,j the valves. Accident required flow rates equipment. This would require injection from the will be performed-'

accumulators which cannot be done due to on a refueling.

cold overpressurization concerns."

fisixxy. See Alternative to -

Check Valve Full Flow Testing -

Justification #V07.'

r,-

h i

h 17

-.. _. - _ _,.. - -. - - -. _. a-.

-~....

- ~ ~... _ _. ~_,. _ _..

,~.

m m

a

-t

, :w i

p i

Table 4.1 (Cont'd) n

ItesaNE.-

Valve ~

i Drawing No..

IJeansee's.

Preposed Alternate

' Identineation

Justincation

Testing '

for Deferred Testing Emluation: These valves open on flow from the cold leg accumulators, safety injection pumps, or residual heat removal pumps to provide flow to the reactor coolant system cold legs. These check valves are also pressure isolation valves and are required to be within.

the leakage limits given in Table 3.4-1 to Technical Specification 4.4.6.2.2.

As discussed by the licensee it is impractical to part-stroke or full-stroke exercise these valves open quarterly using the safety injection pumps, or accumulators, or residual heat removal pumps because their discharge pressure cannot overcome reactor coolant system pressure. It is impractical to full-stroke exercise these valves at cold shutdowns because the residual heat removal pumps cannot provide '

the required accident flow rates and would need to be supplemented by the accumulators, which is not allowed due to cold overpressurization concerns. The licensee will full flow test these valves using nonintrusive acoustical monitoring at refueling outages.

i (See relief request #V07).

The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988, Part 10,1 14.3.2.2(e).

l l

1g; s.

,, + - -

e,-,,

r,-,--.,~

-.,,v.

...w-

-e4,

1. -v..-

... < ~.

.e r-w-,

.v

,,-lvi_.<

,,,~,,v,,,,.-+-

- +,

~,-

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing BB-02 BB8949A, D P & ID:

" Valves cannot be full or partial stroke Exercise check 6 inch check valves, M-22BB01(Q),

exercised during power operation since the valve (full stroke) to Category A/C, normally Rev.15, Reactor only flow path discharges into the reactor the position

closed, Coolant System coolant system. Safety injection pump required to fulfill its Sl/RHR recirculation flow discharge pressure cannot overcome reactor function at to hot legs 1 & 4, Train B coolant system pressure. During cold refueling.

shutdown these valves cannot be full or partial stroke exercised since this could result in a low temperature overpressurization of the reactor coolant system."

Evaluation: These valves open to provide hot leg recirculation flow from the safety injection pumps from RHR heat exchanger B. These check valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 to Technical Specification 4.4.6.2.2.

As discussed by the licensee it is impractical to part-stroke or full-stroke exercise these valves open quarterly using the safety injection pumps because their discharge pressure cannot overcome reactor coolant system pressure. It is impractical to full-stroke exercise these valves at cold shutdowns because this could result in a low temperature overpressurization of the reactor coolant system. The licensee will full flow test these valves using nonintrusive acoustical monitoring at refueling outages. (See relief request #V07).

The alternative provides full-stroke exercising to the open position during refreling outages in accordance with OMa-1988, Part 10, 14.3.2.2.(e).

19

Table 4.1 (Cont'd)

Item No.

Valve Drawing No. -

Licensee's Proposed Alternate Identification Justification

. Testing for Deferred Testing BB-03 BB8949B, C P & ID:

" Valves cannot be full or partial stroke Exercise check 6 inch check valves, M-22BB01(Q),

exercised during power operation since the valve (full stroke) to Category A/C, normally Rev.15, Reactor only flow path discharges into the reactor the position

closed, Coolant System coolant system. Residual IIeat Removal required to Sl/RIIR recirculation flow Pump Discharge Pressure or Safety injection fulfill its function at to hot legs 2 & 3, Train A Pump Discharge Pressure cannot overcome cold shutdown.

reactor coolant system pressure."

Emluation: These valves open to provide hot leg recirculation flow from the safety injection pumps from RHR heat exchanger A. These check valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

As discussed by the licensee it is impractical to part-stroke or full-stroke exercise these valves open quarterly using the safety injection pumps or the residual heat removal pumps because their discharge pressure cannot overcome reactor coolant system pressure. Train A differs from Train B (#BB-03) in that there is an additional connection for the RIIR pumps to feed directly into the RCS. Consequently, the chance of overpressurization at a cold shutdown is much less with an RHR pump than a Si pump. The licensee will full flow test these valves using nonintrusive acoustical monitoring at cold shutdowns. (See relief request #V07).

The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.3.2.2(c).

l 20 l

=

Table 4.li (Cont'd)

Iten No.

Valve.

Drawing No.~

. Licensee's Proposed Alternate Identification

_ - Justification Testing for Deferred Testing BB-04 BBV0001, 22, 40, 59 P & ID:

" Operating these valves would require using Exercise check 1.5 inch check valves, M-22BB01(Q),

a centrifugal charging pump to provide flow, valve (full stroke) to Category A/C, normally Rev.15, Reactor which would result in injection of borated the position

closed, Coolant System water into the Reactor Coolant System required to fulfill its Centrifugal charging pump thereby causing a power decrease and function at flow to cold legs.

thermal shock to the reacter coolant piping.

refueling.

During cold shutdowns exercising this valve could result in a low temperature overpressurization of the reactor coolant system."

Evaluation: These valves open on flow from the centrifugal charging pumps (CCPs). These check valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

The normal flow path for the CCPs to the injection check valves to the RCS cold legs is via the boron injection tank (BIT). The SER of October 26,1987 (Ref.16) indicates that the BIT tank at Callaway has as low as O ppm boric acid concentration. Hence, any increase in boron concentration would have to come from a realignment to the RWST. However, cold water from either the BIT tank or RWST could cause thermal shock to the RCS piping and injection nozzle connections. It is, therefore, impractical to part-stroke or full-stroke exercise these valves open quarterly. It is impractical to part-stroke or full-stroke exercise these valves at cold shutdowns because this could result in a low temperature overpressurization of the reactor coolant system. The licensee will full flow test these valves using nonintrusive acoustical monitoring at refueling outages. (See relief request #V07).

The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988, Part 10, 14.3.2.2(e).

21

I Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's NRJ Alternate Identificatit f Justification Testing for Deferred Testing BB-05 BBIIV8001 A, B, and P & ID:

"If stroked during operation, failure of a Valves will be BBIIV8002A, B M-22BB04(Q),

valve in the open position would put the exercised and stroke 1 inch solenoid operated Rev. 6, Reactor reactor in a potential small break LOCA timed at cold globe valves, Category B, Coolant System situation. Stroking one of these valves open shutdowm.

normally closed, would result in relying on one valve for RCS Reactor Vessel IIead Vent pressure boundary. Also, no matter what j

Valves.

sequence of testing is used, exercising these valves would result in venting out some RCS water directly to the containment atmosphere. This would necessitate installation of a vent rig to control the effluent. The vent is not accessible for

)

installation of a vent rig due to radiation concerns during operation."

Emluation: These SOVs are the reactor vessel head vent valves (or high point vent valves on the RCS).

It is impractical to exercise these valves to the open position quarterly because testing of these valves during power operation could jeopardize the integrity of the RCS pressure boundary by having only one of the valves closed while the other is open tested. The chance I

for a small break LOCA would thereby be increased.

The alternate testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

1 L

22 l

______._____._.______.______..m_s.

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing BB-06 BBPV8702A, B P & ID:

"These valves have an interlock which Valve will be 12 inch motor operated gate M-22BB01(Q),

prevents their opening when Reactor Coolant exercised (full valves, Category A, Rev.15, Reactor System pressure is above approximately 360 stroke) to the normally closed, Coolant System psig to prevent over-pressurization of the position required to RHR pumps suction RIIR system."

fulfill its function isolation valves.

and stroke timed during cold shutdown.

Evaluation: These valves open to provide suction to residual heat removal (RIIR) pumps during normal unit cooldown. They are interlocked with MOVs EJHV8701A, B to prevent opening at an RCS pressure > 360 psig. These valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

As discussed by the licensee it is impractical full-stroke exercise these valves open quarterly because they are interlocked which prevents their opening when RCS pressure is above 360 psig to prevent overpressurization of the RHR system.

The alternate testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10, j 4.2.1.2(c).

23

>L N

1 Table 4.1 - (Cont'd)

Iteam No.

Valve J i Drawing No. -

Licensee's -

Proposed Alternate

. Identification Justification

Testing for Deferred Testing BB-07 BBV0118,148,178, 208 P & ID:

" Closure testing requires isolation of RCP ~

Verify valve' closure 1.5 inch, Category A/C, M-22BB03(Q),

seal injection which could cause RCP seal during performance normally open, Rev.10, Reactor failure and a subsequent LOCA."

of leak rate test ~

RCP seal water supply Coolant System during refueling.

upstream (inboard) isolation check valves.

Emluation: These check valves are inboard containment isolation check valves (for penetrations P-22. -39,-40, -41) for the seal water supplies to the RCPs.

It is impractical to full-stroke exercise these simple check valves closed quarterly because this requires isolation of RCP seal injection -

flow which could cause RCP seal failure and a subsequent LOCA. In accordance with OMa-1988, Part 10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. It is impractical to perform a seat leakage test during cold shutdowns with the reactor coolant pumps secured because this would require containment entry. Containment access for testing presents a personnel safety' hazard due to high radiation levels likely to be experienced by personnel during the test setup and test, and, proximity to high energy '

systems.

The alternative provides full-stroke exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10, T4.3.2.2(e).

9

- 24 e

e

-.,,,w,.-

-,n w

n.-

,m

+

+.

..,,,~,,,,,,a c--

--e

- - + -, -

< - - -,i-r..,---.,.~,,:..,,.<,-

,w-,-w'

y< g 3.

c

.7 y

m

.,e r

i-

-).

Table 4.1. (Cont'd) o

- Itesa No.

. Valvei

- Drawing No?

h 's Proposed Altensee

,s

' 14=tification

. Justification

Testing

- for Deferred Testing ' ~'

l BB-08 BBHV0013,14,15,16 P & ID:

" Failure of this valve in the closed position.

Valve will be _

3 inch motor operated gate M-22BB03(Q), -

during testing would inhibit flow to the exercised (full i

valves, Category B, Rev.10, Reactor reactor coolant pump thermal barriers. - This stroke) to the normally open, Coolant System could result in unit shutdown and possible' position required to :

CCW supply to RCP damage to the reactor coolant pump seals -

fulfill its function thermal barrier cooling coil and pump radial bearings."

and stroke timed outlet isolation valves.

during cold shutdown.

Emluation: These valves isolate flow to the four reactor coolant pump thermal barrier cooling coils. These isolation valves close upon receipt of a containment isolation signal (CIS-R).

It is impractical to full-stroke exercise these valves quarterly because this would interrupt component cooling water (CCW) flow to the RCP thermal barrier cooling coils, thereby creating the potential for damage to the RCPs' seals and radial bearings. However, the -

licensee proposes to perform the full-stroke exercise at cold shutdowns. The conditions for potential damage appear to still be there.-

unless the RCPs have been secured.

The licensee should review this deferral and address the potential (if any) for RCP damage if the full-stroke exercising is performed at cold shutdowns when the RCPs are running. (See deferral #BB-11.)

k i

---

_----,.-,.--.w

-s.,

v.

-,.nn.s..--.N.,~n vG

.,*A-m-o-n-

--~w w.w-

~

ae

.. A a-

.n.~~

Table 4.1 (Cont'd) i Ite:a No.

Valve Drawing No.

Licensee's -

Proposed Alternate Identification Justification Testing fer Deferred Testing -

BB-10 BBPCV0455A,456A P & ID:

"The PORVs, BBPCVG155A and Valve will be 3 inch solenoid operated M-22BB02(Q),

BBPCV0456A, should not be opened during exercised (full globe valves, Category B, Rev.15, Reactor normal operation. If they are opened, it stroke) to the normally closed, Coolant System could cause depressurization of the RCS and position required to RCS Pressurizer Power too rapid of a pressure transient. If the fulfill its function Operated Relief Valves.

PORV block valves are closed, there is not and stroke timed enough pressure to open the PORVs."

during cold shutdown.

Evaluation: These valves are the pressurizer power operated relief valves (PORVs).

It is impractical to part-stroke or full-stroke exercise these valves to the open position quarterly because this could result in a depressurization of the RCS and a rapid pressure transient likely to cause a plant trip and if a PORV sticks open a loss of coolant accident would ensue. Generic Letter 90-06 states that testing of the PORVs should not be performed during power operation due to the risk associated with challenging these valves in this condition.

The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

l l

l l

26

-. - ~.~.-

Table 4.1 (Cont'd)

Item No.

Valve -

Drawing No.

. Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing BB-11 BBV0122,152,182, 212 P & ID:

" Testing these check valves in the Valves will be BBV0474, 476, 479, 480 M-22BB03(Q),

safety-related closed direction dictates exercised to their 2 inch and 1.5 inch, Rev.10, Reactor isolating cooling water to the Reactor safety-related closed respectively, Category C, Coolant System Coolant Pumps' (RCP) Thermal Barrier position during normally open, Cooling Coils and Motor Coolers. This reactor refueling CCW supply to RCP function is required when the RCPs are outages.

thermal barrier cooling coil operating. Loss of RCP seal injection inlet check valves.

without Thermal Barrier Coolant would cause catastrophic RCP seal failure and a subsequent Small Break Loss of Coolant Accident. Loss of RCP motor cooling would result in catastrophic motor failure which would cause a loss of forced RCS flow. The cooling water to the RCPs is provided by a common header, therefore testing cannot be performed until all four RCPs are off, which does not occur except during reactor refueling outages."

27

=

Table 4.1 (Cont'd)

Item No.

. Valve L

- Drawing No.

Licensee's ;

Proposed Alternate' Identification :

Justificationi Testing

. for Deferred Testing '

Evaluation: Rese check valves, which are located inside containment, open to supply component cooling water to the four RCP thermal barrier cooling coils and close on reverse flow to isolate flow during a RCP thermal barrier cooling coil rupture accident.

P is impractical to full-stroke exercise these valves during power operation because it would interrupt component cooling water (CCW) flow to the RCPs thermal barrier cooling coils which could damage the RCPs seals and radial bearings. The NRC recommends that affected valves be tested during plant outages when RCPs are stopped for a sufficient period of time and on a refueling outage schedule, but not more than once every 92 days. RCPs need not be stopped for cold shutdown testing. OMa-1988, Part 10 allows the test interval to be extended to refueling outages when the tests cannot be practically performed during power operation or cold shutdowms.

He alternative provides full-stroke exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10, 14.3.2.2(e).

i l

i l

l l

28 l

m

-..s

~

es

+.

e m

m

_....m.

=

7c ~ % 'T o f::

3 dl, S:

1 Table 4.1 L(Cont'd)

Itan No.

Valve.

Drawing No..

'I,bneification

~~ ' '

IJeensee's -

Proposed Alterante Justification iTestams x

for Deferred Testing BB-12 BB8378A, B P & ID:

• Testing these check valves in the Valves will be :

BB8379A,B M-22BB01(Q),

safety-related direction requires access to the.

exercised to'their 3 inch, Category C, Rev.~ 15, Reactor.

valves and isolation of the normal or -.

safety-related closed normally open, Coolant System alternate charging paths. The normal position during Normal and alternate charging path is in continuous operation with reactor refueling charging lines double check the alternate charging line as a backup.

outages.

valves to RCS cold legs 1

.These valves are located behind the bioshield

& 4.

and entry behind the bioshield during power operation would cause um===ry radiation exposure and would not support ALARA.

Furthermore, in order to reduce high area.

radiation levels check valves BBV0001,22, 40, and 59 must be flushed to eliminate crud -

traps. As stated in relief request #BB-04 it is not desirable to flow through BBV0001,-

22,40, or 59 during cold shutdowns due to low temperature overpressurization concerns." (sic)

L 1

e

~

~'

.}9 i

l

'f l

1

. ~. -

...= -.. -....

.~. :..... =.. =...

t'.

Table 4.1 - (Cont'd)

- Itesa No.--

- Valve.

Drawing No.'

Licensee's -

Proposed Alternate Identification Justification Testing for Deferred Testing Emluation: These valves close to maintain RCS pressure boundary. They are not the pressure nor containment isolation valves which are upstream on the charging line side of the regenerative heat exchanger by penetration P-80.

It is impractical to full-stroke exercise these valves to the closed position during power operation because this would require a containment entry. Containment access for testing purposes presents a personnel safety hazard due to high radiation levels likely to be experienced by personnel during the test setup and test, and, proximity to high energy systems. It is impractical to part-stroke or full-stroke these valves during cold shutdown because of low temperature overpressurization concern with the flow path.

The alternative provides full-stroke exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10, 14.3.2.2(e).

1 5

30

....s m

.,,,,,y..v.

,__.,,e

-r-.,. _,

._c. :

Table 4.1 - (Cont'd)

~

• Itema No. =

Valve.

LDrawing No..

, Limnese's Proposed Alternate

Idemalfics*.ioen

. - Justification

Testing

. for Deferred Testing CHEMICAL AND VOLUME CONTROL SYSTEM (BG) 4 BG-01 BG8381 P & ID:

" Testing this valve closed would require Verify valve closure 3 inch check valve, M-22BG01(Q),

isolation of charging flow to the RCS which during performance -

Category A/C, normally.

Rev.13,.

is undesirable from a plant operational ofleak rate test

open, Chemical and perspective "

during refueling.

Charging flow inboard Volume Control isolation check valve to System.

regenerative heat i

exchanger.

Evaluation: This check valve is the inboard containment isolation valve for penetration P-80 on the charging line inlet side to tne regenerative heat exchanger.

It is impractical to full-stroke exercise this simple check valve closed quarterly because this would interrupt the normal charging flow to l

i the RCS during plant operation that could result in a CVCS flow imbalance and a possible plant trip as a result of pressurizer level fluctuations. In accordance with OMa-1988, Part 10,14.3.2.4(a), seat leakage testing is an acceptable means of verifying closure. It is,

impractical to perform a seat leakage test during cold shutdowns with the reactor coolant pumps secured because this would require -

i containment entry. Containment access for testing presents a personnel safety hazard due to high radiation levels likely to be expenenced by personnel during the test setup and test, and, proximity to high energy systems.

j The alternative provides full-stroke exercising to the closed position at refueling outages in accordance with OMa-1988, Part 10,

~

14.3.2.2(e).

- i

'f t

31

.e

.,,s,-

,+-w-.;

,n z.a

,.,h,,.m..

,.-h,,,-.,,.-,,w

._c

Table 4.1 (Cont'd)

Item No.

- Valse P' wing No.

Ucersee's -

Proposed Alternate Identification Justification -

l Testing for Defe". red Testing.

BG-02 BGHV8112, 8100 P & ID:

" Closure of one of these valves during Valve will be 2 inch motor operated M-22BG01(Q),

power operation would inhibit seal water exercised (full globe valves, Category A, hv. 13, flow across the reactor coolant pump seals.

stroke) to the normally open, Chemical and His could result in damage to the puma position required to RCP seal water return V lume Control seals and consequently cause a LOCA."

fulfill its function isolation valves.

Sysem snd stroke timed during cold shutdown.

Emluation: These valves isolate the return flow path from the reactor coolant pump seal water supply (penetration P-24) and close upon receipt of a safety injection signal.

It is impractical to full-stroke exercise these valves quarterly because this action may cause a seal water flow imbalance and possibly damage the RCP seals. The NRC recommends that affected valves be tested during plant outages when RCPs are stopped for a sufficient period of time and on a refueling outage schedule, but not more than once every 92 days. RCPs need not be stopped for cold shutdown testing. OMa-1988, Part 10 allows the test interval to be extended to refueling outages when the tests cannot be practically performed during power operation or cold shutdowns. However, the license proposes to perform the full-stroke exercise at cold shutdowns. He conditions for potential damage appear to still be there unless the RCPs have been secured.

The licensee should review this deferral and address the potential (if any) for RCP damage if the full-stroke exercising is performed at cold shutdowns and with the RCPs running. (See deferral #BB-07).

32

Table 4.1 (Cont'd)

Item No.

Valve -

Drawing No.

Licensee's Prepussi Alternate Identification Justification Testing for Deferred Testing BG-03 BGIIV8160, 8152 P & ID:

" Failure of this valve in the closed position Valve will be 3 inch air-operated globe M-22BG01(Q),

during testing would result in loss of exercised (full valves, Category A.

Rev.13, pressurizer level control and could result in stroke) to the normally open, Chemical and plant shutdown."

position required to CVCS letdown line inboard Volume Control fulfill its function and outboard isolation System and stroke timed valves.

during cold shutdown.

Evaluation: These valves isolate the normal letdown flow from the RCS (penetration P-23) and close upon receipt of a safety injection signal.

Part-stroke or full-stroke exercising these valves closed durine normal operation would introduce upsets in the operation of the letdown, charging, and seal water injection subsystems. If closure cf either valve during a quarterly test lasts too long or fails in that position, the pressurizer level would be affected with the likelihood of a plant trip. It is, therefore, impractical to full-stroke exercise these valves quarterly because of the resulting RCS transients that can challenge the reactor protection system.

The alternative provides f61-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

33

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing BG-04 BG8481 A, B P & ID:

" Valves cannot be full stroke exercised Exercise check 4 inch, Category C, M-22BG03(Q),

during power operation. The only full flow valve (partial normally open, Rev.23, path is through the Boron Injection Tank into stroke) quarterly Centrifugal charging pumps Chemical and the reactor coolant system. This would during plant discharge check valves.

Volume Control cause an increase in reactor coolant system operation. Exercise System boron inventory and possibly cause plant check valve (full shutdown. Valves cannot be exercised stroke) to the during cold shutdown since this could result position required to in a cold overpressurization of the reactor fulfill its function at coolant system."

refueling.

Emluation: These check valves open to provide flow from the centrifugal charging pumps to the normal charging line or boron injection tank and close to prevent flow through the parallel pump.

It is impractical to full-stroke open these valves during normal operation because: (1) nonnal letdown flow is insufficient to verify full-stroke accident flow and (2) the pumps would have to be realigned to the RWST in order to obtain sufficient volume for the test, and the RCS would have to be depressurized to verify full accident flow. It is impractical to full-stroke exercise these valves at cold shutdowns because- (1) high concentrations of boric acid would be injected into the RCS from the RWST that could extend the outage, arxi, (2) there 5 ihe potential for low temperature overpressurization of the RCS. [ Note that the BIT tank may contain as little as O ppm boric acid (Ref.16)].

The alternative provides part-stroke exercising quarterly and full-stroke exercising during refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(d).

34

y Table 4.1 (Cont'd)

-Item No.

Valve Drawing No.

Licensee's Proposed Alternate i

Identification Justification Testing for Deferred Testing.

BG-05 BG8546A, B P & ID:

' Valve cannot be full or partial stroke Exercise check 8 inch check valves, M-22BG03(Q),

exercised during power operation as this valve (full stroke) to Category C, normally Rev.23, would increase the reactor coolant system the position

closed, Chemical and boron inventory and possibly cause plant required to Charging pumps suction Volume Control shutdown. This valve cannot be exercised fulfill its function at check valves from RWST.

System during cold shutdown since this could result refueling.

in a cold over-pressurization of the reactor coolant system."

Emluation: These valves open on flow from the refueling water storage tank to suction of the centrifugal charging pumps and close to prevent back flow to the RWST.

It is impractical to part-stroke or full-stroke open these valves during normal operation because the pumps would have to be realioned to the RWST, and the RCS would have to be depressurized to verify full accident flow. It is impractical to part-stroke or full-stroke exercise these valves at cold shutdowns because: (1) high concentrations of boric acid would be injected into the RCS from the RWST that could extend the outage, and, (2) there is the potential for low temperature overpressurization of the RCS. It is impractical to part-stroke exercise these valves open using test connections because the RWST isolation valves would have to be open to complete the flow paths.

The alternative provides full-stroke exercising during refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e).

35

n g_

j

=

1 Table 4.1 (Cont'd)

-Itema No..

Valve; Drawing No.1 I Jr===e's l Proposed Alternate y;

IN JustlGcation c Testing for Defemd Testing BG-06 BGHV8105, 8106 P & ID:

" Closure of one of these valves during Valve will be -

3 inch motor operated gate M-22BG03(Q),

power operatioc would isolate charging flow exercised (full :

valves, Category A and B Rev.23, to the Reactor Coolant System. This could ~

stroke) to the -

respectively, normally Chemical and result in loss of pressurizer level control and position required to

open, Volume Control cause plant shutdown."

fulfill its function Normal charging isolation System and stroke timed valves to regenerative heat during cold :

exchanger.

shutdownc Evaluation: These valves close to isolate the charging line to the reactor coolant system upon receipt of a safety injection signal.

BGHV8105 is also an outboard containment isolation valve (with inboard isolation check valve BG8381) at penetration P-80.

As discussed by the hcensee it is impractical to exercise these valves quarterly because closure of either'of these valves would isolate charging flow to the RCS which could result in~a loss of pressurizer level control creating the potential for a plant trip.

The alternative provides full-stroke exercising at cold shutdowns in accordance with'OMa-1988, Part 10, 4 4.2.1.2(c).

36

p~;

f.

~. !

t_.

x z)

2 Table 4.1 (Cont'd) '

~

~ Iteen No.'

Valve.

Drawing No.1 Licensee's 4

^

Proposed Aleermate 1,benfication

" ' ~ ',

Justification Testing for' Deferred Testing BG-07 BGLCV0112B, C P & ID:

" Closure of one of these valves during -

. Valve will be '

4 inch motor operated gate M-22BG03(Q),

normal unit operation would isolate the exercised (full J valves, Category B.

Rev. 23, normal suction for the charging pumps.

stroke) to the normally open, -

Chemical and Alternate suction paths would result in position required to Volume control tank Volume Control-increasing the reactor coolant system boron fulfill its function discharge isolation valves.

System inventory and could result in plant and stroke timed shutdown."

during cold shutdown.

Evaluation: These valves close to isolate the volume control tank (normal charging supply) upon receipt of a safety injection signal and after borated refueling water storage system valves BNLCV112D and BNLCVil2E, which also receive a safety injection signal, are fully ;

open.

Closure of either of these valves during normal operation would isolate normal charging pump suction which would damage the RCP -

seals and cause a loss of pressurizer level. Reconfiguring alignment to either the RWST or the boric acid storage tanks in order to maintain charging flow would introduce concentrated boric acid into the RCS further causing a rapid power decrease and possible plant trip or required shutdown. Therefore, it is impractical to full-stroke exercise closed these valves quarterly during normal plant operation.

The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

37

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate

. Identification Justification.

Testing for Deferred Testing BG-08 BGV0147,165,174 P & ID:

" Exercising these valves requires substantial Exercise check 3 inch, Category C, M-22BG05(Q),

boration of the Reactor Coolant System valves to position normally closed, Rev. 9, Chemical which is unacceptable from an operational required to fulfill Boric acid transfer pumps and Volume viewpoint. This boration would cause the function at cold discharge check valves, and Control System unwanted negative reactivity addition and shutdown.

emergency borate header result in reactor power fluctuations."

check valve.

Emluorion: These valves open to provide an emergency boration flow path from the boric acid transfer pumps to the charging pumps suction.

It is impractical to part-stroke or full-stroke exercise these emergency boration flow path valves quarterly because this would introduce highly concentrated boric acid solution from the boric acid tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which adversely affects plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown.

The alternative provides full-stroke exercising to the open position at cold shutdowns in accordance with OMa-1988, Part 10, T4.3.2.2(c).

38 l

l W

D

I

~

f-4 Table 4.1 (Cont'd) -

Item No.

Valve' Drawing No.

Licensee's Pmposed Alternate

- Identification.

Justification

- Testing for Deferred Testing REACTOR MAKE-UP WATER SYSTEM (BL)

BI-01 BL8046 P & ID:

" System design does not provide any Verify valve closure 3 inch, Category A/C.

M-22BL01(Q),

indication for verifying valve closure upon during performance normally closed, Rev.10, Reactor flow reversal and would require a ofleak rate test Reactor make-up water Make-Up Water containment entry at power."

during refueling.

supply isolation check valve System (inside containment).

Emluation: This check valve is in the reactor make-up water supply to the pressurizer relief tank and RCP standpipes and provies inboard containment isolation.

It is impractical to verify closure of this check valve quarterly or at cold shutdowns because this is a simple check valve without position indication and with one of its test connections located inside containment. Containment access for testing presents a personnel safety hazard due to high radiation levels likely to be experienced by personnel during the test setup and test, and, proximity to high energy systems.

The alternate testing provides full-stroke exercising at refueling outages in accordance with OMa-1988, Part 10, T 4.3.2.2(e).

39

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Defened Testing BORATED REFUELING WATER STORAGE SYSTEM (BN)

BN-01 BNLCV0112D, E P & ID:

" Failure of these valves in the open position Valve will be 8 inch motor operated gate M-22BN01(Q),

would result in introduction of borated water exercised (full f

valves, Category B, Rev. 5, Borated into the RCS, resulting in possible unit

' stroke) to the l

normally closed, Refueling Water shutdown."

position required to l

Centrifugal charging pumps Storage System fulfill its function suction isolation valves and stroke timed from RWST.

during cold shutdown.

Emluation: These valves open to provide flow paths from the RWST to the centrifugal charging pumps upon receipt of a safety injection signal or a volume control tank (VCT) low-low signal.

l It is impractical to full-stroke exercise these valves quarterly because failure of either valve in the open position would provide a flow path from the RWST with its higher concentrations of boric acid to the charging pumps suction which would mix with the nornul l

charging flow. The result would be an increase in boron concentration that would cause a reactor power transient and a possible plant shutdown.

The alternative testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10, T 4.2.1.2(c).

40

Table 4.1 (Cont'd)

Item No.

~ Valve

' Drawing No.

Licensee's -

Proposed Alternate Identification -

Justification!

' Testing for Deferred Testing BN-02 BNHV8813 P & ID:

" Failure of this valve in the closed position Valve will be 8 inch motor operated gate M-22BN01(Q),

during testing would result in loss of exercised (full valve, Category B, Rev. 5, Borated miniflow path for both trains of safety stroke) to the normally open, Refueling Water injection pumps which renders both SI position required to SI pumps miniflow return Storage System pumps inoperable. This would result in fulfill its function isolation valve to RWST.

pump damage due to dead heading the safety and stroke timed injection pumps in the event of a safety during cold injection signal with reactor coolant pressure shutdowm.

above safety injection pump discharge pressure. Additionally, BNHV8813 is a T.S. 3.0.3 valve."

Emluation: This valve is normally open to provide a miniflow path to the refueling water storage tank (RWST) for the safety injection pumps. It is interlocked with MOVs EJHV8804A, B and may not be opened unless those valves are closed.

If BBHV8813 should fail closed during testing, the SI minimum flow line to the RWST is isolated.' If an SI signal should occur with (1)

RCS at pressure, and, (2) BBHV8813 closed, the SI pumps are operable but could be damaged because no path e.(is to the RCS nor to the RWST.

The alternative testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

41

Table 4.1 (Cont'd)

, item No.

Valve

' Drawing No. -

Licensee's Proposed Alternate Identification Justification

Testing for Deferred Testing RESIDUAL HEAT REMOVAL SYSTEM (EJ)

EJ-01 EJ8841 A, B P & ID:

" Valves cannot be full or partial stroke Exercise check -

6 inch check valve, M-22EJ01(Q),

exercised during power operation since the valve (full stroke) to Category A/C, normally Rev. 23, Residual only flow path discharges into the reactor the position

dosed, Heat Removal coolant system. Residual Heat Removal required to fulfill its IdIR hot leg recirculation System Pump Discharge Pressure or Safety Injection function at cold for RCS loops 2 & 3.

Pump Discharge Pressure cannot overcome shutdown.-

reactor coolant system pressure."

Evaluation: These valves open on recirculation flow from the residual heat removal pumps to the reactor coolant hot leg loops 2 & 3 via Train A. These check valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2. In addition, these check valves are upstream and in series with RHR hot leg recirculation check valves BB8949B, C (discussed in deferral #BB-03).

l It is impractical to part-stroke or full-stroke these valves open quarterly using the residual heat removal pumps because their discharge pressure cannot overcome reactor coolant system pressure. (The safety injection pumps discharge flow does not open these valves.)

These valves can be full-stroke exercised at cold shutdowns because there is little chance of causing a low tm.maure overpressurization condition with the residual heat removal pumps. The licensee will full flow test these valves using nonintmtive acar.stical monitoring at cold shutdowns. (See relief request #V07).

The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10, j 4.3.2.2(c).

42 m___

^-

Table 4.1 (Cont'd)

Item No..

. Valve.

Drawing No.

_ IJcensee's Proposed Alternate Identification.

' Justification

- Testing for Deferred Testing B-02 88%9B P & ID:

" Valve cannot be full stroke exercised during Exercise check 8 inch, Category C, M-22801(Q),

power operation since the only full flow valve (full stroke) to normally closed, Rev. 23, Residual path discharges into the Reactor Coolant the position RIIR train B supply header IIcat Removal System. Safety injection pump discharge required to fulfill its check valve to SI pump B.

System pressure cannot overcome Reactor Coolant function at System pressure.

refueling.

Valve cannot be full stroke exercised during cold shutdown since this could result in a cold over pressurization of the Reactor Coolant System."

Emluation: This check valve opens to provide suction to the safety injection pumps from residual heat removal (RHR) pump B discharge during the recirculation phase following safety injection actuation.

It is impractical to part-stroke or full-stroke exercise this valve open quarterly using the safety injection pumps because their discharge pressure can not overcome RCS pressure. It is impractical to part-stroke or full-stroke exercise this valve open at cold shutdowms because of the potential for cold overpressurization of the RCS. (It is not evident why the valve table shows a leak test for this valve).

The alternative provides full-stroke exercising at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e). The licensee should verify if a leak test is required for this valve, and, if so, revise this deferral accordingly.

43

Table 4.1 (Cont'd)

Itan No; Valve '

Drawing No.1

. Licensee's Proposed Alternate

~ Ihema6 cation

~

Justification

~

! Testing for Deferred Testing B-03 BHV8701 A, B P & ID:

"These valves have an interlock which '

Valve will be.

12 inch motor operated gate M-22801(Q),

prevents their opening when Reactor Coolant-exercised (full valves, Category A.

Rev. -23, Residual z System pressure is above approximately 360 stroke) to 'he normally closed, Heat Removal psig to prevent over pressurization of the.

position required to RHR pumps suction System RHR system."

fulfill its function isolation valve: from RCS and stroke timed.

hot legs 1 & 4.

during cold shutdown.

Emluation: These valves open to provide suction to residual heat removal (RHR) pumps during normal unit cooldown. They are L

interlocked with MOVs BBPV8702A, B to prevent opening at an RCS pressure > 360 psig. These valves are also pressure isolation l

valves and are required to be within the le* age limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

1-t.

It is impractical to full-stroke exercise these valves quarterly because they are interlocked with MOVs BBPV8702A, B to prevent opening I

at an RCS pressure > 360 psig.

The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988,' Part 10,14.2.1.2(c).

r

_.m.

__._m_u_m.___. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing EJ-Of EJHV8804A, B P & ID:

" Valves cannot be opened during operation Valves will be 8 inch motor operated gate hi-22EJ01(Q),

due to control interlocks with other ECCS exercised and stroke valves, Category B, Rev. 23, Residual valves. EJHV88MA & B are interlocked timed during cold normally closed, Heat Removal with Eh1HV8814A & B as well as shutdown.

RHR train A supply to System BNHV8813. The latter valves are safety charging pumps, and, RHR injection miniflow isolation valves which train B supply to SI pumps, must be closed in order to open the 88M respectively, isolation valves which makes the Safety Injection valves Pumps inoperable. If a SI would occur during testing, the SI pumps could be damaged due to a " dead headed" condition (i.e., loss of required miniflow)."

Emluation: Valves open to provide a recirculation flow path from discharge of the RHR pumps to the suction of the safety injection and centrifugal charging pumps.

As discussed by the licensee testing of these RHR Trains A & B supply valves is affected by various interlocks. In order to open EJHV8804A, the RCS/RHR inlet isolation valves EJHV8701A or BBPV8702A must be closed, and the SI pump miniflow valves Eh1HV8814A, B or the SI test line isolation valve BNHV8813 must be closed. If that is accomplished, the RWST becomes the source of supply and RHR Train A would supply the suction of the centrifugal charging pumps with highly borated water. Injection of highly borated water into the RCS would cause a rapid power decrease and likely plant trip. In order to open EJHV8804B, the RCS/RHR inlet isolation valves EJHV8701B or BBPV8702B must be closed, and the SI pump miniflow valves Eh1HV8814A, B or SI test line isolation valve BNHV8813 must be closed. If an SI signal should occur during either a Train A or Train B test configuration with the miniflow valves and the RWST isolation valve closed, the SI pumps could be damaged due to a dead headed condition because no path exists to the RCS which is at pressure nor the RWST test line which is blocked.

The alternative provides full-stroke exercising during cold shutdowns in accordance with Ohta-1988 Part 10, T 4.2.1.2(c).

45

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's "reimswi Alternate Identification Justification Testing for Deferred Testing B.05 BliV8840 P & ID:

" Valves have power removed during Valves will be 10 inch motor operated gate M-22801(Q),

operation to prevent mispositioning these exercised and stroke valve, Category B, Rev. 23 Residual valves which would result in entry into timed during cold normally closed, Heat Removal Technical Specification 3.0.3."

shutdown.

RIIR recirculation flow to System hot leg loops 2 & 3.

BIIV8809A, B 10 inch motor operated gate valves, Category B, normally open, R11R trains A & B injection flow to cold legs, isolation valves.

Emluation: The function of these valves are to cycle (BIIV8840 opens, BIIV8809A, B closes) to place the RIIR system in hot leg recirculation mode during post accident conditions.

It is impractical to full-stroke exercise these valves quarterly because technical specifications require that power be removed to the valve operators during power eperation as required by plant Technical Specifications.

The alternative provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10, T 4.2.1.2(c).

46

_. -. _ - - -. _ - _.. _ _ _ _ _ _ - _ _ _ -. _ _ _ ~ _ _ - _ _

m MMMMM Table 4.1 (Cont'd) l Item No.

Valve Drawing No.

Licensee's Proposed Altentate l

Identification Justification Testing

{

for Deferred Testing EJ-06 EJHV8811 A, B P & ID:

" Opening valve during operation would drain Valves will be 14 inch motor operated gate M-22EJ01(Q),

the RHR suction header into the containment exercised and stroke l

valves, Category B, Rev. 23, Residual sump rendering the RHR pumps inoperable.

timed during cold normally closed, Heat Removal Current procedures isolate and drain the shutdown when the Recirculation sumps supply System suction header prior to stroking. This proper precautions to RHR pumps suction requires significant time. An alternative is may be taken isolation valves.

to allow the water to go into the sumps without impacting which then would require removal to operation.

decrease cWainment humidity. Another j

concern is the additional risk of not getting j

the system fully vented. Requirements I

currently exist requiring ECCS systems be vented monthly due to problems encountered. The additional risks encountered and amount of time to perform testing do notjustify the small amount of additional assurance gained by the testing."

Emluation: These valves provide containment isolation for penetrations P-14 and P-15. They will open to provide flow paths from the containment recirculation sumps to the suctions of the RHR pumps when there is a safety injection signal present and the RWST reaches the low-low-l level setpoint.

It is impractical and burdensome for the licensee to exercise these valves quarterly because: (1) opening the valves drains the RHR suction header into the containment sumps rendering the RHR pumps inoperable; (2) a containment entry would be necessary to drain the suction header prior to stroking which require Qnificant set-up time; and, (3) allowing water into the sumps will eventually require water removal to minimize humidity and c.treful filling and venting of the header to minimize any air entrapment.

The alternative testing provides full-strok: exercising during cold shutdowns in accordance with OMa-1988, Part 10. T 4.2.1.2(c).

47

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing D-07 BHV8716A, B P & ID:

" Closing either UHV8716A or BHV8716B Valves will be 10 inch motor operated gate M-22801(Q),

isolates each Residual Heat Removal (RHR) exercised and valves, Category B, Rev. 23, Residual pump from two RCS cold legs. This renders stroke-timed at cold normally open, Heat Removal both trains of Emergency Core Cooling shutdown.

RHR trains A & B hot leg System System (ECCS) inoperable, which is in recirculation isolation violation of Technical Specifications during valves.

operation. If either DHV8716A or B is failed in a closed position,2 of the 4 cold leg injection pathways are isolated from the assumed single operating RHR pump.

Additionally, these valves are T.S. 3.0.3 valves."

Evaluation: During RHR system injection into the cold legs, these RHR cross-connect valves assist in balancing flow resistance to 3 of the intact cold leg loops. At the start of cold leg recirculation these cross-connect valves are closed to provide train separation such that each RHR pump recirculates flow to two cold legs. For hot leg, recirculation these cross-connect valves should be open.

As stated by the licensee, it is impractical to exercise these valves quarterly because if either valve should fait closed as a result of testing then only one RHR pump can feed two loops (instead of four loops if the other RHR pump is assumed failed). At the onset of a LOCA the RHR flow from the pump inservice is injected into all cold legs.

The alternative testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

i i

48 i

i l

Table 4.1 (Cont'd)

Item No.

' Valve.

Drawing No.

Licensee's Proposed Alternate l

. Identification Justification Testing for Deferred Testing EJ-08 EJ8958A, B P & ID:

"These valves cannot be full stroke exercised Exercise check 14 inch, Category C, M-22EJ01(Q),

during power operations since the full flow.

valves (partial.

normally closed, Rev. 23 Residual path discharges into the Reactor Coolant :

stroke) every 3 RHR pumps suction check Heat Removal System. Residual heat removal pump.

months. Exercise valves from RWST.

System discharge pressure cannot' overcome Reactor check valves (full Coolant System pressure during full power stroke) to the operations. EJ-8958A and EJ-8958B cannot position required to be full stroke exercised during cold fulfill its function at shutdown due to insufficient expansion refueling.-

volume for injection during cold shutdown."

Evaluation: These check valves open to provide flow from the refueling water storage tank (RWST) to the suction of the residual heat removal (RHR) pumps and close to prevent back flow to the RWST.

It is impractical to full-stroke exercise these check valves quarterly because the RHR pressure cannot overcome RCS pressure.

However, these check valves will be part-stroke exercised quarterly during the RHR pumps recirculation flow path testing. It is also impractical to full-stroke exercise these valves at cold shutdowns. Since the RCS does not have sufficient volume to accept the required accident flowrate from the RWST.

The alternative testing provides partial-stroke exercising quarterly and full-stroke exercising at refueling outages in accordance with OMa-1988, Part 1019.3.2.2.(e).

49 m-

Table 4.1 (Cont'd)

Item No.

Valve

- Drawing No.

Licensee's Proposed Alternate Identification Justification Testing

~ for Deferavd Testing B-09 88%9A P & ID:

"The valve cannot be full stroke exercised Exercise check 8 inch, Category C, M-22801(Q),

during power operation since the CCPs do valve (full stroke) to normally closed, Rev. 23, Residual not full-flow into the RCS during normal the position RHR train A supply header Heat Removal operation (avg flow, = 120 gpm, full flow required to fulfill its check valve to charging System

= 500 gpm.) Partial stroke excidsing function at pumps.

would require starting up the RHR pemp, refueling.

aligning it to the RWST, opening B-IIV-8804A (See Relief Request #B-4),

and as a result, boration of the RCS with 2000 ppm water. This is undesirable from a plant operational perspective."

Emluation: This valve opens to provide suction to the centrifugal charging pumps (CCPs) from residual heat removal pump A discharge during the recirculation phase following safety injection actuation.

It is impractical to full-stroke exercise this check valve quarterly because the differential pressure between the CCPs and RCS will not allow full accident flow. It is also impractical to part-stroke exercise this valve quarterly because alignment to the RWST with its high concentration of boric acid is required and the resulting mix of high boric acid and normal charging would cause power level fluctuations and possible plant trip. In addition, exercising this valve requires opening valves DHV8804A, B which have several interlocks that pose potential damage to the Si pumps. (See deferral #D-04). It is also impractical to part-stroke or full-stroke exercise this valve at cold shutdowns because of the potential for cold overpressurization of the RCS. (It is not evident why the valve table shows a leak test for this valve).

The alternative testing provides full-stroke exercising at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e). The licensee should verify if a leak test is required for this valve, and, if so, revise this deferral accordingly.

50

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justifiution Testing l

for Deferred Testing B-10 88730A, B P & ID:

"These valves cannot be full stroke exercised Exercise check 10 inch, Category C, M-22EJ01(Q),

during power operations since the full flow valves (partial normally closed.

Rev. 23, Residual path discharges into the Reactor Coolant stroke) every 3 RIIR heat exchangers A &

Heat Removal System. Residual heat removal pump months. Exercise l

B outlet check valves.

System discharge pressure cannot overcome check valves (full Reactor Coolant System pressure during full stroke) to the power operations."

position required to fulfill its function at cold shutdown.

Emluation: These valves open to provide flow from residital heat removal (RHR) pumps to the reactor coolant system (RCS) and close to prevent reverse flow through the RHR pump in the opposite train.

It is impractical to full-stroke exercise these valves quarterly because the RHR pump pressure cannot overcome RCS pressure. However, it is practical to part-stroke exercise these check valves during the RHR pumps quarterly tests.

The alternative testing of part-stroke exercising quarterly and full-stroke exercising at cold shutdowns is in accordance with OMa-1988, Part 10,14.3.2.2(b).

51

Table 4.1 (Cont'd)

Iteen No.

Valve

Drawing No.

Iicensee's.

Proposed Alternate

Identification ~

~~

Justification Testing

~ for Deferred Testing HIGH PRESSURE COOLANT INJECTION SYSTEM (EM)

EM-01 EM8922A, B P & ID:

" Valves cannot be full or partial stroke Exercise check 4 inch, Category C, M-22EM01(Q),

exercised during power operation since the valve (full stroke) to normally closed, Rev.13, High only flow path discharges into the reactor the position Safety injection pumps Pressure Coolant coolant system. Safety injection pump required to fulfill its I

discharge check valves.

Injection System discharge pressure cannot overcome reactor function at coolant system pressure.. During cold refueling.

shutdown these valves cannot be full or partial stroke exercised since this could result in a low temperature overpressurization of the reactor coolant system."

Emluation: These valves open on flow from the safety injection pumps to the reactor coolant cold legs or hot legs and close to prevent reverse flow through the opposite train safety injection pump.

It is impractical to part-stroke or full-stroke e.xercise the safety injection (SI) pumps discharge check valves to the open position quarterly because the SI pump discharge pressure cannot overcome the RCS pressure. It is also impractical to part-stroke or full-stroke exercise these valves to the open position at cold shutdowns because this could result in a low temperature overpressurization of the RCS.

The alternative provides full-stroke exercising open at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e).

I 52

_m___-

_.A_

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing EM-02 EMV0001, 2, 3, 4 P & ID:

" Valves cannot be full or partial stroke Exercise check 2 inch, Category A/C, M-22EM01(Q),

exercised during power operation since the valve (full stroke) to normally closed, Rev.13. High only flow path discharges into the reactor the position SI pumps recirculation flow Pressure Coolant coolant system. Safety injection pump required to fulfill its discharge to RCS hot legs.

Injection System discharge pressure cannot overcome reactor function at coolant system pressure. During cold refueling.

shutdown these valves cannot be full or partial stroke exercised since this could result in a low temperature overpressurization of the reactor coolant system."

Evaluation: These valves open to provide hot leg recirculation flow from the safety injection pumps. These check valves are also pressure isolation valves and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

As discussed by the licensee, it is impractical to part-stroke or full-stroke exercise these valves open quarterly using the safety injection pumps because their discharge pressure cannot overcome reactor coolant system pressure. It is impractical to full-stroke exercise these valves at cold shutdowns because this could result in a low temperature overpressurization of the reactor coolant system. The licensee will full flow test these valves using nonintrusive acoustical monitoring at refueling outages. (See relief request #V07).

The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988, Part 10, 14.3.2.2(e).

l 53

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deterred Testing Ehi-03 Eh18815, 3 inch, Category P & ID:

"Using a Centrifugal Charging Pump to Exercise check A/C, normally closed, hi-22Ehf02(Q),

provide flow would result in injecting valve (full stroke) to Boron injection tank (BIT)

Rev. 9. High borated water into the Reactor Coolant the position outlet check valve.

Pressure Coolant System through the cold leg injection lines.

required to fulfill its Injection System This would result in a decrease in reactor function at EhfV0240, 241,1 inch, power and thermal shock to the reactor refueling.

Category C, normally coolant piping. During cold shutdowms closed, BIT tank bypass exercising this valve could result in a low check valves.

temperature overpressurization of the reactor coolant system."

Emluarion: These valves open on flow from the centrifugal charging pumps after their realignment to the RWST. Check valve Ehf 8815 is also a pressure isolation valve and is required to be within the leakage limit given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

It is impractical to part-stroke or full-stroke open these valves quarterly because this will introduce colder water from the boron injection tank (BIT) which may cause a thermal shock to the RCS piping and injection nozzle connections. It is impractical to full-stroke exercise these valves at coli shutdowns because: (1) high concentrations of boric acid would be injected into the RCS from the RWST if l

realignment requires it, that could extend the outage, and, (2) there is the potential for low temperature overpressurization of the RCS.

l l

The alternative provides full-stroke exercising to the open position during refueling outages in accordance with Ohfa-1988, Part 10, l 14.3.2.2(e).

1 54 w

_m

.~

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification :

Justification Testing for Deferred Testing EM-05 EM8926A, B P & ID:

" Valves cannot be full stroke exercised Exercise check 8 inch check valves, M-22EM01(Q),

during power operation since the only full valve (. partial Category C, normally Rev.13, High flow path discharges into the reactor coolant stroke) to the

closed, Pressure Coolant system. Safety injection pump discharge position required to Safety injection pumps Injection System pressure cannot overcome reactor coolant fulfill its function suction check valves from system pressure. During cold shutdown every 3 months.

RWST.

these valves cannot be full stroke exercised Exercise check since this could result in a low temperature valve (full stroke) to overpressurization of the reactor coolant the position system."

required to fulfill its function at refueling.

Emluation: These valves open on flow from the refueling water storage tank (RWST) to the suction of the safety injection pumps and close to prevent back leakage to the RWST.

It is impractical to full-stroke exercise these check valves open quarterly because the safety injection (SI) pumps discharge pressure cannot overcome the RCS pressure. It is also impractical to full-stroke exercise these valves open at cold shutdowns because this could result in a low temperature overpressurization of the RCS. Partial-stroke testing of these check valves is accomplished quarterly during the SI pumps testing.

The alternative provides part-stroke exercising to the open position quarterly and full-stroke exercising at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(d).

55

Table 4.1 (Cont'd)

Item No. _

Valve -

' Drawing No.

Licensee's Proposed Akernate Identification fJustification Testing for Deferred Testing EM-07 EMHV8835 P & ID:

" Valve must remain open to satisfy the flow Valve will be 4 inch motor operated gate M-22EM01(Q),

path from the Safety Injection Pumps to the exercised and stroke valve, Category B, Rev.13, High Reactor Coolant System per T.S. 3.0.3."

timed during cold normally open, Pressure Coolant shutdown outages.

SI pumps injection flow Injection isolation valve to RCS cold legs.

Evaluation: This valve provides isolation bet veen the safety injection pumps discharge and the reactor coolant system cold legs.

Technical Specification 3.03 requires this MOV to be verified open with power removed to its operator. Closing EMHV8835 will isolate SI flow to the cold legs and opening EMHV8802A,B allows SI flow injection to the hot legs.

It is impractical to full-stroke exercise this valve quarterly because Technical Specifications require that this valve be open with power removed to its operator.

The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

56 1

O m

~

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing -

CONTAINMENT SPRAY SYSTEMS (EN)

EN-04 ENIIV0001,7 P & ID:

" Opening valve during operation would run Valves will be 12 inch motor operated gate M-22EN01(Q),

the risk of draining the Containment Spray exercised and stroke valves, Category B, Rev.2, Pumps suction headers into the containment timed during cold normally closed, Containment sump which could cause severe damage to shutdown when the Containment recirculation Spray System the pumps and render them inoperable.

proper precautions sumps supply to Refueling Water Storage Tank must be may be taken containment spray pumps isolated to prevent flooding containment without impacting isolation valves.

should the single check valve not hold when operation.

these valves are stroked open. Current procedures isolate and drain the suction header prior to stroking. This requires significant time. An alternative is to allow the water to go into the sumps which then woald require removal to decrease containment humidity. Another concern is the additional risk of not getting the system fully vented. Requirements currently exist requiring ECCS systems be vented monthly due to problems which were encountered.

The additional risks encountered and amount of time to perform testing do not justify the small amount of additional assurance gained by the testing."

57

Table 4.1 (Cont'd)

. Item No.

_. Identification L Justification Testing Valve-

- Drawing No.

Ucensee's Proposed' Alternate-for Deferred Testing Emluation: These MOVs are located outside containment and provide containment isolation for penetrations P-13 and P-16. During the recirculation phase the operator opens these valves to provide flow paths from the containment recirculation sumps to the suctions of the -

containment spray pumps.

lt is imprxtical and burdensome for the licensee to exercise these valves quarterly because: (1) opening the valves may drain the containment spray pumps suction headers into the containment sumps which could render them inoperable; (2) a containment entry would be necessary cn drain the suction headers prior to stroking which requires significant set-up time; (3) allowing water into the sumps will eventually require water removal to minimize humidity and careful filling and venting of the headers to minimize any air entrapment; and, (4) the RWST supply to containment would be blocked by a single check valve (to prevent flooding) if the corresponding MOV is opened.

The alternative testing provides full-stroke exercising during cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

58 n

c w

~n-r m

m.

,-- e

_..h"'

I'_

^

l

~

Table 4.1 (Cont'd)

. Itema N.'

Valve :

i Drawing No.

IJceasee's -

Proposed Alternate Id-sification Justineation

-; Testing

. for Defemd Testing ACCUMULATOR SAFETY INJECTION SYSTEM (EP)

EP-01 EP8818A, B, C, D P & ID:

" Valves cannot be full or partial stroke Exercise check.

6 inch check valves, M-22EP01(Q),.

exercised during power operation since the valve (full stroke) to Category A/C, normally Rev. 7, only flow path discharges into the reactor-the position '

closed, Accumulator coolant system. Residual Heat Removal required to fulfill its RHR pumps injection to.

Safety. Injection.

Pump Discharge Pressure cannot overcome function at cold cold legs.

reactor coolant system pressure."

shutdown.

L Emluation: 'Ihese valves open on cold leg injection flow from the residual heat removal pumps. These check valves are also pressure isolation valves and are required to be within the leshge limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

i '

As discussed by the licensee it is impractical to part-stroke or fullJstroke exercise these valves open quarterly using the residual heat removal pumps because their discharge pressure cannot overcome reactor coolant system pressure. These valves can be full-stroke exercised at cold shutdowns because there is little chance of ca'.' sing a low temperature overpressurization condition with the residual heat removal pumps. The licensee will full flow test these valves using nonintrusive acoustical monitoring at cold shutdowns. (See relief request #V07).

i The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.3.2.2(c).

1 J

4 i

I 59 1

-i

Table 4.1 (Cont'd)

Item Ne-Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing i

for Deferred Testing EP-03 EPV0010,20,30,40 P & ID:

" Valves cannot be full or partial stroke Exercise check 2 inch check valves, M-22EN1(Q),

exercised during power operation since the valve (full stroke) to Category A/C, normally Rev. 7, only flow path discharges into the reactor the position

closed, Accumulator coolant system. Safety injection Pump required to fulfill its SI pumps injection flow to Safety injection Discharge Pressure cannot overcome function at RCS cold legs.

reactor coolant system pressure. During refueling.

cold shutdown these valves cannot be full or partial stroke exercised since this could result in a low temperature ovo,ressurization of the reactor coolant system."

Evaluation: Th-se valves open on cold leg injection flow from the safety injection pumps. These check valves are also pressure isolation Wes and are required to be within the leakage limits given in Table 3.4-1 of Technical Specification 4.4.6.2.2.

As discussed by the licensee, it is impractical to part-stroke or full-stroke exercise these valves open quarterly using the safety injection pumps because their discharge pressure cannot overcome reactor coolant system pressure. It is impractical to full-stroke exercise these valves at cold shutdowns because this could result in a low temperature overpressurization of the reactor coolant system. The licensee will full flow test these valves using nonintrusive acoustical monitoring at refueling outages. (See relief request #V07).

The alternative provides full-stroke exercising to the open position during refueling outages in accordance with OMa-1988, Part 10, j4.3.2.2(e).

60 a

-.-_,s

s.

Table 4.1 (Cont'd)

Item No. -

Valve

- Drawing No.

Licensee's Proposed'Akernate Identification --

Justification

. Testing for Deferred Testing EP-04 EPIIV8950A, B, C, D, E.

P & ID:

" Opening valve during operplion could Valves will be F,1 inch solenoid operatM M-22EP01(Q),

render an accumulator inoperable. *1'he exercised and stroke globe valves, Category B, Rev.7, Technical Specification action staterrcnt may timed at cold normally closed, Accumulator not allow adequate time to test and restore an shutdown.

SI Accumulator tanks Safety Injection accumulator. Additionally, if one valve vents.

were to fail, insufficient time is allowed for repair and therefore the plant would be required to shutdown."

Emluation: These valves open to depressurize the accumulator tanks during emergency cold shutdown conditions.

It is impractical to ful.1-stroke exercise these valves quarterly because this would depressurize the nitrogen cover gas in the accumulators and render them inoperable until pressure is restored. If one valve should fail, there may not be sufficient tinie for repair before the plant would be required to shutdown.

_The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

61

.. ~..

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing EP-05 EPIIV8808A, D P & ID:

" Stroking the valve closed during power Valves will be 10 inch motor operated gate M-22EP01(Q),

operation would render an accumulator exercised and stroke valves, Category B, Rev. 7, inoperable. Technical Specifications only timed at cold normally open, Accumulator allow one hour in this condition prior to shutdowm.

SI Accumulator tanks A &

Safety Injection commencing unit shutdowm. This may not D outlet isolation valves.

be adecuate time to test a:xi restore the accumulator. Additionally, if one valve were to fail, insufficient time is allowed for repair and therefore the plant would be required to shutdown."

Emluation: These valves are normally open with power removed from the operator but nevertheless receive a safety injection signal to open. They need to have their power restored to isolate the accumulator tanks during certain emergency cold shutdown conditions.

It is impractical to full-stroke exercise these valves quanerly because they are locked open, with their breakers open, during power operation.

The alternative provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c).

62

m_x p

y

_'~

. ::.,9 d.

Table 4.1 (Cont'd)

Itema No.

Valve:

Drawing No.

.JusWication nTesting 11remase's T Proposed Alterunte j

Identification

[

. for Defemd Testing COMPRESSED AIR SYSTist (KA)

KA-01 KAV0029 P & ID:

" Failure of this valve in the closed direction Valve will be.

2 inch air-operated globe M-22KA01(Q),

or stroking this valve during normal plant.

exercised (full valve, Category A, Rev.21, operation would interrupt the. instrument air stroke) to the normally open,-

Compressed Air supply to valves and equipment necessary for position required to Reactor Building instrument System system control and operation (i.e., loss of fulfill its function' air supply flow control the normal letdown path and loss of and stroke time -

valve.

pressurizer spray).- These losses would put tested during cold I the plant in an off-normal situation and shutdown.

possibly cause a reactor trip."

Em/marion: This valve closes to provide outboard containment isolation for penetration P-30.

As discussed by the licensee, it is impractical to full-stroke exe :ise this AOV quarterly because closure will interrupt the instrument air' supply to valves and equipment inside containment that are necessary for system control and operation (i.e., loss of normal letdown' path.

and loss of pressurizer spray), which would cause pressurizer level and RCS pressure fluctuations that may result in a plant trip..The -

i valve table also indicates this valve is fail-safe tested. However, test frequency is missing in valve table.

The alternative testing provides full-stroke exercising at cold shutdowns in accordance with OMa-1988, Part 10,14.2.1.2(c). The licensee should revise thb deferral to identify when fail-safe testing is performed.

J B

63 i

~

...~.-

-..,.-..-..-.---.w.,~~.~...L.;.

Table 4.1 (Cont'd)

Item No.

Valve Drawing No.

Licensee's Proposed Alternate Identification Justification Testing for Deferred Testing KA-02 KAV0204 P & ID:

" System design does not provide any Verify valve closure 1.5 inch check valve, M-22KA01(Q),

indication for verifying valve closure upon during performance Category A/C, normally Rev.21, flow reversal."

ofleak rate test

open, Compressed Air required to be Instrument air supply System performed during inboard containment refueling.

isolation check valve.

Emluation: This check valve closes to provide inboard containment isolation for penetration P-30.

It is impractical to verify closure of this check valve quarterly or at cold shutdowns because this is a simple check valve without position indication and with one of its test connections located inside containment. Containment access for testing presents a personnel safety hazard due to high radiation levels likely to be experienced by personnel during the test setup and test, and, proximity to high energy systems.

The alternative testing provides full-stroke exercising at refueling outages in accordance with OMa-1988, Part 10,14.3.2.2(e).

o 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS Inconsistencies, omissions, and required licensee actions identified during the review of the licensee's second interval Inservice Testing Program are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report.

5.1 in Pump Relief Request #P02 (FER 2.2.1), the licensee seeks relief from measuring vibration of the submerged emergency fuel oil transfer pumps, it is recommended that interim relief be granted in accordance with 10CFR50.55a(f)(6)(i), for a period of one year, or until the next refueling outage, whichever is later, on the basis of the impracticality of immediately imposing Code requirements.

The licensee should subsequently revise and resubmit this relief request to indicate an alternative counc of action, such as the institution of a regular maintenance and spare parts program for these pumps which includes provisions to inspect the pump bearings and perform maintenance when the storage tanks are drained and the bearings are accessible (e.g., once every tea years).

5.2 In Valve Relief Request #V07 (TER 3.2.1), the licensee proposed to use non-intrusive techniques to verify full open capabilities of the ECCS injection line check valves. Relief is not required for this request however, the licensee shotid confirm that each branch line will have temporary instrumentation installed during the ECCS flow balance.

l 5.3 in Valve Relief Requests Nos. EN-01, EN-02, EN-03, EP-02, and IC-01, it is recommended I

that the proposed alternative testing of check valve disassembly and inspection be authorized provided I

that all the criteria of Position 2 is complied with, including adherence to the sample composition (e.g., all valves in the group must be the same size and see the same service conditions. Two of the valves identified in EN-02 are 10 inch pump discharge valves and the other two are 12 inch pump suction valves.) The licensee should revise relief request EN-02 and ensure that the information to support compliance with Position 2 guidance is documented in the IST Program, as GL-89-04 requests.

5.4 General comments on programmatic aspects of deferral testing are as follows:

(a) If a check valve has two safety positions, i.e., open and closed, the licensee must provide a discussion of the impracticality of verifying both poshions quarterly, and at cold shutdowns, as the case may be. Although the forward flow exercise may be impractical quarterly or during cold shutdowns, the licensee may practically verify closure without testing the forward flow. For example, the impracticality of verifying closure quarterly or during cold

)

shutdowns is not discussed in deferrals #EM-01 and #EM-05. Also, in some cases (e.g.,

l

1. EM-03), the impracticality of part-stroke exercising is not explained (b) The valve table could be enhanced if the test frequencies for each test were added to the table, e.g., quanerly, cold shutdown, refueling outage, as the case may be. Also, for safety / relief valve testing either a 5 year or 10 year frequency should be noted.

(c) It is recommended that the licensee review all the systems in the program and verify that safety and relief valves that fall under OMa-1988, Part 10,13.4, which references the safety and relief va~lve testing requirements of OM-1-1987, are in the program. There are numerous cases where relief valves installed in Code Class piping are omitted form the IST Program 65

(e.g., KAV703,704,705,706; EGV170,159; ENV057; EP8855A-D, KJV716A, B,717 A, B; and the valves identified in TER Section 5.12) 5.5 Deferral requests #BB-08, #BB-11, and, #BB-07 and #BG-02 relate to the RCP pump seals.

1. BB-11 deals with the inlet component cooling water supply to the thermal cooling coils where the licensee concludes appropriately that these valves should be tested at refueling outages when the RCPs are stopped. #BB-08 deals with the outlM component cooling water supply to the thermal barrier cooling coils where the licensee concludes that testing at cold shutdowns is appropriate. #BB-07 deals directly with the seal water injection flow where the licensee concludes appropriately that these valves should be seat leak closure tested at refueling outages. #BG-02 deals directly with seal water return flow and the licensee concludes that testing at cold shutdowns is appropriate. The conditions for seal damage are nearly as great at cold shutdowns as they are during operation., and consequently the licensee is being asked to review deferral requests #BB-08 and #BG-02.

5.6 It is not evident why the IST valve program table identifies the need for leak testing Category C check valves EJ8969A, B. This testing is not described in deferrals #EJ-02 and #EJ-09. The licensee should review these deferrals, and revise if required.

5.7 In deferral request #KA-01 for the compressed air system's air-operated isolation valve, KAV0029, the valve is required to be fail-safe tested but the test frequency is missing. The licensee should revise this deferral to include fail-safe testing and its frequency.

5.8 Prior to performing an IST systems review, a comparison of the valves in the IST program under Section XI, IWV, and under OMa-1988, Part 10, was made for deferral testing by using the previous Callaway IST program SERs (Ref.14 thru 20). The following items were found but changes in testing or test configuration may explain the differences:

(a)

ALV006, 9,12,15, essential service water supply check valves to the suction of the auxiliary feedwater pumps. Valve table indicates full-stroke exercising but does not identify disassembly / inspection. The SER of August 19,1987 (Ref.16) states valves will be disassembled / inspected. These valves were not identified in the present relief requests for disassembly / inspection. Although relief is not required the licensee should advise if this is still the case. The present valve table indicates quarterly full-stroke exercising.

(b)

B M H V0001,2, 3, 4, the steam generator blowdown isolation valves. The previous SER (Ref.

15) states these valves cannot be exercised during power operations because failure of a valve in the closed position during testing would isolate normal blowdown flow, which woul.1 disrupt steam generator chemistry limits, which would require a plant shutdown and could cause steam generator damage. These valves would be exercised during cold shutdowas and refueling outages. The valve table indicates quarterly full-stroke exercising. The licensee should review the test procedure for these valves.

(c)

EMHV8802 A, B are the isolation valves in the safety injection headers to the RCS hot legs, and cannot be exerciseJ during power operations because they are required to remain closed with power removed from their actuators by plant Technical Specifications. These valves must open to allow safety injection hot leg recirculation. The valve table indicates quarterly full-stroke exercising. The licensee should review the testing for these valves and document a test deferral, if necessary.

66

I 5.9 The review performed for this TER did not include verification that all pumps and valves within the scope of 10 CFR 50.55a and Section XI are contained in the IST Program, and did not ensure that all applicable testing requirements have be.en identified. The scope of the IST Program, however, was reviewed for several systems. The pumps and valves for the reactor coolant, chemical and volume control, high pressure coolant injection, safety injection, residual heat removal, main steam, feedwater, component cooling water, and essential service water systems were reviewed against the requirements of Section XI and the regulations. Technical input was obtained from the Callaway FSAR (Ref.12) and IPE (Ref.13). In general, the scope of the Callaway IST program for selected systems appears complete, however, certain valves were identified that may be within the scope of IST. It is recommended that the following valves be reevaluated for inclusion in the IST Program if the valves are Code Class 1,2, or 3 and the function of the valves is credited in the i

plant's safety analysis.

5.9.1 Chemical and Volume Control System BGHV8145, pressurizer auxiliary spray control valve, a 3 inch air-operated globe valve, normally closed, which opens to supply pressurizer spray if normal spray is lost.

l BBV0084,2 inch check valve, normally closed, which opens to allow pressurizer auxiliary spray from the CVCS.

If throttle valves BGHV8357A,B to the RCP seals are open during an accident then check valves BGV0589,590 should also open.

Relief Valve: BG8124 - CCP suction header,1 inch relief valve.

5.9.2 High Pressure Coolant Injection System

)

If the boron injection tank (BIT) has been replenished with boric acid smce the SER of October 26,1987 (Ref.16), as would be indicated by deferral #BG-04, then AOVs EMHV8883, EMHV8870A,B should be put back into the program to close, if in the j

recirculation mode, since they receive an SIS signal to close in an accident.

l Relief Valves: EM8853A,B: Si pumps discharge,1 inch relief valves.

EM8858A,B: Si pumps suction,3/4 inch relief valves.

EM8851: SI cold leg injection, I inch relief valve.

5.9.3 Residual Heat Removal System o

Relief Valves: EJ8856A,B: RHR pumps discharge,3/4 inch relief valves.

EJ8842: RHR hot leg recirculation,3/4 inch relief valve.

EJV156,157: RHR pump cooling,3/4 inch relief valves.

EJV084, 85: RHR heat exchanger,1 1/2 inch relief valves.

67

n 5.9.4' Main Steam System.

ABV0345,0346,0347,0348,0349,~ 0350,0351,- 0352 - Air supply and nitrogen backup

.e L

supply to the steam' generators PORVs. Loss of air and nitrogen supply will cause S/G PORVs to remain closed. (It appears that these valves are Code Class 3 based on the piping' designation (i.e., HBC)).

i l

I

{:

e i.

i l

t.

f' l.-

68 1

I

1.. _

o:

6.0., REFERENCES 1.

Callaway Pump and Valve Inservice Testing Program, Donald F. Schnell, Union Electric Company, to USNRC, July 14, 1994.

2.

ASME Boiler and Pressure Vessel Code,Section XI, " Rules for Inservice Inspection",1989 FWition.

3.

ASME/ ANSI OMa-1988, Part 6, " Inservice Testing of Pumps in Light-Water Reactor Power Plants" 4.

ASME/ ANSI OMa-1988, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants".

5.

Title 10, Code of Federal Regulations, Section 50.55a, Codes and Standard 3.

6.

Standard Review Plan, NUREG-0800, Section 3.9.6, " Inservice Testing of Pumps and Valves", Rev. 2, July 1992.

7.

NRC Generic Letter 89-C,, "Guidsnce on Developing Acceptable Inservice Testing Programs", April 3,1989.

8.

Minutes of the Public Meetings on Generic Letter 89-04, October 25,1989.

9.

Supplement to the Minutes of the Public Meetings on Generic Letter 89-04, September 26,

1991, 10.

Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants", P.

Campbell, November 1993.

I1.

Technical Specificatiens, Callaway Nuclear Plant.

12.

Final Safety Analysis Report (FSAR) for Standardized Nuclear Unit Power Plant System, Callaway Plant Units 1 and 2, August 6,1980.

13.

Individual Plant Examination (IPE), Callaway Plant, October 9,1992.

14.

SER, Letter dated June 4,1987, Wiggington (NRC) to Schnell (UEC), "Callaway Relief Requests".

15.

SER, Letter dated August 19, 1987, Alexion (NRC) to Schnell (UEC), "Callaway-First 10-Year Inservice Testing Program".

16.

SER, Letter dated October 26,1987, Wiggington (NRC) to Schnell (UEC), "Callaway-Fire 10-Year Inservice Testing Program Update".

17.

SER, Letter dated June 14, 1988, Perkins (NRC) to Schnell (UEC), "Callaway-First 10-Year Inservice Testing Program, Rev.10".

69

4 18.

SER, Letter dated September 21,1990, Samworth (NRC) to Schnell (UEC), "Callaway-First 10-Year Inservice Testing Program, Revision 11".

19.

SER, Letter dated April 7,1992, Hannon (NRC) to Schnell (UEC), " Pump and Valve Inservice Testing (IST) Program Relief Request Revision 12, for Callaway Plant".

20.

SER, Letter dated September 30,1993, Hannon (NRC) to Schnell (UEC), " Pump and Valve Inservice Testing (IST) Program Relief Request, Revision 13-Callaway Plant".

l 70

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ - -.