Text

Ter,Pump & Valve Inservice Testing Program,Davis-Besse Nuclear Power Station,Unit 1
	ML20086F707
Person / Time
Site:	Davis Besse
Issue date:	10/31/1991
From:	Cain R; EG&G IDAHO, INC.
To:	; NRC
Shared Package
ML20086F713	List: ML20086F707;
References
	CON-FIN-A-6812 EGG-NTA-9770, TAC-M76025, NUDOCS 9112030410
	Download: ML20086F707 (71)
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i EGG-NTA-9770 TECHNICAL EVALVATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 Docket Number 50-346 R. S. Cain Published October 1991 Idaho National Engineering Laboratory EG&3 Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6812 TAC No. 76025

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i-ABSTRACT This EG&G Idaho, Inc., report presents the-results of our evaluation of the Davis-Besse Nuclear Power Station, Unit 1, Inservicc Testing Program for safety-related pumps and valves.

PREFACE This report is supplied as part of the " Review of Pump and Valve LInservice.: Testing Programs for Operating License Reactors (III)" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear-Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc.,

Regulatory -and Technical Assistance Unit..

FIN No. A6812 B&R 920-19-05-02-0 Docket Number 50-346 TAC No. 76025 ii

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3.7 Core Flood System 27 3.7.11 Category A and A/C Valves 27 3.8 Decay Heat System 29 3.8,1 Category B Valves 29 3.9 Emen;ricy Diesel Generator Air Start Systems.........

30 3.9.1 Category B Valves 30 3.10 High Pressure Injection System 32 3.10.1 Category C Valves......,...,.......

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3.11 -Instrument Air System....................

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3.11.1 Category A/C. Valves.................

34 3.12 Main Steam System.......................

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.3.12.1 Category C Valves..................

35 3.13 Make Up System 37 3.13.1 Category A/C Valves.................

37 3.13.2 Category C Valves..................

38 3.14 Nitrogen System.......................

42 3.14.1 Category A/C Val ves.................

42 3.15. Reactor Coolant System 43 3.15.1 Category A/C Valves...........,.....

43 3.15.2 Category B and B/C Valves..............

44 3.16 Service Water Systems....................

48 3.16.1 Category C Valves..................

48 3.17 Station Air System 49 3.17.1 Category A/C Val ves.................

49 APPENDIX A

............................... A-1 1

APPENDIX B B-1 iv

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CONTENTS ABSTRACT ii PREFACE.................................

ii 1.

INTRODUCTION 1

2.

PUMP TESTING PROGRAM 3

2.1 General Pump Relief Requt ats.................

3 2.1.1 Bearing Temperature Measurement 3

2.2 Service Water Pumps 4

2.2.1 Allowable Ranges of Test Quantities 4

2.2.2 Vibration Location Measurement............

6 2.2.3 Reference Flow or Differential Pressure 7

2.3 Diesel Generator Fuel Oil Transfer Pumps...........

9 2.3.1 Pump Hydraulic Parameters 9

2.3.2 Pump Vibration Measurements 11 3.

VALVE TESTING PROGRAM,......

13 3.1 General Valve Relief Requests 13 3.1.1 Cold Shutdown Testing 13 3.1.2 Pressure Isolation Valves (PlVs)...........

15 3.1.3 Valves Required to Reach Cold Shutdown 16 3.2 Auxiliary Feedwater 17

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3.2.1 Category B Va'.ves 17 3.2.2 Category C Valves 19 3.3 Auxiliary Steam System....................

21 3.3.1 Category C Valves 21 3.4 Component Cooling Water System.

22 3.4.1 Category C Valves 22 3.5 Containment Hydrogen Control.................

24 3.5.1 Category A/C Valves 24 3.6 Containment Vacuum Relief 25 3.6.1 Category A/C Valves 25 iii

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-TECHNICAL EVALUATION-REPORT-PUMP AND VALVE-INSERVICE TESTING PROGRAM

~ DAVIS-BESSE NUCLEAR POWER STATION. UNIT 11 l.

INTRODUCTION

. Contained-herein is a technical evaluation of-the pump and valve

~ 1nservice testing (IST) _ program submitted by the Toledo Edison Company for its.

3 Davis-Besse-Nuclear Power Station, Unit ~l'.

By a letter' dated March 22,.1990, Toledo Edison Company submitted their seemd ten year IST program in accordance with'10 CFR 50.55(g)(5)(1) for the Davis-Besse Nuclear Power Station, Unit'l. The licensee's revised program,-

dated Augusti28,-1990,- was received ~and compared to the previous submittal to-identify any changes'.

The licensee's IST Program was: reviewed:to-verify

- compliance of, proposed: tests of safety-related pumps -and-valves with the 1

-requirements of the ASME Boiler and Pressure Vessel Code (the Code).1986

-Edition.

Any11ST program revisions subsequent to those noted above are not addressed in this' technictl evaluation report (TER). Any IST program revisions ~shbuld follow the guidance presented in Generic Letter 89-04,

" Guidance on Developing Acceptable Inservice Programs."

In their submittal', Toledo Edison Company has requested relief from the ASME Code testing requirements for. specific pumps and valves and thsse requests have been evaluated individually to determine if the criteria in

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L10 CFR 50.55a for granting-relief are met f r the specified pumps and-valves.-

This review was performed using the acceptance criteria of the' Standard Review-.-

1 Plan, NUREG-0800, Section 3.9.6, the Draft Regulatory Guide and Value/ Impact Statement titlid-" Identification of hlves for Inclusion in Inservice Testing-1

-Programs",- and Generic letter 89-04, " Guidance on Developing Acceptable Inservice Programs." These IST program. testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requirem(nts.

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These TER relief request evaluations are applicable only to the components or groups of components identified by the. submitted requests.

' These evaluations may not be 5xtended to apply to similar component that are not identifitd by the request at this or ano:Fer comparable facility without separate review and apprv/a1 by NRC.

Further, the evaluations and recommendations are limited to the er.quirement(s) and/or function (s) expli itly discussed in the applicable TER section.

For example, the results of r evaluation of a request involving testing of the cor;tainment isolation fenc; ion of a valve cannot be extended to allow the test to satisfy a requirement to verify the valve's pressure = isolation function, unless that extension is explicitly stated.

Section 2 of this report presents the Toledo Edison Company bases for requesting relief from the Se: tion XI requirements for the Davis-Besse, Unit 1, rump testing program and the reviewer's evaluations and conclusions regarding these requests. Similar information is presented-in Section 3 for the valve testing program.

1 A listing of P&lDs used for this review is contained in Appendix A.

8 inconsistencies and omissions in the licensee's IST program noted during the course of this review are listed in Appendix B.

The licensee should resnive these items in accordance with the evaluationt, coaclusions, and

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guidelines presented in this report.

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2.

PUMP TESTING PROGRAM The Davis Besse Nuclear Power Station, Unit 1, IST program submitted by Toledo Edison Company was examined to verify that all pumps that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI, except where specific relief from testing has been requested as identified below.

Each Toledo Edison Company basis for requesting relief from the pump testing requirements and the EG&G reviewer's evaluation of that request are summarized below.

2.1 Sfneral Pumo Relief Reauests 2.1.1 Bearina Temperatyg Measurement 2.1.1.1 Relief Recueil.

The licensee requested relief from the requirements of stction XI, Paragraph IWP-3100, measurement of annual pump bearing temperature for the following pumps, Auxiliary water P14-1 & 2, Decay Heat Removal P42-1 & 2, Component Cooling Water P43-1,2,& 3, Containment Spray P56-1 & 2, High Pressure Injection P58-1 & 2, Boric Acid Transfer P38-1 & 2, and Makeup P37-1 & 2.

The licenseo proposed to monitor pump differential pressure, flow, and vibration as a means to detect pump degradation and hydraulic performance.

2.3.1.1.1 Licensee's Basis for Reauestina Pelief--The once-a-year temperature measurement will not provide significant information about pump conditions.

Industry experience has shown that bearing temperature changes caused by degrading bearings occur only after major degradation has occurred at the-pump.

Prier to this, the vibration measurement would provide the necessary information to warn the operator of an impending malfunction.

The long running time required to achieve temperature stability could result in increased maintenance and repair.

Deletion of this measurement will not have significant affect on evaluating pump test results since other parsmeters are

-being measured.

Alternate Testina:

Pump differential pressure, flow, and vibration (as applicable) will be used to monitor pump performance.

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2.1.1.1.2 Evaluation--There are several factors such as the working fluid temperature and ambient temperature that would affect the measured bearing temperatures so as to mask changes in pump bearing condition.

Taken on an annual basis, pump bearing temperatures provide little information about the mechanical condition of a pump rior does it provide a useful means of monitoring for bearing degradation, short of catastrophic failure.

Pump vibration measurements taken on a quarterly basis will provide a better indication of a pump's mechanical condition and degradation than a yearly bearing temperature measurement.

The licensee's proposal to monitor pump mechanical condition using quarterly vibration measurements should provide an

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acceptable level of quality and safety.

Based on the determination that the licensee's proposal provides an accepteble level of quality and safety as the Code requirements, relief should be granted as requested.

2.2 Service Water Pumni i

2.2.1 Allowable Ranaes of Test Ouantities 2.2.1.1 Relief Reouest.

The licensee requested relief from the allowable flow range requirements of Section XI, Table IWP-3100-2, for service water pumps P3-1, -2, and 3.

The licensee proposed to test these service water pumps in the "as found" condition using expanded flow ranges.

2.2.1.1.1 Licensee's Basis for Reauestina Relief--Due to climatic conditions the service water system experiences a wide variation in water temperature. The system flow instrumentation is not designed to compensate for temperature variations.

Because of the. variation of water temperature, the use of the Code required acceptable, alert, and required action ranges of Table IWP-3100 2 could result in unnecessary pump maintenance and repair.

Operating experience with these pumps indicates tnat the Code ranges can be

. extended to compensate for temperature variation without adversely affecting the test programs ability to detect pump degradation.

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1 Alternate Testina:

The service water pumps will be tested quarterly in the as found condition using the installed line flow rate instrumentation using the following acceptable, alert, and required action ranges:

Acceptable 0.94-1.06 Qr Alert Low 0.90-<0.94 Qr Alert High

>l.06-1.10 Qr Required Action Low

<0.90 Qr Required Action High

>l.10 Qr 2.2.1.1.2 Lvaluation--Climatic changes cause a wide change in service water temperatures.

These changes in service water temperature change the density of the fluid being pumped.

For a fixed pump differential pressure, fit.w rate will vary due to the density change in the fluid being pumped. These fluctuations in flow rate could cause flow rate data to fall outside the ranges described in Table IWP-3100-2 without the pump being mechanically or hydraulically degraded, it would be impractical for the licensee to test these pumps at the same service water temperature every time since the licensee hi' no control over the climatic conditions that occur each time the quarterly tes, is performed.

The unwarranted pump maintenance and repair that would occur from data falling outside the Code allowable ran p s of test quantities would be costly and burdensome to the licensee.

Because of the above concerns, the licensee proposed less restrictive allowable ranges for flow rate.

However, the licensee has not provided a technical basis that shows that the proposed acceptance criteria will give adequate assurance of pump operational readiness.

The more restrictive Section XI high alert and high required action flow values serve to limit the amount of allowable instrument deviation since it is unlikely that pump hydraulic performance would improve.

The licensee's proposed expanded flow limits would increase the range of test quantitles that would be allowable and c.uld act to permit continued operation of a degraded pump.

Therefore, the licensee's proposed limits may be less conservative and not provide an adequate level of pump operational readiness.

In pumo relief request RP-4, TER section 2.2.3.1 of this report, the licensee submitted a relief request to use pump reference curves instead of a set of fixed reference points.

As explained in TER section 2.2.3.1.2, the 5

establishment of these pump reference curves should provide some relief from the flow rate deviations due to climatic changes.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering the licensee's proposal should provide a reasonable assurance of operational readiness, relief should be granted provided the licensee documents the expanded ranges as required in Section XI, lWP 3210.

The documentation should include the reason for the expanded ranges and an explanation of how the expanded ranges will not mask any pump degradation.

2.2.2 Vibration location Measurement 2.2.2.1 Relief Reouest.

The licensee requested relief from measuring vibration at the bearing housing or its structural support provided it is not separated from the pump by any resilient mounting as required by Section XI, Paragraph IWP 4510, for service water pumps P3-1,- 2, and -3.

The licensee proposed to measure vibration amplitude on the top of the motor housing horizontally in two plar.es 90 degrees apart.

2.2.2.1.1 Licensee's Basis for Reauestina Relief--These pumps are submerged in a pit which makes them inaccessible for measuring vibration amplitude at the pump bearing.

Alternate Testina:

Vibration amplitude is to be measured on the top of the motor housing horizontally in two planes 90 degrees apart.

2.2.2.1.2 Evaluation--The service water pumps are vertical line shaft pumps that are submerged in a pit which makes it impractical to measure pump vibration at the pump bearing housing.

Installation of instrumentation to measure vibration on these pump bearings is impractical because the accelerometers nuld fail in this harsh environment.

Further, this would I

require system modifications and would be burdensome to the licensee.

Industry experience has shown that information can be obtained on pump mechanical condition by measuring vibration on the driver bearing housing.

The measurement that is generally most responsive to changes in vertical line shaft pump condition is the axial vibration measurement taken on the driver 6

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housing containing the thrust bearing.

The licensee proposed to measure horizontal vibration (radial vibration) on these pumps in 2 planes, but is not measuring axial vibration.

The licensee should measure axial vibration on the pump drivers and assign acceptance criteria so that corrective action will be initiated when significant pump degradation occurs but prior to complete failure.

The licensee's proposal to measure vibration amplitude on the top of the motor housing horizontally in two planes 90 degrees apart combined with axial measurements as described above should provide a reasonable assurance of pump operational readiness.

Based on the determinatio tLt the Code required location of measurement is impractical, the c;rde -

+6a licensee if the Code requirements are imposed, and ccnsidtring aat the licensce's proposed i

alternate location of measurement ve. E,e test parameters should provide a reasonable assurance of pumo 9,naratio$al readiness, relief should be granted provided that the licensee measures axial vibration on the driver bearing housing-and assigns acceptance criteria as discussed above.

2.2.3 Reference Flow or Olfferential Pressure 2.2.3.1 Relief Recy111 The licensee requested relief from Section XI, Paragraph IWP-3100, conducting pump testing by varying the system until either the measured differential pressure or the measured flow rate equals the corresponding reference value and comparing any deviations with the limits in Table IWP-3100-2 for service water pumps P3-1, -2, and -3.

The licensee proposed to perform a test with the system in the "as found" operating condition, instead of a reference condition, and compare the test results with a curve of reference values which establish the relationship between flow rate and differential pressure in a band around the design point.

2.2.3.1.1 Licensee's Basis for Reauestina Relief--These systems

-do not have installed pump test lines and system operating conditions will not allow' adjusting system resistance without significant impact on plant operations..These are variable resistance systems that are in continuous operation during all modes of plant operation.

Depending on plant operating conditions and climatic conditions, the cooling requirements range from minimum cooling loads to 100 percent with nany of the loads automatically 7

placed in operation in response to local temperature requirements.

Because of these normal operating requirements, it is not possible to specify a reference test flow path or flow rate that can be repeated for each test.

Alternate Testino:

Pump testing will be performed with the system in the as found operating configuration and the test results compared with a curve of reference values which establish the relationship between flow rate and differential pressure in a band around the design point.

2.2.2.1.2 Evaluation--These service water pumps operate under a variety of flow rate and differential pressure conditions.

These conditions result from mdtiple independent changes in system cooling demand and climatic changes in the temperature of the service water, which make it impractical to return to a reference point.

Significant system redesign and modifications would he required to facilitate returning to fixed points of operation for testing these pumps.

This would be costly and burdensome to the licensee.

The licensee proposed to use pump curves to determine acceptance criteria for inservice testing with measurements taken in the "as found" condition of pump flow and riifferential pressure in lieu of returning to fixed reference value points. The licensee'r proposed alternate testing should provide a reasonable assurance of operational readiness.

Using a reference pump curve to compare differential pressure and flow rate for pump inservice testing can provide an acceptable alternative to the Code requirement to return to a fixed reference point (s). A reference pump curve describes an infinite number of fixed sets of reference values for pump flow rate and head. However, it is important that the reference curve is developed, or the manufacturers curve is validated, when the pump is known to be operating acceptably and that it is based on, or validated by, an adequate number of measurement points. Acceptance criteria based on the curve should not conflict with Technical Specifications or Facility Safety Analysis Report operability criteria, for flow rate and differential pressure, for the affected pumps.

Additionally, the leveis of vibration may vary significantly over the range of pump conditions encountered during testing.

If this occurs, the licensee should develop a method for assigning vibration acceptance criteria that will give equivalent protection as provided by the Code.

This may require taking vibration measurements at various points on the pump curve 8

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and assigning acceptance criteria for regions of the pump curve ( i.e., assign vibration acceptance criteria based on the lowest vibration reading in the region of flow from 1000 to 1500 GPM).

The pump curve may be divided into as many regions as neccssary.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements are imposed, and considering that the licensee's proposal should provide a reasonable assurance of pump operational readiness, relief may be granted from the Code requirements to establish i xed reference points provided the licensee develops the pump curves, or validates the manuf acturers curves, when the pump is known to be operating acceptably and, the licensee develops appropriate acceptance criteria for vibration measurements at the various pump opc*ating conditions.

2.3 Diesel Generator fuel Oil Iransfer punti 2.3.1 Eym_p Hydraulic Parameterl 2.3.1.1 Relief Reauest.

The licensee requested relief from Section XI, Paragraphs IWP-3100 and IWP-3500(b), requirements to measure pump inlet and differential pressure, flow rate, and duration of test for the diesel generator fuel oil transfer pumps, P195-1 and 2.

The licensee proposed a pump flow functional test performed quarterly with the emergency diesel generator test to verify pump start and flow by monitoring the change in day tank level.

Flow rate measurement based on pump run time and day tank level change will be performed on a refueling outage frequency.

2.3.1.1.1 Licensee's Basis far Requestina Relief--The diesel generator fuel oil transfer pumps are located inside the storage tank with the pump discharge plenum and motor bolted to a flange on top of the tank.

These pumps are low flow pumps, rated at 10 gpm for 150 psid. The Day tank can only receive approximately 150 gallons after each EDG test.

None of the pumps have installed instrumentation to measure either flow or discharge pressure, lhe only possible flow measurement is by measuring change in day tank level over time.

Error in measuring this volume is dependent on fuel oil temperature and a limited change in level indication because it is the upper section of a 9

f circular tank.

Flow rate is dependent upon fuel oil viscosity which varies with environmental temperature conditions.

Alternate Testino:

Pump flow functional test are performed quarterly after a Emergency Diesel Generator Test.

Pumps are observed to start with a corresponding increase level in the Day lank.

Pump flow rate tests are performed each refueling.

Flow rate is obtained by measuring a change in day tank level over time. A day tank level change of approximately 150 gallons shall be timed and flow rate determined at each refueling.

Flow rate shall be determined to be greater than 4.5 gpm which is a minimum amount of flow required to p6rform the safety function.

2.3.1.1.2 [ valuation -These are centrifugal pumps located inside the diesel fuel oil storage tanks.

It is impractical to directly measure pump flow rate or discharge pressure because there are no installed flow or discharge pressure instruments.

The system would have to be redesigned and modified to install instrumentation in ordor to take the Code required measurements.

Due to the capacity of the diesel generator day tank and the flow rate of these pumps, if the pumps were ran for the times required by the Code for the bearing temperature measurements, there is a possibility of overficwing the diesel generator day tank during testing.

It would be impractical to require the licensee to meet the run time requirements of IWP-3500(b) because of the possibiHty of a fuel oil spill. However, the licensee should comply with the requirements of IWP-3500(a) for all inservice tests of these pumps.

Monitoring only the flow rate of centrifugal pumps does not provide sufficient information to evaluate the pump's hydraulic condition or to monitor for pump degradation.

Furthermore, the licensee's quarterly functional test provides no information on the hydraulic condition of the pump or possible degradation; it indicates only that the pump has started and some amount of fuel oil is being pumped. Although the licensee's testing should provide a reasonabie as.urance of operational readiness for the interim period,-it is not adequate for the long term.

The licensee should develop some_means to monitor for pump hydraulic condition and degradation. One method would be to modify the system and ins (,1 instrumentation that would meet the Code requiremants. Another possible solution would be the use of 10

pontable, strap on, instrumentation or non-intrusive instruments to perform Code required testing.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were immediately imposed, and considering that the alternate testing should provide a reasonable assurance of operational readiness during the interim period, interim relief may be granted for a period of one year or the next refueling outage, whichever is longer. During this interim period, the licensee should develop a means or test to monitor for pump degradation.

2.3.2 Pumo Vibration Measurements 2.3.2.1 Relief Reauest.

The licensee requested relief from the requirements of Section XI, Paragraph IWP-3100, measurement of pump vibration for diesel fuel oil transfer pumps P1951 and -2.

The licensee has not proposed any alternate testing.

2.3.2.1.1 Licensee's Basis for Reauestina Relief--The diesel fuel Oil Transfer pumps are submersible motor driven geared, centrifugal pumps.

Both the pump and motor are submersed and are not accessible for vibration measurements.

-Alternate Testino:

None.

2.3.2.1.2 Evaluation--It is impractical to take vibration readings on these pumps because both pump and motor are located inside the fuel oil storage tank, submersed in the fuel oil being pumped. The system would require redesigning and modifications, which would be costly and burdensome to the licensee. Although it is impractical and burdensome for the licensee to obtain the vibration readings for these pumps, since pump inlet, discharge, and differential pressure are not being measured as indicated by Relief Request RP-5, TER section 2.3.1.1, the licensee should develop some means of monitoring -for pump mechanical and hydraulic condition and be able to detect pump degradation, 11

Based on the determination that the licensee does not have a means to monitor for pump hydraulic and mechanical degradation, relief is denied.

The licensee should develop a test method or means to monitor for pump mechanical and hydraulic condition 6nd be able to detect pump degradation.

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VALVE TESTING PROGRAM The Davis-Besse Nuclear Power Station, Unit 1, IST program submitted by Toledo Edison Company was examined to verify that all valves that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. The_ reviewers found that, except as noted in Appendix B or where specific relief from testing has been requested, these valves are tested to the Code requirements and established NRC positions.

Each Toledo Edison company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to system and valve category.

3.1 General Valve Relief Reaues_tf 3.1.1 Cold Shutdown Testina 3.1.1.1 Relief Reauest.

The licensee requested relief from the requirements of Section XI, Paragraph IWV-3417, for various valves tested during cold shutdown. The Code states in part,"when corrective action is reqJired as a result of tests made during cold shutdown, the condition shall e

be corrected before startup". The alternate testing proposed by the licensee is when a valve failsSection XI test criteria during cold shutdown testing an analysis will be performed to determine if the test failure _results in system inoperability or would prevent the system from performing its safety-related function (s).

If the analysis determines a valve test failure does not cause the system to.be inoperable then the plant may startup providing corrective action is being or will be performed on the valve.

3.1.1.1.1 Licensee's Basis for Reouestina Relief--The plant technical specifications provide the system operability requirements for plant startup and mode changes.

The failure of a valve to passSection XI test requirements may not affect system operability or prevent the system from performing its safety-related function (s).

For example, failure of a normally closed power operated valve in a pump test line to open does not affect the system from performing its safety-related function (s).

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Alternate Testino: When a valve fatisSection XI test criteria during cold shutdown testing-an analysis will be performed to determine if the test failure results in system inoperability or would prevent the system from performing its safety related function (s).

If the analysis determines a valve test failure does not cause the system to be inoperable then the plant may startup providing corrective action is being or will be performed on the valve. A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.

3.1.1.1.2 Evaluation--The licensee's plant Technical Specifications provide the criteria for safety system operability and requirements for plant startup and mode changes.

The NRC has reviewed and approved the Technical Specifications to ensure that they will provide for safe operation of the plant.

Certain valves may be declared inoperable as the result of failing their Section XI test criteria during cold shutdown and still not affect the operability of their associated safety system or prevent the system from performing its safety related function.

In such a case, a valve may be in or be placed in a position in which the safety system remains operable and plant Technical Specifications allow startup and changing of plant modes.

If the licensee's Technical Specifications are met, then preventing plant.startup as required by the Code would create a hardship on the licensee without a compensating increase in the level of safety.

The licensee stated that if an analysis determines that valve failure does not make the system inoperable, then plant startup may be performed provided corrective action is being or will be performed on the valve.

Ilowever, the licensee should include in their analysis a determination on the capability of the system to perform its safety-related function (s) with the failure present.

Furthermore, a retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.

This criteria should provide a reasonable alternative to the Code requirements.-

Based on the determination that imposing the Code requirements on the

-licensee would result in hardship without a compensating increase in the level of_ safety and considering the licensee's proposed alternate testing provides a reasonable alternative to the Code requirements, relief should be granted provided the licensee includes in their analysis a determination on the 14 l

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capability of the system to perform its safety-related function (s) with the failure present.

3.1.2 Pressure liolation Valves (PlVs) 3.1.2.1 Relief Reogni.

The licensee requested relief from the leak rate testing requirements of Section XI, IWV-3427(b), for various category A and A/C pressure isolation valves (PlV's) and proposed to leak rate test these PlV's in accordance with plant Technical Specifications.

3.1.2.1.1 Licensee's Basis for Rtquestina Relief--Technical Specification Section 3.4.6.2 defines the limiting condition for operation and Section 4.4.6.2.2 defines the surveillance requirements for pressure isolation valves as follows:

"Each reactor coolant system pressure isolation valve specified in Table 3.4-2 shall be demonstrated operable pursuant to Specification 4.0.5 except that in lieu of any leakage testing required by Specification 4.0.5, each valve should be demonstrated operable by verifying leakage to be within the allowable leakage criteria of 1.0 gpm with an upper limit of the maxi'num allowable leakage in Table 3.4-2; and the measured leak rate for any given test cannot reduce the difference between the results of the previous test and the maximum allowable leakage specified in Table 3.4-2 by more than 50%,

a.

After each refueling outage b.

Whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or more, and if leakage testing has not been performed in the previous 9 months, and c.

Prior to returning the valve to service following maintenance, repair, or replacement work on the valve.

Alternate Testino:

The Technical Specifications-defined surveillance testing will be performed.

Per WASH 1400 Event V CF-30, CF-31, OH-76, and DH-77 will be leak tested prior to Reactor Startup when a differential pressure of 100 PSID or less has occurred across any of these check valves.

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3.1.2.1.2 Evaluation -!WV 3427(b) establishes trending requirements for leakage measurement.s of Category A valves.

The Code requires comparison of measured leakage rates with previous rates and if the margin between the previous rate and the maximum permissible rate has been reduced by 50% or more, the testing frequency must be doubled.

Corrective action is reouired when a trend derived from three or more tests, projects that the leakage rate of the next test will exceea the maximum rate by greater than 10%.

The licensee requests relief from IWV-3427(b) and proposes to use the leak rate acceptance criteria of the Davis-Besse Technical Specifications.

The proposed testing incorporates leak rate trending criteria similar to the Code and in most respects is at least equivalent to the Code.

The Davis-Besse plant Technical Specifications identify valves that are leak rate tested as pressure isolation valves and establishes the maximum i

permissible leakage rates, test pressure requirements, test frequency requirements, and required action if the leak rate is exceeded. The licensee's position is in accordance with the Generic Letter (GL) 89-04,, Item 4, position on PIV's. However, the licensee does not describe the corrective action to be taken in case a particular PlV fails to meet its specified leakage limit (i.e., is the valve operable; does it need to be repaired or replaced). Although the licensee's trending criteria appears equivalent to the Code, their corrective actions should be equal to or more conservative than those described by the Code.

Based on the determination that the proposed testing is essentially equivalent to the Code requirements, relief should be granted provided the licensee's corrective action requirements are equivalent to or more conservative than Code requirements of IWV-3427(b).

3.1.3 Valves Reauired to Reach Cold Shutdown 3.1.3.1 Relief Reauest.

The licensee requested relief from the requirements of Section XI, IWV 1100, which requires inservice testing of valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition. The licensee stated that Davis Besse Nuclear Power Station is licensed with hot standby being the safe shutdown mode and proposed to not include cold shutdown valves in their IST program.

16

3.1.3.1.i Licensee's Basis for Reauestina Relief--Davis Besse Power Station defires shutting down the reactor per Section 7.4.1 of the USAR as that station condition in which the reactor is 1.0 percent subcritical and the reactor coolant system temperature and pressure are in the normal operating range.

Per Davis Besse Technical Specification this condition is defined as Mode 3, Hot Standby. A Cold Shetdown is not required to shutdown the reactor.

The Licensing Basis for safe shutdown is Hot Standby.

Alternate Testinat No alternate testing is required.

Present inservice Testing program is limited to those systems and components to reach a safe shutdown condition.

This condition is defined as Mode 3, Hot Standby per Section 1.0, Definitions for Technical Specifications.

Those systems and components required to reach a Cold Shutdown conditions are addressed in an augmented valve-test program.

3.1.3.1.2 Evaluation--The Davis Besse Nuclear Power Station, Unit 1 is licensed by the NRC as a Hot Standby plant per the station's USAR, Section 7.4.1.

The licensee committed to include valves in their IST program which mitigate the consequences of an accident, provide overpressure protection, and perform a specific function in shutting down the reactor to the hot standby mode.

The licensee is adhering to the requirements of their plant Technical Specifications and Safety Analysis Report by which they were licensed.

The licensee's proposed IST program scope should provide a reasonable alternative to the Code requirements, furthermore, the licensee stated those systems and components required to reach r cold shutdown condition are addressed in an augmented valve test program.

Based on the determination that the licensee's alternative provides an acceptable level of quality and safety, relief may be granted as requested.

3.2 Auxiliary feedwater 3.2.1 Cateaory B Valves 3.2.1.1 Relief Reouest.

The licensee requetted relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413, for the 17

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auxiliary feedwater pump discharge to steam generator line flow control valves, AF 6451 and AF-6452. The licensee proposed to exercise and fail-safe tes* these valves on a quarterly basis, but not record the stroke time of these valves.

3.2.1.1.1 Licensee's Basis for Reaunstina Relief--These are Target Rock, solenoid operated valves with position indication from linear variable differential position transmitters.

l'alve position is determined by reading output voltage from the transmitter.

Operability is verified by measuring voltage changes at a test panel as the valve is exercised from a different test panel.

Because of the two locations and method of operability, verification is not possible to accurately measure stroke time.

i Alteenate Testina:

Valves will be exercised and fail safe tested quarterly.

3.2.1.1.2 Evaluation--These Target Rock, solenoid operated, control valves have no means of directly determining valve position.

Valve position indication is from a linear variable differential transmitter.

Timing these valves requires personnel at twn different test panels, one to operate the valve and the other to measure voltage changes due to valve position changes. This method of measuring the stroke times of these power operated valves is inaccurate and does not lead to repeatability of measurements.

Without a concise method of determining when the stroke is completed, it is extremely difficult to obtain repeatable stroke time data to

-monitor.for valve degradation. Due to these limitations in obtaining repeatable stroke times, it is impractical to trend stroke times for these l

fast acting solenoid operated valves.

In orc'er to obtain trendable stroke times for these valves during normal valve operation it would be necessary to perform system modifications and/or to replace these valves with ones that have direct position indication.

However, the licensee's proposal provides no means of detecting valve degradation.

Some means should be developed to monitor valve condition and detect degradation.

Even if system modifications are not performed to permit the measurement of trendable stroke times, it may be possible for the licensee to 18

develop a method of measuring stroke times and verifying that they remain l

under a reasonable maximum stroke time limit.

Alternatively it may be possible to obtain trendable stroke data during refueling outages with only limited extra measures, it would be burdensome to require the licensee to immediately develop a means of monitoring for valve degradation, therefore, and interim period should be provided for the licensee to develop a method of performing this testing. The licensee's proposal of verifying valve operational readiness by quarterly exercising and fail-safe testing should provide a reasonable assurance of operational readiness during the interim period.

Based on the impracticality of measuring and trending valve full-stroke times, the burden on the licensee if the Code requirements were immediately imposed, and considering the licensee's proposal should provide a reasonable assurance of operational readiness during the interim period, interim relief should be granted for the period of one year or until the next refueling outage, whichever is longer.

During the interim period, the licensee should develop an adequate means of monitoring for degradation of these valves.

3.2.2 Cateaory C Valves

' 2.1 Relief Reauest.

The licensee requested relief from the exerc uing frequency requirements of Section XI, Paragraph IWV-3410, for the following motor driven feedwater pump and auxiliary feedwater pump discharge to the steam generator line check valves, AF-39, -43, -72, 73, -74, and -75.

The licensee proposed to full flow test these check valves at refueling outages.

3.2.2.1.1 Licensee's Basis for Recuestino Relief--These lines are equipped with in-line cavitating venturis, Full-flow testing can only be performed with the steam generators at operating pressure.

Full flow testing at reduced pressure results in severe multi-phase flow in the downstream piping.

Hulti-phase flow at design operating flow rates cause extreme pipe movement similar to water hammer and could result in extensive damage to the pipe and pipe supports.

19

1 The only way to verify full flow operability during normal operation is by injecting relatively cold water into the steam generator.

The injection of cold water into the hot steam generators would cause unwanted thermal cycling of the OTSG tubes.

Testing with reduced flow (less than 100 gpm) at cold shutdown could cause excessive cooldown of the RCS and could induce steam generator water level and pressure transients.

Alternate Testina:

Valves will be full-flow tested at refueling.

3.2.2.1.2 Evaluation--The auxiliary feedwater lines, where these check valves are located, do not connect to a feedwater ring but spray directly on the once through steam generator (OTSG) tubes.

The source of water for the auxiliary feedwater system is the condensate storage tank (CST) or service water.

Service water is only used in an extreme emergency due to the chemistry problems it would create.

The CST water is kept chemically within limits and heated to approximately 110 degrees F. The normal downcomer temperature of the OTSG during power operation is approximately 540 degrees F.

Putting cool feedwater directly on the hot tubes of the OTSG would cause a large, unnecessary thermal transient on these tubes.

This thermal shock could lead to OTSG tube damage ir.d possibly a small break loss of coolant accident (t0CA),

it is impractical to full or partial-stroke exercise these valves during power operation due to the potential for OTSG tube damage.

it is impractical to full-stroke exercise these valves at cold shutdown because the large amount of feedwater sprayed directly on the OTSG tubes could cause an excessive cooldown rate in the RCS.

The system would have to be redesigned and undergo modifications in order to meet the Code requirements.

This would be costly and burdensome to the licensee.

The licensee's proposal to full-stroke exercise these valves during refueling outages should provide a reasonable assurance of operational readiness.

However, a partial-stroke exercise may be practical when shutting down the plant to cold shutdown or when starting the plant back up from cold shutdown.

The lower saturation-pressure verses saturation-t m perature in the OTSG would lessen the effects of thermal shock to the tubes and the cooldown to the RCS.

20

Based on the determination that compliance with the Code required test frequency is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable alternative to the Code requirements, relief may be granted provided that the licensee investigates a rethod to partial stroke exercise these valves at cold shutdown and document their findings.

3.3 Auxiliary Steam System 3.3.1 Cateaory C Valves 3.3.1.1 Relief Reouest.

The licensee requested relief from the exercising requirements of Section XI, Paragraph IWV 3522, for the Auxiliary.

Steam to Auxiliary feedwater Turbine Test Line Check Valve, AS-274.

The licensee proposed to verify reverse-flow closure each time the manual isolation _ valve, AS 273, is opened and the valve, AS 274, is exercised, but not more frequently than once every 92 days.

3.3.1.1.1 Licansee's Basis _fLhquftstina Relief--The only time this line is open is during modes 4, 5, and 6 for test purposes.

During normal operation the inline manual isolation valve AS-273 is maintained closed. The valve provides the boundary between the class 3 Auxiliary feedwater System and the non-class Auxiliary Steam System.

The only safety-related function for this valve is to remain closed on loss of Auxiliary Steam System integrity.

Alternate Testing:

Valve reverse flow closure will be verified each time the isolation valve has been opened and the valve is exercised, but not more than a frequency of once every 92 days.

3.3.1.1.2 Enlyltion-Auxiliary Steam val 'o, AS-274, is a nmple passive' check' valve. AS-274, which has a safety position of closed and is normally closed, functions to stop flow from the main steam system to the auxiliary steam system in case of a loss of auxiliary steam system integrity when manual isolatiou valve, AS-273, is open.

The only time AS-274 and AS-273 are open is during modes 4, 5, and 6 for test purposes.

Because this valve is normally closed, the only safety position is closed, and would never be out of 21 l

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position during power operations, it would not have to change position to perform its safety function. Also, in the unlikelihood of a steam line break occurring in this particular area, motor operated valves MS-106 and -106A can be shut immediately to isolate the leak. According to Section XI, Table IWV-3700-1, there are no tests required for Category C passive valves.

The licensee's proposal to reverse flow closure test valve, AS-274, each time the manual isolation valve is gpened, but not to exceed more than once every 92 days, should provide ar CotOc level of safety as provided by the Code.

Based on the deterup / *i) that the licensee's proposal provides an equivalent level of 56/ety a provided by the Code, relief should be granted as requested.

3.4 C n m fat Coolina Water System 3.4.1 Cateaory C YM13h 3.4.1.1 hlitf Rewait.

The licensee requested relief from the exercising frequency requirements of Section XI, Paragraph IWV-3522, for component cooling water inlet to RCS thermal barrier heat exchanger line check valves,00-183, -283, 383, and -483.

The licensee proposed to verify reverse flow closure during refueling outages.

3.4.1.1.k Liq usee's Basis for Reauestina 8eliqi--These tests cannot be performed quarterly during power operation because the system is in operation and cannot be isolated.

Also, these valves are inside containment.

These tests involve an exc'essive amount of time and personnel expo *.ure to hazardous environments, potential delay of plant startup, and are too complex to be performed during cold shutdown.

These valves will be scheduled for refueling outages.

Alterntte Testina: Reverse flow closure will be verified during refueling.

3.4.1.1.2 Evaluation--These valves are check valves, inside containment, in the supply line for cooling water to the reactor coolant pump (RCP) thermal barrier heat exchangers.

It is impractical to verify reverse flow closure of these valves quarterly during power operations because it 22 i

l

isolates cooling water to the thermal barrier heat exchanger for the RCP seals. The loss of cooling water when the RCS temperature is elevated could cause seal damage and create a small break LOCA.

Furthermore, containment entry would be required which is restricted during power operation because of high radiation levels and other personnel safety hazards.

The reverse flow closure test requires an extensive test setup involving a large number of man hours.

If this test were performed at cold shutdown it could delay plant start-up.

This would be costly and burdensome to the licensee.

The licensee's proposal to verify the reverse flow closure of these valves at refueling outage should provide a reasonable assurance of their operational readiness.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable alternative to the Code frequency requirements, relief should be granted as requested.

3.4.1.2 Relief Reauest.

The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3521, for the component cooling water pump discharge check valves, CC-17, -18, and -19.

The licensee proposed to verify reverse flow closure on a quarterly basis of the normally operating and installed spare pump discharge checks.

The discharge check valve on the normal standby pump will only be reverse flow closure verified when-the system is realigned such that it and the installed spare pump are aligned to the common header.

3.4.1.2.1 Licensee's Basis for Reauestina Relief--All three CCW pumps are to a common header.

The header is normally aligned such that two pumps are a?igrcd to one essential loop, with one pump normally in operation to supply normal operating loads.

The second pump is an installed spare and only started to replace the normally operating pump.

The third pump is aligned to the second essential loop and is normally in a standby mode.

To test all three pump discharge check valves for reverse flow closure would require opening header isolation valves and rotating operating pumps to the common header.

This system unfiguration would violate train separation criteria and could place the system in an unanalyzed condition.

23

Alternate Testina:

Reverse flow closure verification is only necessary for the check valve on the non-operating pump of the two pump discharge to a common header configuration.

Reverse flow closure of the normally operating and installed spare pump discharge check valves will be performed quarterly during pump testing. The discharge check valve of the normal standby pump will only be reverse flow closure verified when the system is realigned such that it and the installed sparc pump are aligned to the common header.

3.4.1.2.2 Evaluation--The licensee has not provided adequate technical information nor justification for this relief request. The train separation criteria which could place the system in an unanalyzed condition should be supplied for review along with the source of information.

The licensee has stated that reverse flow closure verification is only necessary for the check valve on the non-operating pump of the two pump discharge to a common header configuration, however, this configuration can be realigned making the non-operating pump any one of the three pumps and thereby necessitates the reverse flow closure verification of all three pump discharge check valves. The licensee has not given a specified time interval, (i.e.

cold shutdown, refueling, etc.), as to when the system can be realigned such that all pump discharge checks can be tested.

Based on the determination that the licensee has not adequately demonstrated the impracticality of perforning the testing at the Code required frequency nor has the licensee demonstrated that the Code testing would constitute a hardship without a compensating increase in the level of safety and quality, and considering that the licensee has not spea fted the test interval for tLe normal standby pump check valve, relief should be denied.

3.5 Containment Hydroaen Control 3.5.1 Cateaory A/C Valves 3.5.1.1 Relief Reauest. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3522, for the containment isolation hydrogen control check valves, CV-124, -125, -209, and -210.

The licensee proposed to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages.

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3.5.1.1.1 Licensee's Basis for Reouestina Relief--The only method available to verify reverse-flow closure is by valve leak testing during Appendix J, Type C, testing at refueling.

Alternate Testing:

Reverse-flow closure will be verified during Appendix J.

Type C, testing at refueling.

3.5.1.1.2 EvaluatioD--These are simple check valves located inside containment. The only practicil method to verify their reverse flow closure is to perform an back flow / leak rate type test.

It is impractical to leak test these valves during power operations because both the valves and necessary connections are located inside centainment. Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing these valves is a non-routine test which requires containment entry, extensive test setup, and a 1:rge number of man hours.

Leak testing these valves during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify valve reverse flow closure in conjunction with the Appendix J. Type C, testing at refueling outages should provide a reasonable assurance of the reverse flow closure capability of these valves.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed.

and considering that the alternate testing should provide a reasonable assurance of velve operational readiness, relief should be granted as requetted, a

3.6 Containment Vacuum Relief 3.6.1 Cateaory A/C Valves 3.6.1.1 Relief Reauest.

The licensee requested relief from the check valve exercising requirements of Section XI, Paragraph IWV-3522, for the containment vacuum relief containment isolation check valves, CV 5080 through CV-5089.

The licensee proposed to verify reverse flow closure in conjunction with the Appendix J Type C testing at refueling outages.

L 25

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3.6.1.1.1 Licensee's Basis for Reouestina Relief--The only method available to verf fy reverse-flow closure is by valve leak testing during Appendix J Type C, testing at refueling.

j Alternate Testina:

Reverse-flow closure will be verified during Appendix J.

Type C, testing at refueling.

3.6.1.1.2 Evaluation--These are simple check valves which open to allow air to enter cont *'nment in case a vacuum is sensed inside containment.

These valves also function in the close position to prevent containment air from escaping when the containment is under pressure.

There is no installed instrumentation in these lines.

The only practical means to verify reverse flow closure of these valves is to perform some type of back flow / leak rate test.

It would be impractical to perform a leak test during power operations

- because the valves and the test connections are located at the top of the containment vessel between the vessel and the shield building, and the difficulty in setting up the leak test <.pparatus.

Leak testing these valves is a non-routine test which requires an extensive test setup and a large number of man-hours.

Leak testing these valves during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The_ licensee's proposal to verify valve reverse flow closure in conjunction with an Appendix J. Type C, leak test during refueling outages should provide a reasonable assurance of the reverse flow closure capability of these valves.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable assurrnce of valve operdional readiness, relief should be granted as requested.

26

~...

3.7 Core flood Systen,)

3.7.1 Cateaory A and A/C Valves 3.7.1.1 Relief Reouest.

The licensee requested relief from the check

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valve exercising frequency requirements of Section XI, Paragraph IWV-3522, for the nitrogen and core flood tank fill line containment isolation check valves, CF-15 and 16.

The licensee proposed to verify reverse flow closure in conjunction with-Appendix J. Type C, testing at refueling outages.

3.7.3.1.1 Licensee's Basis for Reauestina Relief--The only method available to verify reverse-flow closure is by valve leak testing during Appendix J. Type C, testing at refueling.

Alternate Testina:

Reverse-flow closure will be verified during Appendix J, Type C, testing at refueling.

3.7.1.1.2 flaluation--These are simple check valves located inside containment.

The only practical method to verify reverse flow closure is to perform some type of back flow / leak rate test.

It is impractical to leak test these valves during power operations because both the valves and the test connections are located inside containment. Containment entry is restricted during power operations due to radiation exposure and other personnel _ safety considerations.

Leak testing these valves is a non-routine test which requires containment entry, an extensive test setup, and a large number of mhn-hours.

Leak testing these valves during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify valve reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages should provide a reasonable assurance of the reverse flow closure capability of these valves.

1 l

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable assurance of operational readiness of these valves, relief should be granted as requested.

27 1

l 3.7.1.2 Relief Renyni. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3522, for the core flood tank discharge check valves, CF-28 and CF-29. The licensee proposed to verify forward flow capability at refueling outages when the reactor vessel head is removed.

4.7.1.2.1 Licensee's Basis for Reauestina Relief--The Core Flood Tanks are isolated from the RCS by these normally closed check valves.

Each Core Flood Tank is charged with a nitrogen blanket at approximately 600 psig.

This pressure is insufficient during operation to inject into the RCS.

If these vales were to be exercised at cold shutdown, the cc,ntents of the tanks would be dumped into the RCS at the charged pressure which would interfere with RCS depressurization, inventory control, boron control and could result in the overpressurization of the RCS.

Alternate Testina: These valves will be forward flow operability verified at refueling when the Reactor Vessel Head is removed and the Core Flood Tanks can be dumped into the Reactor Coolant System.

Flow rate is measured during the dump test to verify that-the valves open sufficiently to pass full flow rate.

3.7.1.2.2 Evaluation--The core flood tanks are pressurized to 600 psig and the outlet valves are opened prior to exceeding 800 psig in the reactor coolant system (RCS) per standardized Technical Specifications. This 600 psig is insufficient to overcome normal operating RCS pressure, normally 2155 psig, during power operations. Therefore, it is impractical to full or-partial-stroke open these valves during power operation.

It would also be impractical to full or partial-stroke open these valves during cold shutdown, with the reactor coolant system intact, because discharging the core flood tanks could exceed the reactor vessel brittle fracture prevention limit creating a concern for brittle fracture of the reactor vessel and/or RCS piping. With the RCS vented during cold shutdown, full-stoke exercising these valves would be impractical because it would interfere with boron and inventory control.

System design changes and modifications would be required in order to perform the testing at the Code required frequency.

These system modifications would be costly and burdensome for the licensee.

The licensee's proposal to full-stoke exercise these valves during refueling outages when the 28

l I

reactor vessel head is removed should provide a reasonable assurance of operational readiness.

i However, when shutting down to cold shutdown, it may be practical to perform a partial-stroke test by allowing the core flood tanks to dump a small i

amount into the RCS. This would not adversely affect inventory or boron control in the RCS since both are boron and make up are needed during plant cooldown.

The concern for brittle fracture or pressurized thermal shock is dec' eased because of the small amount of water injected and a steam bubble in the pressurizer.

The licensee should investigate a partial stroke test of these valves when shutting the plant down to cold shutdown.

The licensee indicated that flow rate will be measured during the refueling outage testing. Accordia.g to the P&lD's, these lines do not have installed flow rate instrumentation.

If the flow rate is being calculated or determined by a means other than direct measurement, the licensee should describe the method used and the obtainable accuracy so this information can be evaluated to determine the acceptability of the proposed testing.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should ovide a reasonable assurance of operational readiness of these valves, relief should be granted provided the licensee investigates a method to partial-stroke exercise these valves when shutting down the plant to cold shutdown and document their findinga.

3.8 Decay Heat lystem 3.8.1 Category B Valves 3.,8.1.1 Relief Request.

The licensee requested relief from tha test frequency requirements of Section XI, Paragraph IWV-3412, for the decay heat /LHI containment sump block valves DH-9A and DH-9B.

The licensee proposed to exercise and time these valves at refuellrg outages.

29

3.8.1.1.1 Licensee's Basis for Reouestino Relief-Exercising these valves during normal operation would require closing Borated Water Storage Tank outlet valves, DH7A and DH7B which would make the normal flowpath to Makeup and Purification, High Pressure Injection, and Low Pressure Injection Systems inoperable.

In addition DH9A and DH98 provides cor.tainment integrity by be,ng closed during normal operation. Testing of these valves would place the plant in an undesirable condition.

Alternate Tr.iting:

Exercise and time at refueling.

3.8.1.1.2 Evaluation--It is impractical to test these valves dudng power operation because it would require isolating the borated water storace tank (BWST) from one train of safety system components and thereby cause one train of HPI, LPI, and reactor building spray to be declared inoperable.

This could place the plant in an unanalyzed condition.

However, the licensee did not adequately demonstrate the impracticality of performing the Code required testing during cold shutdown. Also, the licensee has not demonstrated that performing the Code testing during cold shutdown would constitute a hardship without a compensating increase in the level of quality ard safety, Based on the above determination, relief should be denied. The licensee should perform the Code required testing during cold

-shutdown, or submit a relief request with adequate technical justification for not performing the Code required testing at cold shutdown.

3.9 Emergence Diesel Generator Air Start Systems 3.9.1 Cateoorv B Valves 3.9.1.1 Relief Recuest. The licensee requested relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413, for the emergency diesel enerator (EDG) air start valves, DA-1147A, -1147B, -1148A, and -1148B. The licensee proposed to monitor the condition of the air. start valves indirectiy by observing the starting time of the diesel generator at least once each quarter.

30 l

l Licensee's Basis for Regt estino Relief--These are 3.9.1.1.1 l

three way solenoid valves mounted on the Diesel Generator (DG) skid mounted package. They are in the DG air start line between the Air Receiver Tanks and the Air Start Manifolds.

Since each generator has two tanks and two manifolds, the DG may start on air supplied by either or both tani The diesel generator test procedure verifies operability of each of trew < alves independently on an alternating basis by isolating one air start he. der and starting the DG from one header at a time.

Stroke time cannot be measured because there are no position indicators and visual observation is not possible due to valve design.

The total time from initiation to DG operation is measured such that in effect each valve's stroke tima is verified as acceptable. The DG start test is performed more frequently than required by Section XI so that actual valve testing criteria is more limiting ;han Section XI requirements.

Alternate Testina:

These valves will be tested as part of the diesel generator air start test. Acceptable diesel generator start time will be used to verify valve operability and acceptable stroke time.

3.9.1.1.2 Evaluation--The air start solenvid valves are small, rapid acting valves that are ccmpletely enclosed.

They operate from an engine start control signal rather than a control switch and do not have remote position indication or any external means to determine valve position.

Therefore, it is impractical to stroke time test these valves as required by the Code.

Since these valves must operate rapidly to start the diesel within the allowed time, significant degradation or the failure of one of these valves to function would be indicated by increased diesel generator start times and would cause an investigation into the cause of the failure.

In order for the licensee to time these valves according to the Code requirements the diesel air start system would have to be redesigned and modified.

These modifications would be costly and burdensome to the licensee.

The licensee has indicated that each of these valves are tested independently on an alternating basis by isolating one air start header and starting the EDG from one header at a time.

The licensee's proposal to verify these valves operable by confirmation of proper EDG start times provides adequate assurance of the I

operational readiness of these valves.

31

Based on the determination that compliance with the Code requirements is

-impractical, the burden on the licensee if the Code requirements were imposed,.

and considering that the licensee's proposal should provide a reasonable assurance of valve operational readiness, relief should be granted as requested.

3.10 Hiah Pressure In.iection System 3.10.1.QAt.cgory C Valves 3.10.1.1 Belief Reouest.

The licensee requested relief from the check valve. test frequency requirements of Section XI, Paragraph IWV-3521, for the high pressure injection (HPI) to RCS line check valves, HP-48 through HP-51, and HP-56 through HP-59.

The licensee proposed to full-stroke exercise thesa valves at refueling outages.

3.10.1.1.1-licensee's Basis for Reaue,stina Reli_qi--Verification of forward flow operability can only be performed by injecting HPI pump flow-directly into the Reactor Coolant System. The HPI pumps have insufficient head to overcome normal RCS operating pressure for a full flow test.

Partial flow testing using the HPI_ pumps would inject cold borated water directly into the Reactor Vessel and would result in thermal shocking of the HPI nozzle thermal sleeves.

Verification of full design flow rate cannot be done at cold shutdown due to back pressure from the RCS and potential for low temperature overpressurization of de RCS.

Verification-of full flow operability can only be done at r fueling with the RCS depressurized.

Alternate Testina:

Forward flow operability will be verified by full flow testing at refueling.

3.10.1.1.2 Evaluation--The HPI-pumps have insufficient head -to inject full desis low at normal operating RCS pressure. Therefore, it is impractical to full-stoke exercise these valves during power operations.

It would be impractical to partial-stroke exercise these valves at power because the test would inject cold, borated water into the RCS, causing power transients and thermal shock to the HPI injection nozzles.

During cold shutdown, it is impractical to full or partial-stroke exercisu these check 32 l

valves because of the low temperature over pressure (LTOP) concerns and the e

possibility for pressurized * mal shock (PTS).

The system would have to be redesigned anu modifiad in order in exercise these valves at the Code required frequency.

These design changes and modifications would be costly and burdensome to the licensee.

The licensee's proposal to full-stroke exercise these valves at refueling outages should provide a reasonable assurance of operational readiness.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable assurance of operational readiness to the Code frequency requirements, relief should be granted as requested.

3.10.1.2 Relief Reauest.

The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3521, for the high pressure injection pump discharge line check valves, HP-10, -11, -22, and -23.

The licensee propost to full-stroke exercise these valves during refueling outages and perform a partial-stroke exercise durin5 quarterly pump testing.

3.10.1.2.1 Licensee's Basis for Reauestina Relief--The only possible way to verify forward flow operability during normal operation is by flow measurement during quarterly pump testing through the orifice three-inch pump test recirculation line back to thc Borated Water Storage Tank.

The pump test flow rate is approximately 290 gpm.

The design accident flow rate for these valves is approximately 600 gpm.

The only flow prth that can be used to perform a full flow test would inject HPI pump flow directly into the Reactor Coolant System.

Full flow testing can only be done at refueling (see RV-1).

3 Alternate Testina:

The valves will be partial forward flow operability verified quarterly during pump testing and full forward flow tested at refueling with the RCS depressurized.

3.10.1.2.2 Evaluatio_n--The HPI pumps have insufficient head to inject full design flow at normal operating RCS pressure.

Therefore, it is impractical to full-stroke exercise these valves during po<er operations.

33

l.

r These valves are partial-stroke exercised during power operations with quarterly pump testing using a 3 inch test and recirculation line.

This is a partial-stroke exercise because full design accident flow rate cannot be achieved in the smaller recirculation line. During cold shutdown, it is impractical to full-stroke exercise these check valves because of the L10P concerns and the possibility for PTS.

The system would have to be redesigned and modified in order to full-stroke exercise these valves at the Code required frequency. These design changes and modifications would be costly

.and burdensome to the licensee. The licensee's proposal to partial-stroke exercise these valves quarterly with pump testing and full-stroke exercise these valves at refueling outages should provide a reasonable assurance of operational readiness.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and consicering that the alternate testing should provide a reasonable assurance of operational readiness, relief should be granted as requested.

3.11 Instrument Air Systen 3.11.1 Cateaory A/C Valves 3.11.1.1 Relief Reauest. The licensee requested relief from the check valve exercising test frequency requirements of Section XI, Paragraph IWV-3521, for instrument air supply containment isolation check valve IA-501.

The licensee proposed to verify reverse flow closure at refueling outages in conjunction with Appendix J, Type C testing.

3.11.1.1.1 Licensee's Basis for Reauestino Relief--The only method available to verify reverse-flow closure is by valve leak testing during Appendix J, Type C, testing at refueling.

Alternate Testina:

Reverse-flow closure will be verified during Appendix J,

. Type C, testing at refueling.

3.11.1.1.2 Evaluation--This is a simple check valve located inside containment.

The only practical method to verify reverse flow closure 34 1

is to perform some type of-back flow / leak rate test.

It is impractical to leak test this valve during power operations because the valve and its test connections are located inside containment. Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing is a non-routine test which requires containment entry, an extensive test setup, and a large number of man-hours.

Leak testing this valve during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages should provide a reasonable assurance of the reverse flow closure capability of this valve.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable assurance of the reverse flow capability of this valve, relief should be granted as requested.

3.12 Main Steam System 3.12.1 Cateaory C Valves 3.12.1.1 Relief Reauest. The licensee requested relief from the exercising requirements of Section XI, Paragraph IWV-3522, for main steam to auxiliary feedwater pump turbire line check valves MS-726 and -727.

The licensee proposed to use sample disassembly and inspection to verify the

- reverse flow closure capability of these valves.

3.12.1.1.1 Licensee's Basis for Reauestina Relief--There are no system design provisions for verification of reverse flow closure.

Alternate Testina:

Forward flow operability is verified quarterly during auxiliary feedwater pump testing.

In addition, one valve will be disassembled, inspected and manually full-stroke exercised each refueling consistent with item 2 of Attachment 1 to NRC Generic letter 89-04.

3.12.1.1.2 Evaluation--These simple check valves are located in the main steam supply line to the auxiliary feedwater pump turbine. The use l

35

~ 'y 1 lof disassembly:and inspection to verify closure capability (i.e. back flow) may be found to be acceptable depending on whether verification by flow or pressure measurements is practical. The licensee has not demonstrated the impracticality of verifying-valve reverse flow closure by flow or pressure-measurements.

However, a review of_the system-P&ID show that there-is no-position indication,- test taps or installed instrumentation which can be used to verify reverse flow' closure.

It appears the only practical method to verify reverse flow closure of these valves is to disassemble and inspect

-them.- It is impractical to_ disassemble and inspect these valves during power operations because these lines are pressurized with main steam pressure.

Furthermore, isolating these-lines at power, could make the auxiliary feedwater pump inoperable'for an extended period of time. This could place the plant in_a LCO action statement and may require a plant shutdown in accordance with plant technical specifications. Disassembly and inspection is

- a non-routine test requiring a large number of man hours and the placing of the plant in a particular configuration.

Performing this test at cold shutdown could delay plant startup. -This-would be costly and burdensome to

-the licensee. The licensee's proposal to sample disassemble and inspect these valves during refueling outages should provide a-reasonable assurance of the reverse' flow closure capability of these valves provided the disassembly and inspection is performed in accordance with the GL_89-04, Attachment _l, Item 2 position.

Furthermore, if possible, a partial-stroke exercise should be

' performed prior __ to returning these valves to service.

This would provide reasonable assurance-that the reassembly of these valves was performed correctly..It-may-be prudent for the licensee to investigate into other-methods to verify reverse flow closure of these valves.

The installation of isolation valves, test taps, instrumentation, or the use of non-intrusive valve diagnostics might be used to verify reverse-flow closure and be less burdensome to the_ licensee than valve disassembly.

Based on the determination _that_ compliance with the Code requirements is-

-impractical, the burden on the licensee if the Code requirements were imposed, and considering that the licensee's. proposed alternate conforms to the GL 89-04, Attachment 1, Item 2, position, relief may be granted provided the licensee performs a partial-stroke exercise of the reassembled valve prior to returning it to service.

Furthermore, the licensee should document in their IST program the technical basis for not verifying the reverse flow closure of 36 C

these valves using flow, pressure measurements, or non-intrusive valve diagnostics.

3.13 Make Up System 3.13.1 Cateaory A/C Valves 3.13.1.1 Relief Reouest.

The licensee requested relief from the exercising frequency requirements of Section XI, Paragraph IWV-3521, for RCS pump seal supply line containment isolation check valves, MU-242 through j

MU-245.

The licensee proposed to verify reverse flow closure in conjunction with Appendix J, Type C, leak testing at refueling outages, i

e 3.13.1.1.1 Licensee's Basis for Recue.iLina Relief TSs. only method available to verify reverse flow closure is by val"e leak testing during Appendix J, Type C, testing at refueling.

Alternate Testina:

Reverse flow closure will be verified during Appendix J, Type C, testing at refueling.

3.13.1.1.2 Evaluatio.n--These are simple check valves located inside containment. The only practical method to verify reverse flow closure is to perform some type of back flow / leak rate leak test.

It is impractical j

to leak test these valves during power operations because these valves and their test connections are located inside containment.

Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing is a non-routine test which requires containment entry, an extensive test setup, and a large number of man-hours.

Leak testing these valves during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages should provide a reasonable assurance of the reverse flow closure capability of these valves.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing should provide a reasonable 37 l

I 4

assurance of valve operational readiness, relief should be granted as requeded.-

13.13.2 fateoorv-C Valves 3.13,2.1-Relief Reouest. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3521,-far normal make-up to' RCS line'~ check valve, MU-169. The. licensee proposed to

partial-stroke exercise. this valve quarterly and full-stroke exercise this valve at: refueling outages.

)

3.13.2.1.1; Licensee's Basis for Reouastino Relief--During normal

. operation makeup flow to' the RCS is automatically regulated in response to RCS conditions by upstream flow control valve MU-32. To inject full flow into the -

RCS during normal-operation would result in undesirable RCS boron concentrations,-system temperature and level transients and could result in thermal shock to the high-pressure injection nozzle thermal sleeve.

In addition, the MU-pumps are incapable nf. overcoming RCS operating _ conditions sufficiently to inject' full _ feed and bleed design flow rate. The makeup pumps-

~

cannot be run at full feed and' bleed flow rate at cold shut'down with the reactor. vessel head in place due to the inability to letdown that full flow.

-This could result in a low temperature overpressurization 'of the RCS.

Alternate' Testina.: Thirvalve will-be partial-stroke exercised quarterly I

utilizing normal makeup flow and full-stroke exercised at refueling outages by verifying that. the valve opens to pass full flow rate.

3.13.2.1.2. Evaluation--Valve, MU-169, is _ located in the normal makeup line to-the RCS. -It would be impractical to-full-stroke exercise this valve._during power operations because the make-up pumps cannot establish maximum accident flow rate into the _RCS--at _ normal operating pressure.

Further, injection: of full make-up flow into the RCS would cause an Lundesirable temperature and level transient.

It would be impractical to full-stroke exercise thisivalve with the RCS intact during cold shutdown because of the LTOP concerns and the possibility of PTS.

The system would have to be redesigned and undergo modifications in order to perform-testing at 38

the Code required frequency. This would be costly and burdensome to the licensee.

The licensee's proposal to partial-stroke exercise MU-169 quarterly and full-stroke exercise this valve at refueling outages should provide a reasonable assurance of the reverse flow closure capability of this valve.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the-licensee's alternate testing should provide a reasonable assurance of operational readiness, relief should be granted as requested 3.13.2.2 Relief Reouest. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3521, for the'make-up to RCS feed and bleed line check valve, MU-800.

The licensee proposed to full-stroke exercise this valve at refueling outages.

3.13.2.2.1 Licensee's Basis for Reouestino Relief--This line is isolated during all modes of operation except during the MU system feed and bleed mode of operation. To test the valve by injecting makeup flow into the RCS during normal operation would result in undesirable RCS boron concentrations, system temperature and level transients and could result in thermal shock to the high pressure injection nozzle thermal sleeve.

In addition, the MU pumri are incapable of overcoming RCS operating conditions sufficiently to inject full feed and bleed design flow rate.

The makeup pumps cannot be run at full feed and bleed flow rate at cold shutdown with the reactor vessel head in place due to the inability to letdown that full flow.

This would result in a low temperature overpressurization of the RCS.

Alternate Testino: This valve will be full stroke exercised during refueling outages by verifying that the valve opens to pass full forward flow rate.

3.13.2.2.2 Evaluation--Valve, MU-800, is located in the makeup to feed and bleed line to the RCS.

It is impractical to full-stroke exercise this valve during power operation because the make-up pumps cannot establish maximum accident condition flow rate into the RCS at normal operating l

pressure.

Further, injection of full make-up flow into the RCS would cause an l

undesirable temperature and level transient.

It would be impractical to 39

9

-full-stroke exercise this valve with the RCS intact during cold shutdown because of LTOP concerns and the possibility of PTS.

The system would have to be redesigned and undergo modifications in order to perform testing at the Code required frequency. This would be costly and burdensome.to the licensee.

The licensee's proposal to full-stroke exercise MU-800 during refueling outages should provide a reasonable assurance of operational readiness.

However, the licensee stated the line in which MU-800 is located in is in operation during the flu system feed and bleed mode of operation.

This mode o' operation of the make-up syster is frequently used when placing the plant in on coming out of cold shutdowr he licensee has not demonstrated the impracticality of partial-stn.

thi* "alve while placing the plant in or coming out of cold shutc ense,=nould investigate the v

possibility of partial-stroke ers

. b a when entering or exiting cold shutdown.

The licensee shot' Tindtags in their IST program.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the licensee's alternate testing should provide a reasonable assurance of valve operational readiness, relief should be granted as requested.

3.13.2.3 Relief Reouest. The licensee requested relief from the check valve exercising frequency _ requirements of Section XI, Paragraph IWV-3521, for makeup pump minimum flow line check valves, MU-204 and MU-207.

The licensee proposed to full-stroke exercise these valves during refueling outages.

3.13.2.3.1 Licensee's Basis for Reouestina Relief--Forward flow operability of these valves cannot be verified by line flow rate due to lack of installed instrumentation.

Flow rate can only be obtained by using the borated water storage tank as the makeup pump liquid supply and measuring a known volume increase over time in the makeup tank.

l Alternate Testina:

These valves will be forward flow tested each refueling by measuring a-volume _ increase on the makeup tank over time, i

i 40

3.13.2.3.2 Evaluation--Check valves MU-204 and MU-207 are located in the minimum recirculation lines for makeup pumps P37-1 and -2.

These lines have no installed instrumentation. These lines are used only to protect the pump and not for quarterly pump testing.

In order to test these check valves it would require a special valve line-up.

It is impractical to full or partial-stroke exercise these valves during power operations because there is no installad instrumentation and the special test line up would require isolating RCP seal return and other necessary systems in order to isolate the make-up tank to perform the test.

Furthermore, the BW3T would have to be used as the fluid source which would upset the boron concentration in the RCS and could cause a plant transient or reactor shutdown.

However, the licensee has not provided adequate technical sustification showing impracticality or hardship without a compensating increase in the level of safety when performing the Code required testing during cold shutdown.

Based on the determination that the licensee has not provided adequate technical justification showing impracticality or hardship without a compensating increase in the level of safety, relief is denied.

3.13.2.4 Relief Reauest.

The licensee requested relief from the check valve exercising frequoncy requirements of Section XI, Paragraph IWV-3521, for makeup rump discharge line check valves, MU-196 and MU-197. The licensee proposed to partial-stroke exercise these valves quarterly with normal makeup flow and full-stroke exercise these valves at refur' Nq outages.

3.13.2.4.1 Licensee's Basis for Reouestina Relief--During normal operation makeup flow to the RCS is automatically regulated in response to RCS conditions by upstream flow control valve MU-32.

To inject full flow into the RCS during normal operation would result in undesirable RCS boron concentrations, system temperature and level transients and could result in thermal shock to the high pressure injection nozzle thermal sleeve.

in addition, the MU pumps are incapable of overcoming RCS operating conditions sufficiently to inject full feed and bleed design flow rate.

The makeup pumps cannot be run at full feed and bleed flow rate at cold shutdown with the 41

reactor vessel head in place due to the inability to letdown that full flow.

This could result in a low temperature overpressurization of the RCS.

Alternate Testina:

These valves will be partial stroke exercised quarterly utilizing normal makeup flow and full stroke exercised at refueling outages by verifying that the valves open to pass design flow.

3.13.2.4.2 Evaluation--These valves, MU-196 and MU-197, are located in the makeup pump discharge lines to the RCS.

It is impractical to full-stroke exercise these valves during power operation because the make-up pumps cannot establish maximum accident condition ficw rate into the RCS at power operations pressure.

Furthermore, injection of full flow would cause an undesirable temperature, level, and boron transient in the RCS.

It is impractical to full-stroke exercise these valves with the RCS intact at cold shutdown because of the low temperature overpressure (LTOP) concerns and the possibility of pressurized thermal shock (PTS). The licensee would have to redesign and modify the present system or open the RCS every cold shutdown; possibly delaying plant start-up.

It would be costly and burdensome to the

.lijensee to redesign and modify the system or open the RCS every cold y

shutdown.

Thelicensee'sproposalt[ partial-strokeexerciseMU-196and MU-197 quarterly and full-stroke exercise these valves at refueling outages provides a reasonable assurance of operational readiness.

Based on the determination that compliance with the Code required test frequency is impractical, the burden on the licensee if the Code requirements p.

were imposed. and considering that the alternate testing provides a reasonable assurance of operational readiness, relief should be granted as requested.

3,14 Nitroaen System 3.14.1 Cateaory A/C Valves 3.14.1.1 Relief Reauest.

The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3521, for nitrogen system containment isolation check valve, NN-58.

The licensee proposed to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages.

42 l

1 3.14.1.1.1 Licensee's Basis for Reauestina Relief-lhe only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C, testing at refueling.

Alternate Testino:

Reverse-flow closure will be verified during Appendix J, Type C, testing at refueling.

3.14.1.1.2 Evaluation--This is a simple check valve located inside contattiment. The only practical method to verify reverse flow closure is to perform some type of back flow / leak test.

It is impractical to leak test this valve during power operations because it is located inside containment.

Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing is a non-routine test which requires an extensive test setup and a large number of man-hours.

Leak testing this valve during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages provides a reasonable assurance of the reverse flow closure capability of this valve.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing provides a reasonable assurance of the reverse flow closure capability of this valve, relief should be granted as requested.

3.15 Reactor Coolant System 3.15.1 Cateaory A/C Valves 3.15.1.1 Relief Reauest. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3522, for the pressurizer quench tank inlet line containment isolation check valve, RC-113.

The licensee proposed to verify reverse flow closure in conjunction with Appendix J, Type C, testing during refueling outages.

43

)

3.15.1.1.1 Licensee's Basis for Reouestino Relief--The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C, testing at refueling.

Alternate Testino:

Reverse flow closure will be verified during Appendix J, Type C,. testing at refueling, 3.15.1.1.2 Evaluation--This is a simple check valve located inside containment.

The only practical method to verify reverse flow closure is to perform some type of back flow / leak test.

It is impractical to leak test this valve during power operations because it is located inside containment.

Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing is a non-routine test which requires an extensive test setup and a large number of man-hours.

Leak testing this valve during cold shutdown could delay plant start-up which would-be costly and burdensome to the licensee. The licenree's proposal to verify reverse flow closure in conjunction with Appendix J, Type C, testing at refueling outages provides a re~asonable assurance of the reverse flow closure capability of this valve.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing provides a reasonable assurance of the reverse flow clusure capability of this valve, relief should be granted as requested.-

3.15.2 Cateoory B and B/C Valvn 3.15.2.1 Relief Reauest. The licensee requested relief from the exercising frequency and stroke time measurement requirements of Section XI, Paragraphs IWV-3412 and -3413 (b), for power operated valve (PORV), RC-2A, the

- pressurizer power operated relief valve.

The licensee proposed to full-stroke -

exercise this valve at refueling outages per DB-SP-03366, pressurizer PORV

-cycle test. There is no alternative proposed for timing the stroke of this valve.

j 44

1

=

3.15.2.1.1 Licensee's Basis for Reauestino Pelief--Full stroking and timing cannot be visually verified or measured on this valve since the valve mechanisms are internal.

Only indication in the control room is an electrical signal to RC-2A's pilot valve which does not indicate true valve position but only the open demand signal. Acoustic monitors provide flow indicatior, however these are independent of the valve. There is no fail position for this valve.

System testing at normal pressure and temperature cannot occur since this would cause a large pressure drop in the RCS hence causing a pressure transient with a possible Low Pressure Reactor Protection Trip.

Valve testing with the PORV Block Valve (RC 11) closed cannot occur since system pressure is the motive force for opening the valve, Valve testing cannot occur at cold shutdown because the correct cond'tions for the testing may not be present.

Testing can only occur during a defined RCS pressure band to ensure the valve has sufficient motive force to stroke open, to limit any RCS system pressure transient, and to limit generation of radioactive waste.

Alternate Testina:

Valve will be fully stroked at refueling per DB-SP-03366, Pressurizer Powered Operated Relief Valve Cycle Test. This will measure acceptable flow through the PORV by timing pressure drop from 200 psig to 190 psig or from 100 psig to 90 psig. This drop in pressure is correlated to flow and must occur in a set time period.

RCS pressure must be at approximately 200 psig to meet prerequisites for this test, hence the test will occur during refueling.

Channel calibration of PORV setpoint occurs every refueling per DB-MI-03051, Channel Calibration of 58A-ISPRC02B2 RCS Pressure to RPS Channel 1.

Present setpoint as allowed by Technical Specification is less than 2355 psig.

This test verifies the solenoid associated with RC-2A will energize at the system setpoint.

3.15.2.1.2 Evaluation--The pressurizer PORV is a pilot actuated, pressure assisted relief valve with no external valve position indication.

45 l

1The PORV is located on top of the pressurizer inside containment.

The control room indication is based on the electrical demand signal to the pilot valve, t

which is not a true indication of valve position. The only other means of PORV position indication is downstream tailpipe temperature and acoustic monitors. With no positive means of valve indication, stroke timing the PORV does not give repeatable data.

It is impractical to test this valve during i ^

power operations because it would cause a severe pressure transient in the

{

RCS. This could possibly cause a reactor trip on low RCS pressure or high l

pressurizer level.

Testing the PORV with the block valve shut, gives little information since_the valve is pressure assisted in the open direction.

It is

+

-impractical to test the PORV during cold shutdown because the test requires j

special plant conditions.

Establishing these special conditions in order to i

perform the test could delay plant shutdown operations and start-up.

This

[

would be costly and burdensome to the licensee.

The licensee proposed to test the PORV during refueling outages by timing the pressure drop between specific pressures.

The licensee is using this test as a means of determining flow rate, full-stroke exercising, and verifying valve operability.

This test method can be useful provided the licensee applies sufficiently restrictive acceptance criteria to permit monitoring and determination of valve degradation.

1 Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, and considering that the alternate testing provides a reasonable alternative

{

to the Code requirements, relief should be granted provided the licensee develops sufficiently restrictive acceptance criteria to permit monitoring and determination of valve degradation.

3.15.2.2 Relief Reauest. The licensee requested relief from the exercising frequency requirements of Section XI, Paragraphs IWV-3412 and

-3415, for post accident RCS loop vent valves, RC-4608A, -46088, -4610A, and RC-4610B. The licensee proposed to exercise, time, and fail-safe test these valves during refueling outages or at least once every 18 months as required by the plant Technical Specifications.

i' 46

9 3.15.2.2.1 Licensee's Basis for Reouestino Relief--These post-accident RCS loop vent valves are Valcor solenoid operated valves with magnetic position switches integral to the valve. This valve design-is susceptible to line pressure surges and will open if subjected to a pressure surges.

If the valves are cycled at system pressure the closed valve may be forced open and could result in a significant RCS leak.

Alternate Testino:

These valves will be full-stroke exercised and flow path verified operable at refueling or at least once every 18 months as required by the Plant Technical Specifications.

3.15.2.2.2 Evaluation--These Valcor solenoid operated valves are installed with two valves in series in each vent line.

However, due to their susceptibility to burping open when subjected to line pressure surges, it is not practical to exercise these valves quarterly during power operations.

Opening either valve could subject the other valve to a pressure surge that could cause it to open, thereby, releasing reactor coolant to the containment atmosphere and causing an RCS pressure and volume transient.

These valves would have to be replaced or the system substantially redesigned to permit testing during power operations.

It would be burdensome to require the licensee to make these costly modifications.

However, while in cold shutdown with the RCS intact and at a reduced RCS pressure, exercising these valves, one at a time, is less likely to affect the l -

other in line valve with pressure surges large enough to.cause inadvertent opening.

Furthermore, if the RCS is drained or vented during cold shutdown there should be no problem in performing these tests. The licensee has not I

shown that it is impractical or burdensome to test these valves during cold shutdown.

1 Based on the determination that the licensee has not demonstrated the-

. impracticality of exercising these valves during cold shutdown or that doing so would constitute a hardship without a compensating increase in the level of I

quality and safety, relief should be denied.

i 47

3.16 Service Water Systems 3.16.1 Cateoory C Valves 3.16.1.1 Relief Requgil. The licensee requested relief from the check valvc exercising frequency requirements of Section XI, Paragraph IWV-3522, for service water pump discharge check valves, SW-17, -18, and -19.

The licensee proposed to verify reverse flow closure only for the idle service. water pump discharge check valve.

Verification will be performed during pump switching and pump shutdown unless reverse flow closure has been verified within the previous 90 days.

3.16.1.1.1 Licensee's Basis for Recuestino Relief--During normal operation two of the three Service Water pumps are in operation.

The third pump is an installed spare and is aligned to the Essential Service Water train. The two trains are isolated from each other by normally closed manual cross-tie valves. The nonessential train supplies Service Water to the nonessential loads and the essential train supplies Service Water to the essential loads. To perform reverse flow closure verification on all three pump discharge check valves during normel operation would require realigning both the manual cross-tie header valves and the nonessential loads.

Realignment of the loads with pump rotation during, normal operation could result in temperature and pressure transients which could result in equipment damage or a forced plant shutdown.

9

' Alternate Testino:

Reverse flow closure will be verified or.ly for the idle service water pump. Verification will be performed during pump switching and pump shutdown unless reverse flow closure has been verified with the previous 90 days.

3.16.1.1.2 Evaluation--The licensee has not made it clear as to the frequency with which "ase check valves will be tested.

Relief cannot be granted to an indeterminate time interval.

With the redundancy designed into the system and the requirement for quarterly testing of the service water pumps, it -is unclear why these discharge check valves cannot be tested quarterly with their respective service water pump.

48

l l

Based on the determination that the licensee has not demonstrated the impracticality of exercising these valves during quarterly service water pump testing or that doing so would constitute a hardship without a compensating increase in the level of quality and safety, relief should be denied.

3.17 Station Air System 3.17.1 Cateaory A/C Valves 3.17.1.1 Relief Reoggil. The licensee requested relief from the check valve exercising frequency requirements of Section XI, Paragraph IWV-3522, for station air containment isolation check valve SA-5GE.

The licensee proposed to verify reverse flow closure capability of this valve in conjunction with Appendix J, Type C, testing during refueling outages.

3.17.1.1.1 Licensee's Basis for Reauestino Relief.--The only method available to verify reverse-flow closure is by valve leak testing during Appendix J, lype C, testing at refueling.

Alternate Testina:

Reverse-flow closure will be verified during Appendix J, Type C, testing at refueling.

3.17.1.1.2 Evaluation--This is a simple check valve located inside containment. The only practical method to verify reverse flow closure is to perform some type of back flow / leak test.

It is impractical to leak test this valve during power operations because it is located inside containment.

Containment entry is restricted during power operations due to radiation exposure and other personnel safety considerations.

Leak testing is a non-routine test which requires an extensive test setup and a large number of man-hours.

Leak testing this valve during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure capability in conjunction with Appendix J, Type C, testing at refueling outages provides a reasonable assurance of the reverse flow closure capability of this valve.

Based on the determination that compliance with the Code requirements is impractical, the burden on the licensee if the Code requirements were imposed, 49 l

4 d

and considering that the alternate testing provides a reasonable assurance of the reverse flow closure capability of this valve, relief should be granted as-requeste6.

W h

50

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i APPENDIX A P&ID LIST.

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M A-2

.g APPENDIX A P&ID LIST The P&ID's listed below were used in the course of this revi:w SYSTEM P&ID No.

Reactor Coolant-H-030A M-040A M-0#0B Core Flood M-033B M-034 Containment Spray M-034 Decay Heat M-033A M-033B M-033C M-042C Fuel 011 Transfer M-017A D. G. Air Start-M-017B High; Pressure Injection M-033A Makeup M-031A M-031B M-031C M-045 Main Steam M-003A H-003C M-007A M-0078 Feedwater M-006D M-0078 Auxiliary Feedwater M-006D M-0078 Service Water M-006D M-031C M-041A M-041B M-041C Component Cooling Water M-036A-M-036B M-036C M-0400 Containment Vacuum Relief M-029B Containment-Purge M-029E Containment Hydrogen Control M-029B M-0290 l-Aux. Bldg. Radwaste,- Fuel Handling L

and Access Control HVAC M-028B l

Nitrogen Supply M-019 M-036 Demineralized Water.

M-010C l

M-036A-L Sample M-007A M-040A i

Boric Acid Transfer M-045C A-3

s

~

SYSTEM 0 "0' Borated Water Instrument Air lA

^

Station Air

-0 D

Station Drainage

,3 Gaseous Radioactive Waste M-046 Auxiliary Steam

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M-003C A-4

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9 APPENDIX B AN0MALIES 4

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APPENDIX B AN0HAllES Inconsistencies and omissions in the licensee's program noted during the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

D 1.

In TER Section 2.2.1.1 of this report, the licensee requested expanded flow ranges in the Acceptable Range, Alert High Range, and the Required Action High Pange for service water pumps, P3-1,

-2, and -3.

The licensee's proposed expanded flow limits would increase the range of test quantities that would be allowable and could act to permit continued operation of a degraded pump.

Therefore, the licensee's proposed limits may be less conseravative and not provide an adequate level of pump operational readiness.

Relief may be granted with the provision that the licensee documents the expanded ranges as required in Section XI, lWP-3210.

The documentation should include the reason for the expended ranges and an explanation of how the expanded ranges will not mask any pump degradation.

For further details, see the above mentioned TER Section.

2.

In TER Section 2.2.2.1 of this report, the licensee proposed to measure horizontal vibration (radial vibration) on service water pumps, P3-1,

-2, and -3 in 2 planes, but is not measuring axial vibration.

Relief may be granted provided the licensee measures axial vibra son on the pump drivers and assign acceptance criteria so that co.iective action will be initiated when significant pump degradation occurs but prior to complete failure.

For further details, see the above mentioned TER Section.

3.

In TER Section 2.2.3.1 of this report, the licensee requested to perform testing of service water pumps, P3-1, -2, and -3, in the "as found" operating condition instead of returning to a particular reference condition.

Relief may be granted with the provision that the licensee develops the pump cur: or validate B-3 t

(

O t

the manufacturt 's pump curve when ths: pump is known to be operating acceptably.

Furthermore, the licensee should develop appropriate acceptance criteria for vibratien measurements at the various pump operating conditions.

For further details, see the above mentioned TER Section.

1 4.

In TER Section 2.3.1.1 of this report, the licensee requested relief from measuring pump flow rate, inlet and differential pressure and the duration of the test for the diesel generator fuel oil transfer pumps, P195-1 and -2. The licensee proposed to verify the operation of these pumps quarterly with the emergency i

oiesel generator test ar.d to calculate flow rato during refueling outages. However, the licensee's tests do not provide adequate information to evaluate the pump's hydraulic condition or monitor for pump degradation.

Interim relief may be granted for a period of one year or until the next refueling outage, whichever is langer, for the licensee to develop a suitable method to mon'.or for pump hydraulic ndition and degradation. For further details see the aouve mentioned TER Section.

5.

In TEh ction 2.3.2.1 of this report, the licensee requested relief trem measuring pump vibration for diesel fuel oil transfer pumps P195-1 and 2.

The licensee did not propose an alternative.

Although it is impractical and burdensome for the licensee to obtain the vibratica readings for these pumps, since pump inlet, discharge, and differential pressure are not being measured as indicated by Relief Request RP 5, TER section 2.3.1.1, the licenss should develop some means of monitoring for punp mechanical and hydraulic condition and be able to detect pump degradation.. Based on the determination that the licensee does not have a means to monitor for pump hydraulic and m chanical degradation, relief is denied. For further details, see the above mentioned TER Section, i

6.

D, TER Section 3.1.1.1 of this report, the licensee requested relief from the corrective action requirements of the Code, Paragraph IWV-3417 for various valves.

The licensee proposed to B-4

e l

use Technic.n Specification requirements as guidance in order to determine the possibility of plant start up/ mode change.

Relief may 40 granted provided the licensee ensures that the test failure analysis includes a determination on the systems capability to perform its safety related function (s).

7.

In TER Section 3.1.2.1 of this report, the licensee requested relief from the corrective actions requirements of the Code, Paugraph IWV 3427(b) for various Category A and A/C pressure isolation valves (PlV's). The licensee proposed to test these valves in accordance with Davis Besse Technical Specifications.

The licensee's Technical Specifications has equivalent trending j

criteria as the Code, however, the licensee did not provide adequate information on the corrective actions required if the valve (s) failed to meet their required leakage limits.

Relief may

- 2 be granted provided that corrective actions wuld be required if these valves fail to meet the " leakage limits and that these corrective actions are equivalent or more conservative than the Code requirements.

For further detail, see TER section 3.1.2.1.

8.

In TER Section 3.2.1.1 of this report, the licensee requested relief from measuring stroke times for auxiliary feedwater valves, AF-6451 and AF 6452.

The licensee proposed to exercise and fail safe test these valves quarterly but not record stroke times.

Interim relief may be granted for the licensee to develop a method to monitor for degradation of these valves.

For further details, see the above mentioned TER Section.

9.

In TER Section 3.2.2.1 ef this report, the licensee requested relief from the test frequency requirements of the Code, Paragraph IWV-3410 for metor driten and auxiliary feedwater pump discharge to the steam generator line check valves, AF-39, -43, -72, -73, L

-74, and -75.

The licensee proposed to full flow test these check valves at refueling outages.

Relief may be granted provided the licensee investigates a method to partial-stroke exercise these valves at cold shutriown and document their findings.

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=r4yy=--r--myw-mie_-_i-w--tugv--'ru--w-er-=*r-rmg w -?PN-dss-ur-

1 10.

In TER Section 3.4.1.2 of this report, the licensee requested relief from verifying reverse flow closure on a quarterly basis i

- for component cooling water check valves, CC-17, -18, and -19.

The licensee has not given adequate technical information nor justification for this relief. The licensee did not supply the train separation criteria which could place the system in an unanalyzed condition if the testing tool place, furthermore, the I

licensee's statement that reverse flow closure is only necessary for the check valve on the non operating pump is non-conservative.

Relief should be denied.

For further details, see the above mentioned TER Section.

11.

In TER Section 3.7.1.2 of this report, the licensee requested relief from the test frequency requirements of the Code, Paragraph IW-3522 for. the core flood tank discharge check valves, CF-28 and CF-29. - The licensee proposed to to verify forward flow capability at refueling outages when the reactor vessel head is removed.

Relief may be granted provided the licensee investigates a method to partial-stroke exercise these valves when shutting down to cold shutdown and document their findings.

12.

In TER Section 3.8.1.1 of this report, the licensee requested

- relief from exercising and timing decay heat valves DH-9A and DH-9B. The licensee proposed to perform testing at refueling outages. The licensee did not provide adequate technical justification for not performing the Code required testing during cold shutdowns.

Relief s'..ould he denied.

For further details, see the above mentioned TER Section.

l 13.

In TER Section 3.12.1.1 of this report, the licensee requested relief from the method of performing reverse flow closure verification for main steam check valves, MS 726 and -727. The-licensee proposed to sample inspection and disassembly according to Generic letter 89-04, Attachment 1, Item 2.

Relief may be granted with the provision that the licensee performs a partial-stroke test upon completion of the inspection and prior to placing 0-6 m

-e,

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,-,ww--

,rn.w,,

v ww,--,---

,--,,v-v.

,-me a-n,

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e the valve back in service where possible, for further details, see the above mentioned TER Section.

14, in TER Section 3.13.2.3 of this report, the. licensee requested relief from tha exercising frequency requirements on Section XI, j

Paragraph IWV-3521, for makeup pump minimum flow line check valves, MU-204 and MV 207.

The licensee proposed to exercise these valves during refueling outages.

The licensee has not providd adequate technical justification showing impracticality or hardship witho t a compensating increase in the level of safety when performing the Code required testing during cold shutdown.

Relief should be denied.

For further details, see the above mentioned TER Section.

-15.

In TER Section 3.15.2.1 of this report, the licensee requested relief from the exercising frequency and stroke time measurement for PORV RC-2A.

The licensee proposed to perform test DB SP-03366 during refueling outages and did not propose an altcenative for stroke timing this valve.

Relief may be granted provided the licensee develops acceptance criteria sufficiently restrictive to permit monitoring for-valve degradation.

For further details, see the above mentioned TER Section.

16.

In TER Section 3.15.2.2 of this report, the licensee requested relief _ from exercising, timing, and fail testing quarterly post accident RCS loop vent valves, RC 4608A, -4608B, -4610A, and

-4610B.

The licensee proposed to exercise, time, and fail these valves during refueling outages or once every 18 months as required by Techrical Specifications.

The licensee did not s

' justify why it is impractical or burdensome to test these valves when in cold shutdown at a reduced RCS pressure.

Relief should be denied.

For further details, see the above mentioned TER Section.

17.

In TER Section 3.16.1.1 of this report, the licensee requested relief from quarterly verification of reverse flow closure of service water check valves, SW-17, -18, and -19.

The licensee has not made it clear as to the frequency with which these check l

B7

t valves will be tested.

Relief cannot be granted to an indeterminate time interval.

Relief should be denied, for-further details, see the above mentioned TER Section.

i B-8 l

1

f ~

O Page No.

1 DAVIS BESSE NUCLEAR POWER STATION UNIT 1

SUMMARY

OF RELIEF REQUESTS RELIEF SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC i

l RP-1 2.1.1.1

-IWP-3100 All pumps except Monitor pump Relief Granted Bearing service water vibration, flow (a)(3)(i) temperature and and differential measurement diesel fuel oil pressure.

transfer pumps.

RP-2 2.2.1.1 Table Service water Use expanded ranges Relief Granted IWP-3100 2 pumps on the high end With Provisions Ranges for P3-1,-2,&-3 for. Acceptable, (g)(6)(1) acceptable Alert, and Required pump Action High Ranges, operation RP-3 2.2.2.1 IWP 4500 Service water Measure pump Relief Granted Measurement pumps vibration With Provisions of bearing P3 1,-2,&-3 on top of (g)(6)(i) vibration motor housing.

RP-4 2.2.3.1 IWP-3100 Service water Test-in the Relief Granted Testing pumps pumps as found condition.

With Provisions at reference P3-1,-2,&-3 (g)(6)(1) conditions

_RP-5 2.3.1.1 IWP-3100 &

Diesel fuel oil Functional test Interim Relief

-3500 transfer pumps quarterly and Granted Measurement P195 1 and -2 flow rate during (g)(6)(i) of flow refueling outages, differential pressure and duration of test

.RP-6 2.3.2.1 IWP-3100 Diesel fuel oil None.

Relief Denied Measurement transfer pumps of pump P195-1 and -2 vibration General 3.1.1.1 IWV-3417 Various valves Change plant modes Relief Granted Valve Required tested at provided technical With Provisions Relief corrective cold shutdown.

specifications are (a)(3)(ii)

VG-1 actions met.

L m

=

i Page No.

2 DAVIS-BESSE NUCLEAR POWER STATION UNIT 1

SUMMARY

OF RELIEF REQUESTS RELIEF SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC VG 2 3.1.2.1 IWV 3427(b)

Category A & A/C Perform testing Relief Granted Valve leak pressure according to With Provisions rate tests isolation technical (a)(3)(i) valves (PlV's).

specifications.

Separate test for Event V valves.

VG 3 3.1.3.1 IWV Il00 Various valves All valves included Relief Granted Valves required to for safe shutdown (a)(3)(1) required in reach cold to hot standby.

thutting down shutdown.

the reactor to cold shutdown Aux 3.2.2.1 IWV-3522 Auxiliary Full stroke exercise Relief Granted Feedwater Exercising feedwater check at refueling With Provisions RV-1 frequency valves AF-39 outages.

(g)(6)(1)

-43,-72,-73

-74,and 75

' 2.1.1 IWV-3413 Auxiliary Exercise and Interim Relief RV-2 J.

Measure feedwater fail-safe test Granted stroke times flow control valves quarterly.

(g)(6)(1) of power valves operated AF-6451 and valves

-6452 Aux Steam 3.3.1.1 IWV-3522 Auxiliary steam Verify reverse flow Relief Granted RY-1 Exercising to auxiliary closure after each (a)(3)(i) frequency turbine test operation not to line check valve exceed once every AS-274 92 days.

Component 3.4.1.1 IWV-3522 Component Verify reverse flow Relief Granted Cooling Exercising cooling water closure at refueling (g)(6)(1)

RV-1 frequency check valves outages.

CC-183,-283,-383 and -483 RV-2 3.4.1.2 IWV-3522 Component Verify reverse flow Relief Denied Exercising cooling water closure on operating frequency valves CC-17 and stand-by

-18 and -19 operational pump.

l Page No.

3 DAVIS-BESSE NUCLEAR POWER STATION UNIT 1

SUMMARY

OF REllEF REQUESTS RELIEF SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Hydrogen 3.5.1.1 IWV-3522 Containment Reverse flow closure Relief Granted Control Exercising hydrogen control at refueling outages (g)(6)(1)

RV-1 frequency check valves Appendix J CV-124.-125 Type C testing.

-209 and -210

)

4 '

Vacuum 3.6.1.1 IWV-3522 Containment Reverse flow closure Relief Granted Relief

. Exercising vacuum relief at refueling outages (g)(6)(1)

RV-1 frequency isolation check Appendix J valves CV-5080 Type C testing.

through -5089.

1 I

Core 3.7.1.1 IWV-3522 Core flood check Reverse flow closure Relief Granted Flood Exercising valves CF-15 &

at refueling outages (g)(6)(i)

RV i frequency

-16 Appendix J l

Type C testing.

F RV-2 3.7.1.2 IWV-3522 Core flood full stroke exercise Relief Granted i

Exercising discharge check at refueling outages With Provisions i

frequency valves when the vessel (3)(6)(1)

CF-28 & 29 head is removed.

5 Decay 3.8.1.1 IWV-3412 Decay heat Exercise, time and itelief Denied Heat Test valves fail-safe test l-RV-1 frequency DH-9A and 98 at refueling outages.

Emergency 3.9.1.1 IWV-3413 Emergency diesel Exercise and time Relief Granted Diesel-Measure generator valves with (g)(6)(i)

RV-1 stroke times air start valves emergency i

of power DA-ll47A &

diesel generator operated

-1147B start times.

valves DA-ll48A &

-11488 l

HPI 3.10.1.1 IWV-3521 High pressure Full-stroke exercise Relief Granted RV-1

- Exercising-injection valves at refueling (g)(6)(i) frequency HP-48.-49.-50 outages.

r

-51,-56,-57,-58 and HP-59 RV-2 3.10.1.2 IWV-3521 High pressure Partial stroke Relief Granted Exercising injection valves quarterly (g)(6)(i) frequency HP 10, II,-22 full-stroke at and HP-23 refueling outages.

m.

m y..,

.,-s.3g

.-.c s- * -,

Y Page No.

4 DAVIS BESSE NUCLEAR POWER STATION UiIT 1

SUMMARY

OF RELIEF REQUESTS REllEF SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Instrument 3.11.1.1 IWV-3521 Instrument air Reverse flow closure Relief Granted Air Exercising containment at refueling outages (g)(6)(i)

RV-1 frequency isolation check Appendix J valve Type C testing.

IA 501 Main 3.12.1.1 IWV-3522 Main steam check Verify reverse flow Relief Granted Steam Exercising valves MS 726 closure by using With Provisions GL-1 frequency and MS-727 sample dissassembly (g)(6)(i) and inspection at refueling outages.

Make up 3.13.1.1 IWV-3521 Hake up valves Reverse flow closure Relief Granted RV 1 Exercising MU-242,-243,-244 at refueling outages (g)(6)(i) frequency and MU-245 Appendix J Type C testing.

RV-2 3.13.2.1 IWV 3521 Make up valve Partial-stroke Relief Granted Exercising MU-169 quarterly (g)(6)(i) frequency full-stroke exercise dt refueling outages.

RV 3 3.13.2.2 IWV-3521 Make up valve Full stoke cxercise Relief Granted Exercising MU-800 at refueling (g)(6)(1) frequency outages.

RV-4 3.13.2.3 IWV-3521 Make up valves Full-stroke exercise Relief Denied Exercising HU-204 and 207 at refueling frequency outages.

RV-5 3.13.2.4 IWV-3521 Make up valves Partial-stroke Relief Granted

)

Exercising MU-196 and -197 quarterly (g)(6)(1) frequency tull stroke exercise

/.

at refueling outages.

Nitrogen 3.14.1.1 IWV-3521 Nitrogen valve Reverse flow closure Relief Granted RV-1 Exercising NN-58 at refueling outages (g)(6)(i) frequency Appendix J Type C testing, i

7 c

Voge No.

S DAVIS BESSE NUCLEAR POWER STATION UNIT 1

SUMMARY

OF RELIEF REQUESTS RELIEF SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTIM REQUIREMENT IDENTIFICATION ME1H0D OF BY NUMBER

& SUBJECT TESTING USNRC Reactor 3.15.2.1 IWV-3412 &

Reactor Coolant Full-stroke exercise Relief Granted Coolant

-3413(b) valve RC-2A at refueling With Provisions RV 1 Exercising outages.

(g)(6)(1) frequency and stroke time measurement RV-3 3.15.2.2 IWV-3412 &

Reactor coolant Exercise, time and Relief Denied 3415 valves fail-safe test Test RC-460BA,-460BB at refueling outages frequency

-4610A and or once every 18

-46108 months.

RV-2 3.15.1.1 IWV-3522 Reactor coolant Reverse flow closure Relief Granted Exercising valve RC-ll3 at refueling outages (g)(6)(i) frequency Appendix J Type C testing.

Service 3.16.1.1 IWV 3522 Service water Verify reverse flow Relief Denied Water Exercising valves SW-17 closure when RV-1 frequency

-18,& -19 possible.

Service 3.17.1.1 IWV-3522 Service Air Reverse flow closure Relief Grantid Air Exercising valve SA-502 at refueling outages (g)(6)(1)

RV 1 frequency Appendix J Type C testing.

l l

l-

,

v t e Letter Sequence Other
TAC:M76025, (Open)
Initiation Acceptance... Administration Questions Answers Results Approval... Other: ML20086F707
MONTHYEAR1991-10-31 [Table View]

ML20086F707

Text

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

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