ML20091N326

Forwards Temporary Change Notice to S023-V-35,Rev 9, IST of Valves Program

ML20091N326
Person / Time
Site:	San Onofre
Issue date:	08/28/1995
From:	Marsh W SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091N329	List: ML20091N326 ML20091N340
References
NUDOCS 9508310124
Download: ML20091N326 (24)

Text

. . . ._ _ ._ _. _ _ _ _ _ . _ ,

r,

+ , , ,. ,

I N,, l 1, l c pw . . .

u ?i ! <

[y.

p >

T ,

. Southem Califomla Edison Company  ;

t' ,: " .

o. m. .  !

I SAN CLEMENTE, CALIFORNIA 92674-0128 -

hplfy August 28, 1995 m_

[ ' wacran c. u4nes 1 ,,

.J -

m;r a ,, .

. m 2  %

3 ,

l

,1

> U.tS.:NuclearLRegulatory Commission

> " Attention:~ Document Control Desk-x; Washington, D.C.- 20555-(Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 ASME Code Update for the Second Ten Year Interval, Inservice  !

' Testing Program. l San Onofre Nuclear Generating Station ~

E t ,

ynits 2 and 3 - -

~

Referenge: ;LetterfromTheodoreR. Quay'(Nr to"Mr. Harold B. Ray (SCE)

• 'O dated August;31,.'1994;

Subject:

and 10-Year-Interval for-c M Inservice Testing of Pumps and T. ses - San Onofre Nuclear 4 ' Generating Station, Unit.No.;2.'(TAC No. M87283) and Unit No. 3 y 'f(IACNoJM87284).

\ ,

tThis letter'pYovides' Southern California Edison's (Edison's) response to the

,  ; referenced August 31, 1994, NRC Safety Evaluation. Enclosure 1 is a table

, that shows how Edison addressed each of the items contained in Table 3.1 of Lthe'INEL Tedd.ical Evaluation Report attached to the NRC's Safety Evaluation.

. Enclosure'2 is Revision 9-2 of 5023-V-3.5, " Inservice Testing of Valves" which

-was issued on August 25, 1995.

0ur' review' of. the NRC Safety Evaluation and NUREG 1482 resulted in :ianges to our program. These changes consisted of (1) revisions to justifications for

'non-quarterly test intervals to enhance the clarity of the basis for the extended intervals, and, (2)-modification of some test intervals to reflect o ,

Ithe latest guidance'in NUREG 1482.

. ; , JSan Onofre U' nit 2 completed a refueling outage on May 23, 1995, and Unit 3 is l currently in a refueling outage.which is' scheduled to end on October 5,1995.

. Some'valveitest intervals were changed in Revision 9 of the program from cold

-shutdown'or: reactor refueling to quarterly. . Accordingly, affected Unit 2 and

Unit' 3. valves-will be phased.into the quarterly test' schedule and tested r ' Lwithin 92 days foilowing the completion of the Unit 3 refueling.

t , ,

f l'

. gau .

f, .

it .

a" . 9508310124'950928 f 4\\

PDR ADOCK 05000361 P: __ _, POR u _ - @/ l

[

M

. Document.Contro1LDesk i -- Please let melknow'if youIha've any questions.~

.g Very.truly yours,

_(

/hh i

- ;Endlosures-cc: . L.'.J. Callan, Regional Administrator, NRC Region IV .

.J. E. Dyer. Director,' Division of Reactor Projects, Region IV K.' E. Perkins, Jr., Director,. Walnut: Creek Field Office, NRC Region IV

.J. A..Sloan,~NRC Senior Resident Inspector, San.Onofre Units 2 & 3

-M. B. Fields NRC Project Manager, San Onofre Units 2 and 3 I

i t

Y ,

f

g ?s

s s.a.,- a ,wr - a - a _

,a4 u 4 >.a , .-

---44, s. , ,a ._ x . _e.- 4 +

A t

a

g ENCLOSURE 1 RESPONSE COMPARISON FOR INEL; TECHNICAL EVALUATION REPORT TABLE 3.1 e

9

~

I Responses to Table 3.1 Resolution of INEL Technicd Evaluation Report (TER) Issues Page 1 Responses to Table 3.1 1 l Deferred Test Evaluations l

l

INEL Technical Evaluation Report (TER)

Original Submittal Justification and Proposed TER Evaluation of the Resoluthm of the Alternate Testing Justification TER Concern and Basis i

ATJ 1.0, Part 3, S2(3)1306MU4SS,469 and 538, AFW Punip Section ATJ 1.3 does not adequately demoi. strate Resolution: The test interval has been charsed to quarterty.

Isoletten Velves the impracticality of exercisirt these valves quarterty. Beelo: A review of the basis for the nonquarterty interval was Juetincetion: Closing the suction isolation valve will cause the associated AFW completed in Ight of the guidarce in NUREG 1482, issued in pump to be inoperable. This is contrary to the requirements of Tech Spec Appendia A, IST Psegroas .ah, April 1995. As a result, the original basis was found to be 3.7.1.2.1. Strokirt the AFW pump suction isolation valve closed every three para 2, discusses the inadequacy of inconsistent with this new guidance and the test Interval was trenths will result in the affected pump being declared inoperable each time settirq a cold shutdown Interval solely on a4:sted accordirgfy.

the valve is stroked closed. This exacerbates the unavailability of the AFW the basis of Ted rucal Specifications pumps durirg plant operation. entry.

Attemete Testing- Test the vahe at cold shuta - intervals.

ATJ 3.0, Part 1,2(3)HV9200, Clierging Pumps to Recomerative Heat it is inv as.kai to exercise this valve Roselutlen: (no cha ge in interval) Continue to test at Cold Encineager E063 quarterly during power operations. Shutdown intervals. In the IST Program, enhance our Therefore, the siternative is in -

di-si. discussion of the basis for this intervat Justincetion. Exercising while the plant is at power would isolate normal with Part 10. Para 4.2.1.

charging to the RCS. This wouPasult in a nonwndiai= with Technical -

Beele: (SO2343.5. Attachment 3. Para 3.1) In addition to Specification 3.1.2.2, which required two flow paths for boration during power Appendix A,IST Pmgress Ah, Technical Specification action statement entry, exerdsing this operatiort Para 2 discusses the inadequacy of air operated valve during plant power operation wodd require setting a cold shutdown interval solely on securing letdown and charging entirely. This is a laruthy plant Attemete Testing ~ est the valve ' cold shutdown This shifts the testing to the basis of Technical W evolution as is the restoration of letdown following the exerdse a period during w'Ach it is allowed by to Technical Specifications and avoids entry. test. Further, stopping chargirt and letdown flow imposes a RCS pressure arij boration control probleh.' or wndk.i. Ens. large thermal transient on the components in the charging / letdown path that would eventually damage these wuvv.-as such as the letdown heat excharyer and the regenerative heat exchanger.

I ltams in the INEL TER Table 3.1 that were listed without comment by the NRC are tmt listed in this table.

Responses to Table 3.1 Resolution of INEL Technical Evalualion Report (TER) Issues Page2-i

@ SUINnitial Justifloatlon afMi W TER Evalasation of the Resolution of the Alternate Testing - Justifloation TER Concern'anel Basis ATJ 3.0, Part 3,2(3)LV02275, VCT Oettet, and, S2(311200MUO18 VCT to it is imprar*al to enordse tiese valves . e- a=*=' (SO23V,3.5, Attachment 3 Para 3.3.1) The -

Chespug Panap Sostion Check Velve dosed quarterly. Therefore, the _

referenced 0410 paragraphs were rewtowed for correctness attemauve is in aa:ordann with Part 10

~

throtshout the ATJ section and corrected.

JestMostles. Esercisers these vehes closed requires shifting charging pump paras. 4.2.1 and 4.3.2.

suction and triecting highly concentrated boric add into the Reactor Coolant System, causitt plant chutdown Apponen A,IST Psepose AmesmeAss, Para 6 idenuSes the error in the ATJs such Aftomate Testing- Test these valwes at cold shutdown as this one that idennfy the wrong 0410 paragraph for Category C vehes.

ATJ 3.0, Port 7. S2(3312neamenea . Chessing Pensp Dischesgo t(, it is impractical to esordse this valve Itoseletten: (no charge in interval) Contmus to test at Cold flagoossative Heat Eschenger quarterty. Therefore, the altamative is in Shutdown intervals. In the IST Program, enhance our amordance with Part 10 Para 4.2.1. dsaassion of the basis for this interval.

Justmoetion: This vehe cannot be stroked dosed during normal operation as it would isolate CVCS and chargirt pumps to the RCS. This would result in a

~

Appeeds A. IST Peugpass Amessalles. Besto: (SO23V 3.5 Attachment 3. Para 3.7) In adduon to nortcompeiance with Technical t---r--=L- 3.1.2.2, which requires two flow Para 2 d-==s the ir==re=qu=ry of Technical Specification action statement entry, esordeirt this paths for boration during power veration. settire a cold shutdown intsevel soiety on manual vehe durtre plant power operation would require the basis of Technical Specification entry. secunre letdown and dierging entirely. This is a lerethy plant Aatemete Testing- Test the valve at cold shutdown. This shifts the testing to Para 3 states ATJ 3.0, Part 7,is an evolution as is the restoration of letdown followmg the esordse I

a period during which it is allowea by the Technical Specifications and avoids example of where the justification does test. Further, stopport chargeng and letdown flow imposes a -

RCS pressure and boration control problems or complications. not idenbfy any negative cor=aT=nce that large thermal transient on the components in the may make more frequent testirq charging / letdown path that would eventuaNy damage these l Impracticable components such as the letdown heat eachanger and the l ,egenersove heat enchanger.

l ATJ 4.0, Part is 2(3)HV4211,6218,8223 and 6238, CCW Non Celtical Loop It is impractical to full-stroke exerdse flooetation: (SO23V3.5, Attachment 3. Para 5.1) Clarised Cees=a====t leetettee Velves these valves quarterty. Therefore, the d-=3on to include HV6223 and HV6236.

altemative is in accordance with Part 10 I Justillection: Exercising HV6211. HV6216. HV6223, and HV6236 during Para 4.2.1.

operation would secure coohrt water flow from RCP seals, or drect cooling l water flow from RCP seals. This could result in seal damaga and p; ant Appemen A,IST Peugreme AmouseDas, l shutdown. Pare 6 Identifies HV6223 and HV6236 I

were inadvertently omitted from the Altamete Testing: Stroke these vahes at cold shutdown intervals to avoid di-= ion.

damage to plant equipment which can result from interruption of CCW flow.

ATJ 4.0, Post S, S2(3)1203MU2SS and 299, Sesvloe Water Sepply te CCW lt is impractical to fullstroke exercise e- a.ma - (no charge in interval) Contmue to test at Cold these valves quarterly Therefore, the Shutdown intervals. In the IST Program, enhance our Justinoation: To acheews a close stroke of these check valves, the upstrearn altamative is in accordance with Part 10 dscussion of the basis for this interval.

volume of the associated piping must be isolated and depressurimd. This Para 4.3.2.

l renders the assodated CCW surge tank and therefore the assodated CCW loop Bosto: (SO23V,3.5, Attachment 3. Para 5.5) To be peeponsive l inoperable. The reeult is entry into multiple Technical 9-*=*"9 LCO Action app an= A,IST Peupam AmeoneNos. to the INEL TER, the basis for the Cold Shutdown IST interval i Statements if done during plant operation. Para 2 dscusses the inadequacy of was clartfied to indicate that testing is consistent with the j setting a cold shutdown interval sole!y on NUREG 1482, Para 4.1.4 dscussion.

! Alteneeto Testing- Stroke at cold shutdown intervals when plant w4t; ens the basis of Tectmical W=hn entry.

i allow CCW loops to be Inoperable without rendenng several Technical Specification required aw. u.is inoperable.

l

m _ ._ _ __ _ . _ .. __ . . _ _ __ __

Responses to Table 3M Resoluton of INEL Technic 1 Evaluation Report (TER) Issues Page 3 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Altemate TestN Justifloation TER Conoom and Basis AU 5.0, Part 3,52(3)1305MUO36 and 129, Male Few to S/G eemeh valves it is impractical to futtstroke exerdse *=== W8== Continue to test at Refuelirq intervals by partial these vanes closed quarterty or during di====ambly and manual strolong. In the IST Program, enhance Jastincatian: Of410 Section 43.2.2, Exercising Requirements Paragraph (e) cold shutdowns. The attemate method for our dscussion of the basis for this intervat and test technique.

stipidates if exerdsing is not practicable dunng plant operations or cold desure vertfication is approved by GL shutdowns, it may be limited to full stroke during refueling outages. 8904 provided that tf e testirt comphes sosia: (SO23N,3.5, Attachment 3. Para 6.3)To be responshe with all of the provisions of GL 8904, to the INEL TER, the basis for the Refueling interval was Secbon 43.2.4(c), Valve Obturator Movement, further states, "As an Position 2. darified to indicate that norwntrusive test technsques to wrtfy attemative to the testing in (a) or (b) above, dsassembly every refueling outage closure have been considered, and determmed to be to verify operability of check vahes may be used " Appendix A,IST Psagraan ah, Wtical The vehes are located in containment, and para. 4: The Licensee has not adequatsly performance of magnetic and/or acoustics would nxpJire GL 8904, Position 2, allows for C. .'., mea of staggered schedules for demonstrated the impracticality of worlung in containment at power, which would increase testing of like -,pm i by estabilshirt an inspectkm plan for groups of verifying the required obturator rmvement radiation exposure (Atrasonics have been attempted in the valves. by testing Some test method may be post, but were urm reassftd because ultrasonics depend upon feasible to vertfy the ter'uired exerdse of we+er as a modum, and the water drains from these valves ARamste Teating At cold shutdown intervals, perform a full stroke test (open) these vehes. The Ucensee should upon shutdown. Radiography may be feasible, but would of each valve using system flow, consider methods such as usirt require securing access to the refuehng dock during the outage, non4ntrusive techniques (e,g., acoustics, thus impacting the critical path of the outage. Also, vatve At each refueling outage, test the valves by partial disassembly, inspecton and ultrasonics, magnetics, radiography, and degradation has been observed in these vanes, and as a result manual stroking on a rotating basis (one vahe per refuelirt). If it is found that "de-..w.phy) to verify a full-stroke all valves are esassembled each outage to inspect for the full stroke capability of the daassembled vane is in question, the other exercise of the subject check vehes. This cxmtmued degradation. Thus, no addrtional impact (e.g., human vahe will be similar1y d==== ambled and inspected and marua!!y full stroked testing may only be practical at cold error)is introduced in performirt the hardstroke to credt the during the same outage. shutdowns or refuelmg outages. The IST.

heensee should perform their irwestigation Following reassembly the vahe is be tested by partial stroking using system and if a test method is found to be Disassembly and inspection is performed in accordance with, flow. practicable, the IST requirements of the and does not deviate from. 09410 Para 4.3.2.4, and GL 8904, applicable vehes should be satisfied by Position 2.

testing instead of disassembly and inspection. The licensee should respond to this concem.

Responses to Table 3.1 Resolubon of INEL Technical Evaluation Report (TER) Issues Page 4 Original Submittal Justifloation and Proposed TER Evaluation of the . Resolution of the Alternate Testing Justification TER Concern and Basis ATJ 7.0, Part 1 ATJ does not adequately demonstrate the R- =M= . (no charge in interval) Contmue to test at Cold l 2(3)HVS150, leeletion Velve - Shetdown Caelleg System Heat Eschenger impracticality of exercisirt these valves Shutdown intervals. In the IST Program, enhance our E004 to LP58 Heeder, med, open quarterly durirg power operseon. disetasion of the basis for this interval 2(3)HVS151, leeletlen Valve Shetdows Caellag System Heat Exchanger E003 to LPSI Needer AppeedEx A,IST Prespun Ah, sesis:(S023V3.5. Attachment 3. Para 8.1) For ECX:S system Para 5: This ATJ indicates that openmg operabihty, the Technical Specifications (Surveillance 4.5.2.a)

Jestilleettom: Applyirg power or openitt these valves while the plant is at the subject vanes could defeat both trains require verification at least once per twehe hours that HV8150 power would result in nork,vmpuew with the Technical Rnac+=Hans. of LPSI. It is highly undesirable to defeat and HV8151 are closed ar. > , awer to the vahe operators is Opening these valves could defeat both trains of LPSI. both trains of LPSI, however, it is not clear removed why the varves could not be tested one et AMoreste Testing- Tast the valve at cold shutdown a time, which should disable only one train Testing these vanes at a cold shutdown interval is consistent of LPSI at a tkne. with NUREGr1482. Para. 3.1.1. Removirt these vehes from power lockout. restonrg power and openitt them in Modes 1. 2 or 3 involves a hardship;i.e., repositionert of a breaker from "off" to *on*, and clositt the manual isolation vehes for HVS150 and HV8151. Manual action would be required to restore the ECCS If an accident occured while the test was in progress.

This risk outweighs the benefits achieved with a quarterly test in light of the facts that (1) these vanes are in the kSe shutdown cooung loops that are not used except when the plant is placed in cold shutdown, (2) being in power lockout, these vanes have a minimal probability of failure. They are kne (potential sources of failure are very 16mited); and.

(3) the realignment of the system for the exercise tests in question Irwaiidates the assumptions in the Safety Analysis (see the Technical W6aHan Bases, Section B 3/4.5.2).

Responses to Table 3.1 Resolution of INEL Technical Evaluation Report (TER) Issues PageS Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justification TER Concern and Basis ATJ 7.0, Part 2. 52(3)120821U004 and 006, Containment isolation Stop it is impractical to full-stroke exerdse Resolution Continue to test at Reactor Refuenig by l

Check Vafves for Spray Heedees lashle Costalement these valves closed quarterty or during Disassembly and hand stmking. In the IST Program, enhance cold shutdowns. The attemate method for our dscussion of the basis for t:1:s testing Just9Hcetlon. Fullstroke exerdsing these valves using the containment spray dosure vertfication is approved by GL punps would result in a containment spraydown and consequer't potential 8944 pmvided that the testart complies Beals:(SO23V,3.5, Attachment 3, Para. 8.2)In addition to the equipment damage as well as create additional liquid radwaste to be removed with ad of the provisions of GL 8904 dfficuttles described regarding full flow test rg, the use of from the Containment Buildrg sump. Position 2. non4ntrusive test tediniques to verify full open capatality has been considered and determined to be impractical. Acoustics PARTIAL FLOW TESTING- The riser inside the containment buildng is drained Appendix A,IST Program.ah. were attempted to determine whether the vahes went full open each refuelirg and remled pnor to retumirt the plant to service. When the riser Para. 4: The Ucensee has not adequately at a reduced flow, but no openirg impact could be detected (the is being filled with water, the water can be put in the system upstream of each demonstrated the impracticahty of system arrangement does not permit adequate 1 tow).

l stop check valve. Therefore, this flow through the Spi ny Header Contamment verifying the required obturator movernent

, isolation Stop Check Valves during the fitting of the riser would result in a by testing. Some test method may be Disassembly and inspection is performed in in.m h with.

I partLJ stroke of these valves. Other methods to achieve a partial open stmke feasible to verify the required exerdse of and does not deviate from. Of410. Para 4.3.2.4. and GL 8904, l are also available. these valves. The Ucensee should Position 2.

!. consider methods such as using l CONCLUSIOft NRC Generic Letter 8904, Attachment 1. Position 2, identifies non4ntrusive techniques (e.g., acoustics, partial disassembly ard inspection as an acceptable attemative for strokirt a ultrasonics, magnetics, radiograg:hy, and valve when it is impractical to use flow. In this case, there is no way to stroke thenr.ography) to verify a full-stroke these valves with the existing system design usirt flow. The Code required exerdse of the subject check valves. This fulletmke testing using flow could only be performed after considerable testing may only be practical at cold modification of the system design, such as hstailation of an instrumented test shutdowns or refuelsrg outages. The loop. The high costs of the necessary design changes involved would not be licensee shot.dd perform their investigation Justified by the improvement of the valve testing. Further, the additional valves, and if a test metted is found to be piping, supports and penetrations could result in reduced plant reliability. practicable, the IST requirements of the applicable valves should be satisfied by TEST SCHEDULE. Disassembly and inspection of both of these valves each testirg instead of dsassembly and refueling outage requires additional draining of the assodated system pipirg inspection. The licensee should respond over and above draining the riser as previously dscussed. This generates a to this conmrn.

significant amount of radioactive liquid waste. In addition, considerable radiation exposte can be received by personnel performing the partial dsassembly, hand stroking and inspection.. As a consequence, there is a dear advantage in reducing the number of these tests required in each refueling.

GL 8904 allows development of staggered testing of like unwc-imets by establishing an inspection plan for similar groups of watves. This is stated in position 2 of the Genenc Letter.

Altemate Teeting- At each refueling outage, (1) test the valves by partial disassembly, inspection and manual stroking on a rotating basis (one valve per refueling), and (2) perform a partial stroke test (open) of each valve using system flow.

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

R---:- r to Table 3.1 Resolution of INEL Technical Evaluation Report (TER) Issues Page 6 Original Submittal Justifloathm and Proposed TER Evaluation of the Resolution of the Alternate Testing Justifloation TER Concern and Basis ATJ 7.0, Part 4, S2(3312nessuess 14,29 and 30, Ces*=h===t Sprey panup ATJ does ret adarr=r=8y demonstrate the Reestatise. (no charge in interval) Test these vehes at Cold W CheekVatves impracticairty of exercisirig these vehes Shutdown (or Reactor Refusing intervals. as explained in open quarterly durtre power operanon. ~ BASIS", no60w). In the IST Program, enhance our dear ===an of M. FW1 stroke exercising of these check valves while the plant is at the basis for this interval.

power would require dsatWing both trains of LPSI. Appenes A, IST Psessem ^====8'=t, Para 5: This ATJ inecates that futstroke snels: (SO23V-3.5. Attachment 3. Para 8.4) The OPEN Altamete Testing Test these valves at cold shutdown intervals. exercsseng the =Har* check vehes wodd EXERCISE test for these vehes requwes a flow rate of . .i disable both trains of LPSI. It is highly 230G2750 spm. The flow path for this test irwohes undesirable to defeat both trains of LPSI. establishirt flow through S2(3)1204MU162 to the 3WST. The however. !t is rW. clear why the vahes lineup uses a portion of the mrnmon LPSI header for the flow could not be tested one at a time, whie path. Ahenwg the Corfainment Spray (CSS) and LPSI systems should dsable only one train of LPSI at a in this manner renders one train of contaenment spray and both time. trains of LPSI inoperable. With the LPSI and CSS aligned to support this testirt. LPSI flow from both trains is diverted to the RWST. This constitutes a loss of LPSI system functon and places the plant in a condtton which is outside the limnelet basis. Because of this loss of system function. MUO12. 014, 029 and 030 are encluded from quarterly tesang consistent with the guidance in NUREG1482, Para. 3.1.1(1).

The EXERCISE CLOSED test is also done at cold shutdown intervals. There is a dfference between the CLOSE tests for Unit 2 and for Unit 3. Unit 2 has a vent between vahe pair 9 that -

allow the CLOSE tests to be performed by measunna leakage using a test rig. Perfomurg these tests at refuehrt intervals while measuring leakage is consistent with NUREG1482, Seenon 4.1.4.

This vent does not exist in Unit 3 and the valves are vertiled CLOSE using radlagtaphy. The radiography is performed at refuelirt intervals on a rotating basis consistent with NUREG1482. Section 4.1.2.

As an addleonal argument to CLOSE test the vehes at refusiku intervals. 00410. paragraph 1.3 defines exercisirt as "the demonstration h reon direct visual or ind;ect positne inscabons that the moviet parts of a vshe functiott" Since it is not possible to OPEN EXERCISE test these vahes at a quarterly interval. vertfymg the valves CLOSED at a quarterly intervat woukt not satisfy the code requirement to exercise the vehes. Therefore, the interval for the CLOSED EXERCISE test is set at the same interval as the OPEN EXERCISE test.

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

-I R-.+n : to Table 3.1 Resc!ution of INEL Technied Evaluation Report (TER) lesues Page 7 Original Submittal Justilisation and N r M TER Evaluation of the .Rosolution'of the Alternate Testing Justifloation - TER Concern and Boots i

The desel generator shid mounted am has==- Deen ==3an moved out of SO23VG.5. ,

ATJ 8.0, Diesel Sidd Blomsted Valves components are tested during the diesel Attachment 3. '

generator loaded run sunseinance tests.

W Each component is demonstrated operable by virtue of the fact The loaded run tests are performed at Basis: As saggested by the NRC. mowirt this dea ==aan to f that the ergine(s) start in the requisite time, carry the required load, and least once each quarter, whidiis in . SO23N.3.5. Attachment 2 Note 17 clartfles the program exhibit operating parameters (temperatures, pressures, etc.) that fall within the accordance wtth Part 10, paras. 4.2.1 overall.

vendor's recommended values. Monthly surveinance runs of the diesel and 4.3.2. . .

+

generators load the engine to approximately 4840 kw. The anudpated Mode i These valves are nortcode sidd mounted valves sae=*=d in the throtch 4 acddent loading is 4700 kw (Mode 5 and 6 loadng is approximately Appmedia A. IST Psepam Aneumates, lube oil, fuel oil, startsrig air, or other desel generator systems.

80% of this value). Engine parameters are recorded and transmitted to Para 7: ATJ 8.0 deals with an altamate Proper operation is vertiled durirt regularly act = Mad *Ea= dad  ;

Technical Drwision for rewtow and trendng. The OM16 code committee has run surveiNance. This is in agreement with NUREG 1482.' '

test method while all other ATJs in the IST taken the possbon that Section XI testing does not enhance the reliability of the program provide bases for other than the Seebon 3.4. =

desels. . quarterly test interval. There may be a '!

more appropriate place la the IST program These vatwos are noncode vahes that have a safety function Altosaate Testing- Verify proper operation of the diesel generators during for the information provicied in ATJ 8.0. and therefore require periode surveimance. They are listed in .,.

regularly scheduled

• loaded run* survoiNance. Record engine run data per the IST Program for convenience, however, a missed or failed  ;

OF16 and vendor recommendations. surveiuance will not constitute a violaeon of Tedinical Specificebon 4.0.5. See Letter. J. G. Portlow. NRC, to AM -

Licensees, etc. Adinutes of the PutWk meebrgs on Generic letter 8904, October 25,1989. Response to Question #53, and NUREG 1482. Section 2.2. .

The third paragraph fobowmg the ammahee== The dea ==Aan has been removed from the

• Altemate Testing

• indudes the following Program.-

l statement

• a single failure of any active component cannot affect the ability Beeis: The conditions under whidt the Diesel Generator system

• to store and deliver fuel." in addition, the valves are tested are ansistent with the d6=a= alan in the i fourth paragraph fonowirt the "Altemate NUREG Paragraph 3.4. Testirig of the desels vertiles the i Testing" indudes the statement *A single opersbonal readiness of the ===ar4=*=d siddmounted valves. '

failure in the startmg air system, will not in addtion, these volves are non AShE Sechon 111 components. ,

prevent a diesel start." These statements Accordingly, our test methodology does not require advance -

indcate that there is total re&mdancy in NRC approval. -

the desel fuel oil and startmg air systems .{

such that one train could fait and the diesel would still be capaham of perfom'ing 'I its function. However,the Afth paragraph followirig the *Altemate Testirgt* states- ,

• Each of the mmponents idemfied in the l i

attached tabtes is demonstreWf Meerable by virtue of the fact that the ordine(s)

.i start in the requisite time, cantes the requwed load, and exhituts operatirq parameters (temperatures, pressures,  ;

etc.) that fall within the vendors  ;

recommended values.

• This peregraph >

does not appear to take into account the i total subsystem redundancy refened to in the previous quotations. '

i

_-._% ,.- _,_ _ m _

._ __ . ._ 4 . _ _ . _ .. .m . .. . _ , . . .

h Responses to Table 3.1 Resolution of INEL Technical Evaluation Report (TER) Issues Page 8 '

Original Submittal Justifloation and Proposed TER Evaluation of the Resolution of the

, Alternate Testing Justifloation - TER Concern and Basis ATJ 9.0,2(3)lfv5eSS, SA2301MU081 and SA2301MUO95, Fire Water it is impractical to exercise this vehe Ilesetution: Contamment isolation MOV 2(3)HV5686 w'll be Systems s '-lealetten quarterty Therefore, the afternathe is in exercised quarterly accordance with Part 10, paragraph 4.2.1.

JustMcetsen: Exercising these vahes during plant power operation will activate The open and close exercise tests for SA2301MUO61 and the fire protection system in the respective containment buildirt. Appendix A,IST Puespesa ah, SA2310MUO95 have been removed from the IST program Para 3: This section does not provide requirements. Accordirsty, no attemate testirq interval Attemete Testsag- . Test at cold shutdown intervals. adequate)Nvt for not testirt at justification is necessary power operation and/or durirq cold shutdowns. The reviewer must make smole: Regarding 2(3)HV5686, a review of the basis for the assumptions to demair postulate the nor>quarterty interval was completed in light of the guidance in negative consequences of performing NUREG 1482, issued in April 1995. As a result, the original testing during power operations. basis was found to be inconsistent with this new guidance and the test interval was a4usted accordmgly Upon further review of the ibnction of SA2301MUO61 and SA2310MUO95, the IST basis document has been revised to require only a dose verificanon. This vertf6 cation is conducted concummt with the seat leakage test and is in acmrdance with NUR! 11482, Section 4.1.4.

ATJ 11.0, Part 2. Cl ock velves for the CCW essgo tank backup nitrogen it is impractical to exercise these vanes Itesolution; (SO23-VG.5, Attachment 3. Para 10.2) Delete the cyNadore, $2(3)2412MU356, S2(3)2412MU358, S2(3)241 AMU 300, quarterly during power operations. reference to ADVs and charge the Altemate Testing to read.

S2(3)241aMUSS2, S2(3)241 AMU 364, $2(3)241 AMU 3es, Therefore, the attemative is in accordance

• Test at cold shutdown intervals in a plant mode that permits S2(3)241SMU388. 52(3)241SMU371. 52(3)2412MU373, witn Part 10, Para 4.3.2. the associated CCW train to be inoperable

• S2(3)241 AMU 375, S2(3)241SMU377,32(3)241 AMU 379,

$2(3)241SMUSS7, S2(3)241 AMU 389, S2(3)241 AMU 406, Appendix A,IST Psognem a, S2(3)241 AMU 400,S2(3)241 AMU 410 S2(3)2412MU412 Para 6: This ATJ states that the listed S2(3)241 AMU 414 and $2(3)241 AMU 41g vanes admit bacl<up nitrogen to the CCW surge tanks. However,the Attemate Justmostles: These valves open to admit backup nitrogen to the CCW surge Testing states that the valves will be tanks from the individua! nitrogen storage bottles. They close to prevent tested at cold shutdown intervals in sysam depressurization in the event a bottle is removed for replacement. cor(unction with the testmg of the Testing these valves requires placing the assodated Component Cooling Water associated ADV. There does not appear Loop out of sen4ce. This can only be done in a mode in which the Technical to be any mnnection between the listed

$+-F- -@-s permit one CCW Loop to be inoperable. vanes and the ADVs.

Attemete Testing- Test at cold shutdown intervals.

! Responses to Table 3.1 Resolubon of INEL Technier1 Evaluation Report (TER) !ssues Page 9 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justifloation TER Concern and Basis l

l ATJ 11.0, Port 3, S2(3)241aAAU396 and 402, Nitrogen 11ee clieck vefves la It is impractical to exerdse these vahes Roselettee: Change the test interval to reactor refuehng l sepply to CCW serge tasks quarterty durirg power operations.

j. Therefore, the afternadve is in accordance Beels: (SO23rV,3.5, Attachment 3. Para 10.3) The cense

! Jeetinestlos: To acNeve a CLOSE stroke of these check vatves, the upstream with Part 10. Para 4.3.2. exercise test is performed very rnuch like a 10 CFR 50, volume of the associated pipirt must be isolated and depressurized. This Apperdx J seat leakage test. Vertfyirt closure irwolves renders the assodated CCW surge tank and therefore the associated CCW loop Appeedix A,IST Progren ah installMon of a flowmeter on a test tee and measuring leakage to be inoperable. The result is entry into multiple Techrucal Specification LCO Para 2: This section does not provide flow past the valves. Performire the CLOSE test of these vanes

. Accon Statements if done during plant operatkm. adequate justification for not tesdng at in .reancuon with the LEAKAGE test at refueling interva:s is l power operation and/or during cold corwastent with NUREG1482 Section 4.1.4.

l Attornate Testing Stroke at cold shutdown intervals. shutdowns. The reviewer must make assump:lons to L. bey postidate the negative consequences of performirt testing durirq power operabons l ATJ 13.0, Port 1 Reacter tiend med presserizer voet volves,2(3)HV0296A, it is 'w .m iid to exercise these valves Roseletten. (no change in interval) Continue to test at Cold 2(3)HV02968,2(3)HV029TA,2(3)HV029TB,2(3)HV0298, and,2(3)HV0299 quarterty. Therefore, the alternative is in Shutdown intervals. In the IST Program, enhance our accordance with Part 10. Para 4.2.1. Th di=cualon of the basis for this interval, l JeetlAcettee. These valves are part of the Reactor Coolant System Boundary licensee's basis should be clartfled.

Isolation. Operdng these valves while the Reactor Coolant System is Beele:(SO23rV,3.5. Attachment 3. Para 13.1) Power is pressurized would release Reactor Cootant to the vent system. Further, power Appeedia A, IST Progreen .ah, normally removed from these scienoid valves because they are is normally removed from the solenoids. Para 3: This section does not provide part of the RCS boundary and openirt them while the RCS is adequate justificauon for not testing at pressurized would release RCS to the vent system. Both the Attemete Teetleg* Stroke these wafves open and dosed at cold shutdown power operation. The reviewer must make very restrictive action statement in the Technical Spedficanons l

intervals. assumptions to confidently postulate the (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) and the risk of a potential accident, dictate against negative consequences of perfomiing the quarterty IST interval in Modes i through 4. ~

l testing during power operations.

. Technical MM 3.4.10, Reactor Coolant Gas Vent System, requires that the valves listed all remam dosed in Modes 1 through 4. If any of these valves are inoperable -

or open, the action statement must be completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

. The design redundancy of the RCS Gas Vent System serves to minirrize the probability of inadvertent or irreversable actuation while ensurirt that a sirgte failure of a vent valve, or control system does not prevent isolation of the vent path.8 If, in Modes 1 throtch 4, a valve were to remain open durirg an exercise IST, the potential for a Loss of Coolant Accident (LOCA) would exist.

From Technical Specification basis, Paragraph 3/4.4.10.

Responses to Table 3.1 Resolution of INEL Technied Evaluatr,n Report (TER) Issues Page 10 Original Sutwnittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justifloation TER Concern and Basis ATJ 13.0, Part 3. leeletten Velves in the une frees the R;- - _ _ Heat it is impractical to exerdse these valves Roseletten: (no change in interval) Contmue to test at Cold Eschengst to the RCS,2(3)HV9202, and 2(3)HV9203 quarterfy. Therefore, the altamative is in Shutdown intervals. In the IST Program, enhance our

--h wtth Part 10, Para 4.2.1. The di-on of the basis for this interval JeetlAcetion: These valves must remain open during power operation in order licensee's basis should be clarifled.

to ensure consistency with assumptions made regardng system flow to the Beele: (SO23V,3.5. Attachment 3. Para 13.3) These vahes RCS cold legs in the accident analysis and to comply with the intent of LCO Appendia A,IST Psegreen ah block the charging line from the Regenerative Heat Exchanger to 3.5.2. Para 2: This section does not provide the Reactor Coolant System when they close. They are located adequate justification for not testing at in the Ime between these two -sw as.

Alternate Testing Stroke these valves open and closed at cold shutdown power operation and/or during cold intervals. shutdowns. The reviewer must make These vahes must remain open duririg power operation in order assumptions to confidently postulate the to ensure cer&i- ., with assumptions made regarding system negatne consequences of performing flow to the RCS cold legs in the accident analysis and to comply testing during W operatums. with the intent of LCO 3.5.2. In addition to Techrucal Specification action statement entry, exerdsirq either air operated vahe during plant power operabon would require securing letdown and charging entirely. This is a lengthy plant evolution as is the restoration of letdown following the exerdse test. Further, stoppirig charging and letdown flow imposes a large thermal transient on the components in the marging/

letdown path which would eventually damage these cv.iw- is such as the letdown heat exchanger and the regenerative heat exchanger.

ATJ 13.0, Part 5, RCS Bleed o# to VCT leeletten. Valves,2(3)HV921T, and The basis identrfled for the cold shutdown Rossistion. (no change in interval) Continue to test at Cold 2(3)HV921s interval does not contain adequate Shutdown intervals. In the IST Program, enhance our

) istification for not exercising these valves dscussion of the basis for this interval.

Justificetten These valves are the containment isolation valves for the quarterty.

reactor coolant pump seat leakoff line to the Volume Control Tank (VCT). Beele: (SO23V,3.E. Attachment 3, Para 13.5) These vahes Exercisirig these valves could result in Reactor Coolant Pump seal failure and Appendis A,IST Psegrens A%, are the containment isolation vahes for the reactor coolant subsequent reactor shutdown. Para 3: This section does not provide pump seal leakoff line to the Volume Control Tank (VCT),

adequate justification for not testift at Altamete Testing Stroke these valves closed at cold shutdown intervals. power operation. The reviewer must make Exercising these valves could result in Reactor Coolant Pump assumptions to -hdii postulate the (RCP) seat failure and subsequent reactor shutdown. Operation i negative consequences of performing of the RCP mechanical seals % ends on steady bleedoff flow testing during power operations. to maintain proper staging and seal cooling. Without continuous bleedoff the seals very quicidy overheat and are destmyed Because of historical performance problems with our RCP seals, great care is exercised to avoid ewm momentary fluctuation or interruption of seal bleedoff flow. Exerdsing these valves while the RCPs are in operation Intemets the seat bleadoff now and consequeeniy, HV9217 and HV9218 cannot +

be shut while the RCPs are in operation without the risk of destruction of the RCP seals.

1

l Responses to Table 3.1 Resoluton of INEL Technical Evaluation Report (TER) Issues Page 11 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Attemate Testing Justification TER Concem and Basis .

ATJ 13.0, Part 8,52(3)1201MU200 and 202, LPSI Pung Section Check it is impractical to exerdse these valves Resolution (no change in interval) Contmue to test at Cold Valve quarterty. Therefore, the attemative is in Shutdown intervals. In the IST Prograrn, enhance our accordance with Part 10, Para 4.3.2. The discussson of the basis for this interval.

Justfacetloa. These vahes can only be exerdsed while the plant is on licensee's basis should be dartfled.

shutdown coolirg. Basis: (SO21V-3.5, Attachment 3. Para 13.9) These check Appendia A,IST Progenen Ah, vahes provide flow into the suction of the respectne LPSI Altomate Testing- Test these valves dosed at cold shutdown intervals. Para 3: This section does not provide pumps and prevent backflow from the pump into the lines from adequate )-MW for not testing at the RWST, etc.

power operatictL The reviewer must make assumptions to conndentfy postulate the lhese are check vanes on the shutdown cooling (SDC)line to regative consequences of performing the LPSI pump suctions. The suction from this line comes from testing durirg power operations. the RCS, on the hot leg irvecuon line inside the first pressure isolation valve. The only flow path that wodd open these vahes during plant operation would require taldng suction from the RCS and pumpeng it into the RWST on miriflow, which is not practical. The only practical method of opentrq these vahes is on shutdown cooling, and so the vanes nusst be tested at cold shutdown Lervals.

Closure of these vanes is verified by measuring leakage past the valves. OM-10. Paragraph 1.3 defines exercising as "the demonstration based on direct visual or indirect positive .

Indicatums that the moving parts of a valve function." Since it is not possible to OPEN exerdse test these vahes at a quaterty interval, vertfying the vane dosed at a quarterly interval would not satisfy the code requirement to exercise the vaNo. Once the vane has been venfled closed, there is no mechanism to open the vane onm SDC is secured, and hence no benefit on reverifyirg dosure on a quartetty basis. Therefore, the interval for the CLOSE exerdse test is set at the same inte vai as the OPEN exercise test. This position is further supported by NUREG1482, Section 4.1.4, which recognizes the difficulty in 4 performing a seat leakage test to sausfy a CLOSE test, and provides the extension of the test interval for testing of this nature is appropriate.

Responses to TaNe 3M Resolubon of INEL Technical Evaluation Report (TER) Issues Page 12 Orfginal Submittal Justifloation and Proposed TER Evaluation of the Resolution of the' Alternate Testing Justifloation TER Conoem and Basis ATJ 14.0, Part 3,52(3)2423MUO17*, Service Air Costainment teolation This attemate testing justiScation does Reseistion: The dose exercise test has been removed from the CheckVelve ret contain an adequate justificadon for Inserwoe Testire Program Requirements. Acxordingly, no not exercising this valve during cold attemate testing interval )_**rian is necessary.

Jeetincetten: This valve is a containment isolation valve and is not used during stwtdowns.

power operation. Streddng this varve during operation would require opening Beele: The basis document calls only for a close verification, the cx>ntainment penetration and performance of operations within the AppeedEx A,IST Progreen ah, upon further review of the function of this valve. This containment. Para 3- TNs section does not provide venficauon is conducted concurrent with the seat leakage test adequate y e"'-A-. for not testing at and is in accordance with NUREG 1482, Secuon 4.1.4.

Alternate Teeting Test this valve at reactor refueling intervals. power operation. The reviewer must make assumptions to confidently postulate the negative consequences of performmg testing durirg power operations.

ATJ 15.0, Port 2 Shetdown CoeNag Systeen Valves 2(3)HV0396, it is impractical to exerdse these valves Resolution; (no charge in intervst) Continue to test at Cold 2(3)HV8152,2(3)HVS153,2(3)HV9420 and 2(3)HV9434 quarterfy. Therefore, the altamative is in Shutdown intervals. In the IST Program, enhance our accordance with Part 10. Para 4.2.1. The diam"lan of the basis for this interval JustIncetion: These vahes are employed in directirg Shutdown Cooling )"*ification should be clartfled.

System flow into the Reactor Coolant System and controlling that flow. Basis: (SO23-V,3.5. Attachment 3. Paras.15.1.15.2. & 15.3)

Appendix A,IST Progreen Ah, For ECCS system operability, the Technical Speciftcations Full stroke testing during power operation would result in noncompliance with Para 2: This section does not prov6de (Surveillance 4.5.2.a) require wi&,ahn at least once per Technical Specification 3/4.5.2, which requires these valves to be dosed with adequate)*% for not testing at twelve hours that these valves are closed and power to the power to the valve operator removed _ power operation. The reviewer must make valve operators is removed.

assurnpdons to u.,44--ei postidate the Afternete Testing- Test these valves at cold shutdown intervals. negative consequences of performmg Testirt these vahes et a cold shutdown interval is consistent testing during power operations. with NUREG1482, Para. 3.1.1. Removing these valves from power lockout, restoring power and repositioning them in Modes 1,2 or 3 involves a hardsNp;i.e., repositionirt of a breaker from "off" to *on" (and closing the manual isolation valves for HV8152 and HV8153). MarNai action would be required to restore the ECCS if an acddent occurred while the test was in progress.

This risk outweighs the benefits achieved with a quarterty test in light of the fact that;(1) being in powG sockout, these valves ham a minimal probability of failure. fhey are ide (potential sources of failure are very limited); and, (2) the realignn ent of the system for the exercise tests h question invalidates the assumptions in the Safety Analysis (see the Technical Spedfication Bases, Section B 3/4.5.2).

This valve number was shown erroneously as $2(3)2317MUO17 in the INEL TER Table 3.1.

Raamnses to TaNe 3.1 Resolution of INEL Technical Evaluation Report (TER) Issues ' Page 13 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justification TER Concern and Basis ATJ 15.0, Part 2. Sinutdown Coeling System Valves 2(3)HVS160, it is impractical to exercise these vahes Resolution 2(3)HV8160 and 2(3)HV8161 No change in 2(3)HVS181, 2(3)HYS182, and 2(3)Hvas at qt.arterty. Therefore, the altamative is in interval.

accordance with Part 10. Para 4.2.1. The Justinceties. These valves are used in establishing the Shutdown Cooling justification shotdd be dartfled. 2(3)HV8162 and 2(3)VV8163: Change the test interval to System flow pattwhen the plant is siwtdown. quarterty.

Appendix A,IST Psegramam Full stroke exercising of tNs valve during power operation would result in Para 2: This section does not provide in the IST Program, enhance our discussion of the basis for the nork.oridia. with Technical WA =A-> 3/4.5.2, which requires this valve adequate justification for not testing at test intervals, to be open with power removed. power operation. The reviewer must make assumptions to confidently postulate the Basis: (SO23V,3.5. Attachment 3. Para 15.3) Technmal Altemate Testing- Test tNs valve at cold shutdown intervals negative consequences of p-L.n4 W 3/4.5.2, requires valves 2(3)HV8160 and testing during power operations. 2(3)HV8161 to be locked in the open position with power removed during plant power operations.

Reposinonmg these vahes results in entry into Technical w% Action Statement 3.5.2. Further, being in the common LPSI header, repositioring either of these vahes also renders both trains of LPSI inoperable since they are in the common discharge line for the LPSI system. Because of this loss of system function,2(3)HV8160 and 2(3)l'V8161 are excluded from quarterty testing consistent with the guidance in NUREG 1482, Para. 3.1.1(1).

ATJ 15.0, Part 3,2(3)HV9300 and 9301, Reheeling Water Tank Outist Valves it is impractical to exercise these valves Resolut. ion: The test interval has been changed to quarterly quarter 1y. Therefore, the attemative is in JustlRcetlea Closing either vane during normai plant operation will isolate accordance with Part 10, Para 4.2.1. The Basis: A review of the basis for the nor>quartni.rty interval was the pump suction and therefore cause the associated train of safety irvection )_=MW should be darified. completed in light of the guidance in NUREG 1482, issued in (Containment Spray, HPSI and LPSI) to become inoperable. This is contrary to April 1995. As a result, the original basis was ww$ to be the requirements of Technical SpecMcation 3/4.5.2. and puts the plant in a 72 Appendis A,IST Psegrasm Ama==a==, inconsistent with tNs new guidance and the tot aterval was hour action statement. Para 2: TNs secuon does not provide a4usted accordingty.

adequate F#% for not testire at

, Alternate Testing- Test these vanes at cold shutdown intervals. power operation. The reviewer must make l assumptions to w..~4-4 postadate the negative consequences of performing l testing during power operations.

ATJ 15.0, Part 8,2(3)HV9340,2(3)HV9350,2(3)HV9360 and 2(3)HV9370 it is impractical to exercise these valves Resolutlen: (SO23 V-3.5, Attachment 3. Para 15.6) Replace

, Safety Injection Tank Ostiet Valves to the RCS Leopo quarterty. Therefore, the altamative is in opening with cleeing as appropriate in the ATJ. In addition, the l

accordance with Part 10. Para 4.2.1. ATJ was darifled to show that the test interval is consistent with Justification. These vanes block the discharge path of the Safety triecuon NUREGr1482, Para. 3.1.1.

i Tanks into the Reactor Coolant System when dosed. Appendis A,IST Psegreen Anonnelles.

Para 6: TNs ATJ states that opening the Restoring power to tNs valve or opening this valve while the piant is at power subsect valves while the plant is at power would result in nonwndi== with the Technical Specifications would result in non compilance with the Technical Saa*=%s. These SIT block Alternate Testing- Test tNs valve at cold shutdown intervals. valves are required to be open during power operatJon. '

1 I i i,

Responses to Table 3.1 Resolution of INEL Technical Evaluation Report (TER) issues Page 14 Original Submittal Justmcation and Pregd TER Evaluation cf the Resolut3on of the Alternate Testing Justifloation TER Concern and Basis ATJ 15.0, Peet 11 S2(3)1204MU001 and 002 RWST to CS Puesp Sectlen it is impractical to f4 stroke exercise Resolutten. Continue to partialstmke test at quarterty intervals Check Valves these vanes quartetty or during cold and dsassemble and hand stroke at refuelire intervals as shutdowns. The alternate method for desmbed in the program, JustMcation. Theo vanes cannot be full-stroked usire flow during power fullstroke exerdsing is approved by GL operation, for the folewirg reasons: 8904 govided that the testirt complies Basis: (SO23N,3.5, Attachment 3. Para 15.10) NorHntrusNe with all of the provisions of GL 8904, techniques have been conswiered. However, because a flow The HPSI (shutoff head 1500 psi) and LPSI(shutoff head 200 psi) pumps are Position 2. path cannot be constructed which will fully stroke the vanes, unable to overcome Reactor Coolant System pressure inominal operating there is no norHntruseve technique such as magnetics or pressure = 2000 psi). There is no full 110w recirculates to the RWST from Appendix A, IST Progrene ah, acoustics that can be utmzed to verify the vanes aseve full either pump. Para. 4: The tJcensee has not adequately stroke capability. Althogh it is conceivable radiography could dernonstrated the 6v .Miy of be utilized to verify dosure, the vane must be disassembled The containment spray pumps cannot be utilized to full +troke these vanes verifying the required obturator movement anyway to verify the open capability, and so there is no ustrg flow, as the only full flow path during plant operation is throtch the by testing. Some test method may be acklitional value in vertfying closure throtch norHntrusive w.a-..=ut spray header and nozzles, feasible to verify the required exerdse of techniques.

these vanes. The t.icensee should These valves cannot be fWstroked ustrg flow dunng cold shutdown because consider methods such as using OM10, Paragraph 4.3.2 allows that a vahe may be sufficient flow to fullstroke the RWST outlet check vaNas is not achievable in non4ntrustve techruques (e.g., acoustics, dsessembled as an attemathe to full flow testirg.

i this condition. Retum flow from the HPSI and LPSI pump discharge lines is ultrasorucs, magnetics, radiography, and very limited, consisti g of mini-flow recirculation lines and Reactor Coolant thermography) to verify a full-stroke GL 8904, Position 2, allows c'siv.ncs4 of staggered testing System vent lines. The containment Spray (CS) pumps have a 6" recuculation exercise of the subject check vanes. This of like components by establishing an inspec*Jon plan for similar l line to the RWSTs, but these pumps by themselves cannot develop full-stroke testing may only be practical at coks groups of valves. Disassembly and inspection is performed in l f!w for the RWST outlet check valves. shutdowns or refuelirs outages The accordance with, and does not deviate from. OM10, heensee should perform their irwestgation Para 4.3.2.4, and GL 8904, Position 2.

Stroking the RWST outlet check vanes with flow from the LPSI pumps is and if a test method is found to be prohibited by the Technical Specifications in Cold Shutdown because the LPSI practicable, the IST requirements of the pumps must be aligned to take suction from the Reactor Coolant System to applicable vanes should be satis 6ed by pmvide shutdown cooling during this mode of operation. The LPSI pumps testing instead of disassembly and cannot, therefore, take a suction through the RWST outlet check valves. Inspection. The licensee should respond to this concem.

The equivalent of the combined Containment Spray. l. PSI, and HPSI flow rate cannot be developed with the HPS3 pumps alone. Furthermore, the HPSI pumps cannot be used to exercise these vahes during cold shutdown because of the risk of exceedirig cooldown rat 6 limits. The borated water in the RWST is normally at an ambient temperature of = 65'F and the cooled down Reactor Coolant System is nominally at = 135*F.

l The Code required testing of the RWST outlet check valves while the plant is in i

Cold Shutdown could only be performed after significant redesi2n of the system, such as the addition of an instrumented full flow test line.

Similar arguments also can be made for testing during reactor refuelirg.

, No allowable flow path exists in any plant mode for a full-stroke of the RWST l

outlet check valves using flow.

Afternato Teetlag- Quarterty, perform a partial stroke test (OPEN) of each valve using system flow. At each refueling outage, test the valves by partial disassembly, inspection and manual stroking on a rotatirg basis (one valve per refueling).

Responses to Table 3.1 Resolution of INEL Technical Evaluaton Repxt (TER) issues Page 15 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justification TER Concern and Basis ATJ 15.0, Part 12. S2(3)1204MU003 and 004, Check Va!ves, Containmat it is impractical to fulktroke exerdse Resolution: Continue to test at reactor refuelings with Samp to ECCS Pumps

• Sect 5on these vatves quarterfy or dunng cold dsassemNy and also with partial flow. Expand our discuss 6cn shutdowns. The attemate method of in the program to mcre ctear*y describe the status of the valve Jentification. The only source of water to the inlet of the containment sump full-stroke exercise is approved by GL testing and our basis for the attemathe testing we employ outlet check valves is the containment buildng sump. During normal plant g with 8904allprovided that the testing of the provisions complies of GL 8904 operation this sump is required to be kept dry and the isolation vatwes shut. Casts: (SO23N-3.5, Attachment 3 Para 15.11) Norwntrusive This system lineup predudes either full-stroke or partial stroke of these check Position 2. techniques ham been considered. However, because s flow valves using flow in this mode. path cannot be constructed which will fully stroom the valves.

Appedix A,IST Pmgram Anomallas, there is no nornntrusive techrnque such as magnetics or in cold shutdown or reactor refuehng modes, part stroke exer::ising of these Para 4: The Ucensee has not adequately acoustics that can be utilized to verify the valves achieve futt valves is possible with flow frtm the containment surno, however, the sump is deny nstrated the impracticality of stroke capability. Although it is conceivaNe radiography could not maintained at a deanhness level consistent with the internals of the Safety verifying the regtered obturator movement be utilized to venfy closure, the valve must be disassembled injection or Reactor Coolant system piping. The cleanup of the containment by testing. Some test method may be anyway to verify the open capabihty, and so there is no sump to a cleanliness level consistent with the internals of the Safety triection feasible to verify the required exerdse of aditional value in venfying dosure through norWntrusive or Reactor Coolant system would be labor intensive. these valves. The Licensee should techniques.

consader methods such as using if partstroke exerdsing were conducted by filling the sump with water and flow non4ntrusive techniques (e g., acoustics, Disassembly and inspection is performed in accordance with, testing these valves, this would potentially contaminate the safety iriection ultrasonics, magnetics, radiegraphy, and and does not deviate from, OM10, Para 4.3.2.4, and GL 8904, systems, the refuehng water storage tank, and/or the reactor coolant systern hnwawhy) to verify a full-stroke Position 2.

with low quality water. This contamination of the systems would cause exerdse of the subject check valves. This accelerated corrosion and degradation. Extensive flushing and deanup testing may only be practscal at cold following suels testing would therefore be required. shutdowms or refuehng outages. The licensee should perform their investigation The Code required testing could only be performed after significant system and if a test method is found to be modifications irwohirg considerable costs. These system modifications would practicable, the IST requirements of the involve additional containment penetrations and long runs of large diameter apphcable valves should be satisfied by piping with assodated supports and isolation valves. NRC Generic Letter testing instead of disassembly and 8904, Attachment 1. Position 2, identifies partial disassembly and inspection inspection. The lio=nsee should respond as an acceptable attematnm for stroking a valve when it is impractical to use to this concem.

flo* v.

A!tomate Testing The valves will be partially disassembled, inspected and manually full stroked a' each refueling outage on a rotating basis (one valve per refueling).

A method of partial flow testing will be developed and used following the partial disassembly and prior to retuming the valve (s) to service.

ATJ 15.0, Part 18, $2(3)1204MUO22 and 023. RWST laciation Valves to The attemative testing Justification does Resolutten: These valves have been removed from the IST LPSI Suction not adequate'y demonstrate the Program.

impracticality of exerdsing these valves Justification. MUO22 and MUO23 are locked open during normal operation. clowd quarterty during power operations. Basis: Additional review has revealed that the functions of Closing them during plant operation will cause the associated train of LPSI to these valves do not fall under the scope statement, Para.1.1, be inoperable and fail to meet the requirements of Technical Specification Appendix A,IST Program Anomallee, of Part 10 of the OM Code.

3/4.5.2 which requires two ir: dependent Emergency Core Coohng System Para 2: This section &es not provide (ECCS) subsystems to be operable and restore the inoperable subsystem to adequate Justification for not testing at operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. power operation and/or during cold shutdowns. Entryinto a Technical Altomate Testing- Test these valves at cold shutdown intervals Specification alone is not suflident reason to postpone an IST until Cold shutdown or reactor refueling.

. .- .- -. .. .- . ~.

Responses to Table 3.1 Resolubon of !NEL Technicr-3 Evaluation ReportITER) lesues ' PeGe 16 Original Submittal Justifloation and Proposed TER Evaluation of the Resolution of the Alternate Testing Justifloation TER Concern and Basis ATJ 15.0, Part 19, S2(3)1204000034,25,38,37, 83 and 104, Seesty It is impractical to exercise these vanes - 1 Charge the tST trtterval to reactor reW henetten Paump RemIRow Une Check valwee quarterty. Therefore the altamatNe is in ,

accordance with Part 10. Para 4.3.2. smeis: (SO23Va5, Attachment 3 Para 15.17) These Joseen==n==- Vaifsng closure of these vanes requwes placing the trenieow stopcheck valves direct mirMow reewadation Rom the HPSI,-

line out of serwcm for the HPSI, LPS4 and Conts nment S(say system pumps. AM A, BST Peugpane AnemeGee, LPSI purnps back to the Refuehng Water Storage Tanks.

This renders those systems our of service and is only practical in modes where Para 3- This asction does not provide .

these systems are not required to be operable artartuata justsScation for not testirg at - Prowectng Gow or pressure to vertfy completion of the h power operatiort The rowewer must enrke stroke requires placerg the minieow line out of sendee ior the Allesuch Teethg Test these vahes at cold shutdown intervals. assumptions to con 6dently postadate tiu HPSt. LPSI and Conuunment Sprey Systerns. These purnos may negathe consequences of performing run for a proiorged time dising a smaK break LOCA and rely testing durirt power operations. upon the tvunlAow for pump cooling. The pumps wit be damaged if this cooling is not aweilable. Thus, placing the menrnow line out of service renders those avstems inoperable .

and is only practical in modes during which these systems are -

not required to be operable under the Todinical Specsfications.

The only way to verify closure of these vulwes is to measure leakage into a test volume upstream of the check vulwes using a hydro pump. The elaborate valve lineup, test equipment required, and high manhours required to perform this test make it impractical to perform on a more frequent beeis. Performing the CLOSE test of these valves in cc-? ~6. with the LEAKAGE test at refusiwg intervals is consistent with NUREcr1482 Sechon 4.1.4.

Responses to Table 31 ReschMon of INEL Technicd Evaluation Report (TER) issues Page 17 Original Submittal Justification and Proposed TER Evaluation of the Resolution of the .

Alternate Testing Justification TER Concern and Basis ATJ 15.0. Part 20, S2(3)1204MUO40,41,42 and 43, Safety injectlen . it is impractical to exercise these valves Resolutten: These valves will have stroke capability vertfled Tank (SIT) Outlet Cineck Valves quarterty or during cold shutdowns. The ustrq non4ntmsave (M) testirg at each refuelirt outage on a attemative method for fulktroke totatirg basis in acccedance with NUREGr1482, Sec6on 4.1.2, Justillcaties, Opening these vanes during power opera +Jon is not possitie exercisirg is approved by GL 8904 against normal RCS operating pressure. A partstroke test is the ocdy test provided that the testirt complies with all Fail dosure of the valves is ensured by leak testing the valves possible during cold shutdown due to system configuration. 0M10 Section of the provisions of GL 8904, Position 2. to the limits specified in Technical S- -P- -Li 4.4.5.2.2 after 4.3.2.4(c) states, "As an attematrve to testing in (a) or (b) above, dsassembly they have been exerdsed but prior to Mode 2.

every refueling outage to wrtfy operability of check velves may be used." GL Appeedix A,IST Progrene am, 8404 allows development of staggered testing of like www ,- 6 by Para 4: The Ucensee has not adequately Beste: (SO23V3.5, Attachment 3. Para 15.18) This test establishing an inspection plan for similar groups of valves. This is stated in demonstrated the impracticality of utilizes a dump of the SITS to achieve the flow necessary to fuH position 2 of GL 8904. vestfying the required obturator movement stroke the valves, and magnetic and acoustic sensors to verify by testing. Some test method may be fun open stroke cf the obturator. This testinC is done during Altoniste Testing Partstroke on a cold shutdown interval. At refueling feasible to verify the required exerdse of fitting of the refueling cs#ity. If the M testing does not provide intervals disassemble and hand stroke. these valves. The Licensee shotdd adequate results, afterWwe techniques, including a -

consider methods such as using determination of the *Kulue* of the system, and/or a norWntrusive techniques (e,g., acoustics, calculation of flow velocity through the valves calculated usirg ultrasonics, magnetics, radiography, and changing tank levels, wiu be utilized to determine a successful thermography) to verify a fullstroke stroke. If these techniques are ur-ssfd, disassemt9y armi exercise of the subject check valves. This handstroking will be performed in accordance with Generic testing may only be practical at cold Letter 8904.

shutdowns or refbeting outages. The licensee should perform their investigation and if a test method is found to be practicable, the IST requirements of the appik:able valves should be satisfied by te; ting instead of disassernbty and inspection. The licensee should respond to this concem.

ATJ 15.0, Part 24, S2(3)1204MUO99, Muel Costainaseet isolation Vehre - The altamathe testire )_Non does Resolutten The exercise test has been deleted from the IST SIT Drain to RWST not adequately A. h4.the program requirements for this valve.

impracticality of exercising this valve Justification: Opening this valve at power for test requires entry into a quarterly during power operations. Beele: Additional review has revealed that the dose function of Technical Specif! cation Action Statement due to breach of containment this manual valve does not fall under the scope statement, integrity. Appendix A,IST Progresa Anormelles Para.1.1, of Part 10 of the OM Code.

Para 2: This section does not provkle Alternate Tasting- Part-stroke test this valve at cold shutdown intervals. adequate justification for not testing at power operation and/or during cold shutdowns. Entry into a Technical Whtfon alone is not sufficient reason to postpone an IST until Cold shutdown or reactor refueling.

Responses to Table 3.1 Resolution of INEL Technical Evaluation Report (TER) Issues Page 18 s

Original Submittal Justification and Proposed TER Evaluation of the Resolution of the Alternate Testing Justification TER Concern and Basis ATJ 18.0, Part 4,2(3)PCVS463 and 8465, ADV Nitrogen Accumulator it is impractical to exerdse these vanes Resolution: (no change in interval) Provide a corrected and Pressure Control Valves quarterty. Therefore, the alternative a in darified )_dnedan for attemate testirig in c.cs=Jw with the ac::ordance with Part 10, paras. 4.3.2. Code and guidance provided in NUREG 1482 and G1. 8904.

Justification These valves are pressure control valves and are therefore The licensee's basis should be darif,ed.

excluded from insensce testing requirements under 0410. Section 1.2. The Basis: (SO21V,3.5, Attacnment 3. Para 16.4) These valves backup nitrogen gas supply to the ADV will not be available while pressure Appendix A,IST Program Anomalies are not Code valves, bewever, they have been included in the corrtrol valves are stroked open. This necessitates an entry into the action Paras. 2 and 5: This section ooes not IST program to assure functiona!ity. They era listed in the IST requirements of Techracal Speciftcation 3.7.1.6. These valves are open provide adequate.wnanan for not Program for convenience, howsver, a missed or failed stroked durirg IST of the respectrve ADV's at coid shutdown intervals. testirig at power operation and/or during survei!!ance will not constitute a violation of Techrucal Therefore the practical test frequency is cold shutdowrt in conjunction with the cold shutdowns. Entry into a Technical Spedftcation 4.0.5.

ADVIST. Specification alone is not sufficient reason to postpone an IST urrtil Cold shutdown or See t.etter,1 G. Partlow, NRC, to Alt Licensees, etc. Minutes of Afternate Test!ng- Test at refueling intervals in corgunction with the testing of reactor refueling. the Public meetings on Generic lstrer 8904, the associated ADV. October 25,1989. Response to Question #53, ard NUREG 1482, Section 2.2.

The IST basis documentation requires only certain tests for these valves. The stroke time of these control vanes verifies the open stroke. These valves are open stroked during IST of the ADVs at cold shutdown intervals. Therefore the practical test frequency is cold shutdown in cordunction with the ADV LST.

ATJ 16.0, Part 5, S2(3)1301MU1264 and 1265, ADV Equalizing Bett Valves it is impractical to exerdse these vatves Resolution: Revise the justification for the cold shutdown quarter 1y. Therefore, the attemative is in interval to provide darification.

Justification: These valves are not Code valves. In spite of the fact that they Ehdi== 6 with Part 10. Para 4.2.1. The are exempted from IST since they are provided for operating convenience, they justification should be dartfied. Basle: (SO21V3.5 Attachment 3. Para 16.5) These vahes have been included in the IST program to assure functionahty. MU1264 and are normally dosed and are opened to equalize the pneumatic MU 1265 are open and dosed stroked during IST of the associated ADV at cold Appendix A,IST Program Anomalies, pressure across the valve actuator to permit manual operation shutdown intervals. In order to stroke the valve dosed, the assodated ADV Para 5: This ATJ states that the listed of the atmospheric dump valve, if these valves remain dosed, must be dedared inoperable because normal control air must be isolated. vanes are normally open but are required actuator pressure would not be equallred, and manual Therefore the practical test frequency is (x>ld shutdown in cortunction with the to dose to isolate the ADV nitrogen supply operation would be dif5 cult. This could delay manual operation ADV IST. The response to Question 53 in Reference 2.5.2 is followed for to allow manual ADV operation which is of the ADVs. Local manual operation o"the ADV is used when guidance in these cases, requ!redif remote operation is not the ADV car:not be operated from the Control Room during; a possible during a steam generator tube steam generator tube rupture; main steam line break outside Attornate Testing- Test these valves at cold shutdown intervals. rupture, main steam kne break Feedwater containment; feed water line brealc fire and control room fins break, fire and control room evacuation.

evacuation. However, the ATJ further states that the valves are for operating These valves are not Code valves, however, they have been corwenience and exempted from IST. If included in the IST program to assure functionality. MU1264 the valves perform a required safety and MU1265 are open ard dosed stroked during IST of the function, they are not operating associated ADV at cold shutdown intervals, in order to stroke corwenience valves. the vatve dosed, the associated ADV must be declared inoperable because normai control air must be isolated.

Therefore the practical test frequency is cold shutdown in conjuncbon with the ADV iST. The response to Question 53 in letter, J. G. Partlow, NRC, to All (Jcensees, etc Minutes of the Public meetirgs on Generic Letter 8904. October 25,1989 is followed for guidance in these cases.

. _ .- . . . _ .. -m._..._y_...__.. . , _ _.,.x ._ . ..._ . . - , - ~ ~ _ . _ , _ . - - . . sm. . . . ,_

, x - . _ _

s  % , ;ry .

- g .W w.

~

,y '

nw" _ < <

s_ . , ~

7 t

'~ - ~

>[d

Responses to Tame 3.1 Ramawan of INEL Technical Evaluation Report (TER) leeues ~ 9 Page 19

, .+ _

_,~ *'T 4

.6o.

4 _.

~ gy 3,egManHan * - -

~

lM hM M W q~ l;! q

![ ATA 2868, Past'7. S3(3)wmemmanaeand 005. Cheek Velves AStoem Sepply it is impractical to AS strohn esordeo n===Mm=- Imgeous Was ve=r==*=a in Wie geograin tomier Wie L ?I s~

i. to AFW Pasip Toshine these vehos guertarty or durW cold beeis ==r*=i ter sie Attemets Teethtg piscieds and interte's j L

al=*8a==is. The altamethe meWind for -

~ ~"

citoesn.

l[

j _

JonWeedoo:- Dwing nonnet plant opereton, main steem pressure tends to 1 open those vehes. No pressure souros selets to reverse this pressure in the Ametseles eemsdairs is opgeoved by GL1 8904 proulded that Was testirq complies Boots: (8023V3.5 Attacionant 3 Pere 16.7) The use of;

. . , . . . Ell l

steem une where these vehes asewand amour detection of Wa closure with sE the faculsions of GL 8904, non4ntruelve test tecimiques are being pursued, with some _

q or value leakage. consequency, with the present system doelen, werWying the Pr,sition 2. - =% en these velwes. Sucesestid ===de and magistic l doeure of the AFP Steam Supply dieck wehes by leek tenerg or with reverse traces hoe been obtained to werfy both coon and deeme of ; J nour, when the piant is operatire, is not pr=*=i Althotch a temporary , Appemen A,IST Penguem Asemaeus. Wiese wehos. Neverth=a=== we conduct disassembly and 3 ._

Li estamos prosaure source could be connected to the doom.etroem pipisg and Pere 4: The Licanese has not =*=r=8=ey in=p=reir=i oveey outage because of post problems with these . a

'2: apply sour a pressure to these dieck vehes, the required vehe unsup would demonstrated the impr=*=my of . valves; N R is detensined that dsessemedy and trap =r*=i ls no -!

cause the waei=ted madsery Feedwater pump to be inoperside during the - verWylng the regidred obturator movement losger seguired, the norwntrushe todmiques may be '

l test.

~

by tomeng. Some test mothed may be : . Implemented. >

5 m . . ... . .

sensible to versy the seguired onesdee of . . . . . . .

l- lleganSees of plant mode, there is no posiehe means of verNyirt that the vehe . these valves. The Liaonome shondd .' Diseosomedy and Ip= par *=iis performed in accontence elWi c ,

i" dec travels to the +==ri poemon. System conneenons, audi as wants and . consider methods audi as using - and does not deviene from Oneio, Para L3.2.4. and GL 8944, a drains (and appropriate line imaame==i valves) are not present in the system to - norHntrushe tediniques (e,g., =cr===de=

~ "

Posetion 2..

'~

allow verilication that a pressure diferentlel osists acnoes the AFP Steam ultremonics, magnetics, redography, and .

i Supply chedc vehos when they are in the closed position.

thermography) to verify a fud strates ,

eaerdes of the siddect dio fouhes. This ~

08410 and PWIC Generic Letter 8904, Attachment 1 Position 2, identilles testeg sney only be prececal at cold :

pertial dsessembly and in= par *=i as an ar-r*=Ma altamative for stroldrq a shutdoens or sofueNrq outages. The :I welwa when it is impractical to use Sour. In this caso, these is no way to test lloenoce shoidd posform their investigation 9

~

these dieck vehes closed with the existmg system design usirg reverse flow or and N a test nisthod is found to be .

pressure. Testing of these wahos could only be accompNahed sher signNicent pr=*=N=, the IST requirements of the ~

3 redeelen of the system, such as in=*=e=8ir=i of adcBtional i=aaen,wi wehos and ' =Pr ee=Ma walves shosed be sedeAed by j appropeiste wants and drains in the high pressure steem piping. The high costs - teseng instead of disassembly and ' - i of the necessary design charges invoked wondd not be JustNied by the .

Inar=*=t. The noensee shoeid seapond improvement of the vehe tesung. Rother, the addition of webes, steports and toihis concom.  ; ' j noosenery pipirs modificodens could result in r=rw plant =e=Nety i Altesmate Testleg- Quartetty, perfonn a partial stroke test (open) of each wehe h unire system nour. At each sofueling outage, test the wolves by partial q

.e=====nidy, inspection and menuel stroldrq on a totatirg beels (one velve por ":

! refuoNng). d >

O pec-SERJtESP.w61 , .j Aiguet 22,1995 r j q

i

. 1 I

k

~

l

4:

' T 4

n

3 l

3-a t

1 I

i s

J ENCLOSUREH2 PROCEDURE S023-V-3.15.,

-INSERVICE TESTING 0F VALVES REVISION 9-2 s

j .-

2 4

l l

l f

4 1

l I i 1

- i

f. i i- I i'

l f

,, I, J l 1

, 1 i

l 1

l