ML20094P188

TER, Duane Arnold Energy Ctr Pump & Valve Inservice Testing Program,Rev 13,Third 10-Yr Interval

ML20094P188
Person / Time
Site:	Duane Arnold
Issue date:	05/31/1995
From:	Dibiasio A BROOKHAVEN NATIONAL LABORATORY
To:	NRC (Affiliation Not Assigned)
Shared Package
ML20094N694	List: ML20094P188
References
CON-FIN-L-2301 TAC-M91683, NUDOCS 9511280350
Download: ML20094P188 (39)

Text

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l TECHNICAL EVALUATION REPORT l

Duane Arnold Energy Center IES Utilities Inc.

Pump and Valve Inservice Testing Program Revision 13, Third Ten-Year. Interval Docket Number: 50-331 TAC Number: M-91683 Prepared by:

A. M. DiBiasio Engineering Technology Division Department of Advanced Technology Brookhaven National Laboratory Upton, New York 11973 Prepared for:

Division of Engineering Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 FIN L-2301, Task Assignment 15 May 31,1995 951128035o 951121 ENCLOSURE 3 PDR ADOCK 05o00331 P PDR

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. l ABSTRACT l

This report presents the results of Brookhaven National Laboratory's evaluation of the pump and valve relief requests, cold shutdown and refueling outage justifications and, for selected systems, a review of the scope of the Duane Amold Energy Center, ASME Section XI Pump and Valve Inservice Testing Program.

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TABLE OF CONTENTS ABSTRACT ................................................................. iii 1.0 NTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. . . . . . .

2.0 PUMP RELIEF REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 . . . . .

2.1 Pump Relief Request No. PR-02, River Water, Core Spray and RHR Pumps . . . . . . . . . . . ................................

2 2.2 H PC I P ump . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............

............. 3 2.2.1 Relief Request No. PR-03, instrumentation . . . . . . . . . . . . . . . . . . . . . . 3 2.2.2 Relief Request No. PR-04 Test at Reference Value ................ 4 2.2.3 Relief Request No. PR 05, Test Each Pump ...................... 7  ;

3.0 VALVES IST PROGRAM RELIEF REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7. . . . . .

3.1 Generic Valve Relief Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 3.1.1 Reliei Request No. VR-01, Solenoid Valves . . . . . . . . . . . . . . . . . . . . . . . 8 3.1.2 Relief Request No. VR-02, Excess Flow Check Valves .............. 9 3.2 Relief Request No. VR 04, CRD Accumulator Rupture Disks ............ 10 3.3 Relief Request No. VR-14, HPCl Barometric Condenser Relief Valve ...... 11 3.4 Relief Request No. VR-16, Vacuum Breaker Valves . . . . . . . . . . . . . . . . . . . . 12 3.5 Relief Req uest No. VR.22, MSIVs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

13 3.6 Relief Request No. VR 23, Emergency Service Water Valves ............ 13 4.0 DEFERRED TESTING JUSTIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ...  ;

5.0 IST PROGRAM RECOMMENDED ACTION ITEMS . . . . . . . . . . . . . . . . . . . . . . . . . . .30 ...

6.0 REFERENCES

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1 i Technical Evaluation Report

) Duane . Arnold Energy Center 1

Pump and Valve Inservice Testing Program Third Ten Year Program 4 Revision 13

1.0 INTRODUCTION

Contamed herein is a technical evaluation report (TER) of Revision 13 of the ASME Section XI Third Ten Year Program for pump and valve inservice testing (IST) submitted to the U.S.

1 Nuclear Regulatory Commission (NRC) by lES Utilities Inc. for its Duane Arnold Energy Center on January 30,1995 (Ref.1). The program for this third ten year interval is based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code,1989 Edition (Ref.

2). The 1989 Edition of Section XI provides that the rules for inservice testing of pumps and valves are as specified in ASME/ ANSI OMa-1988, Parts 1, 6 and 10 (Refs. 3,4,5).

This program revision supersedes all previous submittals. The Duane Arnold Energy Center is i

a General Electric Boiling Water Reactor (BWR) which began commercial operation on I February 1,1975. The third ten year inspection interval is defined for the Duane Arnold Energy Center as beginning February 1,1995 and ending January 31,2005.

Title 10 of the Code of Federal Regulations, $50.55a 1(f) (Ref. 6) requires that inservice testing of ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with l Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where  ;

specific relief has been requested by the licensee and granted by the Commission pursuant to '

$50.55a 1(a)(3)(i), (a)(3)(ii), or (f)(6)(i). IES Utilities Inc. has requested relief from certain ASME Section XI testing requirements. A review of the relief requests was performed using Section 3.9.6 of the Standard Review Plan (Ref. 7), Generic Letter 89-04, ' Guidance on Developing Acceptable Inservice Testing Programs,' (Ref. 8), the Minutes of the Public Meeting on Generic Letter 89-04, dated October 25,1989 and September 26,1991 (Refs. 9, 10), and Supplement 1 to Generic Letter 89 04 which contains NUREG-1482, ' Guidelines for Inservice Testing Programs at Nuclear Power Plants,' (Ref.11). The IST Program requirements apply only to component (i.e., pump and valve) testing and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements. As discussed in NUREG 1482, Section 2.2, relief requests for non-Code components do not require NRC evaluation and approval and, therefore, are not included in this TER.

1 Section 2.0 of this report presents the evaluation of four of seven pump relief requests

' submitted. Section 3.0 presents the evaluations of seven of twenty one valve relief requests submitted. Two pump relief requests and seven of the fourteen other valve relief requests are for non-ASME Code classified components and NRC approval is not required in accordance with the regulations. The remaining pump relief request was previously evaluated (Ref.12). The

. seven other valve relief requests are authorized by Generic Letter 89-04 and, consequently, 1

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are not specifically evaluated in this Technical Evaluation Report. However, any anomalies associated with these relief requests are addressed in Section 5 of the report. The evaluation of justifications for deferring quarterly valve testing are presented in Section 4.0. Section 5.0 summarizes the actions required of the licensee resulting from the TER evaluations of the relief requests, he deferral justifications, a systems review, and programmatic aspects, while Section 6.0 lists the references.

I 2.0 PutBP RELIEF REQUESTS 1

l in accordance with $50.55a, IES Utilities Inc. has submitted five relief requests for pumps at the Duane Arnold Energy Center which are subject to inservice testing under the requirements of OMa-1988, Part 6.

Relief Request PR 07 was previously evaluated by the staff (Ref.12).

The other four relief requests have been reviewed to verify their technical basis and determine their acceptability. These relief requests, along with the technical evaluation by BNL, are summarized below.

2.1 Pump Relief Request No. PR-02, River Water, Core Spray and RHR Pumps I Relief Request: The licensee has requested relief from the requirements of Part 6,15.2 which l

requires measurement of test parameters at a given reference value(s), and 15.6, which l

requires test parameters to be measured two minutes after stable conditions are achieved, for i

the river water, core spray and residual heat removal (RHR) pumps.

'{

Froposed AAremate Testing: The licensee has proposed measuring differential pressure (AP) at a flowrate above and below the ieference flowrate, and calculating the AP at the reference flowrate by Enear interpolation. The licensee will bound the flowrates where data is taken to ensure that he linear interpolation is valid.

Licensee's Basis for Relief: The licensee states: " Operating experience has shown that flow rates (independent variables during inservice performance testmg) for these pumps cannot be readily duplicated with the present flow control systems. Flow control for these systems can only be accomplished through the operation of large valves as throttling valves. Because these valves are not generally equipped with position indicators which reflect percent open, the operator must repeatedly ' jog

• the associated motor or air operator to make minor adjustments in flow rate. These efforts to exactly duplicate the reference flowrate require excessive valve manipulation which could ultimately result in damage to valves and their operators.

Since using his method precludes operating the pumps at the ' established

• reference conditions for any appreciable period of time, the 2 minute run time (interpreted to be at reference conditions) can only be applied at those points where data is taken.

The method described... is essentially equivalent to that required per Part 6, Paragraph 5.2 and will provide an equal measure of assurance of pump operability to that of the Code."

Evaluation: The licensee has stated that it is impractical to comply with the Code requirements, based on the difficulty of configuring the system to replicate the reference flowrate at every test and the potential for valve damage due to throttling (i.e., jogging) valves 2

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. that are not designed for trottling nor equipped with position indication. It is suggeste' d t the licensee review NUREG-1482, Section 5.3. The staff has recognized that certai

not allow the setting of flowrates at an exact value, and allows a 12 percent tolerance of the j reference value without approval from the NRC. The licensee has stated that the flowrates

! where data is taken will be bounded, to ensure that the linear interpolation is valid, but, has i not provided specific information on the range of data. If the licensee's procedures restrict the 1

data to 12 percent, relief is not required.

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If the licensee determines that setting the reference value to A2% of the reference flow is i

impractical for these pumps, the licensee's proposed method of determining the differential l pressure at the reference flowrate based on interpolation of two data points provides an -

j acceptable means of determinkig pump degradation. The calculated AP will be equal to or lower than the actual AP, based on the concavity of a pump curve, and, therefore, will caus

{* to enter the lower required action range sooner, in general, degraded pumps will not get b  ;

i.e., have a higher AP. The intent of the Code, as documented in a paper given by J. Zudans i

the technical differences between Part 6 and Section XI, Subsection IWP at the First ASME/NI i Pump and Valve Symposium (Ref.13), is that the high alert range is provided to assure test repeatability and to identify instrument fluctuations. Therefore, the lower than actual AP i j  !

j should not impede the determination of pump degradation. The licensee should ensure that the calculation method meets quality assurance requirements and is included in a procedure.

d i The Code,15.6, requires test parameter measurement to be taken after the pump is run at least i two minutes after pump conditions are stable. The licen;ee's proposal to apply the 2-minute run time at those points where data is taken complies y,ith these requirements and relief from 15.6 is not required.

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! Provided the licensee reviews the testing for these pumps and documents the impracticality

! performing inservice testing at the reference flowrate 12 percent, and proceduralizes the

calculation, it is recommended that the alternative proposed by the licensee be authorized in accordance with 10CFR50.55a(a)(3)(i), as the alternative provides an acceptable level of quality and safety.

i 2.2 HPCI Pump

} 2.2.1 Relief Request No. PR-03, instrumentation i

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• Relief Bequest:

requirements The licensee has requested relief from the instrument accuracy and range of Part 6,14.6.1.1 and 4.6.1.2 for the HPCI pump.

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• Proposed Alternate Testing- "During inservice testing of the HPCI pump, suction pressure I will be measured with the installed instrumentation. During testing a digital Multimeter will be inserted into the instrument loop, yielding readings equivalent to a 0-60 psi, 2% of Full-

, Scale pressure gauge."

f Licensee's Basis for Relief: The licensee states: "The instrumentation loop accuracy for HPCI j

i pump 85 paig.suction pressure is 12.06 percent (excluding calibration) and the range is 30' Hg -

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The installed HPCI suction pressure gauge is sized to accommodate post accident torus pressures (85 peig); however, during testing the only source of pressure for the HPCI suction line comes from the head of the condensate storage tank (approximately 20 psig). Given the installed instrument loop, the maximum reading error is less than 2.5 pai. Considering that the typical i

j HPCI pump differential pressure during inservice testing is approximately 1,100 paid, an additional error of 2.5 psi in reading the pump suction pressure is inconsequential with l respect to evaluating pump operability or degradation.

r h

l During the first and second ISI inspection intervals the test results obtained using this

} instrumentation have proven to be satisfactory and consistent providing reliable information."

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{ Evaluation: The Code,14.6.1, requires pressure instrumentation to have an accuracy of 12 %

i of the full range, which can be up to three times the reference value for analog instruments.

{ Based on discussions between Mr. William Huffman, NRC, with Mr. William Connoley, IES,' the HPCI suction pressure is normally measured with a electro-mechanical transmitter, which is j

connected to an analog gauge. This arrangement yields an accuracy of 2.06%. During inservice testing, however, the electro-mechanical transmitter will be connected to a digital multimeter.

j The Code requires the reference value, when using digital instruments, not to exceed 70% of the calibrated range of the instrument and an accuracy of 12 percent over the calibrated range.

The licensee stated that the proposed instrument loop to be used for IST yields an accuracy of i

! 0.7%. Based on the information provided, the Code accuracy and range requirements for digital instruments are met and no relief is required.

2.2.2 Relief Request No. PR 04, Test at Reference Value Relief Request: The licensee has requested relief from the requirements of Part 6,15.2, which requires measurement of test parameters at a given reference value(s) for the HPCI i

pump, and 15.6, which requires test parameters to be measured two minutes after stable conditions are achieved.

l Proposed Altemate Testing: The licensee proposes to use a pump reference curve. The pump will be run for 2 minutes before any data is taken. However, at each data point on the curve, the pump will only be run until stable conditions are achieved.

l " Pump differential pressure and flow rate will be evaluated using a reference value test derived pump curve over a limited range of pump operation. This 4

reference value test pump curve will be restricted to an operating regime that is f

representative of the pump operation under accident conditions or conditions that are the most sensitive indicator of pump degradation.

Based on the reference value test pump curve, acceptance criteria curves will be established for the upper and lower required action and alert range limits.

Detailed Technical

Description:

The reference value curve will be established by measuring a minimum of five (5) sets of differential pressure /flowrate data when the pump combination is

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known to be operating acceptably. The measurements w21 be distributed across the expected range of potential inservice test conditions.

The equation for the reference value curve will then be computed using a third-order polynomial regression technique that employs a least squares fit of the data by successive polynomials of orders 1 through 3. The standard deviation about the regression line will be evaluated for each case. The resulting reference value curve is expressed as a third order polynomial in the general form:

' y=a*3+anxt+apa , owhere y is the dependent variable and x is the independent variable, j

The Required Action and Alett Range Curves will be scaler multiples of the reference value curve.

I The measurements taken during inservice testing will be restricted to only those falling within the envelope of reference value test measurements. The inservice test differential pressure /flowrate test results will be plotted on a typical pump curve or evaluated by an equivalent tabular method and the results included in the permanent test records.

Finally, the combined differential pressure /flowrate test results will be

! evaluated for variation from test to-test to identify any pump degradation. In addition, the results of all IST testing will be evaluated with respect to operability criteria for flowrate and differential pressure set forth in the DAEC Technical Specifications and UFSAR.

Pump vibration values will be measured at the highest and lowest points used for constructing the pump curve. From this data the vibration acceptance criteria will be derived in accordance with Part 6, Paragraph 6.1 and Relief Request PR-07 using the most conservative vibration data.

When the reference curve may have been affected by repair, replacement, or routine service, a new referenca curve will be established or the previous curve will be revalidated by conducting an inservice test.

Pump operating run time is limited by torus temperature limitations, thus allowing the pump to stabilize for 2 minutes at each data point may cause torus temperature to rise to a point where the test may be prematurely terminated. To alleviate this concern during reference value tests, initially the pump will be operated under nominal conditions for at least 2 minutes to allow instrument stabilization. Following this, the flowrate will be adjusted as required to obtain the required number of data points. At each data point readings will be taken as soon as conditions stabilize; however, the 2 minute operation time at each data point will not be imposed."

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Licensee's Basis Apr Relief: The licensee states: " Operating experience has shown that l'ow rates (independent variables during inservice performance testing) for the HPCI pump canno be readily duplicated with the present flow control systems. Efforts to exactly duplicate the reference values would require excessive' valve manipulation which could ultimately result I damage to valves or operators. In order to perform accurate trending and data analysis, the u of an accurate reference value is very important. The complexities of the flow control sys found within these systems makes it extremely difficult to exactly duplicate the reference values.

Current result NRC policy promulgated via NUREG 1482 allow using a ' graphical' method of test interpretation."

EvaAustion:

The licensee states that exactly duplicating the reference flowrate during inservice testing requires excessive valve manipulation due to a lack of precise means of throttling the HPCI pump flow rate. The potential exists for valve damage due to throttling (i.e., jogging valves that are not designed for throttling. As discussed in NUREG-1482, however, exact duplication tolerance of of the reference value is not necessary. Section 5.3 of the NUREG explains that a 12 percent of the reference value is acceptable and relief is not required to use this tolerance. The licensee should evaluate this guidance and determine if relief is still necessary. Other BWR plants have not requested relief from these requirements for the HPCI and RCIC pumps. If relief is necessary, the licensee should discuss the range of flowrates experienced.

The staff in NUREG 1482, Section 5.2, provides guidance for utilizing pump curves when it is impractical to establish a fixed set of reference values. The licenses complies with the seven elements identified in Section 5.2, except for element 6. The licensee states that " Pump vibration values will be measured at the highest and lowest points used for constructing the pump curve. From this data the vibration acceptance criteria will be derived in accordance .

with Part 6, Paragraph 6.1 and Relief Request PR 07 using the most conservative vibration data." Pump vibration readings may vary widely with changes in pump flowrate. The highest and lowest flowrates may not yield the most conservative vibration readings. The licensee should evaluate vibration levels at each point on the curve before determining the acceptance criteria. Provided the licensee evaluates the vibration levels over the range of pump conditens and determines that it is impractical to attain the reference value 12%, relief in accordance with 10CFR50.55a(f)(6)(i) may be recommended.

The licensee has also requested relief from OMa 1988, Part 6,15.6 which reqisires that after the pump conditions are as stable as the system permits, each pump shall be run at least two minutes. At the end of this time, measurement of the required parameters shall be made. The licensee has proposed to run the pump for 2 minutes before any data is taken when constr the reference curve. However, at each of the five data points on the curve, the pump will only be run until stable conditions are achieved. The licensee has based the justification on the increase in suppression pool temperature. However, no specific information on the suppression pool temperature increase experienced during testing has been provided. The licensee must provide additionalinformation before a recommendation to approve the attemate in accordance with 10CFR50.55a(s)(3)(ii) can be made. The licensee should revi resubmit the request with the additional information discussed above.

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J 2.2.3 Relief Request No. PR-05, Test Each Pump i Relief Request: .The licensee has requested relief from the requirements of Part 6,14 and 5  !

which require an inservice test to be run on each HPCI pump. )

Proposed Attemate Testing: The licensee has proposed to measure the differential pressure the HPCI pump combination (i.e., the booster and main pump).

Ucenese's Basis ibe R4. lief: ~ The licensee states: "There are no suitable provisions for measuring the pressure in the cross-over piping between the HPCI booster and main pumps

- Since these pumps are driven by a common driver and are connected in tandem, they are necessarily tested together, simultaneously, under the same operating conditions (flowrate and turbine speed). Therefore measuring the inlet pressure of the booster pump and calcula the differential pressure of the pump combination will effectively verify operability and serve to monitor the performance of the pair."

Evaluation:

The HPCI main and booster pumps are driven by the same turbine. They are coupled together on the same shaft and act as a unit to provide high pressure reactor coolant makeup. The flowrate through both pumps is essentially the same (There is a small amount of flow from the booster pump discharge that is diverted to the barometric condenser for condensate). There is no provision for measuring the pressure at the discharge of the booster pump, which is the suction of the main pump. It is not practical to test these pumps for hydraulic degradation independently. The licer.4ee has proposed to measure and evaluate the differential pressure across both pumps and apply the Code acceptance criteria. This prl provides an acceptable level of quality and safety to determine pump hydraulic degradation as any degradation in the performance of either or both pumps would be seen as a change in the differential pressure across the combination. Therefore, it is recommended that relief be granted in accordance with 10CFR50.55a(f)(6)(i).

3.0 VALVES IST PROGRAM RELIEF REQUESTS in accordance with $50.55a, IES Utilities Inc. has submitted fourteen relief requests for valves at the Duane Arnold Energy Center which are subject to inservice testing under the i requirements of OMa-1988, Part 10. Seven of these relief requests have been reviewed to verify their technical basis and determine their applicability. These relief requests, along with their technical evaluation by BNL, are summarized below. The other seven relief reques (i.e., VR-03,5,6,13,18,19, and 21) propose alternate testing as discussed in NRC Generic Letter 89-04, Positions 1,2, or 7, and have not been specifically evaluated. Duane Arnold's IST Program was written to comply with the 1989 Edition of Section XI. This edition references OMa-1988 Part 10 for valve testing. Generic Letter 89 04 does not address Part 10.

Part 10 has not been revised to address control rod drive (CRD) valve testing nor full-stroke check vafve exercising, and the guidance provided in Generic Letter 89 04 remains valid. Part 10, unlike earlier versions of Section XI, discusses disassembly and inspection in lieu of check valve exercising with flow. Part 10, however, does not discuss a sampling technique and requires that disassembly be performed each refueling outage. The NRC, as documented in Generic Letter 89-04 Position 2, recognized that disassembling all applicable i

valves each refueling outage may be burdensome and allowed grouping of similar valves and a 7

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valve d- em,bly not to exceed once every six y ,

revised the OM Code to allow a sampling technique (i.e., in the 19 code has not been endorsed by the NRC in $50.55a. The relief is ,

Letter 89-04, Position 2, pursuant to 10 CFR 50.55a(g)(6)(i) [now 10 CFR 50.55a(f)(6)(i)] provided the alternative is in compliance with all of the gu in Position 2. The relief requests indicate that the disassembly nce delineated and compliance with such guidance. r gram is in 3.1 Generic Valve _ Relief Requests 3.1.1 Relief Request No. VR-01, Solenoid Valves Relief Request:

The licensee has requested relief from the requirements of Part 1014216 which requires valves with fail safe actuators to be tested , ...,

by observin actuator of uponvalves all power operated losstoof be valve actuating power, and 14.2.1.4(b), which req measured.

Proposed Alternate Testing:

The licensee has proposed that normal stroking of the air-as required. Proper operation of the main valve -

est (st associated valves solenoid will be performed. pilot valve is also operating satisfactorily.eNo additio Licensee's Basis for Relief: The licenses states:

to air-operate.d valves typically stroke to their fail-safe position upon n of their electric power.- De energizing the solenoid valve has the same effect as power or control air, therefore, the normal stroke constitutes a In fail-safe addition, test.

these pilot valves have no position indication making strokempractical." time measureme Evaluation:

The Code, OMa-1988, Part 10,14.2.1.6, be tested by observing the operation of the actuator upon loss of valve . If normal stroking of a valve to its fail-safe position has the same affect as the power (e.g., the control switch deenergizes an electrically-operated valve, or o then a normal exercise to the fail safe position ... and wou associated not required. solenoid valve to its safety position co ,

t The licensee has proposed that testing the air operated valves adequately a satisfactory operation of the associated solenoid valves. The staff in NUR addresses testing skid-mounted components and component subassemb . . ,

for the main steam isolation valves). In this guidance, the staff esting has determ of the major component is an acceptable means for verifying the operatio skid-mounted and component subassemblies, provided the licensee do 8

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

t i

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(. document this position in the IST program.ths IST program.

con'tinue to R 3.1.2 Relief Request No. VR 02, Excess Flow Check Valves Relief Requesf:

which requires position indication to be locally verifi 2 years; and 14.3.2.1, which requires check onths.

va ,

Prqposed Alternate Testing:

reactor refueling outage in accordance with DAEC Technic During these tests, downstream tubing will be vented and ...

drained and tubing. Following testing, each valve pass that equalizes pressure and allows the valve to reset (open).

is opened valve b

Licensee's Basis & Relief: The licensee"Eaercising states: of these valves during normal plant operation is impractical since it requires isolating instrumentation excess 6.>w check valves. Much of this instrumentation is related to safety fun isolation is thereby undesirable due to the potential for creating r p.

a plant tr Normally, testing of these valves is performed during te shutdown n the evolut cooldown is halted and an elevated reactor pressure is available , if this to wereclose the va impa:t on outage time and plant availability, dons eat each cold it should be noted that these valves see little or no flow and function e exercise testing. Also, the significant intemal components arengfabricated -

the fro resistant materials that are not expected to degrade during the plant lifetime reasons, general seat degradation is highly unlikely.

The testing required per the DAEC Technical Specifications is inclu testing and position indication verification; thus it is not practical to perform th at different frequencies (2 years vs. refueling outage)." s tests Evaluation:

containment. These valves are normally open and clo i The only test method available to stroke them closed is to isolate .

n the ins ,

the line downstream of the valve. The valves are then stroked open by open enoid.

operated bypass vafve, which equalizes the pressure. The licensee has exercise testing of all excess flow check valves to during shutdowns for r on the impracticality of testing at cold shutdowns or quarterly. The licensee has generically that isolating the instrumentation during operation increases the the cooldown to cold shutdowns due to the " negat i

check valve to ensure that the statement that isola -

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transient is accurtta for til tho subject valves. If isolating some not -

of the valves jeopardize continued plent operation, the licensee should revise perform t!

the request to justify the burden of complying with the Code. ust be Specific inf!

provided. For those vanes whose isolation could cause a transient or p!

impractical to perform testing quarterly. ,

cold shutdowns due to the delay in shutting down or starting u! 1 Specification requirements provide an adequate level of quality

. Therefore, it is and

- safety l

recommended that relief for these valves be granted in accordance w .

( Although the licenses has requested relief from the requirements o ...

1 require position indication to be verified and leak rate testing to be p based on the 18 month refueling cycle, relief is not required. , or Testin overy 18 months, will satisfy the Code requirement to test every two years.

1 3.2 Relief Request No. VR 04, CRD Accumulator Rupture Disks Relief Request:

The licensee has requested relief from the requirements of Part 1,11.3.4.2, years, for the CRD accumulator rupture disks, PSE-1848 Proposed Alternate Testing: The licensee has not proposed any attemate.

i Licensee's Basis for Relief: The licensee states: "These rupture discs prote safety function associated with these components." accumulators "Each of the 89 CRD accumulators is provided with a rupture disk to ensu protected from shattering and becoming a personnel hazard. The failure of a relieve since or to rupture it is unlikely that: prematurely is not expected to impact reactor plant l

• more than one disc would fail simultaneously; or l

+ a disc would fail coincidentally with a reactor accident. '

There is no history of failure of these rupture discs throughout the industry ,

i little gain in expending the significant plant resources that would be requi replacement of these discs. In addition, there is the possibility that the distur components may ultimately result in leakage and future maintenance problems."

Evaluation: OM Part 10, 14.4.2 required function in shutting down the reactor, in maintaining in mitigating the consequences of an accident from overpressure Part 1 for non reclosing pressure relief devices. Part ents of to meet 1, 11.3.4.2, requires Class 2 and 3 indicates a requirement for more frequent replacementnon-recio 10

The licensee states that there is no specific reactor safety function associated with these components. At the March 1995 ASME O&M Committee Meeting, it was reported ta the OM-1 Working Group that the BWR Owner's Group has reviewed the function of these rupture di and determined that they are not safety related. As discussed in Section 4.3.1 of NUREG if the rupture disks do not perform a necessary safety or overpressure protection function '

they may be removed from the scope of the IST program.

AddtionaNy, these rupture disks are installed on the nitrogen side of the accumulators. The licensee has not discussed in Section 3 of the IST Program how the ISI class boundaries were developed. The licenses should review the Code classifbatbn of the nitrogen system per the guidance in Regulatory Guide 1.26, " Quality Group Clessifications and Standards for Wa Steam , and RadW4 tive Waste-Containing Components of Nuclear Power Plants," to evaluate if these rupture are within the scope of 10CFR50.55a (Ref.14).

If the licensee has determined that these disks are within the scope of the regulations (i.e., a ASME Code Class) and are necessary for the protection of the nitrogen system from overpressure, then additional information is required to support the request. It appears that the licensee is seeking approval under 10CFR50.55a(a)(3)(ii), which states that alternatives ,

may be authorized when compliance with the requirements of the Code would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The licensee must provide additional information concerning the hardship of com with the Code, before the request could be authorized. As stated by the licensee, there is no industry experience with these rupture disk failures. A review of the INPO NPRDS dat BNL 1984.revealed only one CRD rupture disk failure, which occurred at Browns Ferry Unit 3 in 3.3 Relief Request No. VR-14, HPCI Barometric Condenser Relief Valve Relief Requese The licensee has requested relief from the requirements of Part1,11.3.4.1(d) and 1.3.4.1(a), which requires the limiting as found set pressure for safety / relief valves to be equal to 1.03 times the stamped set pressure, for the HPCI Barometric Condenser Relief Valve, PSV-2223.

Proposed Attemate Testing: The licensee has proposed to establish the upper limit for this valve's set point, as it applies to Paragraph 1.3.4.1, at 17 psig.

Licensee's Basis for Relief: The licensee states: "For this valve the stamped set pressure is 15 peig which requires that the limiting setpoint would be 15 times 1.03 or 15.45 psig.

Meeting this requirement on a consistent basis would not be practical and, as result, this valve would be subjected to repeated unnecessary adjustments and maintenance.

Assigning an upper limit for this valve's set point of 17 psig will not significantly affect the reliability of the HPCI system nor endanger any equipment."

Evaluation:

As discussed in NUREG-1482, Section 4.3.9, the 1994 Addenda of the OfA Code (Ref.15) has provided clarification on testing relief valves. This includes clarifiestion to the requirements for testing additionalvalves. The 1994 Addenda of the OM Code requires when the 11

= -

i as-lound set pressure exceeon the greater of either the i tolerance limit of the Owner specified set pressure acceptance criteria or 2.3% of valve nameplate set pressure, two additional valves shall be tested from the same valve group (i.e., same manufacturer, type, service, application, and service , media). If the as-found set pressure of any of the additional valves l exceeds the criteria noted therein, then all the remaining valves of the same valve group shall be tested. The Owner is required to evaluate the cause and effect of valves that fail to comply ,

with the Owner specified acceptance criteria or other required tests. Based upon this evaluation, the Owner is required to determine the need for testing, in addition to the minimum j tests specified, to address any generic concems which could be applied to valves in the same or other valve groups. The Owner is also responsible for establishing the acceptance criteria, i based upon system and valve design basics or technical specifications, and documenting the acceptance criteria (OM Code, Appendix 1,11 1.3.1(e) and 1 1.3.2(c)).

As discussed in the NUREG, relief is not required to use this clarification. The licensee should ensure that, in addition to establishing, documenting, and using Owner specified acceptance

- criteria, the required actions if a valve fails that acceptance criteria, as discussed above, are also met. Use of this clarification should be documented in the licensee's IST Program.

3.4 Relief Request No. VR 16, Vacuum Breaker Valves Relief Request: The licensee has requested relief from the requirements of Part 1,11.3.4.1(d) and 1.3.4.1(e), which requires the limiting as found set pressure for safety / relief valves to be equal to 1.03 times the stamped set pressure, for the vacuum breaker valves, PSV-4439A through F.

j Proposed Attemate Testing: The licensee has proposed to establish the upper limits for determining the operability of vacuum breakers based on system and component functional requirements, I i

Licensee's Basis for Relief: The licensee states: "For these vacuum breakers with .5 psig setpoints, compliance with this requirement is beyond the capability of test equipment.

Meeting this requirement on a consistent basis would not be practical and, as a result, these valves would be subjected to repeated unnecessary adjustments and maintenance. 1 Assigning upper limits for these valves' set points based on system design and functional requirements will not significantly affect the reliability of the affected systems nor endanger any equipment."

Evaluation: As discussed in NUREG-1482, Section 4.3.9, the 1994 Addenda of the OM Code has provided clarification on testing relief valves. This includes clarification to the requirements for testing additional valves. The 1994 Addenda of the OM Code requires when the as found set pressure exceeds the greater of either the i tolerance limit of the Owner specified set-pressure acceptance criteria or13% of valve nameplate set pressure, two additional valves shall be tested from the same valve group (i.e., same manufacturer, type, service, application, and service , media). If the as found set pressure of any of the additional valves exceed the criteria noted therein, then all the remaining valves of the same valve group shall be tested.

The Owner is required to evaluate the cause and effect of valves that fail to comply with the 12

l l .

j Owner specified acceptance criteria or other required tests. Based upon this evaluation, the

' Owner is required to determine the need for testing, in addition to the minimum tests specified, b address any generic concems which could be applied to valves in the same or other valve

[

j groups. The Owner is also responsible for establishing the acceptance criteria, based upon system and valve design basics or technical specifications, and documenting the acceptance i criteria (OM Code, Appendix 1,11 1.3.1(e) and 1 1.3.2(c)).

j- As discussed in the NUREG, relief is not required to use this clarification. The licensee should h

j ensure that, in addition to estabhshing,' documenting, and using Owner specified acceptance

)

criteria, the required actions if a valve fails that acceptance criteria, as discussed above, are j

1

_ also met. Use of this clarification should be documented in the licensee's IST Program.

d 3.5 Relief Request No. VR-22, MSIVs Relief Request: The licensee has requested relief from the requirements of Part 10,14.2.1.8(d), which requires corrective action in accordance with 14.2.1.9 when the stroke l time of the MSIVs, CV 4412 through 4416 and 4418 through 4421, exhibits more than 150 j

percent change in stroke time when compared to the reference value.

i j Proposed Altemate Testing: The licensee has proposed to establish the acceptance criteria for I these valves based on the DAEC Technical Specifications,3-5 seconds. No reference values will be established, nor will the acceptance criteria of Part 10, Para. 4.2.1.8(d) be applied to the test results.

Lscensee's Basis fbr Relief The teensee states: "The stroke times of these valves are adjusted within an acceptable band of 3-5 seconds by adjusting orifices associated with hydraulic

)

dashpots attached to each operator. Thus, the stroke time performance of each valve operator is '

more a function of the dashpot setting than the material condition of the valve.

The strict acceptable band of 11 second is restrictive enough to ensure that each 'of the valves remains operable within the established limits of the plant safety analyses.

Elimination of the 150 percent limit on deviation will have no significant impact on the reliability of these valves nor on the health and safety of the public."

Evaluation: The licensee has not provided information on the expected reference stroke time for the MSIVs. The Code, OMa-1988, Part 10,13.3, requires establishment of the reference value based on preservice or inservice test results, when the valve is known to be operating acceptably. Based on the licensee's request, however, the reference value would have to be somewhere between 3 and 5 seconds. Paragraph 4.2.1.8(d) would require corrective action when the stroke time exceeded 1.5 to 4.5 or 2.5 to 7.5 seconds, based on the reference value.

The licensee has implied that the valve will be declared inoperable and adjusted when the valve stroke time does not fall within 3-5 seconds. It appears that the licensee's proposal provides an equivalent level of quality and safety to the Code, and it is recommended that the altemative be authorized in accordance with 10CFR50.55a(a)(3)(i).

l 13

3.6 Relief Request No. VR 23, Emergency Service Water Valves Relief Request: The licensee has requested relief for the emergency service water valves, CV-1956A and B, CV 2080, and CV 2081, from the requirements of Part 10,14.2.1.8(d), which specifies the acceptance criteria for air-operated valves with reference stroke times less than or equal to 10 seconds.

Proposed Alternate Testing: The licensee has proposed to exercise these valves every three ,

months. During this testing, valve operation will be observed, and a stroke time " estimated '

based on valve stem movement. Because the stroke time is estimated, the results of this test will be evaluated with respect to the maximum allowable stroke time of Part 10, Para. 4.2.1.4 (a). The acceptance criteria of Part 10, Para. 4.2.1.8.(d) will not be applied to the test results."

1 Licensee's Basis for Relief: The licensee states: "CV 1956A & B are actuated by the starting l logic of the associated emergency service water pump, with no individual control handswitch.

Also, there are no position indicators for these valves. The test sequence requires an operator )

to be stationed at the valves, which are physically separated from the pumps, to measure the stroke time of the valve. The operator starts timing upon announcement of the ESW pump start and stops timing based upon the cessation of valve stem movement. For these reasons, precise stroke time measurements are impractical. CV-2080 and CV-2081 do not have position indication. To measure the stroke times of these valves the operator starts timing upon operation of the handswitch for the valve and stops timing based upon cessation of valve stem movement. Thus precise stroke time measurements are impractical." '

Evaluation: These emergency service water valves are not provided with position indication.

Valve obturator movement is determined by an operator observing the stem movement once the pumps are started (CV-1956A & B) or the handswitch is operated (CV-2080 and 2081).

Precise stroke time measurement is difficult. The Code, however, only requires stroke times to be measured to the nearest second. The licensee has not provided information on the normal range of stroke times for these valves (although they must be operated under 10 seconds based on the request).

The licensee has proposed declaring the valve inoperable only wher, the valve exceeds the limiting stroke time. The licensee has not provided information on this limit. Corrective action in accordance with 14.2.1.9(b) will not be taken when the stroke time exceeds more than 150% of the reference value. Paragraph 4.2.1.9(b) allows, when the valve exceeds the acceptance criteria of 14.2.1.8, the valve to be retested, and, if the second test fails the acceptance criteria of 14.2.1.8, an analysis may be performed to verify that the valve is operating acceptably. The Code requirements do not appear to be excessively burdensome.

Based on the lack of sufficient information to determine the burden or imp ncticality of complying with the Code requirements, relief cannot be recommended. The licensee should comply with the Code requirements or revise the request to include information on the normal and limiting stroke times, including the basis. The proposed alternative must provide a means for detecting and correcting valve degradation before a valve cannot perform its intended safety function.

14

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

4.0 DEFERRED TESTING JUSTlFICATIONS valves quarterly, during operation, as required y of testing by O Of the 38 deferral requests,13 deal with testing deferred to cold shutdowns and o 25 dea refueling outages. Eleven of the justifications dealt with non-Code evaluated. The justifications are listed in Table 4.1 and the remaining t justifications were reviewed to verify their technical basis. Any anomalie ociated with the plant trip, damage to a system or component, ered o

practical. Removing one train for testing, or entering into a limiting s co not sufficient basis alone for not performing required tests, unless s so provided, such as that the testing renders systems inoperable for exte (Reference 17), it is not the intent Generic of IST toLetter 87-09 (Ref.16)).

cause unwarranted plantecessarily shutdowns e.As or disc to un difficulty of the test may be considered. challenge other safety , e sy 15

)

i

Table 4.1-Evaluation of DAEC's Deferral Justifications iTas VALVE No. lopmRCADON UCt=fSJusDRCADON FOR Du u.w TESTNG EvauanON i CSJ- CV-4428, 01 4429, Reactor "These valves cannot be cycled during reactor operation. To do so would cause an unnecessary reactor transient which would affect continued From the information presented in the justification Vessel Head reactor operation." it is not apparent why cycling each of the two Vent Air-operated valves in series would cause a reactor transient.

The licensee should clarify why quarterly testing is Valves impractical and review the safety function of these valves. Per the deferral justification, the safety function is to only provide reactor coolant pressure boundary. The licensee should evaluate whether CSJ- MO-4841A & these valves have an active safety function.

02 B, RBCCW "During plant operation, these valves are open to supply (and return) cooling water to (and from) reactor recirculation pump components inside Based on the potential for damage to the Drywell the drywell These include the pump motor windings, seat water coolers recirculation pumps, exercising these valves during isolation and lube oil coolers. Closing these valves interrupts cooling water tiow and power operation is impractical. .The alternate Valves provides full-stroke exercising during cold could result in damage to pump and motor components.*

shutdowns in accordance with OMa-1988. Part 10, CSJ- MO-4441 and 14.2.1.2(c).

03 4442, "During plant operation at power, reactor feedwater must be supplied through both these valves to maintain reactor coolant inventory and Based on the potential for damage to the nozzles and Feedwater a reactor trip, exercising these valves during

! Outoard CIVs reactor vessel water level. Closing either of these valves will isolate two of the four supplies of feedwater into the reactor vessel. power operation is impractical. The alternate This could result provides full-stroke exercising during cold in thermal shock to the reactor vessel feedwater nozzles and spargers upon I resumption of flow and a plant trip due to the potential for severe reactor shutdowns in accordance with OMa-1988, Part 10, vessel water level and power transients." 14.2.1.2(c).

CSJ. MO-4627 and 04 4628, Reactor " Closing either of these valves during power operation places the Based on the potential for reactor power Recirculation recirculation system in a " single loop" configuration. Although single loop operation is possible, routinely entering into this configuration is transients, exercising these valves during power Pump undesirable and contrary to the prudent and safe operation of the reactor operation is impractical. The alternate provides Discharge plant.

Valves In addition, operation in a single loop configuration requires a severe full-stroke exercising during cold shutdowns in power reduction." accordance with OMa-1988 Part 10,14.2.1.2(c).

16

Table 4.1-Evaluation of DAEC's Deferral Justifications ima VatvE  ;

LICBEEEts JustinCADON FoR DEFERRED TEST 9G EvatuAn0N No. loemFICADON i CSJ- MO-4629 and *During normal plant operation these valves remain open to eliminate i 05 4630 Reactor The licensee states that the testing cannot be undesirable thermal stresses across the valves. (Reference GE SIL No. performed because of consequences if the valve '

Recirculation 104) If during testing, either of these valve were to fail in the closed Pump failed dunng testing. The licensee should not position. prudency would require a plant shutdown to correct the problem Discharge and reopen the valve (s)." base the justification simply on an assumed Bypass Valves failure, unless the failure could cause a loss of a safety system function or the probability and '

risk associated with a test induced failure warrants it. For example, the NRC staff has concluded that quarterly testing of PORVs in PWRs is impractical because PORVs have shown a high probability of causmg a small LOCA by i sticking open. Typical valves, whose failure in a non-conservative position during exercising would cause a loss of system function, include  :

the RHR pump discharge crossover valves for plants whose licenseg bases assumes that all four cold legs are being supplied by water from .

at least one pump (Reference NRC Information Notice 87-01 (Ref.18)). Other valves may fall into this category under certain system I configurations or plant operating modes, e.g.,

• when one train of a redundant ECCS system is moperable, non-redundant valves in the i remaining train should not be cycled because their failure would cause a total loss of system  ;

function. The licensee is referred to NUREG-i 1482, Sections 2.4.5 and 3.1.1 for the staff's guidance on impractical conditions.

CSJ- Reserved 06 t

l 17

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

L L

t 1

Table 4.1-Evaluation of DAEC's Deferral Justifications  !

Im Vmm l t

No. Iss.rA.anDN Lcents's JUBTFCATEN mR DUEnnm Testen >

Evauanow CSJ. MO-1908 07 &1909 RHR "Under normal conditions these valves could experience a differential l Shutdown pressure of 900 paid. Exercising these valves under those conditions could Based on the potential for equipment damagee and result in valve or actuator damage.

Cooling Supply in addition, with one of these valves in valve interlocks, exercising these valves during  ;

Valves the open poellion, limited to a single valve.

pressure isolation protection for the RHR systempower is operation is impractical. The alternate  ;

Note also that these valves are electrically provides full-stroke exercising during cold interlocked psig." to prevent opening with reactor pressure greater than 135 shutdowns in accordance with OMa-1988, Part to, 1' 14.2.1.2(c).

CSJ- V-19-149 and  !

08 V-2 0-082, "These are simple ch&d valves with no means of operation except other I RHR4.PCI than system flow. With the reactor at operating pressures the Based RHR pumps on the discharge head of the RHR pumps, insection Check cannot develop sufhcient discharge pressure to open these valves." exercising these valves open during power i Valves operation is impractical The alternate provides  ;

full-stroke exercising during cold shutdowns in CSJ- V-22-021 and i 09 accordance with OMa-1988, Part 10.14.3.2.2(c).

22,HPCI " Exercising these valves to their closed position requires closing V-22 Condensate 022 and performance of a seat leakage test. As discussed in NUREG-1482, Section 3.1.2, If HPCI were to initiate while Drain Valves this testing was in process, condensate could backup into the turbine entering a LCO is not sufficient justification alone

• exhaust piping and casing resulting in potential damage to critical for deterring testing. The licensee should provide i

components or adverse affects with respect to system performance." additional justification or perform testing CSJ- V-22-063 and quarterly.

10 64.HPCI "If HPCI should initiate during the period when these valves are isolated for Exhaust Line testing, be adverselytheyimpacted." would not function and the operation of the HPCI system could in NUREG-1482, Section 3.1.2, As discussed l

' Vacuum entering a LCO is not sufficient justification alone j

Breakers for deferring testing. The licensee should provide 1 additional justification or perform testing CSJ. V-22-016, quarterly.

11 HPCI Turtnne "During plant operation this valve must be capable of opening to allow Exhaust Check turbine exhaust steam to exit into the suppression chamber. Testing of this As discussed in NUREG-1482, Section 3.1.2, Valve valve to the closed position requires downstream valves to be closed enteringwhen a LCO is not sufficient justification alone air used to verify valve closure (sic). for deterring testing. The licensee should provide r While the tests are in progress, the  ;

espective pump is inoperable since there is no path for exhaust steam." additional justification or perform testing CSJ- V-24 046 and " quarterly.

12 47 RCIC t If RCIC should initiate during the period when these valves are isolated for Exhaust Line besting, e adverselythey would not function and the operation of the RCIC Not impacted." systemCode Class.

could Vacuum i Breakers 18

I Table 4.1-Evaluation of DAEC's Deferral Justifications ITas VRVE LEBdSEE's JUST1FEATEM FOR DEFERED TESTN2 Ev4UATION No. loemncATxw CSJ- V-2 5-036, " Opening this valve with RCIC system flow is not practical during plant Based on plant transients or personnel hazards,  ;

13 RCIC Purry operation due to the potential for severe reactor vessel water level and exercising these valves during power operation is '

Discharge temperature transients as well as possible contamination of the reactor impractical. The alternate provides full-stroke Check Valve foodwater. For these reasons the valve is provided with a local mechanical exercising during cold shutdowns in accordance exercise capability; however, the location of the valve in the steam tunnel with OMa=1984, Part to,14.3.2.2(c).

makes it inaccessible during power operation."

CSJ- V-25(sic)- "During plant operation this valve must be capable of opening to allow 14 Not Code Class. The valve is identified on the PalD 023 RCIC turbine exhaust steam to exit into the suppression chamber. Testing of this and in the IST Program as V-24-023.

Turbine valve to the closed position requires downstream valves to be closed when Exhaust Check air pressure is used to verify valve closure. While the tests are in Valve. progress, the respective pump is inoperable since there is no path for exhaust steam."

RRJ. V-43-503, TIP "This is a simple check valve with no disk position indication and the only Not code class. i 01 System Purge practical method of verifying closure is by performing a leak test. The Check Valve method of leak testing for this valve requires separation of the containment penetration flange which constitutes a breach of primary containment integrity and thus not practical during plant operation. Furthermore, the  ;

testing requires approximately 20 manhours to complete. Taking into  :

account the typical general area radiation dose rate in the vicinity of these I valves at cold shutdown of 200 Mr/ hour, the estimated total exposure per test is approximately 4 man-Rem. Based on the foregoing discussion, the costs and burden on the plant staff associated with cold shutdown testing of i this valve is not justified by the little potential gain in plant safety afforded i by this test."

l l

l 19 l

Table 4.1-Evaluation of DAEC's Deferral Justifications les VavE No. IDEhmuADON LICO 3*S JUSMFICAHON FOR DEFERRED TESTm EVRUADON RRJ- CV-4412, 13 02 15, 16, 18, "These valves have two fail-safe mc&,s. One is loss of electric power.

This mode is tested on-line (quarterly) by normal closure of each valve As discussed in NUREG-1482, Section 3.1.1.3, it is 19, 20, 21; acceptable to extend the test interval for those MSIVs where the closure signal de-energizes the solenoid valves which control the  ;

actuator pilot valves. valves which cannot be tested unless the ,

containment is de-inerted, as is the case with fail-i The second mode is loss of nitrogen gas pressure to the actuator.In this safe testing the MSIVs at Duane Arnold. Therefore, case the nitrogen pressure on the underside of the actuator piston, which the alternate provides fail-safe exercising during  !

keeps the valve open, is exhausted to atmosphere upon the failure of the refueling outages in accordance with OMa-1988, 3 Part 10,14.2.1.2(e).

supply system. The closure time is 3 to 5 seconds, after the nitrogen pressure has decayed to the point at which the air-valves reposition (internal spring force overcomes the pneumatic force). Exercising the MSIV's by closing utilizing spring force only, complies with the .

I recommendations of General Electric Service information Letter 477.

During refueling shutdowns, the MSIV's are also cycled utilizing the j accumulators only (non-safety grade nitrogen makeup is isolated) in accordance with NRC Information Notico 85-84, inadequate Inservice  ;

Testing of Main Steam isolation Valves. Both of these tests requires access i to the drywell and a considerable expenditure of plant staff resources.  ;

This, periods." the scope of these tests precludes testing during cold shutdown RRJ- Reserved 03 t

e i

20 l

. _-_.___m____ . . _ _ _ _ _ _ . _ _ . . - . _ _ _ _ . . . . _ - . . . . - . _ . - - - . . . - . - - . - _ . _ -._m-.... .

i Table 4.1-Evaluation of DAEC's Deferral Justifications-  !

l Ima VALVE Nel Uc=='s JusnncAn0N mR Dutmu TESTen loemRCAn0N EvAtunn0N RRJ- PSV (SV)-

04 "Due to the obvious potential for plant transients these valves can only be .

4400, 1, 2, 5, As discussed in NUREG-1482, Section 4.3.4, the 6, 7; Reactor tested at very low reactor power levels with primary system pressure greater than 50 psig. The test sequence requires: staff recommends reducing the number of i

Relief Valves challenges to the ADS valves by deferring testing to

a. Openmg at least one turbine bypass valve discharging main steam in to [

and Aa===ted the main condenser; refueling outages, because failure in the open  :

Solenoid position is equivalent to a small break LOCA. I

b. Actuating the relief valve while observing the corresponding closure of Valves Therefore, the altomate provides exercising during  ;

the turbme bypass valve (pressure control on the turbine bypass valve is fairly quickly to respond,1-1/2 seconds), and the response of pressure refueling outages in accordance with OMa-1988, i switches and thermocouples downstream of the relief valve.

Part 10,14.2.1.2(e). .?

c. Closmg the relief valve while obserwhg the corresponding opening of the ,

turbine bypass valve and the resNnse of pressure switches and  !

thermocouples downstroom of f.no relief valves.

I i

Each relief valve actuation transmits hydrodynamic loading to the torus. (

i The Duane Arnold Mark i Containment Plant Unique Analysis Report (PUAR) fatigue evaluation is based on 740 relief valve actuations with norme i operating conditions (i.e., 740 actuations for testing purposes). Quarterly testing of each of these valves would result in 960 test actuations over  ;

piant life, which could exceed the approved design basis. '

3 Finally, the failure of any relief valve to close would cause an uncontrolled rapid de-pressurization of the primary system and plant shutdown. jr Testing during cold shutdowns contradicts the pokcy of reducing the number  :

of challenges to safety / relief valves as recommended by NUREG-0737 and 7 the BWR Owners Group Evaluation of NUREG-0737 Item II.K.3.16. Reduction  !

of Challenges and Failures of Relief Valves.*  ;

}

i I

i i

i  :

21

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Table 4.1-Evaluation of DAEC's Deferral Justifications i

tTas VnvE LESSEE'S JUsTFCATION FOR DEFBWIED TEBTm No. lopmRCADON Evauan0N RRJ- V-19-149 and "These valves cannot be opened with system flow during power operation 15 V-20 082, it is impractical to exercise these valves quarterly i because the RHR pumps cannot develop sufficient head to overcome due to the insufficient discharge head of the RHR '

INRLPCI recirculation system pressure. They also cannot be manually stroked pumps. It is also impractical to full-stroke Injection Check during operation due to their location in the drywell.

exercise these valves during cold shutdown because Valves  :

access to the inerted containment is required. The in-situ testing has determined that these check valves fully open at licensee has proposed to part-stroke exercise only i approximately 10,000 gpm. To ensure compliance with Part 10, Paragraph one valve each cold shutdown based on the burden of  !

4.3.2.4, positive verification of the valve operation is required. To realigning the RHR system to allow testing of the achieve this verification, a mechanical indicator is attached to the rotating other valve.

Although it may be impractical to disk pin (shaft). This testing cannot be conducted at cold shutdown because exercise both valves every cold shutdown, there the contamment is inerted with nitrogen and thus inaccessible. In order to may be shutdown periods of sufficient length to '

gain personnel assess to the drywell, the nitrogen must be de-inerted allow realignment of the system. If the licensee can (normally a 16-24 hour operation) and subsequently re-inerted before the only exercise one valve at a cold shutdown period, plant is restarted (another 16-24 hour operation). Inerting and de-inerting they should ensure that the other valve is exercised the drywell solely for the purpose of valve testing is excessively at the next cold shutdown. Therefore, the alternate burdensome. Additionally, a full stroke test of these valves cannot be provides full-stroke ex6rcising during refueling performed with flow at cold shutdown because it would be necessary to outages and partial-stroke exercising during cold test two channels / loops of a safety system (RHR) at the same time. shutdowns in accordance with OMa 1988 Part to, Current guidance only allows the operation of one train of a safety system 14.3.2.2(d).

for surveillance purposes.

I One of these valves is partially stroked during cold shutdown during  !

operation of the RHR system in the shutdown coolmg mode. This is only a i partial stroke test since the normal flowrate in this mode is only 4000 gpm versus the required accident flowrate of 14,400 gpm. Exercising (partial) both valves requires shftmg the cold shutdown RHR system lineup. While shifting system operation to the idle loop is possible, it is a time consuming '

operation involvmg more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of preparation and lineup work by '

operations personnel. This would result in an unreasonable burden on the plant staff that is not commensurate with any gain in plant safety provided by such testing."

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Table 4.1-Evoluation of DAEC's Deferral Justifications ITEM VRVE IJCBISEE's JusnncAn0N mR DEFERRED TEEmG Evaunn0N No. loemRCAn0N RRJ- Reserved 25 RRJ- V-22-017 "This is a lift stop check valve with no positive means of determining disk The test setup and system limitations makes testing 26 HPCI Turtune position. Determining closure by performing a leak test is not practical during operation or cold shutdowns impractical.

, Steam Exhaust since there is no means of isolating the forus from the downstream piping Stop-Check The alternate provides full-stroke exercising during l and reverse flow testing would merely lift the valve and relieve pressure refueling outage in accordance with OMa-1988, '

valve to the torus. Non-obtrusive acoustical methods would probably result in Part 10,14.3.2.2(e). ,

inconclusive results. Thus, the only available method of verifying disk j position is radiography. Radiography of these valves requires extensive I preparations includmg system draining and scaffold erection. During cold ahutdown conditions, performance of this testing is impractical dus M the }

extenssve resources and time needed to complete testing."

j RRJ- V-24-023, "This is a lift stop check valve with no positive means of riotermining ' disk I N7t code class.

27 RCIC Turtune position. Determining closure by performing a leak test is not practical  ;

Steam Exhaust since there is no means of isolating the torus from the downstream piping i Check Valve and reverse flow testing would merely lift the valve and relieve pressure to the torus. Non-obtrusive acoustical methods would probably result in inconclusive results. Thus, the only available method of verifying disk '

position is radiography. Radiography of these valves requires extensive preparations including system draining and scaffold erection. During cold shutdown conditions, performance of this testing is impractical due to the ,

extensive resources and time needed to complete testing." '

RRJ- V-13-037 and "These are simple check valves with no positive means of determining disk As discussed in NUREG-1482, Section 4.1.4, due to 28 52. Emergency position. Determining closure by performing a backloakage test requires v

the extensive setup and performance limitations, Service depressurization and draining of the associated well water train as well as ,

leak testing during operation or cold shutdowns is  :

Water /Well realignment of the ESW train. The extensive preparations and operational impractical. The alternate provides full-stroke  !

l Water isolation impact on the plant precludes performing the backloakage test during exercising during refueling outage in accordance "

l Check Valves operation or cold shutdown periods." '

1 with OMe 1g88, Part 10,14.3.2.2(e).

I

. I l

l l

28 1

__ ._-__..__._--..-..-.m. . _ _ - - . . _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - " - "~ ~ ~ "~ ~ '- ~~ ^ ' ~ ~

Table 4.1-Evaluation of DAEC's Deferral Justifications trEM VavE LCENSE'S JwnrcATm FOR DEFERRm TESTre EVMUADON NO. k)ENDRCATM RRJ. CV-1859A & " Fail safe testing of these valves is typically performed with the testing of The licensee has not provided adequate justification 29 B,1867A & B, the associated reactor protection system. During operation this is not for not exercising these valves at cold shutdown.

CRD Scram practical since such testing could result in a scram and plant trip. Testing The licensee should discuss if fail-safe testing can Discharge of the reactor protective system is normally beyond the scope of work be performed without testing the RPS and why the Header Vent normally performed during short duration outages." normal exercising of these valves quarterly does '

and Drain not fulfill the requirements of 14.2.1.6. Other Valves BWRs, such as Oyster Creek perform this testing at cold shutdowns.

29

There is no flow instrumentation installed to measure flow through each of these valves.

The installed flow instrumentation on these lines is upstream of piping that cross-connects the two feedwater trains. The licensee has referred to calculation M93 which will be used to verify that the valves will full-stroke open. Specific details of the test method have not been provided in the request. Therefore, no determination of the acceptability of the test method has been made. As discussed in Generic Letter 89-04, Position 1 and in NUREG 1482, Appendix A, Group Question 2 Current Considerations knowledge of total flow through multiple paths does not provide verificatie of flowrates through the individual valves and is not a valid full-stroke exercise. The licensee is referred to the January 24,1992 Safety Evaluation on the Beaver Valley inservice Testing program, referenced in Appendix A of NUREG 1482. The licensee should review these documents and ensure that the test method is both sufficient to indicate check valves are full-stroke exercised, and repeatable.

5.7 it is not apparent from the information detailed in the justification why cycling each of the two reactor vessel head vent valves in series would cause a reactor transie licensee should clarify why quarterly testing is impractical and review the safety function of these valves. Per the deferral justification (CSJ-01), the safety function is to only provide reactor coolant pressure boundary. The licensee should evaluate whether these valves have an active safety function.

5.8 The licensee states that the testing of the recirculation pump discharge bypass valves cannot be performed because of consequences if the valve failed during testing (CSJ-05). The licensee should not base the justification simply on an assumed failure, unless the failure could cause a loss of a safety system function or the probability and risk associated with a test induced failure warrants it. For example, the NRC staff has concluded that quarterly testing of PORVs in PWRs is impractical because PORVs have shown a high probability of causing a small LOCA by sticking open. Typical valves, whose failure in a non-conservative position during exercising would cause a loss of system function, include the RHR pump discharge crossover valves for plants whose licensing bases assumes that all four cold legs are being supplied by water from at least one pump (Reference NRC Information Notice 87-01). Other valves may fall into this category under certain system configurations or plant operating modes, e.g., when one train of a redundant ECCS system is inoperable, non-redundant valves in the remaining train should not be cycled because their failure would cause a total loss of system function. The licensee is referred to NUREG-1482, Sections 2.4.5 and 3.1.1 for the staff's guidance on impractical conditions.

5.9 As discussed in NUREG 1482, Section 3.1.2, entering a LCO is not sufficient justification alone for deferring testing. The licensee should provide additional justification in CSJ-09,10 and 11, or perform testing of the subject valves quarterly.

5.10 it is impractical to exercise the LPCI injection check valves quarterly due to the insufficient discharge head of the RHR pumps. It is also impractical to full stroke exercise these valves during cold shutdown because access to the inerted containment is required. The licensee has proposed to part stroke exercise only one valve each cold shutdown based on the burden of realigning the RHR system to allow testing of the other 31

8.0 IST PROGRAM RECOMMENDED ACTION ITEMS Incon~sistencies, omissions, and required licensee actions identified during the review of the licensee's third interval inservice Testing Program are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report.

5.1 Relief is recommended for he licensee to calculate the river water, core spray, and RHR pumps' differential pressure at the reference flow rate, and for the licensee to utilize a reference curve for the HPCI pump, provided the licensee reviews the procedures and documents the impracticality of measuring the differential pressure after achieving the reference flowrate 12%, and proceduralizes the AP calculation. (TER Sections 2.1 and 2.2.2) 1 5.2 The licensee must provide additional information justifying the burden of running the HPCI pump for two minutes at each of the points on the reference curve (i.e., the suppression pool increase experienced during the test period and the limiting suppression pool temperature). (TER Section 2.2.2) 5.3 The licensee must verify that for all excess flow check valves tested in accordance with Relief Request VR 02, isolating the associated instrumentation has the potential for causing a plant trip or transient. If isolating the valves will not jeopardize continued plant operation, the licensee should perform testing quarterly or revise the relief request. (TER Section 3.1.2) 5.4 The licensee should review the code classification and safety function of the CRD rupture disks. If the disks are within See scope of the regulations and Code, the licensee must l

provide additional information concerning the hardship of replacing these disks every j five years, before relief can be recommended. Additionally, the licensee should provide  !

an alternate (neans or schedues for monitoring degradation commensurate with their safety significance. (TER Section 3.2) 5.5 The licensee has proposed an exception to the requirements of 14.2.1.8(d) for four emergency service water valves based on the variance of stroke times. The licensee has not provided the normal range of stroke times nor the maximum limiting stroke time that will be applied. Additionalinformation on the burden of complying with the Code and assurance that the proposed alternate will provide an adequate means for detecting valve degradation prior to failure is necessary before relief can be recommended. The licensee should revise and resubmit the request. (TER Section 3.6) 5.6 The licensee has proposed to exercise the HPCI and RCIC to feedwater valves (V 14 001 i and 3) with feedwater flow quarterly, when practical (i.e., when operating above 90 percent power and pressure instruments are available). Based on the request (VR-03),

it is not apparent how pressure instrumentation will be used to verify the full-stroke of the valves, and why the unavailability of pressure instruments and power levels less '

than 90% make testing impractical. The licensee should provide additional information why testing quarterly is impractical.

30

l, , l 4

4 valve.

j .

Although it may be impractical to exercise both valves every cold shutdown, there may be shutdown periods of sufficient length to allow realignment of the system. i If the licensee can only exercise one valve at a cold shutdown period, they should ensure that the other vahre is exercised at the next cold shutdown. (RRJ 15) 5.11 It is impractical to exercise the core spray injection valves quarterly due to the insufficient discharge head of the core spray pumps, it is also impractical to full-stroke exercise these valves during cold shutdown periods because of operational

constraints with the RPV water level. The licensee has not specifically described the impracticality of partial stroke exercising the valves at cold shutdown, but has stated

" that preparations to inject water via the core spray pumps are excessive and burdensome. The core spray pumps are tested quarterly. It is not apparent why a l partial stroke exercise is so burdensome. The licensee should partial stroke exercise the valves at cold shutdown, or revise the deferral justification accordingly. (RRJ-17)

{

5.12 Full-stroke exercising of the SBLC injection check valves during operation or cold shutdowns is impractical due to the extensive test set up and system restoration. The licensee should evaluate the practicality of partial stroke exercising these valves at cold shutdowns utilizing test connections. Other BWRs, such as Quad Cities, perform testing in this manner. The licensee should either partial-exercise these valves at cold shutdown or revise the justification. Additionally, the licensee should correct the justification to reflect the correct valve number, i.e., V-26 009. (RRJ 21) 5.13 The licensee has not provided adequate justification for not exercising the CRD scram discharge header vent and drain valves at cold shutdown. The licensee should discuss if fail-safe testing can be performed without testing the RPS and why the normal exercising of these valves quarterly does not fulfill the requirements of 14.2.1.6. Other BWRs, such as Oyster Creek perform this testing at cold shutdowns. (RRJ 29) 5.14 The licensee in Sechon 5.4 of the IST Program states that an extension of +25% may be applied to the test intervals, as allowed by the Technical Specifications. The Technical Specifications do not however. address the test intervals for relief valves, and as discussed in NUREG-1482, Section 3.1.3, the extension should not be applied to valves tested in accordance with OM Part 1.

5.15 The licensee in Section 5.6 of the IST Program states that when quarterly testing is

" undesirable," Part 10 allows deferral to cold shutdowns or refueling periods. Part 10,14.2 and 4.3, allow testing to be deferred only when quarterly testing is impractical. If testing is practical, but undesirable, the licensee is required to submit a relief request. The Econsee is requested to review and IST Program and revise the deferral justifications as necessary based on this clarification.

5.15 Note 2 to Table A states that the pump suction pressure will be derived indirectly from level. As discussed in Section 5.5.3 of NUREG 1482, the calculation must be included in the implementing procedure and the accuracy must comply with the Code requirements, i.e.,12%. The licensee should verify that the Code requirements are met, or submit a 32 s

)

1 i .

relief request, Additionally, Note 4 discusses test frequency, however, this note is not

j. applied to any of the pumps in the table.

5.16 Relief Requests VR 07 and 8 discuss rupture disks and state that there is no history of failure of these disks. Although these requests concern disks that are not ASME Code classified and staff approval is not required, the licensee is referred to NRC Information i Notice 93-067 (Ref.19), NUREG/CR 6014 (Ref. 20), and AEOD Report E402 (Ref.

i

21) for documentation of failures of these components. '

l L

5.17 The review performed for this TER did not include verification that all pumps and valves within the scope of 10 CFR 50.55a and Section XI are contained in the IST Program, and did not ensure that all applicable testing requirements have been identified. The IST  ;

Program's scope was, however, reviewed for selected systems. The pumps and valves in j  !

the residual heat removal and service water-pumphouse systems were reviewed against l

l OMa-1988, Part 6 and 10 requirements. The review results showed compliance with i the Code, except for the following items. The licensee should review these items and make changes to the IST Program, where appropriate. The licensee should also consider j generically the types of omissions noted here and where necessary, review and revise j the IST Program for other systems, as well.

j  !

• Valves AV-4926E and F, and 4929C and D, in the service water system are only tested closed. These valves generally have a function to open to allow the air to be vented, j

thereby preventing air binding. The licensee should review the function for these valves, and revise the IST Program as necessary.

+

• Air-operated strainer bypass valves CV-4939A & B and 4940A & B in the service j water system fail closed. These valves are not, however, included in the IST Program.  ;

The licer.see should review the function for these valves, and revise the IST Program as  !

l necessary.

i

! *The licensee has not included the RHR/ Core Spray fill pump in the IST Program, nor j ,

has specified exercising the associated check valves open (they are only exercised closed). The licensee should review the function of this pump that maintains these

{ systems full of water to prevent a water hammer, and revise the IST Program as l necessary.

l

• Appendix C indicates that valve MO 2010 will be exercised at cold shutdown.

'mwever, there is no justification referenced or contained in Appendix E. This valve

j. wid be tested quarterly or a justification must be prepared.

l

• Appendix C indicates that valve V-20-008 will be disassembled and inspected at

refueling outages. However, no relief request or deferral justification is noted. It j

appears that VR-05 also applies to this valve. Appendix C and D should be revised as j appropriate.

1

,

• Valve V 20-010 is only exercised closed per the IST Program. This valve must open

. to allow service water to be injected into the reactor vessel, via the RHR system. The i

1~

33 l

l

. safety function in the open direction, and .

a revi 5.18 oil, and standby liquid control pumps are ,

. The locate licensee were developed. has not discussed in Section 3 of the IST Program how th with the commitments The licenseecontainedshould in ensure that the plant's the code safety classificat analysis report.

I referred scope to Program.

of the IST NUREG-1482, Sections 2.2 and 2.3 for the staff's guida l

i i

I 34

8.0 REFERENCES

1.

Letter NG 95-2071, " Third Ten Year Inservice Testing (IST) Progra

! Franz, IES, to W.T. Russell, USNRC, January 30,1995. , ..

2.  !

ASME Boiler and Pressure Vessel Code,Section XI, " Rules for Ins 1989 Edition. ,

1 3.

Nuclear Power Plant Pressure Relief Devices."ASME/ AN 4.

ASME/ ANSI OMa-1988, Part 6 " Inservice Testing of Pumps in Ligh Power Plants."

5.

ASME/

Power ANSI Plants." OMa 1988, Part 10, " Inservice Testing of Valves in Lig 6.

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

7.

Valves," Rev. 2, July 1992. Standard Review Plan, NUREG-0800 I

8.

Programs," April 3,1989.NRC Generic Letter 89-04," Guidance on 9.

Minutes of the Public Meetings on Generic Letter 89-04,25,1989. October 10.

Supplement 26, 1991. to the Minutes of the Public Meetings on Generic Letter ,

11.

NRC Generic Letter 89-04," Guidance on Developing Acceptable In Programs," Supplement 1, which includes NUREG-1482, " Guidelines

• f Testing at Nuclear Power Plants," P. Campbell, April 1995.

12.

Center, TAC No. M91182, March 21,1995. Safety Evaluation

13. '

NUREG/CP-0111, "Proceedngs of the NRC/ASME Symposium on I Pumps and Valves," Washington, D.C., August 1989. 1 I

14.

Regulatory Guide 1.26, " Quality Group Classifications and Standards for W Steam Revision 3, , and Radioactive-Waste-Containing February 1976. Components of Nuclear Powe 15.

American Society of Mechanical Engineers (ASME), Code for Operation of 1994 the Nuclear Addenda.Power Plants, New York,1990 Edition including addenda 35

o 16.

1 I

Specifications (STS) on the Applicability Surveillance Requirements," May 4,1987. on and of 17.

Manual Sections on Resolution ofandDegraded Operability," November 7,1991.

nspection on a

18.

in PWRs," January 6,1987.NRC Information Notice of ECCS 87-01, "RH I 1

19.

Steamline Rupture Discs injures Plant Personnel."NR n ection 20.

Guide for Hatch Nuclear Power Station," .

c on A. M.

21.

Systems," January 1984.NRC AEOD Report E402, n ection

%ater Ham l

l l

l l

l 36

_.c.