ML20097A828

Technical Evaluation Rept Pump & Valve Inservice Testing Program Point Beach Nuclear Power Plant,Units 1 & 2 Wepc, Per 10CFR50.55a(g)

ML20097A828
Person / Time
Site:	Point Beach
Issue date:	04/06/1992
From:	Dibiasio A, Grove E, Lofaro R BROOKHAVEN NATIONAL LABORATORY
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20097A672	List: ML20097A828
References
CON-FIN-A-3869 TAC-M79386, TAC-M79387, NUDOCS 9206030193
Download: ML20097A828 (84)

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1

. TECHNICAL EVALUATION REPORT

= Pump and Valve Inservice Testing Program Point Beach Nuclear Power Plant, Units 1 and 2 Wisconsin Electric Power Company.

Docket Number: 50 266 and 50-301 TAC Number: 79386 and 79387 A. M. DiBiasio, E. Grove, and R. Lofaro

' Engineering Technology Division Dept.rtment of Nuclear Energy Brookhaven National Laboratory Upton, New York 11973 b

April 6,1992 Prepared for the:

U. S. Nuclear Regulatory Commission

~ Washingtonc DC 20555 --

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FIN 'A-3869, Task Assignment 55 l

TAC.79386 and 79387 L

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9206030193 9E0417 PDR ADOCK-05000266-P PDR 1=

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4 AllSTitACT This report presents the results of Brookhaven National Laboratory's evaluation of the Point Beach Nuclear Plant Pump and Valve Insenice Testing Prograin relief requests.

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3 CONTENTS Page No.

iii ABSTRACT 1

1.0 ~

INTRODUCTION 1

2.0 PUMP IST PROGRAM RELIEF REQUESTS.

2 2.1 Generic Pump Relief Requests.

2 7

2.1.1 All Pumps in the IST Program, Relief Request No. PRR 1 2.1.2 All Pumps in the IST Program, Relief Request No. PRR.2 2.1.3 All Pumps in t!'.e IST Program, Relief Request No. PRR-7 2.1.4 All Pumps in the IST Program. Relief Request No. PRR-8 2.1.5 All Pumps in the IST Program, Relief Request No. PRR-9 2.1.6 All Pumps in the IST Program, Relief Request No. PRR.10 I

2.1.7 All Pumps in the IST Program, Relief Request No. PRR.16 2.2 Safety injection and Residual Heat Removal System 10 2.2.1:. Safety injection Pumps, Relief Request No. PRR 3 2.2.2 Safety injection Pumps and Residual IIcat Femoval Pumps, Relief Request No. PRR-17 2.2.3 - Residual Heat Removal Pumps. Relief Request No. PRR 4 15 2.3

- Auxiliary feedwater System......

2.3.1 Auxiliary Feedwater Pumps. Relief Request No. PRR-5 2.32 Auxillary Feedwater Pamps, Relief Request No. PRR-IS 2.4 Containment Spray System...

18 2.4.1 Containment Spray Pumps, Relief Request No. PRR-6 2.5 '

Chemical and Volume Control System.....

20 2.5.1

Boric Acid Transfer Pumps, Relief Request No. PRR-11 7

'2.5.2

. Boric Acid Transfer Pumps, Relief Request No.: PRR-12 2.5.3. CVCS Charging Pumps, Relief Request No. PRR-14

.. 24-

2.6

- Service Water-System.........

2.6.1

. Service Water Pumps, Relief Request No. PRR 13 2.7

. Chf1 fed Water System............

25 2.7.1_-

Cable Spicading Room Chilled Water Pumps and Contro!

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Room Chilled Water Pumps. Relief Request No. PRR-1:i 3.0L

' VAVLE IST PROGRAM RELIEF REQUESTS...

. 25 3.1

' Auxiliary Feedwater System 26 3.1.1 L Auxiliary Feedwater Pump Minimum Flow Valves.

Relief Request No. VRR-a V

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CONTENTS (Cont'd)

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3.2 Auxiliary Steam, Heating Steam, Chilled and Hot Water System 27 32.1 Chilled Water Pump's Discharge Check Vahes. Relief Request No. VRR-31

. 2S 3.3 Chemleal and Volume System 3.3.1 Charging Pump Discharge to Reactor Coolant Pump Seal Check Valves, Relief Request No. VRR-12 i~

3.3.2 Charging Line Containment Isolation Valve, Relicf Request No.- VRR-13 3.3.3 Charging Pump Discharge to Reactor Coolant Pump Manual Throttle Valves, Relief Requer No. VRR-19 3.3.4 Boric Acid Transfer Pump Discharge to Charging Pump Suction Check 'alves Relief Request No. VRR 24 3.3.5 Boric Acid Transfer Pumps Discharge Check Valves,

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Relief Request No. VRR-26 4

34 3.4 Component Cooling Water System.

3.4.1 - Component Cooling Water to RCP Check Valves.

Relief Request No. VRR-10 3.4.2 Component Cooling to Excess Letdown Hea' Exchangers Check Valves, Relief Request No. VRR 30 3.5 Containment Spray System.

35 3.5.1 Refueling Water Storage Tank to Containment Spray Pumps Suction Check Valves, Relief Request No. VRR-8 3.5.2 Ctmtainment Spray Nozzle's Supply Check Valves, Relief Request No. VRR-9 i

3.6 Emergency Diesel Generator Air Start System 3S 3.6.1 Emergency Diesel Generator Air Starting Motors' Starting Valves, Relief Request No. VRR-17 3.6.2 Emergency Diesel Generator Air Start Valves, Relief Request No. VRR-25 3.7 Emergency Dictel Generator Fuel Oil System.

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-3.7.1 Emergency Diesel Fuel Oil Transfer Pumps' Discharge Valves. Relief Request No. VRR-33

-3.8 Heating and Ventihtion System..

41-3.8.1 - Containment Atmospheric Monitorihng System Containment Isolation Valves.

Relief Request No. VRR.16 42

.3.9

-Instrument Air System 3.9.1 Instrument Air Check Valves to Purge Valve Boot Seals, g

Relief Request No. VRR-14 3.9.2 PORV instrument Air Supply Check Valve Relief Request No. VRR-32 g

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CONTENTS (Coat'd)

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3.10 hiain Feedwater System

. 44 3.10.1 hiain Feedwater Check Valves to Steam Generators.

Relief Request No. VRR-21 3.11

. hiain and Reheat Steam System.

46 3.11.1 Rapid-Acting Valves, Relief Request No. VRR 1 3.11.2 Service Water to Auxi!Lry Feedwater Pumps Solenoid Operated Valves, Relief Request No. VRR-20 i

3.12 Post-Accident Containment Vent /htonitoring System.,. _.

.4S 3.'2.1 Post-Accident Containment Vent Containment isolation Valves, Relief Request No. VRR-34

. 49 3.13 Reactor Coolant System.

3.13.1 Pressurizer Relief Tank Nitrogen Supply Check Valve, Relief Request No. VRR-11 3.13.2 Pressurizer Relief Tank Primary hiakeup Supply Check Valves.

Relief Request No. VRR-18 3,14 Satety injection and Residual Heat Removal System 51 3.14.1 Safety Injection Pressure Isolation Check Valves, Relief Request No. VRR-2 3.14.2 Safety Injection and RHR Pressure Isolation Valves, Relief Request No. VRR-3 3.14.3 Safety Injection and Safety injection Accumulator Check Valves, Relief Request No. VRR-4 3.14.4 RWST to RHR Pump Suction Check Valves Relief Request No. VRR-6 '

3.14.5 Safety Injection Pump's Discharge Check Valves, Relief Request No. VRR-7 3.14.6 Safety injection and RHR Pressure Isolation Valves.

Relief Request No. VRR-22 3.14.7 Safety injection Pumps' hifnimurn Flow Line Check Valves, Relief Request No. VRR 3.15 Service Water System..

. 61 3.15.1 Service Water to AFW Pump Check Valves, Relief Request No. VRR-15 62 3.16 Containment Isolation Valves...........

3.16.1 Containment isolation Valves.

Relief Request No; VRR-23 3.16.2 Containment Isolation Valves NPS 6 and Greater, Relief Request No. VRR-29 3.17:

Generic Relief Requests..

, 64 3.17.1 Valves Tested During Ccid Shutdowns.

Relief Request No. VRR 5 vii j-

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CONTENTS (Coat'd)

Page No.

4.0

. Cold Shutdown Justifications...............

- 5.0 IST Program Anonialics and Action Items.....

. 66 74 6.0 References f

APPENDIX A 77

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Technical Evaluation Report Pump and Valve Insenice Testing Program Point Beach Nuclear Plant

1.0 INTRODUCTION

Contained herein is a technical evaluation of the ASME Section XI pump and valve insenice testing (IST) program relief _ requests submitted by Wisconsin Electric Power Company for its Point Beach Nuclear Plant, Units 1 and 2. The Point Beach Units are Westinghouse Pressurized Water Reactors (PWRs) that began commercial operation in 1970 and 1972.

Wisconsin Electric submitted revision 1 of "The Pump and Valve Inservice Testing.

. Program, Point Beach Nuclear Plant" by a letter dated June 10, 1991. This program addresses the third inten>al, which began December 31,1990, and complies with the !?86 edition'of the ASME Section XI Code. This program supersedes Rev. O of the program

. submitted December 31,1990. Any IST program revisions other than those noted above are not addressed in this Technical Evaluation Report (TER).

2 The Code of Federal Regulations,10CFR50.55a(g) requires that insenice testing of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with 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 10CFR50.55a(a)(3)(i), (a)(3)(ii), or (g)(6)(i).

Wisconsin Electric has requested relief from certain ASME Section XI testing requirements in revision 1 of their IST program. A number of these relief requests are outside of the scope' 'of Generic _ Letter 89-04, Attachment 1, and an identified as

" Approved via GL89-04." Relief requests submitted after April 3,1989 require specific NRC staff approval and may not be implemented until receipt of such approval. The relief

- requests are subject to' review by the staff at the ten year update for consistency with current NRC regulatory positions. These requests have not been " grandfathered" (i.e;,

approved by the Generic Letter) and have been evaluated herein to determine if the criteria in.10CFR50.55a for granting relief have been met. This review was performed utilizing the Standard Review Plan, Section 3.9.6; Generic Letter No. 89-04," Guidance on Developing Acceptable Inservice Testing Programs;" and the minutes of the Public Meeting on Generic Letter 89-04, dated October 25,_1989. The IST Program requirements apply onlylto component-testing (i.e., pumps and valves) and are not intended to provide a basis.

to change the licensee's current Technical Specifications for syctem test requirements.

Section 2'of.this report presents the eighteen Point Beach Nuclear Plant relief requests and. rookhaven National Laboratory's (BNL) evaluations and conclusions B

- regarding these requests for the pump testing program. Similar information is presented I

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in Section.3 for the thirty-four relief requests for the valve testing program. A review of thirty the valve cold shutdown justifications was performed and details of this review are contained in Section 4.

Other inconsistencies and omissions in the licensee's IST program noted during the course of the cold shutdown justification reviews and relief request evaluations are presented in Section 5.

Additionally, any actions required of the licensee in the relief request evaluations are presented in Section 5. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

2.0 PUMP IST PROGRM1 RELIEF REQUESTS In accordance with 10CFR50.55a, Wisconsin Electric Power Company nas submitted relief requests for specific pumps at the Point Beach Nuclear Plant that are subject to inservice testing under the requirements of ASME Section XI. These relief requests have j

been reviewed to verify their technical basis and determine their acceptability. Each relief request is summarized below, along with the technical evaluation by the BNL reviewer.

2.1 Generic Pumn Relief Renuests 2.1.1 All Pumps in the IST Program, Relief Request No. PRR-1

- Note: Although the relief request applies to "various" pumps, Appendices A and B of the IST Program reference this relief request for all pumps in the IST program.

2.1.1,1 ReliefRequest: The licensee has requested relief from ASME Section XI, paragraph IWP-4120, which requires that the full scale range of each instrument used to measure pump test parameters shall be three times the reference value or less. The relief request specifically addresses instruments used to measure pump bearing temperature and pump speed.

2.1.1.2 Proposed Allemate Testing: Whenever portable instruments are used for measudng performance parameters, the instruments \\ vill be such that the " reading" accuracy is 5

- percent for temperature and i2 percent for speed.

2.1.1.3 Licensce's Basis for Relief: " Table IWP 4110-1 requires the accuracy of instruments

.used to measure temperature and speed to be equal to or better than 15 percent of full

- scale for temperature, and-2 percent for speed, both based on the full scale reading of the instrument. This means that the accuracy of the measurement can vary as much as 15 percent-andfi6 percent, respectively, assuming the range of the instruments extended to the allowed maximum.

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l These IST pump parameters are often measured with portable test instruments

. where commercially available instruments do not necessarily conform to the Code requirements for range. In these cases, high quality calibrated instruments will be used where the ' reading' accuracy is at least equal to the Code requirement for full-scale accuracy. This will ensure that the measurements are always more accurate than the accuracy as determined by combining the requirements of Table IWP-4110-1 and Paragraph IWP-4120."

2.1.1.4 Evah4ation: ASME Section XI, paragraph IWP 4100 includes Table IWP-4110-1 which specifies an acceptable instrument accuracy of 2 percent of full-scale for speed, and 15 percent of full-scale for temperature, Also, subparagraph IWP-4120 requires that the full scale range of each instrument shall be three times the reference value or less. The intent of these requirements is to ensure that an acceptable " reading" accuracy is obtained -

when test parameters are measured. The combination of these requirements could result in a " reading" accuracy of 16 percent for speed and 115 percent for temperature to be censidered acceptable. Since the licensee's instruments provide a " reading" accuracy which exceeds the Code requirement for full. scale accuracy, as determined by combining the requirements of Table IWP 41101 and paragraph IWP-4120, the proposed alternative instrument accuracies are equivalent to the Code requirements and will provide an acceptable level of quality and safety. Therefore, it is recommended that relief be granted from the full-scale range requirements of Section XI paragraph IWP-4120 in accordance with 10CFR50.55a(a)(3)(i).

2.1.2 Al1' Pumps in the IST Program, Relief Request No. PRR-2 l

- 2.1.2.1 -Relief Request: The licensee has requested relief from meam pump inlet pressure prior to starting the pump, which is a requirement of ASN tection XI, paragraph IWP-3100 Table IWP-3l00-1. If the pump being tested is already operating the licensee does not wish to stop it for the sole purpose of measuring static inlet pressure.

2.1.2.2 Proposed Alternate Testing: No alternate test is proposed. Static inlet pressure will

_ not be measured on operating pumps.

2.1.2.3 Licensce's Basis for Relief: "If a pump being tested is in operation as a result of plant or system needs, it is unreasonable to reconfigure system-lineups simply to provide for measurement of static inlet pressure.

Inlet pressure prior to pump _ startup is not a significant parameter needed for evaluating pump performance or its material condition."

2.1.2.4 Evaluation: ASME Section XI, Table IWP-3100-1 requires that pump inlet pressure be measured prior to starting the pump and during the test. Ilowever, the measurement

. of static inlet pressure is not intended to be used as a test parameter for evaluating pump performance, and there are no acceptance criteria specified for this parameter. Static inlet 3

l pressure measurement is only included to help the licensee set up the test and recognize that adequate suction pressure should oc available. In ASME/ ANSI OMa-1988, Part 6, the requirement for measuring static iniet pressure is eliminated since it is recognized that the licensee is responsible for addressing testing limitations, and that those limitations will be incorporated into the procedures. Compliance with the Code requirements would result in a hardship to the licensee without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted from measuring pump inlet pressure before starting the pump in accordance with 10CFR50.55a(a)(3)(ii). All other pump parameters, including operating pump inlet pressure, should continue ta be measured unless specific relief has been granted.

2.1.3 All Pumps in the IST Program, Relief Request No. PRR-7 2.1.3.1 Relief Request: The licensee is requesting relief from measuring pump vibration displacement amplitude, and from determining the direction perpendicular to the pump shaft which has the largest deflection, which are requirements of ash 1E Section X1, paragraph IWP-4510.

' 2,1.3.2 Proposed Alternative Testing: Pump vibration measurements may be taken in either displacement or velocity Units. When velocity Unit; are used, the acceptance criteria will confo7n to those set forth in OMb 1989, Part 6, Tables 3 and 3a.

For centrifugal and rotary (non-reciprocating) positive displacement pumps, vibration readings will be taken in a plane perpenJicular to the operating shaft in two mutually perpendicular directions. Test data shall be evaluated per IWP-3100 with successive vibration readings compared to reference values previously taken at that specific location.

2.1.3.3 Licensce's Basis for Relief: " Measuring vibration in velocity Units rather than displacement is an industry-accepted practice considered to be more sensitive to small changes that are indicative of developing mechanical problems. Velocity measurements detect not only high-amplitude vibration, characteristic of major mechanical problems, but i

low amplitude vibration, as well, caused by mirdignment, imbalance, or minor hearing I

wear.

j It is impractical to search for the direction with the largest deflection and procedurally return to that precise location on successive tests. In addition, the direction of maximum deflection may vary with the material condition and age of the pump, thus eliminating consistency between test data. Adapting thi requirement to test procedures could cause confusion as to the proper locationi for i = nsuring pump vibration. Also, comparing subsequent test data to reference test data n La at different locations does not-provide a good measure of pump degradation.

ASME/ ANSI OMa.1987, Operation and Maintenance of Nuclear Power Plants, Part

6. Section 4.6.4 has adopted the concept of measuring vibration at two mutually l

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perpendicular locations and comparing subsequent seat data to the reference value at that specific location.

Measuring vibradon in velocity Units is pcimitted by the nw.n recent version of OM-b 19S9 Stanhrd for Inscrvice Testing at Nuclear Power Plants, Part 6."

2.1Jt.4 Eralarlor' The usc of vibration velocity measurements is recognized in the industry as.. more sensitive and effective indicator of mechanical degradation than displacement measurements for pumps with speeds greater than 600 rpm. Displacement measurements are useful primasi!y for deteding relatively high amplitude vibration, which is charaderistic

,f me.ior mechanical problems, such as bearing failure or shaft warpage.

Velocity measurements detect not only high aiaplitude vibration, but also low amplitude vibration, J

which can be caused by misalignment, imlulance, or minor _ bearing wear. This makes i

velocity mea.mrement a niore versatile parameter for momtoring pump degradation.

I ASME/ ANSI OMa 1988, Pa:t 6 allows vibration measorements tola taken in either displacement or velocity Units.170r centrifug d pumps. it also requires the measurements to be taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each. cessible pump bearinf. housing and in the axial direction on each accessible pump thrust bearing' housing. The vibration measurement requirements of ASME/ ANSI OM. Pi.rt 6 provide an acceptable alternative to the Section XI code requirements for assuring pump operritional readiness and foi detecting pump degradation.

In addition, Revision 8 (Noveraber 1990) of Regulaton Guide 1.147. " Inservice Inspection Code Cue Acceptability A3ME Section XI Division 1," has approved Code Case N-465, which stn'e that the NRC has approved the use of ASME/ ANSI OMa 1988, rart 6 for pump testing in lieu of Section V Subsection IWP. Therefore, if the licensee were to adopt the use of OM, Part 6 for pump vibration measurement it would pro.ide an acceptabb level of quality and safety.

I in the licensee's description of alternative :esting there is a. apparent discrepancy in whether Section XI or OM, Part 6 will be followed for vibration testing. !n the first i

paragraph it is stated that " pump vibration measurements may be taken in either L

- displace ment or velocity Unit'. Acceptance criteria for velocity measurements will conform to those set fcrth in OMb 1939, Part 6, Teb:, 3 and 3a."

llowever. in the second paragraph it is stated that " test data shal; he evaluated per IWP 3100...", whi1h is a part of l

Sectior, XL If the requirements of OM, Part 6 are te be adopted for vibration measure-L ments, all of the requirements specified in OM, Pap 6 pertaining M vibration measme-L ments must bc met, including evaluation criteria. The licecce should riot collect test data per OM, Part 6'requiremects and then evaluate it using Section XI Code requirements i

since this could violate the t ent af the Code.

The alternat ve tesugdescription also does not address axial thrust bearing i

vibration measurement, which is a requirement of OM, Part 6. In addition to measuring vibration in two orthogonal directions perpendicular to the pump shaft, measurements must 5

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n also be taken in the axial direction on each accessible pump thrust bearing housing, This should be specified as part of the IST program if ON1, Part 6 will be adopted.

Therefore, it is reconunended that relief f om measuring pump vibsation j

displacement am,litude and from determining the direction perpendicular to the shaft which has the largest deflection be granted in accordance with 10CFR55a(a)(3)(i) plovided that all of the requirements of ASN1E/ ANNI ON!b-1989 Part 6 are met with regard to vibration measurement, including evaluation criteria and axial thrust bearing vibration measurement.

1 Note: The only differen e between the 1989 and the NRC approved 1988 Addenda i

of Oh!, Part 6 u the addit on of Figure I to Table 3 as errata (i.e., this " revision was j

i inadvertently omitted from ONia-1938.") The 1988 Addendt referenced the missir.g i

figure.

2.1.4 All Pumps in the IST Program, Relief Request No. PRR-8 2.1.4.1 Relief Rcquest: The licensce is requesting relief from the ASN1E Section XI, paragraphs IWP 3300 and IWP 4310 requhements for tocasuring the temperature'of all centrifugal putup bearings outside the main flow path, and the main shaft bearings of reciprocating pumps.

2.1.d.2 hoposed Allematiw Tearmy Bearing temperature will not be measured as part of the inservice test. Vibrat on monito ing will be performed, which will provide adequate monitoring and evaluation of the material condition of the pump bearings.

f 2.1.4.3 Licensec's Beisfor Relief: "The data associated with bearing temperatures taken at one-year intervals pw. ides little statistical basis for determining the incremental degradation of a beaiing or any meaningful trending information or correlatir.

_ in many cases, the pump bearings are water-cooled and, thus, bearing temperature is a function of the temperature of the cooling medium, which can vary considerably.

. Vibration measurements are a significantly more reliable indication of pump bearing degradation than are temperature measurements. All pumps in the program are subjected to vibration measurements in accordance with IWP-4500.

Although excessive bea.ing temperature is an indication of an inuninent or existing bearing tailure, it is highly unlikely that such a condition would go unnoticed during routine surveillance testing since it would manifest itself in other obvious indications such as audible noise, unusual vibra' ion, increased motor currenti etc.

- l Any potet.nal gain from taking bearing me,surements, which in most cases would L

be done k>cally using portable instrumentatior.. cannot offset the cost in terms of dilution l

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9 of operator effort, distraction of cpelators trom other piimary duties, excessive operating periods for standby pumps especiallj under minimum flow conditians, and unnecessary personnel radiation exposure."

2.1.4 A &aluation: 'lhe industry recognizes tlu.t an increase in bearing temperature can be used as an indicator of bearing failure, llowever, in most cases the temperature does not increase to any measurable degree until failure is inuninent. Ily this time other indications of bearing failure would also be present, such as increased vibration or audible noise.

Therefore, the data obtained from measuring bearing temperature once a year would be s

of little use, unless it happened to occur when a bearing failure was inuninent. This is recognized in ash 1E/ ANSI Ohla.1988, Part 6 (Oht d), inse vice Testing of Pumps in Light

. Water lteactor Plants, which eliminates the requirement for measuring bearing tempera-ture. hicasurement of pump vibration provides a means of monitoring bearing wear. By recording and trending this information, a more effective method of detecting bearing degradation is provided. Since it is consistent with ON16, the elimination of bearing temperature measurement will not adversely effect the level of quality or safety provided by the inservice pump test. Therefore, it is reconunended that relief be granted from measuring bearing temperature pursuant to 10CFR55a(a)(3)(i).

2.1.5 All Pumps in the IST Program, Relief Request No. PRR 9 2.1.5.1 Relief Request: The Licensee is requesting relief from the requirement of AS$1E Section XI, paragraph IWP-4210 when measuring pump suetion pressure. This requirement states that if the presence or absence ofliquid in a gage line could produce a difference of more than 0.25% in the indicated value of the measured pressure, means shall be provided to ensure -or determine the presence or absence of liquid as required for the static correction used.

2.1.5.2 Proposed Alternatice Testing: If the presence or absence of liquid in a gage line used for sensing pump suction pressure could pro < luce a difference of more that 0.25% in the calculated value of nump differential pressure, means s;iall be provided to ensure or determine the presence or absence of liquid as required for 1:1e static correction used.

2.1.5.3 Licensec's Basis for Relief: "When this requircraent is applied to the measurement of pump suction pressure, the 0.25% limit is overly restrictise and oftentimes results in complicated venting procedures and unnecessary health physics risks associated with handling and disposal of radioactive contaminated

• vater with no commensurate gain or improvement of test reliability.

2 Normally, the only quantitative use of suction pressure is in determining pump differential pressure or head.

In most cases, suction pressure is relatively low, and discharge pressure exceeds it by at least a factor of five. This being the case, a.25% error introduced into the suction pressure measurenient results in an error of.05% in the

-differential pressure calculation. This is insignificant in light of the potential 6% error 7

l allowance applied to both the suction and discharge pressure instruments (Reference IWP.

- 4110)."

2.1.5.4 Inaluation: The requirement to account for the presence or absence of liquid in pressure sensing lines is intended to ensure that accuiate pressure measurements are obtained. Pump suction pressure itscif is not required to determine pump performance, and thue are no acceptance criteria for it. This !c iccognized in AShlE/ ANSI Ohta 1988 Part 6, which elimit,ates pump suction pressure measurement as a requirement. It was included in the Section XI Code to help the licensee recognize that adequate suction pressure is (muired for proper pump operation. Its only quantitative use is in calculating pump differential pressure,if differential pressure cannot be measured directly. Therefore, the error in sucticn pressure measusenient is only important to the calculated value of differential pressure. The licensee's alternative for accounting for liquid in the gage lines J

is acceptable since it meets the intent of the Code.

Ilowever, it-must be properly pmceduralized to ensure that differential pressure accuracy meets Code rep.irements.

S.

e the licensee's alternative w;ll provide an acceptable level of quality and safety, it is rewmmended that relief from the requirements of IWP-4210 be granted in accordance with 10CFR5Sa(a)(3)(i) provided that the calculation of pump differential pressure is properly proer 'uralized to account for liquid N the pressure sensing gage lines so that the accuracy of the final value meets Code requirements.

2.1.6 All Pumps in the IST Program, Relief Request No. PRR 10 2.1.6.1 Relief Request: The licensee is requesting relief from the requirements of ash 1E Section -XI, paragraph IWP 4110, which requires that th instrument accuracy be as specified in Table IWP-411041.

' l.6.2 hoposed Alternarim Testing: For instruments which have primary sensors associated with the instrument loop (an orifice for flow, for example), the primary sensor accuracy is not considered. For instruments which have instruments and indicators positioned locally,

'and when remote computerized indication is used, Table IWP 41101 will be applied. For instrument loops which consist of transmitters and remote readouts - for pressure, differential pressure, and flow rate, an acceptable accuracy is 3%.

l 2.1.6.3 Licensce's Basisfor Relief:"I he intent of Articles 4110 and 4120 is to ensure that the recorded test parametery are accurate within certain bounds, thereby providing assurance i

of accuracy and repeatability.

The articles do not provide any guidance on the specific bounds within which they apply, it is unclear whether or not primary sensors are considered, Further, numerous instrument loops in our facility utilize remote indicators without redundant, local indication."

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2.1.6.4 Era /uatmn The intent of the Code reouirements on instrument accuracy b to ensure that accurate test data is obtained that is representative of actual pump operating conditions so that a meaningful evaluation of pump performance can Le made. The

nstrument accuracies specified in Section XI. Table IWP-4110-1 are bastJ on a percentage I

of full scale for individual analog instruments. In cases where an instrumentation loop i

- consisting of a combination of instruments is used, the accuracy should be interpreted to be the loop accuracy, which represents the accuracy of the final measured value obtained from the loop. As clarified in OM Code Interpretation 913, issued May 14,1991, the accuracy requirements apply only to the calibration of the instrumems. Attributes such as orifice plate tolerances, tap locations and process temperatures do not have to be included.

The licensee has not, however, demonstrated that it would be impractical or would impose a hardship without a compensating increase in the level of quality or safety to

- procure and install instrumentation that meets the Code requirements. The proposed dternative provides no technical justification for establishing an acceptable accuracy of

+3% for instrument loops. The licensee should review current instrumentation accuracy and determine whether the Code requiremtnts can be met. If they cannot, the licensee should determine whether modifications can be made to bring the instrumentation into compliance. If this is impractical, technical justification should be provided for establishing instrumentation accuracies that can be met.. Additionally, the relief request should bc tevised to address specifie instrutnentation and pumps.

Compliance with Code requirements would result in a hardship since it would require a plant shutdown to install instrumentation that will have to be procured. Safety related instrumentation requires a long procurement lead time. The licensc 's rJternate testing using existing instrumentation provides an acceptable level of safety and quality for an interim period. The Code required accuracy exceeds the licensee's instrument accuracy by only 1% Although this is acceptable for an interim period. long term the licentee should meet the Code requirements or provide justification. Therefore, it is recommended that interim relief from-the instrument accuracy requirements be granted-in accordance with 10CFR50.55a(a)(3)(i) for one year or until the next refueling outage, whichever comes later; to allow the licensee time to comp!cte their review.

2.1.7 All Pumps in the IST Program, Relief Request No. PRR.16 2.1.7.1 Relief Retfuest: The licensee is requesting relief from measunng pump differential pressure directly in accordance with ASME Section XI, paragraph IWP 3100.

2.1.7.2 Proposed Alternative Testing Differential pressure will be a calculated value based on the values of suction and discharge pressure.

2.1.7.3 Licensce's Basis for Relief: " Pumps are not equipped with instruments which directly provide a value of differential pressure."

9

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0..'.nm hon XI, paragraph IWP4240 allows the calculation of pump

.Etm 7 sure using measured valucs of pump inlet and discharge prusure.

& > <," A. is not required.

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2. 2 Safety iniection and Residual lleat RcInoval Systeln 2.2.ll Safety injection Pumps, Relief Request No. PRR 3 2.2.1.1 Relief Request: The licensee is requesting relief from measuring the Unit I and 2 Safety injection Pumps', P-015A&D, flow rate quarterly, which is a requirement of ASME Section XI, -

agraph IWP 3100.

In addition, the licensee is requesting relief from performing post maintenance testing prior to, or within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after returning the pump to normal se vice, which is a requirement of Section XI, paragraph IWP 3111.

2.2.1.2 Proposed Alternate Testing: The pumps will continue to be tested quarterly using the recirculation line during which all required pump parameters, except flow rate, will be measured, recorded, and evaluated.

In addition, at least once during each reactor

- refueling, when significant Cow can be established through an instrumented test circuit, an insenice test will be performed where all required pump parameters, including How rate, will be measured and recorded at three points along the pump curve. Test data taken at these. points will be evaluated in accordance with IWP 3200.

Should maintenance be performed that requires post maintenance testing per IWP.

. 3111, testing will be performed as follows:

If the plant is not in a refueling shutdown condition such that the testing in the recirculation mode is the only testing practical, then such testing will be performed and the test results evaluated per IWP 3111. Following this, the subject pump will be tested during the next refueling shutdown period where.

-all parameters (including flow rate) will be measuied and evaluated with respect to 'WP-3111.

'If the plant is in a refueling shutdown condition, the subject pump will be tested with all parameters (including flow rate) measured and evaluated with respect to IWP 3111.

t 2.2.1.'3 Licensce's Basisfor Relief: "The insenice testing of these pumps is accomplished by operating the pumps in a recirculation mode through a fixed flow limiting orifice.

The orifice is sized such that pump operation is in the flat (horizontal) region of the pump characteristic curve where the pump head is relatively independent of flowrate. Under these test conditions, flowrate measurements may not be indicative of pump performance.

NRC Generic Letter 89 04, Position 9, allows climination of flowrate measurements during quarterly testing where flowrate instrumentation is unavailable provided that 10

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

I appropriate insenice tests are pe formed duiing cold shutdowns or icfueling where full oi substantial flow conditions can be established and nowrates measmed.

The only practical means of establishing full or substantial flow and obtaining quantitative Dowrate data during testing of these pumps requires pumping into the teactor coolant system (RCS). Dur;ng plant operation under normal conditions, this is not possible due to the large differential between the RCS and the maximum pump disciiarge pressure.

Under shutdown conditions when the RCS is depressurized, operation in such a mode is precluded by low-temperature over pressurization concerns and restrictions.

Performing post maintenance testing for all reference values would require a plant shutdown and couldown prior to ieturning a repaired pump to service. Tests performed in the recirculation mode (quarterly) are sufficient to provide adequate assessment of the pump to perform its safety function."

a 2.2.1.4 Eca!narion: Review of the safety injection system Piping and instrument Diagram (P&lD) verifies that testing of the pumps in their primary flow path during normal plant operation would require water injection threctly into the reactor coolan' system, w hich is not possible due the large differential pressure between the RCS (over 2200 psia) and the maximum safety injection pump dischange pressure (approximately 1500 psia).

A recirculation line with a Dow limiting orifice is avadable for quarterly and post-mairtenance pump testing, however, it does wt currently include Cow instrumentation. Compliance with the Code would require modifications to include Dow instrumentation.

In addition to the normal 2-inch recirculation How line, the P&lDs indicate th-existence of test lines (3/4 - Sl-1501R 4) which includes flow indicators (F1-929). It appears that the system can be aligned such that the pumps can pump through.his line to the refueling water storage tank for test purposes. Therefore, an instrumented path does exist for measuring pump How during normal plant operation. The licensee has not addressed the potential use ca this line for quarterly or post maintenance testing of the safety injection pumps. Ilowever, the size of titis test line (3/4 inch) would not allow full Dow testing of the pumps. The alternative test proposed by the licensee includes full flow testing during refueling autages where all pump parameters are measured and three points on the pump curve are v:rified. la addition, quarterly testmg using the recirculation Hov.

g line will continue with measuiement of pump differential pressure and vibration being performed. This would provide a more comprehensive evaluation of pump operational readiness than only performing quarterly testing where a small pump How can be established and measured. The proposed alternative has also been approved by Generic Letter 89-OL Attachment 1, Position 9. Therefort the proposed alternative is considered to be a more appropriate option. Ilowever, the liceasce should address the test line i'i the inservice test program and document why it is not used. Additionally, the licensee should addres the modifications to allow testing at Dowiates equal to or great + c than the mininum flous recommended by the manufacturer discussed in the licensee's letter to the USNRC, dated October 2,1990, as they pertain to this relief request. The licensee should I1 T _-__-_

consider installing flow instrumentation if the system is to be redesigned, in addition to this relief request, relief request VRR 27 concerning the ruin mum Cow check valves would not be seguired if instrumentation was installed.

i'herefore, based on the detennina: ion that compliance with the Code requirements is impractical and considering the borden on the licensee if the Code requitunents were imposed and since inservice testing will be performed at refueling outages with all parameters measured, and quarterly testing will continue with puir.p ufferential pressure and vibration being measured, which is consistent witti the NRC position stated in Generic Letter 89-04 (Attachment 1, Position 9), it is recommended that iclici from measuring pump flowrate quarterly be granted in accordance with 10CFR50.55a(g)(6)(i).

The licensee has also proposed defeiring post-maintenance testing where flowrates are measured to the next iefueling outage, when inaintenance is not performed during a refueling outage. Testing the pump at the design ficwrates would require the plant to be shut down and vented to preclude low temperature nverpressurization. The pump will be g

tested followmg maintenance using the minimum Dow line. The minimum How line, however, dees not contain How instrumentation and the 3/4# test line would not result in a

stable now conditions. Therefore, based on the determination thr,t compliance with the 7

code requirements is impractical and considering the burden on the licensee if the Code requirements were imposed, it is recommended that relief from post-maintenance testing be granted ir accordance with 10CFR50.55a(g)(6)(i) provided that the licensee perfonns post maintenance tests during the next plant shutdown when the RCS is vented to preclude low temperature overpressurization.

t 2.2.2 Safety injection Pumps and Residual lleat Removal Pumps, Relief Request No.

PR P.17 2.2.2.1 Relief Reque.st 'lne licensee is requeat;ng relief from running the Unit I and 2 Safety injection Pumps, P-015A&B, and RIIR Pumps, P 010A&B, at least five minutes under conditions as stable as the system permits before measuring test parameters during the three-data point pump curve testing performed during refueling outages The five minute hold period is a requirement of ASME Section XI, paragraph IWP-3500.

2.2.2:2 Pmp:> sed Alternatice Testmg: When performing the three data-poin' pump curve test, an overall run time of five minutes will be mrt.

Pump operatien dusing periodic recirculation line testing will be at least five minutes in duratiou.

2.2.2.3 Licensce's Ba3i;for Relief "When perfonning the three-data-point fully instrumemed, significant Dowrate test at refueling shutdown conditions, the pumps use the RWST as a suction source and deliver to the refueling cavity. The RWST does not contain a sufFeient amount of fluid to allow each pump te run at the reference point for five minutes phis get performance data at two other points.

12 l

1 The overall run time for tL' complete test of each pump (thres or more data points) does exceed five minutes. When performing periodic noninstumented recire ime tesGug, the pump will be operated for at least five minutes" 2.2.2.4 Era /uatwn: Examination of the P&lDs indicates that the RWST is the only practical source of fluid for full.Gow testing of these pumps. Since the RWST inventony is limited, it would be impractical for the licensee to operate the pumps for five minutes before taking data. However, the intent of the Code in imposing the five minate hold period is to ensure

- that pump operating conditions have stabilized before data is recorded. This eliminates the possibility cif recording error.cous data during temporary fluctuations in operating conditions, which are likely w'

.ver a pun'p is moved to a new point on its operating curve. The overall run time of five minutes proposed in the alternative testing does not satisfy this intent since there is no stabilization period specified before recording data efter pump operating conditions are changed.

ash 1E/ ANSI Ohta 1988, Part 6 revises the hold period to two minutes before data measurements are taken. The requirements of Part 6 provide an acceptable alternative to the _Section XI requirements for_ assuring pump operational readiness lhe staff has determined that it provides ata acceptable level of quality and safety, and has approved its use in Regulatory Guide 1.147 (Code Case N 465).'

%erefore,it is recomme::ded that relief from the five rainute hold period be glauted in accoruance with 10CFR50.55a(a)(3)(i) provided the licensee establishes a two minute hold period before taking data measurements in accordance with Oh!, Part 6, 2.23 Residual lleat Removal Pumps, Relief Re-t No. PRR-4 2.2.3.1 Relief Request: The licensee is requesting relief from measuring the Unit I and 2-RHR pumps', P-010A&B, flow rate quarterly, which is a requirement of AShiE Section X1, paragraph IWP 3100, in addition, the licensee is requ sting relief from performing post maintenance testing prior to, or within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> aftet returning the pump to normal service, which is a requirement of Section XI, paragraph IWP 3111.

12.3.2 Proposed Alternate Testing: The pumps will continue to be tested quarterly using the recirculation minimum now line during which all required pump parameters, except flow ra:e, will be measured, re:o.ued, and evalu.ited. In addition, at least once during each reactor refueling when significant flow can be established through an iratrumented test circuit, <m insersice test will be perfonned where all required pump parameters, including flowrate, will be measured and recorded at three poims along the pump curve. Test data taken at these points will be evaluated in accordance with IWP-32i Should maintenance be performed that requires post maintenance testing per IWP.

3111, testing wili be perfonned as follows:

13

l

+

If the plant is not in a refueling shutdown condition such that t'.e testing in the recirculation mode i3 the only tesiing practical, then such testing will bc performed aad the test resuhs evaluated per IWP 3111. Following this, the subject pump will be tested during the next refueling shutdown period where all parameters (including now rate) will be measured and evaluated with i

respect to 1Wp-3111.

If the plant is in a refueling shutdown condition, the subject pump will be tested with all parameters (including flow rate) measured and evaluated with respect to IWP 3111.

i 2.2.3.3 Liccmce's Basis for Relief "The only practical means of establishing full or substantial flow and obtaining qt.i.ntitative and meaningful flowrate data during testing of these pumps requires pumping into the reactor coolant system (RCS). During plant operation under normal conditions. this is not possible due to the large differential between the RCS and the maximum pump discharge pressures. Thus, the quarterly insenice testing i

of these pumps is accompli _hed by operatmg the pumps in a recirculation mode through 4

a fixed flow hmiting orifice. The orifice is sized such that _ pump operation in the Hat (hoiizontal) region of the pump characteristic curve where pump head is relatively independent of flowrate. In addition, the range and accuracy of the flow instrumentation do nct provide adequate repeatability at the redaced dowrate available in this flow scheme.

Under such test conditions, flowrate measurements may not be indicative of pun.p perfortuance.

i NRC Generic Letter 89-04, Position 9, alloves elimination of flowrate measurements during testing where dowrate instrumentation ts unavaihble provided that appropriate insenice tests are performed during cold shutdowns or refueling where full or substantial flow conditions can be established and flowrates mcasured.

Performing post mr.intenance testing for ajl reference values would requite a plant sht.tdown 'and coo!down prior to returning a repaired pump to service. Tests perfoimed 7

in the recirculation mode are sufficient to provide adequate assessment of the pump to perform its safety function."

2.2.3.4 Evaluation Review of the residual heat removal system P&lD verifies that full flow testing of the pumps in their primary flow path during normal plant operation would require water mjection directly into the reactor coolant system, which is not possible due to the_large differential pressure between the RCS (over 2200 psia) and the maximum residual heat removal pump dischaige pressure (le;,s than 200 psia). An instrumented minimum flow recirculation line is available for pump testing during nonnal plant operation, however, the range and accuracy of the flow instrumentation are not suitable far-the low flow rates obtainable. The licensee has stated in Relief Request VRR 3 that the RIIR P!Vs will be full-stroke exercised at cold shutdowns when ' Event V" valve testing is requir(d. It is assumed that the RilR pumps ivill be operated to perform the valve tests.

14

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i Therefore, based on the determination that compliance with the Code requirements is impractical during operation due to system piersures and considening the burden on the licensee if the Code requirements were impos(d which would require a major system modification to incluoe a full flow test loop, and since inservice testing at full or substantial now can be performed at refueling outages and co;d shutdowns with all parametcis measured, which is consistent with the NRC position stated in Generie 1.etter 89 04 (Attachment 1, Position 9); it is recommended that relief be granted in accordance vath 10CFR50.55aig)(6)(i) provided testing is peitormed at both refueling outages and cold

. shutdowns when " Event V" vahe testing is pei fo r m ed. The licensee should however address the modificatiom to allow testing at Dowrates equal to or greater than the minimum nows reconunended by the raanufacturer, w hich is discussed in their letter, dated October 2,1990, as they pertain to this relief request. The licensee should consider installing now instrumentation if the system is to be redesigned.

The licensee has also propored deferring post maintenance testmg where pump Dowtates are meneured to the nest refuehng outage. when maintenance is not performed during a refueling outage. Testing the pump at design Howrates wouhl require the plant to be shutdown where the RCS pleasun is less than 200 psia. The pump will be tested following maintenance us;.y the minimum tiow line.

Ilowen r, accurate now measurements are not obtainable at the low flowrates.

~llie refore, based on the determiaation that compliance with the Code requirements is impracti al and considering the burden on the licensee if the Code requiremen's were imposed,it is ucommended that relief from post-maintenance t sting be granted in accordance with 10CFR50.55a(g)(6)(i) e provided that the licensee performs post-maintenance tests during the next cold shutdown when "Ever.t V" valve testing is performed.

Amilim1 eedwater System F

2.3 2.3.1 Auxiliary Feedwater Pumps, ilelief Request No. PRR 5 2.3.1.1 Relief Recptest: The hcensee is requesting relief from measuring the Auxiliary Feedwater Pumps', P-029 (Unit I and 2) and P 038Akil (shared by Units 1 and 2), How rate quarterly, which is a requirement of ASME Section X!, paragraph IWP 3100. In addition, the licensee is requesting relief from performing post maintenance testing prior to, or within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after returning the pump to normal service, which is a requirement of Secticn XI, paragraph IWp-3111.

2.3.1.2 hoposed Ahenrate Tening: The pumps will continue to be tested q arterly using the uninstnanented recirculation minimum-flow line during which all requiied pump parameters except flow rate will be measured, recorded, ana evaluated. In addition, during cold shutdo vn periods when significant Gow can be established through an instrumented test circuit to the steam generators, an inservice test will be performed where all required pump parameters will be measured and recorded at three points along the pump cuise.

Test data taken at these points will be evaluated in accordance with IWP-3200. The 15 1

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p

4 inservice testing will be performed at cach cold shutdown, unless less than three months has elapsed since the last cold shutdown.

Should maintenance be perfonned that requiics post mamtenance testing per IWP-3111, testing will be performed as follows:

If the plant is not in a cold shutdown condition such that the testing in the recirculation mode is the only testing practical, then such testing will be performed and the test results cvaluated with respect to IWP-3111.

Following this, the r.ubject pump will be tested during the next cold shutdown period where all parameters (including Dow rate) will be measured and evaluated with respect to IWP 3111.

If the plant in in a cold shutdowr. cendition, the subject pump will be tested with all parameters (including Dow rate) measured and evaluated with respect to IWP 3111.

1.3.1.3 Licenscei Basis for Relicf:

"The only practical means of establishing full or substantial flow and obtaining quantitative and meaningful flowrate data during testing of these pumps requires pumping into the steam generators. During plant operation under normal conditions, this is undesirable due to the possibility of causing thermal shock to the auxiliaiy feedwater piping nozzles. For this reason the inservice testing of these pumps is accamplished by operating the pumps in a recirculation mode through a fixed Dow limiting orifice. The orifice is sized to provide pump operation in the Hat (horizontal) region of the pmnp characteristic curve where pump head is relatively independent of flowrate. In addition, flow instrumentation is not provided in this test scheme. Thus, under these test conditions, Dowrate measurements are neither practical nor would they provide any meaningful information if available.

NRC Generic Letter 89-04 Position 9, allow elimination of Dowrate measurements during quarterly testing where Dowrate instrumentation is unavailable provided that appropriate insersice tests are performed during cold shutdowns or refueling where full or substantial flow conditions can be established and Howrates measured.

Performing post maintenance testing for i] reference values would require a plant d

shutdown and ccoldown piior to returning a repaired pump to service. Tests performed in the recirculation mode (quarterly) are sufficient to provide adequate assessment of the pump to perform its safety function."

2.3.1.4 &alumum:

Review of the auxiliary feedwater system P&lD verifies that the uninstrumented minimum-Gow recirculation line is the only available pump test now path during plant opermion. Testing of the pumps in their primary Gow path during normal plant operation would require water injection directly into the steam gene.ators, which could cause thermal shock to the auxiliary feedwater nozzles and possibly lead to 16

equipment damage. Comgance with the Code would require system modifications to include instrumentation or a full flow test loop.

i i

The licensee has stated that both the turbine driven pumps (P 029) and motor driven pumps (P-038A&B) will be tested at cold shutdowns. There is no motive power (i.e. steam) available at cold shutdowns to test the turbine driven pumps. Therefore, relief cannot be reconunended for these pumps. The staff's position is that in the cases where caly the minimum flow line is available for pump testing, regardless of the test intenal, flow instrumenhtion that meets the requirements of the Code must be installed (Reference Generic Letter 89 04, Attachment 1. Position 9).

Based on the determination that compliance with the Code requirements is impractical and considering the burden on the beensee if the Code requirements were imposed and since insenice testing will be performed at cold shutdown periods for the motor driven pumps with all parametns measured, which is consistent with the NRC position stated in Generic Letter 89 04 (Attachment I, Position 9); it is recommended that relief from measuring pump Howrate gunrterly and post maintenance be gianted in 4

accordance with 10CFR50.55a(g)(6)(i). Note: The minimum How check valves are not addressed in the IST Program. Full stroke exercise tests are not possible due to the lack of instrumentation as discussed above. (See TER Section 5.25) 2.3.2 Auxiliary Feedwater Pumps, Relief Request PRR-15 2.3.2.1 Relief Request The licensee is requesting relief from running the Auxiliary Feedwater Pumps, P-029 (Unit I and 2) and P-038A&B (shared by Units I and 2), at least five minutes under conditions as stable as the system permits before measuring test parameters during the three data point pump curve testing performed during cold shutdowns. The five minute hold period is a requirement of AShlE Section XI, paragraph IWP-3500.

' 2 3.2.2 Proposed Alternatiec Testing: When performing the three-data point pump cune test, an overall run time of five minutes will be met.

Pump operation during periodic recirculation line testing will be at hast fise minutes in duration.

2.3.2.3 Licensec's Basis for Relief: "During cold shutdown periods when operation of the auxiliary feedwater pumps pumping to a steam generator is possible without the potential of thermal shock, inservice testiec will be performed such that all required pump parameters will be measured and recorded at three (3) points along the pump curve.

At this time, however, there is veiy little decay heat remaining in the RCS system.

Sustained operation of auxiliary feedwater at substantial flow rates causes significant pressure decreases in the reactor coolant system which challenge reactor coolant pump operation limits and cause reactor coolant level decicases due to temperature induced shrin k.

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l 2.3.2.4 Eruluation: Examination of the auxiliary feedwater P&lDs indicates that the How path to the steam generatoro is the only practical path for full flow testing of these pumps.

During cold shutdown, surtain d operation of the auxiliary feedwater pumps could result in reactor coolant system pressure decrease when the level of decay heat in the reactor is low. The licensee believes it is in prretical to operate the pumps for five minutes prior to recording data, llowever, the intent of the Code in imposing the five minute hold period is to ensure that pump operating pinions have stabilized before data is recorded. This eliminates the possibility of recceding erroneous data during temporary fluctuations in operating conditions, which are lihely whenever a pump is moved to a new point on its operating curve. The overall run time of five minutes proposed in the alternative testing does not satisfy this intent since there is no stabilization period specified before recording d.ata after pump operating conditions are changed.

ash!E/ ANSI Ohla.1988. Part 6 revises the hold period to two minutes before data measurements are taken. The requirements of Part 6 provide an acceptable alterr.ative to the Section XI requirements for assuring pump operational readiness. The staff has deter nined that it provides an acceptabh: level of quality and safety, and has approved its use in Regulatory Guide 1.147 (Code Case N 465).

Therefore, it is recommended that relief from the five minutes hold time be granted in accordance with 10CFR50.55a(a)(3)(i) provided the licensee establishes a two minute hold period before taking data measurements in accordance with 051 Part 6.

2.4 Containment Sprav System 2.4.1 Containment Spray Pumps, Relief Request No. PRR-6

2. t.l.1 Relief Reynest: The licensee is requesting relief from measuring the Unit I and 2 I

Containment Spray pumps', P-014A&B, flow quarterly, which is a requirement of ash 1E Section XI, paragraph IWP.3100.

2.4.1.2 Itoposed Al!crnatire Teating: No alternative testing is proposed for measuring pump How rate. The pumps will continue to be tested quarterly in the recirculation mode with all parameters specified in Section XI Table IWP-3100-1, except flow rate, measured, recorded, and evaluated.

2.4.1.3 1icensec's Basis for Rc/lef:

"The only practical means of establishing full or substantial flow and obtaining quantitative and meaningful flowrate data during testing of these pumps requires pumping into the containment spray headers and into the containment atmosphere. This is obviour,1y impractica! _and undesirable. For this reason the quarterly inservice testing of these pumps is accomplished by operating the pumps in a recirculation mode through a fixed flow limiting orifice. The orifice is sized such that pump operation is in the flat (horizontal) region of the pump characteristic curve where pump head is relativelv independent of flowrate. Note also that flow instrumentation is not 18

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n provided in the recisculation circuit nor in the constant recirculation line through the eductors. Thus, under these test conditions, nowrate measurements are not possible.

Durit1g each in'iervice test of these pumps performed in the recirculation mode via the fixed orifice, all required pump panuneters (per IWp 3100). except flow, will be measured, recorded, and evaluated."

2.4.1.4 Eraluation: Review ot' the Containment Spray System P&lD verifies that use of the primary flow path would require pumping directly into the containment atmosphere, which is impractical. An uninstrumented minimum-flow recircuhtion line with a flow limiting

- orifice is available for pump testing during normal plant ope 4ation, in addition, an alternate test line is available (3/4 SI 150lR 4) which includes a now indicator (FI-933).

in their response to Generic Letter 89-04 (letter from C.W. Fay, Wisconsin Electric to U.S.

NRC dated October 3,1989), the licensee stated that this alternate test flow path would

- be investigated to determine if it is a viable option since it contaim, only single valve isolation between the spray pump discharge and the spray header in containment. Testing was to be completed by Decem' 't 31,1989 for Unit 2, and June 1,1990 for Unit 1. If testing indicated that this flow path was not viable, the licensee stated that modifications would be made to install flow instrumentation in the recirculation line, llowever, neither this alternate flo_w path nor the installation of Cow instrumentation was addressed in the relief request. Additionally, in the licensee's letters dated March 2 and October 2,1990 to the USNRC, they committed to modifying the containment spray system to allow full Gow

. testing. This is also not discussed in the relief request.

Generic Letter 89-04, Attachment 1, Position 9 clearly states that in cases where only the minimum flow line is available for pump testing, regardless of the test interval Dow instrumentation which meets the requirements of IWP 4110 and 4120 must be installed in the' mini flow return line.

Pump flow rate is a key parameter in assessing pump performance and the licensee has not pr<wided any alternative for this information. If Ocw rate measurement is eliminated; the pump tests may not assure that pump performance has not degraded. Although the licensee has stated that the flow limiting orifice in the mini.

- flow line limits pump operation to the 11at portion of the pump characteristic curve, where 110w rate measurements may not provide meaningful data, no technical justification is given for not removing or resizing the orifice _to allow an adequ. ate flow rate to be obtained.

during testing. In addition, the licensee has not andressed the existing alternate Dow path, which inchide 4ow instrumentation and may be a viable option.

- The licensee has not shown that it is impractical, or that it imposes an excessive handship without a compensating increase in safety to modify the mini flow line

. configuration to allow aniadequate flow and install now instrumentation, or that it is

~ impractical to use the existing alternate flow path.- Also, the proposed alternative does not

- provide a reasonable alternative to the Code requirements for long arm. The licensec should review the recirculation _ line_ configurntion and investigate potential modifications to allow an increased flow to be achieved, and the appropriate flow instrumentatien to be 19 P

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i-installed. Also, the licensee should investiple the t.w of the existing alternate test flow path for quarterly pump testing. If the licensee is only requesting relief until the s3 stem j

modifications to allow full flow testing are installed, the request should so state. Othenvise, i

it is assumed based on the more recently submitted relief request, that these n'odific..tions are not bemg performed.

i in the interim, the licensee's curient insenice test should provice an acceptable level of quality and safety and should be continued.

Immeniate ompliance with Code requirements wot41d be burdensome to the licensee since it could require testing t>y methods not yet deceloped or plant shutdown to install instrumentation Therefore, it is recommended that interim relief from measaring Dowrate quarterly oc granted in l

accordance with 10CFR50 55a(a)(3)(i) for one year or until the next refueling outage, i

whichever comes later, to ellow the licensee time to complete their review and investi ation.

F 2.5 Chemical and Vohune.fontrd System 2.5.1 Boric Acid Transfer Pumps, Relici Reque.st No. PRR-11 2,5.1.1 Relief Request: The licensee is requesting relief fiom measuring the Unit I and 2 Boric Acid Transfer pumps', P 001A&B, flow rate quarterly, whicit is a requircment of AShlE Eection XI, paragraph IWP.3100.

2 5.1.2 Puy>osed Alternate Tearing: During the quarteny insenice test the pumps will be operated using the uninstrumented ruirculation minimum Gow lint. In addition, the pumps will be tested during refueling outages on an instrumented flew path at full or substantial flew conditions. The iefueling outage test will include measurement of all parameters required by lWP 3100.

2.5.1.3 Licensec's Basis for Relief "The quarterly insenice testing of there pumps is

-accomplished by operating the pumps in a recirculation mode in a circuit having nc.

capability for flow measurement. A test circuit is available in which pump flowrate can be measured, however, it requires injection of highly coacentrated boric acid solution into the reactor coolant system. During plant operation, this is not practical since it would upset the reactor coolr nt borie acid balance and adversely effect reactor power and crea,c a plant

- power transient. If injection, vere to be performed during cold shutdown periods (othei than refueling) die result would-be over boration of the 'RCS and assochted pusntial operating difficulties during the subsequent plant startup.

- NRC Generic Letter 89 0-1, Position 9, allows elimination of flowrate measurements-during qur.rterly: testing where flowrate instrumentation is unavailable provided that appropriate insenvice tests are performed during cold shutdowns or refueling where full or substantial flow conditions can be established and tiowrates measured."

20

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m.

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2.5.1.4 Evaluation:

Review of the boric acid transfer system P&lD veiifies that the min: mum dow recirculation line is the only available pump test Gow path during plant operation. Testing of the pumpa in their pr: mary flow path du.ing normal plant operation would require horic acid injection directly into the reactor coolant system. This would result in unnecessary plant power transients and potential safety systems challenges.

Generic Letter 89 04 (Attachment 1, Positien 9) states that in cases where flow can only b: established througl a non instrumented minimum ilow path during quarterly pump testing and a path exists et ccid shutdown or refueling outages to perform a test of the putap unde r full or substandal Gow conditions, measurement of flow iate can be eliminated from the quarterly incerv:ee test. Ilo. sever, in order for this to be an acceptable alternative, during the quarteriy pump test using the niini ilow line at least pump differential pressure and ubration must be sneasured Merely operating the pump in the recirculation mode withoat measuring any performance parameters is not an acceptable alternative test long icim. Review of the P&lDs indicate:, that no inttrumentation is a.ailable in the mini flow line to measure pump suction or discharge pressure. This is corrobosated by the licensee's relief request PRR 12 for the same pumps, which states that the system installations do not prcuide any mechunism for measuring pump suction pressure, discharge pressure, or pump now rate during normal plant opration. In order for this relief request to be consistent with the< NFC's parition in Generic Letter 89 04, the quarterly pump test using the mini.

flow line must include the measurement of pump differential pressure and vibration.

licwever, from the information available, it appears (nat the licensee cannot meet these requirements. Therefore, this relief request is not consistent with Generic Letter 89 01,, Position 9 and reliet should not be granted.

The licensee thould review this selief request and resubmit it with clarification of how the criteria of Generic Letter 89 04 will be met with regard to quarterly measurement of pump differential pressuce and vibratian. If 'the appropriate instrumentation is not available, the licensre should evaluate the procurement and instal *ation ofinstrumentation.

- Since imposition of Code requirements Tvould require a plant shutdown to instali instrumentation, which would be burdensome to the licensee, it is recommended that interim relief from measuring Howrate quarterly oc granted in acccrdance with 10CFR50.55a(a)(3)(i) for 12 monihs or until the next refueling outage, wh!chever comes later, to allow the licensee time to complete their review. In the laterim, the licensee's proposed testing at refueling outages will provide an acceptable level of quality and safety.

- 2.5.2 Boile Acid Transfer Pumps, Relief Request No. PRR-12 2.5.2.1 Relief Rcqucst: The licensee is requesting relief from the requirements of Section XI.

paragraph IWP-3400(a), which requires that an inservice test shall be run en each Horic Acid Transfer pump, P-004A&B (Unit I and 2), nominally every 3 n)onths during normal plant operation. Relief is al-equested from the requirements of ASME Section XI.

Pardgraph IWP-3100, which r ms that all parameters listui in Table IWP-31001 must be measured.

21 4

2.5.2.2 hoposed ellicinatire Tenim:: During reactor refueling outages, each of those pumps will be tested and flow rate will be vesilied to t>e adequate to serse its safety function. In conjunction with these tests, pump vibration will be measured as practical considering the insulation encapsulation.

)

2.5.2.3 Licenace's Basis for Rclief: "The system installations do not provide any mechanism for ineasuring pump suction pressure, discharge pressure, or oump dowiate dunng nonnal piant operation. The only practical means of determining pamp Cowrate is to pump to the RCS. Due to the problems associated with over-boration of the RCS, this can only be dore during reactor refueling outages.

To prevent boric acid crystallation each of these p unps is encapsulated in insulation and is heat traced precluding acce.ss for measuring pump or motor vibration.

It is impractical to routinely teniose this insulation to provide such access.

The CVCS system is configured such that any of the four (4) boric acid transfei pumps (2 in each Unit) can supply either Unit if necessary. This prosides a significant l

amount of redundancy and reliability for the function of RCS boration. In consideration of this, a reduced frequency and reduced scope of testing of these pumps is adequate."

2.5.2.4 Evaluation: Lack of instrumentation and component redundancy are not sufficient justifications for not complying with Code requirements. The pumps cannot be full Dow tested during normal plant operation since this would require the injection of botic acid into the reactor coolant system, which would cause a plant power transient. Therefore, the pumps are tested quarteily in a minimum now recirculatbn line. This was evaluated in a previous relief iequest (PRR-ll), which was sulunitted w obtain relief from measuring pump Gow rate quarterly. Ilowever, the licensee has not demorctrated that procuren ent and installation ofinstrumentation to comply vith Code requirements would be impractical or impose a haidship without a compensatir.g increase in the level of quality or safety. The licensee has also not demonstrated that it would be impractical to remove sufficient pump insulation to provide access for vibration measurements.

in a letter from C.W. Fay Wisconsin Electric to the U.S. NRC, dated April 22, 1991, the licensee stated that a modification to change the insulation will be evaluated by June 1,1992. The licensee has not addressed this evaluation in the relief request, therefore, modification of the pump insulation may be a viable option for allowing vibration measurements to be taken.

The fact that redundant components are included in the design is not a justification for reducing the testing frequency or scope. Redundancy is used to improse reliability and is an indication that the fun. tion of the components is very important. Reducing the testing requirements is cortrary to the intent of this design feature and acts to negate its purpose. Each of tht. components must be maintained in a condition of operational readiness to attam the full benefits of the sedundancy. Therefore, testing frequ' ';y and scope should not be reduced.

22

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d The alternative testing proposed in this relief r, quest is not consistent with that proposed in relief request PRR-11 for the same pumps. In PRR-ll it was stated that quarterly insenice testing would continue, and at least once during each refueling outage an inser ice test would be pesformed where all pump parameters would be measured and evaluated in accordance with Code requirements The alternative testing proposed here implies that only testing during refueling outages will be performed, and that the Code a.;ceptance criteria will not be used for evaluating performance parameters. In addition, it does not specify what criteria will be used to serify that pump flow rate is " adequate to serve its safety function." The alternative testing aho does not define what is considered

practical" in relation to measuring pump sibration. In light of the inconsistency with previously proposed alternatne testing, and the vague terminology used, the alternative v

testing cannot be judged to provide an acceptable alternative to the Code requirements.

d i

The licenne has not provided sulficient justification to conclude that it is impractical or would result in undue hardship to impose Code requirements. liased on the unaccept-able basis for relief and the unacceptable alternatise testing propostd, it is secommended that relief be denied.

s 2

2.5.3 CVCS Charging Pumps. Relief Request No. PRR 14 2.33.1 Relief Request: The beensee is requesting relief from measuring the Unit I and 2 CVCS Charging Pumps', P 002A through C suction and diffeiential pressure, which are jequirements of ASNIE Section XI, paragraph IWP-3300.

4 2.53.2 Proposed Ahemative Testing: During insenice testing, suction and diffe ential pressure will not be measured or recorded. Pump discharge pressure will be measured and evaluated per IWP 3200 and IWP 6000.

2.533 Licensec's 9 asis for Relief: "The CVCS configuration is such that these is no 9

f installed instrumentation provided for measuring charging pump suction or differential pressures. installation of temporary instrumentation is burdensome and there is little value in measuring these parameters, The Charging Pumps are multiple plunger. positive-displacement recipmcating pumps where the pump discharge presure is purely a function of pump design and is independent ef suction pressure. This is reflected in AShlE/ ANSI Ohla 1987, Operation and hlaintenance of Nuclear Power Plants, Part 6 (Tables 2 and 3b) where this new standard requires measurement and evaluation of pump discharge pressure as opposed to ddferential presst.re. Further, ruction pressure measurements are not required."

2.33,4 Ecaluation: Resiew of the Chemical and Volume Control System P&lDs indicates that the charging pumps are positive displacement type pumps. For pumps of this type, discharge pressure is independent of suction pressure and is a functinn only of the pump design Therefore. measuring pump inlet and d;fferential pressure would not provide any 23 i,

-._. y i

meaningful information fo: ev luating pump performance.

This is recognized in ASME/ ANSI OMa 1988, Part 6, which eliminates the requirement for measuring inlet pres >ure and diffe:entiat pressure for positive displacement pumps. Since the alternative testing includes the measurement and evaluation of pump discharge pressure, it provides an acceptable abernative to the Code requirements for assuring pump operational read!aess. Therefore,it is:ecommented that relief from measuring suction and differential pressure be granted as requested in accordance with 10CFR50.55a(a)(3)(i).

2.6 Senice het Systenf l

2.6.1 Senice Water Pumps, Relief Request No. PRR 13 2.6.1.1 Relief Requear: The liccusee is requesting relief from measuring the shared Unit I and 2 Senice Water pumps, P 032 A through F, inlet pressure, which is a requirement of ASME Section XI, paragraph IWP-3300. In addition, relief is requested from measuring i

inlet pressure before startiag the pump.

2.6.1.2 Proposed Alternatiec Testing: During testing of these pumns, one value of inlet pressure will be calculated based on water level at the intake structure.

2.6.1.3 Licensce's Rasis for Relief: "The pumps listed above are vertical line shaft pumps submerged in the intake structure with no practical means of measuring pump inlet pressure. The inlet pressure, however, can be detennined by calculation using, as input, the measured height of water above the pump inlet as measured at the intake.

i During each insenice test, the water level in the intake pit remains relatively constant, thus only one measurement of level and the associated suction pressure

~,

calculation need be performed."

2.6.1.4 &aluation: Review of the senice water system P&lDs indicates that the location of the pumps in the intake structure would make it impractical to measure inlet pressure directly. To require the licensee to make system modifications to enable inlet pressure to i

be nicasured would be burdentome. Calculating inlet pressure based on the measured intake structure water level is a reasonable alternative test to assure component operational L

readiness, provided it is properly proceduralized and the accuracy of the calculation is l-within the accuracy required by Cede using direct measurement. In addition, static inlet pressure is not intended to be used as a measure of pump perfonnance and no acceptance

' criteria are specified.

This is recognized in ASME/ ANSI OMa-1988, Part 6 which E

eliminates static inlet pressure as a test requirement. Calculating one value of pump inlet o

L pree,sure basco on-intake struciure water level will provide an acceptable level of quality L

and safety in evaluating pump operational readiness. Therefore,-it is recommended that l

relief be granted from the Section XI requirements of measuring inlet pressure and 1

- determining static inlet pressure in accordance with 10CFR50.55a(g)(6)(i) provided the E

calculation ofinlet pressure is properly proceduralized and within the accuracy of the Code requirement using direct measurement.

2.7 Chilled Water Syster.n 2.7.1 Cable Spreading Room Chilled Water Pumps and Control Room Chilled Water Pumps, Relief Request No. PRR-15 2.7.1.1 Relicf Rcqncst: The licensee is requesting relief from measuring the shared Unit I and 2 Cable Spreading Room Chilled Water Pumps', P-lll A&B and Control Room Chilled Water Pumps', P 112A&B, flow rate quarterly, which is a requirement c,f ASME Section XI, paragraph IWP 3300.

2.7.1.2 Propead <Jvrratwe Testing: During inservice testing the pumps will be operated in a mode such that the systen. rasism is fixed and repetitive. Pump differential pressure will be measured and evaluated in accorda.ee with the requirements of ASME Section N1, paiagraph IWP-3210.

2.7.1.3 L.icensec's Basis for Relief: "The chilled water system configuration is such that there is no installed instrumentation provided foi measuring flowrate, however, the installation does provide for the capability of operation under a constant (fixed) resistance mode such that pump can be monitored and evaluated from pump differential pressure."

2.7.1.4 Evaluation: Lack of instrumentation is not sufficient justificatien for not complying with Code requirements. The licensee has not demonstrated that tne procurement and installation of appropriate instrumentation would be impractical or would impose undue hardship without a compensating increase in the level of quality or safety. Measurement of pump differential pressure is a requirement of Section XI, paragraph JWP-3300. The proposed alternative testing prosides no alternative to replace the evaluation of flow rate data. Therefore, the alternative testing does not provide an acceptable alternative to the Code requirements long term. The licensee should investigate the practicalhy of procuring and installing instrumentation to meet the Code requirements. In the interim, the current quarterly test measuring pump differential pressure will provide an acceptable level et quality and safety and should be continued.

Since immediate imposition of Code requirements could require plant shutdown to perform system modifications, which would be burdensome to the licensee, it is recommended that interim relief from measuring flowrate quarterly be granted per ICCFR50.55a(a)(3)(i) for 12 months or until the next refueling outage, whichever comes later, to allow the licensee time to compleic their investigation.

3.0 VALVE IST PROGRAM REl.lEF REQUESTS in accordance with 10CFR50.55a, Wisconsin Electric Power Company has submitted relief requests for specific valves at the Point Beach Nuclear Plant that are subject to 25 l

l

l inservice testing under the requirements of AShiE Section XI. These relief requests have been reviewed to verify their technical basis and determine their acceptability Each relief equest is sununt,rized below, along with the technical evaluation by BNL 3.1 6.pxiliary Feedwater System 3.1.1 Auxiliary Feedwater Pump hiinimum Flow Valves, Relief Request No. VRR-28 3.1.1.1 Relief Request: The licec.see has requested relief from measuring the full. stroke time of the air operated auxiliary feedwater (AFW) pump minimum flow valves, AF-4002 (Units i

I and 2), 4007 (Unit 1), and 4014 (Unit 1), in accordance with AShlE Section XI, paragraph IWV-3413.

3.1.1.2 Proposc</ Alternate Testing: The !icensee has proposed verifying that the valves close

= when the pump main line flow reaches a value which assures the pump will not be damaged. No stroke-time will be measured.

3.1.1.3 Licensec's Basis for Reynesting Relief: "These valves are actually control valves, in that they respond to discharge flow and may actually end up in a throttled position. As

- control valves, according to IWV-1200, they could be exempt from testing. They do provide an important function. to shut when sufficiently large main line flows are achieved, thereby ensuring full pump capacity is available to meet any accident requirements. The appropriate acceptance criteria for these valves is to assure they respond properly to flow."

3.1.1.4 Evaluation: ash 1E,Section XI, Subsection lWV provides the rules and require-ments for inservice testmg of valvas which are required to perform a specific function in shutting down a reactor to the cold shutdown condit.'on or in mitigating the consequences of an accident. Paragraph IWV-1200(b) exempts only those control valves that do not have a required safety function. Th;s position is clarified in ash 1E Code interpretation XI 1 59 and Generic Letter 89-04, Attachment I, Position-11.- These AFW pump minimum flow valves perform a safety function to close, ensuring full design flow to the steam generators and to open to provide minimum flow for pump protection. Therefore, these valves are not exempt frorn the requirements of Subsection IWV. Note: The IST Program currently does not recuire these valves to be tested open (See TER Section 5.25).

i These valves operate based on the AFW pump flowrate into the steam generators.

The valves' full stroke time is dependent on the AFW pump's operation, the flowlogic, and L the valve's condition.. hieasuring stroke times during AFW. pump operation would not provide an accurate assessment of the vaives ability to close. The licensee has stated, however, that the valves are exercised closed and fail-safe tested each cold shutdown, since AFW pump operation -is -not practical during plant operation.

The licensee should investigate measuring full stroke times during the cold shutdown fail-safe tests or quarterly in order to verify valve operational readiness and detect valve degradation.

a 26

.- --. ~. = - - - - -, - - -. -

a. - -.

Based on the determination that the valves can at least be full-stroke exercised during the fail-safe cold shutdown tests in accordance with AShlE Section XI, Paragraph IWV 3412, it is recommended that relief be denied.

3.2 AuxilianrSteam. Ileating Steam. Chilled and llot Water System 3.2.1 Chilled Water Pump's Discharge Check Valves, Relief Request No. VRR-31 3.2.1.1 Relief Requat: The licensee has requested relief from full stroke exercising the chilled water pumps' discharge valves, llV 00898A,0900A,00914A and 00916A (shared Unit I and 2), quarterly in accordance with ash 1E Section XI, paragraphs IWV-3521 and 3522.

3.2.1.2 Pmposed Alternate Testing: The licensee has proposed partial-stroke testing these valves quarterly and disassembling and inspecting each valve at least once every six years.

One vahe will be inspected every two years. If the disassembled valve is in a condition that would have prevented it from stroking full open, one additional valve will be inspected. If the second valve is found in a condition that would prevent it from stroking full open, the remaining two valves will be inspected.

3.2.1.3 Licensec's Basis for Relief: "There is no instrumentation available with which to measure system flowrate in order to satisfy the requirements of NRC Generic Letter 89-04

- Position 1, for full stroke exercising check vpives."

3.2.1.4 Evaluation: AShtE,Section XI, paragraph IWV-3522 requires, for valves that are to be tested to-the open position. confirmation that the disk moves away from the seat.

This can be determined by visual observation, an electrical signal initiated by a position

- indicating device, observation of substantially freeflow through the valve, or other positive means. The NRC staff believes that other positive means could include confirmation of valve disk position by qualified methods, including nan-intrusive methods, and _ valve disassembly and inspection. Position 2 of Attachment 1 of NRC Generic Letter 89-04 provides the criteria for utilizing valve disassembly and inspection as an alternative to full flow testing of check valves.. Partial valve stroking quarterly or during cold shutdowns is required, if possible. The NRC recommends, however, that other techniques such as non-intrusive test methods be utilized, instead of disassembly and inspection. Position 1 of

' to NRC Generic Letter 89-04 and the response to Question 8 in the hiinutes of the Public hieetings on Generic Letter S9-04 provide guidance on qualifying alternative

- techniques for meeting AShtE Code requirements.

The licensee has proposed to utilize-valve disassembly and inspection and partial-stroke exercising as an alternative to full stroke exercising. The licensee's disassem-bly/ inspection program does not comply with the criteria provided in Position 2 of the E

Generic Letter. The NRC juidelines for sample disassembly and inspection are as follows; 27

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"The sample disassembly and inspection program involves grouping similar valves and testing one valve in each group during each refueling outage. The sampling technique requires that each valve in the group be the same design (manufacteer, size, model number, and materials of construction) and have the same service conditions including valve orientation. Additionally, at each disassembly the licensee must verify that the disassembled valve is capable of full stroking and that the internals of the valve are structurally sound (no loose or corroded parts). Also, if the disassembly is to verify the full stroke capability of the valve, the disk should be manually exercised.

A different vahe of each group is required to be disassembled, inspected, and manually full stroke exercised at each successive refueling outage, until the entire group has been tested. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining vahes in that group must also be disassembled, inspected, and i

manually tull stroke exercised during the same outage.

Once this is completed, the sequence of disassembly must be repeated unless extension of the interval can be justified."

The licensee's proposal requires only one additional valve be inspected if the

. disassembled valve is not capable of being full stroke exercised. The licensee has not provided justification for not disassembling, _ inspecting, and exercising the remaining 3 valves in the group discussed in Position 2. Additionally, the licensee has not provided sufficient inidanation to asce-tain that the four valves are of the same design and sersice, that the valves will be manually exercised and internals visually inspected for worn or corroded parts, and that a different valve will be disassembled, inspected and exercised each refueling outage and the sequence will be repeated.

Therefore, it is recommended that relief from the full stroke exercise be granted in

accordance with Generic Letter 89-04 provided the licensee's inspection, disassembly, and inspection program was revised to conform with all criteria in Position 2 of the Generic Letter. The Generic Letter states: "The staff has determined that relief is granted to follow the alternate testing delineated in Positions 1, 2, 6, 7, 9, and 10, pursuant to -

'10CFR50.55a(g)(6)(i)." The licensee should investigate the use of non intrusive methods-to verify valve position. -Note: TER Section 2.7.1.4 recommends the licensee investigate the installation of flow instrumentation for pump testing. This would eliminate the need for this relief request.

_C.l emical and Volume Control System 3.3' l

3.3.1 Charging-Pump Discharge to Reactor Coolant Pump Seal Check Valves, Relief

. Request No. VRR-12 28 2; _ _

. ~

i 4

3.3.1.1 Relief Request: The licensee has requested relief from exercising the charging pump discharge to reactor coolant pump (RCP) seal check valves, CV-00304C and D (Units I and 2), quarterly in accordance with ASME Section XI, paragraphs IWV 3521 and 3522.

3.3.1.2 Proposed Alternate Testing: The licensee has proposed verifying the valves can fulfill their safety function to close during tl'] 10CFR50, Appendix J leak rate tests. These tests are performed at each refueling outage.

3.3.1.3 Licensce's Basisfor Relief: "These salves are normally open. They are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or backflow test. During plant operation, such testing would require securing the RCP's which is not practical. Performing such tests of these valves involves considerable effort and system re alignment such that routine testing during cold shutdown nutages is impractical."

3.3.1.4 Evaluation: These normally open check valves provide RCP seal water injection flom the charging pumps. The RCPs employ a controlled leakage seal assembly to restrict leakage along the pump shaft and minimize the leakage of reactor coolant into the containment atmosphere. The plant safety analysis (FSAR) states that the plant can be operated indefinitely without seal water injection flow since "the RCP thermal barrier cooler has sufficient capacity to cool the reactor coolant flow which would pass through the thermal barrier cooler and seal leakoff from the pump casing." Loss of injection flow will normally lead to an increase in the pump lower bearing temperature, an increase in the seal temperature and an increase in the No.1 seal _ leak rate. The thermal barrier cooler can prevent-bearing and seal temperatures from exceedin; the maximum tr. commended temperatures and thus possible seal failure, and a resulting unisolatable small break loss of reactor coolant accident. Therefore, the only safety related function of these valves is to close to provide containment isolation for the CVCS systein in the event of an accident.

However, although the pumps can operate with short term interruptions of seat injection flow (generally up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as recommended by the pump vendor), the increased potential of seal damage and pump bearing damage due to overheating and the,

introduction of crud from the RCS into the seals which can result in seal wear and subsequent failure makes it impractical to test the valves during pump operation.

Additionally, these valves are simple check valves which are located inside containment and are not equipped with position indication instrumentation. The only practical method available to verify closure of these valves is to perform a leak test, The test connections are inside containment which would require a containment entryin order to verify valve closure. Routine containment entries are not made during power operations due to high radiation levels and a potentially harsh environment. Performing this testing during cold shutdowns would subject plant personnel to increased radiation doses due to the extensive set up required to perform valve leak tests. The time required to set up and perform the leak test could result in a delay in plant start up which would be burdensome _ to the licensee.

It would be impractical to require the licensee to make containment entry 29

---

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quarterly during power operation or during cold shutdown in order to verify closure of these valves. The licensee's proposal to Appendix J. Type C, leak rate test these valves during refueling outages provides a reasonable assurance of their ability to perform their safety function in the clor d position.

Based on the impracticality of full stroke exercising these valves quarterly and during cold shutdowns, the burden on tha licensee if these Code requirements were imposed, and considering that the licensee's prope I to Appendix J. Type C, leak rate test these valves during refueling outages provides a reasonable assurance of their ability to perfonn their safety function in the closed position, it is reconunended that relief from exercising the valves quarterly be granted as requested pursuant to 10CFR50.55a(g)(6)(i).

3.3.2 Charging Line Containment Isolation Valve, Relief Request No. VRR 13 3.3.2.1 Relief Request The licensee has requested relief from exercising the charging line -

containment isolation check valves, CV 00370 (Units 1 and 2), quarterly in accordance with ASME Section XI, paragraphs IWV-3521 and 3522.

+

3.3.2.2 Proposer / Alternate Testing: The licensee has proposed verifying that the valves fulfill their safety function to close during the 10CFR50. Appendix J leak-rate tests, which are performed at each refueling outage.

3.3.2.3 Licen3ce's Basis for Relief: "This valve is normally open. It is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or backflow test. During plant operation, such testing would require securing the charging pumps which is not practical or prudent and could result in a plant trip if done. Performing such tests of these vahes invohes considerable effort and system re alignment such that routine testing during cold shutdown outages is impractical."

3.3.2.4 Eraluation: These valves are simple check valves located inside containment. They are normally open to supply charging water to the RCS. Their safety position is to close to provide containment isolation for the CVCS in the event of an accident. Since the valves are not provided with position indication instrumentation, the only practical means of testing this valve is a leakage test. The test connections are located inside containment and would require a containment entry to perform this test. Containment entries are not routinely performed during power operation due to the high radiation fields and potentially harsh environments.

Performing this test during cold shutdowns would subject plant personnel to high radiation levels and, due to the time required to perform this test, the shutdown could be extended which would be burdensome.

Therefore, it would-be impractical to require the licensee to perform this test quarterly during power operation or during cold,.hutdowns. Perfonning the Appendix J leak rate test during refueling outages provides reasonable assurance of the valve's ability to close and perform its safety function.-

30

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l Ilased on the impracticality of full-stroke exercising this check valve in acco; dance with the frequency required by ASSIE Section XI, the burden on the licensee if these rode requirements were imposed, and the determination that the licensee's proposed testing provides reasonable assurance of the valve's ability to perform its safety function in the closed position,it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i).

3.3.3 Charging Pump Discharge to Reactor Coolant Pump Nianual Throttle Valves, Relief Request No. VRR 19 3.3.3.1 Relief Request: The licensee has requested relief from exercising the charging pump discharge to reactor coolant pump (RCP) manual throttle valves, CWOO300 A and 11(Units 1 and 2), qu 'rterly in accordance with ash 1E Section XI, paragraphs IWW3411 and 3412.

3.3.3.2 Pmposed Altcenare 7'esting: The licensee has proposed to verify the valves can fulfill their safety function to close during the 10CFR50, Appendix J leak r,.te test, which will be performed at each refueling outage.

3.3.2 3 Licensce's Ba3is for Relief: " Exercising these valves during RCP operation would result in significant damage to the pumps. During cold shutdown periods, it is customary to maintain the RCP's in operation unless plant conditions required securing them. Thus, requiring the exercising of these valves would result in a considerable operational burden.

Note that these small manual valves are highly reliable with respect to their capability to close and exercising during refueling outages will adequately demonstrate their operability."

3.3.3.4 Eealuation: These normally open manual n::dle valves provide RCP seal water injection from the charging pumps. The RCPs employ a controlled leakage seal assembly to restrict leakage along the pump shaft and minimize the leakage of reactor coolant into the containment atmosphere. The plant safety analysis (FSAR) states that the plant can be operated indefinitely without seal water injection flow since "the RCP thermal barrier cooler has sufficient capacity to cool the reactor coolant flow which would pass through the thermal barrier cooler and seal leakoff from the pump casing." 1.oss of injection flow will normally lead to an merease in the pump lower bearing temperature, an increase in the seal temperature and an increase in the No. I seal leak rate. The thermal barrier cooler can prevent bearing and seal temperatures from exceeding the maximum recommended temperatures and thus possible seal failure and a resulting unisolatable small break loss of reactor coolant accident. Therefore, the only safety related function of these valves is to close to provide containment isolation.

However, although the pumps can operate with short term interruptions of seal injection (generally up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as recommended by the pump vendor), the increased potential of seal damage and pump bearing damage due to overheating and the introduction of crud from the RCS into the seals, which can result in seal wear and subsequent failures, makes it impractical to test the valves during pump operation.

Compliance with the Code would require plant shutdown and RCP isolation quarterly. The 31

licensee has not, however, provided sufficient infonnation and justification to support the relief request to not test these valses during cold shutdowns. There may be cold shutdowns when the RCPs are not running. Therefore, it is reconunended that relief from exercising the valves quarterly be granted in accordance with 10CFR50.55a(g)(6)(i) provided that the licensee exercise the valves closed during any cold shutdc s when the RCP are no.

running.

3.3.4 Boric Acid Transfer Pump Discharge to Charging Pump Suction Check Valves, Relief Request No. VRR 24 3.3.4.1 Relief RcqucSt: The licensee has requested relief from exercising the boric acid transfer pump discharge to charging pump suction check valves, CV-00351 (Units I and 2),

quarterly in accoidance with ash 1E Section XI. paragraphs IWV-3521 and 3522.

3.3.4.2 l'roposed Alternate Tc3 ting: Th 'icensee has proposed forward Gow exercising these valves during each refueling outage.

3.3.4.3 Licensce's Basis for Relicf: ' Testing these valves in the open direction requires the introduction of highly concentrated b~ic acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which would adsersely affect plant power level and operational parameters with the potential f.

an undesirable plant transient and a plant trip or shutdown. During cold shutdon the introduction of excess quantities of boric acid is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup."

3.3.4.4 Ecaluation: Full flo.v testing of these check valves quarterly, wot.ld require the injection of baron into the RCS during power operation. This would cause a power transient and may result in a reactor trip, making this test impractical. llowever, the licensee has stated that performing this test during cold shutdown is also undesirable. The licensee has failed to provide sufficient information and justification which demonstrate that the testing of these valves, in compliance with ASN1E Section XI, at every cold shutdown k

results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The proper actuation of these check valves is required to provide f

emergency makeup of borated water to the RCS.

Therefore, relief cannot be recommended. The licensee should provide additional justification to justify why the valves cannot be tested at any cold shutdowns.

3.3.5 Boric Acid Transfer Pumps Dischange Check Valves, Relief Request No. VRR-26 3.3.5.1 Relief Reynest: The licensee has requested relief from exercising the boric acid transfer pumps' discharge check valves, CV-00333 A and B (Units I and 2), quarterly in accordance with ash 1E Section XI, paragraphs IWV-3521 and 3522.

32 1

3.3.5.2 Proposed Altcmate Testing: ' The licensee has proposed full flow exercising there

- valves open each refueling outage during the pumps' tests. Additionally. the valves will be tested quarterly, however, the flow through the valve will not be known.

l 3.3.5.3 Licensec's Basis for Relieft "Fuil-stroke testing these valves requires operating the boric acid makeup pumps at or near rated flow and verifying full accident How through each valve. This can be perfonned during plant operation, however there is no inctrumen-tation available in the test loop by Ahich fluv can be measured.

Flow throut, the individual valves can be measureu Sy pumping into the charging i

pump suction header and measuring charging flow using installed instrumentation. This, however, requires the ir troduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the chargmg pumps. This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. Dur;ng cold shutdown, the introducticm of excess quantities of boric ac.d is undesirable trom the aspect c.f maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent ;tartup in over boration of the RCS. In addition to the above, there is no flow rate measurement instrumentation installed in this flowpath."

3.3.5 4 Evaluation: It is impractical to measure the Howrate through the boric acid transfer pumps quarterly during recirculation to the boric acid tank due to the lack of installed instrumenta: ion. The recirculation path is the only practical flow path to use when testing these pumps quarterly. The only other flow path is to the charging pumps suction. Testing through this flow path would require injection of baron into the RCS. Power tiansients nnd a reactor trip could result. In the request's " Basis," the licensee has stated in the second paragraph that flow into the charging pump suction will be measured "using installed instrumentation " The last line of that paragraph states that there is "no flowrate measurement instrumentation installed in this flowpath." This discrepancy shoulo be resolvM The licensee has stated that performing this tert during cold shutdown is also undesirable..The licensee has failed to provide sufficient inforraation and justification which demonstrates th.i testing these valves, m compliance with ASME Section XI, at every cold shutdown results in a hardship or unusual difficulty without. a compensating increase in the level of quality and safety. Therefore, relief caunot be recommended. The licensee should evaluate the use of oiher techniques, such as non-intrusive methods to-verify valve position during the quarterly testing as discussed in ' Generic Letter 89-04, 1 Attachment 1, Position 1.

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m 3.4 Component Cooling _ Water System 3A.I' Component Cooling Water to RCP Check Valves, Relief Request No. VRR-10 3.4.1.1 Relief Re:/urst The licensee has requested relief from exercising the component cooling water to the reactor coolant pump (RCP) check valves, CC-00755 A and B (Units 1 and 2), quarterly in accordance with AS\\tE Section XI, paragraphs IWV 3521 and 3522.

3.4.1.2 Pmposed Alternate Testing: The licenn e has proposed exercising these valves closed during the 10CFR50, Appendix J leak tests.

3.4.1.3 Licensce's Basis for Relich "These are simple eneck valves with no external means of position indicatica, thus the only practical means of verifying closure is by perfonning a leak test or backflow test. During plar.t operation, such testing would icquire accuring the RCP's which is. not p;actical.

Performing such rests of these valves involves considerable effort and system re alignment such that routine 'esting during cold shutdown outages is impractica)."

3.4.1.4 Craluation: These valves are simple, normally open check valves located inside containment. They provide cooling _ water to the RCP motor bearing cooler and thermal barrier cooling coil. Their safety position is to close to provide containment isolation. The valves are not provided with position indication. The only practical means of testing these valves is a leakage test. The test connections are located inside containment and would require a containment entry to perform this test. Containment entries are not routinely l

performed during power operation due to the high radiation fields a; d potentially harsh l

environments. Additionally, the assceiated RCP must be stopped when exercising these valves, because loss of coeug water during pump operation could cause degnidation of the pu'.np seals and bearings and eventually pump failure or small loss of coolant through the seals. Although the RCP are not required to operate, (i.e., they are not act!vely safety related) they provide a pasive safety related function to maintain the reactor coolant pressure boundary. It would be burdensome to require the licensee to perform a plant shutdown quarterly in order to establish plant conditions that allow the RCP to be stopped.

i

- Performing this test during cold shutdowns would subject plant personnel to high radiat on levels and, due to the time required to perform this test, the shutdown could be extended.

L Therefore, it would be impractical to require the licensee-to perform this test quarterly L

during po'ver operation or during cold shutdowns. Perfonning-the Appendix J leak rate l

test during refueling outages provides reasonable assurance of the valve's ability to close L

and perform their safety function.

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Based on the impracticality of exercising these check valves in accordance with the L

frequency. required by ASME Section XI, the-burden -on the licensee if these Code requirements:were. imposed, and the determination that the licensee's proposed testing provides reasonable assurance of the valve's ability to perform their safety function in the closed position, it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i),

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- 3.4.2-Component Cooling to Excess Letdown lleat Exchangers Check Valves, Relief t

Request No. VRR-30 1

3.4.2,1 Relief Request: The licensee has requested relief from exercising the con ponent cooling water ta the excess letdown heat exchanger check valves, CC-007d7 (Umts 1 and 2); quarterly in accordance with ASME Section XI, paragraphs IWV-3521 and 3522.

3.4.2.2 Proposed Alternate Tcsting: The li:ensee nas proposed exercising these valves closed' during the 10CFR50, Appendix J leak tests.

3.4.2.3 Licensce's Basis for Relief: "These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or backflow test. Performing such tests of these valves involves considerable effort and system re-alignment such that routine testing during plant operation or cold shutdown outages is impractical."

q 3.4.2 4 Evalumion: These normally open valves are simple check valves located inside containment. They provide cooling water to the chemical and volume control excess letdown heat exchangers. Their safety position is to close to provide containment isolation.

The valves are not provided with position indication. The only practical means of testing these valves is a leakage test. Tim test connuctions are located inside containment and would require a. containment entry to perform this test. Containment entries are not

. routinely performed during power operation due to the high radiation fields and potentially harsh environments.- Performing this test -during cold shutdowns would subject plant personnel to high radiatior levels, and due to the time required to perfonn this test, the

- shutdown could be extended whirn would be burdensome, it would be impractical to require the licensee to perform this test quarterly during power operation or during cold shu tdowns. Performing the Appendix J leak rate test during refueling outages provides reasonable assurance of the valves

• ability to close and perform their safety function.

Based on the impiacticality of exercising these check valves in accordance with the frequenmf required by ASME Section XI, the burden on the licensee if these Code requirements were imuosed and the determination that the licensce's proposed testing provides reasonable assurance of the valves

• ability to perform theli safety function in the closed position,it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i).

3.5 Containment Sprav System

- 3.5.1 Refueling Water Storage Tank to Containment Spray' Pumps Suction Check Valves, Relief Request No. VRR-8 e

i 3:5.1.1 Relief Request: The licensee has requested. relief from full-stroke exercising the Refueling Water Storage Tank (RWST) to contaimnent spray pump suction check valves, 35 e

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SI-00856 A and B (Units 1 and 2), quarterly, in accordance with ASME Section XI, paragraphs _IWV-3521 and 3522.

3.5.1.2 Maposed Alternate Testing: The licensee has proposed partial-stroke exercising the valves during plant operation and disassembling and inspecting each valve during refueling outages _

3.5.1.3 Licensee's Basis for Relief: " Full stroke exercising of these valves would require operating the containment spray pumps at nominal accident flowrate and spraying into the containment. building. since no full flow recirculation path exists.

This is obviously impractical and undesirable."

3.5.L4 Evaluation: These valves are required to open to allow water fron, the RWST to the containment spray pump section. The system test line will permit partial stroke exercising quarterly. Ilowever, the only full flow path is into the containment spray headers ud utilizing this pathway is impractical due to the potential containment equipment damage and extensive cleanup required. Compliance with the Code requirements would require the installation.of a full-flow test loop. The licensee is proposing to utilize

' disassembly and inspection as a means to determine the valve will perform i:s safety function to open. It is acceptable to utilize disassembly and inspection provided that the i

program meets all the criteria established in Generic Letter 89-04, Position 2 of Attachment 1, including performing a partial stroke exercise quarterly or during cold shutdowns, if

. possible, and. after reassembly and manually exercising une disk. The NRC, however, recommends that other techniques such as non intrusive test methods be used to verify full-stroke opening in lieu of disassembly. Position 1 of the Generic Letter provides criteria on

- establishing alternate test programs.

The licensee has not described the disassembly and inspection program in sufficient detail to ascertain that it meets all the criteria established in Position 2 of Generic Letter 89-04.

Provided the licensee's program does meet Position 2, a positwe:means of determining the valve disk will full-stroke exercise is achieved and relief can be granted in accordance with Generic Letter 89-04.

The Generic L.etter states:

"The staff has determined that relief is granted to follow the alternate testing delineated in Positions 1, 2, 6, 7, 9, and _10, pursuant to 10CFR50.55a(g)(6)(i)."

3.5.2. Containment Spray Nozzles' Supply Check Vnives, Relief Request No. VRR-9 3.5.2.1 Relief Rcquest: _ The licensee has requested relief from full stroke exercising the-containment spray nozzles supply check valves, SI-00862A and B (Units I and 2), quarterly

. in accordance with ASME 5ection XI, paragraphs IWV-3521 and 3522. Note: The valve function described in the request is inconcet (see TER Section 5.29).

3.5.2.2 Proposed Alternate Testing: The licensee has proposed disassembling and inspecting the valves at refueling e,itages and performing 10CFR50, Appendix J leakag,e tests.

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3.5.2.3 Licenseci Basis for Relief: " Full or part stroke exercising of these valves would L

require operating the containment spray pumps at normal accident flowrate and spraying l/

into the containment building since no recirculation path is available. This is obviously impractical and undesirable.

These are simple check valves with no external means of position indication, thus L

the only practical means of verifying closure is by performing a leak test or backflow test.

Performing such tests of these valves involves considerable effort and system realignment such that routine testing during plant operation or cold shutdown outages is impractical."

3.5.2.4 Evaluation: These valves are required to open to allow the contaimnent spray system to depressurize and cool the containment, given a loss of coolant accident, and to l~

rapidly reduce fission product iodine contentration in the containment atmosphere. In a'ddition, they must close to provide containment isolation. It is impractical to full-stroke exercise these valves open with flow because equipment in the containment would be damaged and an extensive cleanup would be required. The licensee has stated that there is no test recirculation path available. Upon review of drawings 110E035 and 110E017, it appears that a test line is available through valves 864A and.B for a partial-stroke test.

Compliance with the Code full stroke requirements would require the instrumentation of a full flow test loop, which is burdensome.

The licensee is proposing to utilize disassembly and inspection as a means so determine that the valve will perform its safety function to stroke open, it is acceptable to utilize disassembly and inspection provided that the program meets the criteria l.

essablished in NRC Generic Letter 89-04, Position 2 of Attachment 1, including performing a partial stroke exercise quarterly or during cold-shutdowns, if possible, and after reassembly. The NRC, however, recommends that other techniques such as non intrusive test methods be used to verify full-stroke opening in lieu of disassembly. One option the licensee,may consider is to stroke exercise the valve using air with non intrusive diagnostic m:thods to verify valve disk movement.

The licensee has not described the disassembly and inspection program in sufficient ddtail to ascertain that it meets all the criteria established in Position 2 of Generic Letter 89204. Provided the licensee's program meets all the criteria provided in Position 2 of the Generici Letter. including performing a partial-stroke exercise, a positive means of determining the valve disk will full-stroke exercise is achieved and relief can be granted in L

accordance. with Generic Letter 89-04.

The Generic Letter states:

"The staff has determined that relief is granted to follow the alternate testing delineated in Positions 1,

.2,6,7,9, and 10, pursuant to 10CFR50.55a(g)(6)(i)"

Based on the check valves' design, the only practical ruethod of verifying the valves are in the closed position is by a leakage test. These velves and the test connections are located outside containment. The licensee has not provided sufficient justification of the

. hardship resulting from testing these valves quarterly or during cold shutdcwns. Itis, l

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therefore, recommended that relief from performing backflow testing of these valves be denied.

3.6 Emercency piesel Generator Air Start System 3.6.1 Emergency Diesel Generator Air Starting hiotors' Starting Valves, Relief Requect No.

VR R-17.

3.6.1.1 Relief Request: The Licensee requests relief from exercising the emergency diesel generator air starting motor's starting valves, DA-03057A and B and DA-3058A and B shared by Units I and 2, in accordance with AShlE Section XI, Paragraphs IWV-3413 and IWV-3417, which require measurement of stroke time for all power operated valves whenever the valve is full stroke tested.

3.6.1.2 Proposed Alternate Testing: In lieu of performing the tests required by ash 1E Section XI, Paragraph IWV-3413, the licensee proposes to perform a monthly valve stroking test performed in conjunction with the associated emergency diesel generator start testing. Valve stroking parameters will be considered acceptable upon diesel generator start. If the diesel generator fails to start, at no fault of the respective valves, the valve stroking parameters will be considered acceptable, and will be proven with the diesel generator restart following corrective action.

3.6.1.3 Licensee Basis For Relief: "These are enclosed air-pilot operated valves with no remote _or local position indication and where the valve design prohibits visual observation of valve operation or position. Thus, stroke time measurements are not possible. Failure of a valve to operate properly would result in unacceptable start and operation of the associated diesel generators."

3.6.1.4 Evaluation: These valves are not equipped with position indication and vah: stem movement cannot be observed, therefore, it is impractical to measure valve stroke time using conventional techniques.

. In order to test these valves in accordance with AShiE Section XI, significant g

L modifications to the system would be required; including possible valve replacement. These L

modifications l would be burdensome for the licensee and' would allow only a' limited

-increase in valve degradation data.

L These valves operate to admit starting air to the emergency diesel generators starting

- ir motors. Each generator is capable of starting by either one of two pairs of air motors.

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. A selector-switch _ determines which ' pair of air motors are activated first on the diesel linitiationi signal. If the diesel fails to start after 3 seconds, a failure alarm comes on and the diesel will attempt to start using both pairs of starting motors. The air-operated valve's p

opening can indirectly be verified by monitoring the diesels start times. Any degrachtion in the valves stroke time would result in longer diesel start times. A maximum, allowable 38 l?.

start time should be specified. This limiting value should be less than or equal to the

-Technica! Specification. requirement.

Therefore, the licensees proposed-testing of measuring -the diesel generators start times should provide indication of the valves' operation and allow degradation detection.

J Therefore, based on the determination that compliance with the Code requirements in~ impractical and considering the burden on the licensee if the Code requirements were imposed; it is recommended that relief from measuring valve stroke time be granted pursuant to 10CFR50.55a(g)(6)(i), provided the licensee assigns a maximum limiting diesel start time and verifies the operational readiness of the valves in each air start bank at least quarterly by alternating the air motor bank selected during diesel testing.

3.6.2 Emergency Diesel Generator Air Start Valves, Relief Request No. VRR-25 3.6.2.1 Rclicf Reque.st: The licensee has requested relief from full-stroke e),ercising the emergency diesel generator air start check valves; DA-00125,126,225,226 (shared by Units I and 2),in accordance with ASME Section XI, paragraphs IWV-3521 and 3522, and stroke time exercising the emergency diesel generator air start solenoid valves, DA-06316A and B,6317A and B,6313A and B,6319A and B (shared by Units I and 2),in accerdance w;th paragraph IWV-3413.

3.6.2.2 Proposed Alternate Testing The licensee has proposed exercising these valves in conjunction with the diesel generator tests. Stroke times of the solenoid valves and

- flowrates :hrough the check valves will not be measured. The starting times for each diesel L

generator will be verified.

g 3.6.2.3 Licensec's Basisfor Relief: "These valves are integral (skid mounted) with the diesel air start system for each emergency diesel generator with no valve position indication

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mechanism, and, ns such, there is no practical method for measuring the stroke times or flowrates of each individual valve. If a valve were to fail to stroke as required it 4vould be

- reflected in an unacceptable starting time and/or performance of the respective diesel genera tor."

3.6.2.4 Evaluation: These valves are not equipped with position indication and valve stem movement-cannot be observed, therefore it is impractical to measure otroke time or determine check valve disk position using conventional techniques. Additionally, the re are no flowmeters installed to verify full-flow check valve st oking.

L In order to test these valves in accordance v,;C ASME Section XI, significant modifications to the system would be required; including possibly solenoid valve replacement. These modifications would be burdensome for the licensee and would be only

- a limited increase in valve degradation data.

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These valves operate to admit starting air to the emesgency diesel generators starting air motor. Each generator is capable of starting by either one of two pairs of air motors.

A selector switch determines which pair of air motors are activated first on the diesel initiation signal. If the diesel fails to start after 3 seconds, a failure alarm comes on and.

the diesel will attempt to start using both pairs of starting motors. The fast. acting solenoid j

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. va ve s open ng can indirectly be verified by monitoring the diesels.; tart times. Any i

degradation in the solenoid valves stroke time or check valves full opening would result in longer diesel start times. A maximum, allowable start time should be specified. This limiting value should be less than or equal to the Technical Specificatien requirement.

Therefore, the licensees proposed testing of rneasuring the diesel generators start 'imes should provide indication of the solenoid and check valves operation and r.Ilow degradation detection.

Therefore, based on the (;etermination that compliance with the Code requirements

'in impractical and considering the burden on the licensee if the Code requirements were in posed, it is recommended that relief from full stroke exeicising the air start check valves and stroke time exercising the calenoid valves be granted pursuant to IOCFR50.55a(g)(6)(i), provided the licensee assigns a maximum limiting diesel start time and' verifies the operability of the valves in each air start bank at least quarterly by alternating the air motor bank selected during diesel testing.

3.7

_ Emergency Diesel Generator Fuel Oil System 3.7.1 Emergency Dies el Fuel Oil Transfer Pumps' Discharge Valves, Relief Request No.

VR R-33 3.7.1.1 Relief Retprest: TI.e licensee has requested relief from full-stroke exercisirig the fuel oil transfer pumps discharge pressure control valves. FO-03940 ano 03941 (chared by linits I and 2), in accordance with ASME Section XI paragraph IW%3412.

3.7,1,2 Propesed Ahernate 7'esting: The licensee has proposed verifying valve disk movement by monitoring system operating oarameters.

3.7.1.3 Licenace's Sasisfor Re/lef "Since these are essentially back-piessure regulating valves requiring no outside source of power to operate, they are exempt from stroke time measurements per IWW3413, howeser, it is not practical to perfoim a full stroke test since the position of the valve dise cannot be determined visually or by any other practical means.

L Considering the type and function of these valves, an operational (functional) test i

is an effective way of ascertaining the condidon of the valves and proving their operability."

3.7.1.4 Evahenion: ASME Section XI. paragraph IWV-3412 requires valves to be exercised to the position required to fulfil their function. The necessary valve disk movement shall be determined by exercising the valve while ob3erving an appropriate indicator or observing 40

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t iudirect evidence (such as changes in system pressme. flow rate, leve!, or temperature) which reflect stem or disk position. Although the subject valves position cannot be determined directly, each valves' position both open an ! closed, can be determined indirectly based on the emergency fuel tank level changes and pump discharge pressure.

Therefcre, the requirements of paragraph IWV-3412 can be met.

Paragraph IWV-3413 applies to power operated vahes only. Measurement of full-stroke times is not required for self activating centrol valves. Therefore, relief nom Code requirements is not required.

3.8 Ileatine and Ventilation System 3.S.1 Containment Atmcspheric Monitoring System Containmer.. Isolation Valves, Relief Request No. VRR-16 3.S.1.1 Relief Request: The licensee has requested ielief from exercising the containment atmospheric monitoring system return check valves. RM-03'00AA (Units i and 2),

quarterly in accordance with ASME Section XI, paragraphs IWV 3521 and 3322. Note:

The valve numbera do roi appear on the referenced draw:ngs. The reviewer has assumed that the val,'es addressed in the relief request are the " check valves located in the drav.ing coordinates G-3" referenced in the IST Valve Program Tables, Appendices D and E, that do not have their internals removed.

3.8.1.2 Proposed Alternate Testing: The licensee has proposed exercising these vaiws to the closed position during the 10CFR50. Appendix J leak tests.

3m.l.3 Lic nsec's Basis for R(lief: "During normal plant operation, gases from a coatinuous sampling system return sample flow to the contaimnent through these lines / valves. To test these valves during operation or cold shutdewn, it would be necessary to discharge potentially radioactive gases to the enviroament. There is no mechanism to partiai stroke these valves "

3.8.1.4 Evaluation: These valves are simple check valves located inside containment that are normaily open. Their safety position b to close to provide containment isolatior Tne valves are not provided with position indication The only practical means of test ng these i

valves is a leakage test. The test connections are located inside coatainment and would j

require a containmerit entry to perform this test. Coatainme".t entries are not toutniely performed daring power operation due to the h'gh radiation fietris and potentially harsh envh onments. Perfonning this test during cold shutdowns would L burdensome due to the time required to perform this test, and the pctential for extenomg the shutdown. It would be impractical to require the licensee to perform this test quarterly during power operation or during cold shutdowns. Performing the Appendix J leak rate test during refueling outages provides reasonabk arsurance of the valves' abi:ity to close and perfonn their safety function.

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Based on the impracticality of exercising these check salves in accordance with the frequency required by ASME Section XI, the burden on the licensee if these Code requirements were imposed and the determination that the licensee's proposed testing provides reasonable assuiance of the valve's ability to perform it's safety function in the closed position,it is reconunended that relief be granted pursuant to 10CFR50.55a(g)(6)(1).

3.9 Instrument Air System 3.9.1 lustrument Air Check Valves To Purge Vane Boot Seals, Relief Request No. VRR-14.

3.9.1.1 Relief Request: The licensee has requested ielief from testing the instnunent air check ' valves used to purge valve boot seals; IA.00644,645,1280,1281 (Unit 1) and 00876,877,1401,1402 (Unit 2); in accordance with ASME Section XI, Paragraph IWV-3424, which requires valve leakage to be determined by either measuring leakage directly or measuring the feed rate required to maintain test pressure.

3.9.1.2 noposed Allemate 7'esting: In lieu of leakage tests required by ASME Section XI, paragraph IWY-3424, the licensee proposes to test for valve leakage by measuring pressure decay in the test volume. All detected leakage will be assigned to the valve being tested.

Differential pressure will be applied in the same direction as when the valve is performing

- its function.

3.9.1.3 Licensee Basis For Relief: "There are other acceptable techniques available which demonstrate leak rates through valves.

OM Part 10,~ Section 4.2.2.3 describes such techniques."

3.9.1,4 Evaluatian: These Category A!C check v.dves open to provide air to inflate the purge valve boot seals and, upon loss of supply air pressure, close to maintain the boot seals inflated.- The !icensee has requested relief from the ASME Code specified methods for determining leakage through these check vahes. As specified in ASME Section XI, paragraph IWV 3424, valve leakage is to be measured directly or b measuring the feed f

rate required to maintain test pressure.

The mam purpose of an in-senvice testing program is to identify valve degradation.

While the methods specified by ASME Section XI are valid test methods to determine check vahe leakage, there are other equivalent test methods which also will detect and quantify leakage.

ASME/ ANSI OMy1988, part 10, Section 4.2.2.3 describes such techuiquet. Specifically, these are by 1) measuring leakage through a downstream telltale connection while maintaining test pressure en one side of the valve, or 2) measuring _the feed rate required to maintain (est pressure in the test volume, provided the total apparent leakage rate h charged to the valve being tested, or 3) determine leakage by measuring pressure decay in the test volume; piovided the apparent leakage rate is charged to the valve being tested.

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c The licensee proposes to ascertain valve leakage by measuring pressure decay in the test volume. All leakage will be assigned to the valve being tested. Test pressure will be applied in the same directio_n' as when the valve is performing its function. This is an acceptable alternate test method rs specified in Ohl, Part 10. Scction 4.2.2.3, which meets the intent of AShlE Section XI, and provides an acceptable level of quality and safety.

Based upon the. equivalence of the proposed test methods, and given that the licensee will perform these tests at the required t vo year frequency, it is recommeaded that i

relief from measurmg leakage directly or measuring the feed rate required to maintain test pressuie be granted pursuant to 10CFR50.55a(a)(3)(i).

3.9.2 PORV instrument Air Supply Cheet Valve, Relief Request No. VRR-3e.

3.9.21 Relief Requc3t:

a ne licensee has requested relief from seak testing the PORV instrument air supply checi ulves; l IA-01206,01209,01605.01606 (Unit 1) and 2 IA-01335,01338,01652,01653 (Unit 2) in accordance with AShlE Section XI, paragraph IWV-3420. Note: The request and Appendix D identifies valve 1 IA 01600. Ilowever, based i

on a review or drawing N1-209, Sheet i1, Revision 15, the correct valve number appears to be 1-IA-01605 (see TER Section 5.3).

3.9.2.2 Alternarc Testing: The licensee has proposed performing a icak test with two valves in series.

3.9.2.3 Licensec's Basis for Relicp" The plant configuration for these valves is suel: nat two -

l valves are installed in series with no test cormeetion in the common piping between tiiem that could be used to test ttie valves individually. The function of closure and isolation can be accomplished with only one v dve, thus if either valve has acceptable leak-tight integrity, then the system remains fully functional.

Testing two valves in combination adequately demonstrates thc functional adequacy of the system.

Note 'ihat these valves are included in the testing program for information and 3_

tracking purposes and do not strictly meet the requirements of IWV-l RW for inclusion."

3.9.2.4 Evaluation:These simple check valves isolate the PORV pitrogen accumulators from u

the normalinstrument air system. The PORVs are required to prevent over pressurization f

of the Reactor Coolant System during both normal operajion and low temperature water solid cperntion.

Tne valves are not provided with a position incl;cating device. TLere are no drain, vent, or test connecticas installed between these series velves to -individually verify the closure of each vaWe. Individually testing the valves is iequired in accordance with Section XI, unless the safety analysis does not require both check valves to i: alate the instrument 43 l

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system. lea testing the valves in series will verify that at least one of the two valves is capable of closing, but provides no indication about the condition of the other valve.

System modifications v.;ould be requned to individually test each valves capability to perform its saf.:ty function. The licensee has stated that only ane valve is required to isolate the instrument system to fulfil the system's function.

Therefoie, based on the burden on the licensee if the Code requirenients were imposed and considering the licensee's pioposed alternative provides reasonable assurance of operational readiness, relief could be recommended.

i The licensee has stated howevm, that these valves are inrinced in the IST Program for information and tracking purposes only. They are identified for testing per NRC Genetic Letter 90-06 and "must (sic) not satisfy the requirements of Subsection IWV or Generic Letter 89 04." (See TER Section 5.17) Non-Code components may be inchided in the ASME Code IST Piagram, as this program is a reasonab'e vehiclr to provide a perioctic demonstration of the operability of pumps and valves. However, if non-Code components are included in the Code IST Propam and certain Cede provisions cannot be met,10CFR50.55a does not require a request f relief to be subirdtted to the staff.

Documentation that provides assurance of the continued operability of the non-Code components that are important to safety through the pe> formed tests should be mailable at the plant site.

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Therefore, no relief is required.

3.10 Main Feedwater System A10.1 Main Feedveater Check Vahes to Steam Generators, Paliel Request No. VRR-21.

3.10.L1 Rc/lef Request:

The licensee has requested relief from uercising the inain feedwater system check ra',es to the steam generators, CS-00466 AA & BB and CS 00476 AA & DB (Units I ami 2), quarterly in accordance with the requirements of ASME Section XI, paragraphs IWV-145,?! and 3522.

3.10.1.2 Proposed Alternate Testing: The licensee has proposed verifying that each set of series check valves fulfiil their. safety functions through a leakage test to be performed during each refueling outr.ge. Valve closure oi at least onc of the two in 'ine series check valves will be verified. Additional information on the condition of the valves will be obmined through a periodic disassea51y and inspection of each vahe.

3.10.1.3 Licensees Basis For R4/icf: "1here are no position indicators on these valves nor are there any pressure taps between the valves. It is therefore not feasible, with the present plant configuration, to verify individual valve closure. Clesure of at least one of the two series check valves can be verified by uwasuring the dif ferential pressure across, or leal age

?

- past the combination of both vakes. This is adequate to ensure the safety function of the i

vahe combination is maintained and veiified.

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Prompt seating of each va!ve on cessation or reversal of flow cannot be verified at i

l the instant of closure since no direct indication of valve dise position is available. Valve testing can be conducted enly during Unit shutdowns since the flow of main feedwater to the steam generators must be secured in order to perform the tests,"

3.10,1,4 &aluation: These main feedwater series check valves are located upstream of the auxiliary feedwater injection line to the steam generators. These check valves are open during normal plant operation, and close upon reversal of flow to ensure that the auxiliary feedwater flow is unimpaired to at least one of the two steam geneiators while main feedwater is unavailable. The check valves also prevent dimultaneous blowdown of both steam generators in the event of a main feed pipeline failure. Appendix D identifies these valves as Category A/C, As such, seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their function (Reference paragraph IWV-2100(a)).

4 Since there are no position indicators on these check valves, or pressure taps between them, it is not poasible to verify individual valve closure as discussed in the relief request or valve leakage as required by IWV 3420. Individual verification of each valve's closure and leak tight capability would require s!gnificant system modifications. The licensee plans to conduct a test for each set of series check valves during Unit shutdowns.

After flow is secured, the differential pressure across or the leakage past the valves will be measured and evahiated with respect to system operability and its capability to perform the safety function.

The purpose of an in rervice testing program is to monitor each individual check valve for degradation. The preposed series leak test provides infonnation on the closure of one or both of the valves, but does not allow for condition monitoring of each individual valve. The licensee should review the safety analysis for each Unit to ensure that only one of the two series check valves is required to function. If the safety analysis assumes that only one of the two series check valves is required to function, each set of two series redundant valves could be treated as one for testing purposes.

The proposed testing frequency of each Unit shutdown is not in compliance with

. ASME Section XI, paragraphs IWV.3521 and 3522. The Code. specifies that check valves shall be exercised to the position required to fulfill their function at a frequency of once every 3 months, if not practical, the Code allows for extendmg tha tent frequency to cold shutdowns: The licensee has requested relief from this requirement by specifying that the testing will be conducted during refuehg outages. However the " Basis for Reliel" states that testing will be conducted during Unit shutdowns, when the flow of the main feedwatei to the 3 team generators is secured. Additional justification is required before relief from exercising the valves during cold shutdowns can be granted.

Acceptable methods which may be used to verify Category C valve closure include visual observation, electrical signal initiated by a position indicaung device, observation of 45 v

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e appropriate pressure indication in the system, leak testing, or other positive means. The proposed additional disassembly and visual examination program detailed by the licensee will provide additional pertinent information on valve condition.110 wever, as discussed in the Minutes of the pulilic meetings on Generic Letter 89 04, valve disassembly and inspection is not an acceptable method for the demonstration of leak-tight integrity.

Due to the impracticality of individually kak testing the valves with current system configuration, an interim period is necessary to provide the licensee time to complete the safety analysis review, make changes to the test procedure, anJ perform the necessary system modifications, if required, Immediate compliance could result in declaring the 4

valves inoperable, and initiating a plant shutdown to either perfann testing by methods not yet developed or perform system modifications that may be unnecessary based upon the safety analysis review. It is recommended that an interim relief period of one year or until the next refueling outage, whichever is later. be gianted in accordance with 10CFR50.55a(a)(3)(i), provided the licensee performs leakage tests of each set of valves during cold shutdowns and that both valves in the pair are declared inoperable and sepaired or replaced if excessive leakage is detected during testing. The proposed alternate program of testing each series of check valves, with the provisions previously mentioned, provides an acceptable level of quality and safety in the interim period. The relief rec,uest should be revised to address Category A leak test requirements, in addition to valve closure requirements, as it appears these requirements cannot be met. Appendices D and E identify these valves as Category NC and refer to this relief request for leak testing.

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3.11 Main and Reheat Steam Svstem 3.11.1 Rapid Acting Valves, Relief Request No. VRR-1 3.11.L1 Rehef Request: The licensee has requested relief from testiiig rapid-acting valves in accordance with ASME Section XI, paragraph IWV-3417(a).

3.ll.L2 Proposed Alternate Testingc The licensee has proposed assigning a maximum limiting full stroke time of 2 seconds and upon exceeding this limit, the valve will be

-- declared inoperable ami corrective action will be taken in accordance with paragraph IWV-3417(b),

3.11.1.3 Licensee's Basisfor Relief: "The stroke time measurements taken during testing of fast-acting valves (those less than 2 seconds) are subject to considerable variation due to conditions unrelated to the material condition of the vahe (e.g., test conditions, operator reaction time). In accordance with Reference 2.8, Position 6 [ Generic Letter 89-04], an alternate method of evaluating stroke times is considered acceptable."

i 3.11.1.4 Eraluation:

An acceptable alternative to the stroke timing requirements of paragraph IWV-3417(a) for rapid-acting valves (normal stroke times of 2 seconds or less) is provided in Generic Letter 89-04, Attachment 1, Position 6. The licensee's proposed 46 e-m-.~

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m.mm m...,

testing-meets this position.

Therefore, it is recommended that relief be granted in accordance with Generic Letter 8941.

The Generic ' l.etter states:

"The st: ff has determined that relief is granted to follow the alternate testing delineated in Positions 1, 2, 6, 7, 9, and 10, pursuant to 10CFR50.55a(g)(6)(i)."

The relief request states that it is gener!c. Ilowever, it specifically lists valve hts-020S2 as the only component to which it applies. Despite this inconsistency, generic relief is recommended.

3.11.2 Service-Water To Auxiliary Feedwater Pumps Solenoid Operated Valves, Relief Request No. VRR 20, 3.11.2.1 Relkf Revac3t: The licensee has requested relief from exercismg the auxiliary feedwater pumps cooling water solenoid vahes, hts-02090 (Units 1 and 2), in accordance with ash 1E Section XI, Paragraphs IWY 3413 and IWV-3417.

3.11.2.2 Proposed Alternate Tc; ting: In lieu of measuring stroke time, proper operation of the valves will be determined by observing pump bearing cooling water pressure and bearing temperatures. Failure of the valves to operate properly would result in a loss of bearing co61ing water pressure at the bearing cooling water inlet.

3.11.2.3 Licensee Basis for Relief: "These are enclosed solenoid-operated valves with no remote or local position indicati: n and where the valve design prohibits visual observation cf valve operation or position. Thus stroke time measurements are impractical.

Failure of a valve to operate proper!y_would result in a lack of bearing. cooling water pressure at the bearing cocling water inlet."

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3.11.2.4 Evaluation: The purpose of an inservice testing program is to monitor each of the solenoid operated valves for degradation.

In accordance with ash 1E Section XI,

_ paragraphs IWV-3413 and 3417, the stroke time of all power operated valves shall be specified by the licensee. For small solenoid operated valves with a strake time of ten seconds or less, measurements are to be made to the nearest second, if an increase in stroke time of 50% or more is found from the previous test, the licensee is required to increase the test frequency to once per month, until the valve is repaired.

For small solenoid operated valves, such as these, the NRC has recognized that stroke time measurement is difficult, since the valves actuate and stroke normally in two seconds or less.- Generic Letter 89-04, Position 6, " Stroke Time hicasurement for Rapid Acting Valves," provides an acceptable alternative to the Code requirement of comparing stroke times to previous tests, by allowing a maximum stroke time of two seconds for these

. valves.

The licensee has requested relief f om these stroke time measurements due to the absence of remote and local position indication instrumentation, as well as the lack of

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m, visual observation of valve operation and position due to the valve design. In lieu of these tests, the licensee will monitor the pump bearing cooling water pressure and bearing temperatures during the testing of the associated auxiliaiy feedwater pump. The licensee has proposed that acceptable measurements of these parameters will be indicative of proper valve operation Although no position indication is available on these valves, there are non-intrusive test uethods which can oc employed to provide stroke time measurements within two seconds, allowing for data collection inconsistencies. hicasurement of stroke time for these valves is impractical given the current design and test methods customarily used, however it may not be impractical using other test methods. Valve cxercising with no limit on actuation time does not meet the intent of the ash 1E Code for full stroke time testing of the valves.

These valves are normally closed and are required to epen upon start of the auxiliary feedwater pump. hionitoring downstream pump bearing temperature and pressure provides much delayed information on the position of the vd.e. The licensee should evaluate testing these valves while the pumps are not running by isolating and draining the y

downstream piping and then opening the valves.

If the Code requirements were immediattly imposed, a plant shutdown to perform the testing by methods not yet deseloped may be requnmd. An inttrim period is necessary to provide the licensee time to evaluate alternate :est methods and determine a means to measure the stroke time of ranid acting solenoid valves. Provided the proposed alternate testing plan is performed quarterly, and if any degradation in these valves is noted, corrective action is taken and the valves declared inoperable; an acceptable level of quality and safety will be provided for the interim period.

It is recommended that an interim relief period of one year, or until the next refueling outage, whichever is later, be granted in accordance with 10CFR50.55a(a)(3)(i),

provided the licensee tests these valves quarterly, and if aq, degra<!ation in these valves is noted, corrective action is taken and the valves declared inoperable.

3.12 Post-Accident Containment VentjMouitoring_ System 3.12.1 Post-Accident Containment Vent Containment Isolation Valves, Relief Request No.

VR R-34 3.12.1.1 Relief Request: The licensee has requested relief from exercising the post-accident containment vent manual containment isolation valves, H2-V-01,05,12,13,19,20,22, and 23 (Units 1 and 2), quarterly in accordance with ASN1E Section XI, paragraph IWV-3411.

3.12.1.2 Proposed Alternate Testing: The licensee proposes to exercise these valves once per year.

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3.1113 Licensce's Ba3is for Relicp "These valves are manual valves which remain shut at all times except to perfonn stroke testing. They are diaphragm-type valves, thus they do not have a disc which can separate from the stem. Frequent flexing of diaphragms is a failure mechanism. These valves use stainless steel in their construction, thus they are susceptible to galling.1:requent stioking of these valvt 3 could lead to inoperability rather than improving operability."

3.12.1.4 &aluation: These valves are normally closed manual diaphrapu valves that are required to open to veut the containment, prosiding a long-term method of controlling hydrogen accumulation within the containment folle,ving a loss of coolant accident. The licensee inas proposed stroke testing these talves once per year in lieu of the Code required quarterly testing, due to the damage which could be caused by testing. The licensee's

c. pinion is that frequent flexing of the diaphragms is a failure mechanism and that the valves are susceptible to galling. llowever, the licensee has not provided evidence that there is a histow of valve degradation due to testing at Po:nt Beach Additionally, a review of industry expuience, for exainple as documemed in NPRDS, regarding the saine type of valve used in similar service should be performed to justify extending the test frequency.

EPRI Report NP-65!6, " Guide for the Application and Use of Valves in Power Plant Systems" states that although diaphiagm valves have bcen tested and operated satisfactorily with cycles in excess of 50,000, a desiga !ife of 20,000 cycles or 10 years should be considered. Testing the valves quarterly is well within the recomnnded 20,000 cycles.

Without documented evidence, it appears that the risk assock with the valve not perfonning its safety function to open, cutweighs the risk of valve degradation due to testing. Therefore it is recommended that relief be denied.

3.13 Bractor Coolant S" stem 3.13.1 Pressurizer Relief Tank Nitrogen Supply Cbeck Valve, Relief Request No. VRR-ll 3.13.1.1 Rclicf Request: The licensee has requested relief from exercising valves, RC-00528

[

(Units 1 and 2), the pressurizer relief tank i.itrogen supply check valves, quarterly in accordance with the requirements of ASME Section XI, paragraphs IWV-3521 and 3522.

3.13.1.2 Proposed Alternate 7'c3 nag: The licensu has purposed verifying the valve can fulfill e

their safety function to closc during the 10CFR50, Appendix J leak rate test. This test is performed at refueling outages.

3,13.1.3 Licensec's Basis for Relief: "Because nitrogen makeup to the PRT is sch.'om required, these valves are normally closed. These are simple check valves with no external means of position indication, thus the only pr..ctical means of verifying closure is by performing a leak test or backflow test. Performing such tests of these valves involus considerable effort and system re-alignment such that routine testing during plant operation or cold shutdown outages is impractical?

49

6 3.13.1.t Etah<ation: These valves are sirnple check valves located inside containment that are nonnally closed. They are opened to pronde nitrogen to the pressurizer relief tank.

Their safety popt4t to close to provide containment isolation. The valves are not provided with positic...ndication. Therefore, the only practical means of testing these valves is a leakage test. The test connections are located inside containment and would 2

require a containmetit entry to perform this test. Containmen' entries are not routinely performed during power operation due to the high radiation fields and potentially harsh environments. Performing this test dusing cold shutdowns would subject plant personnel to high radiation levels, and due to the time required to perform this test, the shutdown

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E could be extended which would be burdensome. It would be impractical to require the licensee to perform this test quarterly during power opcration or during cold shutdowns.

Performing the Appendix J leak rate test during refueling outages provides reasonable

. assurance of the vahes' ability to close and perform their safety function.

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Based an the impracticality of exercising these check valves in accordance with the i

frequency requiied by ASME Secten XI, the burden on the licensee if these Code requirements were imposed, and the determination that the licensee's proposed testing provides reasonable assurance of the valves' ability to perfonn their safety function, it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i).

3.13.2 Pressurizer Relief Tank Plimary Mab up Supply Check Valves, Relief Request No.

VRR-18 3.13.2.1 Relief Request: The licensee has requested relief from exercising valves, RC.00529 (Units 1 and 2), the pressurizer relief tank primary makeup supply check valves, quarterly in accordance with the sequirements of ASME Section XI, paragraphs IWV.3521 and 3522.

I 3.13.2.2 hoposed Alterrate Testing: The licensee has proposed s erifying the valves c,an fulfill their safety function to close during the 10CFR50, Appendix J 1eak rate test. This test is performed at refueling outages.

3.13.2.3 Licensec's Basis for Relief: "These are simple, nonnally-cicoed, check valves with no external means of position indication, thus the only practical means of verifying closure is L

by performing a leak test or backDow test. Performing such tests of these valves involves considerable effort and system re-alignment such that routine testing during plant operation i

or cold shutdown outages is impractical."

3.13.2A Evaluation: These valves are simple check valves located inside contaicment that are normally closed. They are opened to provide makeup water to, or depressurize the pres.surizer relief tank. Their safety position is to close to provide containment isolation.

l The valves are not provided with position indication.' Therefore, the only practical means L

of testing these valves is a leakage test.

The test connections are located inside i

containment and would require a containment entry to perform this test. Containment entries are not routinely performed during power operatica due to the high radiation fields 30 l

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and potentially harsh environments. Performing this test during cold shutdowns would subject plant personnel to high radiation levels, and due to the time required to perform this test, the shutdown could be extended which would be buroensome. It would be impractical to require the licensee to perform this test quarterly during power operation c-

- or during cold shutdowns. Performing the Appendix J leak rate test during refueling outages provides reasonable assurance o! the valves' ability to close and perform their safety function.

Based on the impracticality of e>,ercising these check valves in accordance with the frequency requiied by /sSME Sectien XI, the burden en the licensee if these Code requirements were imposed, and the determination Lat the licensee's proposed testing provides reasonable assurance of the valves' ability to perform its safety fur.ction, it is recommended tnat relief be granted pursuant to 10CFR50.55a(p)(6)(i).

3.14 Safejy iniection and Residual lleat RemavalSntem 3.l_4.1 Safety injection Pressuce Isolation Check Wives, Relief kequest No. VRR-2 3.14.1.1 Rdief Rufurst: The licensee has requested re!!cf from exercising the safety injection pmssure isolation check valves, SI-00845A through F (Units 1 and 2), quarterly i

in accordance with ASME Section XI, parcgraphs IWV 34 and 3522.

3.14.1.2 Proposed Altemale Testing: The licensee has proposed fuil-stroke exercising the valves-open at each Tefueling outage and verifying valve closure in accordance with Technical Specification 15 3.16.

3.14.1.3 Licensce's assis for Relief: " Full stroke exercising of these valves would require operating a safety injection pump at nominal accident flowrate and injecting into the reactor coolant system since no full flow recirculation path exists. During normal operation the safety injection discharge pressure of 1500 psig is insufficient to overcome reactor coolant system pessure. During shutdown conditions, injection via the SIS pumps is t

precluded by restrictions related tolow-temperature over-pressurization protection concerns in accordance with Technical Specifications. Section 15.3.15.D.

The lack.cf recirculation flowpath precludes partial stroking during operation and cold shutdown conditions. These are simple check valves with no external means of position indicatmn, thus the only practical means of verifying closure is by pcforming a leak test or backflow test. Such testing requires that the valve first be it. ken out of its i

safety position when it may operationally be left undisturbed, i.e., moved solely for test porposes This reduction in plant safetyi not warranted. Additionally, such testing occurs in radia' ion areas, thereby increasing personnel radiation expocure."

l 3.14.1.4 &aluation: These normally closed check valves are required to open to admit flow I

from the high head safety injection pumps in:o the reactor coolant syston. In addition to 51 l

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this open safety function, the valves are required to normally be closed and leak tight to isolate the high pressure reacmr co,lant system from the lower pressure safety injection system and to close to prevent backflow from the Si accumulators and RHR system. These valves cannot be practically full-stroke exercised during power operation because the only full flow path is into the RCS, and the SI pumps cannot overcome the normal operating RCS pressure. Additionally, the relatively coolo injection water =could res it in thermal and pressure transients if testing could be performed at power. Full-stroke testing during cold shutdowns is impractical due to low-temperature over-presurization concerns. In accordance with Technical Specification 15.3.15, when the RCS cold legs are s 275'F, one SI pump shall be demonstrated inopcmbie. The PORVs setpoints are determined assuming a worse case transient of one Si pump discharging into the RCS. Ilowever, it would be impruden: to challenge the low-temperature over-pressure Protection System by operating the_ other SI pump. If the Code requirements were imposed, the plant would have to shutdown and the RCS be vented in order to perform testing. This would be burdensome.

The licensee has stated that a lack of recirculative flowpath precludes partial stroking L

during operation and cold shutdown conditions. It appears, based on a review of drawings 110E035 and 110E017, that 3/4' test hnes are available for partial-stroke testing valves SI-00845A,B,E, and F. There is no practical method of partial-stroke testing valves SI-00845C and D due to the lack of test lines, as stated in the relief request.

Although par'ial-stroke testing valves SI-00845A,B,E, and F open is possible, it is impractical to perfc..m during operation or every cold shutdown because reverse flow or leahape testing would be required to assure the valve's ability to prevent an intersystem l

LOCA. These valves are located inside containment and it is impractical to leak test these valves during operation due to high radiation and personnel safety concerns. Leak testing these valves during every cold shutdown would be burdensome because it could delay teactor startup due to the time required to perform the test.

The licensee *s proposal to full-stroke exercise valves SI-00845C and D open each refueling outage and verify reverse closure by leak testing in accordance with Technical Specification 15.4.16 is a reasonable alternative to the requirements of the Code.

Therefore, based on the impracticality of complying with the Code frequency requirements, the burden on the licensee if the Code requirements were imposed and considering that testing the vahes in accordance with the licensee's proposalis a reasonable alternative to the requirements of the Code, it is recommended that relief be granted for valves SI-00S45C and D pursuant ta 10CFR50.55a(g)(6)(i).

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The licensee's proposal to exercise valves SI 00845A,B,E, and F open each refueling outage howevct, is not acceptable due to the existence of test lines. Relief from exercising

(

the valves quarterly or every cold -- shutdown can be recommended pursuant to -

l 10CFR50.55a(g)(6)(i), provided the licensee partial-stroke exercises the valves during the Technical Specification 15.4.16 cold shutdown leak tests and full-stroke exercises the valves each refueling outage.

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3.14.2 Safety injection and RilR Pressure isolation Valves, Relief Request No. VRR-3 3.14.2.1 Relicf Requot! The licensee has requested relief from exercising the Safety injection (SI) and RilR pressure isolation valves, SI.00853A through D (Units 1 and 2),

quarterly in accordance with ASME Section XI, paragrapha fWV-3521 and 3522.

3.14.2.2 Proposed Alternate Testing: The licensee has proposed full stroke exercising and leakage testing the valves each refueling outages and durinF cold :.hutdowns when " Event V" valve testing is required. In accordance with Technical Specification 15A.16, periodic leakage testing of pressure isolation valves (" Event V" valve testing) is required each time the plant is placed in a cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the preceding 9 months: prior to returning the valve to service after maintenai,,e, repair or replacement work is performed, and every refueling outage.

3.14.2.3 Licensce's llads for Relief: " Full oi partial stioking during normal operation is not possible because low head safety injection pump discharge pressure is insufficient to overcome reactor coolant system pressure.

Even if pump discharge pressure were adequate, any stroking would cause the injection of cold bei ted water into the system, resulting in power and thermal transients.

r Stroke testing the subject valves during cold shutdowns is possible, however, not desirable unless " Event V" leak testing is also scheduled. Tine " Event V" testing assures valve integrity, thus minimizing the possibility of an inter-system LOCA which bypasses containment. Exc rcising these valves during everv cold shutdown may reduce the assurance (nat a' valve is, in fact, properly seated, as established via the " Event V" testing" l

3.14:2.4 Eraluation: These check valves are normally dosed valves that are required to open to admit flow from the low-head safety injection pumps (RHR) and high head safety F

injection pumps (SI) into the reactor vessel. Va4es SbO0d53A and B open to admit RilR flow only. In addition to this open safety function, the valves are. required to close and be l

leak tight toisolate the high pressure reactor coolant system (RCS) from the lower pressure l

RHR or SI systems. These valves cannat be practically full-or partial. stroked open during power operation because the only flow path is into the RCS, and the Si or RilR purns cannot overcome the normal operating RCS pressure. Additionally, the relatively cooier injection water could result in thermal and power transients if testing coniti be performed L

at power. Full-stroke testing during cold shutdowns is possible. However, it is impractical to exercise these valves open esery cc'd shetdown because reverse flow or leakage testing i

would be required to assure the valve's ability to prevent an inter. system LOCA. These, t

valves are located inside containment and it is impractical to leak test these valves during l

' operation due to high radiation and personnel safety concerns. Leak testing these valves l

- during every cold shutdown would be burdensome, because it could delay reactor startup l

due to the time to perform the test. The licensee's proposal to full-stroke exercise the j-

-valves open and verify reverse closure by leakage test each refueling outage and each time the plant is plated in a cold shutdown condition for 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />;, if testing has not been I

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accomplished in the preceding 9 months, is a reasonable alternative to the requirements of the Code. It is assumed that the valves will be full-flow exercised, as well as leak tested prior to returning the valve to service after maintenance, repair or replacement, in accordance with Section XI, paragraph IWV-3200. Therefore, based on the impracticality of complying with the Code frequency requirements, the burden on the licensee if the Code requirements were imposed and considering that exercising these valves in accordance with the test frequency required by the Point Beach Technical Specification 15.4.16 is a reasonable altesnatise to the Code, it is reconntended that relief be granted pursuant to 10CFR50.55a(g)(6)(i).

3.14.3 Safety injection and Safety injection Accumulator Check Valves, Relief Request No.

VRR-4 3.14.3.1 Relief Request:

The licensee 'as requested relief from exercising the safety injection and safety injection accumulator check valves, SI-00867A and B and SI-00842A and B (Units 1 and 2), quarteily in accordance with ASME Section XI, paragraphs IWV-3521 and 3522.

3.14.3.2 Proposed Ahcrnate Testing: The licensee has proposed partial-stroke exercising the valves open at each refueling outage and at each cold shutdown which requires " Event Y' testing in accordance with Technical Specificatian 15.3.16. Valve SI-00867B will also be partial-stroke exercised at each cold shutdown which utilkes an RHR pump.

Valves SI-00S67A and B v.ill be exercised closed in accordance with Technical l

Specification 15.3.16, " Reactor Coolant System Pressure isolation Valve Leakage Tests."

Valves SI-00842A and B will be exercised closed by a leakage test quarterly.

r 1

Additionally, valves SI-00842A and 867A and B will be disassembled and exercised at least once each 10 years. If a condition is discosered during an inspection that would have prevented the valve from stroking full open, a second " identical valve h. the same Unit" will be opened and inspected. Also, during the next refueling outage on the other Unit, the sister valve to the inoperable valve will'be inspected. If a second valve is found inoperable in the expanded sample, all remaining valves will be inspected during the current outage for the Unit refueling and during the next scheduled refueling outage from the Unit L

not in a refueling outage.

l 3.14.3.3 f.icensce's Ibsisfor Relief: "During normal operation, neither safety injection pump l

discharge pressure of 1500 psig nor accumulato: pressure of 760 psig, are suffkient to i

. overcome reactor coolant system pressure. Full or partial stroke testing is, therefore, not i

possible.

l During cold shutdown, partial or fuE stroke testing of valves SI 00867A, SI-00842A, l

and SI-00S42B via the use of the accumulators or safety injection pumps is not permitted 54 l

.... ~.

a so as to prevent the possibility of-a low-temperature over-pressurization event. Partial

~

stroking of SI 00867tl is, however, possible using the RilR pumps.

A full-stroke test by dumping the accumulator to the reactor coolant system could be possible during refueling when the reactor vessel head is removed, but the volume and flowrate required for the test could result in damage to the core internals. There is also the potential of forcing a nitrogen bubble into the reactor coolant system piping and refueling cavity resulting in possible safety implications which makes tLis testing' oncept inadvisable." (VRR-4, IST Program, Rev.1)

The licensee has also provided a basis for extending the inspection interval beyond that allowed by Generic Letter 89-04, Attachment 1, Position 2 and has referenced their response to he Generic Letter dated October 3,1989 for the " justification of the long frequency surveillance internals.. " Generic Letter 89-04, Position 2 requires a disassembly and inspection of each valve in the valve group. " Valves 2-SI-00842A and 2 SI 00867A were disassembled in 1987. Valve 2 SI 842B was not disassembled..." (VRR-4)

"Because of their elevation and their proximity to the residual heat removal connection to the reactor coolant system, Vahes 867D and 842B cannot be opened and inspected unless the entire core is unloaded and the reactor coolant system is drained to the elevation of the reactor vessel nozzles. The need to achieve this plant condition is rare.

It has only occurred once for Unit l'and once for Unit 2. To achieve the required plant condition and to disassemble-and inspect Valve 842B would require approximately five additional critical path days " (Apiil 2.1987 letter from Wisconsin Electric Power Company to USNRC attached to the October 3,1989 letter.)

"Over the last 16 years we have observed nothing which would be indicative of a problem that would inhibit any of the check valves' ability to stroke fully open. The 867A check valves on both units were opened and inspected after approximately six years of service due to suspected seat leakage. In both cases, seating surface wear was observed but no problems were noted with either valve's ability to stroke open freely." (April 2,1987 Letter)

"Four valves, two per unit (SI 842A and SI-867A), have been opened and inspected.

The results of these inspections are documented and have been reviewed. No problems were noted which could affect valve operability.

Two other valves (ISI-S42B and 2SI-842B), will be disassembled and inspected during the upcoming refoeling outages. These results will be reviewed when availab!c "

(Response to Generic Letter 89-04, October 3,1989)

"In response to NPC Information Notice 88-85, in 1989 the retaining block studs in each of the valves in Unit 2 ere replaced and in the process each of these valves were 6

l l

l

.~

disasse'mb!cd and inspected for freedom of motion as per the requirements of NRC Generic Letter 89-04c Position 2.

During all inspections that have been performed on these valves to date, no defects have been di: covered that would signify that they were not fully functional and capable of performing their required function to full stroke. These valves have now performed acceptably at Point Beach for over 19 years with no indications of degradation. This is in agreement with industry experience that showc these valves to be extremely reliable."

(VR R-4)

"A sisting of the reported failures for vahes of this type was requested from the INPO NPRDS data. There were 22 failures reported, including three failures at Point Bcach. All of these failures involved leakage past the seat. There were not reported cases of failure of these vahes to open, or operate freely." (Response to Generic Letter 89 04, October 3,1989)

"These six valves have been reviewed against the EPRI Installation Guidelines. It was noted that all but one valve (ISI.842A) is located close to a source of turbulence. The past maintenance histmy has identified no problems. Recommendations as a result of this review was to inspect aad replace the retaining block hold down studs." (Response to Generic Letter 69-04, October 3,19S9) 3.14.3.4 Evaluation: Th_ese 10 inch Anchor / Darling swing disk check valves perform a safety function in both the open and closed position. Closed, they prevent leakage from the high pressure Reactor Coolant System (RCS) to the lower preasure SI system.

During Emergency Core Cooling System injection, these valves open allowing now from the Si pumps and accumulators into the RCS. These valves cannot be full-stroke exercised quarterly during power operation because the only flow path is into the RCS and the SI pumps' and accumulators' operating pressure is less than the normal RCS operating pressure, preventing flow into the RCS. The safety injection system test line is inadequate for full stroke exercising the accumulator check valves due to its size. Additionally, these valves cannot be full-stroke exercised at cold shutdowns due to the low-temperature overpressurization concerns, or at refueling outages due to the potential damage to the core internals.

ASME Section XI requires check valves to be exercised to the positions in which they oform their safety functions A check valve's full-stroke to the open positic. may be veriried by passing the maximum required accident condition flow through the valve.

Position 1 of Generic Letter 89-04 allows the use of alternate techniques to_ verify that the-

- valve opens sufficiently to pass the maximum iequired accident flowrate, such as non-intrusive methods, when full-stroke testing is impractical Generic Letter 89-04, Position 2 also provides valve disassembly and inspection as an acceptable alternative. The NRC staff position is that where it is burdensome to disassemble and inspect all valves each refueling outage, a sample plan for groups of identical valves in similar applications may 56

~...

be eniployed. One valve in the group nnst be inspected each refueling outage such that each valve is inspected everj six years. Extending the inspection interval may be considered in cases of" extreme hardship" where the extension is supported by actual in plant data from previous testing.

The licensee has proposed inspecting six of eight valves (including three valves from each Unit) once every ten years. For each Unit one of the three valves will be inspected every five to six years. The other two valves are not to be inspected unless there are two failures deuctm from inspecting the other six valves.

In support of extending the

-inspection interval, the licensee has stated that valves SI-00842A and 67A from Unit 2 were disassembled in ~1987 and each of the valves in Unit 2 were inspected in 1989 in response to Infonnation Notice 88-85. Additionally 1-SI-00867A was inspected after six years of service (~ 1977) and 1-SI-00S42A was inspected (Date unknown). Position 2 of Generic Letter 89-04 requires that each valve be disassembled and inspected and that the valves' condition and capability to be full-stroked be documented in detail.

The licerisce has reported, in their response to Generic Letter 89-04, their review of INPO NPRDS data. Based on the 1989 review, there were no cases of similar valves failing to open.

Historically however, there have been various problems with An-chor/ Darling swing check valves including retaining block stud cracking (NRC Bulletin No.

89 02) and hinge pin problems (NRC Information Notice No. 81-35).

It would be excessively burdensome for the licensee to inspect all eight valves each refueling outage. Additionally, it would be an extreme hardship to require the licensee to comply with the six year inspection interval for the two valves which require the reactor to be defueled and drained in order to be. tested (SI-OnS42B). However, the licensee has not 1

provided sufficient evidence that the burden of inspecting the remaining six valves in accordance with Position 2 is extreme. Therefore, is recommended that relief only be granted for valves SI-00842B (for both Units) in accordance with Generic Letter 89-04,, Position 2 provided the licensee has disassembled and inspected the valves and the valves' condition and capability to be full stroked is documented in detail. Relief can only be recommended for the remaining valves provided they are disassembled and inspected in accordance with Position 2 (including the frequency). - Additionally, if the valve disassembled is not capable of being full-stroke exercised, or there is binding or failure of valve intervals, the other two valves in the group for that Unit shall be inspected during the same outage. The other Unit's three valves shall be inspected-at the next scheduled refueling outage. If a second failure is detected, valves SI-00842B shall also be inspected.

Othenvise, it is recommended that relief be denied.

3.14.4 RWST to RHR Pump Suction Check Valves,. Relief Request No.-VRR-6 3.14.4.1 Relief Request: The licensee has requested relief from full-stroke exercising the Refueling Water Storage Tank (RWST) to RHR pump suction check valves, SI-00854A 57 m-

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-w

,,,,---.y.-

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- and B (Units 1 and 2), quarterly in accordance with ASME Section XI, paragraphs IWV-3521 and 3522.

3.14.4.2 Proposed Alternate Testing: The licensee has proposed full. stroke exercising the valves during plant refueling outages.

3.14.4.3 Licensce's Basis for Relief: " Valve stroking is not possible during normal operation because the RHR pump discharge pressure is insufficient to overcome reactor coolant system pressure during normal operation. During cold shutdown periods, full stroke testing of these valves is not possible because the reactor coolant system' does not contain a sufficient expansion volume and there is no return Dowpath to the refueling water storage tank for recirculation."

3.14.4.4 Evaluation: The function of this normally closed check valve is to open to permit flow from the RWST to the RilR pump suction. The valve is required to close to prevent backflow from the RilR pump suction header (including when RilR takes suction from the RCS) to the RWST A full flow test of the valves would require the RilR pumps to inject water into the RCS. During power operation the RilR pump head is inadequate to inject into the RCS.

During cold shutdowns RllR is in operation with the suction and discharge to the RCS to remove decay heat. Injecting the maximum required accident condition flowrate into the RCS could subject the RCS to a low temperature overpressurization, Additionally, the RCS could not accommodate the flow required due to the limited letdown capacity.

The licensee has stated that there is no return Dowpath to the RWST for recirculation. A review of the Point Beach drawings provided,110E029, Sheet 1,110E035, Sheet 2,110E0lS, Sheet 1, and 110E017, Sheet 2, has identified a " refueling water return" path to the RWST through manual _ valve Ril-742. The licensee should provide an explanation in the relief request why these valves cannot be tested using this flowpath.

NRC IE Information Notice 87-01, "RIIR Valve Misalignment Causes Degradation of ECCS in PWRs," should be reviewed. Therefore, without justification for not using this flowpath, relief cannot be recommended.

3.14.5 Safety Injection Pump's Discharge Check Valves, Relief Request No. VRR-7 S.14.5.1 ReliefRequest: The licensee has requested relief from full-flow exercising the safety injection pumps' discharge check valves, SI-.00S89A and B (Units 1 and 2), quarterly in accordance with ASME Section XI, paragraph IWV-3521 and 3522.

3.14.5.2 Proposed Alternate Testing: The licensee has proposed partially-stroking these valv_es quarterly and full stroke exercising them at refueling outages.

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3.14.5.3 Licensce's Basis for Relief: " Full stroke exercising of these valves would require

~

operating a safety injection pump at nominal accident Powrate and injecting into the reactor coolant system since no full flow recirculation path

..sts. Duri.ig normal operation the safety injection pump discharge pressure of 1500 psig is insufficient to overcome reactor

- coolant system pressure. During cold shutdown conditions, injection via the SIS pumps is precluded - by restrictions related to low-temperature over pressurization protection concerns."

3.14.5.4 Evaluation: These check valves perform a safety function in the open position to allow flow from the safety injection pumps to the reactor coolant system (_RCS). These "alves cannot be practically full-stroke exercised during power operation because the only full flow path is into the RCS and the discharge pressure of the pumps cannot overcome the normal RCS operating pressure. The safety injection test lineup only permits partial Dowrates due to the return line's size. It is impractical to exercise these valves during cold shutdowns because a low-temperature over-pressure condition could occur. These valves could only be full stroke exercised quarterly or during cold shutdowns if extensive system modifications were performed, such as full-flow test loops. These modifications would be burdensome to the licensee.

The licensee's proposal to partial stroke exercise the valves quartet.y and full stroke exercise them during refueling outages provides reasonable assurance of the -valves

- operational readiness.

Based on the impracticality of full-stroke exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed and, considering that the proposed alternate testing provides reasonable assurance of operational readiness, it. is recommended that relief be granted in accordance with 10CFR50.55a(g)(6)(i).

3.14.6 Safety injection and RilR Pressure Isolation Valves. Relief Request No. VRR-22 3.14.6.1 Relief Request: The licensee has requested relief from evaluating the leakage of pressure isolation valves (PlV) SI-00845A through F,00853A through D, and SI-00867A and B (Units 1 and 2), in accordance with ASME Section XI, paragraph IWV-3427(b).

3.14.6.2 Proposed Alternate Testing: The licensee.as proposed evaluating the leakage in accordance with the acceptance criteria given in Technical Specification 15.3.16 for pressure -

isolation valves.

3.14.6.3 Licensce's Basisfor Relief: " Leak testing of these valves is primarily for the purpose of confirming their capability of preventing over-pressurization and catastrophic failure to the safety injection piping and components. In this regard, special' leakage acceptance criteria is established and included in the Point Beach Technical Specifications !5.3.16 that add; esses the question of valve integrity in a more appropriate manner for these valves.

59

9 Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult an. con. %g" 3.14.6.4 Evaluation: Position 4 of Generic Letter 89-04, Attachment I states that all PlVs listed in plant Techmcal Specification should be listed in the IST program as categoiy A or AC valves and that the Technical Specification requirements be referenced in the IST Program. The licensee has requested relief from evaluating the pressure isolation valves in accordance with paragraph IW V-3427(b) and has proposed utilizing the Technical Specification. The Point Beach Technical Specification acceptance criteria specifies the maximum permissible leakage rate for the pressure isolation valves to be 5 gpm. Leakage rates greater than I gpm and !ess than or equal to 5 gpm are unacceptable (and require corrective action) if the latest measured rate exceeds the rate determined by the previous test by an amount that reduces the margin between the measured leakage rate and 5 gpm by 50% or greater. This Technical Specification requirement exceeds the requirements of IWV 3427(b) which requires only that the test frequency be increased. The Technical-Specifications considers leakage rates less than or equal to 1 gpm to be acceptable.

- Although tue Technical Specifications do not require evaluations based on previous leak tests as required by IWV 3427(b), leakage rates I ppm and less cannot reduce the margin between measured leakage and 5 gpm by 509i.

The Technical Specifications do not require repairing or replacing a valve if the tests show a leakage rate increasing with time and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate of greater than 10%.

Ilowever, the Technical Specification acceptance criteria discussed above provides reasonable assurance of the pressure isolatio-valves ability to isolate the RCS from an attached low pressure system and to detect valve degradation.

Therefore it is recommended that relief from evaluating leaxage in accordance with parapaph IWV 3427(b) be granted in accordance with 10CFR50.55a(a)(3)(i).

Note: Relief Request No. VRR 22 requests relief from evaluating valves 6 inches and greater in accordance with the Code. In accordance with the IST Program and reterenced drawings, valves SI-00S45A through F are 2 inches: therefore, relief is not required for these valves.

3.14.7 Safety injection' Pumps' Minimum Flow Line Check Valves, Relief Request No.

V R R-27.

3.14.7.1 Relief RequcSt The licensee has requested relief from exercising the safety injection pumps' minimum flow line check valves, SI-00S91A and B (Units 1 and 2),

' quarterly in accordance with ASME Section XI, paragraphs IWV-3521 and 3522.

3.14.7.2 Proposed Alternate Testing: The licensee has proposed partial-stroke exercising the valves quarterly and disassembling and inspecting one valve each refueling outage on a 60 1

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rotational basis. If one vahe is found inoperable, the other valve in that Unit will be inspected during the same outage.

3.117.3 Liccn3ce's R.nis for Relicf: "There is no flow instrumentation available to serify valve full stroke excicising as sequired by Reference 28 (Generie 1.etter 89 04), Position 1."

3 3.14.7.4 Ecaluation: The safety function of these valves to open provides a minimum flow return line to prevent pump degradation during no or low injection flow conditions. These is no flow instrumentation currently inshlled in the flowpath through these check valvec Therefore, it is impiactical to full Dow exercise these valves during any plant condition in accordance with Generie 1 etter 89 04, Position 1. Compliance with the Code requirements would require installation of Dow instiumentation and possibly extensive piping system modifications. The beensee has proposed disassembly and inspection in accordance with Genetic 1 etter 89 04, Pasition 2 as an alternative to this full. stroke exercising requirement.

Position 2 allows a sampling plan for groups of identical vahes in similar applications.

Each of the two sample groups proposed includes both valves from one Unit. llowever, the licensec L:.s not piovided documentation that the valves are the same design and have the mme service conditions including valve orientation.

Although valve disassembly and inspection in accordanc( with Position 2 of the Genciic 1.etter is aceptable, the NRC staff reconunends that other methods such as non-intresive techniques be used which can verify full stroke exercising.

Generic Letter, Position 1 and Qucstion 8 in the minutes of 'he public meetings in Generic Letter 89 01 dis. cuss the qualification program required for these alternate techniilues.

Thcrefore, it is recommended that relief from full stroke exercising the valves quatterly be granted pursuant to Generic Letter S9-04 provided the licensee ensures that the plogram meets all the criteria, including the ciitelia for determining groups of valves, as provided in the Generic Letter, Attachment 1. Position 2.

Note: The licensee's IST Program requires that the valves only be tc vJ cy.a The licensee should review the function of these valves to tasure that they are not required to close to prevent Oow interactions between the safety injection irai,s (refe.,.,ce TER Section 5.39).

3.15 Femce Water Srstem 3.15.1 Service Water to AFW Pump Check Valves. Relief Request No. VRR-15 3.15.1.1 Relic] Requen: The licensee has requested relief from full stroke exercising the senice water to the steam driven auxiliary feedwater pump and turbine check vahes; SW-00ll2A (Unit 2). 00135A (Unit 1); quarterly in accoidance with ASME Section XI, parapaphs IWV-3521 and 3522.

61

=

I 3.15.1.2 Proposed Altrinate 7hting: The licensee has proposed partial stroke exercising the valves quarterly and disassembling and inspecting the valves each refueling outage.

3,15.1.3 Licen3ce's Basisfor Relic / "There is no practical means of measuring flow through these check valves. In accordance with NRC Generic Letter, an acceptable alternative is a program of valve disassembly and inspection to verify operability"

+

3.15.1.4 Evaluation: ash 1E Section XI, paragraph IWV 3522 requires for valves that are l

to be tested in the open position, confinnation that the disk moves away from the seat by visual observation, by an electrical signal initiated by a position hidicating device, by observation of substantially free flow through the valve, or by other positive means. The NRC staff believes that other positive means could include confirmation of valve disk position by qualified methods, including non intrusive methods, and valve disassembly and inspection. Position 2 of Attachment 1 of NRC Generic Letter 89-04 proddes the criteria i

for utilizing "alve disassembly and inspection as an alternative *o full flow testing of check valves. Par,.c.i. valve stroking quarteth or during cold shutdowns is required if possible.

The NRC recommends, however, that other techniques such as non intrusive test methods be utilized, instead of disassembly and inspection. Position 1 of Attachment I to NRC Generic _ Letter 89 04 and the response to Question 8 in the hiinutes of the public h1eetings on Genetic Letter 89 04 provide guidance on qualifymg alternative techniques for meeting 3

ash 1E Code requirements.

There is no installed instrumentation for verifying sufficient flow to full stroke exercise the valves open. The licensee has proposed partial stroke exercising the valves and utiliziag valve disassembly and inspectian. The licensee has not, however, provided sufficient information to ascertain that the valve disassembly / inspection program meets all th: criteria estaMished in Position 2 of the Generic Letter meluding visually inspecting the l

valve internals for worn or corroded parts an:1 manually exercising the valve disk.

Thetefore, it is. recommended that relief from full-stioke exercising the valves quarterly be granted in accordance with Generic Letter 89-04 provided the licensee's disassembly / inspection program meets all the criteria of Position 2 of Generic Letter 89M4.

Cen!!dn uent l<olation Valves

-3.16 J

3.16.1 Containment Isolation Valves, Relief Request No. VRR 23 I

3.16.1.1 Relief Request: The licensee has requested relief from specifying individual leakage rates in accordance with AShlE Section XI, paragraphs IWV 3426 and 3427 for specific containment isolation valves.

Note: Re'icf Request No. VRR 23 is referenced in Appendix E for the Unit 2 Auxiiiary Steam Valves; llV 0263,286,287,636 and 637, and Instrument Air Valves, IA-62

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i-

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1315 and 1316. The relief request, howeser, does not include these valves in Table VR 51.

TliR Section 3.16.1.4 only evaluates those vahes identified in the relief iequest. 'the licenste should review Appendices D and li and revist the relief request to address any additional valu s.

Additionally, Waste Disposal Valve W1. 00S16 is identified in Appendices D and li as SI-00S16.

5.16.1.2 Projward Allemate Tc3 tine: The licensee has proposed assigning maximum leak rates to combinations of valves ',,here lndividual valve testing is impractical. The test results will be evaluated for corrective action in accordance with paragraphs IWV 3426 and 3127 and 10CFIUO Appendix J.

3.16.1.3 Licen3cc'3 Ba3is for Relief: "Due to the configuration of the system piping and components, in many cases individual leakage rate t:sts are impractical. In these cases, it is customary to perform tests with the test volume between valves in series or behind valves in parallel paths. This concept of testing and evaluation is consistent with the intent of 10Cl:R50, Appendix J."

3.16.l A Ecaluativ,i Where it is impractical to leak test containment isolation valves individually due to system design and/or lack of test connections, leak rate testing them as a group should demonstrate the leak tight integrity of the group. The licensee has stated that a maximum leakage limit will be assigned to combinations of valves and not to an indiviJual valve. This limitation is acceptable provided that the limiting leak rate for the valve comoination is conservative considering the numtier and size of the valves in the group and does not allow excessive leakage throept any particular valve in the group to go uncorrected.

According to the piping and instrument diagrams for the Auxiliary Eleam, Chemical and Volume Control, Containment Spray, lleating and Ventilation, and Waste Disposal Systems, there are an inadequate number of test connections to individually leak test the valves referenced in the relief reqaest It would be burdensome to require these valves to be leak tested indi.idually because the systems would luve to be substantially redesigned.

The only practical method to leak test these valves appears to be as a group with a maximum permissible leakage rate assigned to the penet ation Hased on the impracticality of individually leak testing these valves, the burden on the licensee if these Code requirements were imposed, and considering that the proposed alternative should provide reasonable assurance of operational readiness, relief inay be granted as request-d for the Auxiliary Steam [IlV-00632,63:,,808,809,818 (Unit 1 only)],

Chcmical and Volume Contiol jCV-003231),384B (Ur.it I and 2)), Containment Spray [SI-00862A&B,864 A&ll(Unit I and 2)],lleating and Ventilation [VNPSE-03212,3213,3244, 3245 (Unit I and 2)], and Waste Disposal System Valves [WL-00316,1698,1723,1728, 1003A&D (Unit I and 2)), in accordance with 10CFR50.55a(g)(6)(i) provided that the limiting leak rate for the penetration is conservatise and does not allow excessive leakage through any particular valve in the group to go uncorrected.

63 I. _ __ _ __ __

It appears based on a review of the Component Cooling Water (CC-00755A&II, 759Akil(Unit I and 2)], Instrun,ent Air [lA-Oll82, i184 (Unit 1 only)] and Post Accident Containment Venting and hionitoring Systems [112-V-04,5,6,7,12,13,19,20,22,23 (Unit I and 2)], that it is possible to determine individual leakage rates for the valves referenced in the relief request. Therefore, it is recommended that relief be denied for these valves.

3.16.2 Containment Isolation Valves NPS 6 and Gitater, Relief Request No. VRR 29 3.16.2.1 Relief Request! The licensee has request relief from evaluating contaimuent isolation valves'(CIVs) NPS 6 and greater leakage rates m accordance with ASME Section XI, paragraph IWV 3427(b).

3.16.2.2 Pmposed -tllernate Tc3 ting: The licensee has proposed evaluating CIV leakage rates

. in accordance itt pragraphs IWV 3426 and 3427(a).

3.16.2.3 Licensech Rasis for Relief: "The usefulness of applying this requirement does not instify the burden of compliance. This position is supported by NRC Generic 1.etter, Position 10."

3.16 2.4 Ecaluation: This relief request complies with Generic Letter 89-04, Attachment 1, Position 10, and it is recommended that relief from evaluating leakage in accordance with paragraph IWV-3427(b) be granted in acccidance 'vith the Generic Letter.

3.17 Generic Relief Rennests 3.17.1 Valves Tested During Cold Shutdowns, Relief Request No. VRR 5 3.17.1.1 Relief Reync3t: The licensee has iequested relief from full stroke exercising all valves defeired to cold shutdewns each cold shutdown in accordance with AShlE Section XI, paragraphs IWV-3412 and 3522, 3.17.1.2 Propmed Alternate Tc3 ring: The licensee has proposed connuencing valve exercising within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving cold shutdown. If an outage is.ufficiently long, testing need g

not be conunenced in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all valves required to be tested during cold shutdown will be tested prior to plant startup. Valve testing need not be perfonned more often than once every three months except as provided for in IWV-3417(a). Completion of all valve testing during a cold shutdown is not required if plant conditions preclude testing of specific valves or if the length of the shutdown period is insufficient to complete all testing. Testing not completed prior to startup will be rescheduled for the next cold shutdown in a sequence such that the test schedule does not omit nor favor certain valves er groups of valves.

3.17.1.3 Licensce's Basis for Relief: "In many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage or the 64

lack of plant conditions needed for testing specific salves. It has been the pokey of the NRC that if testing commences in a ter.sonalde time and reasonable efforts are made to test all valves, then outage extem. ion or significant changes in plant conditions are not required when the only reason is to provide the opportunity for completion of valve testing.

ash 1E/ ANSI Ohla.1987, Operation and hiaintenance of Nuclear Power Plants, Part 10 (Paragraphs 4.2.1.2 and 4.3.2.2) recognizes this issue and allcws deferred testing."

3.17.1.4 Evaluation: Due to the hardthip that delaying plant startup places on a licensee, the NRC doe not require ennpletion of all testing identified to be performed during cold shutdown prior ta startup from each cold shutdown. Requiring completion of all testing prior to startup could delay the return to power, which would be costly. The proposed alternate test frequency, as stated above (with the exception discussed below), agrees with previously approved ahernatives for valves that can be testod during any cold shutdown and complies with AShlE/ ANSI Ohta 1988, Part 10. Oh! Part 10 is refetenced in the 1989 Editian of Section XI. This Edition bas been referenced in 10CFR50 in a propo3cd rule.

For.these valves this alternate test f equency should not have an adverse effect on the assessment of operational readiness.

Thersfore, the licensee's proposal provides a reasonable alternative to the Code test fiequency requirements.

However, the licensee has included the following statement ir. their request

" Completion of all valve testing during a cold shutdown outage is not required if plant conditions preclude testing c: specific valves..." For any specific valve, or class of vaires, that cannot be tested during each cold shutdown of sufficient duration to complete all testing, a relief request must be submitted and approved by NRC prior to implementation since the test interval for these valves could exceed that allowed by Section XI. The relief request should identify the valves and the specific plant conditions when testing is impractical.

Therefore, based un the determination that the licensee's proposal provides a

- reasonable alternative to the Code test frequency requirements and considering the hardship on the licensee without a compensating increase in safety,it is recommended that relief be granted for valves that can be tested during any cold shutdown in accordance with 10CFRSO.55a(a)(3)(ii). Generic relief should be denied for valves that cannot be tested during any co:J shutdown of sufficient duration to complete cold shotdown testing.

4.0 Col.D SilUTDOWN JUSTIFICATIONS As part of the insenice test program update, Wisconsin Electric Power Company has' proposed that specific vahes in the Point Beach Nuclear Plant can only be tested during cold shutdown instead of quarterly, as required by ash 1E Section XI. The basis for these alternative test frequencies include impracticality due to equipment and operational limitations, potential equipment damage, reduction in safety, or disruption of reactor operation. A total of 30 separate justifications were submitted. Each justification was reviewed to verify its technical basis. All justifications were found to be acceptable, with 65 4

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--_7--~_.-..-----.----.-.-_..-.-..-.-.-._.

l the exception of CSJ 17,22 and 24. Concerns with these thice justifications are provided below.

4.1 The justification provided in CSJ<22 appears not to address the normally closed l

motor operated valves, SI 00878A and C. These valves allow flow frorn the SI pump Jischarge into the RCS and are unrelated to the Si accumulator's injection path as i

discussed in the justification.

i 4.2 CSJ 24 states that exercising the Si pump suction valves from the llAST, SI.0082611 and C, requires isolating valve SI 00826A and that this action would isolate all water sources to both Si pumps. Isolating SI 00826A appears not to affect the SI pumps' RWST tuction path or the llAST's water volume. Therefore, testing these vahes quarterly appears to be practical.

4.3 in accordance with Appendix D, CSJ 17 applies to MS-02018CS and DS. The CSJ incorrectly identifies the subject valves.

IER Section 5.7 addresses additional concerns related to the MSIVs.

5.0 IST PROGRAM ANOMAllES AND ACTION ITEMS ASME Section XI inconsistencies, omissions, and required licensee actionsidentified during the review of the licensee's inservice testing program are summarized below. The licensee should resolve these items in accordaner with the evaluations presented in this t

report.

5.1 As discussed in TER Section 1, the relief request status provide'i in the IST Program is misleading. Relief requests submitted with the ten year update are not approved by Generic Letter 89-04, unless the relief requests comply with the positions provided in Attachment 1 of the Generic Letter.

5.2 Interpretation 1.1.3 providdd in the IST Program Introduction states that, i

" Modifications to the plant to accommodate changes in inservice testing require ments in later editions of the Code are not specifically required." _10CFR50.55a(g) requires that components comply with the requirements of the latest edition and addenda of the Code incorporated by reference 12 months prior to the start of the ten year ' interval to the extent practical. Relief from these requirements may be granted when compliance would result in hardship or unusual difficulty without a compensating increase in the level of safety, the proposed alternatives would provide an acceptable level of quality and safety, or the Code requirements are impractical.

Modifications to the plant to accommodate changes in the Code requirements are required, unless relief from these requirements has been granted.

5.3 Revision 1 of the IST Program was submitted. Ilowever, numerous pages reference a Revision 2 (e.g. page 1 of 4 through page 4 of 4). Additionally, there are l

l 66 i

L L._ _,..____ _ _._ _._,_ __ _._,_ __,,_-_

numerous typographical errors including valve nuinber errors (see TEll Sections 5.12, 3.16.1.1, and 3.9.2.1).

The program should be neviewed to en3ure that typographical errors do not impact the relief requests submitted.

5.4 in generic pump Relief Request PRR 7, the licensee proposes to follow the requirements of ash 1E/ ANSI Oh!, Part 6 for measuring pump vibration. This is an acceptable ahernative to the Section XI requirements provided that all of the requirements of ash 1E/ ANSI Ohtb-1989, Part 6 related to taking and evaluatlag vibrathn measurements are met. (Reference TER Section 2.1.3.4) 5.5 in generic pump helief itequest PRR-9, the licensee proposes to make corrections for the presence or absence of liquid in the pressure sensing gage lines only to the exient that they will ensure a difference of no more than 0.25% exists in the calculated valae of pump differential pressure. This is acceptable provided that the calculation of pump diiferential pressu e is properly proceduralized to address this correction. This licensee should develop or modify existing procedures to satisfy this requirement. (Reference TER Section 2.1.5) 5.6 in generic pump Relief Request PRR-10, the licensee requested relief from instrumentation accuracy requircments. Ilowever, the licensee did noi demonstrate that it would be impractical or would impose a hardship without a compeasating increase in the level of quality or safety to procure and install instrumentation that meets the Code requirements. In addition, the proposed alternative procides no technical justification for establishing an accuracy of 13% for instrument loops.

The licensee should review current instrumentation accuracy in light of the intent of 1.he Code and determine whether the Code requirements can be met. If they cannot, the licensee should determhie whether modifications can be made to bring the instrumentation into compliance. If this is impractical, technical justification should be provided for establishing instrumentation accuracies that can be met. The request should address specific instrumentation and pumps and not be generic. This review should be complete in one year or until the next refueling outage, whichever is later. (Reference -TER Section 2.1.6) 5.7 in pump Relief Requests PRR-17, for the safety injection and residual heat removal pumps, aad PRR-IS, for the auxiliary feedwater pumps, the licensee requested relief from running the pumps for five minu:es before taking data measurements.

However, the proposed alternative does not satisfy the intent of the Code.

ash 1E/ ANSI Ohta.1988, Part 6 revises the hold period to two minutes before data measurements are taken. Relief is granted provided the licensee utilizes a two minute hold period for pump testing. (lleference TER Sections 2.2.2 and 2.3.2) 5.8 In pump Relief Regnest PRR-6, for the containment spray pumps, the licensee requested relief from the requirements of measuring pump flow. Ilowever, the licensee did not show that it is impractical, or that it imposes an excessive hardship 67 i

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

without a compensr, ting increase in safety to modify the 'nini flow line configuration to allow an adequate liow and install How instrumentation, or that it is impractic-1 to use an existing alternate now path which includes How instrumentation. Also, the proposed alternative <loes not provide a wasonable alternative to the Code requirements The licensee should review the recirculation line configuration and investigate potential modifications to allow an increased flow to be achieved and the appropriate flow instrumentation to be installed. In addition, the licensee should i

investigate the use of the existing altunate Dow path for quarterly pump testing and discuss the proposed system modifications discussed in their March 2 and October 2,1990 letters. If these options ate not practical, the licensee should resubmit this relief request sud provide the techn: cal justifications foi their being impractical.

(Reference TER Section 2.4.1) 1 5.9 in pump Relief Requests pRR-ll and 12, for the boric acid transfer pumps, the licensee requested relief from measuring pump now rate quarterly and performing an inservice test quaiterl,,, respectively. The proposed alternate tasiing in Relief Request pRR-ll states that during refueling outages all parameters required by IWp.3100 will be met. Ilowever, Relief Request pRR 12 states that only the flow rate will be verified and vibration will be measuret as practical in order to be i

i consistent with the NRC's position stated in Generic Letter 89-04, the licensee must at least measure pmup differential pressure and vibration quarterly and all parameters at refueling outages. From the information provided it appears that instrumentation is not currently avadable to measure pump differential pressure using the quarterly test Dow path. The licensee should seview the relief sequests and resubmit them with clarification of how the criteria of Generic Letter 89-04 will be met with regard to measurement of pump differential pressure and vibration. If the appropriate _ instrumentation is not available, the licensee should evaluate the -

procurement and installation of instrumentation to meet the criteria contained in Generic Letter 89-04. (Reference TER Sections 2.5.1 and 2.5.2) 5.10 in pump Relief Request PRR 13. for the service water pumps, the licensee requested relief from measuring pump inlet pressure. The proposed alternative involving the calculation of inlet pressure based the water level in the intake structure is an neeptable alternative as long as it is properly proceduralized to ensure the result is within the Code accuracy requirements using direct measurement. The licensee shouhl develop or modify existing procedures to sathfy this requirement. (Re'erence TER Section 2.6.1) 5.11 in pump Relief Request pRR-15, for the chilled water pumps, the licensee requested relief from measuring pump flow rate quarterly. Ilowever, the licensee did not demonstrate that the procu r ement and insta;;ation of appropriate instrumentation wouki be impractical or would impose undue hardship without a compensating increase in the level of quality or safety. The proposed alternative testing does not pimide an acceptable alternatiw to the Code requirements. The 68

-. =

licensee shocid investigate the practicality of procuring and installing instrumentation to meet the Code ;equirements.

Installation of flow instrumentation would also eli ninate the need for Relief Xequert No. VRR-31.

(Reference TER Section 2.71) 5.12 In pump Rehef Request PnR 3, for the safety injection pumps, the licemee d:d not address an lastrumented test line which exists and could provide an alternate test ilow path. Tne lice zee should address thir test line in the inservice 5.est program and provide justification for uct using it. Additionally, the licensee should address the modifica: ions discussed in their Oc:ober 2,1990 ktttr to the USNRC.

(Reference TER Section 2.2.1) 5.13 Section 4.2 of the IST Program incorrectly references ASME Section XI paragraph IWP 3400. The correct references aie paragraphs.!WV-3400,3500 and 3600. The legend of the IST Valve Program Tables (Appendices D and E) incorrectly reference paragraph IWV 2200 for the vahe category. The correct reference is IWV 2100 for the 1986 Edition of the Code.

5.14 Section 4.4 of the IST Program states that the full stroke check valve exercises are required to be performed at "the piedicted full accident condition flowrate." Relief Request VRR-2 states that full stroke er.ercising requires the " nominal accident fWwrate.' la accordance with Generic Letter 89-04, Attachment 1, Position I check valves shall be full stroke exercised by passing the " maximum required accident conditie:. Gew through the valve." Specific relief is iequire<l if a flav rate other than that specified in the Generic Letter is utilized. The licensee should clarify the test flowrates used.

5.15 The legend of Appendices D and E states that leakage test "SLT-5" requires a " seat leakrate test to identify gross leakage. Specific leakage rates will not be measuied."

ASME Section XI, paragraph IWV-3420, requires leakage to be measured and corrective actions if the leakage rates exceed the permissible leakage rates (IWV-3476). Test "SLT-5" has been specified for Category A valves (e.g., RibOO742, 742A). Specific relief is required if leakage rates are not measured in accordance with the Code.

5.16 The legend of Appendices D and E states that proper operation of the a sociated mam valve verifies operability of the pneumatic pilot valve.

(Reference test

" BTP V").

Section XI provides requirements for testing individual valves for degradation. There has been a history of problems associated with the solenoid-operated pilot valves (e.g., Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety Related Equipment," NRC Information Notices 88--43,

' Solenoid Valve Problems," 90-11, " Maintenance Deficiency Associatect with Solenoid Operated Valves," 86-57, " Operating Problems with Solenoid Operated 69 i

7_..-.-._-.~.-------..--_-.---._.--

j 4

Valves a Nurbar Pimer Plants" and NUllEG.1275. Vol. 6," Operating Experience i

Feedhsek Report-Solenoid Operat-d Valve Problems").

Testing the main valves may piovide sufficient information for determinUp the operability of the pilot paeumatic valves. llowever, this is not ahvays the case. For example, testing the MSIVs (MS 02017 and 02dl8) wiU ossure tinat either MC-02017(8)C or D viil open te fulfi!! their safety function. Thes: valve alc recuadaat j

per the FSAR and the operatbn of only one cf die valves will dose ine MSIVs.

i Therefore, the "HT P\\" test specified does not nact the intent of the Code to verify the opuation,1 readiness of individeal valves. The licenme 'hoald teview those ulves tested by the "IlT-PV" method and ensure that each valve's open.tional icadiness can be assessed by testing the niain valve.

Additionally, vahes M3 02017(S)A and B are not meluded in the IST program..it appears in redewing the FSAR that theso vahes are sequired to close by a signal

)

from the steam line bred protectior. system. The licensee should resiew these valves for inclusion in the IST Program.

5.17 Note 1 of Appendices D and E states that "the tests specified must not necessarily satisfy the conespondmg requilements of Subsection IWV or NRC Generic Letter 1

89 04." "May not" is more appiepriate wording.

i 5.18 There are numerous cases where solenoid or air operated valves are not fail safe tested (e.g., RC-00580A and B,101-00624 and 623). The licensee has not proviihd any justification in the IST Program for not testing these valves. Valves that are passive should be so noted in the program.

5.19 in reviewing Relief Request No. VRR-33, it was noted that' valves F014, FOSS, F03922, FO3930 and F03031 are not included in the IST Progrmn while other I

valves ia the emergency diesel generator fuel oil syste.n me includeo (FO-03940 and 3941). *1he licensee should review this systuu to ensure all ulves necessary foi safe operation are tested to denionstrate that they will perform satisfactoniy in scivice.

5.20 in Relief P.equest No. VRR 31, the licensee has proposed a disassembly and inspection program and partial stroke exercising the chilled water pumps' discharge check valves. The proposed disassembly and inspection program does not comply with Generic Letter 89-04, Attachment I, Position 2, therefore ictief has been granted with the provision that the disassembly vnd inspection program be revised.

The licensee has aise been requested to investigate the use of non intrusive methods to verify valve position to comply with the criteria contained in the Generic Letter.

(Reference TER Section 3.2.1) 5.21 The applicable Point _ Beach Unit (s) to which the valve relief request apply is confusing. Some relief requests specifically list both Uniu' valve numbers (e g.,

J 70 b

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E VRRed and 30) nad other requests iruply, tinough the referenced system drawing numbers, that the iclief applies to both Unin (c g., URR 1 and 2). The licensee snould identify the app cable Unit (L) consi:,tendy and deally. A dditionally, Relief Request No. YRP. 32 and the Table of Contents identifies valves 01652 and 01653 as Unit 1 alves. AppemM E lists these sabes as Unit 2 valvc -

5.22 llelief Request Ne. VRR.1 states that the relie; h ge: cric. Ilowes er, it specifical;y lienalve MS.02082 as the only component to which it apphes. The licensee should resolve this apparent inct.nastency. (Peference TEli Section 3.lLI A) 5.23 Relief Request No. VRR02 reqacsts relief fiom evaluating 2 inch valu 2 SI ft0845A through F in accordance wnh ASME Section NI, paragraph IWV 3427(b). This par;igraph is only required for vahes 6 inches and greates. Therefore, rehef is not required. (Reference TER Section 3.144) 5.24 In Relief Request No. VR R-25, the beeraec has propos(d in lieu of stroke testing, verifying the auxiliary feedwater pump.ninimum flow valve closes when the pump mairline flow reaches a value which assures the pa.np will not be damaged. Relief has not been reconunended, since it appeais that suoke tests can be re formed at least during cold shutdowns in accordance with Section,\\l.

(Heference TER Sec tion 3.1.1) 5.25 In reviewing Relief Rege st No. PRR 18 and VR R 28, it was noted that valves AF-00114,115,116, and 117 are not adthessed in the IST Program and valves AF 4002, 7 and 14 are nct tested in the open positioa. As stated in the relief request,"these valves open to ensure ininimum recirculation flow from the pumps to present pump damage." The piogiam should be revised to address these vahes' safety function in the open direction.

5.26 in ReFef itequest No. VRR 19, the licensee has propo3ed enrcising the (harging 9

pump discharge to RCP Mar.ual throttle valves each refueling outage. Relief is recommended provided the licensee nercises the vahes closed during any coh'

. shutdowns when the RCP are not running. (Reference TER Section 3.3.3) 5.27 in Re:ief Requests No. RR 24 and 26, the licensee has proposed :esting the Doric Acid Transfer Pumps' suction and discharge check valves each refueling. The licensee has not provided sufficient information and iustificatian to demonstrate the hardship or unusual di'ficulty of performing the tests during cohl shudowns.

Therefore, relief has not been reconunended. Additionally Rtlief Request No.

YRR-26 contains a discrepancy concerning installed flow instrumen,tutioc in the chargint' pump's flowpath. (Reference TER Sections 3.3A and 3.3.5) 5.28 in Relief Requens No. VRR-P, 9, 27, and the licenset has proposed valve disassembly and inspection progiams as a means to verify the vnhes wdl full strol e b5 71 6

o

4 open. The licensee has not, however, dneribed the disassembly and inspection programs :n sufficient detail to aAccriain they meet Peneric Letter t;9 04, i

At'achment 1, Prsition 2. Reliciis granted providcJ ine lisensee's Program meets all the criteria prxidrd in the Generic Letter. (Reference TER Sections 3.31 3.5.2, 3.14.7, and 3.13.!)

5 29 In Relief Request No. VitR 9, thc licensee tus proposed verifying the containment spray nonics' supply check valve er:crcise in the closed d.irection by the Appendix t

J leaktge tests each refueling octage. The beensce has not pavided sufficient justification for not testing these vahu quarterly or durint; cold shutdowns. Relief has therefore, not been recommended. Additionally, tne " Function" stated in the

. request appears incorrect.

The v4 ves open to piovide flowpath ftom the containment $ pray pumps to the spray noules (Refarence TER Section 3.5.2) 5.30 The Feensee has proposed testing the emergency diesel generator air starting r otor

-valves during the EDG start tests (Relief Requesu No. VRP.-17 and 25). The i

proposed testing ha< been determined to be acceptable provided the licensee assigns i

a maximum limiting diesel start time and verifies the operat oual readiness of the valves ici cach air start bank at least quaiterly by alternt, ting the air motor bank selected dus!r.3 testing. (Reference TER Sections 3.6.1 and 3.6.2) 5.31 Interim relief has been recommended for one year or until the next refueling ouraP,c, whichever is later, for Relief Reque.41 No. VRR 21 provided the licensee perfarms leakage tests of c.th set of feedwater check valves during cold shutdowns ar.d both volves ia a pair are declared inoperable and are icpaired or rf placed if excessive leakage is detected. In the intesim, the licensee should review the safety nnalysis, make ch:nges to the test procedure and perform the necest.any..ystem rnodifications, I

if individual testing is required. Additionally, the Relief Request should be revised to address the Categmy A leak test requirements ns stipulated in the IST Propam, Appendices D and E and correct the reference to 'WV 3522(a) in the "Section XI Requirement" parryaph. (Reference TER Ses..an 3,10.1) 5.32 - In Relief Reque.,t No. VRib34, the licensee has proposed testing the post-accident conteinment,ent manual centainment isolation valves yearly. The licensee has not prosided sufficient justification fsr extending the test frequency and relief has therefore not been recommended. (Reference TEll Saction 3.121) 5.33 The licensee has proposed in Reuef Req.,est No. VRR4 to full stroke exercise the.

SI pressure isolation valves ct refueling outages. Relief has been recommended for t

valves SI 00845C and D. liased on the existence of a partial flow test line for valves g

St.00845 A,13, E, and F, relief has been secommended for these valves provided -

- that the !!censee performs a partial-stroke test during the Technical Specification ,5.4.16 tests. (TER Sec. ion 314.I',

9 72 e

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5.34 In Relief Request No. VRR.4, the licensee has proposed partial stroke exercise tests and a valve disanembly and ir.spection program to verify the operational readiness of tia Si and Si accumulator (heck vanes to open Itelief has been recommended for valves SI 00842B. llowever, selief can only be reconunended for the remaining valves if the disassembly and inspection program is revised to comply with Generic Letter 89 04 Attaclunent 1, Position 2. (TER Section 3.14.3) 5.35 In Relief Request No. VRR-6, the licenace has stated that there is no se s n flowpath to the RWST to test the R% ST to RllR Pump Suction check valves. The Point Beach drawings identify a "ref uelin;' water return" path to the RWST. The licensee should provide a explanation of why this flowpath cannot be used for testing. (TER Section 3.14.4) 5.36 lhe licensee has requested relief from stroke-time testing the auxiliary feedwater pumps cooling water solenoid valves and has proposed measurint system parameters (Relief Request No. YRR 20). Interim relief has been rewnnuended for one year or until the next refueling outage, whie eer is later, to provide the licensee time to evaluate. einate test methods. In the int *im, the licensee should perform the proposed tests quarterly and if any degradat an in these valves is noted, corrective l

action is taken and the valves declared inoperable if they cannot be repaired within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> specified time period. (Reference TFR Section 3.11.2) 5.37 The licensee has proposed assigning a niasinmm leak rate for combinations of valves where individual testing is impractical in Relief Request No. VRR-23. Based on a review of the piping and instrument diagrams (P&lDs), it appears that for the component cooling water, instrument air and post accident containment venting and monitoring systems that it is practical to individually test the valves. The cfore, relief has not been reconnnended for the valves in these systems Relief has been recommended for the other system's vahes referenced in the request. Only those valves reference 3 in Table VR-51 were evaluated. The licensee should revise the relief tequest to addiess the additional valves th.,1 reference llelief Request No.

VRR-23 in Appendices D and E (Reference TER Section 3,16.1)

Additionally, based on a review of the P&lfh and FSAll figures 5.210,5.212, and 5.2 20 (June 1991 revision), there appears to be discrepancies on the location of test connection-.

5.38 Relief Request No. YRR 5, the licensee has proposed 'iulizing the ASME/ ANSI OM, Part 10 requirements for cold shutdown testing valves. Additiona'ly, the licensee has proposed that completion of all valve testing during cold shutdowns is not required if plant conditions preclude test;"y. Use of ASMIUANSI,JM, Part 10 is determined to be acceptable. llo.vever, generic reli f cannot be recommended for valves that cannot be tested during any cold shutdown of sufficient duration to complete cold thutdown testing. Additionally, the requatt " Alternate Testing" 73

l r eferences paragraph IWP-3417(a).

The coriect reference is IWV-3417(a).

(Reference TER Section 3.17.1) 5.39 Relief Request No. YRR-27 and the IST Program Appendices D and E only e

addiess testing the valve in the open direction. The licensee should review the salety function at the Safety inspiretion Pumps' minimu:n flow line check valves (SI-00891 A and 11) and ensure that they are tested in all direction (s) required to verify their safety function (s). (Reference TER Section 3.14.7) 5.40 liased on a review of the containment spray system for Relief Request No. PRR-6, it was noted that the n:inimum flow line chech valves, SI 00849A and U, are not included in the licensee's IST Program. The licensee should review the safety function (s) of these salves and ensure they are tested to verify their safety fuW n(s).

5.41 The valve numbers rekrenced in Relief Request No, VRR 16 da not appear on the referenced drawmgs. t he TER evaluation is only valid if the reviewers assumptions on the subject vnives are correct. (Reference TER Section 3.8.1.1) 5.42 The licensee should addren the proposed system modifications discussed in their October 2,199u letter to 'he USNRC in Relief Request No. PRR-4. (Reference TER Section 2.2.3) 5.43 in Relief Request No. PRR-5, the licenwe has proposed testing the turbine-driven auxiliary f"edwater pumps at cohl shutdowns. liased on the apparent lack of motive power (;.e., steam) during cold shutdown conditions, relief was denied. The licensee shouhl revise the relief request to dbcuss the conditions required for testing these pu mps. (Reference TER Section 2.3.1.4) 5.44 in Relief Request Not PRR 4,5,17 and 18, the licensee has referred to using a three data-point pump curve. It is the opinion of the NRC that if pump refercnce curves aie used in lieu of reference point (s) as required by Section XI, paragraph IWP-3100 selief is required. It is unclear from Relief Request Nos PRR-4,5,17 and 18 whether a reference cutxe or multiple reference points (lWP-3112) are utilized.

6.0 REFERENCFS 1.

" Inservice Testing Program for Pumps ar.d Valves Point licach Nuclear Plant, Units 1 and 2," C.W. Fay (WEP Co) to USNRC, June 10, '1991, VPNPD 91-186.

2 "1990 Pump and Valve Inservice Test Program Point 11each Nuclear Plant. Units I and 2," C.W l'ay (WEP Co) to USNRC, April 22,1991, VPNPD-91-128.

74 i

3.

'Insenice Testing Program for Pump and' Valves, Point Beach Nuclear Plant, Units I and 2 " C.W. Fay (WEP Co) to USNRC, December 21,1990, VPNPD 90 500.

4.

• Supplement to Generie Letter 88-14 Re.tponsc,, Point Peach Nuclear Plant, Units I and 2," C.W Fay (WEP Co) to USNRC, September 5,1991, VPNPD 91303.

5.

"Insenice Testing Program Point Beach Nuclear Plant," C.W, Fay (WEP Co) to A.

DiBiasio (UNL), September 18,1991, VPNPD 91-363 (Transn.ittal of RilR and AFW Pump Curves and Procedures IT-01 and 02).

6.

" Guidance on in. Service Testing Programs, Genede Letter 89 04 Point Beach Nuclear Plant, Units I and 2 " C.W. Fay (WEP Co) to USNRC, October 3,1989, VPNPD-89-519.

7.

AS ate Boiler and Pressure vessel Code,Section XI, ilules for Inservice Inspection of Nuclear Power Plant Components,1986 Edition.

8.

Point Beach FSAR and Technical Specifications.

. 9.

ASMEM NSI OMa 1988, Part 6,"Inservict Testing of Pumpsin Light Water Reactor I

Powe Plants."

10.

ASME' ANSI OMa 1988. Part 10. "Insenice Testing of Valves in I.ight Water Reactor Power Plants."

l 11.

10CFR50.55a 12.

Standard Review Plan, NUREG 0800, Ecetion 3.9 6, hvervice Tes:ing of Pumps and l

Valves, Rev. 2, July 1981.

13.

NRC Generic Lettet 89-04."Guidaece on Developi:g neceptable Insenice Testing Programs," April 3,1989.

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

I 15.

NRC Generic Letter No. 90 06, Resolution of Generic Issue 70, " Power Operated Relief Val,e and Block Valve Reliability," and Generie Issue 94," Addit:0 4al Low-Temperature Overpressure Protection for Light Water Reactort," Pu,soant to 10CFR50.54(f).

16.

EPRI NP 6516, " Guide for the Application and Use of Valves in Power Plant Systems "

17.

NRC Infornntion Notice S. J, "Cacek Valve Failures," December 2,1981.

75 i

v,-w.,--

w w

..i-s-E,

..,4.-

,1,,

. m w. i.

..,,,,.,w.,,,,.._m

,4,

..,,,,,,,_-,,w_.

w.

.ys--~.w.,

---r-

-w1--

_. 7 _ - - _... - - _

18.

NRC Information Notice 88-85, *llioken Retaining lilock on Anchor Darling Check Valves," October 14, 1988.

19.

NRC Ilulletin 89-02, " Stress Corrosion Cracking of liigh llardness Type 410 Stainless Steel Internal Preloaded llotting in Anchor Darling hiodel S350W Swing Check Valves or Valves of Similar Design," July 19,1989.

20.

NRC Information Notice 88 43, " Solenoid Valve Problems," June 23,1988.

21.

NRC Information Notice 90-11,"hlaintenance Deficiency Associated with Solenoid-Operated Valves," February 28,1990.

22.

NRC Information Notice 86 57, " Operating Psoblems with Solenoid Operated Valves at Nuclear Power Plants," July 11,1986.

23.

NUREG.1275 Vol. 6," Operating Experier.ce Feedback Report Solenoid Opciated i

4 Valve Problems."

i 24 NRC Information Notice 87 01,"RllR Valve hiisalignment Causes Degradation of ECCS in PWRs/ January 6,1987.

25.

NRC Generic Letter 86

4. " Instrument Air Supply Sptem Problen,s Affectir g Safety-Related Equipment, August 8,1988.

26.

NRC Regalatory Guide 1,147 " Inservice inspection Cade Case Acceptability, ASME l

Section XI,' Division 1," Revision 8, November 1990.

27.

" Genetic Letter 89 04, Guidance on IST Psograms Point Beach Nuclear Pbut Units

' and 2." CW.- Fay (WEPCo) to USNRC, January 16,1991, VPNPD-91-029.

28,

" Guidance on IST Programs, Ceneric Letter 89 04 Follow Up, Point Ileach Nuclear Plant, Units I and 2,' CW. Ifay (WEPCO) to USNRC, March 2,1990, VPNPD 90-101.

.29 Guidance on IST Programs, Generie Letter 89-04 Follow Up, Point Beach Nuclear Plant, Units 1 and 2," CW. Fay (WEPCO) to USNRC, June 28,1990. VPNPD 90-3

-310.

30.

"NRC Dulletin 88 04 and Generic Letter 89 04, hiinimum Flow Testing Capabilities

- for RilR, Si and Containtaent Spray Pumps" CW. Fay (WEPCO) to USNRC, October 2,1990, VPNPD 90-429.

l 76 l

l

_,~....g_..._.._

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

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

7._______.____.__________._________.._

Appendit A: l'aint lleacli l'iping and insinnuent 1)lagrams (l'KIl>s)

Palp Shert Spkm l<n iston Alternate Drawing 4

Nwnher M 2al 1

Main anj ltchtat Steam 27 (Pil 01 MMSK4XTuol.27)

M 202 i

CovJensate 23 (Pil-01 MCDK4aryol.23) 2 Ferdaatcr 22 (Pil 01 MlwK4t040122)

M 21r/

I smice Water 3h (Pil-01 MWSK4uMo3 38) 2 25 el'Il411 MWSK4atuni.25) 3 24 (Pli.01.MWSK4uMo4 24) 4 11 (Pil01 MWSK4:aMo211)

M 2(N 2

Service Air 03 (Pin 31 MSAK4r Mol413) 7 Instrument Air 17 (l'il 31 MIAK4tXMU7171 5

14 (Pil 31.MlAK4:0406 14) 11 15 (l'It 31 MIAK4sO4rA15) 12 l'awp ney D,oci (o

(PD 31.MOOKanMailan)

Air Saatting M 214 1

Aut. Sun. Iltatmg Stm.

33 (Pil-Ol MASK 4NRMol 33)

[

CinlicJ A flot W.,ter 2

17 (Pil-01 MASKJ AH4H217)

M 213 1

!!cating A Wntdation 27 (Plo01.M VitK40 y nl.27) 2 12 (Pil 01.M VitKanuo212) 1-M 217 1

Aux. Feedwater 48 (Pil4:1 MAFK4 xMol 48)

M 219 1

Fut! Oil 21 (I Il-01 MFOK4xfMul.21)

M 223 1

latrument A Serse 24 7

Instrunient Air 0

M.224-1 twA c. Cuntainment 16 (Pil 01-Ml(MW o x14nt.16)

Venting M 2201-1 Main and Itcheat Steam 20 (Pil412 MMSK4RMol.20) 1 l

M 2202 2

FecJwater 21 (Pil02 MiwK4tu4ol.21)

M 4207 i

Str&e Water 34 (Pil412 MWSK4HMO2 34)

M 2214 1

Aut Sim. IIcating bun.

11 (Pilar 2 M(07405 wo ll)

M 4215 1

llcating and Watilation 17 (Pil40 Mml44WU217) l' 2

7 (Pil 02 MVitKAIMol 07)

M '44 1

ileating and Vrntilation 6

2 lem;w;raturr Control 3

(Pil.31.M(Ol408AA18 03)

PilM 230 1

I<adwaste Comp. Cuil.

7 (Pil 31 MnE4HidAll 07) l-PitMQ.31 --

-1

Deionized & lseactor Make-22 (PIL31 MitWK4uust2-22) l up Water i

5 (Pil.31 MitWK4uunl4 5) l

~

77

-..a - -.-.

e a.

~

1101'017 1

Safety injection 32 (Pil-Ol hil3X4NO4tl2 32) 2 31 (Pil 01 MSIK-fnO40131) 1101U18 i

Autiliary Coolant 36 (I'll4)l MSFK4KENtl2 36) 2 13 (Pil411 MO*eXMall 13) 3 21 (l'1101 MCCKutkC0121) t 24 (Pit 01 MSFK411Mol 24) 110!!029 1

Aurilmy Cmlant 32 (PlVC MSIKat40132) 2 11 (Pil 02 MitmatkV11 ll) 3 21 (I'll 02 MSIK4tKMU3 21)

!!01:035 i

Saruy injection 31 (Pil4c M(ta4119 wo 31) 2 30 (Pil40 MS!K4 040130) 1 31 (Pit-02.MSIKaturQ 31) 311Po>l 1

Reactor Coolant 27 (Pit-01 MRCK4WO4H127) 2 li (Pli-01 MRCKo nMC215) 54 !!U12 1

Sanipling 24 (Pli 01 Mi$K4t aM01241 541F445 1

Reactor Coolant 30 (Pil40 MRCK41rMol.30) 2 12 (Pil 02 MRCKatM0212) 54sF448 i

Sanipling 26 (PIMC-MPSK no4012ti)

(45)175 1

CAVCS 37 (Pil-02 hK3'K40402 37) 2 37 (Pil 02 MCVK4s nMol 37)

(A4J741 1

CAVCS 41 (Pit-01 MCVK4stuul2-41) 2 41.

(I'll 01 MCVK41xMo! 41)

'M1971 1

Waste Diyosal 40 (Pil 31 MRIE4XAMU2 40) 4 2

(Pin 31 MRIL00lMol 401 l

78

• , p w-w 4 m-r-y,w e,,

y-

.,=+,s4r wrywge--

-y-rrrn.

w.-.n-,7--r-v.

,-,s

..+,p.

g-e,-4,4 w.

v w ---

w

.-r-

-' rom-c.a ae ' ese'r

~