ML20126H760
| ML20126H760 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/30/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20126H739 | List: |
| References | |
| NUDOCS 9301050312 | |
| Download: ML20126H760 (19) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NVCLEAR REACTOR REGULATIDN RELATED TO INSERVICE TESTING PROGRAM AND RE0 VESTS FOR RELIEF DV0VESNE llGHT COMPANY OHI0 EDIS0N COMPANY PENNSYLVANIA POWER COMPANY BEAVER VALLEY POWER STATION. UNIT NO. 1 DOCKET NO. 50-334
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain 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 relief has been granted or proposed alternatives have been authorized by the Commission pursuant to 50.55a(f)(6)(i), 50.55a(a)(3)(i), or 50.55a(a)(3)(ii).
In requesting relief or proposing an alternative, the licensee must demonstrate that:
(1) the code requirement is impractical for its facility; (2) the proposed alternative provides an acceptable level of quality and safety; or (3) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.
NRC guidance contained in Generic Letter
.(GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provided alternatives to the Code requirements determined to be acceptable to the staff and authorized the use of the alternatives in Positions 1, 2, 6, 7, 9, and 10 with the provision that the licensee follow the guidance delineated in the applicable position.
When an alternative is proposed which is in accordance with GL 89-04 guidance and is documented in the IST program, no further evaluation is required; however, implementation of the alternative is subject to NRC inspection.
The Code of Federal Regulations, Section 50.55a authorizes the Commission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the necessary findings. The NRC staff's findings with respect to granting or not granting the relief requested or authorizing the-proposed alternative as part of Duquesne Light Company's (the licensee's) IST program are contained in this Safety Evaluation (SE).
The Beaver Valley Power Station, Unit 1, IST Program was developed in accordance with the 1983 Edition, t,irough Summer 1983 Addenda, of ASME Section XI.
This -SE concerns relief requests and supporting information that were submitted by letters dated August 18, 1992, and September 25, 1992, for 9301050312 921230 PDR ADOCK 0500 4
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2-the Beaver Valley Power Station, Unit 1, IST program. The IST program included in the September 25, 1992, submittal generally incorporates the information included in the August 18, 1992, submittal, which provided the licensee's response to 29 anomalies identified in NRC's SE dated May 6,1991, supplemented by an SE dated January 24, 1992.
The attached Table of Anomalies details each of the anomalies, discusses the actions taken to address the concerns, and provides the current status of relief requests related to anomalies and any remaining outstanding actions.
New or revised relief requests, other than as indicated acceptable in the table, are evaluated below.
2.0 RELIEF RE0 VEST VRR,21 A!: identified in Anomaly 21 of the Hay 6, 1991, SE. Interim relief was granted for 1 year or until the next refueling outage, whichever is longer.
The August 18, 1992,
%mittal included a revised relief request which addressed the anomaly relai., to a maximum leak rate for testing two containment isolation valves in parallel.
Outside containment-isolation valves, TV-CC-Il0F1 and 110F2 (cooling water return from the containment air-recirculation cooling coils to the chilled water and river water systems) are a Category A passive 8-inch globe valve and a Category A active 8-inch globe valve, res)ectively.
The requirennts of IWV-3426 and IWV-3427(a) specify that a lea (age limit for each valve be established.
2.1 Licensee's Basis for Relief The licensee states:
As shown on the attached figure (figure not included in SE) for Penetration #11, the configuration of this containment perJ.tration (1.,, two outside containment isolation valves in parallel) is such that individual leakage rates for each specific valve cannot be determined using the test method of 10 CFR 50, Appendix J.
The boundary valve downstream from TV-CC-Il0F1 is a potentially open check valve leading to the circulating water system. The river water system downstream of TV-CC-110F1, therefore, cannot be isolated to provide an accurate leakage rate from TC-CC-Il0F2.
In this case, assigning individual leakage rates is not aractical.
Therefore, a maximum permissible leakage rate will be assigned to tie entire penetration.
The maximum rate assigned to the penetration, however, will be conservatively set at the value normally assigned to just one 8-inch isolation valve."
2.2 Alternative Testing The licensee proposes:
" Assign a maximum permissible leakage rate for the entire barrier to then be used as the criteria for initiating corrective action in accordance with IWV-3427(a)."
2.3 Evaluation L
in rulemaking effective September 8, 1992, the NRC approved the 1989 Edition i
of ASME Section-XI. The rules for inservice testing of valves referenced in
?
the 1989 Edition of Section XI, Subsection IWV, are OM-10, Inservice Testing i
of Valves in Light-Wate. Reactor Power Plants.
The rulemaking indicates that
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. the staff took exception to the OM-10 requirements for containment isolation valves (CIVs) and imposed the requirements of 1 4.2.2.3, " Leakage Rate for Other Than Containment isolation Valves," for CIVs.
Paragraph 4.2.2.3(e),
" Analysis of Leakage Rates," specifies that " leakage rate measurements shall be compared with the permissible leakage rates specified by the plant Owner for a specific valve or valve combination." The licensee's proposal is in accordance with the requirements of OM-10. Paragraph 4.2.2.3(e),
Prior editions of Section XI did not address leak testing of valve combinations.
The desigh configuration of the subject valves does not allow for individual leakage rate determination.
Therefore, it is impractical to meet the requirements of Section XI, IWV-3426 and IWV-3427(a) for the applicable valves.
However, the licensee has proposed leakage testing the penetration and assigning a maximum leakage limit to the valve combination based on a the allowable limit for a single 8-inch valve.
The proposed method is in compliance with OM-10,14.2.2.3(c) for leakage rate analysis, which has been approved by the staff and will provide assurance of the operational readiness of the valves.
Imposition of the requirements of Section XI would be a burden on the licensee based on the modifications that would be required to facilitate individual valve leakage determination.
The modifications would not be required under the latest Code edition as referenced in 5 50.55a.
2.4 Conclusion Relief is granted to leak test these valves in parallel pursuant to 10 CFR 50.55a(f)(6)(1) based on the impracticality of the design to facilitate testing and the burden if the requirements were imposed.
The proposed alternative testing provides assurance of the operational readiness of the parallel valves for leaktight integrity of the containment and is in compliance with the requirements specified in OM-10, 1 4.2.2.3(e).
3.0 REllEF RE0 VEST VRR-41 Relief Request VRR-43 concerns the quarterly exercise and stroke timing of six Class 3 solenoid operated valves (SOVs) that function to control the power operated relief valves (PORVs).
The PORVs perform a safety function to provide overpressure relief when the plant is in a low-temperature mode _of operation (low-temperature overpressuriution - LTOP).
LTOP was designated as Unresolved Safety Issue A-26 in 1978 (NUREG-0371).
Staff guidance related to inservice testing and technical specifications for the PORVs was provided in NRC Generic Letter 90-06, Resolution of Generic Issue 70, " Power-operated Relief Valve and Block Valve Reliability," and Generic Issue 94, " Additional Low-Temperature Overpressure Protection for Light-Water Reactors," pursuant to 10 CFR 50.54(f).
3.1 Licensee's Basis for Relief The licensee states:
"These series SOVs are located inside the subatmospheric containment building and do not have position indication.
There are no individual control switches or lights associated with the valves.
Individual operation of these valves can only be monitored by locally disconnecting a lead for one of the SOVs and observing the PORY stroke.
The 50V stroke cannot be timed directly, bacause the valves cannot be stroked without stroking the l
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. 1 p0RVs, relief is requested from quarterly full or part stroke and time testing at power.
In addition, stroking the 50Vs associated with the low-temperature overpressure protection system cannot be performed while it is in service; therefore, relief from cold shutdown stroke and time testing is also requested."
3.2 Alternative Testing The licensee proposes:
A refueling frequency test procedure will be developed to individually stroke the SOVs open and closed. The valve stroke time will be indirectly measured by timing the PORV stroke.
An acceptable PORV stroke time will indicate an acceptable 50V stroke time."
3.3 Evaluation The intent of stroke time measurements for power operated valves in accordance with IWV-3400 is to allow for determination of degrading conditions.
If a valve experiences an increase in stroke time, particularly in solenoid valves, internal sticking or binding could be indicated and corrective actions could be initiated prior to a condition which results in the valve being inoperable.-
Section XI requires the testing of power operated valves be performed quarterly or during cold shutdown.
OM-10, 1 4.2.1.2, allows extension of the frequency to during refueling outages when testing is impractical quarterly and during cold shutdown conditions.
The subject S0Vs cannot be exercised and stroke-timed directly due to limitations of the design.
There are no individual control switches or position indicating lights. However, during refueling outages, each individual valve can be controlled by lifting an electrical control lead.
This will cause the associated PORV to stroke which verifles that the individual SOV stroked to control air to the PORV. Measuring the.PORV stroke time provides an indirect indication of the stroke time of. the 50V which will allow for monitoring the condition of the valves.
This test method, while not direct, does meet the intent.of the Code.
The testing cannot be performed quarterly during power operations because a plant transient would result.
Testing during cold shutdown conditions is not practical because the valves function in the low-temperature overpressure protection system which is required to remain operational during cold shutdown conditions.
Performance of the test requires the PORVs and the SOVs to be inoperable.
Therefore, the only practical plant condition for performing the test is during refueling outages when the PORVs are not required to be operable.
Imposition of the Code requirements would be a burden in that the licensee could be forced to perform the testing during a plant condition that is prohibited by the plant safety analysis or to modify the system to enable monitoring'the position of the check valve disks.
3.4 Conclusion Relief is granted for extending the test frequency a.d utilizing an -indirect method for measuring stroke time for the subject solenoid operated valves pursuant to 10 CFR 50.55a(f)(6)(1) based on the impracticality, due to limitations of design, of performing the testing in accordance with the Code 9
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. requirements, the burden on the licensee if the requirements were imposed, and consideration that the proposed testing method and frequency provide assurance of the operational readiness of the valves and generally meet the intent of the Code (test method) and frequency of OM-10.
4.0 REllEF RE0 VEST VRR-44 This relief request relates to the quarterly full stroke exercise of the Class 3 Category A/C PORV air supply isolation check valves.
These valves are 3/4" check valves which have a safety function to close.
They are not required to open to fulfill a safety function.
4.1 Licensee's Basis for Relief The licensee states:
"The safety function of these valves is to close on loss of instrument air to allow the back-up nitrogen accumulators to supply the control air system for the PORVs.
These check valves are located inside the reactor containment building and valve closure can only be enecked by a leak test."
4.2 Alternative Testing The licensee proposes:
" Valve closure is verified by leakage testing during refueling outages."
4.3 Evaluation The test frequency for the subject valves must be based on the requirements for PORV operability.
During power operation, the leakage test cannot be performed because the valves are not accessible (inside reactor building).
During cold shutdown conditions, the PORVs are required to remain operable for functioning in the low-temperature overpressurization mode.
Therefore, refueling is the only plant condition that allows for the subject valves.to be leak tested to verify closure capability. 0M-10 1 4.3.2.2 specifies-the acceptable exercising frequencies for check valves and allows for exercising, or in this case verification of closure by leakage testing, to be deferred to refueling outages if it is impractical to perform during pcwer operations or cold shutdown conditions. Therefore, the licensee's proposed test frequency is consistent with OM-10.
. Testing during power operations is impractical due to the location of the valves because the only available test method requires access to the valves.
Testing during cold shutdown conditions could impact:the operability of the PORV and is,. therefore, impractical based on operational limitations and concerns.
Imposition of the Code requirements would be a burden because the test frequency could only be implemented if modifications were made to the air l
supply system for the PORV.
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.. 4.4 Conclusion Relief is granted for extending the test interval for the PORV air supply isolation check valves pursuant to 10 CFR 50.55a(f)(6)(1) based on the impracticality of performing the testing at the Code required frequency, the burden if the requirements were imposed, and in consideration that the proposed test frequency conforms with the requirements of OM-10 and provides assurance of the operational readiness of the valves to close.
5.0 REllEF RE0 VEST PRR-ll The licensee has requested relief for various pumps to allow utilization of pump curves for performing testing and establishing acceptance criteria. The use of pump curves has not been addressed in Section XI or in OM-6,-Inservice Testing of Pumps in Light-Water Reactor Power Plants.
The licensee has based their justification for relief on the premise that using pump curves provides an equivalent level of quality and safety in trending pump performance and degradation.
The staff does not agree with this conclusion.
Therefore, the relief request, as written, cannot be approved.
If the licensee determines that for certain pumps, testing in accordance with the Code is impractical, specific relief should be requested describing the impracticalities of performing testing at a reference value of flow or differential pressure and the related burden.
In the relief request, the licensee should discuss the following guidance related to using pump curves:
(1) Curves are developed, or manufacturer's pum) curves are validated, when the pumps are known to be operating accepta)1y.
(2)
The reference points used to develop or validate the curve are measured using instruments at least as accurate as required by the Code.
(3) Curves are based on an adequate number of points, with a minimum of five.
I (4)
Points are beyond the " flat" portion (low flow rates) of the curves in a-range which includes or is as close as practicable to design basis flow rates.
(5) Acceptance criteria based on the curves does not conflict with Technical Specifications or Facility Safety Analysis Report operability criteria, for flow rate and differential pressure, for the affected pumps.
-(6)
If vibration levels vary significantly over the. range of pump conditions, a method for assigning appropriate vibration acceptance criteria should-
- be developed for regions of the pump curve.
(7) When the reference curve may have been affected by repair, replacement, or routine service, a new reference curve shall be ' determined or the previous curve revalidated'by an inservice test.
7 6.0 M(ERAL PROGRAM During the review, the following items were noted that may require action by
.the licensee.
6.1 When to Declare a Valve Inoperable The valve inservice testing program includes an apparent inconsistency in Section IV.A.2.e., Category A and P C '
s, e 4 IV.B.S., Category C check valves.
Section IV.A.2 states tha 7!
at icus to exhibit the required change of valve stem or disk positi n J <,e ' n k specified ASME limiting value of full-stroke time, the valve MU % addircd inoperable immediately and an evaluation of the valve's conds, e a h respect to system operability and technical specification shall by mado.
Section IV.A.2.e contradicts this general statement by stating that *1f the valve is not covered by any technical specifications and the condition of the valve cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the valve shall be declared inoperable per ASME." A similar discreaancy exists in the check valve section for a failure to exhibit the required c1ange of disk position.
The position stated in the general sections for declaring a valve inoperable immediately upon demonstration of exceeding its stroke time, or failing to exhibit the required change of disk position for a check valve, is correct and is in accordance with the guidance given in GL 89-04, Position 8, " Starting
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Point for Time Period in TS ACTION Statements." The guidance states that "it is the staff's position that as soon as the data is recognized as being within the Required Action Range' for pumps or exceeding the limiting value of full-stroke time for valves, the associated component must be declared inoperable and the TS ACTION time must be started." However, this statement was n91 meant to imply that valves which are api covered by TS are agi required to be declared inoperable when test data exceeds established acceptanco limits of Section XI.
It appears that the licensee has differentiated between valves covered by technical specifications and valves not covered by technical specifications. There should be no distinction other than that the inoperable condition of certain valves would not require entry into a TS ACTION statement The statements included in the referenced sections-of the IST Program appear to require the fo11 ming action for valves not covered by TS which fail to meet the inservice te.iting acceptance criteria:
(1) Declare valve inoperable immediately.
(2)
If not covered by TS and condition-cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. declare the valve inoperable.
As written, the valve would be declared inoperable twice. The discrepancy should be corrected.
6.2 Including Procedure Numbers in Relief Requests The content of the relief requests could be enhanced by providing additional information in the " Basis for Relief" sections. ' Additionally, in the
. Alternative Testing" sections, the licensee often states simply that the
. testing will be performed in accordance with XXX-littli procedure.
For example, in Relief Request VRR-17, the " Alternate Test" is stated as follows:
Full-stroke exercised open per 10ST-ll.14 during refueling outages.
Because the staff does not have copies of the test procedures, and these procedures are not provided as part of the inservice testing program, it is inappropriate to include these as references in relief requests. However, including test procedure numbers in the pump and valve tables is acceptable because the reference provides information necessary to determine which procedure performs the applicable test.
Rather than include references to test procedures in the relief requests, a description of the test method implemented by that procedure should be included.
The information would be much more useful to the 14RC in reviewing and evaluating the relief requests.
6.3 Recommendations Regarding Information to include in Relief Requests The staff believes that with the recent approval of OM-6 and OM-10, the number of relief requests will decrease, thereby reducing the overall burden on both the licensee's and NRC staffs. However, the staff notes that there are several improvements DLC could incorporate in future relief requests that could further staff review.
The relief requests do not specify the applicable system name or number.
The component lists in the IST Program are sorted by system number.
It would be useful to include this information in the relief requests.
References to particular documents (other than test procedures as
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discussed above) should include the name of the document.
For example, Relief Request VRR-32 references IE Bulletin 83-03.
While this information can be readily retrieved, for completeness, the licensee should include the title of the bulletin and explain the purpose of referencing it in the relief request.
Other than test procedures, the licensee includes references to technical
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manuals.
For example, in Relief Request VRR-30, the " Alternative Test" is stated as follows:
Maintenance is to disassemble and inspect one valve per refueling outage per ICMP-75-CRANE CHECK-1M. Without this document, the information is of no use to the staff in reviewing the relief request.
For implementing a disassembly and inspection program, the licensee should follow the guidance in Generic Letter (GL) 89-04, Position 2.
The appropriate statement for facilitating staff review, for example, would be as follows: A disassembly and inspection program will be utilized to verify the full-stroke capability of these valves.
The program will be implemented in accordance with the guidance in Position 2 of GL 89-04, " Guidance on Developing Acceptable Inservice Testing Programs." Based on the alternative testing conforming with the guidance delineated in Position 2, the relief is approved per GL 89-04.
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. Reduced drawings or system schematics are included for several of the relief requests.
These types of drawings should be included for all of the relief requests, if possible, to enhance the quality and completeness of the document.
6.4 Program items Relief Request VRR-7 lists valves TV-CH-F200A/0/C.
Pages 59 and 60 of the.
!ST Program list these valves as TC-Cil-200A/B and TV-Cil-200C.
The IST Program valve list could be enhanced by including the function of each valve and the type of actuator.
Relief Request VRR-27 includes both valves TV-CC110Fl/F2.
The valve table lists VRR-27 for valve 110F1, but not for valve 110F2.
If valve 110f2 is individually leak tested, it should be removed from VRR-27.
Principal Contributor:
Patricia Campbell
Attachment:
Table of Anomalies Date:
December 30, 1992 m
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TABLE OF ANOMALIES SAFETY EVALUATION INSERVICE TESTING PROGRAM i
BEAVER VALLEY POWER STATION, UNIT 1 Annmaty Description of annmaty (stay 6, 1991 50 Ott's Actiews to mMress Anrumely otrestarvting Actans 1.
PRR-1 the ticensee regtested to sessure vibration CLC had revised setief sequest PsR-1 to The actions recysested in velocity instead tif vibration displacement specify that vibration measurements are to be the anceanly are corptete.
for att pt.sps in tt e Ist program escept performed in ecceedance with the requirements to further action is residual heat removat and low head safety of CM-6.
The acceptance criteria of CM-6 is required.
Injection pups. The licensee requested to included in the relief request.
discontinue amuel bearitig terperature measurements on these same ptrps. The preposal to susnitor pt.mp vibration velocity in lieu of displacement and annual bearing tevuperature seasurements was determined to be en acceptable alternative with the provision that the licensee comply with att the vibration measurrJent regJirements of ASME Operations and Maintenance Standards, q
Part 6, Imervice Testing of Pures in tic 6t-Water sawtae powar F1 ants.
2.
PRR-2 The licensee requested relief from sensurirg CLC verified that the ir.tet pressure Interie relief was granted intet pressure f or the charging pucps and calculations meet the Cece requirements.
for one year er tritit the NOTE: PRR-2 pecposed to calculate intet pressure based Investigation cf the use of test connections nemt refueting outage, included several on the height of fluid above the p.rp for sensuring intet pressure is triderway and eAichever was longer. This purps discussed in suction. The proposed Dethod is acceptable will be resolved cbring refueling cutage 9R.
action is to be resolved several ancematies.
provided the accuracy requirements cf the If permanent er tewary pressure gauges are during refueling cutage W.
Code are niet. However, the reviewer noted to be used, these purps will be deleted from The Licensee will need to that Piping and Instrunent Diagrams indicate this relief regsest.
Instatt gauges, use test connections where instrumentation could temporary gauges, or revise be instat ted. Interim relief was granted to ard snit the relief altcw time for an investigation by DLC.
regsest describing that gauges were deterwined to be incractical and the reesens for this determinatim. These actions unast be <tNteted prior to stsetup f rom St.
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Anamely Descripticys__of Arumsty (May 6,1991 SE)
DtC's Actiors to address Anrummty outstanding Actions 3.
FRR-2 The licensee regaested relief from measuring DLC verified that the intet pressure the concems cf this intet pressure for the boric acid pros and calculations are within the Code required anomaly have been I
proposed to calculate intet pressure based accuracy.
ackfressed. ho further L
on the height of fluid above the ptry action is re wired.
suction. The proposed method is acceptaMe provided the accuracy requirements of the i
Code are set.
1 i
4.
FER-3 Relief from measuring ficw rate for the DLC verified that the flew rate calculations The ctvicerns of this boric acid pumps was requested with a are within Code accuracy requirements.
anesely have been proposst to calculate flow during refueting Separate vibration reference values will be acmressed. ho f Jrther j
outages. Relief was granted with the utilized for each test flow condition in the action is required.
provision that the licensee ensure that implementing procedures.
calculations performed seet the Code accuracy requirements for fIow sensurenent.
Ad$itionally, the licensee was to establish I
two sets of reference data for vibration because the flow patti utilized dJring refueling outages is different than the one utilized daring naarterly testing.
5.
par-2 the licensee requested relief free measuring DLC verified that the intet pressure The concerns ef this intet pressure for the safety injection calculations are within tte Code required anomaly have been ptrps and prorosed to calculate intet accuracy.
acifressed. too furthee pressure based on the height of fluid above action is re wired, the pomp suction. The proposed method is aceptable provided the accuracy require== nts of the Code are set.
6.
PRR-2 The licensee requested relief from measuring DLC verified that the intet pressure Interim relief was granted
~ 'et pressure for the qJench spray pumps calculations meet the Code requirements.
for w year or artit the L
croposed to calculate intet pressure Investigation of the use of test connections nest refueling outage, based on the height of fluid above the ptro for measuring intet pressure is mderway and e.f,ichever was tanger. This suction. The proposed method is acceptable wit t be resolved daring refueling cutage SW.
acticn is to be reselved i
previoed the accuracy requirements of the if permanent or temporary pressure gauges are during refueting outage 9R.
Code are met. Mowever, the reviewer noted to be used, these pros will be deleted from The licensee will need to that Piping and Instrument Diagrams indicate this relief re w est.
instatt gauges, use test connectiers where instrumentation could te porary gauge:, or revise be instatted. Interim relief was granted to ard submit the relief allow time for an investigation by DtC.
request describing that l
gauges were determined to be ispractical and the reasons for this determination. These actions must be completed l
prior to start e from 9R.
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An maty Description of Arvsamty (May 6,1991 SO D1C's Actions to Adiress Anmaty outstanding Actions 7.
PRR-2 The licensee revested relief from acesuring DLC verified that the intet pressure The concerns of this intet pressure for the inside recirculation calculations are within the Code required anoasty have been spray ptmos and prcposed to calculate intet accuracy.
acHressed. No further pressure based on the height of fluid above action is required.
the pump suction. The proposed method is acceptable provided the accuracy requirements of the Code are met.
8.
PRR-2 The licensee reg.aested relief f rom measuring DLC verified that the intet pressure The conce-ns of this intet pressure for the outside recirculation calculations are within the Code required ancenty have teen spray paps and proposed to calculate inlet accuracy.
acHressed. ko further pressure based on the height of fluid above action is required.
the par suction. The proposed method is 2
acceptable provided the accuracy reouirements of the Code are met.
9.
PER-8 Relief was requested from measuring flew The quarterly punp tests include measurewnt The licensee should ensure rate qsarterly for aunitiary feedwater (AFW) of both differentiet pressure and vibratim that vibration reference purps, and alternatively, measuring flow e.ith ctzverison to refereme values. The values are established for rate on a refueting outage frequency.
pays are also tested daring cold shutdoens the differe-it test i
Relief was granted with the provision that eben the futt-flow testing of the check cor. figurations as the ticensee investigate several valves is perfor1 ped, even though no credit necessary, depending on the discrepancies noted by the reviewers: (1) has been taken for the tests in the IST results of the tests. The testing at cold shutdonat was not discussed, Prog am.
The IST Pregram was revised to other correrns of the (2) cold shutdcwn justification 25 indicated reference the cold shutchn testing for these anmaty have teen that the AFM pap discharge check volves are psTs.
ackfressed. No further hRC fut1 stroked open daring cold shutchn, (3) action is required. The PRR-8 is not cortistent with the pep vibration reference values testing outline, and (4) vibration reference are stbject to WRC values for both test c mfigurations should inspection.
be established.
- 10. PRR-2 The licensee requested relief from acasuring OLC verified that the intet pressure The concerns of this intet pressure for the river water purps and calculations are within the Cade reg; ired arreely have been proposed to calculate intet pressure based accuracy.
addressed. No further cn the height of f tuid above the prp action is required.
suction. The proposed method is acceptaba,
provided the accuracy reoviren-nts of the Code are met.
- 11. PRR-10 The licensee requested relief from measuring DLC verified that the flow rate calculations the concerns of this flow rate for the dieset fuel cit transfer are within the Code re wired accuracy.
anomaly have been ptmps and proposed to calculate flow rate acHressed. No further based on the change in day tar
- tevet. Th?
action is required.
proposed method is acceptable provided the accuracy recuirements of the Code are met..
Anrumst y Description of An maly 04ay 6, 1991 SO CtC's Actiarm to Address Arumly Outstandirup Actims
- 12. VRR-7 The licensee proposed to assign a maximsa CLC evaluated the attonsable leakage rates for The concerns of this permissible leakage rate to the associated penetrations where indivioual teskage rates anomaly have been penetration and not individual valves, for cannot be obtained.
The maniasm attawable addressed. to further chemical volume and control system valves leakage rate assigned to the entire action is required.
TV-CM-200A, -2008, and -200C, as required by penetration is the value normatty assigned to the Code. Relief was granted provided the the smallest valve in the gro w.
In the timiting teak rate for the penetration is stbject penetration, the three valves are 8-conservative considering the neber and size inch valves. The individust attowable of the valves in the gro @ and does not leakage rate for one 8-inch valve is 160 allow excessive leakage through any scfd; therefore, the attaeable leakage rate particular valve in the group to go for this penetration is 160 scfd.
mcorrected.
- 13. VRR-16 The ticensee requested relief from This relief reqint was further addressed in The licensee is to take the exercisirrJ safety injection cold leg check en HEC safety Ewatuation dated January 24, actions described for the valves 5I-10/11/12 quarterly and proposed to 1992, which stated that " based on the nest refueling outage. Wo exercise these valves during refueling uncertainties of the proposed alternative further maC action is outages. Relief was granted based on the test methods in verifying futt-stroke opening regnred at this time.
impracticality cf Code compliance dee to the of the stbject check vatwes, the licensee tack of flow instrtsmentation in the lines.
should revise the testing to meet either However, it was metear to the reviewer how Position 1 or Fosition 2 of GL 29-04... by a futt-stroke open of these valves could be the nemt refueling outage." The testing will verified during refueling outages.
be revised to meet Position 1 or Position 2 of GL 89-04, and will be incorporated for use in refueling outage 9R.
If necessary, a revised relief request will be submitted prior to 99
- 14. vtR-18 the licensee requested relief from This relief request was further addressed in The licensee is to take the exercising low head safety injection check an WRC Safety Evaluation dated January 24, actions described for the valves 51-23/24/25 quarterly and proposed to 1992, which stated that " based on the next refueting cutage. ho
[
exercise these valves during refueling uncertainties of the proposed atternative further ksC action 's l
outages. Relief was granted based on the test methods in verifying full-stroke opening reg.rired at this tise.
ispracticality of Code cwtiance due to the of the subject check valves, the tfcensee tack of flow instrumentation in the lines.
should revise the testing to meet either i
Nowever, it was unclear to the reviewer how Position 1 or Position 2 of GL 89-04... by a futt-stroke open of these valves could be the ne.at refueling outage." The testing will l
verified during refueling cutages.
be revised to meet Position 1 or Position 2 of Gt. 89-04, and will be incorporated for use in refueling outage 9R.
If necessary, a e
revised retlef request will be sdroitted orior to St.
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l Anamely Description of Anmusty (May 6,1991 SE)
D*sC's Actiers to AMress Anomaly Outstartfing Actions
- 15. VRR-20 The licensee requested relief front This relief request i,as further a Mressed in the licensee is to take twe exercising acetrautator discharge check an kRC Safety Evaluation dated January 24 actions described for the a
valves St-48/49/50/51/52/53 quarterly and 1992, which stated that " based on the nemt refueting outage. no
- proposed to ereecise these valves daring uncertainties of tFe proposed alternative further ERC action is refue8ing outages. Setief was granted based test methods in verifying futt-stroke opening required at this time.
on the lapracticality of Code conptiance due of the subject check watves, the licensee to the lack of flow instrunentation in the should revise the testing to meet either lines. However, it was metear to the Position 1 or Position 2 of GL 89-M... Inr reviewer how a futt-stroke open of these the next refueling outage." The testing mitt valves could be w ified during refueling be revised to meet Position 1 or Position 2 outages.
of GL, 89-M, and wilt be incorporated for use in refueling outage 9R.
If necessary, a revised relief request will be submitted prior to 9R. One nethod wu$er consideration is to measure a C. value daring a blowcown at redated accupmalator pressure in conjmetion with a nonintrusive test, simitar to the method used at Ft. Calhout Nuclear Station.
- 16. vpa-21 The licensee requested relief from quarterty DLC has detemined that these vatwes can be The concern of this snomaly exercising safety injection check valves 51-part-stroke emercised during cold shutdown has been addressed. No 83/84 and proposed to futt-stroke exercise conditions. The relief request has been further action is required.
these valve during refueling outages. Based revised (Revision 1C) to include this on drawings provided, a partial-stroke provision.
exercise of these valves could be performed dJrits cold shutdown conditions. Relief was granted with the provision that the licensee develop a method to part-stroke these valves daring cold shutdom.
i Anommely Description of Anammely (May 6 1971 S O DtC's Actiores to Adtess Arumenty Outstandino Actions
- 17. VFR-22 The licensee requested relief from quarterly cLC has deterwined that valvs SI-95 can be The concerres of the emercising boron injection and safety part-stroke emercised during celd shutdown provision of the granted injection check valves $1-94/95 and proposed conditions, and is now included in w a-21.
relief have been addressed to futt-stroke exercise these valve during Walve SI-96 camot be part-stroke enercised t:y the additional refuetire outages. Based on drawings during cold shutdo m.
Relief teoJest WR-22 justification included in provided, a partiel-stroke exercise of these has been revised trevision TC) to address YRR-22. Therefore, the valves could be performed charing cold boren injection tank check valve SI-94 and relief previously granted shutdown conditions. Fetlef was granted includes justification cf the impracticality remains acceptabte for with the provision that the licensee of part-stro+e esercising darinr, cold f ast t-stroke emercising evaluate and develop a method to part-stroke shutdown as fottows: 'telart-stroke testing valve $1-94 daring these valves da-ing cold shutdown.
during CSD is not possible because the enty refueling outages. No flow path available is thruugh the SIT Iberon further action is recuired.
injection tank). Strckirs the BIT outlet isolation valves could result in borated, crygenate:I water frera the BIT entering the downstream piping. With no means to faush these lines, stagnant conditions develop sgxrt valve closure. The ability to flush out the do mstream piping to minimize the probabitity l
cf intergranular stress corrosion cracking
)
formation is only possitrie daring refueling j
outages in conjunction with the SI futt ftow test."
- 18. VER-23 The licensee requested relief from gaarterly relief secuest VER-23 has been deleted from The concerns cf this exercising bcron injection tank intets, MOV-the IST Program. Cold Shutdown Justification anomaty have been SI-867A/S, and proposed to futt-stroke No. 32 was created for these valves addressed. to further emercise these valves daring refueling indicating that testing is performed during action is re9; ired.
outages. Belief was denied based on cold shutdowns.
inadegante justifiestion of the ippracticality of esercising these volves durir's cold shutdowns when charging paso discherne pressure is significantly fewer.
- 19. VER-13 The licensee proposed using disassewbly and Dtt has revised VER-13 to incitaie the basis The concerns of the inspection to exercise safety injection for the irpracticality of part-stroke provision of the granted check velves SI-1/2. metief was granted exercising these valves f ollowing reassently.
relief have been addressed with the provision that the licensee adfress The only flow path available to test these by the additional ehether a part-stroke exercise is practical valves is to fitt the contairunent stanp with justification included in following reassembly, in accordance with the water and start the low head safety injection VRR-13. Therefore, the guidence in the mire >+es cf the Pdtic pumps. This would result in contaminated and relief previously granted meetines on CL 29-04 dirty watee being introduced into the remains acceptable for refueling water storage tank and reactor valves SI-t/2. No further coctant system.
action is required.
[.
e :
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Anomety Desceiption of Anmanty (May 6,1991 SO OtC*s Actfora te Acdress Ancussty outstanding Actions i
- 20. veR-25 The licensee proposed using disassently and DLC has revised vte-25 to include the basis The concerns ef the inspection to caercise recirculation spray for the impracticality of part-streke provision of the granted I
checit valves ts-153 and RS-160. Relief was exercising these valves following reassevely.
relief have been ackfressed granted with the provision that the licensee The enty flow path available to test these by the additional address whether a part-stroke enercise is watwes would be to fill the outside justification included in practical following reassembly, in recirculation spray pwp casing with watee VEs-25. Therefore, the secordance with the guidance in the seinutes and start the gxse. The inanual isolation relief g:reviously granted l
cf the Ptbile Maetinos on Ct. 89-04 vatwes would then be opened aruf the test remains acceptatrie for w3uld verify flew through the check valves, watwes RS-158 and RS-159 j
using an ultrasonic flow meter, to the Secause the watwes camot charging system. Otherwise, the volume of be part-stro&e esercised water used to test the outside R$ pses is following reassescly, the insuf ficient to stroke the check watwes, even licensee should ensure that 1
1 if the flow is directed to the suction of the the maintenance procedares high-head safety injection gxsps. The part-include provisform for j
j ;
stroke test would introdze water with grcoer disk orientation.
j entrained air into the charging / reactor ao further action is coctant systems, resulting in chemistry required.
prt6tems in the primary coctant, and is, therefore, ircractical.
- 21. bdR-27 Interim relief was granted for one year or Dtc has submitted a revised relief rewest Relief is granted in the smtil the next refueling cutaege, whichewr for review. These boundary valves camet be enclosed SE pursuant to is longer, to assign a maximum teak rate to individually teak rate tested. The bourufary to CFR 50.55a (f)(6)(i).
an entire penetration barrier instead of downstream vatwe, 11GFt, is a potentialty No further action is assigning individJat valve leak rates to open check valve leading to the circulating required.
component cooling water vatwes TV-CC-water system. Therefore, the river water M0f1/11CF2 as required by the Code. It system dcunstream cf 110F1 camet be isetated kg eared that for the particular to provide an accurate Leakage rate for penetration, indivicbat leak rates could be itCF2.
assigned and measured.
i a,
g 3
Annmaty Description of Anaanty (May 6, 1991 50 DtC's Actiers to AMress Anmusty uststanding Actiers
- 22. YRR-30 The ticensee reg;ested relief from quarterly ctC has incorporated a partiat-streks ct 89-06, Position 2 exercising main steam check walves MS-esercise fettowing reasseely. The relief approved the ice of a 80/81/82 and proposed to disasserete and request has been revised to describe the disassent>ty ard inspection inspect these valves daring refueling iepracticality of performing closure progres for checit watwes as cutages on a rotating schedAe. Relief was verification by means other than ty "a pcsitive means of granted with the provision that a partial-disasseetly ard inspection.
determining that a valve's stroke exercise following reassemcly be disk will futt-strc&e performed, if gractical. Interim relief was enercise open or of granted to attow a period for determination verifying closure of a method to verif y closure.
capability, as permitted ty
( W-3522." Therefore, this relief request is accrewed per GL 89-04, with the provision that the licensee i gtements the disasseat>ty and inspection program in acccedance with the guidance detineated in Position 2.
Reference GL 89-04, IST Pwam L
A m s.
- 23. vta-32 The licensee requested retief f rom 9.sarterly A part-strche exercise quarterly has been the concerns of this esercisirs river water check valves RW-xerporated into vta-32. The intent is to anamaty have been 110/111/112 and 113 and proposed to disassemble and inspect ene valve each addressed. me further i
disasseaubty and inspect these valves during refueling cutage en a rotating schedule such action is required.
refueling cutages on a rotating schedule.
that each valve is inspected at least once Relief asas granted erith the provision that a every five years. The relief regaest has partial-strche esercise folloining reassembly been revised to more clearly stipulate this be performed, if practical. The reviewer schedule.
indicated that it was unclear what aonce every 5 years
- seant for the schedute of disassent>ty and inspection.
24 VER-33 Retief from quarterly esercising river water DLC has removed the internals of these check no further action is check valves tv-135 and RW-136 was requested vatwes. Therefore, vas-33 is no tanger required.
with a proposal to futt-strche these vatwes regsired. The vatwes are no teriger required curing refueling cutages. Interie relief to be exercised ard are no longer in the IST was granted to atlow the titersee a period Prog am.
The revised prograse sttaitted to determine if exercising can be perfor med 9/25/92 deleted the vatwes and this relief in accordance with the Code regJired request.
freoJency.
. i i
s Armamely Descriptiars of Anamaty (stay 6,1991 SO OtC's Actiers to Adtress anmaty thtstandirup Actims i
- 25. vta-34 The licerisee requested retief from ouarterly Cic has renewed the internals et these chectt no further action is enercising check watwes til-177/173 and valves. Therefore, Vaa-34 is re tanger rewired.
proposed to disasseely ard inspect these rewired. The vatwes are no longer rewired vatwes dJrirqs refacting outages on a to be emercised ard are no longer in the IST retating schedate. Relief was granted with Program. The revised program sduritted J
the provision that a partist-stroke esercise 9/25/72 deleted the vatwes and this relief following reassencly be performed, if re west.
practical.
l
- 26. VER-37 Relief from quarterly streking and timing CLC revised the relief regeest to stindate Frior to the empiratie of i
contret room emergency air bottle outlet that the valves will be streked quarterty.
the interim relief at the trip isolation vatwes was rew ested with a The current revision of VER-37 relates only e d of refueling outage 9R, proposal to stroke these watwes once every te net sensuring streke time. The lice wee *s the tice see must determine 15 months, but net acasure stroke times.
prcgesat does ret provide an alternative a nears to monitor these i
Interim relief was granted for a period cf means for monitoring for vatwe degradation.
vatwes for degradatiori. A one year on uritit the nemt refueling outage, revised relief rewest whichever is longer. The licensee was oescribing the method is to requested to investigate nonintrusive be s h itted prior to methods to eenitor f or vatwe degradation, startse frca 94
- 27. et/A The licensee was reqJested to investigate ao irnormation was previded relative to this CLC should inclu$e this methods to verify ful1 and partial stroke enamaty.
ieformation wit % their nest 6
exercising for various valves, such as IST related sdsmittet.
instattation of flow instrumentation o*
utitiration cf nonintrusive techni wes.
- 25. vts-15 Relief was rewested fron earterly Dic reviewed the partial-streke ezetrising The concerns cf this i
exercising tow head safety injection pure method. The vatwes had been considered to be ancoaty have been addressed i
discharge check valves $1-6/7 in accordance part-strche eneecised by rereccing the by the revision to vsa-15.
with IW-3522 with a prcposal to perform pressure change in a dead teg of pipe dewn The relief previously d
i partial-strche exercising quarterly and stream of tie check watwes befcre and af ter granted remains effective futt-stroke esercising dJring refueling pro start. It was determined that this for the revised relief cutages. Provisional relief was granted method does net prcvide a true part-stre&e of request to sticw futt-because information on the method cf these valves. Relief Regaest vta-15 was stroke esercisirs with partial-stroke esercising was net included revised to more correctly irdicate that these acciderst fle= during in the retlef request.
valves are exercised closed quarterly and refueling outeges. no futt-strche esercised open at refueling further acticri is rewired.
outaoes.
I 1
t t.
v
B t y Descriptim of Anamusty (by 6, 1971 5 0 DtC*s Actiers to adkess Arummely Outstarufirar Actions
- 29. VER-79 Relief was granted f rom the cparterly DLC bas revised WR-19 to indicate that a The concerns of this exercising f requency for check valve $1-27, part-stroke exercise will be perforised an maty have been addressed high head safety injection /chargmg pise cuarterly when system cor figuration permits, t:y the revision of WS-19.
refueling water storage tar
- suction vatwes, that a part-stroke exercise will be perfor1med to further action is with a proposal te partial-stroke the valve on a cold skutdcun frequency, and that a required.
cuarterly and full-stroke exercise the vatwe futt-stroke esercising will be perfensens dJrire refueling outages, with the provision durirv3 refueling cutages.
that a partial stroke esercise be performed when shutting down from power operation to cold shutdown in addition to the prow testing.
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