ML20126J213
| ML20126J213 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/04/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20126J136 | List: |
| References | |
| TAC-11260, TAC-11261, NUDOCS 8506180558 | |
| Download: ML20126J213 (40) | |
Text
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UNITED STATES 8*
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' g NUCLEAR REGULATORY COMMISSION 8
WASHINGTON. D. C. 20555 i
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ENCLOSURE 2 SAFET) EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION' RELATED TO REQUESTS FOR REL!EF FROM INSERVICE TESTING REQUIREMENTS GEORGIA POWER COMPANY EDWIN !. HATCH NUCLEAR PLANT, UNIT NO. 2 DOCKET NO. 50-366 l
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Subject Pai' Introduction...........................................................
1 Evaluattin.............................................................
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A.
Genera 1............................................................
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B.
Pump Testing Program and Relief Requests...........................
2 1.
Program........................................................
2 2.
Specific Requests for Relief...................................
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a.
Standby Liquid Control Pumps...............................
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i b.
Plant Service Water and RHR Service Water Pumps............
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c.
Residual Heat Removal and Core Spray Pumps.................
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i d.
Jockey Pumps...............................................
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e.
Standby Diesel Generator Service Water Pump................
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1 C.
Valve Testing Program and Relief Requests..........................
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1.
General Considerations.........................................
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2.
Program...............................................
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Gene ra l Reque s t s fo r Re l i e f.................................... 13 4.
Specific Requests for Relief...................................
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j a.
Mai n Steam a nd Fee dwa te r ( 2821)............................ 14 j
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Reactor Recirculation (2831)...............................
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c.
Standby Liquid Control (2C41)..............................
17 d.
Residual Heat Removal (2E11)...............................
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Core Spray (2E21)..........................................
20 f.
MSIV Leakage Control System (2E32)......................... 22 g.
HPC1 2E41)................................................22 i
h.
RCIC 2E51)................................................ 26 i
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Plant Service Wa te r (2P41)................................. 29 l
- j. Reactor Building Closed Cooling Water (2P42)............... 32 3
k.
Chilled Water System (2P64)................................
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D rywe l l Pne uma t i c ( 2 P 7 0 )................................... 3 3 l
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Control Rod Drive.......................................... 34 j
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ENCLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS GEORGIA POWER COMPANY EDWIN !. HATCH NUCLEAR PLANT, UNIT NO. 2 DOCKET NO. 50-366 l
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INTRODUCTICN This report rrovides a safety evaluation of tne Hatch Unit 2 program for inservice testing of pumps and valves; and, in particular, of the licensee's requests for relief from regulatory requirements applicable to the subject p agram. TheCodeofFederalRegulations(10CFR50.55a(g)]requiresthat inservice testing (IST) 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.
10 CFR 50 550.55a(g)(6)(1) authorizes the Commission to grant relief from code requirements for testing upon determining that the testing requirements are impractical.
It also authorizes imposition of alternate requirements and augmenting requirements upon making the necessary l
determination.
The IST program for Hatch Unit 1 and its associated relief requests addressed in this report were submitted to the Commission with the licensee's transmittal letter dated August 12, 1983. Tre program was prepared to comply with ASME l
Section XI,1980 edition with add:nda through Winter 1980 (the Code), which is the applicable code required by 10 CFR 50.55a(g).
l The Final Safety Analysis Report for Hatch Unit 2 and selected piping drawings (listed in Attachment 2) were the primary sources of plant-specific information used in this evaluation. Additional information was obtained from the licensee as follows:
During an inspection at the Hatch site March 14 - 18, 1983 (documented in NRC Inspection Report 321,366/63-08).
During a meeting with licensee personnel held at the NRC Region !! offices on June 23, 1933.
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Enciosure 2 2
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l Dette; an ins;ection at the hatch site February 27. - Mar:h 2.195 (:::u-ree.ted tr. ht; Ins;e:tice. Ketert 321, 3Ef/Ec-0E.)
l A:31 ster.a1 inferratten previced by the 11:eesee in its letter cate:
March 26. 1954 i
Ee: sire e-ts aad irter; etattens censi:e ed a;;11catie te the itceesee's p :; 4 l
and used in the staf f's evaluation in:1uce the fel.c.te;:
(1) Ccde re;wirerents referred te above, an:
(2) Fcsitices and interpretaticas described in the evaluaticns bele..
Ev&wai!ON L
A.
GE% Erat It is the staff's pesttien that the licensee's IST pre;ra-east inclu:e all i
l pue;s and valves it;criant to safety (i.e., pue;s and valves re:uired to I
shut dow* the plant to cold shutdown, saintain the plant in cold or h:t shutdown cendition. cr sitigate the censecuen:es cf an a:cident) and that l
they must be tested in a:ccrcance with the apprc;riate Ccce re:wirerents unless relief is granted.
I It is also the staff's position that where relief from the Code is requested, it is the licensee's responsibility to provide an adeavate basis for granting relief. The staff found that some of the licensee's rtlief requests were not adequately justified; conseavently, additional informtion was re:wested by 6
letter dated February 23. 1954. The licensee responded in a letter sated March M. 1954 t.
PtM TESTIk", PO,uw Ac RELIEp REQUEST 2.
pre;ea-A review cf the pur; pertion of the 157 progree has she.n that tne prc; ras in:1u:es a11 pamps that are tesortant to safety and that east i
be tested as recuired by the Cede. All criteria are in co-;1tae:e with Code reavirements except the allo.able u;;er lirits for ef f fereettal pressure (AP) and flow rate (Q). The Cese specifies that these lietts east be no more than 202% of the reference values. The licensee's proposed iteits for both para *eters are 110'. for all Service Water I
Pue;s (that take tuttien free the river) and 10% for pue:S that are l
le:sted within the plant. Toese less restrictive 11atts have been spe:1fied by the licensee. threw;h its interpretatica cf Paragra:5
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I W 3210 of the Coce, on the basis that the a: curacy of gauge reasu*e-l pents and the f1w:tuatten of river level make it dif ficwit to reet the lower limits. Alle. a review of prevtcus test data by the licensee has j
sho.m that the higher valwes had not a:curately refle:ted cegrafatics cf pu ; creratien.
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The staff a::e: s the use of the less restrictive u:;er lietts f:e t*e re aineer :f the current I5! peri::; n:-ever,.e ce not telieve trese lir.its provide tre sersitivity in detecti:9 cf hydraulic pe-fer ar:e that is intence: ty the C :e. refer to sebeission of the Hatch ;- ;-a-fer the cent ISI ; erica, tre licensee sacalc ceterstne if 1 ;reve seesitivity can be achieve: ty su:5 reans as: use of e re sersitive testre entatien; use of altiple referea:e salues if by cauli: perf:---
an:e can te tra:ed to fa:ters that are n t indicative of :s ; ce;-ada-tic 9; use of te;rcsed vibration tests to e:nitor pu o ce;racatie9; treading cw p test cata and statistically evaluating the results for ce;racatien. The licensee's efferts te these areas.ill te a::ressed csring ins;ections of the 11:ensee's te;1eeentaticn of the currect ISI pr:; ras.
2.
5;e:'ffe Requests fer Relief a.
Staa::y Licui Ceat el (SLC)
Relief Re:.est Tee 11:eesee Pas re;;ested s;e:1fic relief for SLC cs :s 2C41-CCC1 A&E free the re:.tre?ents of Table In?-31CC-1 for reass te; inlet e
cressure (D1), ciffereettal cressure (aF), a9: f10. rate ame pre;:ses to reasuee only cutlet pressure ae: to ceterstne fic. ate ey an alternative reth:.
Licersee's Basis fer Re:vestir; Relief
%: cire:t reams cf.easuries pse; inlet gressure is available.
TP.e SLC ps ;s are positive cispla:e ent tv s fer ht:m cif ferea-tial pressure is e:estaat, regar:less of inlet crossere. Fic ate is reaswee: by the charge in tne SLC Test Tank level carir; a t :-eirwte test sectee.
At tre staff's re: vest, the liceasee, in a letter cate: Pa :n 26, 1934 elaterate: cm the above Basis as folle.s:
Sta ::y Licwie Centrol (5tc) is aligee: se that each cs ; takes sw:tien fres a centreralizee. ate-so.rce and cis:targes tere.;* a thecttle valve to a test taak. The os ; ts ple:e: into c:erati:9 aec t*e thr:stle valve a: Justed to cutain a referee:e cis:Parge cressure. Tee level of the test taet is tre9 reasured aa tPe ts-; tres run for t o mie.wtes. After t*e two etewte ran tPe taek level is a; aim reas. red. Flc.cate is tren deterstred by tre folle.ing etwation:
Fle. (get) = a Taak level (ta.)
4.81 gal./te.
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4 For a situation in which the flowrate is measured by instrutent, a 0-100 gpm instrument would normally be used for the SLC pump flowrate of approximately 43 gpm. The required accuracy of this instrument would be 1 2% or 2 2 gpm. This corresponds to t.83 inches of water level in the test tank. Therefore, the accuracy of the measured flowrate should be well within code allowable.
Evaluation We agree that the configuration of the Standby Liquid Control system and the two SLC pumps make it impractical to determine Pi and AP.
We also approve the alternate method of establishing flowrate and the licensee's request for relief.
b.
plant Service Water and R4R Service Water Pu ps (1) Relief Request The licensee has requested specific relief for Plant Service Water pumps 2P41-C001 A thru D and RHR Service Water pu ps 2E11-C001 A thru D from the requirements of Table IWp-4110-1 to measure inlet pressure and differential pressure within 1 2% of full scale.
Licensee's Bases for Requesting Relief Inlet pressure for these pu ps is determined by measuring the river level at the intake structure. The differential pressure is then: AP = Po + (114.5 f t. - River Water Level),
0.433.
The licensee claims that this method of measurement is well within the Code requirement for the determination of AP.
Evaluation These putps are vertical design and have no direct means for measuring Pi; therefore, Pi is calculated from the depth of the river (i.e., depth (f t) : 0.433 psig/ft). Differential pressure is then determined by subtracting Pi from Po (the pressure measured in the outlet pipe of the pump). We conclude that this procedure will provide pressure values of acceptable accuracy and, therefore, we approve the licensee's request for relief.
(2) Relief Request The licensee has also requested specific relief for pumps 2P41-C001 A thru 0 and 2E11-C001 A thru D from the require-ment of IWP-4310 to measure the temperature of bearings outside the rain flow path.
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t Licensee's Basis for Requestino Relief
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For these pumps the bearings (or bearing surfaces) are cooled j
by the process fluid that is being pumped. Rather than
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measure the temperature of this lubricant, the licensee l
proposes to inspect the bearings for wear whenever the pump i
is disassembled for maintenance. Also, the bearing tempera-
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ture of the pump motor will be monitored.
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Evaluation We agree with the licensee's basis that measurement of the l
temperature of the bearing coolant (river water) does not provide indication of the bearings' conditions. Conse-j quently, we approve the alternative visual surveillance and i
grant the requested relief. It is the staff's position that l
the mechanical operability of pumps is best monitored through very frequent bearts.g temperature measurements (when possible) or by emphasizing the accuracy and sensitivity of vibration measurements.
l (3) Relief Requested l
The licensee has also requested specific relief for pumps j
2P41-Cu01 A thru 0 and 2E11-C001 A thru 0 from the require-ment of Table IWP-3100-1 that the proper lubricant level or 5
j pressure be observed.
Licensee's Basis for Requesting Relief
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l These pumps are being lubricated by the process fluid that is
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being pumped; therefore, the requirement is impractical. The licensee proposes to monitor the lubricant level of the pump l
motor to assure the motor is operable.
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We agree that the requirement is not needed for these pumps t
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and approve the requested relief.
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Residual Heat Removal and Core Spray Relief Reevest The licensee has specifically requested relief for Residual Heat 1
Removal pumps 2E11-C001 A thru D and Core Spray pumps 2E21-C001 A and B from the requirements to measure the temperature of bearings i
outside the main flow path (IWp-4310) and the periodic observation of lubricant level or pressure (Table IWp-3100-1).
Licensee's Basis for Requesting Relief Same as for pumps 2P41 C001 A thru O and 2E*1-C001 A thru D.
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1 Evaluatien Sane as for pu ps 2P41-CCCI A thru 0 and 2E11-C001 A thru D.
The licensee's requests are approved.
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Jockey pu ps l
(1) Relief Request The licensee has recuested specific reitef for pu ps 2E21-CCO2 A and B frem the require ent of Table !Wp-3100-1 that b:th differential pressure and flowrate be measured and proposes to reasure cnly differential pressure, i
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Licensee's Basis for Requesting Relief l
The only function of these pumps is to maintain a water inventory in the RHR and Core Spray piping system, and flea rate instru-entation is not required, however, the putps discharge into a fixed resistance system; therefore, measure-eent of both parateters is not required to Cetermine degrada-tion of the puto.
Evaluatten We agree with the licensee's basis and approve the req.ested relief. In a fixed resistance systet the ceasurement of either AD or flow rate is sufficient to verify the cperabi-l lity of these pu ps.
(2) Relief Request The itcensee also requested specific relief for pu ps 2E21-C002 A and B from the require ent of Table IWV-3100-1 to cbserve lubricant level or pressure.
l Licensee's Basis for Requesting Relief These pu os are lubricated by the process fluid that is being pu ped.
Evaluation We agree with the licensee's basis and approve the reauested relief. This requirement is not applicable when a pu p is
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lubricated by the pu ped fluid.
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Standby Diesel Generator Service Water Puxp (1) Relief Request The licensee has requested specific relief for Standby Diesel Generator Service Water pump 2P41-C002 from the requirements of Table IWP-4110-1 to measure inlet pressure and differen-tial pressure within 2% of full scale.
Licensee's Basis for Requesting Relief Same as for Plant and Service Water Pumps 2P41-C001 and 2E11-C001 respectively (see Section B.2.b(1)).
Evaluation The licensee's request is approved (same as Section B.2.b(1)).
' (2) Relief Request The licensee also requests relief for pump 2P41-C002 from the requirement of Table IWP-3100-1 to observe the proper lubricant level or pressure.
Licensee's Basis for Requesting Relief This pump is lubricated by the process fluid that is being pumped.
Evaluation We agree with the licensee's basis that the Code requirement for observing lubricant level or pressure is not applicable to pumps that are lubricant by the process fluid. Therefore, we approve the relief request.
C.
VALVE TESTING PROGRAM AND RELIEF REQUESTS 1.
-General Considerations
,The following Code requirements, staff positions and staff interpreta-tions of requirements for IST valves are listed because of their particular applicability to the evaluation described herein.
a.
Valve Test Frequency Requirements Subsection IWV-3411 of the Code (which discusses full stroke and part stroke testing) requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IWV-3412(a), IWV-3415, and IWV-3416. IWV-3413 requires the
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owner to specify the full-stroke time of each power operated Category A and B value and to check the time whenever the valve is full stroke exercised.
IWV-3521 requires that Code Category C check valves be exercised once every three months, with the exceptions as defined in IWV-3522.
In the above exceptions for Category A, B and C check valves, the Code permits the valves to be tested at cold shutdowns where:
(1) It is not practical to exercise the valves to the position required to fulfill their function, or to the partial posi-tion, during power operation.
(2) It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.
b.
Passive Power Operated Valves IWV-3700 states that passive valves need not be exercised; however, it is the staff's position that power operated valves which are not required to change position for any accident condi-i tion of the plant must have their positions verified quarterly and each time the valves are cycled.
c.
Testing of Normally Open Check Valves Requirements for testing normally open check valves are stated in' IWV-3522 as follows:
" Check valves shall be exercised to the position required to fulfill their function... Valves that are normally open during plant operation and whose function is to prevent reversed flow, shall be tested in a manner that proves that the disk travels to the seat peomptly on cessation or reversal of flow. Confirmation that the disk is on its seat shall be by visual observation, by an electrical signal initiated by a position indicating device, Oy the observation of appropriate pressure indications in the system, or by other positive means."
In its program, the licensee proposes to verify closure for certain normally open check valves at each refueling, by reversing flow through the check valves and measuring the leakage as part of the local leak rate tests. The staff believes that this alterna-tive method will verify if the valve's disk has returned to its seat.
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Testino of Ner ally Closed Check Valves Re;uirements for testing cereally closed eneck valves are stated l
in IWV-3522, in part, as follows-
" Check valves shall be exercised to the positten recuired to fulfill their function... Valves that are norcally cicsed during plant operation and whose function is to open en i
reversal of pressure differential shall be tested by proving that the cisk ecves premptly away from the seat when the closing pressure differential is removed and flew through the valve is initiated, or a mechanical cpening force is applied to the disk. Confir:ation that the cisk ecves away fres tne seat shall be by visual ctservation, by electrical signal initiated by a position indicating device, by cbservation of substantially free flow through the valve as indicated by appropriate pressure indications in the syste=, cr by cther positive reans. This test may be cade with or without flew through the valve."
The staff considers that these requirements can be =et if any cf the following fcur cetheds are used as confirzation:
(1) By demonstrating that the valve can pass the maxi =u:,
accicent-cesign ficw for which credit has been taken in FSAR analyses.
(2) By shcwing that, fer the ceasured ficw, the pressure less through the valve is such that the valve can cnly be fully open.
(3) By using a mechanical exerciser which can be cbserved to ecve through a full stroke.
(4) By partial disasse-bly of the valve and manually ecving the i
disk through a full stroke.
e.
Leak Rate Testinc of Cate;ory A Valves By Peans of Differential l
Pressure IWV-3423 requires that valve seat leakage tests shall be made with I
the pressure differential in the same direction as will be a:P ied l
l when the valve is perfor=ing its function, with certain s;ecified exceptions..The licensee has requested. relief for eleven Cate-gory A containeent isolation valves that cannet be tested in the required manner, because of the configuration of the system, and proposes to leak-rate test these valves in a noncenservative direction. The ccrrect cirection is to pressurize from the I
inboard side of these valves; however, the piping en the intcard side runs directly frc= the valve to either the terus er to the reacter vessel and is difficult to pressurize for testing. The i
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staff considers that the intent of the Code is met by the licensee's proposed method if a redundant containment isolation valve is leak tested in the correct direction. When the system does net have redundant containment isolation valves (i.e., does not meet Criterion 56 of Appendix A of 10 CFR 50) the single isolation valve is required to be leak tested from the correct direction. For containment isolation valves, correct pressuriza-4 tion direction < pay be obtained during integrated leak tests.
f.
Stroke Times for Category A and B Power Operated Valves IWV-3413 requires the licensee to specify limiting values of full stroke times for power operated valves. These limiting values must be verified each time the valves are full stroke tested and they must be trended (as specified in IWV-3417.) The limiting i
values of full stroke time specified for these valves must assure that any design safety analysis requirements are met.
j For fast acting valves, such as solenoid valves and air pilot operators, the staff considers two seconds to be a suitable maximum stroke time. The absence of indicator lights will not normally be considered an adequate basis for relief from stroke timing.
g.
Deviations in Leak Test Mediums IWV-3425 requires that the test medium be specified by the owner.
l Where leakage rate is to be determined using a different test j
medium than the service medium, IWV-3423 requires that the deter-mination compensate for the test medium difference. Where the
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i licensee proposes to leak test a valve with a different medium than the service medium, as for example in proposing to test i
l pressure isolation valves (PIVs) with air when their service
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medium is water, the licensee must use a proven correlation between the two mediums for the subject conditions.
j h.
Valve Testing at Cold Shutdowns 1
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The staff considers the following conditions to apply to inservice l
testing valves at cold shutdown:
i (1) It is understood that the licensee is to commence testing as i
soon as.the cold shutdown condition is achieved but not.later i
than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power.
I (2) Completion of all valve testing is not a prerequisite to return to power.
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(3) Any testing not Completed at one cold shutdown sho.lc b6 perfortred du-ing any subsequent cold shutcowns that r ay c::.-
before refueling to rneet the Code-specified testint frequency.
For rianned cold shutdowns, where the licensee will complete a'.1 the vahes icentified in his IST rrograe for testing in the ccid 1
shutdown mode, the licensee need not begin testing within the I
specified 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
1.
Leak Test Reouirements for Containment Isolation Valves (CIVs)
All CIVs are required to be classified as Category A or AC.
It is the staff's position that the leak rate test requirements for Cate gory A valves (IWV-3420 through IWV-3425) are met by the requirements for CIVs in 10 CFR 50, Appendix J.
Relief from the requirements of these paragraphs does not present safety problems since the requirments are met by Appendix J testing; however, the requirements of IWV-3426 and IWV-3427 must be implemented.
j.
Application of Appendix J Review to the IST Procram i
The Appendix J review for this plant is a completely separate review from the IST program review. However, with regard to valves subjected to Type C tests, the determinations made by that review are directly applicable to the IST program. Should the Appendix J program be amended, the licensee is required to amend the IST program accordingly.
2.
Program The valve portion of the IST program was examined to verify that all valves important to safety are included in the program and are subjected to the testing required by the Code. The following valves and systems, which apparently should be considered important to safety, were not included on the program:
SYSTEMS Portions of the Instrument and Control Air System that perform a function important to safety VALVES Standby Gas Treatment System valves F002A and F002B The licensee has consnitted to review the functions of these valves and the consequences of their failure. These valves will either be included in the revised IST program to be submitted by the licensee in June 1985 or justifi-cation for their omission will be given to the NRC.
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12 The licensee has stated (Notes 6, 8, 9, and 10) that the following valves, that are listed in the IST program, are exempted from testing per IWV-1200(a); i.e., " valves used only for operating convenience (such as manual vent, drain, instrument, and test valves), valves used for system control (such as pressure regulating valves), and valves used only for maintenance."
Category B Valves 2E11-F068 A and B (RHR Heat Exchanger Service Water Discharge) modulating pressure or flow valves.
Category B 2E11-F126 A and B (Seal Water to RHR Service Water Pump - Pressure Control) valves Flow) air-operating stessure control valves that open and close at set pressures.
Category B valves 2E11-F207 A, B C and 0 (RHR Service Water Pump -
Mini-Flow) air-operating pressure control valves that open and close at set pressures.
Category B valve 2E51-F019 (RCIC Pump Minimum Flow - Torus Isola-tion) minimum flow valve that opens and closes at set pressures.
Category B valves 2P41-F320 A, B, C and D (Service Water Pump Minimum Flow) air-operated pressure control valves that open and close at set pressures.
Category B valves 2P41-F334 A and B (Service Water Pump Cooling Water Pressure Regulator) air-operated pressure control valves that open and close at set pressures.
Category B valve 2T49-F003A (H, recombiner, H from Drywell 2
Shut-off) air-operated control valves that open and close at set pressures.
The NRC staff has been advised by the ASME that the exemptions provided by IWV-1200(a) apply to valves that are used only for the purposes listed in this subsection of the Code. The licensee's positions on the applicability of the code to these valves were discussed during the meeting between the staff and the licensee on June 23, 1983.
It is the staff's position that all valves that are important to safety should be
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stroke tested to show that two criteria are being met, i.e., each valve is opening or shutting in the time required in the FSAR and movement of the valve stem has not been degraded.
In its response of March 26, 1984, the licensee stated that further evaluation of the failure of these valves to perform their designated function is required and the results of the evaluation will be transmitted to the NRC. Until the staff has received and approved further bases for exemption, the valves listed above must be tested per the requirements of the Code.
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13 The Hatch Unit 2 IST program includes Category B valves 2E11-F201 A, B, C and D (RHR Service Water Pump Cooling Water). The program also includes a note that these four one-inch solenoid valves "will be removed per a design change in a future outage.
In the interim, the power to the valve (s) will be removed and the valve (s) left in the open position. As a result the valve (s) is not important to safety." By 1
letter dated July 2,1984, the licensee notified the staff that these proposed actions will not be performed during the 1984 Hatch Unit 2 l
maintenance / refueling outage. Consequently, until the stated actions are taken relating to these four valves, the valves must continue to be 1
tested per the Code.
3.
General Request for Relief a.
Relief Request The licensee has requested relief from the requirements of IWV-3417(b) and IWV-3523. These sections of the Code state that when corrective action is required as a result of tests made during cold shutdown the condition shall be corrected before startup.
I Licensee's Basis for Requesting Relief Under the conditions stated in these sections of the Code, startup should be permitted as provided in the Technical Specifications.
Evaluations 2
When a valve is found to be inoperable at cold shutdown with respect to the Code acceptance criteria, the use of plant Technical Specifications to determine acceptable conditions for restart is acceptable.
~b.
Relief Request J
The licensee has requested relief from the requirements of IWV-3417(a) for valves normally tested during cold shutdown. This section of the Code states that if an increase in stroke time of 25% or more from the previous test for valves with stroke times less than or equal to ten seconds is observed, test frequency shall be increased to once each month until corrective action is taken.
Licensee's Basis for Requestino Relief f
Valves that are normally tested during cold shutdown or refueling cannot be tested once each month. Stroking these valves during power operation may place the plant in an unsafe condition.
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14 Evaluation We agree with the licensee's basis and approve the requested relief on the condition that the licensee stroke time the affected valves each cold shutdown until the corrective action is taken.
4.
Specific Requests for Relief a.
Main Steam and Feedwater (1) Relief Request The licensee has requested specific relief from exercising Category AC valves 2821-F010A&B (Feedwater Inboard Contain-ment Isolation) on the test frequency required by IWV-3421 and proposes to exercise them during each refueling.
Licensee's Basis for Requesting Relief These isolation valves are normally-open, simple check valves with flow through them during normal operation. The only means of verifying closure is to introduce reverse flow through the valves and measure the leakage. This verifica-tion is performed each refueling during the local leak rate tests.
Evaluation We agree with the licensee's basis and approve relief for these valves from the exercising requirements of the Code during power operation and cold shutdown. The valves are verified as open during normal operation and will be verified as closed during the local leak rate tests.
(2) Relief Request The licensee has requested specific relief from the leak rate test requirements of IWV-3423(d) for Category A valve 2821-F016 and proposes to test this gate valve by pressurizing from a non-conservative direction as addressed in the containment leak rste test program for the type C leakage tests.
Licensee's Basis for Requesting Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.
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r 15 Evaluation I
We agree with the licensee's basis and approve the requested I
relief. By pressurizing this 3-inch line between 2821-F016 and 2B21-F019, the redundant outboard valve (F019) will be leak tested in a conservative direction and thereby ensure leak tightness outside of primary containment. This test i
will also give a non-conservative indication of the leakage of F016 inside of containment (Refer to section C.I.e of this Safety Evaluation).
)
(3) Relief Request i
The licensee has requested specific relief from the valve exercising test of IWV-3521 for Category C valves B21-F037 A through L (Vacuum Breaker MSRV Discharge) and proposes to use an alternative test.
Licensee's Basis for Requesting Relief i
These valves are designed to prevent a water leg from forming l
in the relief valve discharge lines under vacuum conditions.
j Since there is no flow through these valves, and they are j
simple check valves, there is no means to test operability.
1 The licensee proposes to observe the movement of the disk, to j
see that it moves freely, during each refueling outage (when i
l the Containment is de-inerted).
]
Evaluation We agree with the licensee's basis, and proposed alternative test, and approve the requested relief. The failure of these valves to open could result in damage to the discharge lines, preventing them from properly functioning in subsequent operation. Failure of the vacuum breakers to properly seat could result in discharge through these valves rather than as designed.
(4) Relief Request i
The licensee has requested specific relief for Category C i
valve 2821-F076 A and B (Feedwater Check) and Category AC l
valves 2B21-F077 A and B (Feedwater Out-board Isolation) from the requirement of IWV-3521 to exercise these valves once l
j every three months.
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16 Licensee's Basis for Requesting Relief l
These normally-open feedwater checir valves have an air assist for tight closure and position lights. Closure will be proven each cold shutdown, but not more frequent than once per three months, by observing the indicating lights.
Evaluation All of these check valves are in the feedwater flow path and cannot be tested, during plant operation, to determine if they will prevent reversed flow. As stated in Section C.1.c, normally open check valves may be tested by observing an indicating light that confirms when the valve disk is on its seat. Consequently, we approve the licensee's request to visually test the position of these valves during shutdown when the air-assist feature can be actuated for these large check valves, b.
Reactor Recirculation System (1) Relief Request The licensee has requested specific relief from exercising Category A/C valves 2831-F013 A&B and 2831-F017 A&B (Recir-culation Pump Seal Water) on the frequency required by IWV-3521 and proposes to exercise them during each refueling.
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Licensee's Basis for Requesting Relief Same as C.4.a.1 (Valves 28-21-F032 A and B)
Evaluation l
Request approved.
Same as C.4.a.1 (2) Relief Request The licensee has requested specific relief for Category B valves 2831-F031 A&B (Reactor Recirculation) from the quarterly test frequency of IWV-3411.
l Licensee's Basis for Requesting Relief 1
These valves are reactor recirculation loop closure valves.
Closure of these valves during normal power operation would reduce cooling water flow to the core by one-half and place the plant in an unsafe condition.
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1 17 The licensee also requests relief from part-stroking these l
valves during normal operation because of the design circuitry of the valve and proposes to full-stroke both valves during each cold shutdown (not to exceed once every three months).
4 i
Evaluation We agree with the licensee's basis and approve the relief requested. The licensee has demonstrated that these valves r
cannot be full-stroked or part-stroked during plant opera-tion. We conclude that full-stroking during cold shutdown will be sufficient to verify the operability of these valves.
c.
(1) Relief Request I
The licensee has requested specific relief for Category AC valves 2C41-F006 and 2C41-F007 (SLC Containment Isolation) from the exercie.ing test frequency required by IWV-3521 and proposes to exercise these valves once per 18 months.
Licensee's Basis for Requesting Relief These normally closed check valves cannot be opened without introducing flow through them with a pressure greater than reactor pressure. Such a test is performed at least once per operating cycle per Technical Specification 4.4A when the i
pump flowrate is verified.
4 Evaluation f
We agree with the licensee's basis and approve the requested relief. Both of these isolation valves are between the explosively actuated valves (2C41-F004 A&B) and the reactor i
coolant in the reactor vessel. We conclude that the opera-bility of both check valves will be verified by an acceptable test of the two SLC pumps.
d.
}
(1) Relief Request The licensee has requested specific relief for Category A valves 2E11-F007 A&B (RHR Pump Minimum Flow Torus Isolation) and 2E11-F011 A&B (RHR Condensate Discharge to Torus) from the method of performing leak rate tests as prescribed by IWV-3423 and proposes to leak test these gate valves in a nonconservative direction as addressed in the containment j
leak rate test program for the type C leakage tests.
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18 licensee's Basis for Requesting Relief These valves cannot be leak tested by pressurizing from the inboard side because the pipirg on the inboard side runs directly from the valve to the torus and cannot be pres-surized for testing.
Evaluation The licensee has identified, in Section 3.7 of the Hatch 1 Technical Specifications, those isolation valves that cannot be tested in the direction required for isolation. These valves will be leak tested by applying pressure between inboard and outboard valves, or between the isolation valve and other system valves. These tests are required to yield equivalent or more conservative results than required by the Code. We consider this Technical Specification to be adequate for leak-testing this valve and approve the requested relief.
(2) Relief Request The licensee has requested specific relief for Category AC valves 2E11-F050 A&B (LPCI Injection Isolation) from valve exercising requirements of IWV-3521 and plans to fulfill these criteria by alternative means.
Licensee's Basis for Requesting Relief These normally closed check valves do not receive " full-open" i
flow during normal operation or shutdown conditions. There has been no practical method demonstrated to fully stroke these valves.
These valves were supplied with a test switch to allow partial stroking during operation; however, the design of the test mechanism does not provide proper testing. Modifica-tions are to be performed, and if they prove successful, the valves will be partially stroked once per 3 months.
At least one of the RHR system check valves will receive shutdown cooling flow through it during cold shutdown condi-tions; however..the flow is not sufficient to fully open the valve.
Valve integrity will be proven during leak rate tests each refueling outage because this valve is a pressure isolation valve and must pass the leakage tests.
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l One of the two valves in the system will be disassembled on a l
rotating basis every other refueling outage.
If the valve is determined to be non-functional, so that design flow would not pass through the valve, the other valve would then be j
disassembled and inspected, i
Evaluation These isolation valves are 24" swing-type check valves that are designed to be tested by the use of an actuator rod that l
will partially lift the valve from its valve seat as the i
actuator rod rotates through the final 30' of a 180' arc.
i Consequently, only part-stroking of these valves can be achieved by the current test procedure. Part-stroking will i
also be attained for one of these valves each time this line e
is used to go to cold shutdown. The capability of these valves to perform their other safety-related function (i.e.,
isolate the low pressure RHR lines from the high pressure reactor cooling water) will be established during leak rate tests. Consequently, we conditionally approve the licensee's request on the basis that the valves be disassembled on the schedule proposed by the licensee until a procedure is developed to achieve full-stroke testing.
(3) Relief Request t
The licensee has requested specific relief for Category C valves 2E11-F078 A&B (RHR Heat Exchanger Servico Water Intertie) from the 3-months test frequency required by IWV-3521 and proposes to test these valves during refueling outages but not more frequently than once per 3 months.
j Licensee's Basis for Requesting Relief Testing of these valves during normal operation requires removing the associated RHR train from operation due to differential pressure across the valve, thereby decreasing the level of plant reliability.
Evaluation We agree with the licensee's basis and approve the requested relief. Not only is there a pressure differential across the valve, but, since the RHR Service Water is drawn from the river, exercising this valve when the RHR pumps are not running would degrade the quality of the water downstream of l
the RHR pumps. It is not the policy of the staff to cause degradation of the plant by meeting the test frequency stated in IWV-3521.
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20 e.
Core Spray System (1) Relief Request The licensee has requested specific relief for Category AC valves 2E21-F006 A&B (Core Spray Injection) from the exercise tests required by IWV-3520 and proposes an alternative procedure for verifying operability.
Licensee's Basis for Requestino Relief Same as C.4.d.2 (Valves 2E11-F050 A and B)
Evaluation Request conditionally approved.
Same as C.4.d.2 (2) Relief Request The licensee has requested specific relief for Category AC valves 2E21-F036 A&B (Core Spray Test Line - Containment Isolation) from the valve exercising test of IWV-3520 and leak rate test of IWV-3420.
Licensee's Basis for Relief Request These valves are required to close to fulft11 their safety function; however, since there is no valve between the check valves and the torus, closure carnot be verified by.a leak rate test. There are no practical means to verify closure of the valves.
This valve has been designated as an inboard containment isolation valve in the Appendix J program; therefore, it was included in the inservice testing program. This valve is sealed from the primary containment because the test line terminates below water level and outboard of the valve is a seismic seal water system. Therefore, any leakage through the valve during a loss of coolant accident (LOCA) would not be released to the environment. The integrated leak rate test (ILRT) is considered to be adequate testing. Disassem-bly of this valve for inspection would not increase the level of safety and ie not considered justifiable.
Evaluation These normally closed valves perform a dual function; 1.e.,
to open to allow the Containment Spray Pump to be tested and to close and provide isolation of the Containment in case of
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21 an accident.
In the latter case, the function of the valve is to prevent reverse flow, and the operability test must show that the disk travels to the seat promptly, if it is open, or remain tight against the seat if it is closed.
IWV-3520 states that confirmation that the disk is on its seat shall be by visual observation, by electrical signal initiated by a position-indicating device, by observation of appropriate pressure indications in the system, or by other positive means. We agree with the licensee that none of i
these specific tests are practical for these valves.
The ILRT will provide an indication of the leak tightness of these check valves; however, the staff believes it would be difficult to identify leakage into the outboard system unless leakage could be observed at a pump seal or other point in the system that is sensitive to the increased pressure of water.
The staff agrees with the licensee's basis that even if the disk is not fully on the seat, containment isolation could be maintained by the water seal in the suppression chamber and by the outboard containment isolation valve E21-F031. Also, testing the operability of these check valves through dis-assembly would not ensure complete closure after each pump test unless the valves were disassembled on the same schedule as the pump tests. Therefore, the staff approves the licensee's request and the use of ILRT to test the closure of these check valves.
(3) Relief Request The licensee has requested specific relief for Category AC valves 2E21-F044 A&B (Jockey Pump - Containment Isolation) from the requirement of IWV-3521 to exercise these valves at least once per three months. The valves will be verified to l
close each refueling outage by the local leak rate tests.
Licensee's Basis for Requesting Relief Same as for valves 2821-F010 A and B. Section C.4.a.(1).
Evaluation Same as for valves 2821-F010 A and B Section C.4.a.(1).
The licensee's request is approved.
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Main Steam Isolation Valve Leakage Control System Relief Request I
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The licensee has requested specific reitef for Category B valves 2E32-F006, 2E32-F007, 2E32-F008, and 2E32-F009 (MSIV Leakage i
Control) from the requirement of IWV-3411 that these valves be j
exercised once per three months.
f Licensee's Basis for Requesting Relief i
i If any of these valves are opened during normal operation, a f
single failure of the second isolation valve in the line, or an t
- l operator error, may result in damage to the lower pressure piping and equipment.
j Due to control circuitry, this valve cannot be partially stroked.
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j Consequently, the valve will be stroked every cold shutdown, but j
not more frequently than once per three months.
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Evaluation L
1 These 1.5-inch globe valves control leakage from the main steam lines when the plant is not operating and are normally closed i
i during plant operation to isolate the high pressure steam system l
from the low pressure exhaust components. We agree with the licensee's basis that it is impractical to test these valves during plant operation, and, as allowed by IWV-3412, testing may.
be deferred to cold shutdown. The licensee's request for reitef is, thereby, approved.
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g.
Hich Pressure Core Injection (HPCI)
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(1) Relief Request l
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The licensee has requested specific relief for Category A 4
j valve 2E41-F002 (HPCI Steam Supply Isolation) from the leak rate test requirements of IWV-3423(d) and proposes to test
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the valve in a nonconservative direction.
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Licensee's Basis for Requestino Relief I
r The correct direction for testing this valve is to pressurize
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from the inboard side of the valve; however, the piping on i
the inboard side runs directly from the valve to the reactor (via the main steam lines) and cannot be pressurized for j
- testing, i
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i closure 2 23 E.a' a*'
r agree n'th the
'1 1 erspe's bas's ar j approve the r e ;..e s t e ?
ne eef A ' t h e, ; *- tF 1rtaa'V t o"ta'omert 1selat' r
=a'.*
n
he pressa' led ' r a nar;orservat've d' rect'or tFe sa e te ?
w
pre s ',
le the outD( ard va'we 2f41-I t 4
correct d' rect'or arf p'av' des reau-jart and simm ' tar e proof va've integr'ty (See [ l e)
(2)
Re'1e' Request The litersee has requested speci'iC relief for Categacy A
va've JE4;-fu06 and Categor 8 kaive 2E4; -FOC-t'a*
the te,t v
freguercy requ' red by !hV-3411 and propose s te dem nst' ate the operab*l'ty of these va ve s dur ' r q eac h ccId shutd a'
'at l
rct mor-frecuert'y trar once per to'ee months
. : prseP' s bas's for ke]uest'rj kel ief
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wa've 2E4;-I c a r r, t be cicsed du' ing cormal operate te.40se its 'a' ure ir the cIused position would resu't I
tne l os, c' the HPi! system Va've 2E41-F006 cannot ce
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0; ered J'.r 'nq rarm.'
powe' operat'or without first c'os rq
?! 41 -I('u ?
f a'uaor ne agree w'tt t"e lI LPPspe's basis and a[prove the rey estej reef as prev'ded b_,
the Code ( I n"v - 3 412 )
( 3) ke'1e' Reques*
The licersee has requested spectfic relief for Categor A y
va've 2E41-F012 from tha lest test requiremerts o' Ing-342 4( d) and proposes to leak test this va've
'r a nor-conservative d'rection L i c e r s e_e_ ' s Bas 2!51-F001 and 2E51-F002 as well as fer Category A0 valves 2E51-F028 (R;!C vacuss p p Discharge -
To us Isolation) arc 2E51-FC40 (R:!C Turdiae Enhaust-Ter;s Isolatten) frem the schedslar re: wire ent of InV-3521 aad pre;cses tc test these valves for c;erability by an alter-native retecd.
Liceesee's Basis for Re:vestir; Relief These check valves are located on the ROIC twebiae stea-enhaust 11res. During quarterly pa p testieg, these valves are cartially strched during system cceration; henever, test ccacittens do not previde suf ficient fice to prcve that the valves are fully epen. Cee of these valves will be disasser31ed en a retattn; tasis each refueling catage. If the valve is determired to be non-fe ctional, se that the a
design fic. =cuic not cass threw;h the valve, an aediticeal valve will be disasse-eled. Failure cf this valve = calc recuire disassettly of the remaining valves.
Evaluatice i
Trese fcur valves have a dsal fu9etten, isolation of tre l
tcrus aad control of flow of water free the E0!C tuettre eshaust and enhaust drain when the H;CI pw's is operating.
Tre elesure function is tested as cescrited in Section C.4.g.1.1 ateve. We agree with the Itcensee's crocosal te test the full-c;en function of these valves by certedic l
disasse-31y. The cuarterly pu o tests will verify inat t*e l
valves are net frecen shut.
We, therefore, approve the l
licensee's re; west for relief.
(2) Relief Request l
The licensee has reawested specific reitef for Cate; cry A 1
valve 2E51-F003 (R !C pv ; Swction - Tcrus !solatics) frc-tre leak rate test requirerents of IWV-3423(d) aed preccses to test the valve in a neccenservative reverse directlen as addressed in the containment leak rate test progra-for tre l
type C leakage tests.
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licensee' Basis for Requesting Relief 1
The correct direction for testing this valve is to pressurize from the inboard side of the valve; however, the piping on the inboard side runs directly from the valve to the torus and cannot be pressurized for testing.
Evaluation l
i We agree with the licensee's basis and approve the requested relief. Although this containment isolation valve will be pressurized in a nonconservative direction, the same test will evaluate valve 2E51-F031 in the correct direction.
Valve 2E51-F031 is in the same line as valve E51-F003 and provides redundant assurance of isolation in the event of a leak through valve 2E51-F003 (See C.1.e).
(3) Rel_1ef Request The Itcensee has also requested specific relief from the leak rate test requirements of IWV-3423(d) for valve E51-F007 (RCIC Steam Supply - Inboard Isolation) and proposes to test this gate valve by pressurizing from a nonconservative direction.
Licensee' s Basis for Requesting Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.
Evaluation We agree with the licensee's basis and approve the requested i
relief. By pressurizing this 4-inch line between 2E51-F007 and 2E51-F008, the outboard valve (F008) will be tested in the conservative direction and, thereby, ensure leak tight-ness outside of the primary containment. The test will also l
give a nonconservative indication of the leakage of F007 l
inside the primary containment (See C.1.e).
l (4) Relief Request The licensee has also requested specific relief from the leak rate test requirements of IWV-3423(d) for valve 2E51-F019 (RCIC Pump Minimum Flow - Torus Isolation) and proposes to test this gate valve by pressurizing from a non-conservative direction.
i 5
29 Licensee's Basis for Requesting Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.
Evaluation We agree with the licensee's basis and approve the requested relief. By pressurizing this 4-inch line between 2E51-F019 and 2E51-F021, the outboard valve (F021) will be tested in the conservative direction and, thereby, ensure leak tight-ness outside of the primary containment. The test will also give a nonconservative indication of the leakage of F019 inside the primary containment (See C.I.e).
(5) Relief Request The licensee has also requested specific relief from the leak rate test requirements of IWV-3423 for valve 2E51-F105 (RCIC Vacuum Breaker - Torus Isolation) and proposes to test this gate valve by pressurizing from a nonconservative direction.
Licensee's Basis for Requesting Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.
Evaluation We agree with the licensee's basis and approve the requested relief. By pressurizing this 4-inch line between 2E51-F105 and 2E51-F104, the outboard valve 2E51-F104 will be tested in the conservative direction and, thereby, ensure leak tight-ness outside of the primary containment. The test will also give a nonconservative indication of the leakage of valve 2E51-F105 inside the primary containment (See C.1.e).
1.
Plant Service Water (1) Relief Request The licensee has requested specific relief for Category C valves 2P41-F024A and B (HPCI Pump Room Cooler), 2P41-F025 A and B (RHR and Core Spray Pump Room Cooler), 2P41-F026 A and B (RHR Pump Cooler) and 2P41-F028 A and B (RCIC Pump Room Cooler) from the valve exercising requirements of IWV-3521 and has proposed an alternate method for verifying that the valves fulfill their functions.
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33 Lice-see's Basis fee ter.estia; c tief e
%:e ally c1:ses cae:A valves 2P41-F024 A ard 9, 2841-F225 A aa 8, 2P41-F026 A and B, aad 2 41-F02S A sad 5 su::1 y ser. ice water to R=R ar: Core 5: ray, HPCI, aad R; C.
aa:
w roes c:alers.
C.*ing c.arterly testie; cf tee tv :s, t*e coolers are pla:ec in c:eratten, there:y strekir; t*ese valves. Mc ever, t*e cest;n of the systes c:es e:t rcetce foe csitive verification cf the fice rate the:w;h ea:5 valve.
Cae valve =111 be cisasse-tied each refueling cutage en a rotating Casis to answee that the design fun: tion of t*e valve can to 4:Mieved.
If t*e valve is deter-tee: to te e:n-fwe:tional an additiceal valve =111 te disasse-ties.
Fatture of this valve will re: wire the cisasse-cli cf the re-atning valves for that unit.
Evaluatten be agree with t*e licensee's basis aed a:; rove the res ested relief. These valves are e:really closed and are cea. trolled by ter:eratwre eleeents in ea:h of the u rc:ss. Tae
- osition of the valve, therefore, is a fue tion of t*e tee;erature of each Pwe R0cm and can be indirectly veetfted by verifytre that swff1cte*t cc
- 11eg is teteg :r vided. We corstcee this tedirect indication, in accitten to the
- ert:01c disassetely of each valve, to fulfill the intent cf.
tte Ccce.
(2) Ee'tef Re: vest Tre Itceasee has retuested see:tfic relief for Cate;:ey B valves 2P41-F035 A and B (H CI Pu : R:en Cooler), 2741-F036 A aed B (R*4 anc C5 Fw?: Rees C:oler), 2P41-F037 A, B, C a*: 0 (Rr; Pu Ceoler), 2P41-F03; A and B (RMR :s ; Cccler),
2P41-F040 A aad B (RCIC Pu?: Re:s Cooler, 2P41-FC42 A and 2 (CR3 Pue: Roen Cooler), 2P41-F339 A and B (Diesel Gererat:r Cooling), and 2P41-F340 (Diesel Geeerator Cooling) fre-the streke-stre re:utre ents of IWY-3413(c) and IWV-3417 aac Orc 3ses to assign a cas1Fu? Stroke tire for these valves.
Liceasee's Basts for Requestiec Relief IWV-3413(b) reRutres stecke tiees shall be measured to the etarest se:ced, fer stecke tires 10 seconds or less,10', cf the s:ecified lintting steche tire for full-stecke tiees Iceger than 10 se: ends.
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!W-3417 requires that if the stroke time increases by 25'i i
l from the previous test for valves with full-stroke times greater than 10 seconds or 50*. for valves will full-stroke times less than 10 seconds, the test frequency shall be increased to once each month until corrective action is taken.
i These valves are air-operated valves without indicating i
lights or control switches. Measurement of stroke times can 1
be performed only by observation of the stem movement when I
the associated room cooler is placed into operation. This i
i type of testing does not provide the accuracy required by i
j IWV-3413(b) and IWV-3417.
l A maximum stroke time will be assigned to each valve and I
j these specifications will be provided to the NRC staff.
If I
the measured stroke time exceeds this value the valve will be I
l declared inoperable.
4 Evaluation i
t I
The staff's position on stroke times is summarized in
[
$ections C.1.f and C.2 of this Safety Evaluation. We approve the requested relief on the condition that the maximum stroke time assigned to ee:h valve will be as short as practical and l.
will not be so long that degradation of the valve cannot be
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identified.
i (3) Relief Request The licensee has requested specific relief for Category A valves 2P41-F096 A and B (Drywell Air Cooler - Isolation) from the schedular requirements of IWV-3411 and proposes to exercise these 8-inch valves during cold shutdown but not
[
i more frequently than once per three months.
Licensee's Basis for Requestino Relief i
IWV-3411 requires that valves be exercised at least once per three months.
1 Closure of this normally open valve would totally interrupt flow to the drywell coolers. This interruption may cause an increase in drywell temperature which would require removing the unit from operation. The valve cannot be partially l
stroked due to control circuitry.'
l This valve will be stroked every cold shutdown but not more j
frequently than once per three months.
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I 32 Evaluation We agree with the licensee's basis and approve the requested relief as permitted by the Code.
(4) Relief Request The licensee has requested specific relief from part-stroke or full-stroke exercising Category B valves 2P41-F316A, F3168, F316C and F3160 (Turbine Building Supply Shutof f) on a quarterly frequency as required by IWV-3411.
Licensee's Basis for Requesting Relief Closure of these valves during normal operation would inter-rupt flow to the turbine building equipment that is normally cooled by service water. Also, the valves cannot be part-I stroked because the control circuitry will not permit part-I stroking. The required exercising will be performed during cold shutdowns (not to exceed a frequency of once every three months).
Evaluation 9
During the June 23, 1983, meeting between staff and licensee, the Itcensee informed the staff that both cooling trains must be available to provide sufficient cooling to the equipment in the turbine building. We agree with the licensee's basis.
that part-stroking or full-stroking cannot be achieved during normal power operation and we approve the required relief.
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Reactor Buildino Closed _ Cooling Water Relief Request The licensee has requested speelfic relief for Category A valves
[
2p42-F051 and F052 (RBCCW to Recirc.-Containment-Isolation) as required by IWV-3411.
Licensee's Basis for Requesting Relief IWV-3411 requires that valves be exercised at least once per three months; however, closure of this valve during normal operation would shut off the cooling water to a Reactor Water Recirculating System Pump. These valves will be stroked every cold shutdown but not more frequently than once per three months.
Evaluation ine staff has examined and agrees with the bases for permitting the requested relief. The requested relief is granted.
33 k.
Chilled Water System Relief Request The licensee has requested specific relief for Category A valves 2P64-F045 and 2P64-F047 (Chilled Water-Containment Isolation) from the requirements of IWV-3411 to exercise that valves once per three months and proposes to test these valves every cold shut-down, but not more frequently than once per three months.
Licensee's Basis for Requ'estino Relief Closure of this normally open valve would totally interrupt flow to the drywell coolers. This interruption may cause an increase in drywell temperature which would require removing the unit from operation. The valve cannot be partially stroked due to control circuitry.
Evaluation The Code (IWV-3412) makes allowances for valves that cannot be exercised during plant operation and that cannot be part-stroked.
We agree with the licensee's basis that neither full-stroking or part-stroking these containment isolation valves is practical during plant operation. Consequently, we approve the relief i
request and the proposal to full-stroke these valves during cold shutdown.
1.
Drywell Pneumatic Relief Request The licensee has requested specific relief fron exercising Category AC valve 2P70-F020 (Orywell Pneumatic - Containment Isolation) on the quarterly test frequency retuired bv IYV-3021 and proposes to exercise it during each refueling outage.
Licensee's Basis for Requestino Relief This isolation valve is a normally-open check valve with design flow passing through it during normal operation. The only means of verifying that it has exercised to closure (th> position required to fulfill its safety function) is les*. testing. This verification is obtained each refueling outa;4 through the local leak rate (Appendix J) test.
Evaluation The staff agrees that the Code requirement is impractical for this valve. Relief is granted.
\\
l l
Er:1essee 2 3:
I e.
C:-t-et :e: -+.,
l et te' :e:.est l
Tre 11:ersee eas re:.este: s:e:tft: reite* f:- t e sai.es t e
C: te:1 t o: C t.e 53stes f-:s e e:.t eveets :* t e *::e
( =i-1100) a : : :::ses :: test : ese isi.es :Sif 1: t e e:.3-e-se* s =f t*e : tat Te:sti:a1 5:e:1ft:sti: s.
tt:easee's Easts *: s : estt :
s lte' e.
e
!='s-11:C set.1:es t*e rales ae: re:.1 eet-ts f:- tese*.t:e testi ;
cf :e tate Class 1. I a : 3 val =es.*.t:t are re:stre: :: :e f:-n a s:e:tft: f. :st:e t-st.ttt ; :.* a rea:::- :: tre ::1: s. ::..
- -:1ti: :- te eitt;atte;
- e
- se:.e :es f a a:: tee-i.
Te
- latt ie: rat:a1 5:e:sft:stt: s re:.tre all :: era:1e.'th: a.-
- ttr:1 r:es to De etee:tse: at least et:e :e* *eet **et at:ee a est;-ate: :D-e* 1eott. a*te ea:t eef.elte; g,;gge, 41) ;;.;p;;
e :s ca:a:1e :f e:-wat tese st:e s*.all te s:ran stee: f :e t e f.11y.its: 4.
- stst:e. als:.10'. af e r::s sP-ait :e s: an sine: f ees t*e f.11y.it :ca.? ::stit:t at least :-:e :e* ::: cay s f ::eratt:t. Tre ie: ret:41 5:e:tft:att:9s ; tee tre alle.a:1e tese-st: stres f:- : ese tests. T e Te:n-t:a1 5:e:tft:att:ts a:e:.atets ceecest-ate t*e ::e a:111ty =f t*e
- mi-ci :e :-t.e syster a*: tre at:tti: al re:4*reseets :f Se::t:- n!.:- 1: :
1 :* ease t*e 1e.el c' safety. I e e*:*e. Te:*t?:a1 5:e:ift: sit: s test 1*;.111 te use: te Ite. =f e Se: t:t II e:,t tee-tt.
E.ai.at*:*
'ee a; ee t*at tre 'e: Pet:ai 5:e:tft:sst: s f:- -at:- U-tt 1 (ie:*tt:al 5:e: tit:att: s 4.3.3. 3.3.E.2. 3.3.0.2 a*: a.3.0.2)
- .i:e f:- s.*.etila :e trat ve tfs
- at tre sal.es (es:e:tatis t*e s:ran telet a stlet salves) ?? es:? =>: a.11: :: te:!.+tt are ::e atte. 411 fs?:st: vi:t erart..(11 : :1e.tt e te 3
5:e:1fte: ttet 11:11. a?:.111 tr:t: ate e.1:et:e f ete-t:-att:-
(t*?:.;* st*cte stre). et a; ee trat tt.:sl te te:ca:tt:s1 1:
test ea:' My:raalt: Certe:1 Vitt se:arately
- e*
t** :tatt ts
- e att*;.
be, t*eref
- e. at *:se tre Itte*see's rette* ret.tst.
CC40ti.'5 f D%%
!e its evali.atica c' 19 lice
- set's relief recasts described ateve. t**
Staff c:e:1uded that certain of t*e rec.ests $5ev1d be cratted aed ctrers cce.dttionalty efa9ted. A susunary tatislatice c# twse c a tus10es is receiced in AttacPv'ient 1.
84 sed os its evaluatices. t N staff cerc190es t?at t*e tedicated reliefs thus granted =111 act eedaager 1tfe er saccierty ce tre cessien defeese and security of tN petitc. In its evaluatica c' t*e Itcesset's program tM staff identified pcssible eeficieMies in t*e s: e C l
the prc=; ras. TMse art susunar?:ef in Se:tice C.2.
The lice *see 1 :uld 6
l eraeine the functices of the systees amt individual valves 10ee,tified ir l
Sectica C.2. consteering tM met staff ecsition eescribed te Sectice A. a-d should revise tM IST progres accordingly if necessary,
e' 9
5 4
t J
/
h
~
ATTACHMENT 1
SUMMARY
OF PUMPS AND VALYES FOR WHICH RELIEF RFQUESTS ARE APPROVED, CONDITIONALLY APPROVED, OR DENIED T
TABLE A -
SUMMARY
TABULATION OF PUMP REllEF REQUEST EVALUATIONS Roller Request References Evaluation Pumps Retier Reauest SER Denied Approyed Standby Liquid Control 7.1.2 Sect. B.2.a.
X and 7.1.5 Plant Service Water and 7.1.3 Sect. B. 2. b. ( 1 )
X RHR Service Water 7.1.1 Sect. B.2.b.(2)
X 7.1.4 Sect. B.2.b.(3)
X RHR a7d Core Spray 7.1.1 Sect. B.2.c.
X a nd 7.1. 4 X
Jockey Pumps 7.1.7 Sect. B.2.d.(1)
X 7.1.6 Sect. B.2.d.(2)
X Standby Diesel Gene ra to r 7.1.3 Sect. B.2. e. ( 1 )
X Se rvice Wa te r Pump 7.1.6 Sect. B.2.e.(2)
X
l C
ATTACHMENT _1
SUMMARY
OF PUMPS AND VALVES FOR WHICH RELIEF REQUESTS ARE APPROVED, CONDITIONALLY APPROVED, OR DENIED TABL6 B.1 -
SUMMARY
OF CENERAL VALVE REll[F REQUESTS EVALUATIONS Evaluation Conditionally Gene ra l Ca tego ry of Va lve s Roller Request SER Section Denied C ranted Granted Valves requiring corrective 6.1.1 C.3.a X
action in accordance with eWV-3523 before startup from cold shutdown valves normally tested at 6.1.2 C 3.b x
cold shutdown or refueling that require increased test f requency in accordance wi th
- WV-3417( a )
4 W
Enclos re 2
(
Aji ACHM(fiU
SUMMARY
OF PUMPS AND VALVES FOR milch RELIEF REQUESTS ARE APPROVED, CONDli10NALLY APPROVID, _0R DENifD TABLE B.2 - }UMMARY TAHULATION OF SELC I F I C vat.yLR1LRfgqut $i. [YALUAl l OM Conditionally Valves Religf_Requ.est
$LR_{ 5mpM Deng d Approvgj
,J pproved_
Main Steam and Feedwater (B21-
)
FOIO A & B 6.1.1 C 4.a.1 X
F016 6.1.2 C.4.a.2 X
F037A thru L 6.1.3 C.4.a.3 X
F076 A & R Note 13 C.4.a.4 X
FOTT A & B Note 13 C.4.a.4 X
Reactor Recirculation System (831-
)
F013 A&B and F017 A&B 6.1.1 C. fa. b.1 X
F031 A&R 6.1.4 C.4 b.2 X
Standby Liquid Control System (C41-
)
F006 and F007 6.1.5 C.4.c.1 X
Residual Heat Removal System ([11-
)
FOOT A&M and f011 A&M 6.1.2 C.4.d.1 X
F0$0 A&H 6.1.7 C.4.d.2 X
- 078 A&B 6.1.8 C.8.d.3 X
4 Core Spray System (E21- )
f006 A&H 6.1.7 C.4.e.1 X
F036 A&B 6.1.6 C.4.e.2 X
MSIV leakage Control System (PE32-
)
F006 6.1.20 C.4.0 X
T001 6.1.20 C.4.0 X
F008 6.1.20 C. 8. f' X
4 1009 6.1.20 C.4.f X
High Pressure Coolant injection System (Elst-
)
1002 6.1.2 C 4.g.1 X
1006 6.1.10 C. fs. g. 2 X
FOOT 6.1.10 C.4.g.?
X f012 6.1.2 C.fa.g.3 X
.-.. - -. _. - -. _... _ ~.. _..
- -.~..
e f
TABLF B.2 -
SUMMARY
TA8ULAfl08l OF SPECIFIC VALVE REll[F REQUEST EVALUAil0NS Conditionally Valves Beller Reevest SER (Sectd Denied Approved
_ Approved _
(E41 Cont'd)
(021 and F022 6.1.11 C.4.g.4.1 X
6.1.12 C.4.g.4.2 X
F040 6.1.12 C.4.g.4.2 X
F045 6.1.13 C.4.g.5 X
F049 6.1.12 C.4.9.4.2 X
rill 6.1.2 C.4.g.6 x
i f
)
i S
1
(
- e.
c -
TABLE B.2 -
SUMMARY
TABtJLATION OF SPECIFIC VALVE REllEF REQUEST EVALUATIONS (Continued)
Conditionally Valves Rollel' Reque11
}FMSylj penied Appt_oved App roved _
Reactor Coolant injection Cooling System (E51- )
f001 and 8002 6.1.11 C.4.h.1.1 X
6.1.12 C.4.h l.2 X
F003 6.1.2 C.4.h.2 X
FOOT 6.1.2 C.4.h.3 X
T019 6.1.2 C.4.h.4 X
T028 and F08 0 6.1.12 C 4.h.1.2 X
4 FIOS 6.1.2 C.8.h.5 X
4 Plant Service Wa te r ( P41-
)
F024 AAB -
6. 1. 18 C.4.3.1 X
F025 A&B 6,1. Ils C.4.l.1 X
F026 A&B 6. 1. 188 C. 8. 3.1 X
4 F028 A&B 6.1.14 C.8.i.1 X
8 F035 A&O 6.1.15 C.4.i.2 X
/036 A&R 6.1.15 C. 84.1. 2 X
F031 A&B 6.1.15 C.8.i.2 X
8 T039 A&B 6.1.15 C.4.3.2 X
l040 A&D 6.1.15 C.4.1.2 X
IO42 A&B 6.1.15 C.4.l.2 X
F096 A&B 6.1.16 C.4.i.3 X
F316 A.
B, C, & D 6.1.11 C. 8. 8.4
- X 8
F339 A&B 6.1.15 C.4 X
F340 6.1.15 C.4 X
Reactor Building Closed Coo l ing Wa te r ( P42-
)
F051 and F052 Note 52 C.4.J X
Chilled Water System
( 2 P684-
)
1045 6.1.16 C.4.k X
l04F 6.1.16 C.4.k X
Drywe i i Pneumatic ( P70-
)
F020 6.1.1 C.4.1 X
Control Rod Drive 6.1.22 C.4.m X
b
il v
d b
P& ids Used in the Staff's Review System Drawing No.
Nuclear Boiler H-26000 Reactor Recirculation H-26003 Standby Liquid Control H-26009 Residual Heat Removal H-26014, H-26015, H-21039 Core Spray H-26018 Main Steam Isolation Valve Leakage Control System H-26081 HPCI H-26020 RCIC H-26023 Plant Service Water H-26050, H-26051 H-21033 Reactor Building Closed Cooling Water H-26055 Chilled Water System H-26081 Drywell Pneumatic H-26066
!