ML20128G780
| ML20128G780 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/15/1985 |
| From: | EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML20128G735 | List: |
| References | |
| NUDOCS 8505300307 | |
| Download: ML20128G780 (54) | |
Text
ID ENCLOSURE 1 J
SAFETY EVALUATION REPORT
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PUMP AND VALVE INSERVICE. TESTING PROGRAM MILLSTONE NUCLEAR POWER STATION, UNIT ~1, FOR THE :SECOND 10-YEAR INTERVAL y>
ACKNOWLEDGEMENT This safety evaluation report was prepared with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idaho, Inc.) under contract to the U.S. Nuclear Regulatory Commission.
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-CONTENTS Page
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1.
INTRODUCTION AND
SUMMARY
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2.
PUMP. TESTING PR0 GRAM.....................................
2 2.1 Generic Relief Requests....................................
3 2.2 Pump Flow Rate Measurement.................................
7 2.3 Pump Differential Pressure Measurement.....................
9 2.4 Test Interval..............................................
10 3.
VALVE TESTING PROGRAM...........................................
13 3.1 General-Considerations.....................................
13 3.1.1 Exercising of CNeck Valves..........................
13 3.1.2 Valves Identified for Cold Shutdown Exercising......
13 3.1.3 Conditions for Valve Testing During Cold Shutdowns...........................................
14 3.1.4 Category A Valve Leak Test Requirements for Contaminent Isolation Valves (CIVS).................
14 3.1.5 Application of Appendix J Testing to the IST Program.............................................
15 3.1.6 Safety Related Valves...............................
15 3.1.7 Valves Which Perform a Pressure Boundary Isolation Function..................................
15 3.1.8 Test Frequency of Check Valves Tested at Cold Shutdown.......................................
17 i
- 03/04/85 ii Millstone 1 IST SER m
i CONTENTS (Cont'd)
_Paae 3.2 Generic Relief Requests....................................
17 3.2.1 All Category A Containment Isolation Valves.........
17 3.3 'Feedwater Coolant Injection System.........................
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- 3. 3.' 1 Catsgory B Valves...................................
21 3.3.2 Category C Valves...................................
22 3.4 Control Rod Drive Hyd aulic System.........................
24 3.4.1 Ca t e g o ry B Va l v e s...................................
24 3.4.2 Category C Valves...................................
26 3.5 Core Spray System..........................................
27 3.5.1 Category C Valves...................................
27 3.6 Low Pressure Coolant Injection System.....................
28 3.6.1 Category C Valves..............................'.....
28 3.7 Standby Liqui d Control Va1 ves...............................
29 3.7.1 Category A Valves...................................
29 3.8 Isolation Condenser...t..................................
30 3.8.1 Ca te g o ry C Va l v e s...................................
30 3.9 Service Water System.......................................
31 3.9.1 Category B Valves...................................
31 3.10 Reactor Building Closed Cooling Water System..............
32 3.10.1 Category B and C Valves..........................
32 3.11 Shutdown Cooling System....................................
33 L
t-3.11.1 Category A, B and C Valves........................
33 3.12 Main Steam System..........................................
34 3.12.1 Category C Va1ves..................................
34 3.13 Emergency Service Water System.............................
35 03/15/85 iii Millstone 1 IST.SER
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a CONTENTS (Cont'd)
Page 3.13.1 Ca te go ry B Val ve s..................................
35 3.14 Standby Gas Treatment Va1ves...............................
35 3.14.1 ~ Cate go ry B Va1 v e s..................................
36 3.15 Head Soray Valves.........................................
36 3.15.1 Category A and A/C Valves..........................
36 3.16 Reactor Coolant Sample Va1ves..............................
37 3.16.1 Category A Valves.............................'.....
37.
TABLE A...............................................................
39 APPENDIX A CODE REQUIREMENTS..........................................
40 1.
CODE REQUIREMENTS--VALVES.......................................
40 2.
CODE REQUIREMENTS--PUMPS........................................
40 APPENDIX B VALVES WHICH MEET CODE REQUIREMENTS AND ARE NO EXERCISED EVERY 3 M0NTHS.............................................
41 1.
FEEDWATER COOLANT INJECTION SYSTEM..............................
41 1.1 Category B Valves..........................................
41
- 1. 2 Category C Valves..........................................
41
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CONTENTS (Cont'd)
Paoe 2.
RENCTOR RECIRCULATION SYSTEM.....................................
42-2.1 C a t e g o ry B V a l v e s...........................................
42 u-
's 3.
CONTROL R00 DRIVE HYDRALIC SYSTEM................................
42' 1
3.1. Category C Valves..........................................
42 4.
CONTAINMENT ISOLATION VALVES....................................
42' 4
4 '.1 Category A and A/C Valves.................................
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5.
REACTOR CLEAN-UP SYSTEM.....................................'.....
43 1
5.1 Category A Va1ves..........................................
43 6.
DRYWELL NITROGEN COMPRESSOR;.....................................
43 6.1 Categcry B Va1ves..........................................
43 i;
APPENDIX C P&IDS......................................................
44 APPENDIX D
SUMMARY
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-APPENDIX E N0TES......................................................
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1.
INTRODUCTION AND
SUMMARY
Contained he~ rein is a safety evaluation of the pump and valve inservice testing (IST) program submitt(f by the Northeast Nuclear Energy Company (NNECO) for its Millstone Nuclear Power Station, Unit 1.
The licensee's IST-program for pumps and valves for 10 year inspection interval two.(December 28, 1980 through December 28, 1990) is evaluated herein.
Initially tne. licensee submitted the program'for inspection interval two by a letter dated September.18, 1980 and amended by the licensee by a letter dated September 30, 1981.
That program was based on the previous program of September 1979.
Interim relief pending transmittal of this SER, to invoke the IST program for 10fyear inspection interval two was granted to the licensee by a-letter from NRC dated April 10, 1981.
The staff continued its review and requested additional information from-the licensee by a letter dated September 24, 1981.
A conference call was held with the licensee on April 1, 1982 to discuss NRC staff concerns.
.The licensee responded to the staff's questions of September 24, 1981 in a letter to NRC dated June 22, 1982.
The staff's contractor (EG&G Idaho) transmitted a report of evaluations of th'e Millstone 1 IST program for 10 year inspection interval two on June 30, 1983.
On January 16,.1985 the licensee submitted a completely revised IST program for pumps and valves for 10 year inspecti6n interval two.
This SER'is based on submittals by the licensee through January IS,1985, as listed above.
The licensee is to ccmply with the IST program dated January 16, 1985 in accordance with the relief granted or denied in this SER.
The licensee is not-to implement any further changes to the IST program except as required by this SER without the written approval of the NRC.
Changes required by this SER must be implemented promptly.
The licensee is to submit a schedule for revision of the IST program and Technical Specifications in order to comply with this SER within 30 days.
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.1 The evaluations in this SER of the Millstone Nuclear Power Station Unit 1 pump and' valve inservice testing program are those of the NRC staff and cover the documents outlined above.
A' summary of Section XI pump and valve testing requirements is provided in Appendix.A.,
Category A, B and C valves that meet the requirements of the 1980 ASME Code,Section XI, and are not exercised quarterly are addressed in Appendix B.
-A-listing ef-P& ids used for this review is contained in Appendix C.
Valves that have an interval between tests longer than each refueling outage and relief requests with insufficient technical basis where relief is not granted are summarized in Appendix D.
Appendix 0 and E also address other items that are not in accordance with NRC requirements.
The Code of Federal Regulations paragraph 50.55a (g)(5)(ii) states:
"If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program.
This application shall be submitted at least 6 months before the start of the period during which the' provisions become applicable as determined by paragraph (g)(4) of this section.
The IST program and the technical specifications should be in full agreement.
If a conflict is identified by the licensee, both the technical specifications and the IST program must be complied with until relief is granted by the NRC.
2.
PUMP TESTING PROGRAM The Millstone Unit 1 IST program submitted by Northeast Nuclear Energy Company was examined to verify that Class 1, 2, and 3 safety-related pumps included in
.the program are subjected to the periodic tests required by ASME Code,Section XI.
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'Except as noted in Appendix D or where specific relief from testing has been 03/15/85.
requested,-these pumps'are tested to the Code requirements summarized in Appendix A.
Each; Northeast' Nuclear Energy Company basis for requesting relief from the pump testing requirements and the NRC staff evaluation of that request appears below.-
~2.1~ Generic. Relief Requests 2.1.1.ReliefRequesth-1.
The licensee has requested specific relief from'the-v.ibration monitoring' requirements of Section XI for all safety related pumps and.
proposes'to utilize their vibration signature analysis program as an alternate.
2.1.1.1 Code Requirement.
IWP-4510 states "At least one displacement vibra-tion ~' amplitude (peak-to peak composite)_ shall be read during each inservice test'."
2.1.1.2 Licensee's Basis for Requesting Relief.
To meet the vibration monitoring-requirements of'ASME Section XI, Subsection IWP, exception is taken to the specific
~ vibration requirements of IWP, and an alternate, more effective vibration signature
' analysis program,-as described herein, is proposed.
During the inservice pump test, vibration data shall be acquired in the form of a " vibration signature" rather than a. simple reading of overall vibration amplitude.
The vibration signa-ture shall consist of a plot of Vibration amplitude in units of inches per second peak. velocity, versus~ frequency in cycles per second, typically over a frequency range of-0_to 500 cycles per-second.
The vibration signature analysis approach
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provides a more reliable means of detecting a deterioration of pump mechanical condition, a determination of the cause of the problem,.and a more accurate assessment of vibration severity.
The periodically acquired vibration signatures shall be~ compared to a' baseline' reference signature and analyzed for changes in amplitude peaks exceeding a threshold value.
Criteria for evaluation of changes as to cause,' severity, and the establishment of the_ alert and required action ranges'shall be specified.in the NNEC0 procedures.
Vibration measurements are made typically with an accelerometer mounted at a reference location on the equipment bearing housing, and the data is processed by a spectrum analyzer to produce a hard copy vibration signature.
The vibra-
' tion sensors can also be interfaced directly with the spectrum analyzer.
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.The measurement locations to be used for monthly and baseline vibration signa-ture data shall be established and specified by NNECO procedures.
2.1.1.3 Evaluation.
Pump vibration is a required measurement to detect any changes in the mechanical characteristics of a pump, thus it is possible to
-detect developing problems so repairs *can be initiated prior to the pump becom-
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ing inoperable.(i.e.,. unable to perform its function).
The ASME Code minimum standards require measurement of the displacement vibration amplitude in mils (thousandths of an inch) every month.
Millstone Unit 1 has proposed an alter-nate program which is more comprehensive than that required by Section XI.
This
. program consists of a monthly vibration signature analysis on each pump over a frequency range of 0 to 500 cycles per second.
The vibration signature would be compared to a baseline reference vibration signature and analyzed for changes in amplitude peaks exceeding a threshold value. -Even though the vibration signature analysis program appears to be more effective for monitoring pump condition, limit-ing values have not been defined in the IST program that clearly indicate when corrective action is required.
Therefore, the proposed alternate' test program is not acceptable.
2.1.1.4 Conclusion.
Due to the lack of limiting values for establishing alert ranges and corrective action limits, the alternate program is unacceptable.
Relief will not be granted from the pump vibration monitoring requirements of Section XI unless and until acceptable alert and required action ranges are established by the licensee and approved by the staff.
Table A (a'ttached) contains ranges of pump vibration velocity which are acceptable to the staff.
2.1.2 Relief Request R-3.
The licensee has requested specific relief from the pumped fluid temperature measurement requirements of Section XI for all safety related pumps.
2.1.2.1 Code Requirement.
IWP-4320 of previous editions of the ASME code stated that the temperature of the liquid being pumped shall be determined at a fixed point in the system.
The point shall be located in such a way that the temper-ature measured is representative of the temperature of the liquid passing though the pump.
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i 2.1.2.2 Licensee's Basis for Requesting Relief.
Pumped fluid temperature measure-ment is not a meaningful parameter to measure for this series of operational. readi-ness tests.
This was recognized by ASME Section XI in code addenda subsequent to the Summ.er, 1978 addenda, when this requirement was deleted.
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2.1.2.3 Evaluation. The licensee has requested relief from the requirement to measure pumped fluid temperature based on it.not being a meaningful parameter for monitoring pump condition and the fact that the requirement was deleted from the Code after the Summer 1978 Addenda.
The Millstone IST Program was originally prepared following the 1974 ASME Code and Summer 1975 Addenda wherein there is no requirement for measuring the pumped fluid temperature.
Therefore, relief snould be granted from pumped fluid measurement requirements of Section XI.
The currently invoked 1980 Edition also has.no requirement.
2.1.2.4 Conclusion.
Measurement of the parameters required by Table IWP-3100-1
-of Section XI, will give reasonable assurance of pump function intended by the Code.
Based on the considerations discussed above, the relief thus granted will not endanger life or property or the common defense and security of the public.
2.1.3 Relief. Request R-2.
The licensee has requested specific relief from the pump bearing temperature measurement requirements of Section XI for all safety related pumps and proposes to use pump vibration signature analysis as the means of monitoring the various pump's mechanical condition.
2.1.3.1 Code Requirement.
Refer to Appendix A.
2.1.3.2 Licensee's Basis for Requesting Relief.
Bearing metal temperature monitoring can be effective in detecting bearing problems.
However, only six of the tabulated pumps (three feedwater and three condensate booster) have the permanently installed temperature sensors required to aieasure bearing metal temperature; i.e., outer race of anti-friction bearing or babbit lining of sleeve bearing.
The annual measurement for bearing housing temperature is far less effective in detecting bearing problems than the monthly performance of vibration signature analysis being performed by NNECO.
The remaining pumps listed in Table IWP do not have adequate design provisions to allow meaningful bearing temperatures to be taken:
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' Low pressure coolant injection, core spray, condensate, service
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o water, and emergency service water pumps are vertical design pumps with bearings located in the motor driver and pump casing.
The bearings are inaccessible.for temperature measurements.
Please refer to the Safety Evaluation attached to Amendment 64 of POL No. DPR-21.
o Standby liquid control pump bearings are mounted in a massive oil-filled reser.voir which is in direct contact with the pumped fluid.
Thus, measurement of housing temperature is not indicative of bearing condition.
Reactor building closed cooling water (RBCCW), reactor shu.tdown cooling, o
secoadary closed. cool-ing water CCW, fuel pool cooling, feed pump seal water, and control rod drive (CRD) pumps have recessed bearings and housing temperature measurements are possible but of questionable value.
o.
The emergency condensate transfer pump bearing temperature cannot be considered meaningful ~since the pump hydraulic circuit (condensate storage tank to condenser hotwell--no recirculation oath) allows only about five minutes 6f operation before the hotwells are filled.
This short run time does not allow the bearing temperature to stabilize.
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Service water and emergency service water pump bearings are underwater and inaccessible.
In general, as internal bearing metal temperatures increase due to bearing over-load, improper lubrication, or faulty installation, etc., much of the heat will be dissipated throughout.the relatively massive housings, oil reservoir, and attached casing.
As a result, bearing housing temperatures will respond much less than bearing metal temperature, greatly reducing the sensitivity to detect detect bearing heat-up problems.
Another important requirement to assure reliable bearing temperature monitoring is that it be continuous, not periodic.
Experience indicates that failing bear-ings, whether anti-friction type or sleeve, often exhibit fluctuations between normal and abnormal metal temperatures.
A good example is the babbit lined sleeve bearing which will initially experience a rapid rise in temperature and then return.to normal temperatures after the bearing wipes and clearances open up causing increased oil flow.
The abnormal temperature rise would most probably go undetected unless continuously monitored.
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The monthly vibration signat're analysis conducted by NNEC0 will detect bearing u
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At the onset of a bearing problem, low level
- vibration'will be generated at characteristic frequencies depending on the nature of the prob,lem.
The low level vibration typically amounts to less than 1 percent of.-the overall vibration amplitude and therefore cannot be detected by a simple -
amplitudemonitoringp;ogramconformingtoIWPninimumrequirements.
However,-
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the low. level changes in bearing distress' frequencies.are routinely detected in the Millstone signature analysis program and analyzed to pinpoint the cause.
As an alternate, NNECO will. record and analyze pump vibration signature monthly.
-Signature will be measured as velocity spectrum between 0 and 500 hertz.
This monthly analysis will provide more meaningful analysis _of pump bearing condition
, than' annual measurement of bearing temperature.
2.1.3.3 _ Evaluation.
The licensee has requested relief from Section XI require-ments of recording ~ bearing temperatures for all pumps important to safety.
Their basis for' relief is that the monthly. vibration signature analysis' program is more effective in monitoring-bearing degradation than recording bearing temperature-Lyearly.
The vibration signature analysis program may be more effective in moni-toring pump condition, however, limiting values have not been established that
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clearly indicate when maintenance. corrective action is required; Therefore, the proposed alternate test program is not acceptable.
2.1.3.4 Conclusion.
The proposed alternate test program of using the vibra-tion signature analysis' program in lieu of bearing temperature is not an acceptable alternative because the licensee's proposed vibration monitoring program does not include accepted limiting values for alerting and corrective action.
Accordingly, approval of the licensee's relief request regarding pump bearing temperature measurement is dependent on the establishment of an acceptable
- vibration measurement program.
See Paragraph 2.1.1.4 above.
2.2 Pump Flow Rate Measurement 03/15/85 7
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Relief Requests.
The licensee has requested specific relief from the individual pump flow-rate measurement requirements of Section XI for the following pumps.
Con'densate R-4, R-5*
Condensate Booster R4, R-7
,Reac, tor Building Closed Coo'ing Water R-14
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Reactor Feedwater (FWCI) R-4 Emergency Condensate Transfer R-10 Secondary Closed Cooling Water R-15 Reactor Feed Seal Water Injection R-9 Service Water R-12 Reactor Shutdown Cooling R-16 2.2.1.1 Code Requirement.
Refer to Appendix A.
2.2.1.2 Licensee's Basis for Requesting Relief.
Individual pump flow measure-ment instrumentation does not exist in the hydraulic circuits for the condensate, condensate booster, or reactor feedwater seal water injection pumps.
For the service water, secondary closed cooling water and reactor shutdown cooling pumps there is no instrumentation and the system flow various with the system line up.
In the case of the reactor feedwater and emergency condensate transfer pumps,.the licensee does not state that flow measuring devices do not exist, but rather, indicates'that flow rates cannot bk !stablished because of time limitations on operation of the pumps during normal plant operating conditions.
2.2.1.3 Evaluation.
Relief should not be granted from the requirement of measuring flow in accordance with the Code.
The current staff position on measuring Section XI parameters requires the necessary instrumentation be installed.
The lack of instrumentation is not an adequate te~chnical justification for granting relief.
'The licensee has not provided any acceptable technical justification for granting relief.
The licensee should provide the required instrumentation so ficw can be monitored in accordance with the Code.
For those pumps where flow measurement is to be made in the "as found" condition, the licensee's procedures for flow measurement and remedial actions must be documented in the IST program.
- Refers to licensee's relief request in IST program submittal of January 1985.
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I 2.2.1.4 Conclusion.
The licensee must test all pumps in the IST program in accordance with the requirements of ASME Code Section XI.
The licensee should make the required modifications prior to startup at the end of the next refueling outage.
Fo,r the balance of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by the licensee.
It would impose unneces-sary hardship on the licensee to make modifications before the next refueling outage and no compensat.ing increase in the level of safety will result for the short term.
Taking into account the tests that will be performed, it is concluded that this interim relief will not endanger life or property or the common defense and security of the public.
2.3 Pump Differential Pressure Measurement 2.3.1 Relief Requests.
The licensee has requested specific relief from the requirements of Section XI for measurement of pump differential pressure for the' condensate (R-6), emergency condensate transfer (R-10), service water (R-11),
emergency service water (R-11), and standby liquid control (SBLC)' (R-13) pumps.
2.3.1.1 Code Requirement.
Refer to Appendix A.
2.3.1.2 Licensee's Basis for Requesting Relief.
The service water and emergency service water pumps take suction directly from Niantic Bay and are not instru-mented for suction pressure, as the inlet pressure difference, caused by tidal swing, would be inconsequential with respect to pump performance.
The standby liquid control pump is a positive displacement punp, so differential pressure measurement would be meaningless.
The condensate pumps have no instrumentation to measure differential pressure directly.
For the emergency condensate transfer purps, insufficient operating time is available in order to establish a reference value.
As an alternate, pump discharge pressure and sea level for the service water pumps will be measured.
For the SBLC pumps, the discharge pressure is throttled to a constant value during the pump capacity test.
Pump flow and discharge pressure will be measured to ensure acceptable pump performance.
2.3.1.3 Evaluation.
Relief should be granted from the inlet and differential pressure measurement requirements of Section XI for the condensate, emergency 03/15/85 9
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condensate transfer, service water, emergency service water and standby liquid control pumps.
The licensee has demonstrated that the differential pressure readings for.the condensate, service water, and emergency service water pumps are'not pos,sible because there are no installed instruments that would give measurements indicative of pump degradation.
There is not sufficient time avail-able to,measpre pressure during the intermittent operation of the emergency condensate. transfer pumps.- The proposed alternate test program of calculating differential pressure by taking the difference between a measured discharge pressure and a suction pressure calculated from the suction level will be adequate to monitor pump degradation and. meet the intent of the Code.
Measuring differen-tial pressure for the SBLC pumps is meaningless because they are positive displace-ment pumps.
The licensee has proposed an alternate test of measuring flow rate and discharge pressure for the SBLC pumps.
The alternate test program wil be adequate to monitor pump condition and meet the intent of the Code.
Where " trend analysis" is indicated, it should be specifically defined along with limiting conditions for cperation in the IST program.
2.3.1.4 Conclusion.
The licensee's proposed alternate testing for the condensate, service water, emergency condensate transfer and emergency service water pumps of calculating pump differential pressure and suction pressure will provide _suffi-cient information to adequately monitor pump degradation and meet the intent of Section XI differential pressure requirements.
Measuring flow rate and discharge pressure will provide sufficient information to adequately monitor SBLC pump condition and meet the intent of Section XI differential pressure requirements.
The trend analysis for the emergency condensate transfer pumps must be adequately defined in the IST program.
Based on the considerations discussed above, the alternate testing proposed will provide reasonable assurance of pump function intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
2.4 Test Interval 2.4.1 Relief Request R-8.
The licensee has requested specific relief from the pump testing frequency requirements of Section XI for the reactor feed pumps and has proposed to perform the pump tests monthly only on the running pumps.
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) RAT 2.4.1.1 Code Requirement.
Refer to Appendix A.
2.4.1.2' Licensee's Basis for Requesting Relief.
Two of the three reactor feed pumps are r,unning during normel plant operation and are rotated every three months to equalize'. wear.
Several years of operating experience on the feed pumps have established this rotat, ion schedule as being the most effective in terms of equip
- ment reliabi.lity, operational readiness, and, reduction of potential plant flow transients which might be brought about by continuous pump switching.
As an alternate, inservice testing of the reactor feed pumps will be performed for those pumps running on a monthly basis.
2.4.1.3 Evaluation.
Relief should be granted from the test frequency require-ments of Section XI.
This relief request is no longer required since the licensee is meeting the 1980 ASME Code requirement for quarterly pump testing.
2.4.1.4 Conclusion.
The licensee should test the reactor feed pumps in accordance with the requirements of-Section XI of the 1980 ASME code on a quarterly basis.
This can be accomplished under the licensee's current test schedule.
2.4.2 Relief Request R-17.
Theilicensee has requested specific relief from the pump testing frequency requirements of Section XI for the reactor shutdown cooling pumps and has proposed to test these pumps during cold shutdown.
2.4.2.'l Code Requirement.
Refer to Appendix A.
2.4.2.2 Licensee's Basis for Requesting Relief.
The shutdown cooling system
. design does not provide for pump testing unless the reactor is in a cold shut-down mode and the system is being utilized for reactor residual heat removal.
There is no pump test loop.
2.4.2.3 Evaluation.
Relief should be granted from the monthly testing require-ments of Section XI for the shutdown cooling pumps.
The licensee has demonstrated that it is not possible to test these pumps when the plant is at power operation due to shutdown cooling system operation being limitad to RCS temperatures 03/15/85 11 MILLSTONE 1 IST SER
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-less than 350 F.
As an alternate test frequency, the licensee has proposed testing the shutdown cooling pumps during cold shutdown when plant temperature is less than 350 F.
2.4.2.4 Conclusion.
The licensee's proposed alternate test interval of cold shutdown.will provide sufficient inf*rmation to adequately monitor reactor shut
- down cooling pump degradation and meet Section XI requirements.
Based on tne considerations discussed above, the alternate testing proposed will provide reasonable assurance of pump function intended by the Code.
The relief thus granted will not endanger life or property or the common defense and security of the pLblic.
2.4.3 Relief Request R-18 The licensee has requested specific relief from the pump testing frequency requirements of Section XI for the control rod drive hydraulic pumps.
2.4.3.1 Code Requirement.
Refer to Appendix A.
2.4.3.2 Licensee's Basis for Requesting Relief.
One control rod drive pump is in service during normal power operation.
The pumps are rotated when pump suc-tion filters require changing (approximately three months).
Observation of these pumps has shown that frequent starts and stops of these high speed, high pressure pumps have led to pump deterioration.
As an alternate, the operating control rod drive' hydraulic pump will be tested monthly.
2.4.3.3 Evaluation.
Relief should be granted from the test frequency require-ments of Section XI.
This relief request is no longer. required since the licen-see is meeting the 1980 ASME Code requirement for quarterly pump testing.
2.4.3.4 Conclusion.
The licensee should test the control rod drive hydraulic pumps in accordance with requirements of Section XI of the 1980 ASME Code on at least a quarterly basis.
This can be accomplished under the licensee's current test schedule.
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3.>
VALVE TESTING PROGRAM The Millstone Nuclear Power Station, Unit 1, IST program submitted by Northeast Nuclear Ene.rgy Company (NNECO) was examined to vreify that Class 1, 2, and 3 safety-related valves included in the program are subjected to the periodic
-tests required by the >.SME Code,Section XI, and the NRC positions and guide-
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lines.
Except where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines summarized in Appendix A and Section 3.1 of this report.
Each NNECO basis for requesting ~ relief from the valve testing requirements, and the NRC staff's evaluation of that request, appears below and is grouped according to system and' valve category.
3.1 General Considerations 3.1.1 Exercising of Check Valves T'he ASME NRC's position was stated to the licensee that check valves whose safety function is to open are expected to be full-stroke exercised.
Since the disc position of a particular valve is not always observable, the NRC staff position is that verification of the maxir6um flow rate through the check valve identified in any of the plant's safety analyses would be an adequate demonstration of the full-stroke' requirement.
Any flow-rate less than this will be considered par-tial-stroke exercising unless it can be shown that the check valve's disc position at the lower flow rate would permit maximum required flow through the valve.
It is the NRC staff'.s position that this. reduced flow-rate method of demonstrating full-stroke capability is the only test that requires measurement of the differen-tial pressure across the valve.
3.1.2 Valves Identified for Cold Shutdown Exercising The ASME Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them quarterly during plant operation.
The licensee has specifically identified the applicable valves, and they are full-stroke exercised during cold shutdowns, thereby meeting the requirements of the ASME Code.
Since the licensee is< meeting the requirements of the ASME Code, it is 03/15/85 13 MILLSTONE 1 IST SER
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MII; not necessary to grant relief; however, it was verified that it 3 not practical to exercise these valves during power operation.
The NRC differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode.
That is,._for valves identified for testing at cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and during each refueling outage. However, when reli$f is granted to perform tests on a refueling outage-frequency,-testing is expected only during each refueling outage.
In addition, for extended refueling outages, tests being performed are expected to be maintained as closely as practical to the Code specified frequencies.
3.1.3 ' Conditions for Valve Testing During Cold Shutdowns Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:
Valve testing will commence as soon as possible, but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, after reaching cold shutdown conditions.
Valve testing will proceed in a normal manner until all testing is complete or the plant is
- ready to return to power.
A completion of all valve testing is not a prerequisite to return to power.
Any testing not completed by the end of the one cold shutdown will be performed during subsequent cold shutdowns, starting from the last test performed at the previous cold shutdown.
For planned cold shutdowns, where ample time is available for testing all the valves identified for the cold shutdown test frequency in the IST program, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
3.1.4 Category A Valve Leak Test Requiremeats for Containment Isolation Valves (CIVs)
All containment isolation valves that are Appendix J, Type C, leak tested must be included in the IST program as Category A or A/C valves.
The NRC has concluded that the applicable leak test procedures and requirements for containment isola-tion valves are determined by 10 CFR 50, Appendix J.
Relief from paragraphs 03/15/85 14 MILLSTONE 1 IST SER
m IWV-3421 through -3425 (1980 Edition through Winter 1980 Addenda) for contain-ment isolation valves presents no safety problem since the intent of these para-graphs is met by Appendix J requirements.
However, the licensee must comply with the an.alysis'of leakage _ rates and corrective requirements of IWV-3426 and 3427 respectively.
See paragraph 3.2.1.
~
A',1 CIV's that perform a pressure boundary isolation function (see paragraph 3.1.7) must also be individually leak rate tested as PIV's.
3.1.5 Application of Appendix-J Testing'to the IST Program The Appendix J review for this plant is separate from the IST program review.
However, the determinations made by the Appendix J review are directly applic-able to the IST program.
The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
3.1.6 Safety Related Valves This review was limited to valves that perform a safety related function Safety related valves are defined as those valves that are needed to mitigate the consequences of an accident ind/or to shut down the reactor and to maintain the reacter in a shutdown condition.
Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-Code class valves.
It should be noted that the licensee may have included valves whose functions are not safety related in their IST program as a deci-sion on their part to expand the scope of their program.
3.1.7 Valves Which Perform a Pres e Boundary Isolation Function Several safety related systems connected to the reactor coolant pressure boundary have derign pressures below the reactor coolant system operating pressure.
Redundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems protect the low pressure systems from pressures which exceed their design limit.
In this role, the valves perform a pressure isolation function.
It is necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity.
03/15/85 15 MILLSTONE 1 IST SER
JRAFI The followingLis.a list of valves:that perform'a pressure isolation function.
Low Pressure Coolant Injection 1-LP-11A, Loop A check valve
.1-LP-l'18, Loop B check valve-
.1-LP-10A,. Loop A isolation valv;
.1-LP-10B, Loop B isolation' valve Core Spray 1-CS-6A, Loop A check valve 1-C5-68, Loop B check valve 1-CS-5A, Loop A isolation valve 1-CS-58, Loop B isolation valve Shutdown Cooling 1-SD-5, Discharge isolation valve 1-SD-1, Suction isolation valve 1-SD-2A, Suction isolation valve 1-50-28, Suction isolation valve Limiting Conditions for Operation (LCO) must be included in the Technical Speci-fications which will require corrective action; i.e., shutdown or system isola-tion when the final approved leakage limits are not met.
Also, surveillance requirements which.will state the acceptable leak rate testing frequency shall be provided in the Technical Specifications.
(The licensee is referred to para-graph 3.4.3.2 of the GE Standard Technical Specifications, NUREG-0123, for guidance.)
The pressure-isolation valves (PIV's) noted above must be listed in the Technical Specifications.
Pressure isolation valves are required to be Category A or AC per IW-2000 and to meet the appropriate requirements of IW-3420 of Section XI of the ASME Code except as discussed below.
Periodic leakage testing on each PIV shall be accomplished each time the plant is placed in the cold shutdown condition for refueling, each time the plant is placed in the cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the preceding 9 months, each time any check valve may have moved
.03/15/85 16 MILLSTONE 1 IST SER
I
?
e il I
g from the fully closed position (i.e., any time the differential pressure across the valve is less than 100 psig), and prior to returning the valve to service after maintenance, repair, or replacemnt work is performed.
If all of the'following conditions exist, the PIV's may be leak rate tested at an interval no greater,than every 18 months:
(1) full closure of the PIV's is verified in the control room by direct monitoring position indicators, (2) inadvertent opening of the PIV's is prevented by interlocks which r? quire the primary system pressure to be below subsystem design pressure prior to opening, and (3) gross intersystem leakages into the core spray, low pressure coolant injection, and shutdown cooling, return and suction lines woald be detected by high pressure alarms' and increases in the suppression pool level.
The staffs present position is that leak rate limiting conditions for operation on each valve shall be no greater than one-half gallon per minute (gpm) for each nominal inch of valve size but no greater than 5 gpm for any particular valve.
The requirements of paragraph IWV-3427 of Section XI of the ASME code are to be strictly observed.
3.1.8 Test Frequency of Check Valves Tested at Cold Shutdowns The 1974 Edition through the Summer 1975 Addenda of the ASME B&PV Code,Section XI, states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three mont.hs for Category A and B valves and once every nine months for Category C check valves. It is the NRC's position that the 1974 Code is inconsistent in this regard and that Category C check valves should'thus be tested on the same schedule as Category A and B valves.
This discrepancy was corrected in the 1980 Edition of the ASME Code which is now invoked for this plant.
3.2 Generic Relief Requests 3.2.1 All Category A Containment Isolation Valves
' 03/15/85 11 MILLSTONE 1 IST SER t
DR+A1,
m 3.2.1.1 Relief Request V-9.
The licensee has requested specific relief for all containment isolation valves from the exercising and the leak-rate testing requirements of paragraphs IW-3420 of Section XI of the ASME Code and specifically from paragraphs IW-3426 and IW-3427(b) respectively).
The utility has proposed to perform exercise testing as per their Tech Specs and leak rate testing per their established procedures.
3.2.1.1.1 Code Requirements.
See Appendix A.
2.2.1.1.2 Licensee's Basis for Requesting Relief.
The containment isolation valve list consists of valves whose only safety function is containment isola-tion.
Present Technical Specifications require both an individual and an inte-grated leakage rate test for containment isolation valves and penetrations.
Technical Specifications also require repair and retest of any valve exceeding the leakage criteria.
NNEC0 states that these tests insure the leak-tightness of all containment isolation valves, in that they are tested under the condi-tions for which they are designed.
Exercising of these valves during normal plant operation could cause a loss of containment integrity and/or system function if a valve failed in a non-conservative position.
HNECO also requests relief from paragraph IW-3426 " Analysis of Leakage Rates" in that present rules for local leak rate testing of containment isolation valves provide analytical data for determining acceptance criteria, based on combined leakage of several valves.
Based on seat leakage data recorded to date, in connection with the containment leak rate test program, NNEC0 requests relief from paragraph IW-3427(b) in that no meaningful trends have been established.
3.2.1.1.3 Evaluation.
Relief should be granted for the leak-rate testing require-ments of Section XI of the Code for all containment isolation valves, that is, values which perform a containment isolation function only.
The licensee has demonstrated that the proposed alternate testing procedure of using 03/15/85 18 MILLSTONE 1 IST SER
DRXT their Tech Specs which have been prepared following Appendix J will be sufficient to demonstrate valve degradation.
However, although the current NRC position allows leak raili testing per Technical Specifications, the requirements of IW-3426
, and IW-342,7 must still be met.
See paragraph 3.1.4.
3.2.1.1.4 Conclusion.- The licensee's proposed alternate test program of leak-rate testing per their Technical Specifications will demonstrate proper valve leak tigh'1ess.
Based on the considerations discussed above, the' alternate testing proposed will provide reasonable assurance of operability intended by the Code and that1the relief thus granted will not endanger life or property or the common defense and security of the public.
~
Relief will not be granted from the requirements of IW-3426 and IW-3427.
These requirements must be observed the next time ne valves are tested and at all subsequent tests.
Trends are to be established and maintained for all con-tainnent isolation valves.
Containment isolation valves are to be exercised per Section XI requirements.
3.2.2 Fail-Safe Valves 3.2.2.1 Relief Request V-3.
The licensee indicates that fail-safe valves are
.to be tested by de-energizing the electrical supply or venting off the actuator air supply in order to duplicate loss of actuator power.
3.2.2.1.1.
Code Requirements.
See Appendix A.
3.2.2.1.2 Licensee's Basis For Requesting Relief.
Normal testing of these valves satisfies the Code Requirement of fail-safe testing.
These valves operate to the position required to fulfill their function by de-energizing the electrical power supply and/or venting off the actuator air supply which is essentially the same as loss of actuator power.
3.2.2.1.3 Evaluation.
The licensee's procedure satisfies the code requirement to demonstrate the' fail-safe feature of these valves by disabling the actuator.
03/15/85 19 MILLSTONE 1 IST SER
DRAF~
9 3.2.2.1.4 Conclusion.
The licensee's procedure satisfies-the ASME code require-nent to demonstrate the fail safe capabilities of the valves. Therefore it is unnecessary to grant relief.
' 3.2.3 Solenoid and Rapid Acting Air Operated Valves
- 3. 2. 3.1 Relief. Request V -12.
The licensee has requested relief from measuring stroke time for "various solenoid and rapid acting air operated valves".
The licensee proposes that " valve stroke times shall be considered acceptable, pro-vided that the valve actuates promptly upon signal to operate and actuates less than the. maximum required stroke time."
3.2.3.1.1 Code Requirements.
Refer to Appendix A.
3.2.3.1.2 Licensee's Basis For Requesting Relief -- These valves change position less.than 5 seconds and are difficult to accurately time.
Random errors in timing such fast acting valves yields erroneous test results causing unnecessary retesting.
3.2.3.1.3 Evaluation.
This relief request is considered vague with respect to which valves are included and4also with respect to the phrase " actuates promptly" in the licensee's request.
Article IW-3413(b) of Section XI,1980 Edition states:
"(b)The stroke time of all power, operated valves shall be measured to the nearest second, for stroke times 10 see or less, or 10% of the specified limiting stroke time for full-stroke times longer than 10 see whenever such a valve is full-stroke tested."
The above requirement is not unreasonable and should be complied with.
Relief should be sought for individual valves where the requirement cannot be met.
The staff considers that an error of 1 second in the time measurement is acceptable.
03/15/65.
DRAF" 3.2.3.1.4 Conclusion.
Relief is denied to test these valves as the licensee proposes in relief request V-12.
The ASME code requirement is to be complied with.
Stroke time is to be measured to the nearest second within an error range
.of one seco,nd.
3.3 Feedwat'er' Coolant Injection System 3.3.1 Category B Valves
- 3. 3.1.1 Relief Request V-10.
The licensee has requested specific relief from the exercising requirements of Section XI for valves 1-FW-14A, 148, and 14C, feed pump minimum flow control valves, and proposed to full stroke exercise and test the fail position during cold shutdowns.
3.3.1.1.1 ' Code Requirements.
Refer to Appendix A.
3.3.1.1.2 Licensee's Basis for Requesting Relief.
These valves are opened only during starting of the reactor feedwater pumps or partially open at low flow conditions to prevent overheating of the pumps.
They do not receive any safety related actuating signal from FWCI.
Stroke time is not an appropriate refer-ence parameter for valves serving this function.
Exercising these valves during pcwer operation disrupts the balanced feedwater flow to the reactor vessel.
3.3.1.1.3 Evaluation.
Relief should be granted from the exercising require-ments of Section XI for valves 1-FW-14A, 148, and 14C.
Testing these valves during normal operation will adversely affect plant operations.
3.3.1.1.4 Conclusion.
The licensee has provided adequate justification for granting relief for the exercising requirements of Section XI for valves 1-FW-14A, 148, and 14C.
Therefore, these valves will be exercised at cold shutdowns.
Relief thus granted will not endanger life or property or the common defense and security of the public.
3.3.1.2 Relief Request V-5.
The licensee has requested specific relief from the exercising requriements of Section XI for valves 1-MW-7 and 1-CN-67, con-l l
l 03/15/85 21 MILLSTONE 1 IST SER
gPM
~
denser hotwell level control valves.
The licensee states that these valves are e
adequately exercised in the normal course of plant operation and require no further exercise.
3.3.1.2.1 Code Requ'irement.
Refer to Appendix A.
l l
3.3.1.2.2 Licensee Basis for Requesting Relief.
These valves modulate.
continuously to maintain the condenser hotwell level in an operating band.
They have no safety function or receive any safety related actuating signal from FWCI.
Stroke time is not an appropriate reference parameter for valves of this design.
Proper valve operation is verified through normal ceration and satisfies the exercising requirements of the code as defined by Article IWV-3414, y
" Valves in Regular Use".
3.3.1.2.3 Evaluation.
Since these valves are in the IST program the licensee acknowledges that they fulfill a safety function.
The licensee has not furnished adequate justification for not full stroke exercising these valves in accordance with the ASME Code because it has not been demonstrated that the exercising require-i
.ments of the code are fulfilled by normal plant operation.
3.3.1.2.4 Conclusion.
The licensee must exercise valves IMW-7 and 1CN-67, in accordance with Section XI of the ASME code, every 3 months.
3.3.2 Category C Valves 1
3.3.2.1 Relief Request V-6.
The licensee has requested specific relief from the exercising requirements of Section XI for valves 1-FW-2A, 28, and 2C, feed pump discharge check valves, and proposed to exercise them during pump startup l
when rotating each pump into service.
L 3.3.2.1.1 Code Requirement.
Refer to Appendix A.
p r
3.3.2.1.2 Licensee's Basis for Requesting Relief.
Two of the three Reactor Feed Pumps are running during normal reactor power operation.
Exercising these l
03/15/85 22 MILLSTONE 1 IST SER i'.
DRAFT r
valves requires cycling each pump which will result in feedwater pressure and 3
flow fluctuations which may place the plant in an unstable condition.
The license,e proposes alternative testing as follows:
" Verify that the check valves open upon pump starting during reactor startup.at cold shutdown and during pump rotation.
Valve closure is verified by the P; ant Equipment Operators during routine operator rounds by observation or suction and discharge pressures and reverse rotation of an idle pumps' shaft.
(The NRC assumes that the tests will fully verify full stroke operation of i
these valves.)
3.3.2.1.3 Evaluation.
Relief should be granted from the exercising requirements of Section XI for valves 1-FW-2A, 28, and 2C.
The licensee has provided an adequate technical justification for not full stroke exercising these valves to the Section XI schedule requirements.
Full stroke verification, as the licensee proposes, is acceptable.
3.3.2.1.4 Conclusion.
The licensee has provided adequate technical justifi-cation for not full-stroke exercising these valves per the ASME Code Section XI schedule requirements.
Relief thus granted will not endanger life or property or the common defense and securit'y of the public.
3.3.3 Cateogry A/C Valves 3.3.3.1 Relief Request V-8.
The licensee has requested specific relief from the exercising requirements of Section XI for valves 1-FW-9A, 98, 10A and 10B feedwater system containment isolation check valves.
The licensee proposes to verify these valves are open upon reactor startup from cold shutdown and to verify closure during refueling outages.
3.3.3.1.1 Code Requirement.
Refer to Appendix A.
3.3.3.1.2 Licensee's Basis for Requesting Relief.
These valves remain open during normal power operation, supplying feedwater to the reactor pressure l
03/15/85 23 MILLSTONE 1 IST SER L
DRIEI vessel.
Exercising these valves requires disruption of the feedwater to the reactor vessel which cannot be done at power.
3.3.3.1.3, Evaluation.
The licensee has demonstrated that these valves cannot be exercised every 3 months without disrupting reactor operation.
The licensee's proposal. to verify that the check vanes open upon reactor startup from cold shutdown by cbservation of feedwater flow and verify that the valves are fully closed at refuel outages during performance of Appendix J type C Local Leak Rate Testing is acceptable.
3.3.3.1.4 Conclusion.
The licensee has provided acceptable justification for not exercising valves 1-FW-9A, 98, 10A and 10B in accordance with Section-XI.
Therefore, relief is granted to verify opening and closing of these valves as outlined above.
Relief thus gratned will not endanger life or property or the common defense and security of the public.
3.4 Control Rod Drive Hydraulic System 3.4.1 Category B Valves 3.4.1.1 Relief Request V-11.
The licensee has requested specific relief from exercising requirements of Section XI for valves 302-19A, 19B, 19C, 19D and 302-20A & 208, air solenoid valves to CRD hydraulic system, and proposed exer-cising these valves during refueling outages.
(flote:
valves 10C and 19D were added to the relief request in the licensee's submittal dated Jan 16, 1985.
These valves do not appear on the sketches included in the licensee's IST program submittal).
3.4.1.1.1 Code Requirement.
Refer to Appendix A.
3.4.1.1.2 Licensee's Basis for Requesting Relief.
These valves are solenoid operated and thus cannot be part stroked.
Full stroking could cause an unsche-
'duled reactor trip.
These valves are operated 145 times each refueling as part of control rod testing.
03/15/85 24 MILLST0fiE 1 IST SER
e
~
)RAF-3.4.1.1.3 Evaluation.
Relief should be granted from the exercising require-ments of Section XI for valves 302-19A, 19B, 19C, 190 and 302-20A & 20B.
The o
licensee has demonstrated that testing during power operation is not possible, because-it,could initiate an unscheduled reactor trip.
The utility has proposed an alternate. test interval of testing during each refueling outage.
Relief should not belgranted for the proposed test interval.
The licensee has not Lenished information tnat will justify a test interval any longer than cold shutdown.
3.4.1.1.4 Conclusion.
Relief will be granted from the Section XI exercising requirements for valves 302-19A, 198, 19C, 190 and 302-20A & 208. The licensee's proposed alternate testing is for a testing interval of each refueling outage.
- The licensee has not provided sufficient technical justification for not exercising these valves at each cold shutdown.
Therefore, the relief will not be granted for the period of testing proposed by the licensee.. Based on the considerations discussed above, and assuming that the licensee will perform testing at each cold shutdown, such alternate testing will provide reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.4.1.2 Relief Request V-11.
Th'e licensee has requested specific relief from exercising requirements of_Section XI for valves 305-126 and 127, contral valves for scram operation of control rods and valves 305-117 and 118, scram solenoid valves (145 of each), and proposed full stroke exercising during refueling uutages.
3.4.1.2.1 Control Requirement.
Refer to Appendix A.
3.4.1.2.2 Licensee's Basis for Requesting Relief.
These valves cannot be part stroked because of their construction.
They cannot be exercised at cold shutdown because of system interlocks.
The cold shutdown mode switch prohibits the with-drawal of control rods.
03/15/85 25 MILLSTONE 1 IST SER
t7"
'hD #N 1:
3.4.1.2.3 Evaluation.
Relief should be granted from the exercising require.
ments of Section XI for valves 305-126 and 127 and valves 308-117 and 118.
The licensee has demonstrated that it is not possible to test these valves during operation or cold shutdown due to design.
Therefore, the only time interval available is.during refueling outage.
3.4.1.2.4 Conclusion.
Exercising valves 305-126 and 127 and valves 305-117 and 116 each refueling outage will demonstrate valve operability.
Based on the considerations discussed above, the alternate testing proposed will provide reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.4.2 Category C Valves 3.4.2.1 Relief Request V-11.
The licensee has requested specifi,c relief from the exercising requirements of Section XI for valves 305-114, scram discharge header checks, and 305-115, scram accumulator charging header checks (145 of each), and proposed to full-stroke exercise during refueling outages.
3.4.2.1.1 Code Requirement.
Refer to Appendix A.
3.4.2.1.2 Licensee's Basis for Requesting Relief.
These valves cannot be partial nrake exercised because of their construction.
They cannot be exercised at ccid shutdown because of system interlocks.
The cold shutdown mode switch prohibits the withdrawal of control rods.
3.4.2.1.3 Evaluation.
Relief should be granted from the exercising require-ments of Section XI for valves 305-114 and 115.
The licensee has demonstrated that is is not possible to test these valves during power operation or cold shutdown due to design.
Therefore, the only time interval available for testing is during refueling outages.
3.4.2.1.4 Conclusion.
Exercising valves 305-114 and 115 each refueling outage will demonstrate proper valve function.
Based on the considerations discussed 03/15/85 26 MILLSTONE 1 IST SER
m.
m I
l.
above, the alternate testing proposed will provide reasonable assurance of valve r
operability intended by the Code.
The relief thus granted will not endanger life or property or the common defense and security of the public.
3.4.2.2 Relief Request V-11.
The licensee has requested specific relief from the exercising requirerents of Section XI for valves 301-122A, B and C, scram
~
pilot air header check valves.
The licensee proposes to exercise these valves at refueling outages.
2 3.4.2.2.1 Coda Requirements.
Refer to Appendix A.
3.4.2.2.2 Licensee's Basis For Requesting Relief.
These valves cannot be operated during power operation without causing a reactor scram.
3.4.2.2.3 Evaluation.
Relief should be granted from the exercising requirements of Section XI of the ASME code for valves 301-122A, B, ard C.
The licensee has demonstrated that it is not possible to exercise these valves when the plant is operating.
Relief should not be granted for the proposed test internal.
The licensee has not furnished any information that will justify a test interval any longer than cold shutdown.
3'.4.2.2.4 Conclusion.
Relief will be granted from the Section XI exercising requirements for valves 301-122A, B and C.
The licensee has not provided suffi-cier.t technical justification for not exercising tiese valves at each cold shut-down.
Therefore the relief will not be granted fc< the period of testing proposed by the licensee.
Based on the considerations discussed above, and assuming that the licensee will perform testing at each cold shutdown, such alternate testing will provide reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public, 3.5 Core Spray System 3.5.1 Category C Valves 03/15/85 27 MILLSTONE 1 IST SER
J)RAr"i
- !~
.D
.3.5.1.1 Relief Request V-17.
The licensee has requested specific relief from the exercising requirements of Section XI.for valves 1-CS-6A and 68, inside containment check valves, and proposed-alternate testing at each refueling outage.
3.5.1.1.1 Code Requirement.
Refer to Appendix A
~
3.5.1.1.2 Licensee's Basis for Requesting Relief.
Exercising these valves requires injecting Core Spray Water into the vessel.
This is not possible at reactor power or cold shutdown because of pressure differentials and the high volume flow rates.
3.5.1.1.3 Evaluation. -Relief should be granted from the exercising require-cents of Section XI for valves 1-CS-6A and 6B.
The licensee has demonstrated it is not possible to test these valves at power operation because of the differ-ential pressure between the core spray pumps an'd the reactor coolant system.
If
- the full flow stroke exercising was attempted during cold shutdown, a low temper-ature over pressurization of the RCS could result because of the large flow rate required to exercise these valves.
The licensee proposes to full-stroke exercise these valves during refueling outages, when the reactor vessel head has been removed and the refueling water c'avity is available to provide the required expansion volume for the high flow rate.
3.E.1.1.4 Conclusion.
Exercising valves 1-CS-6A and 6B during each refueling outage will demonstrate proper valve function.
Based on the considerations discussed above the alternate testing. proposed will provide reasonable assur-ante of valve operability intended by the Code.
The relief thus granted will not endanger life or property or the common defense and security of the public.
3.6 Low Pressure Coolant Injection System 3.6.1 Category C Valves 3.6.1.1 Relief Request V-15 and V-16.
The licensee has requested specific relief from the exercising requirements of Section XI for valve 1-LP-11A and 03/15/85 28 MILLSTONE 1 IST SER L
r j
11-B, low pressure coolant injection inside containment check valves, and proposed to full-flow stroke exercise these valve at each refueling outage.
3.6.1.1.1. Code Requirement.
Refer to Appendix A.
3.6.1.1.2 Licensee's Sasis for Requesting Relief.
There is no design provision" for manually exercising this valve.
Stroking with system flow requires that water be pumped into the reactor vessel.
This is not possible at power because of pressure differences.
3.6.1.1.3 Evaluation.
Relief should.be granted from the exercising require-ments of Section XI for valve 1-LP-11A and 11-B.
The licensee has demonstrated it is not possible to test these valves at power. operation because of the dif-ferential pressure between the low pressure coolant injection pumps and the reactor coolant system.
If the full flow-stroke exercising was attempted during cold shutdown, a low temperature over pressurization of the RCS could result because of the large flow rate required to exercise this valve.
The licensee proposes to full-stroke exercise these valves during each refueling outage, when the reactor vessel head has been removed and the refueling water cavity is available to provide the required expansion volume for the high flow rate, 3.6.1.1.4 Conclusion.
Exercising valve 1-LP-11A and llB during each refueling outage will demonstrate proper valve operability. _ Based on the considerations discussed above, the alternate testing proposed will provide reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.7 Standby Liquid Control System (SLCS) 3.7.1 Category A/C Valves 3.7.1.1 Relief Request V-18.
The licensee has requested specific relief from the exercising requirements of Section XI for the combined discharge injection check valves 1-SL-7 & 1-SL-8 and proposes to exercise these valves during refueling outages during a test of the whole SLCS.
03/15/85 29 MILLSTONE 1 IST SER
n[1CI l 1).
O n
3.~7.1.1.1 Code Requirements.
Refer to Appendix A.
3.7.1.1.2 Licensee's Basis For Requesting Relief.
There is no provision for manually st,roking these valves.
Hydraulic stroking. requires pumping water into the reactor vessel and the firing of a squib valve.
3.7.1.1.3 Evaluation.
Relief should be granted from the exercising requirements of Section XI for valves 1-SL-7 and 1-SL-8.
It is not practical to exercise thes, valves except at refueling outages.
3.7.1.1.4 Conclusion.
Thelicensee'spropohaltoexercisevalves1-SL-7and 1-SL-8 at refueling outages is acceptable and will demonstrate proper ulve function.
Relief-thus granted will not endanger life or property or the common defense and security of.the public.
- 3. 8 Isolation Condenser 3.8.1 Category C Valves
- 3.8.1.1 Relief Request V-21.
The-licensee has requested specific relisf from the exercising requirements of 56ction XI for valve 1-IC-11, reverse flow check valve in' makeup line to isolation condenser, and proposed to exercise'this valve during refueling outages.
3.8.1.1.1 Code. Requirement.
Refer to Appendix A.
.3.8.1.1.2 Licensee's Basis for Requsstin'g Relief.
Exercising this valve requires filling the shell side of the condenser which may cause the level to increase above the normal operating band.
This canaot be done except at reac-tor refuelings when it is possible to drain the.shell side i.o a low level and refill to.the operating band.
Because of the complexity of this test, NNECo
^
prefers to attempt this during reactor refueling.
3.8.1.1.3 Evaluation.
Relief should be granted from the exercising require-
.ments of Section XI for valve 1-IC-11.
The licensee has demonstrated that it
-03/15/85 30 MILLSTONE 1 IST SER 4
I i
t is not practical to exercise this valve during power operation or cold shut-down.
The licensee has proposed an alternate test interval of refueling outages.
3.8.1.1.4,onclusion.
The proposed alternate exercising interval of refueling C
outages will demonstrate proper valve function.
Based on the considerations dis-cussed above,-the alternate testing proposed will provide reasonable assurance of vC ve function intended by the Code.
The relief thus granted will not endanger life or property or the common defense and security of the public.
3.9 Service Water System 3.9.1 Category B Valves 3.9.1.1 Relief Request V-22.
The licensee has requested specific relief from the exercising requirements of Section XI for valve 1-SW-9, service water stop valve to turbine building closed cooling water heat exchangers, and proposed to exercise this valve during refueling outages.
3.9.1.1.1 Code Requirement.
Refer to Appendix A.
3.9.1.1.2 Licensee's Basis for Requesting Relief.
This valve is in the flow path'of service water to the Turbine Building closed cooliig water heat exchan-gers.
If this valve' fails to reopen after exercising, the TBCCW heat exchangers would not provide essential cooling for many balance of plant components, such as. generator stator windings, hydrogen coolers, off gas blowers, etc.
The remote position indicating test is done when the valve is exercised.
- 3. 9.1.1. 3 - Evaluation.
Relief should be granted from the quarterly exercising requirements of Section XI for valve 1-SW-9.
The licensee has demonstrated that it is not possible to exercise this valve while at power operation without causing a loss of cooling water to balance of plant components. However, a test interval
.any longer than cold shutdown is not justified.
03/15/85 31 MILLSTONE 1 IST SER
l 3.9.1.1.4 ' Conclusion.. Relief should~be granted from the quarterly exercising requirements of'Section XI for valve 1-SW-9.
However, a time interval longer than cold shutdown is not justified.
Based on the considerations discussed above relie,f will be granted for a test interval not exceeding each cold shut-down.
Relief thus granted will not endanger life or property or the common
~
defense and security.of the public.
4 3.10 Reactor Building Closed Cooling Water System 3.10.1 Category B and C Valves.
3.10.1.1 Relief Request V-25.
The licensee has requested specific relief from the exercising requirements of Section XI for Category C check valve 1-RC-6 and Category B valve 1-RC-15, drywell header inlet and outlet valves, and proposed to test these valves at each refueling outage.
3.10.1.1.1 Code Requirement.
Refer to Appendix A.
3.10.1.1.2 Licensee's Basis for Requesting Relief.
Exercising these valves disrupts cooling water to the recirculation pump motors and may cause over-heating.
Failure of the valves to open during operability testing will also cause a loss of cooling water to the drywell air coolers with resultant shut-down due to high drywell ambient temperature.
3.10.1.1.3 Evaluation.
The licensee has demonstrated that is is not practical to exercise these valves during plant. operation.
However, a test interval of every refueling outage is not justified.
Also, these valves are containment isolation valves.
They should be classified as A/C (1-RC-6) and A (1-RC-15),
and Appendix J leak rate tested accordingly.
3.10.1.1.4 Conclusion.
Valves 1-RC-6 and 1-RC-15 must be categorized as Cate-gory A/C and A respectively, and leak-rate tested according to Appendix J of 10 CFR 50.
Based on the considerations discussed above, relief will be granted to exercise these values at an interval not exceeding each cold shutdown.
Relief 03/15/85 32 MILLSTONE 1 IST SER
e s
j
.I thus granted will not endanger life or property or the common defense and safety of the public.
3.10.1.2 0,riginal Relief Request. The licensee originally requested specific relief from.the exercising requirements of Section XI for Category B valve 1-RC-39, stop valve in RBCCW sy, stem discharge from shutdown heat exchangers, and proposed
~
to exercise this valve during cold shutdown.
In the latest IST submittal (January 1985) this. valve was omitted from the program.
3.10.1'.2.1. Code Requirement. Refer to Appendix A.
3.10.1.2.2 Licensee's Original Basis for Requesting Relief.
The shutdown heat exchanger is " laid up" between operations and is operated as necessary to control temperature at specified conditions during cold shutdowns.
3.10.1.2.3 Evaluation.
The licensee originally requested relief from the exer-cising requirements of Section XI for valve 1-RC-39 on the basis that the shut-down heat exchanger is " laid up" between operations.
The licensee has not provided sufficient technical justification for granting relief and, therefore, relief should not be granted unless the ut ;11ty provides adequate information demon-strating no compromise in safety'for not meeting the requirements of Section XI.
The licensee has provided no explanai. ion for dropping this valve from the IST program.
3.10.1.2.4 Conclusion.
Relief will not be granted and valve 1-RC-39 must be exercised per Section XI.
The licensee has not provided sufficient technical justification for granting relief or for omitting this valve from the program.
3.11 Shutdown Cooling System 3.11.1 Category A, B and C Valves
. 03/15/85' 33 MILLSTONE 1 IST SER
kN 3.11.1.1 Relief Request V-24.
The licensee has requested specific relief from.
the exercising requirements of Section XI for Category A valves 1-SD-1, 2A, 28,
-3A, 3B, 4A, 4B, and 5, shutdown cooling isolation valves, and proposed to exercise these valve,s~during reactor refueling.
3.11.1.1.1 Code Requirement.
Refer'to Appendix A.
~
~
3.11.1.1.2 Licensee's Basis for Requesting Relief.
These valves are normally closed during reactor pwoer operation interlocks prevent opening the isolation valves when reactor reciruciation loop temperature is greater than 350 degrees.
3.11.1.1.3 Evaluation.
Relief should be granted from the quarterly exercising requirements of Section XI for valve's 1-50-1, 2A, 2B, 3A, 3B and 5.
The licensee has demonstrated that it is not possible to exercise these valves during power operation since they isolate the shutdown cooling from the RCS, when RCS temper-ature is above 350+F.
However, the licensee has not given a suff,icient technical justification for not exercising 1-SD-4A and 4B per Section XI, therefore, relief should not be granted for these valves.
Further-the licensee has not provided sufficient justification for testing at refueling outages only.
3.11.1.1.4 Conclusion.
The lice'nsee should exercise valves 1SD-1, 2A, 2B, 3A, 3B, and 5 at cold shutdown.
Valves 4A and 4B should be exercised in accordance with Section XI requirements.
3.12 Main Steam System 3.12.1 Category C Valves 3.12.1.1 -Relief Request V-20.
The licensee has requested specific relief from the the exercising requirements of Section XI for the main steam line relief valves 1MS-107A through 107F,1-MS-111A through 111F and 1-MS-112A through 112F.
The licensee proposes to exercise these valves at refueling outages.
3.12.1.1.1 Code Requirements.
Refer to Appendix A.
-03/15/85 34 MILLSTONE 1 IST SER
JRAR 3.12.'1.1.2 Licensee's Basis For Requesting Relief.
These valves can only be exercised manually by hand when access to the containment is available.
3.12.1.1.3 Evaluation.
The licensee has furnished no reason for not exercising
-these valves at cold shutdown.
These valves were added to the program in the licensee's submittal of January 1985 along with the relief request.
3.12.1.1.4 Conclusion.
The licensee must exercise these valves at each cold shutdown, which will comply with code requirements.
3.13 Emergency Service Water System 3.13.1 Category B Valves 3.13.1.1 Relief Request V-23.
The licensee has requested specific relief from the exercising and stroke timing requirements of Section XI for heat exchanger outlet throttle valves 1-LPC-4 and 4B and proposes to part-stroke' test these valves when the emergency service water pumps are tested.
3.13.1.1.1 Code Requirements.
Refer to Appendix A.
3.13.1.1.2 Licensee's Basis For Requesting Relief.
Actuating power for these valves is available only when an Emergency Service Water Pump is started.
Fully opening the throttle valve causes the pump to run-out and may result in pu:tp
~
d r. age.
3.13.1.1.3 Evaluation.
The licensee's basis does not provide sufficient justifi-
. cation.
Relief should not be granted from the code requirement to full stroke exercise.
These valves and measure stroke timing.
3.13.1.1.4 Conclusion.
Relief will not be granted from the exercising and stroke timing requirements of Section XI of the ASME code for valves 1-LPC-4A and 48.
3.14 Standby Gas Treatment System 03/15/85 35 MILLSTONE 1 IST SER
DRAE.
-3.14.1 Category B Valves 3.14.1.1 Reli.af Reauest V-28.
The licensee has requested' specific relief from the exercis,ing requirements of Section XI for all standby gas treatment system valves. The. licensee indicates that these are valves in regular use and, as such, meet the exercise requirements'of ASME Code paragraph IWV-3414.
~
3.14.1.1.1 Code Requirements.
Refer To Appendix A 3.14.1.1.2 Licensee's Basis for Requesting Relief -- These valves operate auto-matically during the start sequence of the standby gas treatment systems.
In-dividual stroking of these valves is not possible.
Observation of their proper operation during starting of the standby gas systems satisfies the exercising requirements of the Code.
(
Reference:
Article IWV-3414, Valves in Regular Use.)
3.14.1.1.3 Evaluation.
The licensee requests relief from individually exer-cising and strok timing these valves.
They will be exercised and stroked timed as'a group at least every three months.
This is acceptable to the staff because these are solenoid operated valves whose stroke time is very small and non-operation of a particular-valve will be detected immediately.
4
-3.14.1.1'4 Conclusion.
Relief will be granted from the individual exercise requirements of.Section XI for the standby gas treatment system valves.
Relief thus granted will not endanger life or property of the common defense and of the public.
'3.15 Head Spray Valves 3.15.1 Category A and A/C Valves 3.15.1.1 Relief Request V-29.
The licensee has requested specific relief from the exercising requirements of Section XI for head spray and outer containment isolation valves 1-HS-4 and 1-HS-5 and proposes to exercise these valves at refueling outages.
3.15.1.1.1. Code Requirements.
Refer to Appendix A 03/15/85 36 MILLSTONE 1 IST SER
7,<
4 3.15.1.1.2 Licensee's Basis for Requesting Relief. These valves are normally closed and are opened to admit water to cool the reactor vessel head and upper reactor internals before removal of the closure head at refuel outages.
~
3.15.1.1.3 Evaluation.
These valves remain closed (their safety related position) during plant.cperation.
Exercising these valves at intervals as long as refueling outages causes no safety concern and therefore relief should be granted.
3.15.1.1.4 Conclusion.
Relief will be granted to exercise valves 1-HS-4 and 5 at refueling outages.
Relief thus granted will not endanger life or property or the common defense and security of the public.
3.15 Reactor Coolant Sample Valves 3.16.1 Category A Valves 3.16.1.1 Relief Request V32.
The licensee has requested specific relief from exercising requirements of Section XI for reactor coolant sample valves 1-RR-37 and'l-RR-38 and proposes to exercise these valves to verify function every refueling cutage.
3.16.1.1.1 Code Requirements.
Refer to Appendix A 3.16.1.1.2 Licensee's Basis for Requesting Relief.
These valves remain closed during all modes of operation and are.cpened as an alternate coolant sample flow path when the normal clean-up system sample line is out of service which occurs periodically during reactor refueling.
Failure of these valves to close during operability testing results in a loss of containment isolation.
3.16.1.1.3 Evaluation.
This valves remain closed (their safety related
-portion) during reactor operation.
There is no reason to require that they be tested at an interval shorter than each refueling outage and therefore relief should be granted.
03/04/85 37 Millstone 1 IST SER
=
3 [-
,J i \\
i 3.16.1.1.4 Conclusion.
Relief will be granted to exercise valves 1-RR-37 and
. 38 at each refu'eling outage to verify function.
Relief thus granted will not I
. endanger life or property or the common defense and security of the public.
9 4
i B
4 f
o 03/04/85 38 Millstone 1 IST SER
o -
TABLE A R
2 ALLOWABLE RANGES OF VIBRATION VELOCITY FOR PllMP TESTING PER SilBSECTI0ft I\\lP k
Test Band No.
Test Quantity Acceptable Range Alert Range Required Act. ion Range 1
V When 0$Vr 10.05 in/sec 0 to.075 in/sec 0.075 to.1.'in/sec
>0.1 in/sec t
y 2
V When 0.05 in/sec 0 to.15 in/sec 0.15 to 0.2 in/sec
>0.2 in/sec t
$Vr 1 1 in/sec 2
3 V When. 1 in/sec 0 to 0.2 in/sec 0.2 to 0.25 in/sec
>0.25 in/sec t
$Vr 1 15 in/sec 3
4 V When.15_in/sec 0 to 0.285 in/sec 0.285 to 0.314 in/sec
>0.314 in/sec t
$Vr 5 25 in/sec 4
ww Definitions:
V = Reference velocity measurement (in/sec filtered peak) y[=Surveillancetestvelocitymeasurement(in/secfilteredpeak)
Note:
The frequency response range of.the vibration measuring tranducers and their readout system shall be from one-half minimum pump shaft rotational ~ speed to speed to at least 1,000 liertz.
(This table refers to paragraph 2.1.1.4 of this SER) x 1'
G B
O K;
33 tw 4
,, c p.
BA'T APPENDIX A~
lJ
~ CODE REQUIREMENTS ---VALVES.
~
ASME Code,Section XI, Subsection IWV,.1980 Edition including the 1980 Winter Addenda.
~
' 2.
-CODE REQUIREMENTS -- PUMPS.
ASMEiCode,.Section XI, Subsection-IWP, 1980 Edition including 1980 Winter Addenda.
h A
g l-c L.
I:
03/04/85 40 Millstone 1 IST SER e
$I L i APPENDIX B The following are Category A, B, and C valves that meet the exercising requirement.s of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation.
These valves are specifically
~
identified by',the owne; and-are full-stroke exercised during cold shutdowns and refueling outages.
Testing these valves during power operation is not possible due to the. valve type and location or system design.
These valves should not be exercised during power operation.
These valves are listed below and grouped according to the system in which they are located.
1.
FEEDWATER COOLANT INJECTION SYSTEM-1.1 Category B Valves 1-CN-58, steam jet air ejector minimum flow control valve, c,annot be exercised or fail position tested during power operation.
Operation of this valve during power operation could lead to a condensate flow disruption.
This valve will be exercised and fail position tested during cold shutdown conditions.
See Relief Request V-2.
1-CN-701, cooling water supply to off gas condensers, cannot be fail position tested or exercised during power operation.
Operation of this valve while at power could lead to a decrease in condenser vacuum.
This valve will be t'sted and exercised at cold shutdown.
See Relief Request V-4.
e 1-FW-4A, 48, 4C, SA, 5B, and SC, feedwater control and regulating valves, cannot be exercised while at power operation.
Operation of these valves could cause reactor vessel level fluctuations and possibly an inadvertent reactor trip.
These valves will be exercised at cold shutdown.
See Relief Request V-7.
1.2 Category C Valves 1-CN-2A, 28, 2C, 1-CN-30A, 308, and 30C, condensate and condensate booster pumps discharge check valves, can not be exercised during power operation.
03/04/85 41 Millstone 1 IST SER s
L__
Operation of these valves during power operation could induce flow transients in the feedwater and condensate systems. These valves will be full flow-stroke exercised at cold shutdown.
See Relief Request V-1.
r 2.
REACTOR RECIRCULATION SYSTEM 2.'1 Cateoory B Valves Valves 1-RR-2A, 1-RR-2B and 1-RR-5A cannot be exercise tested without securing the reactor recirculation pumps which cannot be done during power operation.
These valves will be full flow tested at cold shutdown.
See relief request V-26.
3.
CONTROL R0D DRIVE HYDRA:JLIC SYSTEM 3.1 Cateoory B and C Valves Control rod drive hydraulic system valves 305-120, 121, 122, 123, 137 and 138 are exercised weekly during normal plant operation.
See relief request V-13.
3.2 ' Category A Valves control rod drive hydraulic system valves 1-SDV-1N, 2N,15, 25, 3N, 4N, 35 and 45 cannot be exercised during power operation.
These valves will be exercised via a test circuit every 3 months and exercised for normal operation during cold shutdown by initiating a scram.
See relief request V-14.
4.
CONTAINMENT ISOLATION VALVES 4.1 Category A and A/C Valves 1-MS-5 and 6, main steam line drains, will not be exercised during power operation.
These valves are passive and exercising is not necessary during power operation.
These valves will be exercised during cold shutdown.
See licensee's Relief Request V-19.
03/04/85 42 Millstone 1 IST SER
c:
3R/R S.
REACTOR WATER CLEAN-UP SYSTEM 5.1 Category A Valves
' Auxiliary clean-up pump suction valve 1-CU-5 will not be exercised during power operation.
This, valve is normally closed during power-operation (safety position) and opening the valve at power oper,ation causes pressure and flow-
' transients.
The~ valves will be exercised at cold shutdown.
See relief request
.V-27.
Bypass isolation valve 1-CU-2 will not be exercised during power operation because this is a containment isolation valve.
This valve will be exercised at
. ccid shutdown.
See relief request V-31.
6.'
DRYWELL' NITROGEN COMPRESSOR 6.1 Category B Valve Drywell nitrogen compressor /back-up nitrogen supply discharge isolation valve 1-AC-50 cannot be exercised during power operations because this valve
.1s required 1or. operation of safsty related valves within containment.
This-valve will be exercised at cold shutdown.
See' relief request V-30.
'03/04/85 43 Millstone 1 IST SER
g 3 RAFT APPENDIX C The P& ids listed below were used during the course of this review.
System-P&ID Revision
~
IWB. Examination Boundary D'iagram 25202-26032 SH 1 2
Condensate and FWCI
-25202-26032 SH 2 3
Fuel Pool Cooling and Filtering-25202-26032 SH 3 1
CRD Hydraulic and Head' Cooling _ Systems 25202-26032 SH 4 4
-LPCI Containment Cooling System
'25202-26032 SH 5 4
Turbine Building Secondary Cooling 25202-26032 SH 6 Water System Standby Liquid Control System 25202-26032 SH 7 1
Isolation Condenser 25202-26032 SH 8 1
Core Spray Cooling System 25202-26032 SH 9 2
' Service Water System 25202-26032 SH 10 1
~ Reactor Building Closed Cooling 25202-26032 SH 11 2-Water System g
? Standby Gas and Atmosphere Control System 25202-26032 SH 12 2
l -
' Shutdown Cooling System 25202-26032 SH 13 1
I i
h.'
03/04/85 44 Millstone 1 IST SER u
r:
APPENDIX D
SUMMARY
r 1.'
In a relief requett (Item 2.1.1), the licensee has proposed to use a
~
vibration signature program to monitor pump condition instead of measuring displaceme~nt vibration amplitude as per Section XI.
Relief was not granted.
The licensee's basis did not include acceptable, alert and action ranges for vibration' measurements.
2.
In a relief request (Item 2.1.3), the licensee has proposed to use a vibration signature analysis program in lieu-of using bearing temperature recordings for monitoring pump condition.
Relief was not granted.
Acceptable limiting conditions for operation and maintenance were not included in the licensee's proposal.
3.
The'following paragraphs are those where relief requests have not provided adequate technical justification for granting relief.
2.2.1 i
3.2.1.1 3.2.3 3.2.1.2 3.10.1.2 3.11.1.2 3.13.1.1 4.
In a relief. request (Item 3.2.1.1), the licensee has proposed an alternate testing program for all' containment isolation valves which consists of exercising per their Tech Specs and leak-rate testing per their established Appendix J procedures.
Leak-rate testing per the established procedures
'is acceptable to the staff, however, the licensee should meet the require-ments of Section XI IW-3426 and IW-3427.
The Technical Specification 03/04/85 45 Millstone 1 IST SER
1
'i[)AI'y#
I" g s
mandated exercising of.the containment isolation valves does not give complete assurance that all these valves will be exercised.as required by the Code.
5.
In the following relief requests the basis for relief is acceptable how-
~
~
ever,.the testing interval is not acceptable, and therefore total relief was not granted.
3.4.1.1 3.4.2.2 3.9.1.1 3.10.1.1 3.12.1.1 6.
In a relief request (Item 3.10.1.1), the licensee requested relief from exercising requirements for 1-RC-6 and 1-RC-15, drywell inlet and outlet reactor building closed cooling water system valves, on the basis that their -Tech Specs do not categorize these valves as containment isolation valves.
However, the NRC has required these valves to be added to the IST program and modifications made to the system so that testing could be performed to the requirement's of the Code.
These valves must be categorized as A/C and A respectively and exercised according to Section XI with leak-rate testing per Appendix J.
7.
The licensee did not inclede Diesel and Fuel Oil Transfer System pumps or valves or Diesel Air Start System valves in their IST program, nor did they provide P&ID's or information to allow evaluation of these systems.
These system's pumps and valves perform a function that is important to safety and must be included in the IST program and tested in accordance with the Code requirements.
8.
In NNECO W. G. Counsil, Senior Vice President's letter to Mr. Dennis M.
Crutchfield, Director of Nuclear Reactor Regulation, Chief Operating Reactors Branch No. 5, U.S. Nuclear Regulatory Commission, dated June 22, 1982, it was demonstrated that the instrument air system was modified (Item No.2).
The licensee went on to indicate that valve 1-IA-124 would 03/04/85 46 Millstone 1 IST SER
c DIAa o4 then be removed from the IST program.
Valve 1-IA-124 should not be removed from the program; since valve 1-IA-130 is retained as part of the IST program, it appears #that the backup air supply has been taken credit for in,their analysis.
Therefore, valve 1-IA-124 would have to close for the backup air supply to operate, thus requiring it to be part of the IST program.
9.
The licensee has requested relief (Item 3.5.1.1) from the exercising requirements of Section XI for valves 1-CS-5A and 58, core spray admission valves.
Their proposed alternate test is to exercise these valves at cold shutdown and leak-rate test per Appendix J at refueling outage. 'All portions of the basis are acceptable except that Appendix J testing alone L
is insufficient.
Since 1-CS-SA and 5B also serve as pressure isolation valves, they must be leak tested per Section XI of the ASME Code as well '
as Appendix J.
- 10. The licensee has requested relief (Item 3.6.1.1) from the exercising requirements of Section XI for valves 1-LP-10A and 108, LPCI recirculation icep inboard stop valves.
The proposed alternate test is to exercise these valves at cold shutdown.and leak-rate test per Appendix J at each
/
refueling outage.
Since 1-LP-10A and 108 also serve as pressure isolation valves, they must be leak tested per Section XI of the ASME Code as well as Appendix J.
03/04/85 47 Millstone 1 IST SER
=
=
-1.
t
' APPENDIX E NOTES r
' 'Thezfollowing items are apparent incJnsistencies in the Millstone IST program.
These items were noted in the review of the program submitted by Northeast Nuclear Energy Company.
These items should be corrected.
1.
In' Table IW-1 (page 62 of. the licensee's 1980 program submittal *), the licensee has~ indicated that valve 1-IA-68, instrument air stop is passive.
This valve is not passive and should be exercised per Section XI or relief requested.
L.
In Table -IW-1 (page 61 of the licensee's 1980 program submittal *), the 2
licensee has indicated that valve 1-IA-69, instrument air check valve,
-would be exercised open only'and a relief request had been generated for-leak-rate testing. This valve needs to be verified closed.
No relief.
request for the leak-rate. test was found.
- 3. -In Table IW-1 (page 61 of the licensee's 1980 program submittal *),
the licensee has indicated that valve 1-SM-1, reactor sampling isolation' valve, is passive and that-it would be exercised quarterly and leak-rate tested.
This-valve is not. passive and should be stroke timed and position indicator verification-tested.
4.
- In Table _IW-1 (page 61 of the licensee's 1980 program submittal *) the licensee has indicated that valve 1-SM-2, reactor coolant sampling valve,
-is passive and that it would be exercised and stroke timed.
This valve is.not passive and also needs to be leak-rate tested and position indicator verification tested.
These valves were dropped'from the licensee's January 1985 program submittal.
03/04/85-48 Millstone 1 IST SER
g mm U. \\n
~
~
5.
In NNECO W. G. Counsil Senior Vice President's letter to Mr. Dennis Crutchfield, Director of Nuclear Reactor Regulation, Chief Operating Reactors Branch No. 5, U.S. Nuclear ~ Regulatory Commission, dated June 22, 1982,,it was indicated that valves 1-IA-99A through F, instrument air to accumulators, would be exercised and leak tested at refueling outages
~
(Item No. 2).
A.soecific relief request should be written to cover this deviation from the quarterly exercising requirements.
6.
-In Table IWP the licensee refers to relief requests R-6, R-10, R-11 and R-13 in the Column labeled " inlet pressure." However, none of these relief requests refer to inlet pressure.
Therefore, the NRC staff will expect that measurement of inlet pressure is in full compliance with ASME Code require-ments unless specific relief is requested.
7.
In those cases where a valve or pump is deleted from the IST program, the item should not be erased from the submittal.
Rather, a notation that the item has been omitted (with explanation where appropriate) should be added.
The licensee has dropped a number of valves from the IST program (see submittal of September 18, 1980 and January 16, 1985).
These deletions are not approved.
The licensee must submit, and NRC then accept, suitable explanations and relief requests for omitting each of these valves.
8.
Any program revisions subsequent to those noted herein are not approved.
Required program changes, such as additional relief requists or the dele-tion of any components from the IST program, should be submitted to the NRC under separate cover in order to receive prompt attention; but must not be implemented prior to review and approval by the NRC.
9.
In relief request V-1 valves 1-CM-2A is mislabled.
10.
In relief request V-7 valves IFW-4B and 4C are mislabeled.
03/04/85 49 Millstone 1 IST SER
.