ML20128G797
| ML20128G797 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/30/1983 |
| From: | Rockhold H, Stromberg H EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML20128G735 | List: |
| References | |
| CON-FIN-A-6445 EGG-EA-6326, NUDOCS 8505300316 | |
| Download: ML20128G797 (58) | |
Text
{{#Wiki_filter:nt%t;exn t Yh EGG-EA-6326 June 1983 SAFETY EVALUATION REPORT, PUMP AND VALVE INSERVICE TESTING PROGRAM, MILLSTONE NUCLEAR POWER STATION,
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1 . H. C. Rockhold H. M. Stromberg
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EGG-EA-6326 ! l
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SAFETY EVALUATIO!1 REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM
-MILLSTONE NUCLEAR POWER STATION, UNIT I H. C. Rockhold H._M. Stromberg Published June 1983 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 m Prepared for the-U.S.~ Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570
' FIN No. A6445
r-J CONTENTS ABSTRACT .............................................................. 11
,, FOREWARD ....................... '................ . .. .. ......... 11
- 1. INTRODUCTICN ..................................... ............... 1
- 2. PUMP TESTING PROGRAM ...................... ...................... 3 2.1 Generic Relief Requests . .... ... .............. .. ...... 3 2.2 Pump Flow Rate Measurement ... .... .... .... ............. 9 2.3 Pump Differential Pressure Measurement .. . . .. .... ... 10 2.4 Test Interval ............................ ................. 11
- 3. VALVE TESTING PROGRAM ............................................ 15 3.1 General Considerations ................. ................... 15 3.1.1 ' Exercising of Check Valves ....... ........ ..... .. 15
.3.1.2 Valves Identified for Cold Shutdown Exercis'ing . ... 15 3.1.3 Conditions for Valve Testing During Cold Shutdowns .......................................... 16 3.1.4 Application of Appendix J Testing to the IST Program ............................................ 17 3.1.5 Valves Important to Safety ......................... 17 3.1.6 Valves Which Perform a Pressure Boundary Isolation Function ..................... .. ........ 17 3.2 Generic Relief Recuests .................................... 19 3.2.1 All Category A Containment Isolation Valves ........ 19 3.3 Feedwater Coolant Injection System ......................... 21 3.3.1 Category B Valves .................................. 21 3.3.2 Category C Valves .................................. 21 3.4 Control Rod Drive Hycraulic System . . .. .. .. . .. .... ... 22
. 3.4.1 C a t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.4.2 Category C Valves ......... ........ ............... 24
.' 3.5 Core Spray-System .... .................. ................ 25 3.5.1 Category A Valves .................................. 25 3.5.2 Category C Valves .................................. 26
'3.6 Low Pressure Coolant Injection System ...................... 27 3.6.1 Category A Valves .. .. ......... ... ......... ... 27 3.6.2 C a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . ............ 29 tii
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- 1. INTRODUCTION
' Contained herein is a safety evaluation of the pump and valve inservice. testing (IST) program submitted by the Northeast Nuclear Energy cepany (NNECO).fo? its Millstone Nuclear Pcwer Station, Unit 1.
ihe licensee's sucmittal for Interval 2, dated September 1980, was received by EG&G Icaho, Inc., August 10, 1981, and an evaluation of the-
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pr gram's variance with the program dated Septemoer 1979 was performed. The cifferences cetween the programs were evaluated for compliance of proposed tests with the requirements of the ASME Boiler. and Pressure Vessel Code, Section XI, 1974 edition, through the summer of 1975 addenda. Those
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items nct in compliance were discussed during conference calls with NNECO representatives, NRC personnel, and EG&G Idaho, Inc., reviewers on April 1,
.1982. Tne licensee's written response addressing changes resu,lting from the conference call was received by EG&G Idaho Inc., June 7, 1982. In their IST-program su0mittal dated August 10, 1981, and the written response of' June 7,1982, NNECO nas 'requestec relief from the ASME Code testing requirements for specific pumos and valves anc these requests have been evaluated indivicually to cetdrmine wnetner they have significant risk implications and whetner the tests, as required, are indeed impractical.
The evaluations in this SER of the Millstone Nuclear Power Station, Unit 1 pump and valve inservice testing program and the associated relief requests are the recommendations of EG&G Idaho, Inc. 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
.ASME Code, Section XI, and are not exercised quarterly are addressed in
. Attachment.1.
A listing of P& ids used for this review is contained in Attacnment 2. 1
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EGG-EA-6326 SAFETY EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM MILLSTONE NUCLEAR POWER STATION, UNIT 1 _ H. C. Rockhold H. M. Stromberg Published June 1983 EG&G Idaho, Inc. Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Centract No. DE-AC07-76ID01570 FIN No. A6445
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. ABSTRACT
.4 This EG&G Idaho, Inc., report presents the results of our evaluation
,.of the Millstone Nuclear Power Station, Unit I-' Inservice Testing Program '
for safety-related pumps anc valves. FOREWARD This report is supplied as part of the " Review of Pump and Valve
' Inservice Testing Prcgrams1for Operating Plants" Program being concucted ufer the U.S. Nu: lear Regulatory ' Commission, Office of-Nuclear Reactor
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Regul'ation, Division of-Engineering, by EG&G Icaho, Inc., NRC Licensing Support Section. The U.S. Nuclear Regulatory Commission funded the work under ne autnerization E&R 20-19-10-11-2, FIN A6445. l ' Occket No. 50-245 11 C-
P l CONTENTS ASSTRACT ..................................................... ........ 11
.. FO R EWA R D * . . . . . . . . . . . . . . . . . . . . . . . ' . . . . . . . . . . . . . . . .. ........
. . .. 11
-n-
. Ninuvb,Ci lCN ........................ .......... ... ......... 1
- 2. PUMP TESTING PROGRAM .......................... .... ............. 3 2.1 Generic Relief Requests .... ... ... . .. . ...... .. 3 2.2 Pump Fio. Rate Measurement ... . ... ..... . . . .... . . 9 2.3- Pump Differential Pressure Measurement . .. .............. '1C 2.4 Test Interval .......... ................................... 11
- 3. VALVE TESTING PROGRAM ............................................ 15 3.1 General Considerations ........ .... ... ................... 15
.s. 3.1.1 Exercising of Check Valves ...... . ....... .... ... 15 3.1.2 Valves Icentifiec for Cold shutdown Exercis'ing ..... 15 3.1.3 Conditions for Valve Testing During Cold Shutdowns .......................................... 16 3.1.4 Application of. Appendix J Testing to the IST Program ............................... ............ 17 3.1.5 Valves Important to Safety ....... ... ............ 17 3.1.6' Valves Which Perform a Pressure Boundary Isolation Function ............. .............. . . 17 3.2 Generic Relief Requests .......... ......................... 19 3.2.1 All Category A Containment Isolation Valves ........ 19 3.3 Feedwater Coolant Injection System ......................... 21 3.3.1 C a t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.3.2 C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.4 Control Rod Drive Hycraulic System . ... .. .. ........... 22
. 3.4.1 Category B Valves ................................. -22 3.4.2 Category C Valves ............ ............ ........ 24
. 3.5 Core Spray System ................ ......... .... ......... 25
-3.5.1 C a t e g o ry A Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
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3.5.2 Category C Valves ..... .............. .......... .. 26 3.6 Low Pressure Coolant Injection System .. .................. 27 3.6.1 Category A-Valves ........ ... .. ... .... .. ..... 27 3.6.2 - C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 111
DRAT 3.7 Main Steam System .......................................... 30
. 3.7.1 -Category A Valves ............... . . . ........... 30 3.8 Isolation Condenser ........................................ 31
, 3.8.1 Catego y A Valves .................................. 31 _
3.S.2 CategCry C Valves .................. .. ..... . .. 32 -
'3.9 Service Water System ............... ....................... 33 _
3.9.1 C a t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
- 3.10' Reactor Building Closed' Cooling Water Systen .. ............ 34 3.10.1 Ca te go ry B a nd C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 3.11 Containment Isolation Valves............................ ... 36 3.11.1 Ca t e g o ry A a n d A/C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . 36 APPENDIX A ............................................. .............. 41
- 1. CCDE REQUIREMENTS--VALVES .....................................'... 41
- 2. CCDE REQUIREMENTS--PUMPS ......................................... 41 ATTACHMENT ~1 .......................................................... 42
- 1. FEE 0 WATER CCOLANT INJECTION SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 1.1 C a t e g o ry B V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 1.2 Category C Valves .......................................... 43
- 2. LOW PRESSURE COOLANT INJECTION SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 2.1 C a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43-
. 3. SHUTDOWN COOLING SYSTEM ........................................ . 43 3.1 Category C Valves .......................................... 43
- 4. CONTAINMENT ISOLATION VALVES ..................................... 44 4.1 C a t e g o ry A a n d A/C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
' ATTACHMENT 2 --
.......................................................... 46 --
- ATTACHMENT 3 .......................................................... 47 ATTACHMENT 4 .......................................................... 49 l.
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- 1. INTRODUCTION '
Contained herein is a safety evaluation of the pump and valve
-inservice, testing (IST) program submitted by the Northeast Nuclear Energy C0acany. (8NECO) fo ' its Millstone Nuclear Powea Station, Unit 1.
The licensee's submittal for Interval 2, dated September 1980, was ~
^
received by-EG&G Icaho, Inc., August 10, 1981, and an evaluation of the. program's variance wi.h the program dated September 1979 was performed. The differences ce: ween :ne programs were evaluated for compliance of proposed tests with the requirements of the ASME Boiler and Pressure Vessel Code, Section XI, 1974 edition, through..-the summer of 1975 addenda. Those items not in compliance were discussed during conference calls with NNECO representatives, NRC personnel, and EG&G Idaho, Inc., reviewers on April 1, 1982. The licensee's written response addressing changes resu.lting from the conference call was received by EG&G Idahe Inc., June 7, 1982. In their IST program submittal dated August 10, 1981, and the written response of. June 7, 1982, NNECO has requested relief from the ASME Code testing requirements for specific pumps'and valves anc these requests have been evaluated indivicually tq cetermine whetner they nave significant risk implications and whether the tests, as required, are indeed impractical. d The evaluations in this SER of the Millstone Nuclear Power Station, Unit 1 pump and valve, inservice testing program and the associated relief
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requests are the recommendations of EG&G Idaho, Inc.
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A' summary of Section XI pump and valve testing recuirements is provided in Appendix A. Category A, B and C valves that meet the requirements of the
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ASME Code, Section XI, and are not exercised quarterly are addressed in
. Attachment.1.
A 1.isting of P& ids used for this review is contained in Attacnment 2. I
n JRAFTI Valves that'have an interval between tests longer than each refueling Loutage and relief; requests with. insufficient technical basis where relief is not recommenced are summarized in Attachment 3. This attachment also addresses.other-items .from-the report tnat are not in accordance with NRC
~ :recuieccents. -
- A . listing ofiinconsistencies noted in the Millstone IST Program is contained lin Attachment 4.
l: F 9 2 {l__.
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- 2. PUMP TESTING PROGRAM
-The Millstone Unit 1 IST program submitted by Northeast Nuclear Energy Company was examined to verify the.tJClass 1, 2, and 3 safety-related pumps
!"cluced in .the prcgra;; are subjected te the pericdic . tests re;uirac cy
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~ASME' Code,'Section XI. 0ur review found tnat, except as noted in
. Attacnment 3 or where specific relief from testing has.been recuested, these pumps are tested to tne Code requirements summarized in Appendix _A.
Eacn Nortneast Nuclear Energy Ccepany basis for regtesting relief frem the o.:mp testing recuirements and the EG&G Idaho, Inc. , evaluation of that , recuest is summarized below. 2.1 Generic Relief Recuests
'2.1.1 Relief Recuest -
The licensee has requested specific relief from the vibration 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 . Cede Recuirement. IWP-4510 states "At least one dis;:lacement vibration amplitude (peak-to peak corrposite) shall be read during each inservice test." 2.1.1.2 Licensee's Basis for Recuestino Relief. To meet the
' vibration monitoring recuirements of ASME Section XI, Subsection IWP, exception is taken to the specific vibration requirements of IWP and an I alternate, more effective vibration signature analysis program, as.
y : described herein, is-proposed. During the inservice pump test, vibration
- data snall-be acquirec in tne form of.a " vibration signature" rather than a g simple reading of overall vibration amplitude. The vibration signature shall consist of a plot of vibration amplitude in units of inches l 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 provides a.more reliable means of detecting a 3
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e Yl I i 9 deterioration of pump mechanical condition, a determination of the cause of the problem, and a more accurate assessment of vibration severity. The periodically acquirec vibration signatures'shall be compared to a baseline
. reference signature and analyzed for changes in amplitude peaks exceeding a threshold value'. Criter S for evaluation of changes as to cause, ' /erity,
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and the establishment of the alert and required action ranges shall be specified in :ne NNECO procecures. Vibration measurements are ma'de typically with an accelerometer scunted at a' reference location on the equipment cearing housing, and the data is process by a soectrum analyzer to produce a Farc cocy vibration
" signature. The vibration sensors can also be interfa:ed directly with the spectrum analyzer.
The measurement locations to be used for monthly and baseline v-ib*ation signature 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 pumo, thus it is
- ible to cetect de< eloping probie' s so recairs can be initiatec prior to ne ' oump becoming 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 inen) every month.
Millstone Unit I has proposed an alternate program which we believe to be 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 biseline reference vibration signature and analyzed for changes.in amplitude peaks exceeding a threshold value. The current NRC position is that even though the vibration signature analysis program - appears to be ?:re ef'ective for monitoring pumo concition, limiting values nave not been establishec -tnat clearly indicates corrective action is . recuired. Therefore, we feel the proposed alternate test program is not acceptable. 4
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2.1.1.4 Conclusun. The. current NRC position is, that due to the lack of limiting values for establishing alert ranges and corrective action limits, the alternate program-is unacceptable. Tnerefore, we recommend that. relief not be granted from the pump vibration monitoring requirements
- of Section XI unles acceptable alert and recuired action ranges are
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established. 2.1.2 Relief Recuest The licensee has requested specific relief from the pumped fluid temperature measurement requirements of Section XI for all safety related pumps. l 2.1.2.1 Code Recuirement. IWP-4320 states 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 temperature measured is representative of the temperature of the liquid passing though the pump.
.2.1.2.2 Licensee's Basis for Recuestinc Relief. Pumped fluid tc.mperature measurement is not a meaningful parameter to measure for this series of operational reaciness tests. This was recognized cy ASME Section XI in code accenda sucsequent to the Summer, 1978 addenda, when this requirement was deleted.
2.1.2.3 Evaluation. The licensee has requested relief from the requirement of measuring pumped fluid temperature based on it not being a meanir.gful parameter for monitoring pump condition and the fact that the requirement was deleted from the Code after tne Summer 1978 Adcenda. The Millstone IST Program was prepared following the 1974 and Summer 1975
. Adcenda 1.n which there isn't a requirement for measuring the pumped fluid temoerature and, therefore, we feel relief should be granted from pumped fluid measurement requirements of Section XI.
2.1.2.4 Conclusion. We conclude that measurement of the parameters recuired by Table IWP-3100-1 of Section XI, will give reasonable assurance 5
DRW of pump operability intended by the Code. Based on the considerations ciscussec above, we conciuce that the relief thus grantec will not encanger life or property or tne common defense and security of the public. 2.1.3-Reliefkeouest , Tne licensee has recuested specific relief from the pump bearing temperature measurement requirements of Section XI for all safety related ' pumos and proposes to use pump vibration signature analysis as the means of m:nitoring the various pump's mechanical condition. 2.1.3.1 Code Reouirement. Refer to Appendix A. 1 2.1.3.2 Licensee's Basis for Recuestino 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 measure bearing metal temperature; i.e., outer race of anti-friction bearing or baboit lin.ing of sleeve bearing. The annual
,easurement .for bearing bcusino teEperature is far less effective in m e: ting bearing problems than the monthly perfermance of vibration
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signature analysis being performed by NNECO. The remaining pumps listed in Table IWD do not have adequate design provisions to allow meaningful bearing temperatures to be taken: o low pressure coolant injection, core spray, condensate, service 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 - FOL No. DPR-21. o Standby liquid control pump bearing are mounted in a massive oil-filled reservoir which is in direct contact with the pumped fluid. Thus, measurement of housing temperature is not indicative of bearing condition. 6
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, ti l ni ~d o RBCCW, reactor shutdown cooling, secondary CCW,- fuel pool cooling, feed pump seal water, and CR0 pumps-have recessed
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bearings and housing temperature measurements are possible'but of questionable value. . 4 o The emergency condensate transfeb oump bearing temperature cannot-be' considered meaningful since tne pump hydraulic circuit (condensate storage tank to condenser hotwell--no recirculati:n patn) allows only about five minutes of operatien before the. notwells are fillec. Inis short run time cces not allow the bearing temperature to stabilize. o Service water and energency service water pump bearings are underwater and inaccessible. In general, as internal bearing metal temperatures increase due to bearing overload, improper lubrication, or faulty installation, etc., much of the heat will be dissipated throughout the relatively massive housings, oilL reservoir, and attached casing. As a result, bearing housing temperatures will responc mucn'less than bearing metal temperature, greatly recucing the sensitivity to 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 bearings, whether anti.-friction type or sleeve, often exhibit . fluctuations between normal and abnormal metal temperatures. A good examcie is tne 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
-i acnormal temperature rise would most probably go undetected unless continuously monitored.
The monthly vibration signature analysis conducted by NNECO will cetect bearing problems at a very early stage. At the onset of a bearing croblem, low level vibration will be generated at characteristic frequencies depending on the nature of the problem. The low level 7 L
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vibration typically amounts to-less than 1 percent of the overall vibration
. amplitude and therefore cannot be detected by a' simple amplitude monitoring program ccnforming to IWP minimum requirements. However, the low level changes in bearing distress frequencies are routinely detected in the Milistone signature anabais program and analyzec to pinpoint tne cause.
As an alternate, NNECO will record and analyze pump vibration signature monthly. Signature will be measured as velocity spectrum between
~0 and 500 hert:. This monthly analysis will provide core meaningful anabsis of pump bearing condition than annual measurement of bearing temerature.
2.1.3.3 Evaluation. The licensee has requested relief from Section XI requirements of recording bearing temperatures for all pumps important to safety. Their basis for relief is that the monthly vib' ration signature analysis program is more effective in monitoring bearing degradation than recording bearing temperature yearly. We agree with the licensee's basis, however, the current NRC position is that the vibration signature analysis orogram may be mo,re effective in monitoring oump concition, nowever, limiting values have has not been established that clearly indicates when maintenance corrective action is required. Therefore, we-feel the proposed alternate test program is not acceptable. 2.1.3.4. Conclusion. We conclude that the proposed alternate test program of using the vibration signature analysis program in lieu of bearing temperature-is not an acceptable alternative. Based on the considerations discussed above we recommend that relief.not be granted unless the.. licensee provides sufficient additional information demonstrating no compromise in safety for not meeting the Section XI recuirements.
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4 1 . 2.2 Pumo Flow Rate Measurement
-2.2.1 Relief Recuest'- l
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The licensee M.s requested specific' relief from the-individual pump 7
- flow-rate measurement requirements of Section XI-for the.following pumps.
Condensate Condensate'5 coster - C.eactor Building Closed Cooling Water Secondary Closed Cooling Water-e' Reactor Feed Seal Water
-Service Water Reactor Shut.own Cooling !
2.2.1.1 Code Recuirement. _ Refer to Appendix A. 2.2.1.2 Licensee's Basis for Requesting Relief Individual pump flow measurement instrumentation does not exist in the hydraulic circuits for these pumps. Pump differential pressure, motor current'(except as notec on the table), and/or system flow rate can be used to measure each pump's performance,~ providing that an established set of reference-conditions are utilized for each test. .Please refer to the
. Safety Evaluation attached to Amendment 64 of POL No. OPR-21. As an alternate, reference conditions for these pumps will be established using
' installed: instrumentation as shown in Table IWP.
2.2.1.3 i..aluation. We do not agree with the licensee's basis for
- relief and, therefore, feel that relief should not be granted from the requirement _of measuring flow as per the Code. The current NRC/MES
, position on measuring Section XI parameters requires the necessary instrumentation be instaled and states that the lack of instrumentation.is not an adequate technical justification for granting relief. Therefore, we feel =the licensee has not provided adequate tecnnical justification for 9
A h r *;'
- gran_ ting' relief.and feel the licensee should provide the required instrumentatien.se flow can ce monitored per tne Coce.
-2.2.1.4 Conclusion. 'We conclude that the licensee-should test.all
. cumes in the IST program in accordance ith the flow requirements of Sectien.XI-'unless sufficient information is provided that demonstrates no I recuc. ion in pump reliability and no comprcmise in safety for not
- erforming the required Section XI. testing.
2.3 Pumo Di#ferential-Pressure Measurement 2.3.1 ' Relief Recuest
'The licensee has requested specific relief from the requirements of
' Section XI for measurement of pump differential pressure for the seryice water, emergency service water and standby liquid control pumps.
2 ' 3.1'.1
. Code Rdcuirement. Refer'to Appendix A.
2.3.1.2 Licensee's Basis for heccestine Relief. The service water and emergency service water pumps take suction -directly frem Niar. tic Bay and are not instrumented.for suction pressure, as the inlet pressure differer.ce, caused by tidal swing, would be inconsequential in regarc.to
. pump. performance. The standby liquid control pump 1s.a positive.
q displacement pump, so differential pressure measurement would be
-meaningless. 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. We agree with the licensee's basis and, .
. therefore,' feel relief should be granted from the inlet and differential
' pressure measurement requirements of Section XI for the service water, emergency service water and standby liquid control oumos. The licensee has 10
~ hagr M @.f .I demonstrated that the differential pressure readings for the. service water and emergency service water pumps are not possible because there are no
' installed-ins: uments'that would give measurements incicative of pump degradation. -refore, we feel t, hat the proposed alternate test program
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of ca'iculating differential pressure by taking the difference between a measured discharge pres'ure s and a suction pressure calculated frca tne suctien level should be adeouate to monitor pump degradation and meet the intent of the Code. The licensee has also demonstated that measuring cifferential pressure,for the SBLC pumps is meaningiess because they are < p;sitive displacementipumps. The licensee has cropo:ec an alternate test > of measuring flow rate and discharge pressure for the SBLC pumps. We feel that the alternate test program should Oe adequate to monitor pump condition and meet the intent of the Code. 2.3.1.4 Conclusion. We conclude that the licensee's proposed alternate testing for the service water and. emergency service water pumps of calculating pump diffe ential pressure and suction pressure should provide sufficient information to acequately monitor pump degracation and meet the intent of Section XI differential pressure recuirements. We also feel that measuring flow rate and discharge pressure snould preside sufficient information to adequately monitor SBLC pump conditier, anc meet the intent of Section XI differential pressure requirements. Based on the considerations discussed above, we conclude that the alternate testing proposed should provide reasonable assurance of pump 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. 2.4 Test Interval 2.4.1 Relief Reouest
. The licensee has recuested specific relief from the pump testing frequency requirements'of Section XI for the reacter feed pumps and has proposed to perform the pump tests monthly only on the running pumps.
11
,:6k. d 2.4.1.1 Code Recuirement. Refer to Appendix A.
-2.4.1.2 Licensee's Basis for Recuestino Relief. Two of the three
. reactor feed pumes are running during normal plant operation and are rctated every tnree montI_ to ecuali:e wear. Several years of operating
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experience'on the ' feed pumps have established this rotation schedule as Oeing the most effective in terms of equipment reliaDility, operational readiness, anc recuttion of potential plant flow transients which might be brougnt 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. We do not agree with the licensee's basis and feel that relief should not be granted from the test frequency requirements of Section XI. We feel.that the licensee has not provided sufficient technical justification for an increase in test interval from monthly to cuarterly. ,
2.4.1.4- Conclusion. We conclu'ce that the licensee should test tne reactor feed pumps in accordance with the requirements of Section X: c'es:
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sufficient information is provided that demonstrates no reduction in pump reliability or compromise in safety because of an increased testing-interval. 2.4.2 Relief Recuest she licensee has requested specific relief from the pump testing frequency recuirements of Section XI for the reactor shutdown cooling pumps and has proposed to test these pumps during cold shutcown. - 2.4.2.1 Code Recuirement. Refer to Appendix A. . 2.4.2.2 Licensee's Basis for Recuestino Relief. The shutdown cooling system d'esign does not provide for pump testing unless the reactor 12
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i is.in a cold shutdown-mcde and the system is being utilized for. reactor residual heat removal (i.e., there is no pump test hop). 2.4.2.3 Evaluation. .We' agree with the licensee's basis for relief and, therefore, fer that relief.should be granted frem the monthly testing requirements of Section XI for the shutdown cooling pumps. The licensee
'has cemonstrated that it is not possible to test these pumps when the plant is=at power operation due to shutdown cooling. system operation being limitec to RCS temperatures less tnan 350'F. As an alternate test frecuency, the licensee has prcposed testing the shutecwn cocling pu:rps curing cold shutdown when plant temperature is less than 350 F.
2.4.2.4 Conclusion. We conclude that the lice.see's preposed alternate test interval of cold shutdown should provide sufficient information to acequately monitor reactor shutdown cooling pump cegradation and meet Section XI requirements. Based on the considerations discussed above, we conclude that the alternate testing croposed should provide
; reasonable assurance of pump operability intended by the Code and that the relief thus granted will not enoanger life or property or the common defenseandsecurityofthepbb1fc.
2.4.3 Relief Recuest The licensee has requested specific relief from the pump tasting frequency requirements of Section XI for the control rod drive hydraulic pumps. 2.4.3.1 Code Recuirement. Refer to Appencix A. 2.4.3.2 Licensee's Basis for Recuestino Relief. One control rod drive pumo is in service during normal power oceration. The pumps are rotated when pump suction filters require changing (approximately three months). Observation of tnese pumps has shown that frequent starts 13
e and stops of these'high speed, high pressure" pumps have led to pump ceterioration. As an alternate, the operating cor:rol rod-drive hydraulic pump will te tested monthly. , 2.4.3.3 Evaluatien. We do not agree with the licensee's basis and,
.therefore, feel that relief should not be granted from the' test frecuency recuirements of Section XI. We feel that the licensee has not proviced suf ficient technical justification for an increase in test interval frem nentnly to approximately_ quarterly.
2.4.3.4 Conciusion. We concluce tnat the licensee should test the control rod drive hydraulic ' pumps in accordance with requirements of Section XI unless sufficient technical information is provided that-demonstrates no reduction in pump reliability or compromise in safety due to an increase in the interval between tests.
'14 a . -_ - ~ '
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"$ ' k . ' .
- 3. VALVE TESTING PROGRAM The Millstone Nuclear Power Station, Unit- 1, IST program submitted oy i Northeast Nuclear Energy Company (NNECO) was examined to verify that f
Class- 1,-2, and 3 safety-related valves included in the program are suojectec to _the periocle tests reouired by the ASME Coce, Section XI. and the NRC positions and guidelines. Our review found that, except as noted in Attachment 3 or where specific relief from testing has been requestec, these valves are tested to the Code requirements and the NRC positions and guttelines summari:ed in Accendix A and Section 3.1 of this report. Each NNECO basis for' requesting relief from the valve testing requirements and the EG&G Icaho, Inc., evaluation of.that request is summarized below and grouped according to system and valve category. 3.1 General Conside-ations 3.1.1 Exercisino of Check Valves The NRC's position was stated to the licensee that check valves whose safety function is to open are excected to be full-stroke exercised. Since tne disc position is not always coservable, the NRC staff position is that verification of the maximum 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 partial-stroke exercising unless it can be shown that the check
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valve's disc position at the lower flow rate would permit maximum reouired flow through the valve. It is the NRC staff's position that this reduced flow-rate metnoc of cemonstrating full-stroke capability is the only test that requires measurement of the differential pressure across the valve. 3.1.2 Valves Identified for Cold Shutdown Exercisino The 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 15
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f.ull-stroke exercised during cold shutdowns, thereby meeting the require-ments'of the ASME Code. 'Since the licensee-is meeting the requirements of the'ASME Code,~ it is not nec.essary to grant relief; however, curing our-reviewofthe'bicenseetsISTprogram,wehaveverifiedthatitisnot
;rsstical to exercise thi.$e valves during power. c eratien. It snoulc be noted that the NRC differentiates, for valve testing purposes, between the
' cold shutdcwn mode and the refueling moce. That is, for valves identified fcp testing at-ccid shutccwns, it-is expected that the tests-will be '
cerformed'botn'during cold shutdowns and-during each' refueling outage. However, when relief -is granted to perform tests on.a refueling outage.
.frecuency, 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 tne 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:
- 1. The licensee is'to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours after
- hutdcwn, and centinue until complete er the plar.t is ready to return to power.
- 2. Completion of all valve testing is not a prerequisite to return to power.
- 3. -Any testing not completed during one cold shutdown should be performed during any subsecuent cold shutdowns that may occur -
before refueling to as closely as cossible meet the Code-specified testing frequency. . 16
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- 4. For planned cold shutdowns, where ample time is available for
' testing all.tne valves.ident'ified for the cold shutdown test frequency in the.IST program, exceptions to the 48 hours may be taken.
' jn e- 3.1.4 Acolication of Accendix J Testing to the IST Program
'The Appendix J review for this plant is completely separate frcm the IST orogram review. However', the determinations made by that review are
.directly aoplicatie to tne IST pregram. The licensee has agreed that,
~s hould the Appendix J program be amended, they will amend their IST program
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accorcinoly. p 3.1.5 Valves Imoortant to Safety
'This review was limited to valves that perform a function important to safety. Valves important to safety are defined as those valves tnat are needec to mitigate the consecuences of an accident and/or to shut cown the reactor anc to maintain the reactor in a shutdown condition. Valves in tris category woulc typically lnclude certain ASME Coce Class '.,- 2, and 3 valves anc could include some non-Coce class valves. It should be noted that'the licensee may have included valves whose functions are not important to safety in their IST program as a decision on their part to expand the scope of their program.
3.1.6 Valves Which Perform a Pressure Boundary Isolation Function
-Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface cetween these high and low p" essure systems protect the low
. pressure systems from cressures which exceed their design limit. In this role, the valves perform a pressure isolation function. The NRC considers the redundant isolation provided by these valves to be important. The NRC consiaers it'necessary to assure that the condition of each of these valves
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is acequate to maintain this reduncant isolation and system integrity. 17
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x%.. - The(followine;is a list.of valves that appear toLperform a pressure-tisolation. function.
-- Low' Pressure Coolant' Injection' -
4 LP411A,-Loop A check valve
; 1-LP-11B, LLoop S cneck valve 1-LP-10A,1LocciA is51ation valve ~~j 1-LD-102,DL6cp E solation valve Core So~ ray.
l 1-CS-6A, Loop A. check valve 1-CS-65, Loco B check' valve 1-CS-5A, Loop A isolation valve - CS-58, Loop B isolation valve , Shutdown Coolino 1-SD-5,Disenargeisciationvaive .
=1-50-1, Suction-isolation valve 1-SD-2A, Suction isolation valve 1-50-29, Suction isolation valve We have. discussed the valves listed above with the licensee. The
' licensee has agreec to review leak testing these valves-in accorcance with IWV-3420 of the applicable edition of the ASME Code and to categorize these valves'with the appropriate designation. If the licensee determines that
?. ' leak testing is not necessary because there are other methods that they .
-nave and will use to determine each valve's condition, they shall provide -
- c1the.NRC for evaluation,~on~a valve by valve basis, the details cf :ne Emethoo used that clearly cemonstrates the concition of each valve. ,
18
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, wa 1 3 .' 2 Generic Relief Recuests
~3.2.1 All Catecory A Containment Isolation Valves
. ~3.2.1.1 Relief Recuest. The licensee has reouested specific relief for all containment iso'lation valves from the exercising and tne leak rate testing requirements of paragraohs IWV-3420(f) and (g)(2) of Section XI of
- ne ASME Code. The utility has proposed to perform exercise testing as per tr.eir Tech-Specs and leak-rate testing per establishec procedures.
i 3.2.1.1.1 Cooe Recuirements--Refer to IWV-3410 and IWV-3420 of the 1974 edition tnrough and including Summer 1975 Adcenda of the ASME B & pV C0de, Section XI. 3.2.1.1.2 Licensee's Basis for Recuestine Relief--The containmentisolationvalhelistconsistsofvalveswhoseonlysafety
-function is containment isciation. Present Tech Specs require both an indivicual,and an integrated leakage rate test for containment isolation valves and penetrations. Tech Specs also require repair and retest of any
/alve exceeding the leakage criteria. NNECO feels that these tests insure tne leak-tigt.tness of all containment isolation valves, in that they are tested uncer the conditions for wnicn they are designed.
l Cperability testing 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. [
'NNECO also requests relief from paragraph IWV-3420(f) " 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, NNECO requests relief from paragraph IWV-3420(g)(2) in that no meaningful trends have been established. 19
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3.2.1.1.3 Evaluation--We agree with the licensees-basis and,. stne'refore,' feel that relief should be granted for the leak-rate testing requirements of Section XI of the Code for all' containment isolation valves. :The 1.icensee has demonstrated that the proposed alternate testing pvecedure'of using.the1 # Tech Specs which have been prepared follcwing .
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Appendix:J should be sufficient.to demonstrate valve degradation. However, we co not agree with the' licensee's basis for relief from the requirements of IWV-3420(f) and -(g). The current NRC position allows leak. rate testing
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'per Tech Specs but the requiremen'ts of IWV-3420(f) and (g)'must still be ret.
The licensee has also requested relief from the exercising requirements of Section XI. The licensee has not provided any technical justif.icationLthat assures the operability of all containment isolation valves in lieu of exercising per~the requirements of the Code. - 3.2.1.1.4 Conclusion--We conclude that the licensee's proposed alternate. test program of leak-rate testing per their Tech Specs should cemenstrate proper valve operability. Based on the considerations dis:asse: acove, we conclude that t'he alternate testing proposed should provice. reasonable assurance of operability intended by the Code and that
.the relief thus granted will not endanger life or property or the common cefense and security of the 'public.
f However, we recommend that relief not be granted from the requirements of IWV-3420(f) and (g) unless the licensee provides more sucperting data tnat demonstrates there is no compromise in safety for not performing these Section;XI test requirements. The licensee's. request for relief from the exercising requirements and -
-their propesec alternate test of utilizing their Tech Specs does not provide the necessary assurance that all containment isolation valves will .
be operated per the Code. Therefore, we recommend that relief not be granted from the exercising requirements of Section XI and that specific relief be requested for any valves that deviate from the Code. I 20 L-
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3.3 Feedwater Coolant' Injection System
~3.3.1 Catcory 5 Valves
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13.3.1.1 Reitaf Recuest. The licensee has requested sDecific relief
-from the exercising requirements of Section XI for valves 1-FW-14A,143,
.and 14C, feed pump minimun flow control valves, and proposed to full stroke
" exercise and test the fail position curing cold shutdowns.
3.3.1.1.1 Code Re:utrements--Refer to Appendix A. 3.3.1.1.2 Licensee's Basis for Recuestino Relief--These valves are normally closed and open only for ceriods of low flow into the reactor vessel during startup. They remain closed during,FWCI. Opening these valves during power operation would require a load reduction because feedwater flow to'the reactor would be diminished. 3.3.1.1.3 Evaluation--We do not agree with the licensee's basis,-and therefore, feel that relief should not be granted from the exercising requirements of Section XI for valves 1 tW-14A, 143, and IdC. The licensee has not proviced sufficient technical justification for _ granting relief. 3.3.1.1.4 Conclusion--We concluce that the licensee has not provided adequate technical justification for granting relief for the exercising requirements of -Section'XI for valves 1-FW-14A,148, and 14C. Therefore, we feel these valves should te exercised per the Code unless further information is provided cemonstrating tnat tnere is no compromise in safety for not exercising there valves to the Section XI requirements. 3.3.2 Catecory C Valves 3.3.2.1 Relief Recuest- 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 curing pump startup on rotation into service. 21
_,4 3.3.2.1.1 Code Recuirement--Refer to Appendix A. 3.3.2.1.2 Licensee's Easis for Recuesting Relief--Two of tnese valves are in' normal service and are er,ercised as pumps are routinely rotated. 'Eacn' individual va,1ve will n:t be exercised'every tnree m:nths. , Two of the three feed pumps .are ncrmally operating. NNECO believes tnese . valves are being properly demonstrated for coerational readiness and
-intends to continue to exercise them as pumps are rotated-into service.
3.3.2.1.3 Evaluation--We do not agree with the licensee's basis,-therefore,-we feel that relief should not be granted from the exercising requirements of'Section XI for valves 1-FW-2A, 28. and 2C. The licensee has'not providec an adequate tecnnical justification for not full stroke exercising these valves to the Section XI reouirements. 3.3.2.1.4 Conclusion--We conclude that the licensee has not provided adequate technical justification, therefore, we feel the licensee should perform the testing per the Code unless additional information is
.orovided that cemonstrates no compromise in safety for not exercising these valves quarterly.
3.4 Control Rod Drive Hydraulic System 3.4.1 Category B Valves 3.4.1.1 Relief Request The licensee has reouested specific relief frca exercising requirements of Section XI for valves 302-19A & 19B and 302-20A & 208, air solenoid valves to CR0 hydraulic system, and proposed exercising these valves during refueling outages. 3.4.1.1.1 Code Recuirement--Refer to Appendix A. 3.4.1.1.2 Licensee's Basis for Reouestino Relief--These valves are' solenoid operated and thus cannot be part stroked. Full stroking could cause an unscheduled reactor trip. These valves are operated 145 times each refueling as part of control red testing. 22
I Dji**T M inf l w 3.4.1.1.3 Evaluation--We agree with the ifcensee's basis and, therefore, feel relief should be granted from the exercising requirements of Section XI for valves 302-19A & 19B, and 302-20A & 208. The licensee has demonstrated that testing duri g9 power operation.is not possible,
. becau'se ti could initiate an unscheduled reactor trip. The utility has oroposec an alternate test interval of testing curing eacn refueling outage. We agree -tnat relief should be granted, however, we feel that relief should not be granted for the croposed test interval. We cannot justify a test interval any longer than cold shutcown unless additional su::crting informatien is crevided.
3.4.1.1.4 Conclusion--We conclude that relief should be granted from the Section XI exercising requirements for valves 302-19A & 195, and 302-20A & 206. The proposed alternate testing is for a testing interval of each refueling outage. It is our opinion that tne licensee nas not provided sufficient technical justification for not exercising these valves l at each cold shutdown. Therefore, we feel the relief should not be granted for the frecuency of testing, unless the utility provides sufficient-information demonstrating no compromise in safety for not exercising these valves at each cold shutdown
- Eased on the consicerations discussed acove, we conclude that the alternate testing proposed shoulc crovide reasonable assurance of valve operability intended by the Code and tnat the relief tnus granted will not endanger life or property or the common defense and security of tne public.
3.4.1.2 Relief Recueg . The licensee has requested specific relief from exercising requirements of Section XI for valves 305-126 acc 127, control valves for scram operation of control rods (145 of each), and proposed full stroke exercising during refueling outages.
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3.4.1.2.1 Centrol Recuirement--Refe- to Appendix A. 3.4.1.2.2 Licensee's Basis for Recuestino 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 moce switch prohibits the withdrawal of control rods. i 23 m .
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3.4 1.2.3
. Evaluation--We agree with tht licensee's basis for relief.and, therefore, feel relief should be grinted from the exercising
-requirements of Section XI for valves 305-126 anc.127. ine licensee has demonstrated th.at it is not possible to test these valves during operation or. cold sh'u tdown due to C sign. -Therefore, the only time intervai available is during refueling outage. ,
3.4.1.2.4' Conclusion--We conclude that exercising valves ' 305-126 and 127 each refueling out' age shculd demonstrate valve coe ability. Based'en t"e censicerations ciscussed a cve, we ccnciuce that the' alternate testing' proposed should provide reasonable assurance of valve operability intended by the Code and that the relief thus granted will not entanger life or property or tne common' defense and security of the puolic. 3.4.2 .Cateoory C Valves , 3.4.2.1 Relief Recuest. The licensee has requested specific relief from the exercising recuirements of Section XI for valves 305-114, scram discharge header checks, and 305-115. scram accumulator charging header che:ks (145 of each), anc cr :csed t'o full stroke exercise during refueling outages. 3.4.2.1.1 Cece Recui-ement--Refer to Appendix A. 3.4.2.1.2 Licensee's Basis for Recuestino Relief--These valves cannot be partial stroke exercised because of their construction. They cannot be exercised at colc snutcown because of system interlocks. The cold shutdown mode switch prohibits the withdrawal of control rods. 3.4.2.1.3 Evaluatier--We agree with the licensee's basis and, - therefore, feel relief snoulc te granted from the exercising requirements 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 is during refueling outages. 24
il Fi ILY j 3.4.2.1.4 Conclusion--We conclude that exercising valves 3C5-114 and 115 each refueling outage should demonstrate pro:er valve operacility. _ Based on-the considerations discussed above, we conclude (that the alternate testing proposed should provide reasonable
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assurance'of valve eerability intended by the Code and that the relief snus granted will not endanger life or property or the common cefense and security of tne public. 3.5 Core Sray System i 3.5.1 Cateoory A Valves 3.5.1.1 ~ Relief Recuest. The licensee has requested specific relief
.from tha exercising requirements of Secticn XI for valves 1-CS-5A and 55, core spray acmission valves, and proposec an alternate test of exercising at cold shutdown and leak-rate testing at refueling outage.
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3.5.1.1.1 Code Recuirement--Refer to Appendix A. 3.5.1.1.2 Licensee's Basis for Recuestine Relief--These valves togetner with 1-CS-6A, 6E isolate the Reactor Coolant System from tne Core Scray System. There is no positive method for determining the leak tightness or closure of 1-CS-6A, 6B. By cycling 1-CS-SA, 55 at power there is a possibility of subjecting the system to pressure in excess of their design pressures. Test connections are being added (1980 outage) to enable 1-CS-5A, 5B to receive a type "C" test to 43 psid as stated in NNECO's A;:endix "J" preposal. In that the valves are gates, this test pressure would be conservative with respect to tne higner test pressures associated with pressure isolation testing per ASME Section XI. Additionally there is an alarm set at 350 psig immediately downstream of 1-CS-5A, SS which sound in :ne control room. l-3.5.1.1.3 Evaluation--We agree with the licensee's basis and, L therefore, feel that relief should be granted from the exercising recuirement! of'Section XI for valves 1-CS-5A and 58. The licensee has demonstrated that there in no method for exercising these val.ves during 25
. . . . . ~, - -., _- ..
3 I power'cperation without.the possibility of subjecting the core spray system - to pressures _ in excess of , design pressure and'when exercised during cold shutoown there is no method of- verifying valve closure. _The utility has
-proposed an alternate' test program of e,xercising the valves open during
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-cold shutcown a'nd leak-rate +esting'per Aopendix J during. refueling
,- ' outages. LThe licensee agreec to modify the system curing the 1980 outage se the leak-rate testing could be performed.
3.' 5.1.1. 4 Conclusion--We conclude that exercising
< valves:1-CS-5A-anc 5B at cold'shutcown and leak-rate testing at refueling outages should sufficiently-demonstrate valve operability. Eased on the
' considerations discussed above, we conclude that.the alternate testing.
'croposed:should' 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. However .we
. feel that since.these valves also perform a pressure isolation function,
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they should be Section XI leak-rate tested as well as Appendix J tested. 3.5.2 Cateoory C Valves L 3.'5.2.1 Relief Recuest. 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.
3.5.2.1.1 Code Recuirement--Refer to Appendix A 3.5.1.1.2 Licensee's Basis for Recuesting Relief--There is no
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design provision for manually exercising these valves and stroking with ~
. system flow requires that water be pumped into the reactor vessel. This is '
I not possible at power because of pressure differences and thermal-bydraulic
. considerations. ,
3.5.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief sh0uld be granted from the exercising
. requirements of Section.XI for valves 1-CS-6A and 6B. The licensee has l
[ 26
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u f demonstrated it is not possible to test these valves at power operation because of the differential pressure between the core spray pu ps and tne reactor coolant system. If the full flow-stroke exercising was attempted during cold shutdown, a low temperature over pressurization of the RCS
, could res' ult because of the.large flow rate reoutred to exercise these
. . valves. The licensee p'roposes to full-stroke exercise these valves during refueling cutages, when the reactor vessel f.ead has been removed and the refueling water cavity is available to provide the required ex::ansion volume for the high flow rate.
3.5.2.1.4 Conclusion--We concluce that exercising valves 1-CS-6A and 6B during each refueling outage should demonstrate proper valve coerability. Cased on the considerations discussed above, we conclude that the alternate testing proposed should 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. 3.6 Low Pressure Coolant Injection System 3.6.1 Catecory A Valves 3.6.1.1 Relief Recuest. The licensee has requested specific relief from the exercising requirements of Section XI for valves 1-LP-10A and 105, LPCI to recirculation loops inboard stop valves, and proposed an alternate test of exercising at cold shutdown and verifying closed with leak-rate testing at refueling cutace.
'3.6.1.1.1 Code Reauirement--Refer to Appendix A.
3.6.1.1.2 Licensee's Basis for Recuestine Relief--These valves
. together with 1-LP-11A, llB isolate the Reactor Coolant System from the Low Pressure Coolant System. There is no positive method for determining the leak tightness or closure of 1-LP-11A and 115. By cycling 1-LP-10A and 108, there is a possibility of subjecting tne system to pressure in excess of their cesign pressures. Test connections are being acced 27
7
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, (19S0 outage) to enable 1-LP-10A and 10B to receive a type "C" test to 43'osid as stated in NNECO's Appendix "J" proposal. In that the valves are
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. gate val'ves, this test pressure would be conservative with respect to the higher test _ pressures associated with. pressure isolation testing per ASME Section'XI. Accitionallt there is an alarm downstream of 1-LP-9A and 95 wnich alarms in the control room at 350 psig.
3.6.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising re:uirements of Section XI for valves 1-LP-10A anc'IOB. Tne licensee has cemonstrated that there is no method for exercising these valves during
- power _ operation without the possibility of subjecting the low pressure injection system to pressures in excess of design pressure and wnen exercised during cold shutdown there is no method of verifying valve closure. The utility has proposed an alternate test program of exer.cising the valves during cold shutdown and leak-rate testing per Appendix J during refueling outages. The licensee agreed to modify the system during the 1980 outage so the leak rate testing could be conducted. The licensee intends to perform leak-testing per Appendix J.
3.6.1.1.4 Conclusion--We conclude that exercisirg valves 1-LP-10A and 10B at cold shutdown and Appendix J 1eak-rate testing at refueling outages shoulc sufficiently demonstrate valve operability. Based on tne consicerations discussed above, we conclude that the alternate testing proposed should 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. However, we feel that since these valves also perform a pressure isolation function, they should be Section XI leak-rate tested as well as Appendix J tested. 28
%e l
3.6.2 Cateoory C Valves 3.6.2.1 Relief Recuest. The licensee has recuested specific relief from the-exercising requirements of Section XI for valve 1-LP-11A, low oressure coolant;i(iection inside containment check valve, and procosed to full flow stroke exercise this valve at each refueling outage.
~
3.6.2.1.1 Code deovirement--Refer to Appendix A. 2.6.2.1.2 L':ensee's Basis for Recuestine Relief--There is no cesign provision for manually exercising tnis valve. Stroking with system flow requires that water be pumped into the reactor vessel. This is not possible at power because of pressure differences and thermal-hydraulic consicerations. 3.6.2.1.3 Evaluation--We agree with the licensee's basis and,
'therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 1-LP-11A. The licensee has cemenstrated it is not possible to test this valve at power operation because of the differential p'ressure between the low pressure coolant injection pumps and the reac or coolant system. If the full flow-stroke exercie ng as attempted curing cold shutdown, a low temperature over pressurization of tne RCS could result becituse of the large flow rate 6 reovired to exercise this valve. The licensee proposes to full-stroke exercise:these valves during refueling outage, when the reactor vessel head has been removed and the refueling water cavity is available to provide the
-swirec exoansion volume for the high flow rate.
3.6.2.1.4 Conclusion--We conclude that exercising b.- valve 1-LP-11A during each refueling outage should cemonstrate proper valve coerability. Based on the considerations discussed above, we conclude that
. tne alternate testing pt posed should orovide reasonable assurince of valve operability intended by tne Code and that the relief thus granted will not endanger life or property or the common defensa and security of the public.
29 L
DRAFTl 3.7 Main Steam System 3.7.1 Catecory A Valves
- 3. 7. I'.1 R'elief Recuest., The licensee has recuested specific relief ,
f-om the leak-rate and fati testing requirements' of Section XI for valves 1-MS-1A, 18, IC, 10, 2A, 2B, 2C and 2D, main steam line isolation valves inside.and outsice containment. The utility ~ proposed to perform leak-rate testing per their Tech Specs and perform fail position testing at ofceling outages. 3.7.1.1.1 Code Recuirement--Refer to Appendix A. 3.7.1.1.2 Licensee's Basis for Recuestino Relief--NNECO procoses a continuation of tne 25 psig test pressure currently being used to verify seat leakage, per Tech Specs, Section 4.7 as this pressure is consistent.with presently approved local leak rate test cr'iteria. It is not-possible to test the fail function of these valves while at power. 3.7.1.2.3 Evaluation--We' agree with the licensee's basis and, tnerefore, feel that relief should be granted from the leak-rate and fail function testing. requirements of Section XI for valves,1-MS-1A, 18, IC, 10, 2A, 25, 2C, and 2D. The licensee has cemonstrated that leak-rate testing
.per the Tech Specs should give reasonacie assurance of system integrity.
The licensee has also demonstrated that it is not possible to failsafe test while.at power operation. However, we cannot justify fail testing these Lvalves at an interval longer tnan cold shutdown. Therefore, we feel tnat relief should not be granted for the frequency of fail testing valves 1-MS-1A, IB, IC, ID, 2A, 2B, 2C, and 20. 3.7.1.1.4 Conclusion--We con: luce that leak testing per the Tech Specs should provide. proper assurance of valves 1-MS-1A, IB, IC, 10, - 2A, 2B, 2C, and 2D operability. Based on the considerations discussed above, we conclude that the proposed alternate testing shoulc provide reasonable assurance of operability intended by the Code and t at the relief'thus granted will not endanger life or property or the r-en 30
defense and security of the public. However, we feel that sufficient technical justification has not been provided for a fail test interval of any longer than cold shutcown, therefore, we recommend relief not ce granted unless'the.itcensee provides further information demonstrating no
., compromise in safety for not test:ng these valves at colc shutdown.
3.8 Isolation Concenser 3.8.1 Catecocy A Valves
.3.8.1.1 Relief Reouest. The licensee has requested specific relief from the leak-rate testing requirements of Section XI for valves 1-IC-1. 2,
- 3. and 4, isolation condenser containment isolation valves, and proposed to leak-rate test these valves in accordance with their Tech Specs.
3.8.1.1.1 Code Reouirement--Refer to Appendix A.
'3.8.1.1.2 Licensee's Basis for Recuestine Relief--The safety function of these valves is to provide containment isolation when recuired. These. valves are and have been tested as containment isolation valves as specified in Tech Specs Section 4.7--Local Leak Rate tests.
3.8.1.1.3 Evaluation--We agree with 'the licensee's basis and, taerefore, feel that relief should-be granted from the leak-rate testing requirements of Section XI for valves 1-IC-1, 2, 3, and 4. The licensee has demonstrated that these valves are containment isolation valves and leak-rate testing in accordance with the containment isolation vtive portion of their Tech Specs should demonstrate proper valve leak tight
. integrity.
3.8.1.1.4 Conclusion--We conclude that leak-rate testing valves 1-IC-1, 2, 3, and 4 per the Tech Specs snould demonstrate proper valve leak tight integrity. Based on the considerations discussed above, we conclude that the alternate testing proposed should provide reasonable 31
y)D/ t r
.._ IQ j assurance of valve integiry 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.
3.8.1.2 Relief Rec'+st. The licensee has recuested specific relief , from.the leak-rate testing requirements of,Section XI for valves I-IC-6 and 7, isolation concenser vent to main steam, and proposed to leak test curing the containment Integrated Leak Rate Test. 3.3.1.2.1 Code Recuirement--Refer to Acpendix A. 3.8.1.2.2
~
Licensee's Basis for Reouestino Relief--These valves hase no provision for local leak rate tests. 3.8.1.2.3 Evaluation--We agree with the licensee's basis ,and, therefore, feel that relief should be granted from the leak-rate requirements of Section XI for valves 1-IC-6 and 7. The licensee has cemonstrated that there are no provisions for performing leak-rate testing, therefore, the only time leak-rate testing can be performed on these valves
'is caring containment integrated lesk testing.
3.8.1.2.4 Conclusion--We conclude that leak-rate testing these valvas during containment leak testing ~ should demonstrate proper valve leak tignt integrity. Based on the considerations discussed above, we conclude that the alternate. testing proposed should provide reasonable assurance of
' valve leak tight integrity intended by the' Code and that the relief thus grar.ted will. net encanger life or property or the commen cefense and security of the public.
3.8.2 Catecory C Valves' 3.8.2.1 Relief Recuest. The licensee has requested specific relief . from the exercising requirements of Section 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. 32
k
-JdLG 3.8.2.1.1 Code Reouirement--Refer to Appendix A.
3.8.2.1.2 Licensee's Ba' sis for Reouestino Relief--In order to exercise this valve, flow must be established into the shell side of the Isolation Condenser In that the shell side water inventory must be in compliance with Tech Specs, Section 3.05, this cannot ce done except during reactor refuelings_when it is possible to drain the shell side to a low
~
level and refill to the operating band. Because of the complexity of this test, NNECO prefers not to attempt it during cold shutdowns. Makeup flow to the Isolatier. Condenser is not required until 40 minutes after the LOCA. 3.8.2.1.3 Evaluation--We agree with licensee's basis and, therefore, feel relief should be granted from the exercising requirements of Section XI for valve 1-IC-11. The licensee has demonstrated that it is nct practical to exercise this valve during power operation or, cold shutdown because of Tech Spec limitations and the lengthy procedure required for exercising. The licensee has preposed an alternate test interval of refueling outages. 3.8.2.1.4 Conclusien--We concluce that the proposed alternate exercising interval of refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate' testing proposed should provide reasonable assurance of valve
.operacility intended by the Code and that the relief thus grantec will not endanger life or property or the common defense and security of. the public.
3.9 Service Wate- System 3.9.1 Cateoory B Valves 3.9.1.1 Relief Recuest. The licensee has recuested 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 propose'd to exercise this valve during refueling outages.
3.9.1.1.1 Code Recuirement--Refer to Appendix A. 33 E
r .t
/
3.9.1.1.2 Licensee's-Basis for Recuestino Relief--This valve is in the flow path of service water to the Turoine Building closec cooling water' heat exchangers. If this valve fails to reopen aft' exercising to close, the TBCCW heat exchangers would ,9ot provide essent;al cooling for any balan'ce of plant'ccmponents, such as generator stater winding's, hycregen coolers, off gas blowers, etc. The remote position incicating test is done when the valve is exercisec.
.3.9.1.1.3 Evaluation--We agree with the licensee's basis and, i
therafore, feel relief shecid be granted from tne quarterly exercising recuiremen'ts of Section XI for valve 1-SW-9. The licensee has oemonstrated that it is not possible to exercise this valve wnile at pcwer operation ( without causing a less of ccoling water to calance of plant components, however, we cannot justify a test interval any longer than cold shutdown unless the licensee supplies additional supporting information. . 3.9.1.1.4 Conclusion--We conclude that relief should be granted
.from the- quarterly exercising .recuirements of Section XI for valve 1-SW-9.
However, we cannot justify a time interval longer tnan cold shutdown. Based on the considerations ciscussed aDove we recommenc relief not be grar.ted for the tcst interval unless the utility provices sufficient
'information demonstrating no ccmpromise in safety for not exercising-this
. valve at cold shutdown.
3.10 Reactor Buildino Closed Coolino Water System 3.10.1' Cate;ory B and C Valves
-3.10.1.1 Relief Recuest. The licensee has requested specific relief
'from the exercising requirements-of Section XI fer Category C check
. valve 1-RC-6 and Category B valve 1-RC-15, cryweil header inlet and outiet valves' anc proposed to not test tnese valves.
~
~3.10.1.1.1 Code Recuirement--Refer to Aependix A.
34
a- --
,s,e g
*~
~' ' < t3 f' l 3.10.1.1.2 Licensee's Basis for Reouesting Relief--The RSCCW cooling requirements for equipment inside containment are nonessential duringlaccicent modes of operation and so the positions of 1-RC-5 and.15 are incon' sequential, and left to if.e discretion of plant operators.
FurtS'er, the val'ves are not consicered containment isolation valves, per tne present plant Technical Specifications', Section 4.7. 3.10.'1.1.3 Evaluation--The licensee has reouested relief from Section XI exercising requirements for valves 1-RC-6 and 15 on the basis that their Tech Specs do not categorize them as containment isolation valves. However, the NRC required these valves to be added to the IST Program and modifications have been proposed for the system so that - exercising and leak-rate testing could be performed (see W. G. Counsil, Senior Vice President, Northeast Nuclear Energy Company letter to Mr. Dennis Crutchfield, Chief Operating Reactors Branch, U.S. Nuclear Regulatory Commission, dated June 22,1982). It is our opinion that these valves should be enangeo to Category A/C and A respectively and exercised accor' ding to ASME Code Section XI and leak-rate tested according to Apoendix J. 3.10.1.1.4 Conclusion--We concluce that valves 1-RC-6 and 1-RC-15 should be categorized as Category A/C and A respectively and
-exercised according to Section XI and leak-rate tested according to
-Appendix J. Based on the considerations discussed above we recommend that
- j relief not be granted. .
3.10.1.2 Relief Raouest. The licensee has requested specific relief from the exercising requirements of Section XI for Category B valve 1-RC-39, stop valve in RBCCW system discharge from shutdown-heat exchangers, and proposed to exercise this valve during cold shutdown.
. 3.10.1.2.1 Code Recuirement--Refer to Appendix A.
3.10.1.2.2 Licensee's Basis for Recuesting Relief--The shutdown e heat: exchanger is " laid up" between operations and is operated as nece~ssary to control 1 temperature at specified conditions during cold shutdowns. 35
r b 3.10.1.2.3 Evaluation--The licensee has' requested relief from ne exercising requirements cf Section XI for valve 1-RC-39 on-the basis that the shutdown heat exchanger is " laid up" between operations. We feel
. the~ licensee has not given sufficient technical-justification for granting
#elief and, therefore, f >el- relief should not be granted unless the utility ,
provides adequate -information ceaonstrating no compromise in safety for not , meeting the' requirements of Section XI. 3.10.1.2.4- Conclusion--We conclude that relief should not be granta: and valve 1-RC-39 :e exercised per Secti:n XI. The licensee has not provided sufficient technical justification for granting relief. 3.11 Containment Isolation Valves 3.11.1 Cateoory A and A/C Valves - 3.11.1.1 Relief Recuest. The licensee has requested specific relief from tne exercising requirements of Section XI for Category A/C valves 1-SL-7 and 8, Standby Licuid Control system combined discharge checks insice anc outside crywell, and proposed to exercise open at refuelir.g outage and leak-rate test closed during containment integrated leak-rate tests. 3.11.1.1.1 ' Code Recuirement--Refer to Appendix A. 3.11.1.1.2 Licensee's Basis for Recuestino Relief--There is no provision for. manual operation of tnese valves. Hydraulic stroking recuires pumping into the reactor vessel and the operation of a squib
- valve. There are no test connections at present by which an individual-Evalve leak rate test could be performed.
3.11.1.1.3 Evaluation--We agree with tne licensee's basis and, . therefore, feel that relief should be granted from the requ'irements of Section XI for valves 1-SL-7 and S. The licensee has cemonstrated that it is not possible to test these valves during power operation or cold shutdown because there isn't a manual operator on the valves and automatic 36 o
DRfFT operation requires the operation of a scuib valve and injection of boric acid into the reactor vessel. Automatic initiation.is not practical during power operation or cold snutdown. We feel that exercising these valves at refueling outages and verifying. closed with leak-rate testing at containment integrated leak-rate testing is the most practical nethod of-cemonstrating valve ocerability. . 3.11.1.1.4 Conclusion--We concluce that the licensee's prcposed alternate test of exercising valves 1-SL-7 anc 3 open at refueling outage and verifying closed with isak-rate testing at containment integrated ' leak-rate testing should provide reasonable assurance of valve operability. Based on the considerations ciscussec above, we conclude that the alternate testing proposed should provice reasonable assurance of operability intendec by the Code and that the relief thus granted will not encanger life or property er the cccmon defense and security of the public. 3.11.1.2 Relief Recuest. The licensee has requested specific relief from the exercising requirements of Section XI for Category A valves 1-50-1, 2A, 2B, 4A, 48, and 5, shutdown cooling isolation valves, and proposed to exercise these. valves curing colc shutdewn, not to exceed cnce every nree months. 3.11.1.2.1 Code Recuirement--Refer to"Appencix A. 3.~11.1.2.2 Licensee's Basis for Recuestino Relief--This system is held in " wet layuo" until such time as it is desired to be operated. The system ccerates as necessary to contrcl temperature at specified conditions curing colo snutcown. 3.11.1.2.3 Evaluation--We agree witn the licensee's basis for requesting relief ,nd,'therefore, feel tnat relief snould be granted from
.- tne quarterly exercising requirements of Section XI for valves 1-50-1, 2A, 23, and 5. The licensee has demonstrated that it is not possible to l exercise these valves during power operation since they isolate the 37 = -
V DRSFT
-a shutdown cooling from the RCS, while RCS temperature is above 350 F.
However, the licensee has not given a sufficient technical justification sfer not. exercising 1-50-4A and 4B per Section'XI, therefore, we feel relief should not-be granted for these valves.
~
3.11.1.2.4 Conclusien--We conclude that the licensee's proposed
-alternate test of exercising valves 1-50-1', 2A, 29, and 5 at cold shutdown snculd provide reasonable assurance of valve operability. Basec on the '
considerations-discussed above, we conclude that tne alternate testino pro:osed should provice reascnable assurance cf cperability intended :y the Coce and that the relief thus granted will not endanger life or property or che' common defense and security of the public. . however, we feel that relief for valves 1-SD-4A and 4B should not be granted cecause the licensee has not provided adequate sufficient technical justification for not meeting-the exercising requirements of Sc.uon XI. d 9 e I . k i L p I 38 F
4 e 2 p u s',
!.il\i.3 ;
4 O APPENDIX A S O f
. p 39
l APPENDIX A
- 1. CODE REQUIREMENT--VALVES x
Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code (whicn discussed full stroke and partial' stroke requirements) requires that Code Category A and S valves be exercised once every three months, with excections as cefined in IWV-3410(b)(1), (e), and (f). IWV-3520(a) (which discusses full stroke and partial stroke requirements) requires that
- Ccce Category C valves be exercised once every three months, with excections as defined in IWV-3520(b). .In the above cases of exceptions,
'tne: Code permit ,he valves to be tested at cold shutcown where:
~1. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
- 2. It is not practical to observe the operation' of the valves (with .
failsafe actuators) upon loss of actuator power. Subsection IWV-3410(c) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of tne maxinum allowable owner-specified time.
.2. CODE REQUIREMENTS--PUMPS .
An inservice test shall be conducted on all safety-relatec punos, nominally once each montn curing normal plant operation. Each inservice test.shall include the measurement, observation, and recording of all
- ' *1 ' quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
c . When measurement of bearing temperature is required, each pump shall
-be run until the bearing temperatures stabilize, and then the cuantities specified shall be measured or observed and recorded.
! 41 t L
D I F-ts);[,) a
,F u,i/
ATTACHMENT 1 The following are Category A, B, and C valves that meet the exercising requirements of, the ASME Code, Section 4I, and are not full-stroke
~
exercised every three months.during plant operation. These valves are specifica'ly l identified oy the owner and are ful'l-stroke exercised curing cold shutcowns and refueling outages. EG&G Idaho has reviewec all valves ~ in.this attachment and agrees with the licensee that testing these valves during pcwer operation is not possible due to the valve type and location cr :yster design. We feel that these valves snculd not be exercised curing
- power'cperation. .These valves are listed below and grcuped according to the_ system in which they are located.
- 1. FEEDWATER COOLANT INJECTION SYSTEM 1.1 Catecory B Valves 1-CN-58, steam jet air ejector minimum flow control valve, cannot be exercised or-fail position _ tested during power operation. Operation of this vaive during pcwer coeration coulc leac to a concensate flow cisruption. This valve will be exercised and fail position tested during cold shutdown conditions.
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 concenser vacuum. This valve will be tested and exercised at cold shutcown.
i 1-FW-4A,.48, 5A, 53, and SC,.feedwater control and regulating valves,
. cannot be exercised while at power cperation. Operation of_these valves -
could cause reactor vessel level fluctuations and possibly an inaovertent
~
reactor trip. These valves will be exercisec at cold shutdown. , 9 4 42
- l 1.2 Catecory C Valves 1-CN-2A, 23, 20, 1-CN-30A, 303, and 30C, concensate and ccndensate booster pumps discharge check valves, can not be exercised during power . ope r&ti on'. Ooeration of these vaives during power coeration could induce flow transients in tne feedwater and concensate systems. Inese valves will be full flow-stroke exercisec at cold shutcown.
- 2. LOW PRESSURE COOLANT INJECTICN SYSTEM 2.1 Cateoory C Valves 1-LP-110,-low pressure coolant injection inside containment check valve,.cannot be exercised while at power operation. Exercising at power cperation is not.possible because of the differential pressure between the low pressure coolant injection pumps or the shutdown cooling pumps and the RCS. These. valves will be exercised at cold shutdown.
- 3. SHUTDOWN COOLING SYSTEM 3.1 Catecory C Valves SD-3A and 33, shutdown cooling pump discharge check valves, cannot ce exercisec curing power operation. Exercising of these valves curing power operation is not possible because of the maximum of 35J- -i- fcr shutdown. cooling pump operation and these valves can only be operated with tre snutdown cooling oumps, therefore, these valves will be-exercised at colc shutdown.
9 4 43
i-I j
- 4. CONTAINMENT ISOLATION VALVES 4.1 Cate; cry A and A/C Valves 1-HS-4, outside.cor -inment head spray stop valve, and 1-HS-5. inside con ainment head spray check valve, can not be exercised during power-
. operacion. These valves 'are passive and exercising is not necessary during i- -pcwer operation. These valves will be exercised during cold shutdown.
1-MS-5 and-6, mair. steam line drains, will r.o: ce exercisec during power operation. These valves are passive and exercising is not necessary
-curing power operation. :These valves will be exercised during cold shutdown.
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O 0 i t I. P .. k-E i-I-
- 44 2 --- - m --e r,- ,
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.i.h\Y[f r ATTACHMENT 2 The P& ids listed celow were used during the course of this review.
'S stem P&ID Revision
.v -
IWS Examination. Boundary Diagram 25202-26032 SH 1 2-Concensate and FWCI 25202-26032 SH 2 3 Fuel Peoi_ Cooling. and Filtering 25202-26032 SH 3 1 CR0 Hycraul.ic and Head Cooling Systems 25202-26032 SH 4 4
.LPCI Containment Ccoling 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 'I
- Core' Spray Cooling System 25202-26032 SH 9 2 Service-Water System 25202-26032 SH 10 1
. Reactor Builcing Closec Ceciidg 25202-26032 SH 11 2 Water System
. Standb'y Gas ~and Atmosphere Centrol System 25202-26032 SH 12 2 Shutdown. Cooling System 25202-26032 SH 13 1 I #
e d 4 8 45 m
ATTACHMENT 3
- 1. In a relief request (Item 2.1.1), the licensee has proposed to use a vibration , signature program to mon + tor pump concition instead of easuring displacement v.ibration amplitude as per Section XI. We recommend relief not be granted because it is not consistent with the
. current NRC position.
- 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. We recommend relief not be granted because it is not consistent with the current NRC position on using the vibration signature. analysis program.
- 3. We feel the followinc relief requests have not provided adequate
' technical justification for grant _ing relief.
2.2.1 2.4.1 2.4.3 3.2.1.1 3.3.1.1 3.3.2.1 5 3.10.1.2 2.11.1.4
- 4. In a relief request (Item 3.2.2.1), the licensee has proposed an alternate testing program for all containment isolation valves of ,
exercising per-their Tech Specs and leak-rate testing per their. estaolished Appendix J procedures. We agree with leak-rate testing
- per tne estaolished crocedures, bewever, we feel the licensee should meet the requirements of Section XI IWV-3420(f) and (g)(2). We also -
feel the Tech Spec exercising of the containment isolation valves does not gi_ve proper assurance that all these valves will be exercised as recuired by the Code. 46' b
y.+ W}P
- 5. In the following relief requests we agree with the basis for relief, however,-we do not agree with the testing interval and recommend that relief not be granted.
' 3. 4.'1.1 4
3.7.1.1 ' 3.9.1.1
- 6. In a relief recuest (It'em'3.10.1.1), the licensee requested relief from. exercising reautrements 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 tne requirem,ents of the Code. We recommend these valves be categorized as A/C and A respectively and exercised according to Section XI with leak-rate testing per' Appendix J.
- 7. The ifcensee did not ineTude Diesel and Fuel Cil-Transfer System pumps or valves or Diesel Air Start System valves in their IST program, nor did they provide us with P&ID's or information to allow us to evaluate these systems. We feel that these system's pumps and valves perform a function that is important to safety and should be included in the IST program and tested in accordance with the Code requirements.-
S. 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 en to indicate that valve 1-IA-124 would then be removed from the IST program. It is our opinion that valve 1-IA-124 should not be removed from the program; since valve 1-IA-130 is retained as part of Ethe IST program, it appears that the backup air supply has been taken 47
v + 1 i il 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. Tne licensee has reI.ested relief (Item 3.5.1.1) frcm tne exercising recuirements of Section XI for valves 1-CS-5A and 55, core spray acr.ission' valves. Their proposed alternate test is to exercise these valves at cold shutdown and leak-rate test per Appendix J at refueling Outage. We agree with all portions of the basis except the Appendix J testing. We feel that since 1-CS-5A and 5B also serve as pressure isolation valves, they should 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 loop inboard stop valves. The proposed alternate test is.to exercise these valves at cold shutdown and leak-rate test per Appendix J at_ refueling outage. We feel that since 1-LP-10A and 10B also serve as cressure isolation' valves, they should be leak tested per Section XI of tne ASME Code as well as Appencix J. 4 48
/);7
..ma, ATTACHMENT 4 The below items appear.to be inconsistencies in the Millstone
'IST program. These items were noted in our review of the program submitted cy Northe'ast Nuclev Energy Comoany. We feel tnat to make the program correct and complete, these items should be corrected.
.1. In Table IWV-1, page 26, the licensee has indicated that valves 1-FW-9A, 98, 10A and 108, feedwater inside anc outsice containment check valves, wculd be verified open ovarterly and that a relief reauest for the leak-rate testing recuirements had been issued. A relief request was not located addressing the ceviation from the Code.
- 2. The licensee has indicated that a relief recuest (IWV-1, page 56) has been generated for the leak-rate testing requirements of Section XI for valves 1-SD-1, 2A, 2B, and 5, shutcown cooling isolation valves.
A relief request was not located.
- 3. In Tabie IWV-1 (page 62), the licensee has indicated that valve 1-IA-68, instrument air stop is passive. We feel this valve is not passive and.snould be exercised per Section XI or relief requested.
In Table IWV-1 (page 61), the licensee has incicated that
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4 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 and a relief request for the leak-rate test was not located. L, 5. In Table IWV-1 (page 61), the licensee has indicated that valve 1-SM-1, reactor sampling isolation valve, is passive and that it
- would be exercised cuarterly and leak-rate tested. We feel this valve
. is not passive and snould be stroke timed and position indicator verification tested.
- 6. 'In Table IWV-1 (page 61) the licensee has indicated that valve 1-SM-2, reactor coolant sampling valve, is passive and that it would be 49 U . _ _ _ - _ _ - - . _ _ _ - - _.
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exercised and stroke timed. We feel this valve is not passive and also needs to be leak-rate tested and position indicator verification tested. F 7. In NN$CO 'J. G. Counsil S,enior Vice President's letter to Mr. Dennis Crutchfield, Director of Nuclear Reactor Regulation, Chief Cperating-Reactors Branch No. 5, U.S. Nuclear-Regulatory Commission,
- dated June 22, 1982, it was indicated that valves 1-IA-99A through F,
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instrument air to accumulators, would be exercised and leak tested at refdeling cutages (Item No. 2). A specific relief recuest needs to ce written to cover this deviation from the quarterly exercising requirements. 1 e C u 50 b'
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NRC Peru 335 ett 49 U.S. NUCLEAR REGUL ATORY COMMIS$10N BIBLIOGRAPHIC DATA SHEET EGG-EA-6326 4 TITLE AND SUBTITLE 2. Iteave otanal Safety Evaluation Report, Pum0 and Valve Inservice Testing Program, Millstone Nuclear Power Station, Unit} J RECIPIENT'S ACCESS 10N NO
- 7. AvTMOR SD L S. OATE REPORT COMPLETED ucNTH lvEaR H. C. Rockhold. H. 4. Steceberg luno 10M
- c. Pi a c C a .9:N4 ORG AN C ATION N AME ANO V AILING ADD RE SS #ac'ude l a Cooe/ O ATE REPO*' *SSUED
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McNT= l*Eaa EG&G Idaho, Inc. e <t,, , ,,,,,
- Idaho Falls, ID 83415 8 (Leave ao"kI
*: $2CNSOR:NG ORG ANIZ ATION N AVE AND YAILING ADORESS fiae' woe Ia Coces
- 10. PROJE CT/ TASK. WORK UNIT NO Civision of Engineering Office of tanclea, coacter Reaulation ii riN NO.
U.S. Nuclear Regulatory Commission Washington, DC 20555 A6445 t 1: T>>E OsREDORT- *E nico cove nE O Unctussve 2stest 14 Itasw aan= # , l 15 Sv PP'.E ME N T A R Y N OTE S I
- 16. ABSTR ACT 200 voros or sess)
This EG&G, Inc, report presents the results of our evaluation of the Millstone Nuclear Power Station, Unit I Inservice Test Program for safety-related pumps and valves. g 17 KEY WOROS AND DOCUMENT AN ALYSIS 17. OESCRIPTORS 8 4 3 7s tOENTt FIE RS ~ OPE N ENDE D TE RMS 18 AV AIL ABtLITY ST ATEVENT t9 SE CURITY .'L ASS (Ta.: reo ore r :t NO CS P AGE S Unclassified 20 < =cuai Tv CL Ass ira.n os,i l22 *R.CE Unlimited Unclassified i > Ncc sonu sas m en}}