ML20136G294
| ML20136G294 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/07/1994 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20136C539 | List:
|
| References | |
| FOIA-96-485 NUDOCS 9703170258 | |
| Download: ML20136G294 (75) | |
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i ENCLOSURE 1 i
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM REQUESTS FOR RELIEF j
FLORIDA POWER & LIGHT COMPANY i
ST. LUCIE PLANT. UNIT 2 j
DOCKET NUMBERS 50-389 L
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1.0 INTRODUCTION
i The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing j
(IST) of certain ASME Code Class'1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME 8 oiler and Pressure Vessel Code and applicable addenda, except where alternatives have been authorized or relief'has-l been requested by,the licensee and granted by the Commission pursuant to Sections (a)(3)(1), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of_ quality and safety; or (3) conformance is impractical for its facility.
NkC guidance contained in Generic Letter (GL) 89-04, Guidaace on Developing Acceptable Inservice Testing Programs, provides alternatives to the i
. Code requirements determined acceptable to the staff.
i Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings. The NRC staff's findings with respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).
Furthermore, in rulemaking to.10 CFR 50.55a effective September 8,1992, (see 57 Federal Reaister 34666), the 1989 edition of ASME Section XI was incorporated in j (b) of 5 50.55a. The 1989 edition provides that the rules for IST of pumps and valves shall meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Re' actor Power Plants,".and Part 10.(OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants."
Pursuant to (f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and subject to Commission approvai. Because the alternatives meet later i
l editions of the Code, relief is not' required for those inservice tests that are conducted.in accordance with OM-6 and OM-10, or portions thereof, provided all related requirements are met.
Whether all related requirements are met is
' subject to NRC inspection.
The IST program evaluated in this SE covers the second ten-year IST interval for St. Lucie Plant,-Unit 2.
The. interval began August 8, 1993, and ends August 8, 2003. The second ten-year interval'IST program is based on the requirements of the 1986 Edition of the ASME Section XI Boiler and Eressure vessel Code which was incorporated by reference.in f 50.55a(b) by Volume 53 Federal Re'aister 16051, dated and' effective May 5, 1988.
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9703170258 970301 PDR FOIA BINDER 96-485 PDR l
e certain relief requests were approved for an interim period of one ye'ar, or until the next refueling outage, whichever is later, in a Safety Evaluation (SE) issued August 23, 1993, relating to the first ten-year interval. In that SE, the staff indicated that the interim period could continue into the second ten-year interval in order to give the licensee a period of time to address the issues and determine the appropriate long-term action.
lhe SE also directed the licensee to implement the updated IST program developed for the second ten-year interval at the second interval start date in accordance with the requirements of 10 CFR 50.55a(f)(4)(ii).
The IST program submittal includes 14 relief requests for pumps covering all 22 pumps, 31 relief requests covering 85 valves, and 31 cold shutdown justifications covering 85 valves. The valve table lists approximately 436 valves.
l 2.0 EVALUATION The Mechanical Engineering Branch, with technical assistance from Brookhaven National Laboratory (BNL), has reviewed the information concerning IST program requests for relief submitted for. the St. Lucie Plant, Unit 2, in Florida Power
& Light Company's letter dated August 3, 1993.
The staff adopts the evaluations and recoamendations for gr:nting relief or authorizing alte natives contained in the attached Technical Evaluation Report (TER) prepared by BNL.
Relief is panted from, or' alternatives are authorized to, the testing requirements which have been determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety.
Certain relief requests have been approved pursuant to 10 CFR 50.55a (f)(4)(iv) where it has been determined that the proposed alternative is in accordance with the requirements of the 1989 Edition of ASME Section XI, and therefore, relief from Code requirements is.not required. When an alternative is approved pursuant to (f)(4)(iv), any applicable related requirements, as listed in the TER, must be implemented, and such implementation is subject to NRC inspection.
A summary of the NRC actions is provided in Table 1.
The IST program relief requests which are granted, authorized, or approved are acceptable for implementation provided the action items identified in Section 5 of the TER are addressed within one year of the date of the SE or by the end of the next refueling cutage, whichever is later, including the interim relief requests approved in the August 23, 1993, SE.
Additionally, the granting of relief is based upon the fulfillment of any commitments made by the licensee' in its basis for each relief request and the alternatives proposed.'
Program changes involving new or revised relief requests should be submitted to the NRC. Programs changes that meet the positions in GL 89-04, Attachment 1, may be implemented provided the guidance in GL 89-04, Section D, is followed.
Program changes that add or delete components from the IST program should be periodically provided to the NRC.
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I 3.0 RELIEF - REQUEST VR-13. SAFETY INJECTION TANK TO REACTOR COOLANT SYSTEM CHECK VALVES V-3215. V-3225. V-3235. AND V-3245. AND RELIEF REQUEST VR-14. SAFETY INJECTION HEADERS TO REACTOR COOLANT SYSTEM CHECK VALVES V-3217. V-3227. V-3227. AND V-3247 j
In addition to the evaluations in Section 3.2.2 and 3.2.3, and discussion in j
Action Items 4.9 and 4.10, of the TER, the staff provides the following information for the licensee to consider in evaluating the extension of the i
disassen.bly and inspection for the safety injection tank discharge check valves and the safety injection headers check valves.
l Disassembly and inspe~ction of a check valve is not considered a true substitute for an operability test conducted under operating flow conditions, but is allowed when no other means for testing is available.
Under operating conditions the i
valve internal parts are subjected to dynamic flow loads, pressure gradients,
. temperature gradients, and flow-induced and system-generated mechanical j
vibration.
Pipe loading on the valve body can affect the alignment of valve internal parts. Any of these conditions, or a combination of these conditions, 4
j can alter the valve performance and the effects could be diagnosed during
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operational testing., However, these operating conditions are not duplicated, and the results may not be apparent, in a disassembly and inspection effort. There have been instances where ' operational problems were. discovered after i
disassembly / inspections. There are also examples of latent problems caused by 1
the disassembly and inspection efforts, such as installing a bonnet-hung check
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valve is an incorrect orientation. Certain of these problems could be identified during a p.artial-flow test or a leakage test following disassembly / inspection, if performed.
In the past, conditions limiting testing of certain check valves justified the use of disassembly and inspection since no other-practical test method was available. With the acceptance of.nonintrusive methods and the development of other test methods, this ju' tification requires a re-examination (reference s
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NUREG/CP-0123, " Proceedings of the ~ Second NRC/ASME Symposium on Pump and Valve Testing").
GL 89-04,' Position 2, was developed prior to wide-spread use of 4
nonintrusive techniques.
It allowed disassembly and inspection (D&I) conditionally wh'en other methods were. impractical;' however, in the public meetings, in response to questions on use of D&I, the staff indicated the use of other alternate techniques, including nonintrusives, were under investigation and were being encouraged by NRC. Allowing D&I on a sampling basis was an extension of the Code required time interval for valve testing. The D&I sample was small and valves in the group were identical in type, size, service conditions, exposure to operating environments, and age. The GL 89-04 sampling interval extension was justified on the basis that one valve in the group would be examined during e'ach refueling outage and the performance of each valve in the group was representative of-all the others.
GL 89-04, Position 2,' allowed the use of a limited sampling plan to reduce the burden on the licensee to D&I all valves in the group during each refueling. The sampling plan allowed that only one valve in each group be D&I at each refueling
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rather. than disassembling and inspecting all valves in the group. The sampling plan further allowed a different valve in the group be D&I at each refueling and
.the process be repeated until all valves were inspected.
With an 18-month -
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l operating fuel cycle, this would ensure that no valve D&I interv'al would be greater than six years. Position 2 also suggested conditions of extreme hardship for ansideration in extending the inspection interval beyond once every 6 years.
In Position 2 the staff, in part, stated "[i]n order to support extension of the valve disassembly and inspection interval to longer than once every 6 years, the licensee should develop the following information:
"a.
Disassemble and inspect each valve in the grouping and document in detail and the condition of each valve and the valves's capability to be full stroked...."
l Although GL 89-04 suggested information to be considered by the licensee in Jeveloping justification for an interval extension it was not all inclusive. The staff expected the licensee would conduct an in-depth review of all the safety J
effects as discussed during the public meetings.
The staff expectations for justification of an interval extension were amplified in the responses to questions during the GL 89-04 public meetings.
Included in the staff justification expectations was a licensee's detailed evaluation of the effects on public safety, the maintenance history, service history, and other information relative to valve reliability and that the review and evaluation would rely on known and recorded valve condition of each valve from previous inspection data rather than subjective qualitative judgement. The licensee's justification fo'r extending the inspection interval appears to be based on concerns of mid-loop operation.
The evaluation presented in the relief ' request is considered inadequate for justifying extending the inspection interval,per the guidance delineated in GL 89-04, Position 2.
Further, the concerns regarding personnel exposure and potential loss of decay heat removal are the result of performing disassembly and inspection.
In addition to attempting to provide additional justification to comply with GL 89-04, Position 2, for the extreme hardship of performing D&I each refueling outage, the licensee should consider the advantages.
of other test methods available, including nonintrusive techniques, to reduce exposure and avoid the potential loss of decay heat removal. A discussion of the resul.ts of the efforts'to apply other testing techniques should be included in the licensee's response to Action Items 4.9 and 4.10.
4.0 RELIEF RE0 VEST VR-28 AND'AN0MAlY 5.15 In addressing the use of installed flow elements or non-intrusive techniques for testing the applicable valves, the licensee may consider the use of non-intrusive techniques to periodically verify that the flow during the quarterly tests is adequate to full-stroke the valves.
This approach would allow credit for the quarterly test and could elimin. ate the need to perform the flow test during refueling outages.
The relief request meets the requirements of OM-10 for deferral of testing, but has been identified as an.open item for the licensee to comment on the installed flow instruments shown on the system piping and instrument diagram, which would also be a means of meeting the test requirements during quarterly pump testing.
5.0 CONCLUSION
The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, Brookhaven National Laboratory (BNL).
The Technical Evaluation Report (TER) provided as Attachment 1 is BNL's evaluation of the licensee's IST program relief 4
i requests.
The staff has reviewed the TER and concurs with the eval'uations and recommendations for granting relief or authorizing alternatives. A summary of
-the relief request determinations is presented in Table 1.
The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the i
alternatives proposed.
Implementation of the IST program is subject to inspection by NRC.
Relief requests which are in accordance with the 1989 Edition of ASME Section XI (which incorporated OM-6 and OM-10) have been approved pursuant to 10 CFR 50.55a 1 (f)(4)(iv) as listed in Table 1; however, because these meet the Code requirements, these are listed as " relief is not required." Certain other relief requests are authorized for an interim period to provide the licensee a period of time to review the testing and address long-term actions.
Section 4 of the TER provides BNL's evaluation of valve testing deferral justifications with anomalies identified in Section 5.16 of the TER.
n The licensee should refer to the TER, Section 5, for a di'scussion of IST program anomalies identified during the review. The licensee should review and address, 1
as necessary, all items in accordance.with the guidance therein. The IST program relief requests are acceptable for implementation provided the action items identified in Section 5 of the TER are addressed within one year of the date of j
this SE or by the end of the next refueling outage, whichever is later, including the interim relief requests approved in the August 23, 1993, SE. The licensee
. should respond to the NRC within one year of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address,each of these items.
The staff concludes that the relief. requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions. The staff has determined that granting relief ~ pursuant 'to 10 CFR 50.55a (f)(6)(1),
authorizing alternatives pursuant to 10 CFR 50.55a (a)(3)(1) and (a)(3)(ii), and approving alternatives pursuan.t to 10 CFR 50.55a (f)(4)(iv) is authorized by law and will not endanger life or property,. or the common defense and security and is otherwise in the public interest.
In making this determination, the staff has considered the impracticality of performing the required testing and the burden on the licensee if the requirements were imposed.
Principal Contributor:
Patricia Campbell, DE/EMEB 5
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ENCLOSURE 2
.SALP INPUT Facility Name St. Lucie Unit 2 J
Eummary of Review Activity l
The review covered the inservice testing program submittal for the plant's second ten-year interval which began August 8, 1993, and ends August 8, 2003.
Narrative Discussion of Licensee Performance The program seemed to be comprehensive, adequately-focused on safety, provided technical justification where appropriate, and was, in general a quality document.
There were a few issues identified which will require additional action by the licensee over the next refueling cycle'.
ORIGINATOR: Patricia Campbell.
DATE: February 1994 9
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St. Lucia Linit 2-SE ~ Tst, Summary cf Ralist Rzqusets l
Relief Request TER
.Section XI Requirement Equipment Proposed Alternate NRC Action No.
Sect.
Identification Method of Testing L
i PR-1 2.1.1 IWP-330C, 4310, Measurement All pumps None.
Reli3f not required per
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of numo t,earina temperature 650.55a 1(fif4)fiv).
PR-2 2.1.2 IWP-4120, Instrument range Various pumps Use portable instruments with Authorized in accordance f
reading accuracy of 2% for with $50.55a 1(a)(3)(i), with speed.
provisions.
i PR-3 Reauest withdrawn PR-4 IWP-3100, Measurement of Auxiliary Feedwater Measure AP and vibration Granted in accordance with flowrate quarterly Pumps quarterly, measure flowrate, AP Generic Letter 89-04, f
and vibration at cold shutdowns.
Position 9.
PR-5 IWP-3100, Measurement of Boric Acid Makeup Meastre AP and vibration Granted in accordance with
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flowrate quarterly Pumps quarterly, measure flowrate AP Generic Letter 89-04, and vibration at refueling Position 9.
outaaes.
PR-6 IWP-3100, Measurement of Containment Spray Measure AP and vibration Granted in accordance with flowrate quarterly Pumps quarterly, measure flowrate, AP Generic Letter 89-04, and vibration at refueling Position 9.
outaaes.
i PR-7 Request withdrawn PR-8 2.2.1 IWP-3100, measurement of Boric Acid Makeup Calculate pump inlet and Authorized in accordance i
suction and differential pressure.
Pumps differential pressure based on with 550.55a 1(a)(3)(i), with
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tank level.
provisions.
I PR-9 IWP-3100, Measurement of High Pressure Safety Measure AP and vibration Granted in accordance with flowrate quarterly injection Pumps quarterly, measure flowrate, AP Generic Letter 89-04, and vibration at refueling Po.ition 9.
outar es.
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PR-10 IWP-3100, Measurement of Low Pressure Safety Measure AP and vibration Grmted in accordance with flowrate quarterly injection Pumps quarterly, measure flowrate, AP Generic Letter 89-04, a_n ; vibration at cold shutdowns Position 9.
PR-11 2.3.1 IWP-3100, Measurement of intake Cooling Water Calculate pump inlet and Authorized in accordance suction and AP.
Pumps differential pressure based on with $50.55a 1(a)(3)(i), with intake structure level.
provisions.
P R-12 2.2.2 IWP 4520(b), Vibration Charging Pumps Use instrumants with lower interim relief granted in
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instrument frequericy response frequency response of 10 Hz.
accordance with $50.55a rance.
1(f)f 6)(i) in 8/23/93 SE.
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Dt. Luria. Unit 2-SE 'Ttbl5 1-Suri y of R;llsf Requaata (Centinuad) t 6
c Relief Request TER Section XI Requirement Equipment '
Proposed Altemate NRC Action i
No.
Sect.-
Identification Method of Testing P R-13 2.3.2 IWP-4520(b), Vibration intake Cooling Water Use instruments with lower Int 3 rim relief granted in instrument frequency response Purnps frequency response of 10 Hz.
accordance with 650.55a I
rance.
1(f'f 6)fi) in 8/23/93 SE.
PR-14 2.4.2 IWP-4520(b), Vibration CS Hydrazine '> umps Use instruments with lower Interim relief granted in r
instrument frequency response frequency' response of 10 Hz.
accordance with 50.55a I
rance.
1(f)f6)(i) in 8/23/93 S E.
P R-15 2.4.1 IWP-3100, Measurement of Containment Spray and Calculate pump inlet and Authorized in accordance f
suction and AP.
Safety injection Pumps differential pressure based on with $50.55a 1(a)(3)(i), with f
tank level.
orovisions.
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_P R-16 Reauest withdrawn P R-17 2.4.3 IWP-3200, 3300, 4150, CS Hydrazine Pumps Measure vibration only Interim relief granted, with j
Measurement of flowrate quarterfy, and flowrate and provisions, in accordance j
quarterly and associated vibration. at refueling outages.
with.550.55a 1(f)(6)(i) in
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corrective actions.
8/23/93 SE.
ER-1 3.1.1 IWV-3412, 4315, 3522, All cold shutdown Test in accordance with OMa-Relief not required per
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exercise all cold shutdown valves 1988, Part 10,14.2.1.2 and 550.55a _1(f)(4)(iv).
frequency valves each cold 4.3.2.2.
shutdown.
f VR-2 3.2.1 IWV-3427(b), valve acceptance V-3217, 3227, 3237 Use requirements in Technical Relief not required per criteria for valves greater thart 3247, 3258, 3259 Specification for PlVs 50.55a 1(f)(4)(iv).
6 NPS.
3260, 3261, 3215, 3225, 3235, 3245, f
3524, 3525, 3526 L
3527, Safety injection pressure isolation valves f
VR-3 IWV-3417(a), Acceptance Fast-acting Power-Establish a maximum limiting Relief granted in ac~cordance criteria.
Operated Valves stroke time of 2 seconds.
with Generic letter 89-04, i
Position 6.
VR:4 3.3.1 IWV-3426 and 3427, Various CIVs Lcak test groups of valves.
Relief not required per Measurement of individual valves' 950.55a 1(f)(4)(iv).
seat leakaae.
VR-5 3.6.1 IWV.-3520, test frequency V-2177, 2190, 2191, Partial-stroke exercise at cold Relief not required per 2526, Boric acid makeup shutdowns and full-stroke
$50.55a.1(f)(4)(iv), provideo
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pumps to charging pump exercise at refueling outages.
all related requirements are suction check valves met.
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L St. Lucia Unit 2-SE Tabla 1-Sun y cf R111 f RIqusats (Centinu:;d)
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f Relief Request TER'-
~ Section XI Requirernent Equiprnent.
Proposed Alternate
. NRC Action No.
Sect.
Identification Method of Testing
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VR-6 3.6.2 IWV-3520, test frequency V-2443, 2444, Boric Part.al-stroke exercise Relief not required per i
acid makeup pumps to quarterly and full-stroke
$50.55a 1(f)(4)(iv), provided f
emergency boration exercise at refueling outages.
all related requirements are j
header check valves met.
J VR 7 3.6.3 IWV-3520, test frequency V-07000, 07001, RWT Partial-stroke exercise Relief not required per i
to LPSI pump suction quarterly and full-stroke
$50.55a 1(f)(4)(iv), provided
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check valves exercise at refueling outages.
all related requirements are
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met.
I VR-8 3.6.4
!WV-3520, test frequency V-3401, 3410, HPSI Partial-stroke exercise Relief not required per pump suction check quarterly and full-stroke
$50.55a 1(f)(4)(iv), provided valves exercise at refueling outages.
all telated requirements are met.
E VR-9 3.6.5 IWV-3520, test frequency V-3414, 3427 HPSI Partial-stroke exercise when Relief not required per pump discharge check SIT are filled and full-stroke
$50.55a 1(f)(4)(iv), provided valves exercise at refueling outages.
all related requirements are -
met.
VR-10 3.6.6 IWV-3520, test frequency V-3522, 3547. HPSI Full-stroke exercise at refueling Relief not required per
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pump discharge check outages.
650.55a 1(f)(4)(iv), providec l
valves all related requirements are' i
met.
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VR-11 3.6.7 IWV-3520, test frequency V-3113, 3133, 3143 Partial-stroke exercise when Relief not required per 3766, HPSI header to SIT are filled and full-stroke
$50.55a 1(f)(4)(iv), provided RCS check valves exercise at refueling outages.
all related requirements are met.
V R-12 3.6.8 IWV-3520, test frequency V-3524, 3535, 3526 Full-stroke exercise open at Relief not required per 3527, Si hot leg refueling outages. Exercise
$50.55a 1(f)(4)(iv), provided injection check valves closed per Technical Specification all related requirements are on PlVt.
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St. Lucia Unit 2-S E Tcbla 1-Sun
.y cf Rill;f R;quasta (Centinusd) t Relief Request TER Section XI Requirement Equipmerd Proposed Altemate NRC Action i
No.
. Sect.
Identification Method of Testing i
VR-13 3.2.2 IWV-3520, test frequency V-3215, 3225, 3235, Disassemble and inspect each Relief from exercising open 3245 SIT to Si header valve once every to years.
granted in accordance with check valves Exercise closed per Technical Generic Letter 89-04, Specification on PlVs.
Position 1 or 2 with 6
provisions. Relief from exercising cloted not required per $50.55a 1(f)(4)(iv),
provided all related l
reauirements are met.
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V R-14 3.2.3 IWV-3520, test frequency V-3217, 3227, 3237, Partial-stroke exercise at cold Relief.from exercising open
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3247 Safety injectiori shutdowns and refueling outages.
granted in accordance with header to RCS check Disassemble and inspect each Generic Letter 89-04, i
valves valve once every 10 years.
Position 1 or 2 with Exercise closed at cold provisions. Relief from shutdowns per Technical exercising closed not Specification en PlVs.
required.
V R* 15 3.6.9 IWV-3520, test frequency V-3258, 3259, 3260, Partial-stroke exercised open Relief not required per 3261, Safety injection and exercised closed when SIT
$50.55a 1(f)(4)(iv), provided header to RCS check are filled and full-stroke all related requirements are 7
valves exercise open at cold shutdowns.
met.
Exercise closed per Technical Specification on PlVs.
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VR 16 IWV-3427(b), valve acceptance CIVs greater than 6 nps.~ Test in accordance with IWV-Relief granted in accordance '
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criteria for valves greater than 6 3426 and 3427(a).
with Generic Letter 89-04, nos.
Position 10.
V R-17 Reouest withdrawn V R-18 3.6.10 IWV-3520, test frequency V-15328, Makeup water Verify valve closure every 2 Relief not required per supply CIV years in accordance with
$50.55a 1(f)(4)(iv), provided Appendix J.
all related requirements are i
met.
VR-19 3.6.11 IWV-3520, test frequency -
V 18195, Instrument Verify, valve closure capability Relief not required per air CIV every 2 years by 650 App. J 650.55a 1(f)(4)(iv). provided leak test.
all related requirements are met.
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S t.
LucI) Unit 2-S E Tcbla 1 -S u r.
y cf R;ll;f R:quxta (C:ntinu;d)
Relief Request TER Section XI Requirement Equipment Proposed Altem. ate NRC Action No.
Sect.
Identification Method of Testing VR-20 IWV-3520,19st frequency V-07119, 07120, RWT Partial-stroke exercise Relist granted in accordance to CS and SI suction quarterly. Disassemble and wit.1 Generic Letter 89-04, headers check valves inspect one valve each refueling Position 2.
outaae.
VR-21 3.6.12 IWV-3520, test frequency V-07129, 07143 Partial-stroke exercise Relief not required pet containment spray pump quarterly. Full-stroke exercise 650.55a 1(f)(4)(iv), provided discharge check valves each refueling outage.
all related requirements are met.
VR-22 IWV-3520, test frequency V-07172, 07174 Disassemble and inspect one Relief granted in accordance containment sump check valve each refueling outage.
with Generic Letter 89-04, valves Position 2.
V R-23 IWV-3520, test frequency V-07192, 07193, Disassemble and inspect one Relief granted in accordance containment spray valve each refueling outage.
with Generic Letter 89-04, header check valves Position 2.
VR ~24 3.6.13 IWV-3520, test frequency V-07256, 07258, Full-stroke test at refueling Relief not required per Hydrazine pumps to CS outages.
50.55a 1(f)(4)(iv),
pump suction check provided all related valves reauirements are mot VR-25 Request withdrawn VR-26 Reauest withdrawn VR-27 IWV-3520, test frequency V-9303, 9304, 9305, Partial-stroke exercise Relief granted in accordance AFW min. flow check quarterly. Disassemble and with Generic Letter 89-04, valves inspect one valve each refueling Position 2.
outaae.
V R-28 3.6.14 IWV-3520, test frequency V-3104, 3105, LPSI Partial-stroke exercise open Open item.
min. flow check valves quarterly. Back flow test at cold shutdowns. Full-stroke exercise at refuelina outaaes.
V R-29 3.2.4 IWV-3427(b), valve acceptance V-3480, 3481, 3651, Verify valve closure capability Relief not required per criteria for valves greater than 6 3652, Si PlVs.
in accordance with Technical 950.55a 1(f)(4)(iv).
nos.
Specification on PlVs.
t VR-30 IWV-3520, test frequency V-3102, 3103, HPSI Partial-stroke exercise open Relief granted in accordance min. flow check valves.
quarterly. Back flow test at cold with Generic Lotter 89-04, shutdowns. Disassemble and Position 2.
inspect one valve each refueling outaae.
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Ct. Lurie U;.it 2-CE Table 1-k n y cf R;ll:P Request 3 (Continued)
Relief Request TER-Section XI Requirement Equipment Proposed Ahmato
.NRC Action No.
Sect.
Identification Method of Tasting IWV-3520, test frequency U-08130, 08163, Fartial-stroke exercise Relief granted in accordance VR-31 Steam supply to-AFW monthly. Full-stroke exercise with Generic letter 89-04, turbine during refueling outages.
Position 2.
Disassemble and inspect one valve each refuelino outaoe.
VR 32 3.6.15 IWV-3520, test frequency V-3101, SITS to VCT Partial-stroke exercise during Relief not required per check valve cold shutdowns. Full-flow
$50.55a 1(f)(4)(iv), provided exercise at refueling outages.
all related requirements are met.
VR-33 3.4.1 IWV-3414(a), POVs acceptance SE-09-2, 3, 4, 5. FW.
Valves will not be ' trended for Relief not required per criteria solenoid valves alert testing" quarterly. Valves
$50.55a 1(f)(4)(iv), provided will be declared inoperative if all related requirements are stroke times exceed the
- met, maximum allowed stroke time.
During cold shutdowns, if a valve exceeds iw alert limit, it will be addressed prior to startuo.
V R-34 3.5.1 IWV-3414(a), POVs acceptance TCV-14-4 A and B.
Valves will not be
- trended for Relief not required per criteria Intake cocling water to alert testing" quarterly. Valves
$50.55a 1(f)(4)(iv), provided CCW HX temperature will be declared inoperative if all related requirements are control valves.
stroke times exceed the met.
maximum allowed stroke time.
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e 6
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TECHNICAL EVALUATION REPORT St. Lucie Unit 2 Florida Power and Light Company Pump and Valve Inservice Testing Program j
Revision 0, Second Ten-Year Interval i
Docket Number:
50-389 TAC Number:
M87207
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Prepared by:
A. Fresco and A. M. DiBiasio Engineering Technology Division Department of Nuclear Energy Brookhaven National Laboratory Upton, New York 11973
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l Prepared for:
P. L. Campbell, NRC Lead Engineer Division of Engineering Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 FIN L-2301, Task Assignment 7 January 20, 1994
ABSTRACT i
This report presents the results of Brookhaven National Laboratory's evaluation of the relief requests, cold shutdown justifications and, for selected systems, a review of the scope of the St.
Lucie Plant Unit 2's ASME Section XI Pump and Valve Inservice Testing Program.
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TABLE OF CONTENTS l
Abstraet iii l
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1.0 INTRODUCTION
1 2'. 0 PUM P IST PR OG RAM R ELI EF R EQUESTS.............................................................
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2.1 Ge neric Pu mp Relie f Req uests........................................................r.......
2 2.2 C h a r g i ng S y s te m........................................................................................
4 2.3 I ntake Cooling Wa te r System.................................................................
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2.4 Containment Spray and Safety injection Systems....................................
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l 3.0 VALVE IST PROGRAM RELIEF REQUESTS...............................................................
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3.1 Ge neric Valve R elief Requests..................................................................
11 3.2 Safety Injection Sy:4s.n............................................................................
12 3.3 Contain ment isolation Valves.....................................................................
23 3.4 A u xiliary F eed wa te r S yste m.....................................................................
25 3.5 intake Coolin g Water System..................................................................
27 3.6 De fe rral of Tes tin g to Re f ueling.................................................................
28 4.0 EVALU/ TlON OF COLD SHUTDOWN JUSTIFICATIONS........................................
46 5.0 IST PROGRAM RECOMMENDED ACTION ITEMS...................................................
61
6.0 REFERENCES
72
' APPENDIX A
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Technical Evaluation Report Pump and Valve inservice Testing Program S t.
Lucie Plant, Unit 2
1.0 INTRODUCTION
Contained herein is a technical evaluation of ASME Section XI pump and valve inservice testing (IST) program relief requests submitted by Florida Power and Light Company (FP&L) for its St. Lucie Plant, Unit 2. The St. Lucie Plant, Unit 2, is a Combustion t:ngineering Pressurized Water Reactor (PWR) that began commercial operation in August 1983.
FP&L submitted Revision 0 of the Second Ten-Year Interval inservice Testing Program on August 3,1993. This program revision supersedes all previous submittals. The second ten year interval extends from August 8,1993 to August 8,2003. The licensee states that'this program is based on the requirements of the 1986 Edition ~of the ASME Section XI Code.
A Safety Evaluation on Revision 2 of the initial Ten-Year Interval IST Program was issued by the NRC on August 23,1993, following the submittal of the second interval program.
Therefore, many of the required actions identified in the safety evaluation were not incorporated into the revised program. Additionally, interim relief wae granted for a period of
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time that extends into the 'second t.n-year interval.
Title 10 of the Code of Federal Regulations,950.55a (f) requires that inservice testing of ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific relief l
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has been requested by the licensee and granted by the commission pursuant to {50.55a (a)(3)(i), (a)(3)(ii), or (f)(6)(i).
Section 50.55a (f)(4)(iv) provides that inservice testing of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by referenc'e in paragraph (b) of $50.55a, subject to the limitations and modifications listed, and subject to Commission approval. In rulemaking to 10CFR50.55a, effective September 8,1992 (see Federal Reaister. Vol. 57 No.152, page 34666), the 1989 Edition of ASME Section XI was incorporated into paragraph (b) of 9 50.55a. The 1989 Edition provides that the rules for inservice testing of pumps and valves are as specified in ASME/ ANSI OMa-1988'Part 6 and 10, respectively. Relief is not required to utilize portions of OMa-1988 Parts 6 and 10, as modified in paragraph (b) of 650.55a, provided that all related requirements are met and subject to NRC approval. The implementation of related requirements is subject to NRC inspection.
The review of the relief requests was performed utilizing the Standaro Review Plan, Section 3.9.6; Generic Letter No. 89-04, " Guidance on Developing Acceptable Inservice Testing Programs;" and the Minutes of the Public Meeting on Generic Letter 89 04, dated October 25, 1989. The IST Program requirements apply only to component (i.e., pumps and valves) testing and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements.
Section 2 of this report presents the fourteeri pump relief requests and Brookhaven National Laboratory's (BNL) evaluation. Similar information is presented in Section 3 for thirty-one relief requests for the valve testing program. Relief requests that are authorized by Generic 1
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i Letter 89-04 are not specifically evaluated in this Technical Evaluation Report. l'iowever, any anomalies associated with the relief requests are addressed m Section 5 of the report.
Section 4 contains the evaluation of FPL's justifications to defer valve testing to cold shutdowns. Section 5 summarizes the recommended actions for the licensee, resulting from the relief request and deferred testing justification evalu'.n.ons, and the review of the IST Program scope for selected systems. BNL recommends that the licensee resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
2.0 PUMP IST PROGRAM RELIEF REQUESTS in accordance with 50.55a, FP&L has submitted fourteen relief requests for pumps at the St.
Lucie Plant, Unit 2 which are subject to inservice testing under the requirements of ASME Section XI. The relief requests have been reviewed to verify their technical basis and determine their acceptability. The relief requests, along w;m Ine technical evaluation by BNL, are summarized below.
2.1
.Qeneric Pumo Relief Reauests 2.1.1 Pump Relief Request No. PR 1, All Pumps in the Inservice Test Program Relief Request: The licensee requests relief from the requirements of the ASME Code'.Section XI, IWP 3300 and IWP-4310, which state that the temperature of all centrifugal pump bearings outside the main flow path and of the main' shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperature of the bearings.
Proposed Alternate Testing: None.
Licensee's Basis for Reliet. The licensee states that: "A yearly bearing temperature measurement does not contribute to the monitoring of - mp operational readiness during its service life. Concerns regarding extended pump runs while on mini-flow recirculation and ALARA concerns outweigh any benefits obtained from one yearly temperature data point.
The data associated with bearing temperatures taken at one-year intervals provides little statistical basis for determining the incremental degradation of a bearing or any meaningful trending information or correlation. In many cases the pump bearings are water < x> led and thus, bearing temperature is a function of the temperature of the cooling medium, which can wry considerably. Vibration measurements are a significantly more reliable indication of pump bearing degradation than are temperature measurements. All pumps in the program are subjected to vibration measurements in accordance with IWP-4500. Although excessive bearing temperature is an indication of an imminent or existing bearing failure, it is highly unlikely that such a condition would go unnoticed during routine surveillance testing since it would manifest itself in other obvious indications such as audible noise, unusual vibration, increased motor current, etc. Any potential gain from taking bearing measurements, which in most cases would be done locally using portable instrumentation, cannot offset the cost in terms of dilution of operator effort, distraction of operators from other primary duties, excessive operating periods for standby pumps especially under minimum flow conditions, and 2
unnecessary personnel radiation exposure. Based on the reasons similar to those set forth above, the ASME deleted the requirement for bearing temperature measurement in ASME OM Code, Subsection ISTB, the revised version of the Code for pmp testing."
Evaluation: Section 50.55a (f)(4)(iv) provides that inservice tests of pumps may meet'the requirements set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of 50.55a, subject to the limitations and modifications listed, and subject to Commission approval. Portions of editions or addenda may be used provided that all related eequirements of the respective editions or addenda are met. The staff imposed no limitations to OMa-1988 Part 6.
Measurement of bearing temperatures is not required by ASME/ ANSI OMa-1988, Part 6, for inservice testing of pumps. Therefore, relief is not required, and the alternative is recommended for approval pursuant to 650.55a 1 (f)(4)(iv).
2.1.2 Pump Relief Request No. PR 2, Various Pumps Relie/ Request: The licensee requests relief from the ASME Code,Section XI, IWP-4120, which requires that the full-scale range of each instrument shall be three times the reference value or less. This relief request applies to only portable instruments used for = peed measurement. Many of the portable instruments used have digital readouts with multiple scales.
Proposed Alternate Testing Whenever portable instruments are used for measuring pump speed, the instruments will be such that the ' reading" accuracy is at least 2 percent.
Licensee's Basis for Reliet. The licensee states: " Table IWP-4110-1 requires the accuracy of instruments used to measure speed to be equal to or better than 2 percent for speed, based on the full scale reading of the instrument. This means that the accuracy of the measurement can vary as much as 6 percent, assuming the range of the instruments extended to the allowed maximum. This IST pump parameter is often measured with portable test instruments where commercially available instruments do not necessarily conform to the Code requirements for range. In this case, high. quality calibrated instruments will be used where the ' reading
- accuracy is at least equal to the Code-requirement for full-scale accuracy. This will ensure that the measurements are always more accurate than the accuracy as determined by combining -
the requirements of Table IWP-4110-1 and Paragraph IWP-4120."
Evaluation: Section XI. Table IWP-41101 requires that speed instrumentation have an accuracy of 2% of full scale and IWP-4120 requires that the full scale range of each instrument be three times the reference value or less, This would result in an instrument reading accuracy of 6% of the reference value or better.
The t'9C does not consider installation or replacement of instruments an undue burden, and compliance with later editions of the Code for instrumentation requirements is not a backfit.
However, if instrumentation is available which meets the mtent of the Code requirements for the actual reading, the use of such instrumentation provides an equivalent level of quality and safety for testing. When the range of an instrument is greater than 3 times the reference value, but has an accuracy more conservative than the Code, the combination of the range and 3
accuracy provides a reading accuracy equivalent or better than the reading accuracy that would be achieved from instrumentation which meets the Code requirements.
Therefore, based on the readir.g accuracy of the speed instruments meeting the accuracy requirements of IWP-4110, it is recommended that the licenseek alternative testing be authorized in accordance with 10 CFR 50.55a(a)(3)(i). When using temporary instruments, the licensee should ensure that the instrurients are calibrated prior to use and are traceable to the inservice test records.
2.2 Charalna System l
2.2.1 Pump Relief Request PR 8, Boric Acid Makeup Pumps 2A, 2B Relief Request The licensee requests relief from the ASME Code,Section XI, IWP-3100, which rNuires that each inservice test shallinclude the measurement of suct.on'and differential pressure, for the Boric Acid Makeup Pumps 2A and 28.
Proposed Altemate ' Testing: The Boric Acid Makeup Pump suc$on pressures will be calculated based on the height of liquid in the associated tank once during each inservice test.
Subsequently, these calculated values will be used to determine pump differential pressures for evaluation of pump parameters.
Licensee's Basis for Relief: The licensee states that: "The system installation does not provide any mechanism for measuring pump suction pressure, and thus, the requirement for measuring suction pressure and pump differeniial pressures cannot be satisfied. A measure of pump suction pressure can, however, be determined by a calculation using the height of liquid in the boric acid makeup tanks. Since there is essentially fixed resistances between the tanks and the pumps this will provide a consistent value for suction pressures.
l Since the tank levels are not expected to vary significantly during the tests, tank level and' associated calculations will only tie taken once during each test instead of prior to pump operation and during operation, as rvquired by Table IWP 31001."
Evaluation: A review of the licensee's drawing 2998 G-078, Sheet 121, ' Flow Diagram -
Chemical & Volume Control System (Sheet 2)," Revision 5, dated 10/20/89, indicates that there is no instrumentation to directly measure suction pressure of the Boric Acid Makeup pumps. Instead, the licensee proposes to use the height of liquid in the Boric Acid Makiup Tanks J
to determine pump suction pressure.
Lack of instrumentation is not sufficient justification for not complying with Code requirements, as discussed in response to question 105 of the Generic Letter 89-04 public meeting minutes. However, calculation of inlet pressure based on the measured tank level would provide an acceptable alternative method of determining inlet pressure, provided the calculation is properly proceduralized, and the accuracy is within the accuracy required by the Code using direct measurement.
Based on the alternative providing an acceptable level of quality and safety, it is recommended that the alternative be authorized in accordance with 50.55a (a)(3)(i), provided that the 1
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accuracy of the reading scale of the level measurement is within Code requirements and the calculation method is properly proceduralized.
2.2.2 Pump Relief Request PR-12, Reactor Coolant Charging Pumps 2A, 28, and 2C Relie/ Request: The licensee requests relief from the ASME Code,Section XI, IWP-4520(b),
which requires that the frequency response range of the readout system (for instruments used to measum vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed, for the Reactor Coolant Charging Pumps 2A,28 and 2C, Proposed Alternate Testing: Vibration will be measured as required by IWP-4510, except that the lower frequency response for the instruments will be 10 Hz, for an interim period (until March 1994).
Licensee's Basis for Relief: The licensee states that: "The reactor coolant charging pumps operate at approximately 210-215 RPM which equates to a rotational frequency of 3.5 Hz. In 1
accordance with the ASME Code, the frequency response for the vibration instruments would have to be one half of this or 1.75 Hz. Following an extensive investigation of available and potentially suitable instrumentation, it has been determined that instruments satisfying this requirement for the charging pumps are commercially unavailable."
j Evaluation: The charging pumps operate at very low speeds.Section XI,1 IWP-4520(b),
requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimurn speed to at least maximum pump shaft rotational speed for all pumps. Additionally, OMa-1988 Part 6 now requires that the frequency response range of the vibration measuring transducers and their readout system to be from one third minimum pump speed to at least 1000 Hz, in order to more adequately envelop all potential noise contributors. The lower limit of the range is to allow for detection of problems sucn as bearing oil whirl and looseness of bearings.
The licensee has proposed using vibration instrumentation that cannot measure subharmonic or the first or second harmonics. The licensee has stated that instrumentation that complies with the Code is commercially unavailable. However, equipment with a frequency response of less than 10 Hz is available. Tha licensee has requested an interim period of seven months to procure instruments that meet the ' Code requirements or provide justification for the continued use of existing instruments. A Safety Evaluation (SE) addressing Revision 2 of the First Ten-Year Interval IST Program was issued by the NRC on August 23,1993. This SE granted relief to use the existing instruments for one year, or until the next refueling outage, whichever is later. Per the SE, the interim relief remains in effect into the Second Ten Year intarval.
Therefore, the licensee's current request is ccvered by the August 23,1993 SE.
2.3 Intake. Coolino Water System 2.3.1 Pump Relief Request PR 11, intake Cooling Water Pumps 2A, 28, 2C Relief Request: The licensee requests relief from the ASME Code,Section XI, IWP-3100, which requires that each inservice test shall include the measurement and observation of
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suction and differential pressure, for the intake Cooling Water Pumps 2A,2B and dC.
Proposed Alternate Testing: During testing of these pumps, one value of inlet pressure will be calculated based on water level at the inlet structure.
Licensee's Basis for Relief: The licensee states that: "The pumps listed above are vertical line snaft pumps submerged in the intake structure with no practical means of measuring pump inlet pressure. The inlet pressure, however, can be determined by calculation using. as inpyt, the measured height of water above the pump inlet as measured at the intake.
During each inservice test, the water level in the intake pit remains relatively constant, thus only one measurement of level and the associated suction pressure calculation need be performed."
Evaluation: A review of the licensee's drawing 2998-G-082, " Flow Diagram - Circulating and
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Intake Cooling Water System," Revision 23, 10/20/89, indicates that there is no instrumentation to directly measure the inlet pressure of the intake cooling water pumps. Lack of instrumentation is not sufficient justification for not complying with Code requirements, as discussed in response to question 105 of the Generic Letter 89-04 meeting minutes. However, calculation of inlet pressure based on the measured inlet structure level would provide an acceptable alternative method of determining inlet press.ure, provided the calcu:ation is properly proceduralized, and the accuracy is within the accuracy required by the Code using direct measurement.
Based on the alternative providing an acceptable level of quality and safety, it is recommended that the alternative be authorized in accordance with 650.55a (a)(3)(i), provided that the accuracy of the reading scale of the level measurement is within Code requirements and the calculation method is properly proceduralized.
2.3.2' Pump Relief Request PR-13, intake Cooling Water Pumps 2A, 28, 2C Relief Request: The licensee requests reliet from the ASME Code,Section XI, IWP-4520(b),
which requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed, for the intake Cooling Water Pumps 2A,28, and 2C.
Proposed Alternate Testing: For an interim period (until March 1994), vibratir'n will'be measured as required by Section XI, IWP-4510, except that the lower frequency response for the instruments will be 10 Hz.
Licensee's Basis for Relief: The licensee states that: "The St. Lucie Plant completed a major upgrade to its ASME pump vibration program in August 1991 to better comply with the Code.
As part of the upgrade, new vibration instruments were purchased. The instruments were chosen for their ease of use and reliability; however, the instrument's lower frequency response does not comply with the Code when used on the Intake Cooling Water pumps. The intake cooling water pumps operate at a shaft speed of approximately 885 RPM. Based on this
' speed and the Code requirement, the instrumentation used to measure vibration (disniacement) would require a response range down to 7.38 Hz. The new instruments are capable of a lower 6
1 frequency response to 10 Hz,2.62 Hz higher than the Code.'
l Evaluation: The intake cooling water pumps operate at very low speeds. The shaft rotational speed is 885 RPM.Section XI, IWP-4520(b), requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude). shall be from one-half minimum speed to at least maximum pump shaft rotational speed for all pumps.
Additionally, OMa-1988 Part 6 now requires that the frequenc'/ response range of the vibration measuring transducers and their readout system to be from one-third minimum pump speed to at least 1000 Hz, in order to more adequately envelop all potential noise contributors. The lower limit of the range is to allow for dctection of problems such as bearing 3
oil whirl and looseness of bearings.
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The pump's shaft speed translates to a frequency of 14.75 Hz Therefore, the code required i
frequency range is 7.38 Hz to 14.75 Hz. By measuring an actual frequency range of 10 Hz to 14.75 Hz, the licensee is measuring only 64.36% of the code required range. The licensee has requested an interim period of seven months to procure instruments that meet the Code requirements or provide justification for the continued' use of existing instruments. A Safety Evaluation (SE) addressing Revision 2 of the First Ten-Year interval IST Program was issued 4
by the NRC on August 23,1993. This SE granted relief to use the existing instruments for one year, or until the next refueling outage, whichever is later. Per the SE, the interim relief remains in effect into the Second Ten Year Interv sl. Therefore, the licensee's current request is covered by the August 23,1993 SE.
2.4 Containment Sorav and Safety inlection Systems 1
2.4.1 Pump Rollef Request PR-15, Containment Spray Pumps 2A and 2B; High Pressure Safety injection Pumps 2A and 2B; and Low Pressure Safety injection Pumps 2A and 2B Relief Request: The licensee requests relief from the ASME Code,Section XI, $ IWP-3100, which requires that each inservice test shall include the measurement and observation of suction and differential pressure, for the 2A and 2B Containment Spray, High Pressure Safety injection, and Low Pressure Safety injection Pumps.
Proposed Altemate Testing: During the quarterly pump tests, the pumps' suction (inlet) pressures will be calculated based on the height of liquid in the, associated tank. Subsequently.
these calculated values will be used to determine pump differential pressure's for evaluation of pump parameters.
During the cold shutdown or refueling substantial flow testing of these pumps, temporary suction gages will be installed to measure pump suction pressure.
Licensee's Basis for Relief: The licensee states that: 'The system installation does not provide any installed suction gages. A measure of pump suction pressure can, however, be determined by calculation using the height of liquid in the refueling water tank (RWT). During the quarterly pump tests, the flow rate through the suction piping is very low, therefore, the amount of head loss is negligible. This is not the case during the substantial flow tests. The flow rates used during these tests would cause a noticeable head loss in the wction piping.
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1 Since the RWT level is not expected to vary significantly during the quarterly tests, RWT level and associated calculations will only be taken once during each quarterly test instead of prior to pump operation and during operation as required by Table IWP-3100-1."
Evaluation: The licensee is requesting relief from measuring inlet pressure and differential pressure for the 2A and 2B Containment Spray, High Pressure Safety injection, and Low Pressure Safety injection pumps. Measurement of inlet pressure and differential pressure is a requirement of the ASME Code,Section XI, IWP 3100 (Table IWP 31001).
The licensee's drawing 2998-G-088, " Flow Diagram - Containment Spray and Refueling Water Systems," Revision 13, 10/20/89, denotes the presence of PX 07-1 A,2A and PX 07-18,28 at the suction of each Containment Spray pump, respectively. The licensee has indicated that these are locations where temporary pressure instrumentation may be attached, and that permanent pressure instrumentation is not provided.
Licensee drawing 2998-G-078, Sheet 130, ". Flow Diagram - Safety injection System (Sheet 1)," Revision 4, 10/20/89, indicates that there is no instrumentation to directly measure the inlet pressure of the High Pressure and Low Pressure Safety injection pumps, except for differential pressure switches across the pump suction strainers.
Lack of instrumentation is not sufficient justification for not compliing with Code requirements, as discussed in response to question 105 of tb.s Generic Letter 89-04 meeting minutes. However, calculation of inlet pressure based on the measured tank level would provide an acceptable alternative method of determining inlet pressure, provided the calculation is properly proceduralized, and the accuracy is within the accuracy required by the Code using direct measurement.
Based on the alternative providing an acceptable level of quality and safety, it is recommended that the alternative be authorized in accordance with {50.55a $(a)(3)(i), provided that the accuracy of the reading scale of the level measurement is within Code requirements and the calculation method is properly proceduralized.
2.4.2 Pump Relief Request PR-14, Containment Spray System Hydrazine Pumps 2A and 2B Relief Request: The licensee requests relief from the ASME Code, S'ection XI, IWP4520(b),
which requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one hG minimum speed to at least maximum pump shaft rotational speed, for the Containment Spray System Hydrazine Pumps 2A and 28.
Proposed Alternate Testing: For an interim period (until March 1994), vibration will be measured as required by IWP-4510, except that the lower frequency response for the instruments will be 10 Hz.
Licensee's Basis for Relief: The licensee states that: 'The hydrazine pumps operate as low at 105 rpm. This equates to a rotational frequency of 1.75 Hz. In acconlance with the ASME Code, the.requency response for the vibration instruments would have to ce one half of this or 0.875 8
Hz. Following an extensive investigation of available and potentially suitable ins'trumentation, it has been determined that instruments satisfying this requirement for the hydrazine pumps are commercially unavailable.'
Evaluation: The containment spray hydrazine pumps operate at very low speeds.Section XI, IWP-4520(b), requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational. speed for all pumps. Additionally OMa 1988 Part 6, now requires that the frequency response range of the vibration moeuring transducers and their readout system to be from one-third minimum pump speed to at least 1000 Hz, in order to more adequately envelop all potential noise contributors. The lower limit of the range is to allow for detection of problems such as bearing oil whirl and looseness of bearings.
The licensee has proposed using vibration instrumentation that cannot measure subharmonic or the first to sixteenth harmonic. The licensee has stated that instrumentation that complies with the Code is commercially unavailable. However, equipment with a frequency response of less than 10 Hz is available. The licensee has requested an interim period of seven months to procure instruments that meet the Code requirements, or provide justification for the continued use of existing instruments. A Safety Evaluation (SE) addressing Revision 2 of the First Ten-Year Interval IST Program was issued by the NRC on August 23,1993. This SE granted relief to use the existing instruments for one year, or until th,e next refueling outage, whichever is later. Per the SE, the interim relief remains in effect into the Second Ten Year Interval.
Therefore, the licensee's current request is covered by the August 23,1993 SE.
2.4.3 Pump Relief Request PR-17, Containment Spray System Hydrazine Pumps 2A and 28 Relief Request: The licensee requests relief from the ASME Code, Section XI:
1.
IWP 3200 and IWP-3300, which require evaluation of pump differential
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pressure and flow rate quarterly, aad appropriate corrective actions, and 2.
lWP 4150, which states that symmetrical damping devices or averaging techniques may be used to reduce instrument fluctuations to within 2% of the observed reading, for the Containment Spray System Hydrazine Pumps 2A and 28.
Proposed Alternate Testing: During the quarterly pump tests, each pump's rpm will b~e'
. measured to verify the required flow rate of 0.71 to 0.82 gpm. Pump flow will be recorded but not alert trended and vibration will be measured during the quarterly tests. During each refueling outage, at least one flow test will be performed for eat 1 pump to verify proper performance. Pump vibration will be measured during this flow test.
Licensee's Basis for Relief: The licensee states that: "The Hydrazine Pumps are positive '
displacement pumps with a variable speed drive. They operate at a very low rpm and flow rate (0.71 to 0.82 gpm). The flow instrument orifice is located in the pump's suction line. Its ouput signal pulsates sharply with each stroke and cannot readily be averaged. The flow recorder for the hydrazine pumps, FR-07 2, displays a wide trace for flow rate.. The only way to know the true flow rate of the pumps is to collect the pumps output in a container and 9
measure it.
During the 1992 Unit 2 refueling outage, several flow tests per hydrazine pump were performed. The discharge of one pump was directed to a container of a known volume. The amount of time to fill the container was measured and then used to calculate an average flow rate for the pump. Each of the flow tests for each pump were performed at a different purrip rpm. A correlation be; ween pump rpm and average flow rate was developed and compared to the expected value. The measured and the expected correlations between rpm and flow: rate were in close agreement. The expected correlation was based upon piston diameter, piston stroke, and pump rpm. Based upon these results, hydrazine pump fiow rate can be accurately. set by selecting the proper pump rpm.
Frequent performance of the above mentioned flow testing can not be performed. Hydrazine is a highly flammable liquid with cumulative toxic effect when absorbed through the skin, inhaled,
- v. ingested. It has also been identified as a known carcinogen."
Evaluation: The licensee has proposed recording flowrate quarterly, but flowrate will not be
" alert trended."Section XI, IWP-3200 requires flowrate to be measured and corrective' actions taken, if necessary, by either increasing the test frequency or declcring the pump inoperativa, if the measured value is in the alert or required action range, respectively.
Referring to the licensee's request, it appears that the licensee will not take any corrective i
actions based on the flowrate me'asured quarterly exceeding the alert or required action values.
The licensee should evaluate the establishment of required action ranges for quarterly testing.
The licensee has referenced Section XI IWP-4150 in the relief request, but has not discussed the possible use of a symmetrical damping device to provide for flow rate averaging.
Additionally, the licensee has not discussed the impact or burden of installing flow instrumentation that could be used effectively for the quarterly test.
In Generic Letter 89-04, Position 9, the staff determined that in cases where flow can only be established through a non-instrumented minimum flow path during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test of the pump under full or substantial flow conditions, the increased interval is an acceptable alternative to the Code requirements. During the deferred test, pump differential pressure, flow rate, and bear;ng vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
Reference to the licensee's Appendix A, Pump Prc; ram Table indicates that the licensee will not measure the pump inlet pressure or differential pressure. The ASME/ ANSI Code OMa-1988, Part 6, Table 3b, requires that pump discharge pressure be measured for positive displacement pumps, in lieu of differential pressure. The licensee has not provided a basis for not measuring pump differential or discharge pressure.
Provided the licensee determines that there is no practical means of installing flow instrumentation that is adequate for inservice testing purposes, deferring flowrate measurement to refueling outages may be considered acceptable. The licensee s!.muld, however, evaluate the procurement of da,mping devices or new flow instrumentation, and measure and evaluate pump differential or discharge pressure, as well as vibration, quarterly.
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immediate imposition of the Code requirements is impractical due to lack of adequate installed -
flow instrumentation, and it would be an undue burden to require the plant to declare these pumps inoperable until the availability of new instrumentation could be reviewed., A Safety Evaluation (SE) addressing Revision 2 of the First Ten-Year interval IST Program was issued by the NRC on August 23,1993. This SE granted interim relief for one year, or until the next refueling outage, whichever is later. Per the SE, the interim relief remains in effect into the Second Ten-Year Interval. In the interim, the licensee should establish acceptance criteria for the rpm / flow rate correlation, and take corrective actions if needed, and measure, discharge pressure, if possible.
3.0 VALVE IST PROGRAM RELIEF REQUESTS In accordance with 50.55a, FP&L has submitted thirty-one relief requests for specific and generic valves a the St. Lucie Plant, Unit 2 that are subject to inservice testing under the requirements of ASME Section XI. The relief requests have been reviewed to verify their technical basis and determine their acceptability. Each relief request that is not authorized by Generic Letter 89-04 is summarized below, along with the technical evaluation by BNL.
3.1 Generic Valve ReIIef Reauests 3.1.1 Valve Relief Request VR 1, All Valves Te.sted During Cold Shutdown Relief Request: The licensee requests relief from exercising all cold shutdown frequency valves every cold shutdown, as required by Section.XI, 3412(a) and 3522.
Proposed Alternate Testing: "For those valves designated to be exercised or tested during cold shutdown, exercising shall commence as soon as practical after the plant reaches a stable cold shutdown condition, as defined by the applicable Technical Specification, but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown. If the outage is long enough to test all the cold shutdown valves, then the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> requirement need not apply. If the 48-hour requirement is waived, then all cold shutdown valves must be testet' during the outage.
Valve testing need not be performed more often than once every cold shutdown exc'ept as provided for in IWV-3417(a). Completion' of all valve testing during a cold shutdown outage is not required if the length of the shutdown period is insu+ficient to complete all testing. Testing
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not completed prior to startup may be rescheduled for the next shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves."
Licensee's Basis for Relief: The licensee states: "In many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage or the lack of plant conditions needed for testing specific valves. It has been the policy of the NRC that if testing commences in a reasonable time and reasonable efforts are made to test all valves, then outage extension is not required when the only reason is to provide the opportunity for completion of valve testing.
ASME/ ANSI OMa 1987 (sic), Operation and Maintenance of Nuclear Power Plants, Part 10 (Paragraphs 4.2.1.2 and 4'.3.2.2) recognizes this issue and allows deferred testing as set forth 11
below" (i.e., in the description of the Proposed Alternate Testing).
Evaluation:
Section 50.55a (f)(4)(iv) provides that inservice tests of valves may meet the requirements se forth in subsequent editions and addenda of Section XI that are incorporated by 4
reference in paragraph (b) of Q 50.55a, subject to the limitations and modifications listed, and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The staff imposed no limitations to OMa 1988 Part 10 related to cold shutdown testing.
The ASME recognized the burden of requiring licensees to complete all cold shutdown frequency inservice testing every cold shutdown. ASME/ ANSI OMa 1988, Part 10 now allows plant startup without the completion of all cold shutdcwn frequency testing, provided the licensee commences testing within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The licensee's request to utilize OMa 1988, Part 10, 14.2.1.2 and 4.3.2.2, is covered by the rulemaking effective September 8,1992, therefore, relief is not required. Approval for implementation is recommended pursuant to 50.55a (f)(4)(iv). There are no related requirements.
The licensee states that valve testing need not be performed more often than once every cold shutdown, except as provided for in IWV-3417(a), which requires more frequent testing as a result of degraded stroke times. The ASME issued a Code interpretation (XI-1-92-41) which ctates that the intent of Section XI, IWV 3410 and 3520, is to require testing of valves every three months, including during extended shutdown periods, for valves other than those in a system declared inoperable or not required to be operable (IWV-3416). Therefore, during plant shutdown periods when the valves can be exercised, the licensee should exercise valves every three months in accordance with the Code or provide a relief request. Additionally, if specific valves cannot be tested during any cold shutdown (i.e., due to "the lack of plant conditions needed for testing"), specific approval is required to defer testing. The licensee should revise the cold shutdown justifications, as required, to discuss the conditions under which testing cannot be performed during any cold shutdowns.
3.2 Safety inlection System 3.2.1 Valve Relief Request VR 2, Safety injection' System Pressure isolation Valve (PlV) Check Valves Relief Request: The licensee requests relief from the requirements of ASME Section XI,1 IWV-3427(b), which requires leakage trending, and corrective actions based on the trend 'results, for the following pressure isolation check valves (PlVs) in the Safety injection System:
V-3217 V-3227 V-3237 V-3247 V-3258 V-3259 V-3260 V-3261 V-3215 V-3225 V-3235 V-3245 V-3524 V 3525 V 3526 V-3527 Proposed Alternate Testing: The leakage rate acceptance criteria.for these valves will be established per the St. Lucie Unit 2 Technic'al Specifications, Table 3.4-1. Leakage rates greater than 1.0 GPM are unacceptable.
12 I
Each Reactor Coolant System Pressure Isolation Valve check valve shall be demonstrated i
operable by verifying leakage to be within its limits:
1.
At least once per 18 months.
.2.
Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months.
3.
Prior to returning the valve to service following maintenance, repair or replacement work on the valve.
4.
Following flow through valve (s) while in MODES 1,2,3, or 4:
j A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and B. Within 31 days by verifying leakage rate.
Licensee's Basis for Relief; The licensee states that: ' Leak testing of these valves is primarily for the purpose of confirming their capability of preventing overpressurization and catastrophic failure of the safety injection piping and components. In this regard, special leakage acceptance criteria is established tnd included in the St. Lucie 2 Technical Specifications (Table 3.4-1) that addresses toe question of valve integrity in a more appropriate manner for these valva. Satisfy'ng both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing.
Specifically applying the trending requirements of IWV-3427 (b) would result in frequent and
. excessive maintenance of these valves. ~,he continuation.of a strict leak ra,te acceptance criteria and more frequent testing than specified by the Code gives a high degree of assurance that these valves will satisfactorily perform their safety function.'
Evaluation: The ASME Code,Section XI, IWV-3427(b), states that for Category C valves NPS 6 and larger, if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate by 50% or greater, ;he test frequency shall be doubled; the tests shall be scheduled to coincids with a cold shutdown until corrective action is taken, at which time the original test frequency shall be resumed. if tests show a leakage rate increasing with time, and a projection based on three or more tests inuicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be replaced or repaired.
Several safety systems connected to the reactor coolant pressure boundary have design pressures below the RCS operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high an1 low pressure systems protect the. low pressure systems from pressures that 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 because it has been demenstrated that the failure of the boundary created by these valves is a dominant accident scenario if the valves are not tested. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity.
13
Consequently, these pressure isolation valves are identified in the Plant Technical Specifications along with specific requirements to monitor their leakage rates periodically.
1 Each of the check valves has a maximum allowable leak rate of 1.0 GPM.
)
Section 50.55a (f)(4)(iv) provides that inservice tests of valves may meet the requirements set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of 9 50.55a, subject to the limitations and modifications listed, and-subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The staff imposed no limitations to
]
OMa 1988 Part 10 concerning pressure isolation valves.
4 l
l Increasing the frequency of testing for valves NPS 6 and larger whose leakage rate exceeds the i
criteria described in Section XI, IWV-3427(b) is not required by ASME/ ANSI OMa 1988, i
Part 10, 4.2.2.
Ir' stead, 4.2.2.3(f) requires that valves or valve combinations.with leakage rates exceeding the values specified by the Owner in 14.2.2.3(e) shall be declared inoperable and either repaired or replaced. A retest demonstrating acceptable operation shall be performed following any required corrective action before the valve is returned to service.
The licensee's proposed alternate testing, which includes limiting the acceptable leakage flow' rate to 1.0 GPM, m.ats the requirements of Part 10, 4.2.2.3(e) and (f). OM-10,1 4.2.2.3(e) requires leakage rates to be specified by the Owner. If not specified. 0.5 D or 5.0 GPM may be used. Therefore, approval to not trend leakage as required by IWV-3427(b) is recommended pursuant to 50.55a (f)(4)(iv). There are no related requirements for the i
deletion.
3.2.2 Valve Relief Request VR 13, Safety injection Tank to. Reactor Coolant System Check Valves V 3215, V-3225, V-3235, and V-3245 Relief Request: The licensee requests relief from full stroke exercising open and closed the 12 j
in. check valves, V-3215, V-3225, V-3235, and V 3245, in each of the discharge lines from the Safety injection Tanks (SIT) to the Reactor Coolant System quarterly _or at cold shutdowns i
in accordance with Section XI,1 IWV-3521 and IWV-3522.
Proposed Altemate Testing: At least once during each ISI (10 year) inspection interval each of these valves will be disassembled, inspected, and manually stroked to verify operability.
Should a valve under inspection be found to be inoperable, then the remaining three valves will be inspected during the same outage. Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly.
These valves will be verified closed in conjunction with PlV leak testing. Each Reactor Coolant System Pressure isolation Valve check valve shall be demonstrated operable by verifying leakage to be within its limits:
1
]
1.
At least once per 18 months.
2.
Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 L
14 4
I hours or more and if leakage testing has not been performed in the previ* us 9 o
i months.
3.
Prior to returning the valve to service following maintenance, repair or replacement work on the valve.
4.
Following flow through valve (s) while in MODES 1,2,3, or 4:
A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and i
B. Within 31 days by verifying leakage rate.
Licensee's Basis for Relief: The licensee states: ' Full stroke exercising of these valves would require injecting from a tank under nominal pressure into a de-pressurized reactor coolant system. At power operation this is not possible because the Si Tank pressure is insufficient to overcome reactor coolant system pressure.
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Under a large' bre'ak L'OCA accident coEitions, the maximu'mlpe'ak) flovirate thiougithese' ~
valves would be approximately 20,000 GPM. During cold shutdown or refueling the required test conditions for developing this full accident flow cannot be established.
The SlT discharge isolation valves aa motor operated valves with a nominal stroke time of 52 seconds. Therefore, the isolation valve cannot be used to simulate the LOCA flow conditions by opening it with a full or partially pressurized SIT. The discharge flow rate would only increase gradually due.to the long stroke time of the discharge isolation valve. The flow rate would not be anywhere near the expected peak blowdown rate of 20,000 GPM expected during a large break LOCA.
FP&L has reviewed the operating and maintenance history of these valves and similar valves used throughout the industry under comparable conditions. Based'on these reviews, there is no' evidence of valve degradation with respect to their ability to open and satisfactorily pass the required flow, it is apparent from the failure data that the primary mode of failure is related to valve leakage - both past the seat and external through the body-bonnet and hinge pin gasket.
joints, it should also be noted that these valves are not subjected to any significant flow during 1
plant operation as well as maintenance periods; thus it is unlikely that these valves would I
experience any service related damage or wear.
Although check valve disassembly is a valuable maintenance tool that can provide a greaf deal of information about a valve's internal condition, due to the difficulties associated with these maintenance activities, it should only be performed under the maintenance program at a frequency commensurate with the valve type and service. In this light, FP&L considers the frequency of inspection for these valves of once each 10 year inspection interval to be adequate to ensure the continued operability of these valves.
These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. The back flow tests are performed as part of the pressure isolation testing per VR-2.*
15 4
a
Evaluation: Cection XI requires check valves to be exercised to the position (s) in which the valves perform their safety function (s). These 12 in. check valves open to provide a flow path from the safety injection tanks to the RCS and close to isolate the' tanks from the high pressure of the reactor coolant system and the safety injection headers.
As discussed in Generic Letter 89-04, Position 1, the NRC considers passing the maximum required accident condition flowrate through the valve as an acceptable means of verifying that a check valve can full-stroke open. The NRC recognized that it may be impractical to perform full flow testing of certain check valves and noted that it may be possible to qualify other techniques to confirm that the valve is exercised to the position required to perform its safety function. When full-stroke exercising is impractical, disassembly and inspection is an acceptable alternative technique, as described in Positian 2. Howewar, the NRC considers disassembly and inspection a maintenance procedure and not a test equivalent to the exercising produced by fluid flow. This procedure has some risk, which makes its routine use as a j
substitute for testing undesirable when some other method of testing is practical. Check valve disassembly is a valuable maintenance tool that can provide significant information about a j
valve's intemal condition and, as such, should be performed under the maintenance program at a frequency commensurate with the valve type and service.
Although, the licensee states that testing with the maximum required accident flowrate is not
. practical, as discussed in the August 23,1993 SE, an analysis or test should be performed to show that the nominal 52 seconds stroke time for the SIT discharge isolation motor-operated valves to open is too long.to permit sufficient flow to cause the check valves to reach their full-open position. If a full-open position can be reached, the licensee should perform the test with flow to confirm disk position.
The use of alternate techniques, such as non intrusive technique's, to verify that the valves are fully open is acceptable, as discussed in Generic Letter 89-04, Position 1, when full-flow testing'is impractical. Furthermore, the use of non-intrusive techniques has been demonstrated to be less costly and less risky than disassembly and inspection (Reference The Nuclear Professional, page 31, Vol. 7 No. 4, Fall 1992). To substantiate the acceptability of any alternative technique for meeting the ASME Code requirements, licensees must, as a minimum, address and document certain items in the IST program, as described in Position 1.
The licensee should note that other C-E plants, such as Palisades and Fort Calhoun, have included in their IST Program full-stroke exercising the Si Tank check valves open at refueling outages (See Reference 20).
However, if the licensee determines that full-stroke exercising with flow is impa tical, the licensee may, as discussed by the NRC in Generic Letter Position 2, perform valve d, sssembly and inspection as a positive means of determining that a valve's disk will full stroke exercise open or of verifying closure capability.
The licensee is currently proposing to utilize Position 2. Assurance of proper reassembly will-be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly. However, the licensee intends to inspect each check valve only once in the 10 year Inservice Inspection program interval. As defined in Position 2 of the Generic Letter, in order to support extension of the valve disassembly / inspection intervals to longer than once every 6 years,i.e., in cases of
- extreme hardship," licensees should develop the 16.
following information:
a.
Disassemble and inspect each valve in the valve grouping and document in detail the condition of each valve and the valve's capability to be full-stroked.
b.
A review of industry experience, for example, as documented in NPRDS, regarding the same type of valve used in similar service.
c.
A review of the installation of each valve addressing tne ePMI Applications Guidelines for Check Valves in Nuclear Power Plants" for problematic locations.
The licensee has documented parts a and b above, but has provided no discussion concerning the EP.RI Guidelines in part c above or the extreme hardship. The licensee should discuss why non-intrusives cannot be utilized when eveluating hardship. Additionally, the licensee states that valve will be leak tested or partial-flow tested following disassembly. Position 2 requires that, if possible, partial. valve. stroking, quarterly or during cold, shut, downs, or after reassembly, must be performed.
In summary, relief is granted per Generic Letter 89-04, Position 1, to full-stroke exercise the valves open with less than the accident flow rate, provided all r+iteria in Position 1 are met. If the licensee determines that full-stroke exercis:.ig is impractical, relief is granted per Position 2 to disassemble / inspect these check valves, provided the licensee meets all the
. criteria in Position 2, including reviewing the installation of the valves, demonstrating extreme hardship, and partial-stroke exercising the valves following reassembly and at cold shutdown if practical.
With respect to exercising the valve closed, verification that a valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating.
device, by observation of appropriate pressure indication in the system, by leak testing, or by other positive means.
These are simple check valves which are not provided with instrumentation, and the only means of testing these valves closed is by leak testing. Backflow leakage testing is performed under the licensee's program for Pressure Isolation Valves, as described in TER Section 3.2.1.
It is impractical to test these valves quarterly or during every cold shutdown because th,e valves and test connections are located inside containment. Access to testing presents a personnel safety hazard due to high radiation levels and proximity to high energy systems.
Leak testing these valves during every cold shutdown would be burdensome to the licensee due to the extensive test setup, which would require substantial man-hours and the potential for extending the shutdown.
Section 50.55a (f)(4)(iv) provides that inservice testing of valves may meet the requiretrents set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of $50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions and addenda may be used provided that all related requirements of the respective editions and addenda are met. The NRC staff imposed no limitations to OMa-1988 Part 10 associated with testing valves during refueling.
17 e
6
.?
OMa 1988 Part 10, 4.3.2.2 allows full-stroke exercising that is not practicable during operation or cold shutdown to be deferred to refueling outages. Accordingly, the alternative testing proposed by the licensee in the closed direction is covered by the rulemaking, effective September 8,1992, as described above. Relief is not required provided the licensee implements all related requirements, including Part 10, 4.3.2.2(h) and $6.2. Approval for i
deferring the verification of valve closure is recommended pursuant to 650.55a (f)(4)(iv).
Implementation of these related requirements is subject to NRC inspection.
3.2.3 Valve Rellef Request VR 14, Safety injection Headers to Reactor Coolant System Check Valves V-3217, V-3227, V-3237, and V 3247 Relie/ Request: The licensee requests relief from full-stroke. exercising the 12 in. Safety injection check valves V 3217, V-3227 V-3237, and V 3247, open and closed quarterly and at cold shutdowns as required by the ASME Code,Section XI, IWV-3522. These utves open to provide flow paths from the safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.
Proposed Altemate Testing: During cold shutdown and refueling periods, each of these valves will be partial-stroke exercised with approximately 1,750 GPM (8 percent of maximum accident flow) using the LPSI pump per Relief Request VR 1.
At least once during each ISI (10 year) inspection interval, each of these valves will be dissssembled, inspected, and manually stroked to verify operability. Should a valve under
)
inspection be found to be inoperable, then the remaining three valves will be inspected dunng j
the same outage. Assurance of proper reassembly will be provided by performing a leak test or l
partial-flow test prior to returning a valve to service following disassembly.
These valves will be verified closed in conjunction with PlV leak testing."
Each Reactor Coolant System Pressure Isolation Valve check valve shafl be demonstrated operable by verifying leakage to be within its limits:
1.
At least once per 18 months.
2.
Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN,for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months.
3.
Prior to returning the valve to service following maintenancs, repair or replacement Work on the valve.
4.
Following flow through valve (s) while in MODES 1,2,3, or 4:
A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and B. Within 31 days by verifying leakage rate.
18
Licensee's Basis for Relief: The licensee states:
- Full stroke exercising of these valves would require injecting from a tank under nominal pressure into a de-pressurized reactor coolant system. At power operation this is not possible because the SI Tank pressure is insufficient to overcome reactor coolant system pressure.
Under a large break LOCA accident conditions, the maximum (peak) flow rate through these valves would be approximately 20,000 GPM. During cold shutdown or refueling the required test conditions for developing this full accident flow cannot be established. The SITMischarge isolation valves are rnotor operated valves with a nominal stroke time of 52 seconds.
Therefore, the isolation valve cannot be used to simulate the LOCA flow conditions by opening it with a fully or partially pressurized SIT. The discharge flow rate would only increase gradually due to the long stroke time of the discharge isolation valve. The flow rate would not be anywhere near the expected peak blowdown rate of 20,000 GPM expected during a large break LOCA.
FP&L has reviewed the operating and maintenance history of these valves and similar valves used throughout the industry under comparable conditions. These four valves have been in operation in Unit 2 since the plant startup in 1983. A total of 3 plant work orders have been initiated for work on these valves. Of the three work orders, one was to repair seat leakage identified by a seat leakage test and the other two were for disassembly and inspection per
. Generic Letter 89-04. A search of the Nuclear Plant Reliability Data Systein for problems j
with valves similar to these revealed 12 reports - 7 due to seat leakage and the remaining S were related to gasket leaks. Based on these reviews there is no evidence of valve degradation with respect to their ability to open and satisfactorily pass the required flow. It is apparent from the failure data that the primary mode of failure is relatet;1 to valve leakage both past the seat and external through the body-bonnet and hinge pin gasket joints.
In order to disassemble and inspect these valves, the reactor coolant system must be placed in mid-loop or ' reduced inventory' condition for several days, in response to issues raised in NRC Generic Letter 88-17, FP&L is concerned about continued operations with the plant in a condition of reduced inventory. During these periods, the risk of over-heating the core is increased due to the higher probability of an incident where shutdown cooling is lost. This risk is compounded by the reduced volume of water available to act as a heat sink should cooling be lost. Since 1982 there have been at least six (6) reported events in the industry where cooling flow was lost while a plant was in a ' reduced inventory' condition.
Although check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition, due to the difficulties associated with these maintenance activities,it should only be performed under the maintenance program at a frequency commensurate with the valve type and service. 'Given the lack of evidence that these valves are experiencing significant failures with respect to their capability of passing the design flow rates and the apparent sensitivity of the valves to leak testing, a frequency of inspection for these valves of once each 10-year inspection interval is adequate to ensure the continued operability of these valves.
These are simple check valves with no eicternal means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. The back flow testing is performed as stated in VR-2. In addition to periodic leak testing, the upstream 19-
o pressure of each valve is monitored by a pressure indicator and alarm. Should any of these valves begin to le'ak by, the upstream pressure alarm would alert plant personnel of the leakage."
Evaluation: Section XI requires check valves to be exercised to the position (s) in which the valves perform their safety function (s). These 12 in. check valves open to provide flow paths from the safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.
As discussed in Generic Letter 89-04, Position 1, the NRC considers passing the maximum F9 quired accident condition flowrate through the valve as an acceptable means of verifying that a check valve can full-stroke open. The NRC recognized that it may be impractical to perform full flow testing of certain check valves and noted that it may be possible to qualify other techniques to confirm that the valve is exercised to the position required to perform its safety function. When full-stroke exercising is impractical, disassembly and inspection is an acceptable alternative technique, as described in Position 2. However, the NRC considers disassembly and inspection a maintenance. procedure and not a test equivalent to the exercising produced by fluid flow. This procedure has some risk, which makes its routine use as a substitute for testing undesirable when'some other method of testing is practical. ' Check valve disassembly is a valuable maintenance tool that car. provide significant information about a valve's internal condition and, as such, should be performed under the maintena..ce program at a frequency commensurate with the valve type and service.
The licensee states that during cold shutdown and refueling periods, each of these valves will be partial-stroke exercised with approximately 1,750 GPM (8 percent of maximum accident flow) using the LPSI pump. As discussed in the August 23,1993 SE, the licensee should evaluate if the valves will achieve a full-open position with this reduced flow rate. If a full-open position can be reached, the licensee should perform the testing with flow. The use of alternate techniques, such as non intrusive techniques, to verify that valves will fully o' pen is accept'able, as discussed in Generic Letter 89-04, Position 1.
If the valves cannot be full-stroke exercised, the NRC defined an acceptable alternative to the full-stroke exercising requirement in Generic Letter 89-04, Position 2, wherein it is stated that valve disassembly and inspectior, can be used as a positive means of determining that a valve's disk wi!! full-stroke exercise open or of verifying closure capability, as permitted by IWV 3522.
.The licensee is currently proposing to utilize Position 2. Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly. However, the licensee intends to inspect each check valve only once in the 10 year Inservice inspection program interval. As defined in Position 2 of the gene.ric letter, in order to support extension of the valve disassemDly/ inspection intervals to longer
~
than once every 6 years,i.e., in cases of ' extreme hardship," licensees should develop the following information:
a.
Disassemble and inspect each valve in the valve grouping and document in detail the condition of each valve and the valve's capability to be full-stroked.
20 m
O O
b.
A review of industry experience, for example, as documented in NPRDS', regarding the same type of valve used in similar service.
1 1
A review of the installation of each valve addressing the 'EPRI Applications c.
Guidalines for Check Valves in Nuclear Power Plante" for problematic locations.
The licensee has documented parts a and b above, but has provided no discussion concerning the EPRI Guidelines in part c above. The licensee should include a discussion of why non-intrusives cannot be utilized when proposing disassembly and inspection. Additionally, the licensee states that valve will be leak tested or partial-flow tested following disassembly.
Position 2 requires that, if possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly, must be performed.
in summary, relief is granted per Generic Letter 89-04, Po'sition 1, to full-stroke exercise j
the valves open with less than the accident flow rate, provided all criteria in Position 1 are
{
met. If the licensee determines that full stroke exercising is impractical, relief is granted per Position 2 to disassemble / inspect these check valves, provided the licensee meets all the criteria in Position 2', including reviewing the installation of the valves, demonstrating extreme hardship, and partial-stroke exercising following reassembly and at cold shutdown if practical.
With respect to exercising the valves closed, verification that a valve is in the closed position can be done by visual observation, by an electrical sigrial initiated by a position-indicating device, by observation of appropriate pressure indicatior, in the system, by leak testing, or by other positive means. The licensee does have instrumentation to continuously monitor upstream pressure. Based on the Technical Specifications, it appears that following the partial-stroke exercise at cold shutdowns, verification that the valves have closed will be performed and relief would not be required. The licensee should exercise these valves closed at cold shutdowns or revise the request accordingly.
3.2.4 Valve Relief Request VR 29, Safety injection System Motor-Operated Valves V-3 4 8 0, V 34 81, V-3651, V-3652 Relief Request: The licensee requests relief from the requirements of ASME Section XI, IWV-3427(b), which requires leakage trending, and corrective actions based on the trend results, for the 10 in. Safety injection System motor operated valves V 3480, V-3481, V-3651, and V-3652.
Proposed Alternate Testing: The leakage rate acceptance criteria for these valves will be established per the St. Lucie Unit 2 Technical Specifications Table 3.41, as applicable for motor-operated valves:
1.
Leakage rates greater than 1.0 GPM but less than or equal to 5.0 GPM are acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.
2.
Leakage rates greater than 1.0 GPM, but less than or equal to 5.0 GPM, are 21
l unacceptable,if the latest measured rate exceeded the rate determined by the-previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 GPM by 50% or greater.
3.
Leakage rates greater than 5.0 GPM are unacceptable.
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Each Reactor Coolant System Pressure isolation Valve motor-operated valve shall be demonstrated operable by verifying leakage to be within its limits:
1.
At least once per 18 months, and l
2.
Prior to returning the valve to service following maintenance, repair, or replacement work on the valve.
I Licensee's Basis for Relief: The licensee states that: " Leak testing of these valves is primarily for the purpose of confirming their capability of preventing overpressurization and catastrophic failure of the safety injection piping and components. In this regard, special leakage acceptance criteria is established and included in the St. Lucie 2 Technical Specifications (Table 3.41) that addresses the question of valve integrity in a more appropriate manner for these valves. Satisfying both the Technical Specification and'the Code acceptance criteria is not warranted and implementation would be difficult and confusing."
Evaluation: The licensee requests relief from the ASME Code,Section XI, IWV 3427(b),
which requires that for Category A valves NPS 6 or larger', if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured,
leakage rate and the maximum permissible leakage rate by 50% or greater, the test frequency shall be doubled; the tests shall be scheduled to coincide with a cold shutdown until corrective action is taken, at which time the original test frequency shall be resumed if tests show a leakage rate increasing with time, and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be replaced or repaired.
Several safety systems connected to the reactor coolant pressure boundary have design pressures beksw the RCS operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems protect the low pressure systems from pressures that 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 because it has been demonstrated that the failure of the boundary created by these valves is a dominant accident scenario if the valves are not tested. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. Consequently, these pressure isolation valves are identified in the Plant Technical Specifications along with specific requirements to monitor their leakage rates periodically.
The subject motor-operated valves open for residual heat removal recirculation during shutdown. Each of these valves is designated as a pressure isolation valve (PlV) and provides isolation of safeguard systems from the RCS.
22
Section 50.55a 1(f)(4)(iv) provides that inservice tests of valves may meet the requirements set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of f 50.55a, subject to the limitations and modifications listed, and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The staff imposed no limitations to OMa 1988 Part 10, concerning pressure isolation valves.
Increasing the frequency of testing for valves NPS 6 and larger whose leakage rate exceeds the criteria described in Section XI, lWV-3427(b) is not required by ASME/ ANSI OMa-1988, Part 10, 4.2.2.3(f). Instead, 4.2.2.3(f) requires that valves or valve combinations with leakage rates exceeding the values specified by the Owner in 4.2.2.3(e) shall be declared inoperable and either repaired or replaced. A retest demonstrating acceptable operation shall be. performed following any required corrective action before the valve is returned to service.
The licensee's proposed alternate to use the Technical Specification requirements, which includes limiting.the acceptable leakage flow rate to 5,0 GPM, meets the. requirements of Part 10,14.2.2.3(e) and (f). Therefore, because the alternative meets later Code requirements, relief is not required. Approval is recommended pursuant to $50.55a (f)(4)(iv). There are no related. requirements for the deletion.
3.3 containment isolation Valves 3.3.1 Valve Rollef Request VR 4, primary Containment isolation Valves Relief Request: The licensee requests relief from ASME,Section XI, IWV-3426 and IWV-3427, which requires individual leak rates for Category A valves to be evaluated and corrected.
The subject valves are:
PENETRATION NO.
VALVES '
10 FCV 25-4 and Blank Flange 11 FCV-25-2 a,nd FCV 25-3
'23 HCV 141 and HCV-14-7 24 HCV-14 2 and HCV 14-6 41 SE-03 2A and SE-03 2B 54 V-OO101 and Blank Flange
-56 FCV-25-36 and FCV-25 26 57 FCV 25-20 and FCV 25 21 Proposed Attemate Testing: The above stated valves and blank flanges will be leak rate tested in pairs. Leakage measurement from tests of multiple valves or blank flanges will be evaluated in accordance with Section XI,1 IWV-3426 and 1 IWV-3427.
Licensee's Basis for Relief: The licensee states that: "For several containment systems,
' individual leakage rate tests are impractical due to the configuration of the system's piping and components. In these cases it is customary to perform leakage tests with the test volume 23 4
i between valves in ser;es or behind valves in parallel paths.
In these cases where individual valve testing is impractical, the valves will be leak tested 1
simultaneously in multiple valve arrangements. A maximum permissible leakage rate will be applied to each combination of valves or valve and blank flange. In each of the valve pairs,, the j
two valves are equal in size and type, and the leakage limit is in proportion to their size. The blank flanges used in testing penetrations 10 and 54 have diameters similar in size to their associated valves FCV 25-4 and V-00101. The leakage limit assigned to each pair ~is such that excessive leakage through any valve, or flange, would be detectable and One appropriate corrective action taken."
Evaluation: The subject valves are Catepory A or A/C valves which are closed to provide containment isolation.Section XI, IWV 3426 requires that Category A or A/C valves be seat leak tested and that a maximum individual permissible leakage rate be specified for each vaive.
The licensee is proposing to leak rate test the subject containment isolation valves in pairs.
Section 50.55a (f)(4)(iv) provides that inservice testing of valves may meet the requirements set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of 650.55a, subject to the limitations and modifications listed, and subject to NRC epproval. Portions of editions and addenda may be used provided that all related requirements of toe respective editions and addenda are met. The NRC staff imposed limitations to OMa-1988 Par 10 associated with containment isolation valves (CIVs) to require the leakage rate analyes and corrective action requirements of OM-10,
'4.2.2.3(e) ar.d (f) to be applied to CIVs.
ASME/ ANSI OMa-1988, Part 10, 4.2.2.3(e) ar.d (f) allows valves to be tested in combinations or groups. Where two or more valves on a containment penetratron are tested as a group, limiting leakage-rate values must be assigned to the group _ for the purpose of monitoring valve conoition and taking corrective action. The limits should be established such that leakage of any valve in the group would be identified, based on the diameter of the smallest valve in the group or based on-a conservative limit established to another criterion not related to the diameter of the valve. If the limiting values are exceeded, the licensee must take actions to determine the leakage path.
The licensee has adequately described the leakage rate limits by indicating that the valves will be tested in pairs and the leakage rate limit is proportional to size and is adequate to detect degradation. Additionally, the licensee will analyze and perform corrective actions in accordance with Section XI, IWV-3426 and IWV-3427. The Section XI, IWV 3426, 3427(a), and 3200 requirements are equivalent to OMa-1988, Part 10, 4.2.2.3(e) ar.d (f). Accordingly, the attemative requested by the licensee is cove, red by the rulemaking, effective September 8,1992, as described above, and relief, ther9 ore, is not required.
f Approval is recommended pursuant to 650.55a 1(f)(4)(iv). There are no related requirements.
24
e i
e 3.4 Auxillarv Feedwater System 1
3.4.1 Valve Relief Request VR-33, Auxillary Feed water System Flow Control Solenold-Operated Valves SE 09 2, SE-09 3, SE-09 4, and SE 09-5 Relief Request: The licensee requests relief from trending valve stroke times quarterly and increasing the test frequency to monthly based on an increase in stroke time relative to the previous test for 4 in. Auxiliary Feedwater System (AFWS) solenoid-operated valves SE 2. SE-09 3, SE-09-4, and SE-09-5, as required by the ASME Code,Section XI, lWV-3417(a). These solenoid valves cycle open and closed during an AFWS actuation to control auxiliary feedwater flow to the steam generators.
Proposed Altemate Testing: During quarterly testing, these valves will be exercised and fail-I safe tested. Dunng this exercising, stroke times will be recorded but the corrective action requirements of IWV-3417(a) will not be applied. If the maximum allowed stroke time is exceeded, then the valves will be placed out of service.
During cold shutdowns, the valves will be exercised and the requirements of IWV-3417(a) will be met.
Licensee's Basis for'Rulief: The licensee states that: "These four valves are pilot-operated normally closed, solenoid globe. valves. When their solenoid coil is energized, the magnetic force lifts the pilot disk, opening the pilot orifice in the main disk. Any pressure in the chamber above the ma.in disk can now vent off through the pilot orifice to the downstrearn side
.of the valve. With the pressure vented above the main disk,' the upstream pressure acting on the lower sido of the main disk lifts it off the main seat, opening the valve. in the absence of a j
pressure differential, no pressure force exists tending to seat the disc, therefore the magnetic force of the solenoid coil is sufficient, acting through the stem, pilot disc, and pin, to directly lift the main disc'off the seat, opening the valve. Due to this arrangement, the stroke times measured without differential pressure are slower and vary sign;ficantly from test to test causing.the valves to be subjected to increased testing per IWV 3417(a) frequently and i
unnecessarily.
In order to establish the appropriate pressure conditions needed for proper testing, the associated AFW pump must be in operation discharging into the steam generator. Pumping from the auxiliary feedwater into the steam generators during normal operation is impractical and undesirable. Injecting the relatively cold auxiliary feedwater into the main feedwater line while the plant is operating at power would cause a large temperature differential (approximately 375'F). Significant thermal shock and fatigue cycling of the feedwater piping and steam generator nozzles could result."
Evaluation: Section XI,1 IWV 3417(a) states that 'If, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full stroke times greater than 10 sec. or 50% or more for valves with full-stroke time less than or equal to 10 sec is observed, test frequency shall be increased to once each month until corrective actiori is taken...'
25
o The valves in question, ASME Code Category B valves, which cycle open and close " uring an d
AFWS actuation to control auxiliary feedwater flow to the steam generators, are piloted, normally closed, solenoid globe valves made by the Target Rock Corporation. Because of the valve design, the stroke times must be measured without differential pressure. The licensee claims that the measured stroke times are not only slower, but they also vary significantly from test to test causing the valves to be placed into alert unnecessarily.
Section 50.55a 1 (f)(4)(iv) provides that inservice testing of valves may meet the requho...ents set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions and addenda may be used provided that all related requirements of the respective editions and addenda are met. The NRC staff imposed no limitations to OMa 1988 Part 10 associated with stroke time measurements.
OMa-1988, Part 10, ~l,3.3 requires that reference values shall be determined from the results of pre. service testin.g or,from the results of inservice testing. These tests shall be performed under conditions as near as practicable to those expected during subsequent inservice testing. Part 10, 3.5 permits the establishment of an additional set of reference values if it is necessary or desirable for some other reason, other than as stated in 3.4, i.e.,
when a valve or its control system has been replaced, repaired, or has undergone maintenance t"at could affect the valve's performance. Therefore, if test conditions for the quarterly tests are different from those at cold shutdown, an additional set of reference values can be established.
OMa-1988 Part 10 does not require alert trending. Part 10, 4.2.1.8 requires that stoke time test results shall be compared to the initial reference values or reference values established in accordance with paragraphs 3.4 and 3.5. For solenoid-operated valves with reference stroke times greater than 10 seconds, 4.2.1.8 states that they shall exhibit no more than a 125% change in stroke time when compared to the reference value. For solenoid-operated valves with reference stroke times less than 10 seconds, 4.2.1.8 states that they shall exhibit no more than a 50% change in stroke time when compared to the reference value. Part 10, 4.2.1.9 requires valves with stroke times that do not meet the acceptance j
critena of 4.2.1.8 to be retested or declared inoperable, if the velve is retested and also does not meet the acceptance enteria of 14.2.1.8, the licensee may analyze the data to verify that the new stroke time represents acceptable valve operation. Otherwise the valve is required to be declared inoperable.
Therefore, provided the licensee uses OM-10, 4.2.1.8 and all related requirements including the corrective actions in 4.2.1.9, relief from trending valve stroke time is covered by the rulemaking, effective September 8,1992, as described above, and relief is not required.
Approval is recommended pursuant to 950.55a (f)(4)(iv). Implementation of related requirements is subject to NRC inspection.
S 26
3.5 Intake Coolina Water System
- 3. 5.1-Valve Relief Request VR 34, intake Cooling Water to Component Coolirig Water Heat Exchangers Butterfly Temperature Control Valves TCV-14 4 A and TCV-14-4B Relief Request: The licensee requests relief from trending valve stroke times quarterly and increasing the test frequency to monthly based on an increase in stroke time relative to the previous tost for the intake cooling water 30 in. butterfly temperature control valves TCV 4A and TCV-14-4B to the component cooling water (CCW) heat exchangers, as required by the ASME Code,Section XI, IWV-3417(a). These control valves regulate the amount of intake cooling water flowing through the component cooling system heat exchangers. In the event of failure, these valves will f ail open.
Proposed Alternate Testing: These cives will be exercised and fail-safe tested quarterly.
However, the corrective action requirements of IWV-3417(a) will not be applied. If their j
stroke times exceed the maximum allowed stroke time, then the valves will be placed out of l
service.
Licensee's Basis for Relie/: The licensee states that: "These two valves are operated via air i
signals from thek temperature controllers. In the manual mode of operation the positioning air signal from the controllers is varied by manipulating a rheostat. Due to the slow response j
time of the controllers in the manual mode there is the potential for a large variation in valve i
stroke times from test to test. This inherent variability is sufficient to cause a valve to fall into the increased test frequency corrective action range without any significant physical change in mechanical condition of the valve. The valve can also be operated (opened) by closing i
the valve using the r.1anual controller t.nd then isolating and then venting the c.ontrol air signal to the valves. The elapsed time required to isolate and then vent the control air is added to the time required to vent the air pressure from the valve operator to arrive at the measured valve stroke time. Thus the measured stroke time is as much a function of the capability of the individual operator to manipulate the valves as it is the mechanical condition.of the valve.
Typically successive stroke times vary sufficiently to cause the valves to be subjected to the increased testing per IWV-3417(a) frequently and unnecessarily."
Evaluation: Section XI, IWV-3417(a) states that "If, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 sec. or 50% or more for valve with full-stroke time less than or equal to 10 sec. is observed, test frequency shall be increased to once each month until corrective action is taken...'
The valves in question, ASME Code Category B valves, regulate the amount of intake cooling water flowing through the CCW heat exchangers. Due to the resportse time of the controllers, the valve stroke times vary from test to test sufficiently to place the valves into alert occasionally. When testing is performed manually, the time to isolate and then vent the control air is dependent upon the operator performing the test. The licensee claims that these stroke times also vary from test to test sufficiently to place the valves into alert occasionally.
Section 50.55a (f)(4)(iv) provides that inservice testing of valves may meet the 27
)
o requirements set forth in subsequent editions and addenda of Section XI that are iricorporated by reference in paragraph (b) of $50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions and addenda may be used provided that all related requirements of the respective editions and addenda are met. The NRC staff imposed no limitations to OMa-1988 Part 10 associated with stroke time measurements.
OMa 1988, Part 10, 3.3 requires that reference values snall be determined from the results of preservice testing or from the results of inservice testing. These tests shall be performed under conditions as near as practicable to those expected during subsequent inservice testing.. Part 10, 3.5 permits the establishment of an additional set of reference values if it is necessary or desirable for some other reason, other than as stated in 3.4, i.e.,
when a valve or its control system has been replaced, repaired, or has undergone maintenance that could affect the valve's performance. Therefore, if test conditions for the quarterly tests are different from those at cold shutdown, an additional set of reference values can be established.
]
i OMa-1988 Part 10 does not require alert trending. Part 10, 4.2.1.8 requira, that stroke time test results shall be compared to the initial reference values or reference values established in accordance with paragraphs 3.4 and 3.5. For air-operated valves with reference stroke times greater than 10 seconds, 4.2.1.8 states that they shall exhibit no more than a' 25% change in strc'te time when compared to the reference value. For air-operated valves with reference stroke times less than 10 seconds, 4.2.1.8. states that they shall exhibit no more than a 50% change in stroke time when compared to the reference value. Part 10, 4.2.1.9 requires valves with stroke times that do not meet the acceptance criteria of 4.2.1.8 to be retested or declared inoperable. If the valve is retested and also does not meet the acceptance criteria of 4.2.1.8, the licensee may analyze the data to verify that the new stroke time represents acceptable valve operation. Otherwise the valve is required to be declared inoperable.
Therefore, provided the licensee uses OM-10, 4.2.1.8 and all related requirements including the corrective actions in 4.21.9, relief from trending valve stroke times is covered by the rulemaking, effective September 8,1992, as described above, and based on meeting Uter Code requirements, relief is not required. Approval is recommended pursuant to 950.55a 4
(f)(4)(iv). Implementation of related requirements is subject to NRC inspection.
)
3.6 Check Valve Relief Reauests -Deferral gLlestina Lq_Ref uelina i
The ASME Ccde,Section XI, IWV-3521 and IWV-3522 specify that check valves shall be.
exercised at least once every 3 months to the position required to fulfill their function unless such operation is not practical during plant operation.~
In rulemaking to 10 CFR 50.55a effective September 8,1992, the 1989 Edition of ASME Section XI was incorporated in paragraph (b) of Q 50.55a. The 1989 Edition provides that the rules for inservice testing of valves are as specified in OMa-1988 Part 10. The NRC staff imposed no limitations to OMa 1988 Part 10 associated with testing valves during cold shutdown or refueling. Section 50.55a (f)(4)(iv) provides that inservice testing of valves may meet the requirements set forth in subsequent editions and addenda of Section XI that are incorporated by reference in paragraph (b) of $50.55a, subject to the limitations and 28 6
i J
modifications listed, and subject to NRC approval. Portions of editions and addenda'may be used f
. provided that all related requirements of the respective editions and addenda are met, j
OMa-1988, Part 10, 4.3.2.1, requires that check valves shall be exercised nominally every 3 months, except as provided by 4.3.2.2.
Specifically, 4.3.2.2(d) and (e) state that if ~
exercising (to the position required to fulfill its function, i.e., open and/or closed) is not j
practicable during plant operation or cold shutdowns, it may be limited to full-stroke exercising during refueling outages. Relief to utilize 4.3.2.2(d) and (e) is not required
(
provided all related requirements are implemented which includes 4.3.2.2(h) and 6.2.
implementation of related requirements is subject to NRC inspection.
i 3.6.1 Valve Relief Request VR 5, Chemical and Volume Control Check Valves I
l V-2177, 2190, 2191, and 2526 Relief Request: The licensee requests relief from fuli stroke exercising, to the open position i
quarterly, the 3 in. CVCS check valves V 2177,2190, and 2191, and the 4 in. CVCS check 4
valve, as required by the ASME Code Section XI, IWV 3521 and 3522.
i Proposed Alternate Testing: " Check valve V-2190 will be verified closed quarterly. Each of these valves will be part stroke exercised once during each cold shutdown per VR 1 and full-l stroke exercised during each reactor refueling outage. If exercising duririg the cooldown j
evolution is impractical, testing for that cold shutdown period may be deferred."
l
}
Licensee's Basis for Relief: The licensee states that: " Testing these valves in the open direction I
requires the introduction of highly concentrated boric acid solution from the boric acid makeup j
tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess
]
{
boron to the RCS. A rapid insertion of negative reactivity could result in a rapid RCS cooldown and depressurization and possibly a plant trip.
During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemis,try and the inherent difficulties I
that may be encountered during the subsequent startup due to over-boration of the RCS. The I
waste management system would also be overburdened by the large' amounts of RCS coolant that would require processing to decrease the boron concentration.
4 Typically, the boron concentration is increased for shutdown margin during cooldown prior to I
reaching cold shutdown conditions. This is the only practical time to perform the partial stroke i
exercise test since boration during shutdown and startup is undesirable. In the event tha.
circumstances prohibit testing during cooldown, tes:ing for that cold shutdown may be deferred i
to the next cooldown evolution."
j Evaluation: The licensee states that 'V 2177 and V 2526 open to provide a flow path for j
emergency boration from the boric acid makeup pumps to the suction of the charging pumps.
Likewise, V 2190 opens to provide a flow path for emergency boration via gravity drain from the boric acid makeup tanks to the suction of the charging pumps.. V 2190 closes to preverit recirculation to the boric acid makeup tanks ' hen the boric acid makeup pumps are in w
operation. Valve V-2191 opens to provide a flow path from the refueling water tank (RWT) to the suction of the charging pumps as an alternate supply of borated water for boration.'
29 1
m
n it is impractical to full-stroke exercise these valves to the open position either quarterly or at cold shutdowns, or partial-stroke exercise them at every cold shutdown because highly concentrated boric acid would be introduced into the RCS which would impose an undue burden with respect to maintainino proper plant chemistry during startup and also with respect to overiaxing the waste management system to process large amounts of RCS coolant to reduce boron concentration.
Thereforo, the licensee will part-stroke exercise these valves during plant cool downs when boron concentration in the RCS must be increased and full-stroke exercise these valves to the open position at refueling outages.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above. Approvalis recommended pJrsuant to 10 CFR 55.55a
.l (f)(4)(iv).
l 3.6.2 Valve Relief Request VR 6, Chemical and Volume Control System Check Valves V 2443 and V-2444 Relie/ Request: The licensee requests elief from full-stroke exercising, to the open position l
quarterly, the 3 in. CVCS check valves V-2443 and 2444, as required by the ASME Code,Section XI, IWV-3521 and 3522.
Proposed Alternate Testing: 'Each of these valves will be partial stroke exercised (open and closed) quarterly. During testing of the boric acid makeup pumps performed during each reactor refueling (See Relief Request PR 5), system flow rate ~will be measured to verify full stroke (open) of these valves."
Licensee's Basis for Relie/; The licensee states that: ' Full-stroke testing these valves requires operating the boric acid makeup pumpe at or near rated flow and verifying full accident flow through each valve. Such testing would cause the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS. This rapid insertion of negative reactivity would result in a rapid RCS cooldown and depressurization. A large enough boron addition would result in an unscheduled plant trip and a possible initiation of Safety injection Systems.
During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-beration of the RCS. The waste management system would also be overburdened by the large amounts of RCS coolant that would require processing to decrease its boron concentration.
A second circuit that circulates water to the VCT has flow rate measuring instrumentation installed (;) however it is limited to approximately 30 gpm. During an accident, either pump's discharge check valve must be able to pass a minimum flow capable of matching the demand of the two running charging pumps (greater than 80 gpm.).*
. 30
l Evaluation: The licensee states that: 'These valves open to provide a flow path from the boric acid makeup pumps to the emergency boration header. They close to prevent recirculation flow through an idle pump.'
It is impractical to full-stroke exercise these valves to the open position either quarterly or at cold shutdowns in order to prevent the introduction of highly concentrated boric acid into the RCS which would impose an undue burden with respect to maintaining proper plant chemistry during startup and also with respect to overtaxing the waste management system to process large amounts of RCS coolant to reduce boron concentration.
Therefore, the licensee will part stroke exercise these valves open and closed quarterly and full-stroke exercise these valves to the open position at refueling outages during testing of the boric acid makeup pumps. The valves also are tested closed quarterly.
Accordingly, the relief requested by the licensee is covered by the,rulemaking effective September 8,1992, and relief is not required, provided that all re!ated requirements are implemented, as described above. Approval is recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
3.6.3 Valve Relief Request VR-7: Safety hdection System Check Valves V-07000 and V-07001 Relief Request: The licensee requests relief from full-stroke exercising, to the open position quarterly, the 14 in. SIS Low Pressure Safety injection (LPSI) pump suction check valves V-07000 and 07001, as required by the ASME Code,Section XI,1 IWV-3521 and 3522.
Proposed Altemate Testing: "These valves will be partial-flow exercised during quarterly testing of the LPSI pumps via the minimum flow circuit and full-flow exercised during each reactor refueling outage.'
Licensee's Basis for Relief: The licensee states that: " Full stroke exercising these valves to the open position requires injection into the RCS via the LPSI pumps. During plant operation this is precluded because the LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. At cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function. Thus, the only practical opportunity"for testing these valves is during refueling outages when water from the RWT is used to fill the refueling cavity.
- Evaluation: The licensee states that: "These valves open to provide flow paths from the RWT to the suction of the associated low-pressure safety mjection pump.'
It is impractical to full stroke exercise these valves to the open position quarterly or during cold shutdowns because during plant operation, the LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure, and during cold shutdowns, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function.
31
Therefore, the licensee will partial-stroke exercise these valves quarterly using partial flow developed during quarterly testing of the LPSI pumps via the minimum flow circuit, and will full-stroke exercise these valves using full flow during refueling outages when water from the RWT is used to fill the refueling cavity.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that ali related requirements are implemented, as described above. Approvalis recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
3.6.4 Valve Relief Request VR 8: Safety injection System Check Valves V-3401 and V 3410 Relief Request: The licensee requests relief from full-stroke exercising, to the ep9n position quarterly, the 6 in. valve V-34'01 and 8 in. valve V-3410, which are the SIS High Pressure Safety injection (HPSI) pump suction check valves, as required by the ASME Code,Section XI,1 IWV-3521 and 3522.
Proposed AItemate Testing: "These valves will be partial-flow exercised during quarterly testing of the HPSI pumps via the. minimum flow circuit and full-flow exercised during each reactor refueling outage. This alternate testing satisfies the requirement of Generic Letter 89-04, Position 1."
Licensee's Basis for Relief: The licensee states that: ' Full stroke exercising these valves to the open position requires injection into the RCS via the HPSI pumps. During plant operation this is precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome
)
primary system pressure. During cold shutdown conditions, operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9."
Evaluation: The licensee states that: "These valves open to provide flow paths from the RWT and the containment sump to the suction of the associated high-pressure safety injection pumps i
(HPSI)."
it is impractical to full-stroke exercise these valves to the open position quarterly or during cold shutdowns because during plant operation, the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure and, during cold shutdowns, operation of the HPSI pumps is restricted to preclude RCS pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.
Therefore, the licensee will partial-stroke exercise these valves quarterly using partial flow developed during quarterly testing of the HPSI pumps via the minimum flow circuit, and will full-stroke exercise these valves using full flow during refueling outages (when water from the RWT is used to fill the refueling. cavity).
The relief requested by the licensee is covered by the rulemaking, effective September 8, 32
1992, and relief is not required, provided that all related requirements are implemented, as described above. Approval is recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
The licensee states that this alternate testing satisfies the requirement of Generic Letter 89-04, Position 1. As discussed in Position 1, the NRC staff position is that passing the maximum required accident condition flowrate through the valve is an acceptable full stroke. It is 3
j assumed that the full-flow exercise proposed by the licensee complies with this position, if
]
other techniques are used, such as non intrusive techniques at reduced flow rate, the licensee j
must comply with the six criteria required by Position 1.
Therefore, the licensee should clarify this statement in the request.
3.6.5 Valve Relief Request VR-9: Safety injection System Check Valves V-3414 and V-3427 Relief Request: The licensee requests relief from full-stroke exercising, to the open position '
quarterly, the 3 in. SIS HPSI pumps discharge check valves V 3414 and V-3427, as required
)
by the ASME Code,Section XI, IWV-3521 and 3522.
3 l
Proposed Altemate Testing: "These valves will be verified closed quarterly and full-flow exercised to the open position during each reactor refueling outage. These valves will be part-stroked open during cold shutdown as per VR-1."
Licensee's Basis for Relief: The licensee states that: " Full stroke exercising these valves to the open position requires injection into the RCS via the HPSI pumps. During plant operation this 4
is precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. During cold shutdown conditions, operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications,.Section 3.4.9.
Partial flow exercising of these valves.can be performed by one of the two following methods:
when the HPSI pump is used to refill a SIT or when a HPSI pump is recirculated back through the SIT to RWT drain line. Partial-stroke exercising the check valves by filling a SIT can not readily be used because the acceptable SIT level band, specified by the Technical Specifications, is very narrow. The SIT are only refilled on an as needed basis; therefore, the partial flow test 3
cannot readily be incorporated into a quarterly test.
' Partial-stroke exercising of these check valves quarterly can not be performed by using the
~
SlT to RWT drain line. This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this I
flow path is precluded in Modes 1,2,3, and 4.*
Evaluation: The licensee states that: "These valves open to provide flow paths from the respective HPSI pumps to the high-pressure safety injection headers..They close to prevent recirculation through an idle pump.'
It is impractical to full stroke exer'cise these valves to the open position quarterly or during cold shutdowns because during plant operation, the HPSI pumps cannot develop sufficient 33-i a
=
discharge pressure to overcome primary system pressure and, during cold shutdowns, operation of the HFSI pumps is restricted to preclude RCS pressure transients that could result in exceeding the pressure-temperature limits specified in the Technics! Specifications, Section 3.4.9.
It is impractical to part-stroke exercise to the open position quarterly these valves because this would require using a HPSI pump to either refill one of the Safety injection Tanks (SIT).
which are located inside containment and function as a passive source of Si flow to the RCS, or to recircuiate the flow from a HPSI pump back through one of the SIT to RWT drain lines. It would be an undue burden without a compensating increase in the level of safety to require the licensee to deplete and refill a SIT or to breach,:ontainment integrity by using a SIT to RWT drain line simply to test these valves.
With respect to testing in the open position, the relief requested by the licensee is covered by the rulemaking and relief is not required, provided that all related requirements are implemented, as described above. Approvalis recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
The licensee should clarify why the Valve Program Table references VR-9, when 'the valves are 4
to be tested closed quar'terly. It appears that no relief is necessary for the closed direction.
3.6.6 Valve Relief Request VR-10: Safety injection System Check Valves V-
~
3522 and V-3547 i
Relief Request: The licensee requests relief from full-stroke exercising, to the open and closed positions quarterly, the 3 in. SIS HPSI hot-leg injection check valves V-3522 and V-3547, as q
required by the ASME Code,Section XI,11WV-3521 and 3522.
Proposed Altemate Testing: "At least once during each reactor refueling outage these valves I
will be full-stroke exercised to the' open position. These check valves will be partial-stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR-1.
This alternate testing satisfies the requirement of Generic Letter 89-04, Position 1."
~ Licensee's Basis for Relief: _The licensee states that: " Full stroke exercising of these valves would require operating a high pressure safety injection (HPSI) pump and injecting into the reactor coolant system through the hot leg injection system. At power operation this is riot possible because the HPSI' pumps do not develop sufficient dir. charge pressure to overcome reactor coolant system pressure. During cold shutdown conditions, full flow operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.
Partial-stroke exercising of these check valves quarterly can not be performed by using the SIT to RWT drain line. This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of
, containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this flow path is precluded in Modes 1,2,3, and 4.*
i 34
i Evaluation: The licensee states that: "These valves open to provide flow paths fror$1 the high pressure safety injection pumps to the RCS for hot-leg injection. Should'the normal charging i
header become disabled, these valves are required to close to direct charging flow to the RCS via the HPSI headers."
It is impractical to iull stroke exercise these valves to the open position quarterly or during cold shutdowns because during plant operation, the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure and, during cold shutdowns, operation of the HPS! pumps is restricted to preclude RCS pressure transients that could result in exceeding the pressure temperature limits specified in the Technical Specifications, Section 3.4.9.
It is impractical to part stroke exercise these valves to the open position quarterly because this would require using a HPSI pump to eithst refill one of the Safety injection Tanks (SIT),
which are located inside containment and function as a passive source of Si flow to the RCS, or to recirculate the flow from a HPSI pump back through one of the SIT to RWT drain lines. It would be an undue burden without a compensating increase in the level of safety to require the licensee to deplete and refill a SIT or to breach containment integrity by using a SIT to RWT drain line simply to test these valves.
~
j The relief requested by the licensee is covered by the rulemaking, effective September 8, 1992, and relief is not required, provided that all related requirements are implemented, as described above. Approval is recommended pursuant to 10 CFR SS.55a 1 (f)(4)(iv).
The licensee states that this alternate testing satisfies the requirement of Generic Letter 89-04, Position 1. As discussed in Position 1, the NRC staff position is that passing the maximum required accident condition flowrate through the valve is an acceptable full-stroke. Itis assumed that the full-flow exercise proposed by the licensee complies with this position. If other techniques are used, such as non-intrusive techniques.at reduced flow rate, the licensee must comply with the six criteria required by Position 1; Therefore, the licensee should clarify this statement in the request.
3.6.7 Valve Relief Request VR 11: Safety injection System Check Valves V-3113, V 3133, V-3143, and V-3766 Felief Request:.The licensee requests relief from full-stroke exercising, to the open position quarterly, the 2 in. SIS HPSI high-pressure injection header check valves V-3113,3133, 3143, and 3766, as required by the ASME Code,Section XI, IWV-3521 and 3522.
Proposed Alternate Testing: "These valves will be partial. flow exercised during cold shutdown periods per VR-1. At least once during each reactor refueling outage these valves will be full-stroke exercised to the open position."
Licensee's Basis for Relief: The licensee states that: ' Full stroke exercising of these valves would r6 quire operating a high pressure safety injection (HPSI) pump at nominal accident flow rate and injecting into the reactor coolant system. At power operation this is not possible because the HPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. During cold shutdown conditions, full flow operation of the HPSI 35
_ _ _ _. _ _ _. -. _ _ _ ~. _.
\\
pumps is restricted to preclude RCS system pressure transiertts that could result in exceeding l
the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.
j i
i Partial flow exercising of these valves is performed whenever its associated SIT is, refilled.
The acceptable SIT level band specified by the Technical Specification is very narrow. The SITS
[
are only refilled on an as needed basis; therefore, the partial flow test cannot readily be incorporated into a quarterly test.
)
Partial stroke exercising of these check valves quarterly can not be performed by.using the SIT to RWT drain line. This method requires that the containment isolation valvos, one of them a
i a manual valve, be opened to complete the flow path. This would constitute a broach of.
containment integrity, as defined in Technical Specifications 3.6.1.1, and there' ore use of this flow path is precluded in Modes 1,2,3, and 4."
Evaluation: The licensee states that:"These valves open to provide flow paths from the high pressure safety injection i.eaders to the RCS."
It is impractical to full-stroke, exercise these valves to the open position quarterly or during.
l-cold shutdowns because during plant operation, the HPSI pumps cannot develop sufficient 1
discharge pressure to overcome primary system pre:;sure and, during cold chutdow'ns, j
operation of the HPSI pumps is restricted to preclude RCS pressure transients that could result in exceeding the prsssure temperature limits specified in the. Technical Specifications, Section 3.4.9.
it is impractical to part stroke exercise these valves to the open position quarterly because this would require using a HPSI pump to either refill one of'the Safety injection Tanks (SIT),
which are located inside containment and function as a passive source of Si flow to the RCS, or j
to recirculate the flow from a HPSI pump back through one of the SIT to RWT drain lines. It would be an undue burden without a compent. g increase in the level of safety to require the 4
licensee to deplete and refill a SlT or to breach containment integrity by using a SIT to RWT drain line.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are
' l implemented, as described above. Approval is recommended pursuant to 10 CFR 55.55a 1 (f)(4)(iv).
3.6.8 Valve Rollef. Aquest VR-12: Safety. Injection System Check Valves V-i 3524, V-3525, V-3526, and V-3527 Relief Request: The licensee requests relief from full-stroke exercising, to the open and closed positions quarterly, the 3 in. SIS HPSI hot-leg injection to RCS check valves V-3524,3525, 3526, and 3527, as required by the ASME Code,Section XI,1 IWV-3521 and 3522.
Proposed Alternate Testing: 'These check valves will be partial stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR 1.
l These valves will be full-str'oke exercised to the open position at least once during each reactor 36
--,r r
~.,--.,: -.
..e--
refueling outage. This satisfies the requirements of Generic Letter 89-04, Position 1.
At least once every 18 months these valves will be verified to close in conjunction with PlV leak testino (see VR-2). In addition, V-3525 and V-3527 will be leak tested if the upstream pressure monitors indicate alarm during normal operation."
Licensee's Basis for Relief: The licensee states that: " Full stroke exercising of these valves would require operating a high pressure safety injection (HPSI) pump at nominal accident flow rate and injecting into the reactor coolant system. At power operation this is not possible because the HPSI pumps do not develop suffic'ient discharge pressure to overcome reactor coolant system pressure. During cold shutdown conditions, full flow operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications Section 3.4.9.
Partial-stroke exercising of check valves V-3524 and.V-3526 quarterly can not be performed by using the SIT to RWT drain line. This method requires that the containment isolation valves, one of them a manual valve, be oper ad to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specificaticos 3.6.1.1, and therefore use of this flow path is precluded in Modes 1; 2,3, and 4.
These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Performing leak tests of V-3524 and V-3526 involves a considerable effort. The test connection (s) for these valves are located in a high radiation area in the pipe penetration room, and one of the two connections is located over 12 feet above the floor. Testing during operation would constitute an unreasonable burden on the plant staff.
The other check valves, V 3525 and V 3527 have upstream pressure alarms. Should either valve leak by..the pressure instruments would detect the increase and alarm in the control room when the alarm setpoint is exceeded."
Evaluation: The !!censee states that: "These valves open to provide flow paths from the high-pressure safety injection pumps to the RCS for hot leg injection and close to isolate the safety injection headers from the high pressure of the reactor coolant system."
It is impractical to full-stroke exercise these va!ves to the apen position quarterly or during cold shutdowns because during plant operatim, the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure and, during cold shutdowns, operation of the HPSI pumps is restricted to preclude RCS pressure transients that could result in exceeding the pressure temperature limits specified in the Technical Specifications, Section 3.4.9.
r l
it is impractical to part-stroke exercise valves V 3524 and 3526 to the open position quarterly because this would require using a HPSI pump to recirculate the flow from a HPSI pump back through one of the Safety injection Tanks (SITS), which are located inside containment and function as a passive source of Si flow to the RCS, to the Refueling Water Tank
'(RWT) drain lines. It would be an undue burden without a compensating increase in.the level of safety to require the licensee to breach containment integrity by using a SIT to RWT drain line.
l l
37 I
l
4 Additionally, it is impractical to partial stroke exercise V-3525 and 3527 quarterly because i
the only path is into the RCS and as discussed above, the RCS pressure exceeds the HPSI pump discharge pressure.
All of these valves are simple check valves without position indication. The only practical method of verifying that the valves are capable of closure is by a leak test. It is impractical to verify closure of these valves quarterly because this requires performing a reverse flow test inside containment in e high radiation area. Based on the amount of time necessary to set-up and, perform the testing and the hazards to personnel, testing is impractical. In addition, V-3525 and V-3527 have upstream pressure alarms which actuate in the control room in the event of excessive leakage.
l The licensee has stated that "These valves will be partial-stroke exercised to the open position s.,u subsequently stroked closed during cold shutdowns per VR 1" and the basis only discus'ses the impracticality of testing quarterly. However, the Valve Program Table identifies the test frequency as 'SP' as per VR 12 and not "CS", and the licensee additionally states that the valves will be verified closed during the PlV leak tests. It is assumed that the valves are exercised to the closed position in accordance with the Code during cold shutdowns, in addition to the PlV leak test. The request's alternate testing should be clarified and, if exercising the valves closed at cold shutdowns is impractical, the basis must be revised to discuss the impracticality.
Therefore, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above. Approvalis recommended pursuant to 1,0 CFR 55.55a (f)(4)(iv).
The licensee states that this alternate testing satisfies the requirement of Generic Letter 89-04, Position 1. As' discussed in Position 1, the NRC staff position is that passing the maximum required accident condition flowrate through the valve is an acceptable full-stroke. 11is assumed that the full-flow exercise proposed by the licensee complies with this position. If other techniques are used, such as non-intrusive techniques at reduced flow rate, the licensee must comply with the six criteria required by Position 1.
Therefore, the licensee should clarify this statement in the request.
3.6.9 Valve Relief Request VR-15: Safety injection System Check V' 'alves V-3258, V-3259, V 3260, and V-3261 Relief Request: The licensee requests relief from full-stroke exercising, to the open and closed positions quarterly, the 6 in. SIS HPSI/LPSI injection headers to RCS check valves V-3258, 3259, 3260, and 3261, as required by the ASME Code,Section XI, IWV-3521 and 3522.
Proposed Alternate Testing: 'These valves will be partial flow tested and then verified closed whenever it!. associated SIT is refilled.
These valves will be full-stroke exercised to the open position during cold shutdown periods per Relief Request VR 1.
38
~.
0 These valves will be verified closed in conjunction with PlV leak testing. See VR 2 for'PlV testing frequency.'
Licensee's Basis for Relief: The licensee states that: "Since no full flow recirculation path exists, full stroke exercising of these valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flow rate and injecting into the reactor coolant
' system. At power operation this is not possible because the LPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure.
Partial flow exercising of these valves is performed whenever its associated SIT is refilled.
These valves are Pressure Isolation Valves which requires that they are verified closed and leak tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following flow through them. The acceptable SIT level band specified by i
the Technical Specification is very narrow. The SITS are only refilled on an as needed basis-therefore, the partial flow test cannot readily be incorporated into a quarterly test.
These are simple check valves with no extemal means of position indicati.on, thus the only practical means of verifying closure is by performing a leak test or back flow test."
Evaluation: The licensee states that:"These valves open to provide flow paths from'the high/ low pressure safety injection headers to the RCS and close to isolate the hea'ders from the high pressure of the' reactor coolant system."
It is impractical to full-stroke exercise these valves to t'he open position quarterly because during plant operation. the LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure.
It is impractical to part-stroke exercise these valves to the open position quarterly because such testing can only be performed when the associated SIT is refilled. The SIT level band specified by the Technical Specification is very narrow (from 1420 to 1556 cube feet). The SITS are only refilled on an as needed basis. Therefore, the partial flow test cannot be incorporated readily into a quarterly test.
It is impractical to verify closure of these simple check valves quarterly or during cold shutdowns because they are.not provided with remote position indication and performing a reverse flow test inside containment is the only practical method. This method is impractical to perform during operation or every cold shutdown due to the amoun't of time necessar' to set-y up and perform the test, personnel hazards, and radiation exposure. Therefore, the licensee's proposal to verify closure in accordance with the St. Lucie Unit 2 Technical Specifications for Pressure Isolation Valves, Table 3.41, at the frequencies defined in VR 2, is acceptable.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above, Approval is recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
9 39
l s
3.6.10 Valve Relief Request VR-18, Primary Make Up Water System l
Containment Isolation Check Valve V-15328 i
i Relief Request: The licensee requests relief from exercising the 2 in. Primary Make-Up Water System containment isolation check valve V-15328 closed quarterly or at cold shutdowns, as required by the ASME Code,Section XI,1 IWV 3521 and 3522.
Proposed Altemate Testing: At least once every refueling outage, this valve will be venfied to close in conjunction with the Appendix J leak testing program.
Licensee's Basis for Relief: The licensee states that: "This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Performing such a test demands that the makeup l
water supply line be isolated. This effectively isolates the sole supply of fire water to the containment which is unacceptable under any plant conditions. Thus, prior to leak testing in this manner.an alternate. firewater source must be established by rigging several temporary fire hoses through the maintenance hatch to the various fire fighting station in the containment
{
building. This is not possible during normal operation when primary containment is required j
and would constitute an undue burden on plant personnel during cold shutdowns."
baluation: This ASME Section XI, Category A/C valve, is the containment isolation valve for the primary make-up water supply line to the containment.Section XI requires check valves to be exercised to the position (s) in which the valves perform their safety function. The only safety-related function of this' valve is in the closed position. Confirmation that the valve is in the closed direction can be done by visual observation, by an electrical signal initiated by a position indicating device, by observation of appropriate pressure indications, by leak testing, or by other positive means.
The valve is not provided with position indication or pressure instrumentation. The only available method for testing this valve is by leak testing. It is impractical to test this valve quarterly or during cold shutdowns because the valve and test connections are located inside i
containment and the licensee has demonstrated that an undue twrclen would exist to leak test the valve in that an alternate source of fire fighting water to the containment building would have to be established.
OMa-1988 Part 10, 4.2.2.2 requires that Category A valves, which are containment isolation valves, shall be seat leak tested in accordance with Federal Regulation 10 CFR 50, Appendix J.
Appendix J requires that such testing be performed during each refueling, but in no case at intervals greater than 2 years.
Part 10,14.3.2.1, requires that check valves shall be exercised nominally every 3 months, except as provided by 14.3.2.2. Specifically, 4.3.2.2(e) states that if exercising (to the position required to fulfill its function, i.e., closed) is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above. Approval is recommended pursuant to 55.55a 1 (f)(4)(iv).
40 vm
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I J
implementation of related requirements is subject to NRC inspection.
3.6.11 Valve, Relief Request VR-19, instrument Air Header Containment l
Isolation Check Valve V-18196 4
R.e/ief Request: The licensee requests relief from exercising the 2 in instrument Air header cor;tainment isolation check valve V-18195 closed quarterly and at cold shutdowns, as required by the ASME Code,Section XI,1 IWV-3521 and 3522.
i Proposed Alternate Testing: At least once every refueling outage, this valve will be verified to close in conjunction with the Appendix J leak testing program.
4 Licensee's Basis for Relie/: The licensee states that: "This is a simple check valve with no external mean of position indication, thus the only practical means of verifying closure is by' performing a leak test or back flow test. This would require a considerable effort, including' entry into the containment building and securing all instrument air inside the containment.
4 There are over 50 valves, instruments, and controllers supplied by this one line. During a normal refueling outage, an alternate instrument air compressor must be connected to the isolated section of instrument air line in order to supply air to critical air operated components. The supply hose from the air compressor to the instrument air line is typical'y routed through thu containment maintenance hatch.
l
. During normal plant operation this is not practical due to the many critical operational components supplied by the instrument air system, the requirement to maintain primary i -
containment integrity, and the potential for unacceptable plant transients.
During cold shutdown, the activities associated with entry into the containtiient building, securing all instrument air inside the contairment, and opening the maintenance hatch to j
provide the alternate air supply are extensive and would likely result in an extension of any
^
interim outage (cold shutdown period). Thus testing this valve'during cold shutdown periods is considered to be an unreasonable burden on the plant staff and not commensurate with the potential gain in plant safety affprded by parformance of this test.'
^
Evaluation: This is a 2" ASME Section XI Category A/C valve, which is the containment isolation valve for the instrument Air header supply line to the containment at penetration 9.
Section XI requires check valves to be exercised to the position (s) in which the valves, perform their safety function. The only safety function of this valve is in the closed position.
Cc,nfirmation that the valve is in the closed direction can be done by visual observation, by an electrical signal initiated by a position indicating device, by observation of appropriate pressure indications, by leak testing, or by other positive means. The valve in question is not provided with position indication or pressure instrumentation.
The only available method for testing this valve is by leak testing. It is impractical to test this valve quarterly or during cold shutdo_wns because the valve and/or test connections are located 4
in, side containment and the licensee has demonstrated that an undue burden would exist to leak test the valve in that it would be necessary to secure all instrument air inside containment and route a hose from an alternate instrument air compressor through the maintenance hatch, thus extending the time in cold shutdown.
41 T
OMa 1988 Part 10, 4.2.2.2 requires that Category A valves, which are containment isolation valves, shall be seat leak tested in accordance with Federal Regulation 10 CFR 50, Appendix J.
Appendix J requires that such testing be performed during refueling, but in no case at intervals greater than 2 years.
Part 10, S 4.3.2.1 requires that check valves shall be exercised nominally every 3 months, except as provided by 4.3.2.2.
Specifically, 4.3.2.2(e) states that if exercising (to the position required to fulfill its function, i.e., closed) is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above. Approval is recommended pursuant to s50.55a (f)(4)(iv).
Implementation of related requirements a subject to NRC inspection.
3.6.12 Valve Relief Request VR-21: Containment Spray System Check Valves V-07129 and V-07143 Relief Request: The licensee requests relief from full-stroke exercising,to the open position quarterly, the 12 in. CS pump discharge check valves V-07129 and 07143, as required by the ASME Code,Section XI,1IWV-3521 and 3522.
Proposed Alternate Testing. "Each of these valves will be partial-stroke exercised quarterly in j
conjunction with testing of the containment spray pumps via the minimum flow test line.
j During each refueling outage, each valve will be exercised at least once to demonstrate full stroke capability."
Licensee's Basis for Relie/ The licensee states that: " Full stroke exercising of these valves-would require operating each containment spray pump at nominal accident flow rate.
Exercising these valves via the normal containment spray flow path would result in spraying down the containment - an unacceptable option. The only other practical flow path available for such a test requires pumping water from the refueling water tank (RWT) to the reactor coolant system (RCS) via the shutdown cooling loops.
During plant operation, the containment spray pumps cannot develop sufficient discha'rge pressure to overcome RCS pressure.
At cold shutdown, the shutdown cooling system cannot provided sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function."
Evaluation: The licensee states that: 'These valves open to provide flow paths from the respective containment spray pump to the containment spray pump headers."
It is impractical to full-stroke exercise these valves quarterly to the open position because -
this would require operating each containment spray pump at the nominal accident flow rate.
42 a
This could only be done by either spraying down the containment or by injecting in'to the
~
reactor coolant system through the shutdown coolir.g heat exchangers and low pressure headers.
This is impractical because the containment spray pumps cannot develop sufficient discharge pressure to overcome RCS pressure and spraying down the containment could. luse equipment damage and would be excessively burdensome.
It is impractical to full stroke exercise these valves to the open position at cold shutdowns because the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function.
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements.are implemented, as described above. Approvalis recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
i 3.6.13 Valve Relief Request VR-24, Containment Spray System Hydrazine Pump Discharge Check Valves V-07256 and V-07258 Relief Request: The licensee requests relief from exercising the 1/9 in. Containment Spray System hydrazine pump discharge check valves quarterly or during cold' shutdowns, as required by the ASME Code,Section XI, IWV-3521 and 3522. These valves open to allow flow from the hydrazine pumps to the respective containment spray pump suction neader.
Proposed Altemate Testing: During each reactor refueling outage these valves will be full-stroke exercised.
Licensee's Basis for Relief: The licensee states that: " Testing these valves using the only flow path available (via the hydrazine pumps) would contaminate the ' containment spray system and refueling water tank with hydrazine. Each of the hydrazine pumps discharge through its check valve into the suction piping of its containment spray pu.mp. The hydrazine would then be j
pumped to the RWT during the quarterly containment spray pump Code test using the mini flow recirculation line. Cont;nued testing would build up the concentra' tion of hydrazine in the RWT and deplete the level in its storage tank."
Evaluation: A review of drawings 2998 G-088, ' Flow Diagram Containment Spray and Refueling Water Systems,' Rev.19, dated 10/20/89 and 2998-G-078 Sh.130, " Flow Diagram Safety injection System (Sheet 1)," Rev. 4, dated 10/20/89, confirms that each of these hydrazine pump discharge check valves is located downstream of the hydrazine pump motor-operated discharge isolation valve in a 1/2 in. line leading to the suction header of the corresponding Containment Spray pump. To quarterly flow test the hydrazine pumps, flow is recirculated back to the Hydrazine Storage Tank (HST) through connections upstream of the pump motor-operated discharge isolation. No flow is passed through the pump discharge check valves during the quarterly pump tests.
Since each of the hydrazine pumps discharge through its check valve into the suction piping of its corresponding Containment Spray pump, the licensee ste.tes that to flow test the check valves, each Containment Spray pump must be operated and flow recirculated back to the 43 w
.m_
I j
Refueling Water Tank (RWT). The licensee sta'es that continued testing would bu'ild up i
concentration of hydrazine in the RWT and deplete the levelin the HST. Due to the personnel hazards associated with handling the hazardous chemical hydrazine, testing quarterly or during
)
cold shutdowns is impractical.
i Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implemented, as described above. Approval is recommended pursuant to 10 CFR.55.55a (f)(4)pv). Implementation of the related requirements is subject to NRC inspection.
1 3.6.14 Valve Relief Request VR-28: Safety injection System Check Valves V-3104 and V-3105 Rellet Request: The licenseo requests relief from full-stroke exercising, to the open position i
quarterly, the 2 in. SIS LPSI pump recirculation lines to the iTNT check valves V-3104 and 3105, as required by the ASME Code,Section XI, IWV-3521 and 3522.
}
Proposed Allemate Testing: "During quarterly pump testing each of these valves will be l
partial-stroke exercised (open) via recirculation through the minimum flow test circuits with S
no flow maasurements.
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During each reactor refueling outage these two valves will be flow tested. The test will calculate the flow through the mini-flow line by draining the reactor coolant system through j
the line while observing the pressurizer level drop or refueling water tank level increase. The i
level change divided by the time can be uted to verify the full, flow exercise of the two check valves.'
The Valve Program Table indicates that these normally closed valves are. tested closed 4
quartbrly.
Licensee's Basis for Relief: The licensee states that: 'There is no flow rate instrumentation available to verify valve full stroke exercising as required by Generic Letter 89-04, Position 1
- 1. "
4
)
Evaluation: The licensee states that: "These valves open to provide for mini-flow recirculation flow paths from'the low pressure safety injection pumps to the refueling water tank. This j
minimum flow through the respective pumps removes pump heat in the event they are' operating under low or no flow conditions. The valves close to prevent recirculation through i
the idle pump, and to prevent overpressurization of the LPSI piping from the discharge pressure of the HPSI pump."-
i From a review of the applicable flow diagrams, 2998-G-078, Sheet 130 Rev. 4, and the l
continuation on flow diagram 2998-G-088, Rev.19, it appears, that there is a flow element on each recirculation line, i.e., FE-03-11 and FE-03-2-1, which could be used to measure the recirculation line flow. The licensee should explain the statement that there is no flow instrumentation available to verify full stroke exercising of these check valves.
i Also, the licensee should explain why the quarterly LPSI pump flow test does not result in a
. 4 4.
l
o recirculation flow sufficient to cause foll-stroke exercising of these valves. No'n-intrusive methods could be utilized to verify the valves' obturator full-stroke.
OMa-1988 Part 10,14.3.2.2 allows full-stroke exercising that is not practicable during plant operation or cold shutdowns to be deferred to refueling outages. Therefore, provided the licensee furnishes information on why the installed flow elements or non intrusives cannot be used to verify the valves' full-stroke open quarterly and implements the related requirements, as described above, the relief requested by the licensee is covered by the rulemaking and approval could be recommended. However, if quarterly full-stroke exercising is practical, the j
licensee must comply with the Code requirements.
3.6.15 Valve Relief Request VR-32: Safety injection System Check ~ Valve V-3101 (2998-G 078, Sheet 130) i Relie/ Request: The licensee requests relief from full-stroke exercising,.o the open position quarterly, the 2 in. SIS supply line from the SITS to the VCT check, valve V3101, as required by the ASME Code,Section XI, IWV-3521 and 3522.
Proposed Alternate Testing: "This valve wiH be partial flow tested during cold shutdowns pe,r VR-1 end full-flow exercised once every refueling outage."
Licensee's Basis for Relief: The licensee states that: " Transferring the large quantity of water from a SIT to the VCR (sic) needed to verify full stroke would result in a significant increase of the boron concentration within the VCT and in the charging system makeup to the reactor coolant system (RCS) as well.
During normal plant operation, any increase of the VCT boron concentration could result in the excessive boron concentration in the RCS along with the insertion of negative reactivity.
Ultimately, the RCS would experience cooldown and depressurization with the potential for a plant trip.
During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration of the RCS. The waste management system could also be overburdened by the large amounts of RCS coolant that would require processing following dilution activities. During cold shutdown, transferring a limited quantity of water (less than that needed to confirm full stroke) from a SIT is '~ractical."
p Evaluation: The licensee states that: "This valve opens to provide to provide a flow path for borated water from the safety injection tanks (SIT's) to the volume control tank (VCT) to provide sufficient water inventory for plant cooldown should the refueling water tank (RWT) become unavailable."
It is impractical to full-stroke exercise this valve to the open position quarterly because this would significantly increase the boron concentration within the VCT and in the charging system makeup to the RCS. This could result in a cooldown and depressurization with the potential for a plant trip.
45 O
It is impractical to full-stroke exercise this valve to the open position during cold' shutdowns because this could result in difficulties in maintaining proper plant chemistry and also delay plant startup due to over boration of the RCS. The resulting excessive quantities of RCS requiring dilution would also overburden the waste management system.
{
Accordingly, the relief requested by the licensee is covered by the rulemaking, effective September 8,1992, and relief is not required, provided that all related requirements are implernnted, as described above. Approvalis recommended pursuant to 10 CFR 55.55a (f)(4)(iv).
4 4.0 VALVE TESTING DEFERRAL JUSTIFICATIONS Florida Power & Light has submitted 31 justifications for deferring valve testing. The,se justifications document the impracticality of testing 85 valvss in each ' unit quarterly, during power operation as required by Sect, ion XI. These justifications were reviewed u verify their
~
technical basis.
As discussed in Generic Letter 91-18, it is'not the intent of.lST to cause unwarranted plant shutdowns or to unnecessarily challenge other safety systems. Generally, those tests involving the potential for a plant trip, or damage to a system or component, or excessive personnel
^
hazards are not considered practical. Removing one train for testing or entering a Technical Specification limiting condition of operation is not sufficient basis for not performing the 2
required tests, unless the testing renders systems inopsrable for extended periods of time (Reference Generic Letter 87-09). 'Other factors, such as the effect on plant safety and the difficulty of the test, may be considered.
Valves, whose faliure in a non-conservative position during exercising would cause a loss of system function, such as non-redundant valves in lines (e.g., a single line from the RWST or j
accumulator discharge), or the RHR pump discharge crossover valves for plants whose l
licensing bases assumes that all four cold legs are being sup' plied by water from at least one i
pump (Reference NRC Information Notice 87-01), should not be exercised during conditions when the system is required to be operable. Other valves may fall into this category under certain system configurations or plant operating modes, e.g., when one train of a redundant ECCS system is inoperable, non redundant valves in the remaining train should not be cycled because their failure would cause a total loss of system function or when one valve in a j
containment penetration is open and inoperable, the redundant valve should not be exercised 4
during this system configuration.
~
BNL's evaluation of each cold shutdown justification is provide in Table 41. Each justification is given an item number to aid with the discussions. The anomalies associated with the specific justifications are provided in Section 5.16 of this TER.
I e
46
- ~ - -
Table 4.1-St.
Lucie Unit 2 Cold - Shutdown Justification Evaluations h
BM.
Valve identificatiorr-Drawing Licensee's Justification for Deferring Valve Proposed. Alternate Evaluation of Licensee's Justification-item No.
Exercising Testing No.
Reactor Coolant System RC-1 V-1460 through V-1466, 2998-G-
"These valves are administratively controlled Per the Valve it is impractical to exercise these. valves reactor vessel and 078, Sheet in the key-locked closed position with the Program Tables, open quarterly because these valves are pressurizer gas vents; ~1
- 107, power supply disconnected to prevent these valves are Class 1 isolation valves for the RCS and in. n6rmally-closed,
" Reactor inadvertent operation. Since these are Class 1 exercised open at are administratively controlled to the key solenoid-operated globe Coolant isolation valves for the reactor coolant cold shutdowns.
locked position with the breaker valves.
System system, failure of a valve to close or.
disconnected to prevent a loss of coolant i
(Sheet 1)", significant leakage following closure could in excess of the limits imposed by Rev.1 result in a loss of coolant in excess of the Technical Specification 3.1.3.
limits imposed by Technical ' 2ecification 3.1.3 leading to a plant shutdown. Furthermore, if a The alternative provides full-stroke -
valve were to fail open or valve indication fait exercising to the open position during cold to show the valve returned to the fully closed shutdowns in accordance with Section XI, position following exercising, prudent plani.
1 IWV-3411.
operation would probably likety result in a clant shutdown.'
RC-2 V-1474 and V-1475, 2998-G-
- Due to the potential impact of the resulting Per the V_alve It is impractical to exercise these valves
' Pressurizer Power-078, Sheet transient should one of these valves open Program Tables, open quarterly because stroking of those Operated Relief Valves; 3
- 108, prematurely or stick in the open position. it is these valves are valves at RCS pressure causes a small
~
in. solenoid-operated,
- Reactor considered imprudent to cycle them during exercised open at loss of RCS inventory and there is a normally closed globe Coolant plant operation with the reactor coolant cold shutdowns.
significant possibility that the any of one,
y
. :tves System system pressurized.*
of the valvos may stick in the open I
(Sheet 2)*,
position.-
Rev.O The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with Section XI, I
1 IWV-3411.
i t
f
+
b A
i 47 l
. ~
. -. ~.. - -. - - - -- - -. -. ~. ~. - -.
. -- -. ~ -
Tenee 4.1 (Cont.)
Ort.
Valve identification
. Drawing Licensee's Justification for Deferring Valve Proposed Alternate Evaluation of Licensee's Justification item.
No.
Exercising Testing g
4-CVCs
{
CV V-2522, Letdown Line -
2998 G.
" Closing this valve during operation isolates Per the Valve it is impractical to part-stroke or full-Containment isolation 078, Sheet the letdown line from the RCS and would result Program Tables, stroke exercise these valves closed Valve; 2 in. diaphragm--
- 120, in undesirable pressurizer level transients this valve is quarterly because of the resulting RCS operated, normally open
- Chemical with the potential for a plant trip. If a valve exercised to the transients.
& Volume failed to reopen, then an unexpected plant claed position and i
Control shutdown would be required.*
also fail safe The alternative provides full stroke System tested (to the exercising to the closed position during (Sheet 1)*,
closed position) at cold shutdowns in accordance with Section i
Rev.4 cold shutdowns.
XI.1 IWV-3411.
l CV-2.1 V-2501, Volume Control 2998 G-
- Cycling this valve during operation of a Per the Valve it is impractical to exercise this valve to Tank Outlet Valve;'4 in.
078, Sheet charging pump would isolate the VCT from the Program Tables, either the open or closed pos; tion i
t normally open, motor.
- 121, charging pump suction header damaging any this. valve is quarterly because of possible damage to
[
operated gate valve.
- Chemical operating charging pumps and interrupting the exercised to the the charging pumps.
t
& Volume flow of charging water flow to the RCS with open position and to Control the potential of RCS transients and plant trip.* the closed position. The alternative provides full-stroke System at cold shutdowns.- exercising to both the open and closed (Sheet 2)*,
positions during cold shutdowns in l
Rev.5 sceordance with Section XI.1 IWV-3411.
CV-2.2 V-2505 and V-2524, RCP 2998-G-
- Exercising either of these valves to the Per the Valve it is impractical to part-stroke or full-Control Bleedoff isolation. 078, Sheet closed position when any of the reactor coolant Program Tables, stroke exercise these valves to the closed i
Valves;. 3/4* normally
- 121, pumps (RCP's) are in operation would interrupt these valves are position quarterly because this could open,* diaphragm-operated ' Chemical flow from tha RCP seals and result in damage exorcised to the result in damage to the RCP seals.-
& Volume to the pump (s).*
closed position and Control fail safe tested (to The alternative provides for full-stroke System the closed position) exercising to the closed position at cold i
(Sheet 2)*,
at cold shytdowns.
shutdowns in accordance with Section XI,
[
Rev.5 1 !WV-3411.
l j
4 48 9
e
-.m-ww
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w
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_ _ _ _ ~ = -...
a Tenie 4.1 (Cont.)
BM.
Valve identification Drawing Licensee's Justification for Deferring Valve Proposed: Alternate Evaluation of Licensee's Justification item No.
Exercising Testing No.
CV 3.1 SE-02-03 and SE-02-04, 2998-G-
' Opening either of these valves (or failure in Per the Valve it is impractical to exercise these valves Auxiliary Pressurizer 078, Sheet the open position) during plant operation would Program Tables, to the open or closed position quarterly i
Spray Vafves; 2 in. locked 122, cause an RCS pressure transient that could these valves are because this could cause an RCS pressure closed, solenoid-operated
' Chemical potentially adversely affect plant safety and exercired to the
. transient that could affect plant safety globe valves
& Volume lead to a plant trip. In addition, the open and closed and lead to a plant trip, j
Control pressurizer spray piping would be subjected to position's and also f
System undesirable thermal shock."
fail safe tested (to The alternative provides full-stoke (Sheet 3)*,
the closed position) exercising to the open and closed positions Rev.5 at cold shutdowns.
at cold shutdowns in accordance with
[
Section XI.1 IWV-3411.
I CV-3.2 V-2431 Auxiliary 2998-G-
- In order to test this valve, either SE-02-03 Per the Valve it is impractical to part-stroke or full-Pressurizer Spray Check 078, Sheet or SE-02-04 must be opened. Opening either Program Tables, stroke exercise this valve to the open I
Valve; 2 in. hormally
- 122, of these valves (or failure in the open position) this check valve is position quarterly because this would closed check valve.
- Chemical during plant operation would cause an RCS f ull-stroke cause a pressure transient in the RCS
& Volume pressure transient that could potentially exercised to the from the spray of cold water into the Control adversely affect plant safety and lead to a open position at pressurizer, which in turn might cause a System plant trip. In addition, the pressurizer spray cold shutdowns.
plant trip and impose thermal stresses on (Sheet 3)*, piping would be subjected to undesirable the pressurizer spray piping.
Rev. S thermal shock.."
The alternative provides full-stroke
(
exercising to the open position at cold
. shutdowns in accordance with Section XI, 1 IWV-3521 and 3522.
CV-3.3 V-2440, Charging Pump 2998-G-
' Opening this valve requires operating a Per the Valve it is impractical to part-stroke or full-Discharge Check Valve to 078, Sheet charging pump and discharging into the RCS via Program Tables, stroke exercise this valve to the open i
Safety injection; 2 in.
- 122, the safety injection nozzles. Thermal cycling this valve is full-position quarterly since this would result normally closed check
" Chemical of the safety injection nozzles is undesirable stroke exercised to in undesirable thermal stress on the valve
& Volume and should be avoided.'
the open position at safety injection nozzies.
Control cold shutdowns.
The alternative provides full-stroke System (Sheet 3)*,
exercising to the open position at cold Rev.5 shutdowns in accordance with Section XI,
' 1 IWV-3521 and 3522.
49 5
n
,r.. -. -
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-.~-e e-e e.-
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Taose 4.1 (Cent.)
l 1
Brt Valve -ldentification Drawing Licensee's Justification for Deferring Valve Proposed. Alternate Evaluation'of Licensee's Justification -
Item -
No.
Exercising Testing -
No.
3'
(
)
CV-3.4 V 2515 and V-2516, 2998-G-
- Closing these valves during operation isolates Per the Valve it is impractical to part-stroke or full-4 Letdown Line isolation 078,' Sheet the letdown line from the RCS and would result Program Tables, stroke exercise these valves to the closed Valves; 2 in. diaphragm-
- 122, in undesirable pressurizer level transients.
these valves are position quarterly because this could operated, normally open
' Chemical with the potential for a plant trip, if a valve exercised to the cause a pressurizer level transient and
[
& Volume '
failed to reopen, then an unexpected plant closed position and possible plant trip.
Control.
shutdown would be required.'
fait safe tested (to System the closed position) The alternative provides full-stroke
[
(Sheet 3)*,
at cold shutdowns.
exercising to the closed position at cold Rev. 5 shutdowns in accordance with Section XI, f
1 IWV-3411 CV-3.5 V-2523 and V 2598, 2998-G-
" Closing these valves during operation isolates Per the Valve it is impractical to part-stroke or full-
[
Charging Line isolation 078, Sheet the charging pumps from the RCS and would Program Tables, V-stroke exercise to'the closed position Valves: V-2523 2 in.
- 122, result in undesirable pressurizer level 2523 is exercised quarterly V-2523 or exercise to the open diaphragm-operated,
- Chemical transients with the potential for a plant trip to the closed -
or closed position quarterly V-2598 locked open globe valve, V & Volume and potential damage to the charging pumps. If position at cold because this could cause a pressurizer
}
2598 2.5 in. normally Control a valve failed to reopen, then an unexpected shutdonns.
level transient and possible plant trip.
open, motor-operated gate System plant shutdown would be required.*
i valve (Sheet 3)*,
V-2598 is The alternative provides full-stroke Rev.5 exercised to the exercising at cold shutdowns in i
i open position at accordance with Section XI,1 IWV-34 tO.
I cold shutdowns.
i Safety injection / Residual Heat Removal Systems SI-1.1 V-3106 and V-3107, LPSI 2998-G-
- During normal plant operation, the LPSI
~ Per the Valve 11 is impractica,I to full-stroke exercise Pump Discharge Check 078, Sheet Pumps cannot develop sufficient discharge Program Tables',
the valves open quarterly.
Valves; 10 in. normally
- 130, pressure to pump through these valves.to the these valves are closed check valves.
'S af ety RCS and exercise them in the open direction.
part stroke The alternative provides part-stroke
(
Injection These valves will be partial flow exercised exercised open exercising to the open position quarterly l
System quarterly and full flow exercised each cold quarterly.and full-and full-stroke exercising to the open (Sheet 1),* shutdown."
stroke exercised position during cold shutdowns in Rev.4.
open at cold accordance with Sectioti XI,1 IWV 3521 shutdowns.
and 3522.
+
i 4
50 1
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t Table 4.1. (Cont.)
-4 EN.
Valve Identification Drawing Licensee's Justification for Deferring Valve Proposed Ahrnate Evaluation of Licensee's Justification ltom No.
Exercising
. Testing
{
No.
~
SI-2.2 V-3480. V-3481, V-2998 G--
- These valves are provided with electrical Per the Valve it is impra:tical to exercise these valves 3651 and V-3652, 078, Sheet interlocks that prevent opening whenever Program -Tables, open quarterly because, to prevent an Shutdown Cooling RCS 131 Reactor Coolant System pressure exceeds 275 these valves are interfacing systems LOCA, these valves l
Isolation Valves; 10 in.
"S a f ety psia. This precludes exercising these valves in exercised open are provided with electrical interlocks motor-operated, locked Injection any plant condition-other than cold shutdown.' with stroke time that prevent opening whenever RCS closed gate valves.
System measurement at pressure exceeds 275 psia.
(Sheet 2),"
cold shutdowns.
Rev.1 The alternative provides full-stroke t
exercising to the open position during cold shutdowns in accordance with Section XI, 1 IWV-3411.
i SI-2.3-V-3545, V-3664, and V-2998-G-
- The motor-operated valves V-3664 and V-Per the Valve The licensee should explain why a failure l
3665, Shutdown Cooling '
078, Sheet 3665 are isolation valvas for shutdawn cooling Program Tables, of V-3664 and V-3665 in the open Isolation and Cross
- 131, and V 3545 is the cross connect valve these valves are position would jeopardize the integrity of Connect Valves, to in.
' Safety between the two trains of shutdown cooling.
exercised open the LPSI System since the Shutd::wn motor-operated. locked injection These valves are normally locked closed. A with stroke time Cooling System valves V-3480 V-3481, closed gate' valves.
System failure of these valves in any other position measurement at V-3651 and V-3652, are immediately J
(Sheet 2)," could jeopardize the integrity of the Low cold shutdowns.
upstream and interlocked closed as Rev.1 Pressure Safety injection System.'
described above for.SI-2.2 Similarly, the licensee should desenbe i
under what conditions the cross connect '
valve V-3545 is opened during the i
^
shutdown cooling mode of operation and
- i also justify that its failure during normal l
plant operation would jeopardize the integrity of th's LPSI System since the it appears that only shutdown coohng would be affected and that shutdown cooling could still be accomplished with th.e valve I
i 3
+
e 52 i
O Table 4.1 (Cont.)
BM.
Valve Identification Drawing Licensee % Justifn.etion for Deferring Valve Proposed Atternate Evaluation of Licensee's Justification Itorn No.
Exercising Testing th SI-3.1 V-03002, V-03003 V-2998-G-
- Exercising these valves requires draining Per the Valve it is impractical to part-stroke or full-03004, and V-03005, 078, Sheet each of the SITS. This is not considered Program Tables, stroke exeicise these valves open Safety injection Tank 132 appropriate nor prudent activity to perform these valves 1re quarterly because this would require (SIT) Drain Line Check
- S a f ety during plant operation due to the obvious full stroke draining the SITS and restoring their level Valves; 1 in. normally injection safety issuet related to SIT inventory and exercis3d to tne which is governed by the Technica closed check valves System chemistry cc.ntrol.*
open position at Specifications.
(Sheet 3),*
cold shutdowns.
~
Rev.O The afternative provides full-stroke exercising to the open position during cold shutdowns in accordance with Section XI, 1 IWV-3M t and 3522 31-3.2 V-3614 V-3624 V.
2998-G-
' Stroke testing these valves in the closed Per the Valve it is i _ 'actical to exercise these valves 3634, and V-3644, SIT 078, Sheet direction during normal operation is not Program Tables, closed quarterly because they are locked Discharge isolation
- 132, possible. The valves are normally locked open these valves are open with their breakers removed, and Valves; 12 in. motor-
- Sa f ety with their breaker opened. Also they are exercised to the they are only closed during a normal plant operated, locked open gate injection interlocked with pressurizer pressure to closed position shutdown to prevent injection of the SIT valves System prevent these valves from closing with RCS with stroke time inventory into the RCS.
(Sheet 3),* pressure > 276 psia. Therefore, the valves measurement at Rev. O cannot be cycled except during cold cold shutdowns.
The alternative provides full-stroke shutdowns.*
exercising to the closed position at cold l
ihutdowns in accordance with Section XI, j
1 IWV-3411.
S1-3.3 V-3733 through V-3740, 2998-G-
- Cycling any of these valves during normal Per the Valve It is impractical to exercise these valves SIT Vent Valves; 1 in.
078, Sheet plant operation with the SITS pressurized is Program Tables, open or closed quarterly since this would solenoid-operated, locked
- 132, undesirable since it a valve were to fail to re-these valves are depressurize the SITS.
closed globe valves
- Sa f e ty close the result would be a depressurization of exercised to both injection the affect SIT.*
the open and closed The alternative providtes full-stroke System positions with exercising 13 both the open and closed (Sheet 3).*
stroke time positions' at cold shutdowns in accordance Rev. O measurements at with Section XI,1 IWV-3411.
cold shutdowns and fail safe tested (tc the closed position) at cold shutdowns.
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l BPL Valve Identification Drawing Licensee's Justification for Deferring Valve
~ Proposed Alternate Evaluation of Licensee's Justification Itom No.
Exercising Testing No.
1 FW-1.2 V-09tO7, V-09123, and N 2998-G-
" Full-stroke exercising of these valves would Per the Valve These check valves are located 09139, Auxiliary 080, Sheet require operation of the related auxiliary Program Tables, downstream of the AFW pump test f
Feedwater Pump 2 of 2, feedwater pump and injection of cold water these check valves recirculation lines to the Condensate Discharge Check Valves; 4 *Feedwater (85 deg-F) into the hot (450 deg-F) feedwater are full-stroke Storage Tank (CST). There valves do not in normally closed check supply piping. This, in turn, would result in exercised.open at open during the periodic AfW pump valves.
Condensate unacceptable thermal stress on the feedwa%r cold shutdowns.
testing.
f Systems
- system piping components.*
Rev.18 Furthermore, the AFW flow lines to the steam generators are isolated by
'normally closed, motor-operated valves l
which are downstream of these check..
[
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require opening the isolation valves and causing the cold AFW tiow to enter the steam generators, resulting in stred on the piping and steam generator nozzle connections.
Therefore, it is impractical to part-stroke or full-stroke open these valves quarterly, i
The alternative provides full-stroke exercising to the open position at cold i
shutdowns in accordance with Section XI, 1 IWV-3521 and 3522.
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l Table 4.1 (Cont.)
Brt.
Valve Identification Drawing Licensee's Justification for Deferring Valve Preposetj Alternate Evaluation of Licensee's Justification it:m No.
Exercising Testing 6
No.
instrument Air System t
IA-1 HCV-18 1 Primary 2998-G-
- Closing this valve isolates operating air to Per the Valve it is impractical to part stroke or full-Containment Instrument 085, Sheet critical components in the containment building Program : Tables, stroke exercise this valve to the closed Air Supply; 1 in. normally 2,
including the pressurizer spray valves and this valve is position quarterly because this could open,' diaphragm-operated "I n st r-CVCS letdown isolation valves and could cause exercised to the cause a severe plant transient and a plant j
ument Air severe plant transients and a plant trip.
closed position trip.
j System -
Failure in the closed position would cause a with stroke time Sheet 1.*
plant shutdewn "
measurement and The alternative provides full-stroke i
Rev. 21 fail safe tested (to exercising to the closed position at cold the closed position) shutdowns in accordance with Section XI, Miscellaneous Samolina SM-t V-27101 and V-27102, 2998-G-
- This is a simple check valve with no external Per the Valve it is impractical to part-stroke or t ill-t Hydrogen Sampling Return 092. Sheet means of position indication, thus the only Program. Tables, stroke exercise these valves to the,losed Line Containment Isolation 1
practical means of verifying closure is to th.ese valves are position quarterly because this regt..res l
Check Valves; 3/4*
- Miscellane perform a backleakage test. Performing such a full-stroke entry into the containment building to -
normally closed check ous test requires entry into the containment exercised to the perform a rcverse flow test.
i valves Sampling building and breaching of the system, thus it is open position Systems,'
impractical to do during plant operations.*
quarterly; and full-The alternative provides full-stroke Rev. 18 stroke exercised to exercising to the closed position at cold the closed position shutdowns in accordance with Section XI, at cold shutdowns.
1 IWV-3521 and 3522.
b 9
i l
I 6
?
I 59 f
___._________---____.____-..m--._...~_v,-.
I Table 4.1 (Cent.)
i BM.
Valve identification Drawing Licensee's Justification for Deferring Valve Proposed Alternate Evaluation of Licensee's Justification Itzm No.
Exercising Testing i
i
)
Heating, Ventilating, &
Air Conditionina HV 1.1 FCV-25-1 through FCV-25 2 998.G-
- These valves are required to remain closed at Per the Yalve it is impractical to part-stroke or full-f 6, Primary Containment
- 878, all times when the plant is operating in Modes Program! Tables, stroke exercise these valves to the closed Purge and Vent Valves; 48 *HVAC -
1 through 4, thus they are not required to these valves are position quarterly because of their.large in, piston-operated, locked Control operate (close) during operational periods. Due exercised to the size, 48 in diameter, and their locked closed, fail closed
.- Diagrams - to the large size of these valves and the closed position '
closed, fait closed position during plant
[
butterfly valves.
Sheet 1,*
potential for damage as a result of frequent with stroke time operation.
l Rev.16 cycling, it is not prudent to operate then more measurement and
{
than is absolutely necessary.'
fail safe tested (to Furthermore. Technical Specification l
the closed position) Table 3.6-2 for Containment isolation
[
at cold shutd. owns.
Valves indicates that valves FCV-25-2,
- 3. 4, and 5 are not testable during plant operation.
I
^
t The alternative provides full-stroke exercising to tha closed position at cold shutdowns in accordance with Section XI, 1 IWV-3411.
?
H V-1. 2 V-25-20 and V-25-21, 2998-G.
"These valves can only be exercised manually Per the Valve 11 is impractical to full-stroke exercise t
Containment Vacuum
- 878, requiring direct access to each valve. Since Program, Tables, these valves either open or closed Breakers; 24 in. normally 'HVAC -
these valves are located within the these valves are -
quarterly because they are located within I
closed check valves Control containment building, access is limited and not full-stroke the containment building.
' {
Diagrams - routinely practical.*
exercised to the Sheet 1,*
open position and to The alternative provides full-stroke l
Rev. 16 the closed position axercising to the open and closed positions at cold shutdowns ~.
at cold shu downs in accordance with Section XI.1 IWV-3521 and 35?2.
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5.0 IST PROGRAM RECOMMENDED ACTION ITEMS Inconsistencies, omissions, and required licensee actions identified during the review of the licensee's sewond interval inservice Testing Program are sumraarized below. The licensee should resolvi. these items in accordarice with the evaluations presented in this report.
5.1 The IST Program does not include e description of: how the components were selected, how testing requirements were identified for each component, or the safety function of the valves. The review performed for this TER did not include verification that all pumps and valves within the scope of 10 CFR 50.55a.and Section XI are contained in the IST Program, and did not ensure that a!l applicable testing requirements have been identified. The licensee is requested to include this information in the IST Program. The program should describe the development process, such as a listing of the documents used, the method of the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. Additiona'ly, for each interval, the licensee should maintain an accurate states of the relief requests including their revision and NRC approval.
The licensee has deleted the diesel air start and fuel oil, and instrument air systems from the IST Program. The licensee explains in the summary of changes between Revision 2 of the First interval to Revision 0 of the Second Interval that these systems are not required to be built to ASME Class 1,2, or 3 standards per Regulatory Guide 1.26, but "were built to. Class standards at the option of FPL. In accordance with IWA-1300(e) (sic), including the pumps and valves in these systems in the IST program was at the option of FPL and not a requirement."
Paragraph IWA-1320(e) states that "If systems safety criteria permit a system to be nonnuclear safety Class and an Owner optionally classifies and constructs that system, or a portion thereof, to Class 2 or 3 requirements, the application of the rules of (a) above is at the option of the Owner and is not a requirement of this Division." Section 3.2.2 of 'the FSAR, however, states that the diesel systems are safety-related Quality Group C components and are required to be built to Section 111, Class 3 requirements. Components were classified per the FSAR in accordance with ANSI N18.2, as well as Regulatory Guide 1.26. The regulations require pumps and valves classified by the Owner as Class 1,2, or 3 to be tested in accordance with Section XI. The regulations do not limit the scope of the IST program to only those systems discussed in Regulatory Guide 1.26. The IST program scope should be consistent with the classification oi components in the safety analysis report. The
!ST Program or FSAR should be revised accordingly.
5.2 The IST Program's scope was reviewed for selected systems. The pumps and valves in the Auxiliary Feedwater System, Main Steam, Chemical and Volume Control System and Component Cooling Water System were reviewed against the requirements of Section XI and the regulations. The FSAR was used to determine if the specified valve categories and valve function; were consistent wi'th the plant's safety analyses. The review results showed coupliance with the Code, except for the following items. The licensee should review these items and make changes to the IST Program, where appropriate. Additionally, the licensee should verify that there are 61'
I not similar problems with the IST Program for other systems.
1 A. Auxiliarv Feedwater and Main Steam Systems Since part of the Auxiliary Feedwater System is shown on the flow diagram for the Main Steam System, the results of tho review for these two systems are presented jointly. The reference drawings are: 2998-G 080, Sheet 2 of 2 Rev.18, " Flow Diagram - Feedwater & Condensate Systems," and 2998-G-079, Sheet 1 of 6, Rev.
16, ' Flow Diagram - Main Steam System - Sheet No.1."
l The following items were identified:
l
- 1. The licensee should review the basis for including and excluding locked open r
l manual valves in the Program. Specifically, the following locked open manual valves which are located on the AFW discharge lines upstream of the steam generators and downstream of normally closed motor operated valves are included in the program:
21 V-09120, 21-V-09152, 21 V 09136, and 21 V-09158 (The licensee should note that the drawing coordinates are incorrectly listed in the program table for the i
, above valves), while the following valves located immediately upstream of the normally closed motor operated valves are not included in the program: 21 V-09108, 21-V-09124, and 21 V 09140. (There are other locked oper. manual valves on the AFW pumps' recirculation lines to the Condensate Storage Tank and also on the pumps' suction lines which are not included in the program).
- 2. For the following check valves, the licensee should verify that the valves do not perform a safety functior. in the closed position:
21-V-09252 and 09294, Steam Generator feedwater line check valves inside containment.
21 V-09107, 09119, 09123, and 09135, AFW pumps' discharge line check valves downstream of normally closed motor operated valves.
21 V-09139, 09151, and 09157, AFW pumps' discharge line check valves immediately adjacent to pump discharge.
8- 'omoonent C6olina Svstem The reference drawing for this system is 2998 G-083, Rev.18, ' Flow Diagram Component Cooling System."
The following items were identified:
- 1. For the Component Cooling Surge Tank, diaphragm-operated vent valve 2RCV )
1, and its accompanying solenoid valve RSE-14-1, on top of the tank are shown as
)
interlocked on a High Radiation signal, yet neither valve is listed in the Program l'
Tables. The licensee should verify that these valves do not perform a safety function.
1 l
62 a.
~_
1
\\
- 2. CC Pumps suction and discharge header inter tie valves MV 14-1 and MV-14 3 are shown on the flow diagram as normally closed while the Program Tables indicate that the normal position is open. Similarly, Containment Cooling Units suction and discharge valves MV 14-9 to MV 14-16 are shown on the flow diagram as locked open while the Program Tables indicate only that the normal position is open. The licensee should revise either the drawing or the Program Tables as appropriate.
C. Chemical and Volume Control System (CVCS)
The reference drawings for this system were:
- 2998-G-078, Sheet 120, Rev. 4, ' Flow Diagram - Chemical & Volume Control System (Sheet 1)*
l
- 2998-G-078, Sheet 121, Rev. 5, " Flow Diagram,. Chemical.& Volume Control System (Sheet 2)*
- 2998-G-078, Sheet.122, Rev. 5, " Flow Diagram - Chemical & Volume Control
}
i
.: System (Sheet 3)" -
s The following items were identified:
I r
- 1. On Sheet 2, check valves V 2112 (G-3), on the nitrogen supply line to the
^
4 l
Volume Control Tank (VCT), V-2188 (F 5), on the Boric Acid Makeup and Primary Water Makeup blending line to the VCT, and V 2308 (F 3), on the discharge of the Chemical Addition Metering Pump, form the boundary between safety class ~ and non-safety class piping yet none of the three valves are in the IST Program for either an open or close test. The licensee should verify whether these valves should be included in the Program, and revise the program, as necessary.
j
- 2. In the FSAR, 9.3.4.3.2, reference is made to heat-traced piping relief valves 4
which are provided for those portions of the boric acid system that are heat traced and can be isolated individually. The valves relieve the maximum fluid thermal expansion rate that would occur if maximum duplicate heat tracing power were inadvertently applied to the isolated line. These valves appear on Sheet 2 as V-2171, V-2631, V-2632, V 2634, V 2636, V 2639, V 2641 and V-2648.
i However, non'e of these valves is included in the IST Program. The licensee should verify whether these valves should be included in the Program, and revise the I
program, as necessary.
i
)
- 3. On Sheet 2, check valves V 2118 and V-2674 (both F-4) are on the outlet line l
of the VCT leading to the suction of the charging pumps and also upstream of the 1
connection from the boric acid makeup pumps' discharge to the charging pumps' suction. Although both valves are included in the Program, they are only tested in the open position. The licensee should verify whether the valves perform a sa:ety i
function in the closed position by preventing backflow into the VCT when the boric acid makeup pumps are in operation, and revise the program, as necessary,
- 4. On Sheet 2, check valve V-2191 (E-3) is on a line leading from the Refueling Water Tank (RWT) to outlet line of the VCT which in turn leads to the charging pump suction. It appears that this valve opens to allow the charging pumps to provide 2
63 1
i boration of the RCS using the RWT to achieve shutdown r.ooling conditior$s. 'in such a case,the normally closed motor-operated valve V 25r,4 immediately upstream must be open so that it does not appear that V-2504 vould be relied upon to prevent reverse flow. Although V-2191 is in the Program, i: is only tested in th,e open
. position. The licensee should verify whether V-2191 performs a safety function in the closed position, by preventing reverse flow from other sources such as the chemical addition metering pump and the contents o' the VCT, and revise the program, as necessary.
- 5. In the FSAR, 9.3.4.3.2, V-2435 is described as tha Charging Line Thermal Relief Valve which is a spring loaded check valve downstream of the regenerative heat exchanger. The valve is sized to relieve the maximum fluid thermal expansion rate that occurs if hot letdown flow continued after charging flow was stopped by i
closing the charging line distribution valves. The valve appears on Sheet 3 (8 7).
However, the valve is not included in the Program for either an open or close test.
The licensee should verify whether this valve should be included in the Program, and revise the program, as necessary.
i
- 6. On Sheet 3, check valves V 2431 (D 8), on the pressurizer auxiliary spray l
line, and V-2432 (C-8) and V-3433 (B-8), on the charging line connections to the RCS, are all located inside containment and appear to form part of the reactor coolant J
pressure boundary (i.e., forming the boundary between Class 1 and Class 2 piping).
Although the valves are included in the Program, they are only designated for testing j
in the open position. The licensee should ve'rify whether the valves perform a safety function in the closed position, and revise the program, as necessary.
5.2 As discussed in the TER evaluation for numerous relief requests. specific portions of
}
OMa-1988, Pa.3 6 and 10 may be utilized without relief, provided all related 1
requirements are implemented. Approval is recommended pursuant to 50.55a l
(f)(4)(iv). The use of specific portions of Part 6 'or 10 and any refueling outage justifications should, however, be documented in the IST Program, implementation of related requirerr, ants is subject to NRC inspection.
5,3 Section 4.2 of the IST Program, states that the valve test frequency may'be extended by 25%, as allowed by the Technical Specifications. The extension of test intervals should not be applied to safety and relief valves tested in accordance with the, intervals defined in Section XI, because the Technical Specifications do not address these test intervals.
5.4 in Generic Pump Relief Request PR-2, the licensee has requested relief concerning portable instruments used for temperature and speed measurement. When using temporary instruments, the licensee should ensure that the instruments are calibrated prior to use and are traceable to the inservice test records. (TER Section 2.1.2) 5.5 in Pump Relief Requests PR 8, PR-11, and PR 15, the licensee is proposing to' calculate pump, suction pressure based on measuring tank or inlet structure levels.
j Calculation of inlet pressure based on the measured level provides an acceptable 1
64
\\
alternative method of determining intet pressure, provided the calculation is properly proceduralized, and the accuracy is within the accuracy required by the Code using direct measurement. This should be documented in the test. records and be available for review. (TER Sections 2.2.1, 2.3.1, 2.4.1) 5.6 in Purnp Relief Requests PR-12, PR 13, and PR 14, the licensee has requested relief from the ASME Code,Section XI, IWP 4520(b), which requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed. Specifically, in~ PR-12 for the Reactor Coolant Charging Pumps, the code-required frequency range is 1.75 Hz to 3.5 Hz. In PR-13 for the intake Cooling Water Pumps, the code-required frequency range is 7.38 Hz to 14.75 Hz. In PR 14 for the Containment Spray System Hydrazine Pumps, the code-required frequenc'y range is 0.875 Hz to 1.75 Hz.
The licensee' claims that instruments satisfying these range requirements are commercially unavailable, and.that the lowest available response frequency is 10 Hz. The Staff has, however, identified equipment with a frequency response range less than 10 Hz. The licen'see should further investigate the procurement of instruments that comply with the Code requirements. Ale, the licensee has not discussed the repeatability and accuracy of the instruments to be used. The licensee should additionally evaluate each pump to determine if the pumps are susceptible to degradation mechanisms that result in increased vibration ;evels at frequenciec lower than 10 Hz. Immediate imposition of the Code requirements is impractical due to limitations in the current instrumentation and it would be an undue burden to require the plant to declare the pumps inoperable until the evaluation of subharmonic frequencies and/or available instrumentation could be reviewed.
Relief was recommended for an interim period of'one year or until the next refueling outage, whichever is later to perform the evaluations in the August 23,1993 SE.
The interim relief remains in effect into the second ten-year interval. (TER Sections 2.2.2, 2.3.2, 2.4.2) 5.7 in Pump Relief Request Pf3-17 for' the Containment Spray Hydrazine Pumps, the licensee is proposing to measure pump flow rate and vibration quarterly but not alert trend the flow rate. At refueling, the pump flow rate and vibration will be measured.
Referring to the licensee's request, it appears that the licensee will not take any corrective actions basod on the flow rate measured quarterly exceeding the alert or required action values. The licensee should evaluate the establishment of required action ranges for quarterly testing.
The licensee has referenced Section XI 1 IWP-4150 in the relief request, however the licensee has not discussed the possible use of a symmetrical damping device to provide for flow rate averaging. Additionally, the licensee has not discussed the impact or burden of installing flow instrumentation that could be used effectively for the quarterly test.
65
i le i
Reference to the licensee's Appendix A, Pump Program Table indicates that the
. licensee will not measure the pump inlet pressure or differential pressure. The ASME/ ANSI Code OMa-1988, Part 6, Table 3b, requires that pump discharge pressure be measured for positive displacement pumps. The licensee has not provided a basis for not measuring pump differential or discharge pressure.
Provided the licensee determines that there is no practical means of installing flow i
instrumentation that is adequate for inservice testing purposes, deferring flowrate measurement to refueling outages may be considered acceptable. The licensee should evaiuate the procurement of damping devices or new flow instrumentation and measure and evaluate quarterly pump differential or discharge pressure as well as vibration. Immediate imposition of the Code requirements is impractical due to lack of adequate installed flow instrumentation, and it would be an undue burden to require the plant to declare these pumps inoperable until the availability of new instrumentation could be reviewed. Therefore, it is recommended that relief be granted for an interim period of one year, or until the next refueling outage, whichever is later. The interim relief remains in effect into the next ten-year.
interval due to begin August 9,1993. In the interim, the licensee should establish acceptance criteria for RPM versus flow rate correlation and take corrective action if needed, and measure discharge pressure, if possible.- (TER Section 2.4.3) 5.8 In Valve Relief Request VR-13, the licensee is proposing to disassemble and inspect every 10 years each of the four 12 in. discharge line check valves in the lines from the Safety inje'ction Tanks to the Reactor Coolant System. Exercising closed is to be in accordance with the Technical Specifications regarding pressure isolation valves (PlVs).
4 Disassembly and inspection should only be used if testing with flow is impractical.
The licensee should provide an analysis or test results to show that the nominal 52 seconds stroke time for the SIT discharge isolatiore rnotor-operated valves to open is too long to permit sufficient flow to ccuse the check valves to reach their full-open position. If a full-open position can be reached, the licensee should perform the test with flow to confirm disk position. To substantiate the acceptability of any alternative technique for verifying that the valves are fully open, licensees must, as a minimum, address and document certain items in the IST program, as described in Position 1.
However, if the licensee determines that full-stroke exercising with flow is impractical, the licensee may, as discussed by the NRC in Generic Letter Position 2, perform valve disassembly and inspection as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability.
The licensee is currently proposing to meet Position 2. Assurance of proper reassembly will be provided by performing a leak test or partial flow test prior to returning a valve to service following disassembly. However, the licensee intends to inspect each check valve only once in the 10 year Inservice Inspection program interval. As defined.in Position 2, in order to support extension of the valve disassembly / inspection intervals to longer than once every 6 years, i.e., in cases -
66
O i
" extreme hardship," licensees should perform a review of the installation of each valve addressing the "EPRI Applications Guidelines for Check Valves in Nucidar Power Plants" for problematic locations. The licensee should justify the extreme hardship, including a discussion on why non intrusives cannot be used..
Additionally, the licensee states that valves will be leak tested or partial-flow tested following disassembly, if possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly, must be performed.
Relief is granted per Generic Letter 89-04, Position 1, to full-stroke exercise the valves open with less than the accident flow rate, provided all criteria in Position 1 are met. If the licensee determines that full-stroke exercising is impractical, relief i
is granted per Position 2 to disassemble / inspect these check valves, provided the licensee meets all the criteria in Position 2, including reviewing the installation of the vaives, demonstrating extreme hardship, and partial-stroke exercising following reassembly and at cold shutdown if practical.
With respect to exercising the valve closed, OMa 1988 Part 10, 4.3.2.2 allows l
full stroke exercising that is not practicable during operation or cold shutdown to be deferred to refueling outages. Relief to use the Technical Specification requirements is not required pursuant to 50.55a (f)(4)(iv), provided the licensee implements 14.3.2.2 and all related requirements, including Part 10, 4.3.2.2(h) and 6.2, implementation of these related requirements is subject to NRC inspection. (TER Section 3.2.2) 5.9 In Valve Relief Request VR 14, the licensee is proposing to partial-stroke exercise at cold shutdowns and refueling outages the four 12 in. Safety injection check valves which open to provide flow paths from the safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.
I The licensee should evaluate if the valves will achieve a full-open position with the proposed reduced test flow rate of 3,000 GPM. If a full-open position can be reached, the licensee should perform the testing with flow. The use of, alternate techniques, such as non-intrusive techniques, to verify that valves will fully open' is acceptable, as discussed in Generic Letter 89-04, Position 1.
If the valves cannot be full-stroke exercised, the NRC defined an acceptable alternative to the full-stroke exercising requirement in Position 2, wherein it is stated that the NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full stroke exercise open or of verifying closure capability.
The licensee is currently proposing to meet Position 2. Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly. However, the licensee intends to inspect each check valve only once in the 10 year Inservice inspection program interval. As def.ined in Position 2, in order to support extension of the valve disassembly / inspection intervals to longer than once every 6 years, i.e., in cases e 67 1
" extreme hardship," licensees should perform a review of the installation of each valve addressing the 'EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" for problematic locations. The licensee should also in'clude a discussion on why non-intrusives cannot be used.
Additionally, the licensee states that the valve will be ' leak tested or partial-flow tested following disassembly. Position P 9 quires that, if possible, partial valve stroking quarterly or during cold shutt is, or after reassembly, must be performed.
Relief is granted per Generic Letter 89 04, Position 1, to full-stroke exercise the valves open with less than the accident flow rate, provided all criteria in Position 1 are met. If the licensee determines that full stroke exercising is impractical, relief is granted per Position 2 to disassemble / inspect these check valves, provided the licensee m.ms all the criteria in Position 2, including reviewing the installation of the valves, demonstrating extreme hardship, and partial-stroke exercising following reassembly and at cold shutdown if practical.
With respect to exercising the valve closed, verification that a valve is in the closed position can be done by visual observaticn, by an electrical si,gna! initiated by a position indicating device, by observation of appropriate pressure indication in the system, by leak testing, or by other positive means. The licensee does have instrumentation to continuously monitor upstream pressure. Based on the Technical Specifications, it appears that following the partial-stroke exerche at cold shutdowns, verification that the valves have closed will be performed and relief would not be required. The licensee should exercise these valves closed at cold -
shutdowns or revise the request accordingly. (TER Section 3.2.3) 5.10 The licensee states in VR-1 that valve testing need not' be performed more often than once every cold shutdown, except as provided for in IWV 3417(a), which requires more frequent testing as a result of degraded stroke times. The ASME issued a Code interpretation (XI 1-92-41) that states that it is the intent of Section XI, IWV-3410 and'3520, to require testing of valves every three months, including during extended shutdown periods, for valves other than those in systems declared inoperable or not required to be operable (IWV-3416). Therefore, during' plant shutdown periods, when the valves can be exercised, the licensee should exere!w valves every three months in accordance with the Code or provide a relief re Additionally, if specific valves cannot be tested during any cold shutdown (i.e., d.K. to "the lack of plant conditions needed for testing"), specific approval is required to defer testing. The licensee should revise the cold shutdown justifications, as i
required, to discuss the conditions under which testing cannot be performed during any cold shutdowns.
e L
5.11 For the following check valves, the licensee has not identified any closed position testing requirement in the Valve Program Table. The licensee should review the
{
safety functions of these valves and revise the program, if necessary:
VR 5: V-2177, 2190, 2191 and 2526 68 l
J
4 VR-7: V-07000 and V-07001 VR 8:. V-3401 and V 3410 VR 11: V-3113, V 3133, V-3143 and V-3766 VR 21: V-07129 and V-07143 VR-32:
V-3101 5.12 For relief requests VR-8, VR-10, VR 12, the licensee states that the alternate testing satisfies the requirement of Generic Letter 89-04, Position 1. As discussed in Position 1, the NRC staff position is that passing the maximum required accident condition flowrate through the valve is an acceptable full-stroke. It is assumed that the full-flow exercise piopused by the licensee complies with this position. If other
. techniques are used, such as non-intrusive techniques ai reduced. flow rate,.the.
licensee must comply with the six criteria required by Position 1. The licensee should clarify this statement in each request.
5.13 The licensee should clarify why the Valve Program Table references VR-19 when it indicate hat V-3414 and V-3427 will be tested closed quarterly.
5.14 The licensee has stated that the valves referenced in VR-12 "will be partial-stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR-1" and the basis only discusses the impracticality of testing quarterly.
However, the Valve Program Table identifies the test frequency.as 'SP* as per VR-12 and not *CS", and the licensee additionally states that the valves will be verified closed during the PlV leak tests. It is assumed that the valves are exercised to'the closed position in accordance with the Code during cold shutdowns, in addition to the l
PlV leak test. If exercising the valves closed at cold shutdowns is impractical, the request's basis must be revised to discuss the impracticality.
5.15 From a review of the applicable flow diagrams, 2998-G-078, Sheet 130, Rev. 4, and the continuation on flow diagram 2998-G-088, Rev.19 for valve's V-3104 and V 3105, it appears that there is a flow element on each recirculation line, i.e., FE-03-1-1 and FE-03-2-1, which could be used to measure the recirculation,line flow. The licensee should clarify why these elements cannot be used in Relief Request VR 28. Additionally, the licensee should explain why the quarterly LPSI pump flow test does not result in a recirculation flow sufficient to cause full-stroke exercising of these valves.
OMa-1988 Part 10,14.3.2.2 allows full-stroke exercising that is not practicable during plant operation or cold shutdowns to be deferred to refueling outages.
Therefore, provided the licensee furnishes information on why the installed flow elements or non-intrusives cannot be used to verify the valves' full-stroke open quarterly, the relief requested by the licensee is covered by the rulemaking, effective September.8.1992, as described above, and approval could be recommended. However, if quarterly full-stroke exercising is practical, the 69
e.
l licensee must comply with th6 Code requirements. The licensee should revise the relief request.
5.16 Anomalies identified during the review of cold shutdown justifications are identified j
below:
i
. The followirg valves are not exercised closed. The licensee should verify that the valves dc vo'. perform a safety function in the closed position, or revise 1he program
{
as appropriate 1
RC 1: V-1460 through V-1466, reactor vessel and pressurizer gas vents: 1 in.
normally-closed, solenoid-operated globe valves.
RC-2: V 1474 and V-1475, Pressurizer Power-Operated Relief Valves; 3 in, solenoid-operated, normally c:osed globe valves.
CV-3.2: V 2431, Auxiliary Pressurizer Spray Check Valve; 2 in, normally closed check valve.
CV-3.3: V 2440, Charging Pump Discharge Check Valve to Safety injection; 2 in.
)
normally clued check valve.
SI 1.1: V-3106 and V-3107, LPSI Pump Discharge Check Valves; 10 in, normally closed check valves.
SI-3.1: V-03002 through V-03005, Safety injection Tank (SIT) Drain Line Check Valves; 1 in, normally closed check valves.
FW-1.2: V-09107, V-09123, and V 09139, Auxiliary Feedwater Pump Discharge f
Check Valves; 4 in. normally closed check valves.
FW 1.3: V-09119, V-09135, V-09151, and V-Oo157, Auxiliary Feedwater Supply Check. Valves;-4 in. normally closed check valves.
CC-1.2: HCV-14-3 A & B, Shutdown Heat Exchanger Return Valves; 14 in. normally open, fail open, diaphragm-operated butterfly valves.
- CV 3.5: V 2523, Charging Line isolation Valve; 2 in, diaphragm-operated, locked open globe valve.
For V-2523, the failure mode is the open position. Since the valve is only exercised j
to the closed position, the licensee should explain why no fait safe testing (to the l
open position) is indicated in the Valve Program Tables.
manually-operated, locked closed gate valve.
l According 19 the flow diagram,2998-G-078, Sheet 130, the two outboard 1
70 1
l
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I containment isolation valves for penetration 41, 21-SE-03 2A and 28. are normally closed and in parallel to each other and in series with V-3463. The Valve l
Program Tables indicate that both of the outboard valves are exercised opened
~
quarterly.
i Furthermore, Technical Specification Table 3.6-2 for Containment isolation Valves indicates that V 3463 is testable during plant operation. Therefore, the licensee should explain why V 3463 cannot be exercised open quarterly.
i SI-2.1: V-3114, V-3124, V-3134, and V 3144, LPSI Cold Leg injection Check Valves; 6 in. check valves, normally closed.
I The licensee has not provided an explanation of why the valves cannot be verified closed quarterly. There appear to be drain or test connections available both immediately upstream and immediately downstream of each of these valves which may be able to be used for both a quarterly part-stroke open test and a quarterly test for closure. Therefore, the licensee should explain why such testing could not be performed quarterly.
J SI2.3: V-3545, V-3664, and V-3665, Shutdown Cooling isolation and Cross Connect Valves,10 in. motor-operated, locked closed gate valves.
]
The licensee should explain why a failure of V 3664 and V-3665 in the open position would jeopardize the integrity of the LPSI System since the Shutdown Cooling System valves V 3480, V 3481, V 3651 and V-3652 are immediately upstream and interlocked closed as described for SI-2.2.
Similarly, the licensee should describe under what conditions the cross connect valve V 3545 is opened during the shutdown cooling mode of operation and also 1
justify that its failure during normal plant operation would jeopardize the integrity of the LPSI System since the it appears that only shutdown cooling would be affected and that shutdown cooling could still be accomplished with the valve open.
- MS-1.1: HCV-08-1 A & B, Main Steam Isolation Valves; 34 in, normally. open, piston operated globe valves.
The licensee should indicate in the Tables what is the failure mode position of these valves.
- MS-1.2:_ V 08130 and V-08163, Steam-Driven AFW Pump Steam Supply Check Valves; 4 in, normally open check valves.
Per the Valve Program Tables, these check valves are part-stroke exercised to the open position quarterly, and full-stroke exercised to the open position at cold shutdowns. Valve relief request VR-31 called for part stroke exercising to the open position monthly and full stroke axercising at cold shutdowns. The licensee should clarify the apparent discrepancies in the testing frequencies.
71 9
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o
6.0 REFERENCES
1, NRC Regulatory Guide 1.147, *lnservice inspection Co'de Case Acceptability. ASME Section XI, Division 1," Revision 9. April 1992.
2.
ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice inspection of Nuclear Power Plant Components,1980 Edition including Winter 1980 Addenda.
3.
St. Lucie Unit 2 Technical Specifications.
4.
ASME/ ANSI OMa-1988, Part 6, " Inservice Testing of Pumps in Light Wt ter Reactor Power Plants."
)
5.
ASME/ ANSI OMa-1988, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants."
6.
Title 10, Code of Federa! Regulations, Section 50.55a, Codes and Standards.
7.
Standard Review Plan, NUREG 0800, Section 3.9.6, inservice Testing of Pumps and Valves, Rev. 2 July 1981.
8.
NRC Generic Letter 89-04," Guidance on Developing Acceptable' Inservice Testing Programs," April 3,1989.
9.
Minutes of the Public Meetings on Generic Letter,89-04, October 25,1989.
~
i 10.
Supplement to the Minutes of the Public Meetings on Generic Letter 89-04, September 26,- 1991.
'1 1.
" Initial Ten-Year Inservice.inspectiori interval inservice Testing Program-Revision 2," D.A. Sager (FP&L) to USNRC, September 15,1992 (L-92-247).
'12.
" Inservice Test Program Relief Requctis VR 18 and VR-30-Check Valve Testing,"D.A. Sager (FP&L) to USNRC, January 13,1993 (L-93-10).
j l
13.
" Inservice Testing' (IST) Program Relief Request," D.A. Sager (FP&L) to USNRC, February 25, 1992 (L-92-38).
14.
" Inservice Test Program Temporary Relief Request-Check Valve Inspection," D.A.
l Sager (FP&L) to USNRC, May 27,1992 (L;92-160).
1 15.
" Revision to the St. Lucie Unit 2 Pump and Valve Inservice Test Program Plan," W.
F. Conway (FP&L) to USNRC, April 4,1988 (L-88-158).
16.
M82931, !!eNHC to FP&L, April 16, 1992.
5 72-1 l
-... - -... ~
w f
.17.
' Safety Evaluation Inservice Testing (IST) Program, St. Lucie Unit 2, TAC No.
81282," USNRC to FP&L, December 5,1991.
j i
18.
"St. Lucie Unit 2-Reliefs from Parts of ASME Code Section XI, TAC No. 67832,*.
USNRC to FP&L, October 2,1989.
19.
" Relief from Parts of ASME Code Section XI, TAC No. 56707," USNPC to FP&L, January 13, 1986.
20.
" Safety Evaluation of IST Program Relief Request for SIT Check Valves-Fort Calhoun Station (TAC No. M84503)," S. Bloom, USNRC, to T. L. Patterson, OPPD, October 1, 1993.
t 4
9 i
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I a.
73 a
e 1
Appendix A: St. Lucie Plant Unit 2 Flow Diagrams Flow Diagram DWG. No.
Sheet No.
Splem Resision 2998-G-078 107 Reactor Coolant 1
2998-G-078 108 Reactor Coolant 0
2990C-978 109 Reactor Coolant 3
2998-G-078 110 Reactor Coolant 2
2998-G-078 111 Reactor Coolant Pump 1
2998-G-078 115
. Reactor Coolan' t Pump 4
i 2998-G-078 120 Chemical & Volume Control 4
2998-G-078 121
'Chefnkal & Volume Control 5
2998-G-078 122 Chemical & Volume Control 5
1 2998-G-078 130 Safety injection 4
2998-G-078 131 Safety injection 1-2998-G-078 132 Safety injection 0
2998-G-078 140 Fuel Pool 2
2998-G-078 145 Refueling Equipment Valve 0
Identification 2998-G-078 150 Sampling 1
. 998-G-078 152 Sampling 1
2998-G-078 153 Sampling i
2998-G-078 160 Waste Management 1
2998-G-078 161 Waste Management 4
2998-G-078 162 Waste Management 3
~
2998-G-018 163 Waste Management 5
2998-G-078 164 waste Management 2
2998-G-078 165 Boric Acid Concentrator 2A 1
Waste Management (Sheet 6) 2998-G-078 166 Boric Acid Concentrator 2B 1
Waste Management (Sheet 7) 2998-G-078 167 Radioactive Waste 2
Concentrator Waste Management (Sheet 8)
A-1
c Appendix A: St. Lucie Plant Unit 2 Flow Diagrams (Cont'd)
Flow Diagram DWG. No.
Sheet No.
System Resision 2998-G-078 168 Waste Management 2
2998-G-078 169 Waste Management 3
2998-G 078 171 Waste Management 4'
2998-G-078 172 Waste Management 1
2998-G-079 1
Main Steam 16 2998 G-079 2
Main Steam 19 2998-G-079 3
Extraction Steam 16 2998-G-079 4'
~18 ' -
2998-G-079 5
Auxiliary Steam 13 l
2998-G-079 6
Air Evacuation 17 2998-G-080 1
Feedwater & Condensate 24 2998-G-080 2
Feedwater & Condensate 18 2998-G-081 1
Heater Drain & Vent 12 2998-G-081 2
Heater Drain & Vent 12 2998-G-082 Circulating and intake 23 Cooling Water 2998-G-083 Component Cooling 18 2998-G-084 Domestic & Make-up Water 19 2998-G-085 1
Service Air 16 2998-O-085 2
Instrument /Jr 21 2998-G-085 3
Instrument Air 17 2998-G-086 1
Miscellaneous 18 2998-G-086 2
Turbine Lube Oil 18 2998-G-086 3
Turbine Lube Oil 0
2998-G-087 Miscellaneous 16 2998-G-088 Containment Spray and 19 Refueling Water 2998-G-089 1
Turbine Cooling Water 15 2998-G-089 2
Turbine Cooling Water 13 -
'l A-2 A
o r
Appendix A: St. Lucie "lant Unit 2 Flow Diagrams (Cont'd)
Flow Diagram l
DWG. No.
Sheet No.
System Resision 2998-G-090 Reactor Coolant Pressure 10 Boundary Diagram 2998-G-091 Miscellaneous 14 -
2998-0-092 Miscellaneous Sampling 10 2998 G-093 Diesel Generator Lube Oil 1
4 2998-G-094 1
Secondary Side Wet Layup 0
Sys. Feedwater Heaters Tube Side 2998-G-0N -
2 Sece,ndary Side Wet Layup 01 Sys. Feedwater Heaters Shell Side 2998-G S62 HVAC - Air flow 16 2998-G-874 1
HVAC - Miscellaneous Areas 9
2998-G-874 3
HVAC - Miscellaneous Areas 2998-G-878 1
HVAC - Control Diagrams 16 2998-G-879 2
HVAC - Control Diagrams 11 l
2998-G-879 3
HVAC - Contr'ol Diagrams 1o 2998-G 880 1
HVAC - Equipment 8
l
. Schedules & Details 2998-G-883 1
HVAC Air Flow Diagram 3
Refrigerant and Control Diagram l
2998-G-096 1
System Diesel Generator 2A 2998-G-096 2
l System Diesel Generator 2B l
A-3