ML20150A864

Pump & Valve Inservice Testing Program,Lasalle County Station,Units 1 & 2

ML20150A864
Person / Time
Site:	LaSalle
Issue date:	05/31/1988
From:	Cook T, Rockhold H EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20150A869	List: ML20150A864 ML20151W963 ML20151X012
References
EGG-NTA-7967, NUDOCS 8807080332
Download: ML20150A864 (103)

Text

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ATTACHMENT 1 EGG-NTA-7967 May 1988 j

TECHNICAL EVALUATION REPORT j

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/daho PUMP AND VALVE INSERVJCE TESTING PROGRAM.

Nat/onal LASALLE COUNTY STATION. UNITS 1 AND 2 i

Engineer /ng Laboratory Managed T. L. Cook by the U S.

H. C. Rockhold Depsrtment ofEnergy i

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Prepared for the 64

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EGG-NTA-7967 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM LASALLE COUNTY STATION, UNITS 1 AND 2 Docket Nos. 50-373 and 374 T

L. Cook H. C. Rockhold Published May 1988 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington 0.C.

20555 Under DOE Contract No. DE-AC07-761D01570 FIN No. A6812 e

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ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation of the LaSalle County Station, Units 1 and 2, Inservice Testing Program for safety-related pumps ar.d valves.

FOREWORO This report is supplied as part. of the "Review of Pump and Valve Inservice Testing programs for Operating Reactors (!!!)".being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., Mechanical Systems Evaluations.

l The U.S. Nuclear Regulatory Commission funded the work under the authori:ation B&R 20-19-05-02-2, FIN No. A6812.

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Docket Nos. 50-373 and 374 1

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CONTENTS i

ABSTRACT..............................................................

11 FOREWORD..............................................................

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1.

INTRODUCTION.....................................................

1 2.

SCOPE............................................................

3 3.

PUMP TESTING PROGRAM.............................................

9 3.1 All Fumps in the IST Program...............................

9 3.1.1 Bearing Temperature Measurement....................

9 3.1.2 Vibration Measure.nents.............................

10 3.1.3 Allowable Ranges of Test Quanti ties................

13 3.2 Diesel Generator Fuel Oil Transfer Pumps...................

15 3.2.1 Pump Inlet Pressure................................

15 3.2.2 Pump Differential Pressure.........................

16 3.2.3 Pump Flow Rate.....................................

18 3.3 High Pressure Core Spray Pump..............................

19 3.3.1 Instrumentation Range..............................

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3. 4-ECCS Water Leg Pumps.......................................

20 3.4.1 Inlet Pressure, Differential Pressure, and Flow Measurements..................................

20 3.5 Standby Liquid Control Pumps...............................

21 3.5.1 Inlet and Differential Pressure....................

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3.6 Residual Heat Removal Pumps................................

22 3.6.1 Instrumentation Range..............................

22 3.7 Reactor Core Isolation Cooling Pump........................

23 4.7.1 Pump Speed.........................................

23 4.

VALVE TESTING PROGRAM............................................

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4.1 All Systems................................................

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4.1.1 Containment Isolation Valves.......................

25 4.1.2 Excess Flow Check Valves...........................

27 4.1.3 Corrective Action..................................

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4.2 Diesel Oil System..........................................

30 4.2.1 Category B Valves..................................

30 4.3 Fe e dwa t e r Sy s t e m...........................................

31 4.3.1 Category A/C Valves................................

31 4.4 High Pressure Core Spray System............................

34 4.4.1 Category A/C Valves................................

34 4.4.2 Category C Valves..................................

36 4.5 Drywell Instrument Ni trogen System.........................

37 4.5.1 Category A/C Valves................................

37 4.5.2 Category A Valves..................................

39 4.5.3 Category B Valves..................................

41 4.5.4 Category C Valves..................................

42 4.6 Low Pressure Core Spray System.............................

45 4.6.1 Category A/C Valves................................

45 4.7 Main Steam System..........................................

47 4.7.1 Category 'A Valves..................................

47 4.7.2 Ca t e g o ry B/C Va l v e s................................

48 4.7.3 Category C Valves..................................

50 4.8 Primary Containment Ventilation and Purge System...........

52 4.8.1 Category C Valves..................................

52 4.9 Control Rod Drive System.................................

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4.9.1 Category B Valves..................................

53 4.9.2 Category C Valves..................................

56 4.10 Residual Heat Removal System...............................

57 4.10.1 Category A/L Valves................................

57 4.11 Reactor Core Isolation Cooling System......................

59 4 11.1 Category A/C Valves................................

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.11.2 Category C Valves..................................

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4.12 Reactor Recirculation System...............................

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4.12.1 Category A/C Valves................................

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4.13 Standby Liquid Control System..............................

68 4.13.1 C a t e g o ry A/ C V a l v e s................................

68 4.13.2 C a t e g o ry B Va l v e s..................................

69 4.13.3 Category C Valves..................................

70 4.14 Primary Containment Isolation System.......................

71 4.14.1 Category A Valves..................................

71 APPENDIX A--VALVES TESTED OURING COLD SHUTDOWNS.......................

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APPENDIX B--P&IO LISTING..............................................

87 APPENDIX C--IST PROGRAM ANOMALIES,10ENTIFIED IN THE REVIEW............

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4 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM

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MSALLEC0_UNTYSTATION. UNITS 1AND2 f

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INTRODUCTION j

Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by the Commonwealth Edison i

Company for its LaSalle County Station, Units 1 and 2.

l' By a letter dated November 12, 1983, Commonwealth Edison submitted an

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IST program for LaSalle County Station, Unit 2.

The working session with l

Commonwealth Edison and LaSalle representatives was conducted on June'30 l

and July 1, 1987. The licensee's revised program, as attached to his I

letter to NRC, dated July 28, 1987, which supercedes all previous i

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submittals, was reviewed to verify compliance of proposed tests of Class 1, i

j 2, and 3 safety-related pumps and valves with the requirements of the ASME i

Boiler.and Pressure Vessel Code (the Code), 1980 Edition, through the-winter of 1980 Addenda. This revised program is.the combination of the i

Unit 1, Revision 4, and Unit 2, Revision 0, programs and has been designated Revision 0 and is applicable to both units.

j Any IST program revisions subsequent to those noted above are not j

addressed in this technical evaluation report (TER).

It is an NRC staff position that required program changes, such as additional relief requests t

l or the deletion of any components from the IST program, should be submitted to the NRC under separate cover in order to receive prompt attention, but a

should not be implemented prior to review and approval by the NRC.

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In their submittal Commonwealth Edison has requested relief from the ASMECodete[sti,ngrequirementsforspecificpumpsandvalvesandthese requests have been evaluated individually to determine whether they are j

indeed impractical. This review was performed utilizing the acceptance l

criteria of the Standard Review Plan, Section 3.9.6, and the Draft i

Regulatory Gaide and Value/ Impact Statement titled "Identification of 1

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Valves for Inclusion in Inservice Testing Programs." These !$T Program testing requirements spply only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requirements.

Section 2 of this report presents the scope of the review.

Section 3 of this report presents the Commonwealth Edison bases for requesting relief from the Section XI requirements for the LaSalle County Station pump testing program and EG&G's evaluations and conclusions regarding these requests.

Similar information is presented in Section 4

-i for the valve testing program.

o Category A, B, and C valves which are exercised during cold shutdowns and refueling outages and meet the requirements of the ASME Code,Section XI, are discussed in Appendix A.

A listing of P& ids used for this review is contained in App.endix 8.

Inconsistencies and omissions in the licensee's program noted during the course of this review are listed in Appendix C.

The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

This TER, including all relief requests and component identification

r. umbers, is applicable to Units 1 and 2.

The Unit 2 designator has been I

placed in parentheses to minimize repetition, i.e., 1(2)DO-004, d

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SCOPE l

The EG&G Idaho review of the LaSalle County Station, Unit 2, inservice testing (IST) program for pumps and valves w3s begun in February of 1987.

l The review of the Unit 1 IST program has been completed with issuance of the staff's Safety Evaluation Report dated May 27, 1986.

Both programs identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix B.

To review the licensee's proposed Osting of certain pumps and valves in these systems, they were first 5 ;iated an:1 nighlighted on the

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appropriate system P& ids. After

-e,. u !ying the components and determining their function in the system, the pre p sed L ating was evaluated to determine if it was in compliance with the AS% Code requirements, based on the component type and function.

For rumps, it was verified that each of the seven inservice test quantities of Table IWP-3100 $ are measured or observed as appropriate. For those test quantities that are not being measured or observed quarterly in acco mance with the Code, it was verified j

that a request for relief from the Code requirements had been submitted.

If the testing is not being performed in accordance with the Code and a relief request had not been submitted, the licensee was requested to explain the inconsistency for the Request for Additional Information (RAI) document that served as the agenda for the working meeting between the licensee, the NRC, and the EG&G reviewers. The relief requests were individually evaluated to determine if the licensee clearly demonstrated o

that compliance with the Code required testing is impractical for the identified system components, and to determine if their proposed alternate testing provides a reasonable indication of component condition and degradation. Where the licensee's technical basis or alternate testing was insufficient or unclear, the licensee was requested to supplement or clarify the ' relief request. The system P&ID was also examined to determine whether the' instrumentation ne:essary to make the identified measurems,...

is'available.

If, based on the unavailability of adequate instrumentation or the reviewers experience and system knowledge, it was determined that it may not be possible or practical to make the measurements as described by 1

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the licensee in his IST program, a cuestion or comment was generated requesting the licensee to clarify his position.

The review of the proposed testing of valves verified that all appropriate ASME Code testing for each individual valve is performed as required. The proposed testing was evaluated to determine if all valves that were judged to be active category A, B, and/or C, (other than safety and relief valves) are exercised quarterly in accordance with IW-3410 or 3520, as appropriate.

If any active safety-related valve is not full-stroke exercised quarterly as required, then the licensee's justification for the deviation, either in the fom of a cold shutdown justification or a relief request, was examined to determine its accuracy

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and adequacy. The proposed alternate tasting wa< also evaluated to determine if all testing is being performed that can reasonably be per?ormed on each particular valve to bring its testing as close to compliance with the Code requirement as practical.

For valves having remote position indication, the reviewer confirmed that the valve remote position indication is verified in accordance with IW-3300. The reviewer verified that the licensee had assigned limiting

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values of full-stroke times for all power operated valves in the IST program as required by IW-3413: The assigned limits were examined to determine if they are reasonable for the size and type of valve and the type of valve operator.

It was also verified that the valve full-stroke times are being measured every time that *.he valves are full-stroke i

exercised for the IST program.

For valves having a fail-safe actuator, the reviewer confirmed that the valve's fail-safe actuator is tested in accordance with IWV-3415.

It was confirmed that all category A and A/C valves are leak rate tested to either the 10 CFR 50, Appendix J, and Section XI, IW-3426 and 3427 rekuirements for those valves that perform a ccatainment isolation function, or to the " _ction XI, IW-3421 through 3427 requirements for those valves that perform a pressure boundary isolation function.

It was also verified that valves tnat perfom both a containment isolation and a pressure isolation function are leak rate tested to both the Appendix J anc.

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the Section XI requirements.

Furthermore, if any valve appeared to perform a containment isolation and/or a pressure isolation function but was not categorized A or A/C and being leak rate tested, the licensee was asked to verify that those valves had not been categorized improperly in the IST i

program.

dach check valve was evaluated to determine if the licensee's proposed testing does verify the valve's ability to perform its safety-related j

function (s).

Extensive system knowledge and experience with other similar facilities were used to determine whether the proposed tests will full-stroke the check valve disks open or verify their reverse flow closure l

capability.

If there was any doubt about the adequacy of the identified testing, questions were included in the RAI which required the licensee to address these concerns.

A further evaluation was performed on all valves in the program to determine that the identified testing could practically and safely be conducted as described.

If the ability to perform the testing was in doubt, a question was formulated to alert the licensee to the suspected problem.

Safety-related safety valves and relief valves, excluding those that perform anly a thermal relief function, were confirmed to be included in the IST proccam and are tested in accordance with IWV-3510.

After all of the valves in the licensee's IST program had been identified on the p& ids and evaluated as described above, the P& ids were examined closely by at least two trained and experienced reviewers to determine if any pumps or valves that may perform a safety-related function were not included in the licensee's program.

The licensee was asked to reconcile any valves tha, were identified by this process and that had been omitter? # rom the IST program. Also, the list of systems included in the licensee's program was compared to a system list in the Draft Regulatory e

Guide and Value/ Impact Statement titled, "Identification of Valves for Inclusion in Inservice Testing Programs". Systems that appear in the Draft 9

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Regulatory Guide list but not in the licensee's program were evaluated and, if appropriate, questions were added to the RAI concerning safety-related pumps and valves in those systems.

Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions were written for inclusion in the RAI to clarify those areas of doubt. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this report.

At the completion of the review, the questions and comments generated during the review were transmitted to the licensee. These questions were later used as the agenda for the working meeting with the licensee on June 30 and July 1, 1987. At the meeting each question and comment was discussed in detail and resolved as follows:

a.

The licensee agreed to make the necessary IST program corrections or changes that satisfied the concerns of the NRC and their reviewers.

b.

The licensee provizeu additional information or clarification about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change was required.

1 The item remained open for the licensee to further investigate c.

and propose a solution to che NRC.

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The item remained open for further investigation by the NRC.

i The item remained open for further investigation and discussion e.

by both the NRC and the licensee.

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A revised IST program dated July 28, 1987, was received and was compared to the previous submittal to identify any changes.

The changes were evaluated to determine whether they were acceptable and if not, they were added to the items that remained open from the meeting.

This TER is based on information contained in the submittals and on information obtained during the working meeting and conference call (s) which took place during the review process.

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3.

PUMP TESTING PROGRAM The LaSalle County Station IST program submitted by Commonwealth Edison was examined to verify that all pumps that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI, except for those pumps identified below for which specific relief from testing has been requested and as summarized in Appendix C.

Each Commonwealth Edison basis for requesting relief from the pump testing requirements and the reviewer's evaluation of that request is summarized below.

3.1 All Pumps in the IST Program 3.1.1 Bearing Temperature Measurements The licensee has requested relief from measuring bearing temperature annually en all pumps in the IST program in accordance with the requirements of Section XI, Paragraph IWP-3300, and proposed to measure vibration to monitor bearing degradation.

3.1.1.1 Licensee's Basis for Requesting Relief. Bearing temperature measurements will not provide significant additional information regarding bearing condition than that already obtained by measuring vibration.

Measurement of vibration provides more concise and consistent information with respect to pump and bear ng condition.

The usage of vibration measurements can provide information as to a change in the balance of rotating parcs, misalignment of bearings, worn bearings, changes in internal hydraulic forces, and general pump integrity prior to the condition degrading to the point where the component is jeopardized.

Bearing temperature does not always predict such problems. An increase in bearing temp, era.ture most often does not occur until the bearing has deteriorated to a point where additional pump damage may occur.

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temperatures are also affected by the temperatures of the medium being pumped, which could yield misleading results.

Vibratio,n readings are not affected by the temperature of the meddum being pumped, thus the readings are more consistent.

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ALTERNATE TEST:

Vibration measurements will be taken quarterly.

3.1.1.2 Evaluation. The annual bearing temperature measurement is en l

unreliable method of detecting bearing failure for the reasons discussed above and deletion of this measurement will not effect the licensee's pump monitoring pregram. The burden on the licensee if the Code requirements were imposed would not be justified by the limited in~ formation that would be provided about pump mechanical condition.

It should be noted that the licensee has described the vibration velocity monitoring program in a separate relief request.

See Item 3.1.2 of this report.

Based on the impracticality of complying with the Code requirements and considering the burden on the licensee if the Code requirements were imposed and considering the quarterly pump vibration velocity measurements that will be taken to determine pump mechanical condition and to detect pump bearing degradation, relief may be granted from the Section XI requirement to measure bearing temperature annually on all pumps in the IST program.

3.1.2 Vibration Measurements The licensee has requested relief from measuring vibration amplitude on all pumps in the IST program in accordance with the requirements of Section XI, Paragraphs IWP-3100 and -4500, and proposed to measure vibration velocity during pump tests.

i 3.1.2.1 Licensee's Basis for Requesting Relief. Re. lief is requested from the requirements of measuring vibration amplitude. A far more informative ~ reading is obtained using vibration velocity equipment because it accounts'for both displacement and rate of frequency. Therefore, it is more advantageous to measure vibration velocity than vibration amplitude displacement for determining the mechant al. condition of a pumo.

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ALTERNATE TEST:

l The alternate testing described herein for pump vibration monitoring was developed using ANSI /ASME OM-6 (Draft 8) as a guideline with the intent of incorporating into the program any additional requirements of OM-6 to those found in ASME Section XI.

Pump vibration measurements will be obtained and recorded in velocity (inches per second) and are broadband (unfiltered) peak readings. All monitored locations are clearly marked to identify the specific point at which the transducer is to be placed while taking vibration measurements using portable equipment. The readout system and transducers used to take vibration measurements are capable of frequency response in the range of one-third minimum pump speed to at least one-thousand hertz and they have a minimum accuracy over that range of +/-5%.

All centrifugal pumps in the program will have vibration measurements taken in a plane approximately perpendicular to the rotating shaf t in two orthogonal directions on each accessible pump bearing housing. Measurement will also be taken in the axial direction on all bearing housings when accessible. Reciprocating pumps will have vibration measurements taken approximately perptndicular to the crankshaft and the line of plunger travel, including the axial direction when accessible on each pump bearing housing.

The Acceptable, Alert, and Required Action Ranges of OM-6, Table 6100-1, will be used in lieu of Table 3100-1 of Section XI as shown below. Corrective actions will be taken in accordance with Article IWV-3230.

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RANGCS OF VIBRATION Alert Range Pump Type Low High Required Action Range Centrifugal

>2.5V (ref) 6V (ref)

>6V(ref)

But not >0.325 in/sec But not >0.70 in/sec Reciprocating

>2.5V (ref) 6V (ref)

>6V (ref)

Notes:

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V (ref) is the reference velocity in inches per second.

2.

Any vibration measurement value below the low alert range is acceptable.

3.

All LaSalle's centrifugal pumps in the IST program vperate at a speed of greater than 600 rpm.

3.1.2.2 Evaluation. Fump bearing degradation results in increased bearing noise at frequencies 5 to 100 times the rotational frequency of the pump. These high frequency bearing noises would not produce a significant increase in pump vibration displacement measurements and could go undetected. However, the high frequency noises would result in relatively large changes in pump vibration velocity measurements which could permit corrective action prior to catastrophic failure of the bearing. Because 'of the high frequencies of the vibrations associated with the pump bearings, vibration velocity measurements are generally much bott than vibration displacement measurements in monitoring the mechanical condition of pumps and detecting pump bearing degradation.

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The advantages of using vibration velocity instead of displacement for

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monitoring the mechanical coridition of pumps, with the exception of reciprocating pumps, are widely acknowledged in the industry. The use of pump vibration velocity signatures over a wide frequency range can provide a great deal of information about pump mechanical condittor. that could not beobtained[byusingvibrationdisplacementreadings. Therefore, the licensee's proposed alternate test method is superior to the Code required testing method.

Section XI does not provide allowable ranges for vibration velocities and, since the relationship between displacement and velocity is frequency dependent, a mathematical conversion of the Code displacement ranges is not 12

appropriate.. ANSI /ASME OM-6, Draft 8, provides a set of allowable ranges for pump vibration velocity measurements that has been found to be acceptable by the NRC. The licensee has indicated that they are using the ranges and limits specified in Draft 8 of OM-6.

This is acceptable if the licensee complies with all of the vibration measurement requirements of this draft of ANSI /ASME OM-6.

The licensee has agreed to measure pump vibration velocities in accordance with the requirements of OM-6, Draft 8.

Based on the determination that pump vibration velocity measurements provide more information to evaluate pump mechanical condition and to detect bearing degradation than the Code required displacement readings, and considering the licensee's propcsal to measure pump vibration velocity in accordance with the requirements of Draft 8 of ANSI /ASME OM-6 and to use the allowable ranges and limits specified in that document, relief may be granted from the Code requirements as requested.

3.1.3 Allowable Ranges of Test Quantities The licensee has requested relief from the allowable ranges of test quantities contained in Section XI, Table IWP-3100-2, and proposed to analyze all test parameters for all pumps in accordance with the guidance of ANSI /ASME OM-6-1986, Draft 8.

3.1.3.1.

Licensee's Basis for Requesting Relief. The ASME Code rcquires that the pump test parameters of differential pressure and flow rate be measured and compared with the limits given in Table IWP-3100-2.

Test quantities can be affected significantly by extraneous conditions which are not indicative of pump deterioration such as instrument fluctuation, instrument accuracy, and normal variations in equipment operational performance. ' This data scatter, which may exceed 2%, reduces the repeatability of test surveillance results and can require pumps being declared ino'per'able due to entry into the Action range when, in fact, no deterioration of pump function has occurred.

Since the purpose of pump testing is to detect deterioration of pump function, establishing higher upper limits' for pump test quantities to account for extraneous conditions will have no effect on the ability to detect changes in the pump's

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hydraulic performante. Recent changes in the American National Society for i

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Inservice Testing of Dumps (ANSI /ASME OM-6-1986, Draft 8) have reflected this position.

Coupled with the above, is the use of a more extensive vibration monitoring program than ASME Section XI requires.

Tne LaSalle vibration program meets all of the requirements delineated in ANSI /ASME OM-6-1986, Draft 8.

Vibration analysis is a reliable performance indicator of pump mechanical condition and provides positive identification of degrading conditions. LaSalle's vibration monitoring program is described in Relief Request RP-04.

(See Item 3.1.2 of this report for a discussion of the vibration monitoring program.)

ALTERNATE TEST:

The evaluation of applicable pump test quantities will be per the following table:

a ALLOWABLE RANGES OF PUMP TEST PARAMETERS Acceptable Required Range Alert Range Action Range Test Parameter Low High low High Low High

<.90P

>1.10P P (Positive

.93 to 1.10P

.90 to <.93P 7

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r Displacement Pumps) l AP (Vertical Line

.95 to 1.10P

.93 t <.95AP

<.93AP,

>1.10AP r

r r

Shaft Pumps)

Q (Positive

.95 to 1.10Q

.93 to <.95Q

<.93Q

>1.10Q r

p r

r Displacement and Vertical Line Shaft Pumps)

AP(Centrifdgal

.90 to 1.10AP

<0.90AP

>1.10aP r

r r

Pumps)

Q (Centrifugal

.90 to 1.10Q

<0.90Q

>1.10Q r

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Pumps)

NOTE: The subscript "r" denotes reference value, a.

See American National Standard for Inservice Testing of Pumps - ANSI /ASME OM-6-1986, Oraft 8.

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3.1.3.2 Evaluation. Table IWP-3100-2 of Section XI identifies the pump parametnrs to be monitored during pump tests and the allowable ranges of those parameters.

The licensee's proposal to utilize the expanded ranges of ANSI /ASME OM-6, Draft 8, in lieu of Table IWP-3100-2 has not provided sufficient information to demonstrate that pump degradation will be detected prior to the pump being unable to meet its design basis pressure and flow requirements.

In order to resolve this issue, the licensee should provide the staff with information that identifies the pumps with which difficultiu occur while being tested in accordance with the requirements of Section XI. The licensee should also include information that 61scusses the cause(s) of the data :catter encountered during pump tests and provide a basis to show that significant degradation will not affect required pump operability if the proposed methodology is used.

Based on these considerations, the licensee has not demonstrated the impracticality of conducting pump testing in accordance with the requirements of Section XI, Table IWP-3100-2, nor demonstrated that the proposed alternate technique is at least equivalent to the requirements of the Code, relief should not be granted as requested.

3.2. Diesel Generator Fuel Oil Transfer pumps 3.2.1 Pump Inlet Pressure The licensee has requested reitef from measuring 'nlet prassure on the_

diesel fuel oil transfer pumps, OD001P, 1(2)D001P, and 1(2)D002P, in accordance with the requirements of Section XI, IWP-31CO, and proposed to calculate the inlet pressure.

3.2.1.1 Licensee's Basis for Requesting Relief. The fuel oil transfer pumps do not have gauges installed to directly measure suction pressure in order to perform the required ASME XI testing. The alternate test method proposed should provide adequate performance monitc,ing of these putops in order to determine their hydraulic and mechanical condition as well as detection of degrading performance.

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ALTERNATE TEST:

The fuel oil transfer pumps will be tested using indirect means for determining the test parameters used for performance as follows:

Pump Inlet pressure - This test parameter will be determined by converting the diesel fuel oil storage tank (DFOST) level into a static pressJre head in psig for the pump.

i 3.2.1.2 Evaluation. The diesel fuel oil transfer pumps take their suction directly from the fuel oil storage tanks and would have inlet pressure due to the level of fuel oil in the tank above the pump inlet.

The pump inlet pressure cannot be measured because inlet pressure instruments are not installed. However, it can be calculated because level indication is installed on the storage tank. Also, sufficient blockage of_

the pump inlet would be indicated by a reduction in pump flow rate.

A system modification would be necessary to allow direct measurement of pump inlet pressure and the additional information provided would have a minimal impact on the licensee's ability to detect pump hydraulic degradation. Based on the impracticality of these measurements, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of measuring storage tank level and calculating pump inlet pressure, relief may be granted from the Section XI requirements as requesteo.

3.2.2 Pump Differential Pressure The licensee has requested relief from measuring differential pressure on the diesel fuel oil transier pumps, OD001P, 1(2)D001P, and 1(2)D002P, in accordance with the requirements of Section XI, Paragraph IWP-3100, and proposed toicalculate the inlet pressure.

3.2.2.1 Licensee's Basis for Requesting Relief. The fuel oil transfer pumps do not have gauges installed to directly measure suction 16

pressure or installed flow rate meters to directly measure flow rate in order to perform the required ASME XI testing.

The alternate test method proposed should provide adequate performance monitoring of these pumps in order to determine their hydraulic and mechanical condition as well as detection of degrading performance.

ALTERNATE TEST:

The fuel oil transfer pumps will be tested using indirect means for determining the test parameters used for performance monitoring as follows:

Pump Differential Pressure - This test parameter will be determined by j

recording the pump discharge pressure and subtracting the running inlet pressure. Running inlet pressure is calculated by subtracting the suction

trainer differential pressure when the pump is operating from the static pump inlet pressure. Calculations have determined that the friction head loss resulting from the aaproximate 8 foot sectior of suction piping is negligible.

3.2.2.2 Evaluation.

The diesel fuel oil transfer pumps take their suction directly from the fuel oil storage tanks and would have inlet pressure due to the level of fuel in the tank above the pump inlet. The pump inlet pressure cannot be measured because inlet pressure instruments are not installed. The inlet pressure is calculated based on the level in the tank and, since inlet pressure is calculated, the pump differential pressure mtst also be calculated.

A system modification would be necessary to allow direct measurement of pump inlet pressure or differential pressure and the additional information prcvided would have a minimal impact on the licensee's ability to detect pump, hydraulic degradation. Based on the impracticality of obtaining these measurements directly, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of measuring storage tank level and calculating pump inlet and 17

differential pressure, relief may be granted from the requirements of Section XI as requested.

3.2.3 Pump Flow Rate The licensee has requested relief from measuring flow rate on the diesel fuel oil trans?er pumps, 00001P, 1(2)D001P, and 1(2)D002P, in accordance with the requirements of Section XI, Paragraph IWP-3100, and proposed to calculate the flow rate.

3.2.3.1 Licensee's Basis for Regaesting Relief. The fuel oil transfer pumps do not have gauges installed to directly measure flow rate in order to perform the required ASME XI testing.

The alternate test method proposed should provide adequate performance monitoring of these pumps in order to determine their hydraulic and mechanical condition as well as detection of degrading performance.

ALTERNATE TEST:

The fuel oil transfer pumps will be tested using indirect means for determining the test parameters used for performance monitoring as follows:

Pump Flow Rate - This test parameter will be calculated using the diesel fuel oil day tank lavel indicator as the flow rate quantity meter as permitted in IWP-4600 and converting the measured rate of change to flow rate in GPM.

3.2.3.2 Evaluation. Due to system design, instrumentation is not installed to measure flow rate, however, flow rate can be accurately calculated by monitoring the rate-of-chanae of the level in the diesel generator day tank during pump testing while the diesel engine is secured and is an acceptable alternate test method.

A system modification would be necessary to allow direct measurement of pump flow rate and the additional information provided would have a minimal impact on the licensee's e'ility to detect pump hydraulic 18

degrada..on. Based on the impracticality of obtaining this measurement directly, the burden on the licensee if this Code requirement was imposed, and the licensee's proposed alternate testing of calculating flow rate from day tank rate'of level change, relief may be granted-from the requirements of Section XI as requested.

3.3 High Pressure Core Soray Pump 3.3.1 Instrumentation Range The licensee has requested relief from the instrumentation full-scale range requirements of Section XI, Paragraph IWP-4120, for the high pressure core spray pump, 1(2)E22-C001.

3.3.1.1 Licensee's Basis for Requesting Relief. The reference value for.the inlet pressure of the HPCS pump is 4 psig when drawing water from the suppression pool or the condensate storage tank. The full-scale range of the inlet pressure gage is -30" Hg to 109 psig, or about a 115 psig range. The range is necessary due to the configuration of this system.

When the HPCS pump is being stopped, there is a spike in the suction pressure.

Such a pressure spike causes a suction pressure indicator with a smaller range to go out of calibration. Hence, a suction pressure gage with a larger scale is needed to enable the gage to remain in calibration

)

for the measurement of suction pressure of the HPCS pump.

.l ALTERNATE TEST:

Due to pressure spikes, a gage with a larger scale will be used to measure inlet pressure.

3.3.1.2 Evaluation. The licensee's use of wider range j

instrumentation in this application should prevent instrument damage or intccuracies due to overranging. The proposal to utilize existing instrumentation whose range is greater than three times reference value 19

.. ~ - -

should provide sufficiently accurate data to utilize in the pump monitoring program to assess pump degradation.

Based on the impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, relief may be granted from the instrumentation range requirements of Section XI as requested.

3.4 ECCS Water Leg pumps 3.4.1 Inlet pressure, Differential Pressure, and Flow Measurements The licensee has requested relief from measuring inlet pressure, differential pressure, and flow rate on the high pressure core spray water leg pump, 1(2)E22-C003, the low pressure core spray water leg pump, 1(2)E21-C002, the residual heat removal water leg pump, 1(2)E12-C003, and the reactor core isolation cooling water leg pump, 1(2)E51-C003, in accordance with the requirements of Section XI, Paragraph IWP-3100.

3.4.1.1 Licensee's Basis for Requesting Relief.

Flow is not a significant design parameter for the water leg pumps. Their primary purpose is to maintain the emergency core cooling system (ECCS) pump discharge lines filled and pressurized..The satisfactory performance of this function is verified by the maintenance of the discharge line within allowable standby pressure limits.

Therefore, there is actually no flow criteria on the pumps that could be used to determine whether the pump is satisfactorily performing its safety function.

Because the design basis of the water leg pumps is maintenance of pressure, this is the parameter that will be considered for inservice testing.

ALTERNATE TEST:

Pressure maintenance of ECCS discharge lines within allowable pressure limits.

3.4.1.2 Evaluation. These pumps run against a shutoff head to maintain the discharge line of their associated system pressurized and very 20

. _.-___ _..~ _- _ _ -, _ -.

little, if any, flow occurs. Because of this practically static condition, there are no parameters, other than vibration and discharge pressure, that would provide reliable data to utilize in monitoring pump degradation.

Based on the impracticality of the Code requirements and the burden on the licensee if those requirements were imposed, the proposed alternate testing of verifying proper pressure maintenance in the discharge lines of the system associated with each water leg pump should be sufficient to demonstrate proper pump operability, therefore, relief may be granted from the requirements of Section XI as requested.

3.5 Standby Liquid Control Pumos 3.5.1 Inlet and Differential Pressure The licensee has requested relief from measuring inlet pressure and differential pressure on the standby liquid control pumps, 1(2)C41-C001A und -C0018, in accoroance with the requirements of Section XI.

3.5.1.1 Licensee's Basis for Requesting Relief.

It is impractical to measure standby liquid control pump' inlet pressure in accordance with 4

Section XI requirements. During pump testino, tne pump suction is from a test tank rather than the main standby liquid control tank. The only means available to measure inlet pressure is to correlate tank level to inlet pressure. These pumps are positive displacement and the measurement of inlet pressure is not critical in judging oump performance. Measuring the discharge pressure and the flow rate is adequate to detect changes in the hydraulic charactoristics of the pumps.

ALTERNATE TEST:

Heasure, pump discharge pressure and flow rate quarterly.

3.5.1.2 Evaluation. These are positive displacement pumps and changes in their inlet pressure have no effect on the flow rate or the 4

21 m

tmvr-w'S w-+1

discharge pressure.

For this reason, calculating or measuring inlet or differential pressure would not contribute meaningful data to utilize in monitoring pump degradation.

The proposed alternate testing of measuring pump discharge pressure and flow rate should provids sufficient information to adequately monitor the hydraulic condition of these pumps and relief may be granted from the requirements of Section XI to measure inlet and differential pressure during pump tests. The burden on the licensee would not be justified by the limited information that would be provided concerning pump mechanical condition if the Code requirements were imposed.

3.6 Residual Heat Removal pumps 3.6.1 Instrumentation Range The licensee has requested relief from the instrumentation full-scale range requirements of Section XI, Paragraph IWP-4120, for the residuc1 heat removal pumps,1(2)E12-C002A, -C0028, and -C002C.

3.6.1.1 Licensee's Basis for Requesting Relief. The reference values for the inlet pressures of RHR pumps A, B, and C are all P 3 5 psig.

7 4

The reference value for the inlet pressure of the RHR water leg pump is D t8 psig.

The full scale range of the inlet pressure gages for all four pumps reads 0-250 psig. The inlet pressure for these pumps may attain a maximum pressure of 200 osig and, therefore, the pumps require a gage with a larger scale range.

Al. TERNATE TEST:

Since inlet pressure varies on the RHR pumps, gages with larger scale ranges are required to accommodate pressure rises of pump suction.

3.6.1.2 Evaluation. The licensee's use of wider range instrumentation in this application should prevent instrument da:nage or inaccuracies due to overranging. The proposal to utilize existing 22

instrumentation whose range is greater than three times' reference value should provide sufficiently accurate data to utilize in the pump monitoring program to assess pump degradation.

Based on the-impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, relief may be granted from the. instrumentation range requirements of Section XI as requested.

3.7, Reactor Core Isolation Cooling pump 3.7.1 pump Speed The licensee has requested relief from adjusting the variable speed reactor core isolation cooling turbine and pump, 1(2)E51-C001, to the j

reference speed in accordance with Section XI, Paragraph IWP-3100, and proposed to duplicate a specified pump discharge pressure and flow rate during pump tests.

4 i

3.7.1.1 Licensee's Basis for Requesting Relief. ASRE Section XI, Article IWP-3100, states that pump speed and either flow rate or i

differential pressure must be adjusted to set reference values prior to the measurement of other pump parameters.

LaSalle Station is requesting relief I

from this Code requirement. The two critical performance parameters for the RCIC system are vessel injection pressure and flow rate.

For this reason, Station Tech Specs require that the parameters of flow rate and pump outlet pressure be set at reference values during the conductance of a quarterly RCIC pump operability test. The-test procedure then measures pump speed, inlet pressure, and vibration.

Following the test, all measured parameters are graphically trended to provide for early indi" tion of degrading pump performance if present.

23

ALTERNATE TEST:

Test pump performance in accordance with Station Tech Specs as described above. The acceptable range of pump speed is bounded by an Alert Range as well as Required Action Range to identify a pump condition requiring corrective action.

3.7.1.2 Evaluation. The licensee has not provided a technical justification for not establishing and duplicating a reference speed during tests of the reactor core isolation cooling pump. The turbine reference speed should be reproduced during pump tests in order to more accurately duplicate pump differential pressure and flow rate values for use in assessing the hydraulic performance of this pump. The licensee has stated that Alert and Required Action Ranges will be utilized during evaluation of the resultant pump speed but has not discussed the technical bases considered during selection of the ranges, the magnitude of the ranges, nor how this evaluation of pump speed would be utilized during the analysi.e of the pump per,formance. Also, testing the reactor core isolation cooling pump in accordance with Section XI and duplicating the reference values of the test quantitics as required will not add significantly to the length of the test.

The licensee has not demonstrated the impracticality of duplicating a turbine reference speed, therefore, the licensee should test the reactor

)

core isolation coiling pump in accordance with Paragraph IWP-3100 which j

includes Table IWP-3100-2, "Allowable Ranges of Test Quantities," and relief should not be granted from the requirements of Section XI as requested.

24

4.

VALVE TESTING PROGRAM The LaSalle County Station IST program submitted by Commonwealth Edison was examined to verify that all valves included in the program are s'ubjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief.from testing has been requested, these vehes are tested to the Code requirements and established NRC positions. Each Commonwealth Edison basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to system and valve category.

4.1 All Systems 4.1.1 Containment Isolation Valves 4.1.1.1 Relief Request. The licensee has requested relief fron leak testing all primary containment isolation valves in accordance with the requirements of Section XI, Paragraphs IWV-3420 through -3425, and proposed to leak test these valves in accordance with 10 CFR 50, Appendix J.

4.1.1.1.1 Licensee's Basis for Requesting Relief--Primary containment Category A isolation valves will be seat leak tested in accordance with the requirements of Technical Specification 3/4.6.1.2 and Appendix J to 10 CFR 50. Technical Specification 3/4.6.l.2 surveillance j

testing for measuring valve seat leakage is consistent with the requirements of Appendix J to 10 CFR 50 with the exception of the exemption granted by the NRC for the main steam isolation valves. Operating experience with the MSIVs has indicated that degradation has occasionally occurred in,the leak tightness of the valves; therefore the special requirements, fo'r testing the MSIVs was added.

The ECCS and RCIC systems will be prassurized with water to a minimum pressure of 43.6 psig (1,10 times peak drywell accident pressure) with the system totally isolated from the primary :ontainment.

25

All pressure boundary isolation valves, their classification, and leak rate testing has been previously addressed in the NRC SER for LaSalle, Units 1 and 2.

ALTERNATE TEST:

Perform seat leakage testing in accordance with the requirements of Appendix J to 10 CFR 50 or as amended by Technical Specifications. The seat leakage results of the primary containment isolation valves will be analyzed in accordance with Appendix J to 10 CFR 50, Technical Specification 3.6.1.2, and ASME Section XI, Paragraph IWV-3426. Corrective action will be taken in accordance with Paragraph IWV-3427 and the Technical Specifications. The leakage rates for the primary containment will be limited to the following (as taken from T.S. 3.6.1.2):

An overall integrated leakage rate of less than or equal to L,,

a.

0.635 percent by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P,, 39.6 psig.

b.

A combined leakage rate of less than or equal to 0.60 L, for all penetrations and all valves li.sted in Table 3:6.3-1, except for main steam isolation valves and valves which are hydrostatically leak tested per Table 3.6.3-1, subject to Type B and C tests when pressurized to P,, 39.6 psig.

c.

Less than or equal to 100 scf per hour for all four main steam lines through the isolation valves when tested at 25.0 psig.

d.

A combined leakage rate of less than or equal to 1 gpm times the total number of ECCS and RCIC containment isolation valves in hydrostatically tested lines which penetrate the primary

' containment, when tested at 1.10 P,, 43.6 psig.

All pressure boundary isolation valves as specified in Technical Specification Table 3.4.3.2-1 will be individually leakage rate tested in accordance with Technical Specification 4.4.3.2.2.

26

,~-,y

,,-__m

.m,

_.y.

4.1.1.1.2 Evaluation--The leak test procedures and requirements for containment isolation valves identified by 10 CFR 50, Appendix J, essentially meet the Section XI Code requirements since all of the major elements of Paragraphs IWV-3421 through -3425 are incorporated.

Appendix J, Type C, leak rate testing adequately determines the leak-tight integrity of these valves. Since the 10 CFR 50, Appendix J, leak rate testing does not trend or establish corrective actions based on individual valve leakage rates, the licensee has stated that the Analysis of Leakage Rates and Corrective Action requirements of Section XI, Paragraph IWV-3426 and -3427 will be followed and, therefore, is a:ceptable. Additionally, leak testing the MSIVs in accordance with special procedures that specify a maximum leakage limit is acceptable because the requirements are in i

agreement with previously approved BWR Standard Technical Specifications.

The alternate method of leak testing containment isolation valves in accordance with the requirements of 10 CFR 50, Appendix J, is acceptable and, therefore, relief may be granted from the requirements of Section XI, Paragraphs IWV-3420 through -3425 as requested, j

4.1.2 Excess Flow Check Valves 1

4.1.2.1 Relief Request. The licensee has requested relief from the exercising and leak :esting requirements of Section XI, j

Paragraphs IWV-3411, -3420, and -3521, for all excess flow check valves and proposed to full-stroke exercise these valves and perform modified leak o

rate testing during refueling outages.

4.1.2.1.1 Licensee's Basis for Rec,uesting Relief--These excess flow check valves, depending on service, are designed to automatically close either in the event of a downstream line rupture in which flow exceeds 6.5'gpm or if drywell pressure exceeds 2 psig. Upon closing, these valves are designed to allow a controlled leakage. Exercising these valves requires that such essential instrumentation as recirculation flow, emergency core cooling system initiation, primary containment isolation, reactor protection system, and neutron monitoring be temporarily taken out 27

e of service, which would render these required instruments or that entire emergency core cooling system division inoperable, possibly forcing a plant shutdown.

In addition, isolation of these valves and subsequent return to service may cause transients to other instrumentation causing unnecessary reactor protection system, primary containment isolation system, and emergency core cooling system actuations.

Furthermore, these valves cannot be exercised during cold shutdowns because removal of multiple instruments from service could prevent operation of systems required for decay heat removal.

ALTERNATE TEST:

Full-stroke exercise and leak test during reactor refueling.

4.1.2.1.2 Evaluation--These valves cannot be exercised during power operation because various instrument sensing lines must be disconnected thus removing multiple reactor instrumentation from service.

Those instruments provide reactor protection and control signals and cannot be removed from service without possibly causing a reactor trip.

Additionally, these valves cannot be exercised during cold shutdown because removal of multiple instruments from service could prevent operation of systems required for decay heat removal.

Based on the impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, full-stroke exercising these valves during the performance of a modified leak rate test during refueling outages when multiple reactor protection j

and control instrumentation can be removed from service should demonstrate proper valve operability and, therefore, relief may be granted from exercising frequency requirements of Section XI as requested.

\\

4.1.3 Correttive Action 4.1.3.1 Relief Request.

The licensee has requested relief from the corrective action requirements of Section XI, Paragraphs IWV-3417(b) 28

and -3523, for those valves that are exercised during cold shutdowns and refueling outages and proposed to utilize plant Technical Specifications to determine initiation of corrective action.

4.1.3.1.1 Licensee's Basis for Requesting Relief--Specific relief is requested from the requirements of Paragraphs IWV-3417(b) and IWV-3523 of Section XI of the 1980 Edition of the ASME Boiler and Pressure Vessel Code including the Addenda through Winter 1980. These paragraphs state the corrective actions to be taken when valves fail to exhibit a required change of disk position.

These actions include requirements to take corrective action prior to plant startup should a failure occur during cold shutdown testing for valves which can be tested only during cold shutdown.

If a failure of a valve is disc' overed during cold shutdown testing of a valve which can be tested during operation, the plant can be retur'ned to operation if allowed by the Technical Specifications. Also stated are requirements to declare valves inoperable if corrective action is unsuccessful within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

These paragraphs do not take into account the plant Technical Specifications requirements for limiting conditions for operation wh'ich state the minimum con'ditions necessary for safe operation of the plant. The failure of a particular valve may not necessarily require a plant shutdown or prevent a startup.

In addition, valves not capable of performing their safety-related function.are declared inoperable as taon as that conditian has been verified, not after a 24-hour period has elapsed.

For the above reasons, LaSalle County Station will evaluate the condition of each valve with respect to its safety-related function and take the appropriate corrective action as stated in the Technical Specification - Limiting Condition for Operation.

ALTERNATE TEST:

Evaluate the condition of each valve with respect to its safety function and take appropriate corrective action as stated in the Technical Specification - Limiting Condition for Operation.

i 1

29

4.1.3.1.2 Evaluation--Valves that are tested only during cold shutdowns or refueling outages are tested at that frequency because of specific problems encountered while testing them quarterly during power operation and those problems or the consequences of the testing are addressed in the appropriate cold shutdown justification or relief request. Since Section XI, Paragraphs IWV-3417(b) and -3523, require a successful retest following valve repairs and prior to returning the valve to service, the failed valve should be repaired during the outage in which the failure was discovered if system or plant conditions will not allow retesting following the return to power operation. However, if a valve fails while being testad during cold shutdown, and that valve can be tested following repairs during power operation, then plant startup should be allowed with the valve out of service provided that the plant Technical Specifications permit startup if the applicable Limiting Conditions for Operation are satisfied.

Based on the impracticality of requiring the licensee to delay plant startup in order to repair a valve which the plant Technical Specifications do not require to be operable for plant startup and operation, relief may be granted from'the requirements of Section XI, Paragraphs IWV-3417(b) and -3523. However, any valve that is inoperable prior to startup and cannot be tested prior to return to service and is subsequently required by Technical Specifications during operation shall be repaired prior to startup.

4.2 Diesel Oil System i

4.2.1 Category B Valves 4.2.1.1 Relief Request. The licensee has requested relief from measuring the stroke time of valves 000-004, diesel generator OA day tank inlet, 1(2)DO-004, 1(2)A diesel generator day tank inlet, 1(2)D0-014, 1(2)B diesel generator day tank inlet, and 1(2)DO-024, diesel fire pump fuel oil transfer pump inlet, in accordance with the requirements of Section XI, Paragraphs IWV-3413(a) and -3413(b).

1 30

D 4.2.1.1.1 Licensee's Basis for Requesting Relief--These valves are small (less than or equal to 2" nom. diam.) solenoid operated gate valves that are normally in a closed position.

Each valve opens in conjunction with the start of its associated diesel generator fuel transfer pump in order to maintain an adequate level of diesel oil in the diesel generator day tank. These valves are not equipped with a control switch but open when the fuel transfer pumps starts. Since the opening signal for the valve is not directly controllable, repeatable timing is not possible.

ALTERNATE TEST:

Full-stroke exercise quarterly.

4.2.1.1.2 Evaluation--The design of the control circuit for these valves is such that the valves are not equipped with individual control switches but are signaled to change position by the associated pump control system. Due to this design feature, accurete valve stroke time measurements cannot be taken because the measurement would not be repeatable from test to test and would not be a reliable' indication of valve degradation. Additionally, unnecessary valve maintenance may be performed because of the variat'on in the stroke time measurements.

Based on the impracticality of compiying with the Code requirements and the burden on th. licensee if those requirements were imposed, full-stroke exercising these valves quarterly without measuring stroke time should be sufficient to demonstrate valve operability and, therefore, relief may be granted from the stroke time measurement requirements of Section XI.

4.3 Feedwater Systen I

4.3.1 Category A/C Valves 4.3.1.1 Relief Request. The licensee has requested relief from exercising valves 1(2)B21-F010A, -F0108, reactor feedwater header inboard 31

checks, -F032A, and -F032B, reactor feedwater header outboard checks, and s

from verifying the open position indication of -F032A and -F032B in accordance with the requirements of Section XI, Paragraphs IWV-3300, -3410, and -3520, and proposed to verify closure during refueling outages.

4.3.1.1.1 Licensee's Basis for Requesting Relief--The.feedwater line check valves are normally open during plant operation to allow coolant makeup to the reactor vessel. During plant shutdown conditions, this flowpath is also maintained available to allow normal coolant makeup to the reactor vessel if required. The feedwater-line is also the. return line for the reactor water cleanup system which is in operation during cold shutdown conditions to maintain reactor water quality. A leak rate-test must be i

performed in order to verify the closure of these normally open check valves. This test is not possible during power o,. ration because a flow of coolant is passing through the feedwater lines.

These valves cannot be tested during cold shutdown due to the need to keep this flowpath available for reactor coolant makeup and reactor water cleanup return, the long time required to prepare the piping system for draining and then draining it and performing leakage rate testing. This testing requires a large resource commitment which is not available during normally short cold shutdowns.

performing these tests also thvolves additional radiation exposure. These valves will be exercised during refuell'g outages when ferdwater flow is not needed and the lines may be drained.

This is the or.ly practical time to perform this test without straining resources needed to return the unit to service.

The open position indicator can not be correctly adjusted and set while shutdown (with low or no feedwater flow) and the feedwater lines in 4

the area of these valves are a high radiation area during power operation I

and are inaccessible by personnel.

Since the safety function of the 1(2)B21-F032A/B valves is to close, the absence of the open indication will I

not restrict p'wer operation because the feedwater headers are individually o

q monitored for flow.

4 4

2 32

c I

ALTERNATETEE:

The safety function of these check valves is to close to isolate the feedwater line. The leakage rate test during refueling outages proves the c hsure capability of these valves.

Flow during power operation demonstrates the opening capability. Verify only the closed position indicator operation during each refueling outage.

4.3.1.1.2 Evaluation--The safet>-related function of these four check valves is to shut to isolate' the reactor feedwater headers.

They cannot be exercised shut quarterly during power operation because to do so requires interruption of the reactor.feedwater flow and could result in a

. reactor trip. Adddtionally, they cannot be exercised closed during cold shutdowns because the method utilized to verify closure is a leak rate test which requires that the header under test be resloved from service and drained before leak testing the associated valves. This test method could delay reactor startup due to the length of time required to drain the header and process the water through the radwaste system. Also, since the reactor water cleanup system return flow path is through these valves, the reactor water cleanup system must be removed from service while leak testing and reactor vnel chemistry centrol could t,e lost which, in turn, could delay reactor startup because the Technical Specification chemistry limitations must be satisfied prior to startup.

The accuracy of the valve closed position indication installed on valves -F032A and -F032H can be readily verified during leek rate testing becaun the leak test is the only positive means of closing the valve and is performed at the same frequency as the position indicaticn verification.

Based on the impracticality of full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee t' these Code requirements were imposed, the alternate testing of verifying closure of all four check valves during lesk tests performed at refueling outages; and verifying the position indication of the -F032A and -F032B valves 33

during that testing, should demonstrate proper valve operability and, therefore, relief may be granted from the exercising requirements of Section XI as requested.

4.4 High pressure Core Spray System 4.4.1 Category A/C Valves 4.4.1.1 Relief Reauest. The licensee has requested relief from exercising valve 1(2)E22-F005, high pressura core spray injection testable check, in accordance with the requirements of Section XI, Paragraphs IWV-3412 and -3522, and proposed to partial-stroke exercise this valve...ing cold shutdowns.

4.4.1.1.1 Licensee's Basis for Requesti.sg Relief--This normally closed testable check valve serves as the first isolation valve in the event of a system line break. Testing could be performed during power operation, however, a real possibility exists that this valve may not properly re> eat, rendering it incapable of performing its.1 solation function.

Since the drywell is inaccessible during power operation, the affected penetration would need to be isolated, causing the system to be unavailable for its emercency function. The risk involved with the cycling of this valve during power operation is much greater than the assurance of operability gained by quarterly testing.

The valve will be exercised at cold shutdown when its isolation function is not required.

This exercisable check valve was originally designed and furnished by the manufecturer to verify operability by partially stroking the disk from the closed position. The operator design makes it incapable of closing the valve against flow or keeping it open against reverse flow and moves the disk from the fully closed position to 31% of full-stroke (25' of the 80*

"free tilting" disk travel). Due to the design of the installed equipment,

)

it is impractical to test the valve to the full open position or inject flow into the vessel to full-stroke exercise the valve. A major modification to the valve and plant design would be required to full-stroke l

34

exercise this valve. Based on the manufacturer's experience, if the disk can be partially stroked by means of the test operator, they have a high degree of confidence that the valve will fully open under design flow.

conditions.

(Reference - LSCS -FSAR Question 212.103)

ALTERNATE TEST:

Exercise during each cold shutdown by use of the test operator.

4.4.1.1.2 Evaluation--The design of the operator on this testable check valve is such that movement of the valve disk is mechanically limited to a,nartial-stroke exercise. Due to this featur6, the only method available to utilize to full-stroke exercise the disk of t"is valve is to pass the required design basis accident flow rate through it and the only available flow path is into the reactor vessel. This test method is undesirable both during power operation and cold shutdowns because severe thermal shock to the spray spargers would result whenever the reactor vessel is at operating temperature. Performing this flow test during cold shutdowns could delay plant startup due to the injection of lower quality water and the reautrement to meet the Technical Specification chemistry limitations prior to startup.

The possibility of developing a low-temperature overpressure condition in the reactor vessel also exists due to the limited volume available to accommodate the flow required to full-stroke the valve disk.

Based on the impracticality of full-stroke exercising this valve quarterly and during cold shutdowns, the burden on the licensee if thase Code requirements were imposed, and the licensee's proposal to partial-stroke exercise this valve cach co.d shutdown, relief ma> be granted from the requirements of Sect an XI as requested. However, the licensee should investigate some alternate method or consider system j

modifications to allow full-stroke exercising this valve in accordance with the requirements of the Code as closely as possible.

35

4.4.2 Category C Valves 4.4.2.1 Relief Request. The licensae has requested relief from exercising valve 1(2)E22-F016, high pressure core spray suppression pool suction check, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to full-stroke exercise it during refueling outages.

t 4.4.2.1.1 Licensee s Basis for Requesting Relief--The high pressure core spray system is demonstrated to be operable each quarter by takir.g a suction from and disch&rging back to the cycled condensate storage tank. Valve F016 can be exercised by aligning the HPCS pump suction to the suppression pool and running the HPCS pump. Allowing suppression pool water to enter the HPCS system permits the possibility of severely degrading the water quality of about 300,000 gallons of water in the cyclev condensate storage tank. This would cause may of the units' systems, including reactor water system, to become contaminated with th?5 low quality water.

It would take 2-3 days to clean up the cycled condensate tank and this would use up a significant amount of r, sin capacity resulting in significant cost for resin replacement and disposal.

This degradation of water quality would likely cause accepted industry standards for cycled condensate and reactor chemistry to be exceeded. This situation is undesirable at all times but may be guarded against if this testing is conducted during refueling outages. Therefore, it is requested that this valve be full-stroke exercised during each refueling outage.

ALTERNATE TEST:

Full-stroke exercise each refueling outage during the HPCS alternate

' low path test.

4.4.2.1.2 Evaluation--Due to plant design, high pressure core l

spray system flow cannot be utilized to full-stroke exercise this valve during power operation or cold shutdown. The system suction must be aligned to the suppression pool to full-strcke exercise this valve and 36

would result in the introduction of relatively low quality water into the cycled condensate system and from there, into the reactor coolant system.

The lower quality water could force plant shutdown due to the inability to maintain reactor coolant chemistry specifications or could delay plant startup because the Technical Specification chemistry limitations must be met prior to startup.

Based on the impracticality of exercising this valve quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising this valve during refueling outages, relief may be granted from the Section XI exercising frequency require:aents as requested.

4.5 Drywell Instrument Nitroaen System 4.5.1 Category A/C Valves 4.5.1.1.

Relief Requer.t. The licenste has requested relief from exercising valve 1(2)IN018, drywell instrument nitrogen supply header check, in accordance w1th the requirements of Section XI, Paragraphs IWV-3410 and -!!520, and proposed to verify closure during refueling outages.

4.5.1.1.1 Licensee's Basis for Requesting Relief--This valve provides instrument nitrogen to equipment in the drywell and either isolates the nitrogen compressor when closed or would require the j

instrument nitrogen system to be shut down in order to perform a leak j

test. The loss of the instrument nitrogen system will result in a loss of j

control of the inboard main steam isolation valves, the safety / relief l

valves, and all other air operated valves in the primary containment.

System design provides an alternate emergency air supply in the event the instrument nitrogen compressor is inoperable. However, the drywell is required to be nitrogen inerted during power operation and is not routinely de-inerted during cold shutdown. The use of station instrument air to feed the drywell pneumatic system will result in a gradual increase in primary s

l 37

containment atmosphere oxygen concentration during periods when the primary containment is required to be inerted. Testing this valve would require that the drywell be de-inerted. Also, the drywell nitrogen purge limits the amount of general corrosion on all interior surfaces and thus further reduces the possibility of component failure. When the drywell pneumatic system is no longer required to provide instrument nitrogen to drywell components during cold shutdowns, and the drywell is de-inerted, the instrument nitrogen system may be $5ut down. Typically, the system is shut down only during extended planned unit outages when this evolution and testing would not increase the probability of delaying a unit startup.

ALTERNATE TEST:

The leak rate test during refueling outages proves the closure capability of 1(2)IN018. Normal nitrogen system pressure in the main steam isolation valve accumulators and acceptable operation of all valves utilizing the nitrogen system inside containment demonstrates the opening capability of 1(2)IN018.

4 5.1.1.2 Evaluation--This valve cannot be exercised to its safety position (closed) without stopping the instrument ~ nitrogen flow to the drywell which would result in loss of control of various valves required for plant operation. The main steam isolation valves are of particular concern because, as aitrogen pressure is lost, the valves would drift shut resulting in a plant trip. The automatic depressurization function of the safety / relief valves would also be lost, however, the mechanical relief function of the valves would remain operable. Use of the alternate operating air supply could result in a forced shutdown due to the inability to maintain the drywell nitrogen concentration within Technical Specification limits. And, since the drywell is not de-inerted each cold l

shutdown, use of the alternate air s,upply could delay plant start-up because the concentration limits must be met prior to power ascension.

Leak rate testing this valve is the only positive means of verifying closure because this is a simple check valve that is not equipped with position indication.

38

Based on the impracticality of full-stroke exercising this valve quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the alternate testing proposed should demonstrate proper _ valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

4.5.2 Category A Valves 4.5.2.1 Relief Request. The licensee has requested relief from exercising and fail-safe testing valves 1(2)IN001A, 001B, compressor drywell suction isolations,1(2)IN074, 075, dryer purge isolations, 1(2)!N017, drywell instrument nitrogen supply, and 1(2)IN031, traversing in-core probe (TIP) purge supply, in accordance with the requirements of Section XI, Paragraphs IWV'3410 and -3415, and proposed to full-stroke exercise and fall-safe test them during refueling outages.

4.5.2.1.1 Licensee's Basis for Requesting Relief--These valves are intregal in providing instrument nitrogen to equipment in the drywell and isolate the nitrogen compressor when closed. The loss of the iristrument nitrogen system will result in a loss of control of the inboard main steam isolation valves, the safety / relief valves, and all other air operated valves in the primary containment.

System design provides an alternate emergency air supply in the event the instrument nitrogen compressor is inoperable. However, the drywell is required to be nitrogen inerted during power operation and is not routinely de-inerted during cold shutdowns. The use of statiu instrument air to feed the drywell pneumatic system will result in a gradual increase in primary containment atmosphere oxygen concentration during periods when the primary containment is required to be inerted. Testing these valves would require that the drywell be de-inerted.

In addition, the TIP inderer purge valve allows a continuous purp supply of dry nitrogen to the TIP index mechanisms and guide tubes and is required at all times. This prevents changes in drywell atmosphere humidity from destroying the Sermetal (graphite) coating of the guide tubes wr..ch could render the TIP system inoperable. Also, the drywell nitrogen purge limits the amount of general corrosion on all P

39

r?

interior surfaces and thus further reduces the possibility of component failure. When the drywell pneumatic system is no longer required to provide instrument nitrogen to drywell components during cold shutdowns, and the drywell is de-inerted, the instrument nitrogen sys+,em may be shut down. Typically, the system is shut down only during extended planned uait outages when this evolution and testing would not increase the probability of delaying a unit startup.

E ALTERNATE TEST:

Perform full-stroke exercise coincident with fail-safe operation at a test frequency of_once each refueling outage.

1 4.5.2.1.2 Evaluation--These valves cannot be exercised to their safety position (closed) without stopping the instrument nitrogen flow to the drywell which would result in loss of coi, trol.of various valves required for plant operation. The main steam isolation valves are of particular concern because, as nitrogen pressure is lost, the valves would drift shut resulting in a plant trip. The automatic depressurization function of the safety / relief valves would.lso be lost, however, the mechanical relief function of the valves would remain operable. Use of the alternate operating air supply could result in a forced shutdown due to the inability to maintain the drywell nitrogen concentration within Technical Specification limits. And, since the drywell is not de-inerted each cold shutdown, use of the alternate air supply could delay plant startup because the concentration limits must be met prior to power ascension.

The traversing in-core probe indexer purge must remain in operation at all times to prevent genersi corrosion of the indexers and guide tubes which could cause failure of the TIP system. The TIP system is used to I

update the plant process computer and to calibrate the nuclear j

instrumentatiori and would severely curtail plant operation if it were to fail.

40 I

Based on the impracticality of full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee if these i

Code requirements were imposed, the alternate testing proposed should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

l 4.5.3 Category B Valves 4.5.3.1 Relief Request. The licensee has requested relief from exercising and fail-safe testing valves 1(2)IN100 and 101, drywell nitrogen i

supply isolations, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3415, and proposed to full-stroke exercise and fail-safe test them during refueling outages.

4.5.3.1.1 Licensee's Basis for Requesting Reitef--These valves are intregal in providing instrument nitrogen to equipment in the drywell and isolate the nitrogen compressor when closed. The loss of the i

instrument nitrogen system will result in a loss of control of the inboard i

main steam isolation valves, the safety / relief valves, and all other air q

operated valves in the primary containment.

Systenfesignprovidesan l

' alternate emergency air supply in the event the instrumert nitrogen f

compressor is inoperable. However, the drywell is required to be nitrogen inerted during power operation and is not routinely de-inerted during cold shutdown. The use of station instrument air to feed the drywell pneumatic system will result in a gradual increase in primary containment atmosphore oxygen concentration during periods when the primary containment is required to be inerted. Testing these valves would require that the drywell be de-inerted. Also, the drywell nitrogen purge limits the amount of general corrosion on all interior surfaces and thus further reduces the possibility of component failure. When the drywell pneumatic system is no longer required to provide instrument nitrogen to drywell components during cold shutdowns, and the drywell is de-inerted, the instrument nitrogen system may be shut down.

Typically, the system is shut down only during extended planned unit outages when this evolution and testing would not l

increase the probability of delaying a unit startup.

i 4

41

o ALTERNATE TEST:

Perform full-stroke exercise coincident with fail-safa operation at a test frequency of once each refueling outage.

4.5.3.1.2 Evaluation--These valves cannot be exercised to their safety position (closed) without stopping the instrument nitrpgen flow to

~

the drywell which would result in loss of control of various valves required for plant operation. The main steam isolation valves are of particular concern because, as nitrogen pres.sure is lost, the valves would drift shut resulting in a plant trip. The automatic depressurization function of the safety / relief valves would also be lost, however, the mechanical relief function of the valves would remain operable.

Use of the alternate operating ai. supply could result in a forced shutdown due to the inability to maintain the drywell nitrogen concentration within Technical Specification limits. And, since the drywell is not de-inerted each cold shutdown, use of the alternate air supply could delay plant startup because the concentration limits must be met prior to power ascension.

i Based on the impracticality of full-stroke exercising these v,alves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the alternate testing proposed should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

4.5.4 Category C Valves 4.5.4.1 Relief Request. The licensee has requested relief from exercising valves 1(2)IN043 and 044, drywell instrument nitrogen supply header checks, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to full-stroke exercise them during refueling outages.

l 4.5.4.1.1 Licensee's Basis for Requesting Relief--These valves provide instrument nitrogen to equipment in the drywell and either isolate 42

~

the nitrogen compressor when closed or would require the instrument nitrogen system to be shut down in order to perform a closure verification utilizing a leak test. The loss of the instrument aitrogen system will result in loss of the inboard main steam line isolation valves, the safety / relief valves, aad all other air operated valves in the primary containment. System design provides an alternate emergency air supply in the event the instrument nitrogen compressor is inoperable. However, the drywell is required to be nitrogen inerted during power operation and h n_o_t routinely de-inerted during cold shutdowns. The use of station instrument air to feed the drywell pneumatic system will :esult in a gradual increase in primary containment atmcsphere oxygen concentration during periods when the primary containment is required to be inerted.

Testing these valves would require that the drywell be de-inerted. Also, the drywell nitrogen purge limits the amount of general corrosion on all interior surfaces and thus further reduces the possibility of component failure. When the drywell pneumatic system is no longer required to provide instrument nitrogen to drywell components during cold shutdowns, and the drywell is de-inerted, the instrument nitrogen system may be shut down. Typically, the system is shut down only during extended planned unit outages when this evolution ar)d testing would not increase th2 probability of delaying a unit startup.

ALTERNATE TEST:

These valves will be full-stroke exercised during refueling outages.

4.5.4.1.2 Evaluation--These valves cannot be exercised to their safety position (closed) without stopping the instrument nitrogen flow to the drywell which would result in a loss of control of various valves required for plant operation. The main steam isolation valves are of particular concern because, as nitrogen pressure is lost, the valves would drif t shut resulting in a plant trip. 'The automatic depressurization function of the safety / relief valves would also be lost, however, the mechanical relief function of the valves would remain operable, Use of the alternate operating air supply could result in a forced shutdown due to the inability to maintain the drywell nitrogen concentration within Technical 43 i

i Specification limits. And, since the drywell is not de-inerted each cold shutdown, use of the alternate air supply could delay plant startup because the concentration limits must be met prior to power ascension.

Leak rate testing these valves is the only positive means of verifying closure because they are simple check valves that are not equipped with position indication.

Based on the impractica'lity of full-stroke exercising these valves I

quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the alternate testing proposal should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

)

4.5.4.2 Relief Request. The licensee has requested relief from exercising valves 1(2)B21-F024A, -F0248, -F024C, -F0240, main steam isolation valve accumulator supply checks, -F040C, -F0400, -F040E, -F040R,

-F040S, -F0400, and -F040V, automatic depressurization system supply I

checks, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to full-stroke exercise them during refueling outages.

1 4.5.4.2.1 Licensee's Basis for Requesting Relief--In order to prove the closure capability of the automatic depressurization system and the inboard main steam line nitrogen accumulator supply check valves, a pressure drop test is required to be performed.

This requires access to the drywell to install temporary pressure gauges to measure pressure decay in each accumulator. Normally, the drywell atmosphere is inerted with 4

nitrogen gas rendering it inaccessible by personnel at all times except during refueling outages.

Furthermore, each of the accumulators is monitored by pressure instrumentation which alarms in the main control room on lo.f pressure to alert operating personnel of abnormal conditions. This is considered to be an acceptable level of testing to ensure the operability of these valves, 1

44

ALTERNATE TEST:

Exercise during reactor refueling outage.

4.5.4.2.2 Evaluation--These valves cannot be exercised quarterly because they are located inside the primary containment and are inaccessible during power operation since the drywell is inerted with nitrogen gas. These small check valves are not equipped with actuators or position indication and are 7.ccessible only during shutdowns and only when the drywell is de-inerted. They cannot be exercised during each cold shutdown because the drywell is not routinely da-inerted each cold shutdown.

Based on the impracticality of full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, full-stroking these valves during refueling outages when the dryweil is de-inerted to allow a cess should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

l 4.6 Low Pressure Core Spray System 4.6.1 Category A/C Valves 4.6.1.1 Relief Receast. The licensee has requested relief from exercising valve 1(2)E21-F006, low pressure core spray injection testable check, in accordance with the requirements of Section XI, 1

Paragraphs IWV-3412 and -3522, and proposed to partial-stroke exercise this i

valve during cold shutdowns.

4.6.1.1.1 Licensee's Basis for Requestino Relief--This normally closed testa,ble check valve serves as the first isolation valve in the i

event of a system line break. Testing could be performed during power operation, howerver, a real pos*ibility exists that this valve may not properly reseat, rendering it incapable of performing its isolation function.

Since the drywell is inaccessible during power operation, the i

i 45

~

affected penetration would need to be isolated, causing the system to be unavailable for its emergency function.

The risk involved with the cycitng of this valve during power operation is much greater than the assurance of operability gained by quarterly testing. The valve will be exercised at cold shutdown when its isolation function is not required.

This exercisable check valve was originally designed and furnished by the manufacturer to verify operability by partially stroking the disk from the closed position. The operator design makes it incapable of closing the

. valve against flow or keeping it open against reverse flow and moves the disk from the fully closed position to 31% of full-stroke (25' of the 80' "free tilting" disk travel). Due to the design of the installed equipment, it is impractical tn test the valve to the full open position or inject flow into the vessel to full-stroke exercise the valve. A major modification to the valve and plant design would be required to full-stroke exercise this valve. Based on the manufacturer's experience, if the disk can be partially stroked by means of the test cperator, they have a high degree of confidence that the valve will fully open under design flow conditions.

(Reference - LSCS 'FSAR Question 212.103)

ALTERNATE TEST:

i Exercise during each cold shutdown by use of the test operator.

4.6.1.1 2 Evaluation--The design of the operator on this testable check valve is such that movement of the valve disk is mechanically limited to a partial-stroke exercise. Due to this feature, the only method available to utilize to full-stroke exercise the disk of this valve is to p&ss the required design basis accident flow rate through it and the on19 available flow path is into the reactor vessel. This flow path cannot be utilized during power operation because the low pressure core spray pump does not develop sufficient discharge pressure to overcome reactor pressure.

Performing this flow test during cold shutdowns could

4 I

delay plant startup due to the injection of lower quality water and the requirement to meet the Technical Specification chemistry limitations prior to startup.

Based on the impracticality of full-stroke exercising this valve i

quarterly and during cold shutdowns, the burden on the licensee if these.

t 3

j Code requirements were imposed, and the licensee's proposal t'o partial-stroke exercise this valve each cold shutdown, relief may be granted from the requirements of Section XI as requested. However, the licensee should investigate some alternate method or consider system modificaticns to allow full-stroke exercising this valve in accordance with the requirements of the Code as closely as possible.

4.7 Main Steam System 4.7.1 Category A Valves

)

i 4.7.1.1 Relief Request. The licensee has requested relief from fail-safe testing valves 1(2)B21-F022A, -F0228, -F022C, and -F0220, inboard main steam isolation valves, in accordance with the requirements of Section XI, Paragraph IW-3415, and proposed to fail-safe test these valves j

during those cold shutdowns when the drywell is de-inerted.

4.7.1.1.1 Licensee's Basis for Requesting Relief--Full-stroke 4

testing these valves during normal reactor operation requires isolating one of the four main steam lines.

Isolation of these linec results in primary system pressure spikes, reactor power fluctuations, and. increased flow in a

the unisolated-steam lines. This unstable operation can lead to a reactor scram and, as discussed in NUREG-0626, pressure transients resulting from j

full-stroke testing MSIVs increase the chances of actuating primary system 1

relief valves., It is proposed that only partial-stroke testing be performed during power operation and that valves be full-stroke and stroke a

timed during cold shutdowns. This partial-stroke exercising provides an i

acceptable means of verifying valve performance during plant operation without affecting safety margins. This request also contributes to the reduction of the relief valves challenge rate as recommended in NUREG-0626.

t I

47 j

1 I

I ALTERNATE TEST:

Part-stroke exercise quarterly and full-stroke exercise and stroke time during cold shutdowns. The fail-safe operation of these valves will be completed only at cold shutdowns during which the primary containment is de-inerted since access to the valves to perform this testing requires entry into the drywell.

4.7.1.1.2 Evaluation.

The Code allows these valves to be partial-stroke exercised quarterly and full-stroked during cold shutdowns.

The Code also allows the valves to be fail-safe tested during cold shutdowns if such testing is impractical quarterly, however, operation of these valves cannot be observed each cold shutdown as required by Paragraph IVV-3415 because they are located inside the drywell. The drywell atmosphere is required to be inerted with nitrogen gas during power operation and is not routinely de-inerted to allow safe access during each cold shutdown.

Based on the impracticality of observing fail-safe operation of these valves each cold shutdown and the burden on the licensee if this Code requirement were imposed, the alternate testing frequency of observing fail-safe operation during those cold shutdowns when the drywell is de-inerted and during refueling outages should demonstrate proper valve operability and, therefore, relief may be granted from the fail-safe o

testing frequency requirements of Section XI as requested.

4.7.2 Category B/C Valves 4.7.2.1 Relief Request. The licensee has requested relief from exercising valves 1(2)B21-F013C, -F0130, -F013E, -F013R, -F0135, -F0130, and -F013V, 'aut'omatic depressurization system safety relief valves, in accordance with the requirements of Section XI, Paragraph IWV-3410, and proposed to full-stroke exercise them during refueling outages.

4.7.2.1.1 Licensee's Basis for Requesting Relief--Vendor specifications for these A05 safety relief valves require steam pressure 48

==

4 behind the disk before cycling. Thus,'the plant must be in an operating or startup condition with the required steam pressure in the main steam lines. The Technical Specifications require these valves to be exercised

- at least once per refueling cycle. The Technical Specifications also

)

I require the reactor to be scrammed within 2 minutes if unable to close a stuck open valve. Considering the possibility and consequences of a stuck

~

open valve, they will be exercised at each refueling outage, l

ALTERNATE TEST:

l Perform an "in place" exercise at each refueling outage.

k 4.7 2.1.2 Evaluation--Operation of these valves during power operation should be minimized because each operation results in reactor pressure and power trantients that could result in a reactor trip. Also, failure of one of these valves in the open position-would result in rapid depressurization and cooldown of the reactor vessel and a reactor trip.

However, these valves must be exercised while the reactor is at power i

because reactor steam is the motive force and, therefore, they cannot be

[

t operated during cold shutdowns or refueling outages since. reactor steam is.

not available during those plant conditions. The license'e has not requested relief from measuring the stroke time of these valves, however, they cannot be stroke timed without the installation of special test and timing equipment because they are extremely fast acting, are locatrd inside primary containment, and are inaccessible during power iperation.

i 1

Based on the impracticality of full-stroke exercising and stroke.

timing these valves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, full-stroke j

exercising these valves, without stroke timing, at a refueling outace frequency (1,.e., entering or leaving a refueling outage) when :ome reactor steam is available, should be sufficient to demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency and stroke timing requirements of 3ection XI.

9 49 I

r-

_..,..,_,m m.~,,

,,,_m.

,_y_--..,-r_,-4

O e

4.7.3 Category C Valves 4.7.3.1 Relief Request. The licensee has requested relief from exercising the main steam relief valve discharge line vacuum breakers in accordanc6 with the requirements of Section XI, Paragraph IWV-3522, and

-proposed to manually full-stroke exercise them during refueling outages.

The valves are:

1(2)B21-F037Al 1(2)B21-F037G1 1(2)B21-F037V1 1(2)B21-F037A2 1(2)B21 F037G2 1(2)B21-F037V2 1(2)B21-F03781 1(2)B21-F037K1 1(2)B21-F037U1 1(2)B21-F03782 1(2)B21-F037X2 1(2)B21-F037U2 1(2)B21-F037C1 1(2)B21-F037L1 1(2)B21-F037H1 1(2)B21-F037C2 1(2)B21-F037L2 1(2)B21-F037H2 1(2)B21-F03701 1(2)B21-F037Pl.

1(2)B21-F037J1 1(2)B21-F03702 1(2)B21-F037P2 1(2)B21-F037J2 1(2)B21-F037El 1(2)B21-F037R1 1(2)B21-F037M1 1(2)B21-F037E2 1(2)B21-F037R2 1(2)B21-F037M2 1(2)B21-F037F1 1(2)B21-F03751 1(2)B21-F037N1 1(2)B21-F037F2 1(2)B21-F037S2' 1(2)B21-F037N2 4.7.3.1.1 Licensee's Basis for Requesting Relief--The vacuum breaker system allows MS?V downcomer pressure to equalize with drywell pressure as downcomer steam is condensed in the suppression pool. The 36 normally closed check valves (2 on each downcomer) which comprise this system are not equipped with an external means of actuation for exercising the valve.

Exercising these valves can be satisfactorily achieved only by manually pushing the valve disk to its open position with a small diameter rod. Access to the disk is gained from the intake port of the valve body.

The exercise test requires access to the drywell, which requires the drywell to be de-inerted, and removal of several sections of seismic mounted grating from each valve location because all the valves are installed below floor level.

1 50

The removal of the floor grating would hinder general area access on the 740' elevation and also creates a hazardous fall area for personnel who need drywell access to perform other drywell activities.

It is estimated that removal and replacement of the grating for all the vacuum breakers would require about 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In addition, the testing itself is very manpower intensive since any work under the grating requires full anti-contamination clothing and wet suit gear. The time required for the necessary radiation surveys and actual testing is approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The total time required to perform this testing is about 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> and this time would be added to the time that the unit must be in cold shutdown and de-inerted. Since our intent is always to minimize the turnaround time for return to power operation when forced to cold shutdown for repairs, this testing would cause an unacceptable delay of plant startup.

ALTERNATE TEST:

Adequate testing of this system would be achieved by esercising the valves during refueling outages as described above.

4.7.3.1.2 Evaluation--These check valves are located inside containment, are not equipped with actuators or position indication, and drywell access is required to manually exercise them. The drywell atmosphere is required to be inerted with nitrogen gas during power operation and 15 not routinely de-inerted to allow safe access during each cold shutdown. Additionally, removing the floor grating to provide valve access for testing and replacing the grating when testing is completed could delay reactor startup because the grating must be replaced prior to startup.

Based on the impracticality of manually full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the proposed alternate. testing of 51

manually full-stroke exercising these valves during refueling outages when the drywell is de-inerted to allow access should demonstrate proper valve

~

operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

4.8 Primary Containment Ventilation and purge System 4.8.1 Category C Valves 4.8.1.1 Relief Request. The licensee has requested relief from exercising valves 1(2)PC001A, 001B, 001C, and 0010, suppression pool to drywell vacuum breakers, in accordance with Sertion XI, Paragraph IWV-3522(b), and proposed to manually full-stroke exercise them monthly and to measure the opening force each refueling outage.

4.8.1.1.1 Licensee's Basis for Requesting Relief--The primary containment vacuum relief breakers allow a return flow path for noncondensable gas from the suppression chamber to the drywell. This system is designed to limit the upward loading on the drywell floor to prevent a loss of strue'tural integrity.

In addition, this system must be operable to prevent steam bypassing the suppression pool in case of an accident.

The use of the torque wrench method for verifying proper opening set points for these vacuum relief breakers was questioned by the NRC (0 pen Item - 373/81-28-07) because of the inconsistencies in the test data results during the preoperational testing (PT-VP-101). An acceptable alternative test method was mutually agreed upon to address this concern.

i Technical Specification 4.6.4.1 reflects this test method and requires a j

monthly full-stroke of the vacuum breakers and an opening force test every 18 months.,

ALTERNATE TEST:

Exercise these valves in accordance with Technical Specifications (4.6.4.1) as follows:

52

a.

Monthly, cycle each vacuum breaker through at least one complete j

cycle of full travel.

b.

During each refueling outage, verify the force required to open the vacuum breaker from the closed position, to be less than or equal to 0.5 psid.

4.8.1.1.2 Evaluation--These simple check valves are located outside containment and, due to valve design, the only method av&ilable to exercise them is use of a mechanical exerciser as proposed by the licensee. Manually exercising these valves monthly should be sufficient to assure freedom of movement of the disk because they are exposed to only air or nitrogen internally and neither is_a hostile environment.

The torque measurement performed during refueling outages should be repeatable because of the monthly exercising and should provide sufficiently accurate data to utilize in monitoring valve condition and operability.

Based on previous discussions between the licensee and the NRC staff and the staff's approval of the licensee's proposed alternate testing frequency, relief may be granted frorn the requirements of Section XI as requested.

4.9 Control Rod Drive System 4.9.1 Category B Valves 4.9.1.1 Relief Request. The licensee has requested relief from exercising valves 1(2)C11-0001-126 and -127, control rod scram inlet and outlet, in accordance with the requirements of Section XI, Paragraphs IWV-3400 and -3415, and proposed to tull-stroke exercise 10% of them every 120 days and all )f them after each refueling outage.

4.9.1.1.1 Licensee's Basis for Requesting Relief--There are 185 of each of the valves listed, i.e., one for each of the 185 control rod '

1 drives. The proper operation of each of these valves is demonstrated 53

during scra; testing.

During scram testing each drive's scram insertion time is measured.

The Technical Specifications limit individual scram insertion times te specific values.

valves are functioning properly.

This insures that the above mentioned

~

ALTERNATE TEST:

Individual scram insertion tests will be performed per the Teconical 9

Specification frequency.

The Technical Specifications require these tests be performed following core alterations, after a reactor shutdown of greater than 120 days, for individual control rods after maintenance or modification to the control rod which would affect the contr time, and for at least 10% of the control rods, on a rotating basi least once per 120 days of operation.

s, at 4.9.1.1.2 Eyaluation--These valves cannot be exercised without causing the associated control rod to scram and the valves must operate properly in order that the associated control red meets the scram inse t

time limits defined in the Technical Specifications r on The alternate exercising frequency required by the Technical Specifications has been previously reviewed and approved by the NRC staff to reduce the wear control rod drive mechanisms and to reduce the number of rapid of the transients to which the reactor core is exposed.

However, since these valves are power operated, they must be stroke timed when exercise relief from stroke timing should be requested.

The licetsee has failed to provide a discussion of any difficulties encountered while attempti stroke time these valves.

ng to These are very rapidly acting valves that operate in pairs and cannot be stroke timed without the installation af special timing and recording equipment.

Also, the scram testing performance with the individual control red test switches duplicates t fail safe test by removing power from the valve solenoids e

i Based on the impracticality of complying with the exercising 1

requirements of Section XI and the burden on the licensee if th'ose requirements were imposed, relief may be granted from the exerci i

1 54 i

frequency requirements of Section XI to allow exercising these valves in acccrdance with the exercising frequency required by the Technical Specifications.

However, the licensee has not demonstrated the impracticality of measuring the stroke tiree of these valves, therefore, they should b, required to measure the stroke time of these valves when exercised or explain why stroke timing cannot be accomplished in the form of a relief request that must subsequently be reviewed and approved by the NRC staff before implementation.

F 4.9.1.2 ReliefRhouest. The licensee has requested relief frem measuring the strcke time of valves 1(2)C11-F380, -F3S8, control rod drive l

scram discharge instrument volume vents, -F381, and -F389, control rod drive scram discharge instrument volume drains, in accordance with the requirements of Section XI, paragraph IWV-3413(b), and proposed to measure l

stroke time of the greup of valves during refueling outages.

4.9.1.2.1 Licensee's Basis for Requesting Relief--The system is i

designed such that the test circuit bleeds air from these air operated valves very slowly, but not necessarily at the same rate each test.

l Consequently, time repeatability is poor and a degraded condition would not be recognizable. However, during reactor shutdown for refueling the closure time for these valves is obtained during an actual scram test.

l ALTERNATE TEsi:

Full-strok2 exercise quarterly.

Stroke time these valves as a group during each refueling outage by measuring the time elapsed from scram initiation to the closure of both valves.

4.9.1.2.2 Evaluation--The design of the test circuit for these l.

valvesisshch,thattheyoperatemuchmoreslowlywhenrespondingtoatest control signal than when responding to a normal (reactor scram) signal.

Stecke time measurements taken while testing these valves would not be representative of valve condition and would not contritute meaningful data to utilize in monitoring valve degradation. The only appropriate time to f

l 55 i

~_.

measure actual stroke time of these velves is during refueling outages because the system realignment required to allow the scram test without damage to the control rod drive mechanisms is a lengthy prncedurs and could delay reactor startup if done during cold shutdowns.

However, the licensee's proposed alternate testing does not meet the requirements of Section XI because a limiting value of full-stroke time has been assigned to the group of valves instead of individual valves and degradation of each valve may not be monitored and corrective action may not be taken when required by the Code.

4 The licensee has not demonstrated the impracticality of measuring the stroke time of these valves individually, therefore, the licensee should be required to rceasure these stroke times in accordance with the requirements

('Section XI on a refueling outage frequency and relief should not be granted as requested. The licensee has demonstrated the impracticality of full-stroke exercising these valves utilizing a normal (scram) signal during any plant conditions other than refueling outages, therefore, relief should be granted from the exercising frequency requirements of Section XI as requested.

4.9.2 Category C Valves 4.9.2.1 Relief Request. The licensee has requested relief from exercising valve'1(2)C11-0001-114, control rod scram discharge header check, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to full-stroke it during control rod scram testing.

4.9.2.1.1 Licensee's Basis for Requesting Relief--There are 185 of each of the valves li ued, i.e., one for each of the 185 control rod drives. The proper operation of each of these valves is demonstrated during scram testing. During scram testing each drive's scram insertion time is measured. The Technical Specifications limit individual scram insertion times to specific values. This insures that the above mentioned valves are functioning properly.

56

ALTERNATE TEST:

Individual scram insertion tests will be performed per the Technical Specification frequency. The Technical Specificetions require these tests I

be performed following core alterations, after a reactor shutdown of greater than 120 days, for individual control rods after maintenance or modification to the control rod which would affect the control rod scram time, and for at least 10% of the control rods, on a rotating basis, at least once per 120 days of operation.

4.9.2.1.2 Evaluation--The 114 valve, which is located in the scram discharge line, must open to allow the control rod to scram and proper operation is verified during control rod scram testing if the associated control rod meets the scram insertion time limits defined in the Technical Specifications. Also, the proposed alternate exercising frequency is acceptable as previously s+ tad in Item 4.9.1.1.

Based on the impracticality of full-stroke exercising these valves quarter.ly and during cold shutdowns and considering the burden on the licensee if these Code. requirements were imposed and since the proposed alternate testing of verifying proper control rod scram insertion times i

demonstrates proper valve operability, relief may be granted from the exercising frequency requirements of Section XI as requested.

4.10 Residual Heat Removal System i

4.10.1 Cateoory A/C Valves 4.10.1.1 Relief Request. The licensee has requested relief from exercising valves 1(2)E12-F041A, -F041B, and -F041C, residual heat removal injection tastable checks, in accordance with the requirements of Section XI, Par'agraphs IWV-3412 and -3522, and proposed to partial-stroke 1

exercise these valves during cold shutdowns.

4.10.1.1.1 Licensee's Basis for Requestino Relief--These normally closed testable check valves serve as the first isolation valver 57

in the event of a system line break. Testing could be performed during power operation, however, a real possibility exists that these valves may

(

not properly reseat, rendering them incapable of performing their isolation function. Since the drywell is ina'ccessible during power operation, the

[

affected penetration would need to be isciated, causing the system to be unavailable for its emergency function. The risk involved with the cycling of these valves during power operation is much greater than the assurance of operability gained by quarterly testing. The valves will be exercised at cold shutdown when their isolation function is not required.

Tnese exercisable check valves were originally designed and furnished by the manufacturer to verify operability by partially stroking the disk from the closed position. The operators' design makes it incapable of closing the valve against flow or keeping it open against reverse flow and moves the disk from the fully closed position to 31% of full stroke (25' ef the 80' "free tilting" disc travel). Due to the design of the installed f

equipment, it is impractical to test the valves to the full open position j

or inject flow into the vessel to full-stroke exercise the valve. A major modification to the valve and plant design would be required to full-stroke exercise these valves. Based on the manufacturer's experience, if the disk can be partially stroked by means of the test operator, they have a high degree of confidence that the valve will fully open under design flow conditions.

l (Reference - LSCS - FSAR Question 212.103)

ALTERNATE TEST:

Exercise during each cold shutdown by use of th. test operator.

4.10.1.1.2 Evaluation--The design of the operator on these testable chgek valves is such that movement of the valve disk is mechanically limited to a partial-stroke exercise. Due to this feature, i

the only method ava'11able to utilize to full-stroke exercise the disk of these valves is to pass the required destgn basis accident flow rate 1

SS

)

o through them and the only available flow path is,into the reactor vessel.

This flow path cannot be utilized during power operation because the residual heat removal pumps do not develop sufficient discharge pressure to overcome reactor pressure. Performing this flow test during cold shutdowns i

could delay plant startup due to the injection of lower quality water and the requirements to meet the Technical Specification chemistry limitations prior to star. tup.

I Based on the impracticality of full-stroke exercising these valves agarter?y and during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposal to partial-stroke exercise these valves each cold shutdewn, relief may be granted from the requirements of Section XI as requested. However, the licensee should investigate some alternate method or consider system modifications to allow full-stroke exercising these valves in accordance with the requirements of Section XI as closely as possible.

4.11 oeactor Cnre Isolation Cooling System j

4.11.1 Category A/C Valves 4.11.1.1 Relief Request. The licensee has requested relief from exercising valve 1(2)E51-F066, reactor core isolation cooling inboard testable check, in accordance with the requirements of Section XI, Paragraphs IVV-3412 and -3522, and proposed to partial-stroke exercise this valve during cold shutdowns.

e i

4.11.1.1.1 Licensee's Basis for Requesting Relief--This normally closed testable chefk valve serves as the first isolation valve in the event of a systea line break. Testing could be performed during power operation, however, a real possibility exists that this valve may not properly res' eat, rendering it incapable of performing its isolation j

function. Since the drywell is inaccessible during power operation, the

}

affected penetration would need to be isolated, causing the system to be unavaliable for its emergency function. The risk involved with the cycling 4

59

of this valve during power operation is much greater than tne assurance of operability gained by quarterly testing.

The valve will be exercised at cold shutdown when 'ts isolation function is not required.

This exercisable check valve was originally designed and furnished by the manufacturer to verify operability by partially stroking the disk from the closed position.

The operator design make 't incapable of closing the valve against flow or keeping it open against reverse flow and moves the disk from the fully closed position to 31% of fuli-stroke (25 of the 80 "free tilting" disc travel). Due to the design of the installed equipment, it is ir actical to test the valve to the full open position or infect f1;

.:e vessel to full-stroke exercise the valve. A major medit

. icu to the valve and plant design would be required to full-stroke exercise this valve. Based on the manufacturer's experience, if the disk can be partially stroked by means of the test operator, they have a high degree of confidence that the valve will f ally open under design flow conditions.

(Reference - LSCS - FSAR Question 212.103)

ALTERNATE TEST:

i i

Exercise during each cold shutdown by use of the test operator.

4.11.1.1.2 Evaluation--The design of the operator on this testable check valve is such that mo.ement of the valve disk is mechanically limited to a partial-stroke exercise. Due to this feature, the only method available to utilize to full-stroke exercise the disk of this valve is to pass the required design basis accident flow rate through it and the only available flow path is into the reactor vessel. This test methodisun[ des,frableduringpoweroperationbecausetheinjectionnozzle would be subjected to unnecessary thermal transients.

This flow test can'ot be performed during cold shutdowns because reac. tor steam is not available to power the turbine c.elven pump.

60

Based on the impract'cality of full-stroke exercising this valve quarterly and during cold shutdowns, the burden on the licensee if these Code Requirements were imposed, and the licensee's proposal to partial-stroke exercise this valve each cold shutdown, relief may be granted fram the requirements of Section XI as requested. However, the licensee >.1ould investigate some alternate method or consider system modifications to allow full-stroke exercising this valve in accordance with the requirements of the Code as closely as possible.

4.11.1.2 Relief Request. The licensee has requested relief from exert.ising talve 1(2)E51-F065, reactor core isolation coolin:. outboard testable check, in accordance with the requirements of Sectiot. XI, Paragraphs IWV-3412 and -3522, and proposed to partial-stroke exercise this valve durirg cold shutdowns.

4.11.1.2.1 Licensee's Basis for Requesting Relief--Due to normal leakage through RCIC inboard check valve 1(2)E51-F066, it is poss',ble during reactor power operation that a pressure approaching 1000 psig may exist on the inboard side of testable check valve 1(2)E51-F065.

Exercising valva F065 using the test operator requires reduciag the different'al pressure across the valve disk.

Inadvertent opening or excessive leakage through F013, RCIC injection isolation, would result in a water hammer of the RCIC piping and/or damage to the low pressure piping on the suction side of the RCIC pump which is designed for a maximum pressure of 100 psig. Relief is requested to exercise RCIC outboard check valve 1(2)E51-F065 at cold shutdown when reactur pressure is substantially reduced.

This exercisable check valve was originally designed and furnished by the manufacturer to verify operability by partially stroking the disk from the closed position.

Tha operator design makes it incapable of closing the valva against flow or keeping it coen against reverse flow and moves '.he disk from the fully closed position to 31% of full-stroke (25* of the 30*

"free tiltinn" disc tra /el). Due to the design of the installed equipment, j

it is impractical to test the valve to the full open position er inje:t 61 i

flow into the vessel to full-stroke exercise the valve. A major modification to the valve and plant design would be required to full-stroke exercise this valve. Based on th? manufacturer's experience, if the disk can be partially stroked by means of the test operator, they have a high degree of confidence that the valve will fully open under design flow conditions.

(Reference - LSCS-FSAR Question 212.103)

ALTERNATE TEST:

Exercise during each cold shutdown by use of the test operator.

4.11.1.2.2 Evaluation--The design of the operator on this testable check valve is such that movement of the valve disk is mechanically limited to a partial-stroke exercise.

Due to this feature, the only method available to utilize to full-stroke exercise the disk of this valve is to pass the required design basis accident flow rate through it and the only available flow path is into the reactor vessel.

This test method is undesirable during power operation because the injection nozzle would be subjected to unnecessary thermal transients. This finw test cannot be performed during cold shutdowns because reactor r> 3am is not available to power the turbine driven pump. Additionally, the possibility does 'xist to overpressurize the pump suction piping ir the inboard testable check were leaking and the injection valve were opened becaase there are no other valves installed in the discharga piping of the centrifugal pump.

Based on the 'mpracticality of full stroke exercising this valve quarterly and during cold shutdowns, the burden on the licensee if these i

Code requirements were imposed, and the licensee's proposal to cartial-stroke exercise thi.s valve each cold shutdown, relief may be granted from the requirements of Section XI as requested.

However, the licensee should investigate some alternate method or consider system l

l l

62 1

~

Modif.ications to allow full-stroke exercising this valve in accordance with the requirements of the Code as closely as-possible.

4.11.1.3 Relief Request. The licensee has +vquested relief from exercising valves 1(2)E51-F028, reactor core isolation cooling barometric condenser vacuum pump suppression pool discharge check, and -F040, reactor core < isolation cooling turbine exhaust check, in accordance with the' requirements of Section XI, Paragraphs IWV-3410 and -3522, and proposed to stroke them open during pump tests and to verify closure during refueling outages.

4.11.1.3.1 Licensee's Basis for Requesting Relief--These normally closed check valves are required to open to allow the RCIC system to perform its function and are verified to open each quarter during the RCIC pump operability rur. These valves, however, also perform a containment isolation function and are required to close. A local leak test has to be performed in order to demonstrate their closure capability.

This is not possiole during pow 0r operation because shutting the downstream isolation valves renders the system inoperable which is highly undesirable for safe plant operation. During cold shutdowns other than for refueling, performing the required leak tests is not practical because the large resource commitment and planning required would cause an unacceptable delay in return to pcwer operation. Both F028 and F040 have a redandant back-up motor operated containment isolation valve which can be shut from the control room if needed. The F069 and F068 are included in the IST program and are exercised and timed quarterly and are leak rate tested togeth9r with F028 and F040, respectively. Closure testing these valves during refueling outages is adequate to demonstrate their closure capability.

ALTERNATE TEST:

The closure capability of these check valves will be demonstrated by means of a local leak rate test performed during eacn refueling outage.

Theopeningcapabilit[vofthesevalveswillbedemonstratedeachquarter during the pump operability run.

63

4.11.1.3.2 Evaluation--These valves can be verified to open pre?erly during the quarterly pump tests by observing proper level control in the barometric condenser and normal turbine exhaust pressure. These valves cannot be exercised open during cold shutdowns because no steam is available to drive the RCIC tt -bine. However, the only method available to verify closure is ieak rate testing because these are simple check valves that are not equipped with position indication.

Leak rate testing during power operation is impractical because it requires that the system be removed from service and, if performed during cold shutdowns, could delay reactor startup.

Based on the impracticality of full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the proposed alternate testing of exercising these valves open during pump tests and of verifying closure during the performance of leak rate testing at refueling outages should be sufficient to demon:trate valve operability and, therefore, relief may be granted from the exercising requirements of Section XI as requested.

4.11.2 Category C Vaives 4.11.2.1 Relief Request. The licensee has requested relief from exercising va!ve 1(2)E51-F030, reactor core isolation cooling suppression pool suction check, in accordance with the requirements of Section XI, paragraph IWV-35;.0, and proposed to partial-stroke exercise it quarterly and to full-stroke exercise it during refueling outages.

4.11.2.1.1 Licensee's Basis for Requesting Relief--The RCIC system is demonstrated operable each quarter by taking suction from the cycled condensate storage tank (CST) and discharging it back tnrough the full flow test line. The water in the CST is reactor grade water, however, this is notinedessarily true of the suppression pool water. Valve F030 cannot be full-stroke exercised unless the full flow test valve interlocks i

are temporirily jumpered out (defeated) and suction is taken directly from the suppression pool and discharged back through the full flow test line to the CST. Since the chemistry of the suppression pool cannot be adequately proven, the possibility exists of severely degrading the water quality of 64 i

about 300,000 gallons of reactor grade water in the CST.

It would take 2-3 days to clean up the CST and would use up a significan' amount of resin capacity resulting in significant. cost for resin replacement and disposal.

This degradation of water quality would likely cause acceptable industry standards for the CST and reactor chemistry to be exceeded. This would also cause many of the units systems, including reactor water systems, to become contaminated with this low quality water which in turn, could have detrimental affects on the reactor heat transfer surfar.es.

The full-stroke exercise of the F030 valve using the above configuration has the least amount of impact on plant operation when performed during startup after a refueling outage when suppression pool water quality has been cleaned up and is at its highest quality.

ALTERNATE TEST:

Perform a full-stroke exercise during the RCIC alternate flow path test at each refueling outage and partial-stroke the valve each quarter.

The partial opening of F030 is confirmed by the sustenance of suction pressure at the RCIC pump.

4.11.2.1.2 Evaluation--Due to system design, reactor core isolation cooling system flow cannot be utilized to full-stroke exercise this valve during power operation or cold shutdown. The system suction must be aligned to the suppression pooi to full-stroke exercise this valve and would result in the introduction of relatively low quality water into the condensate storage tank and, from there, into the reactor vessel and could force unit shutdown due to the inability to maintain reactor coolant chemistry specifications. Also, following this test, considerable effort is required to reestablish water quality conditions in the condensate storage system. This valve cannot be exercised during cold shutdowns because readtor steam is not available to power the turbine driven pump.

The flow path used to partial-stroke exercise this valve quarterly is from the suppression pool through the pump minimum flow line returning to 65

o

]

the suppression pool and a relatively small volume of water is degraded which can be easily flushed from the system and processed.

Compliance with the Code required testing frequency would be burdensome because this could result in a forced plant shutdown quarterly.

Based on the impracticality of full-stroke exercising this valve quarteriy and the licensee's proposed alternate testing of partial-stroke exercising tnis valve quarterly and full-stroke exercising it during refueling outages, relief may be granted from the requirements of Section XI as requested.

4.12 Reactor Recirculation System 4.12.1 Category A/C Valves 4.12.1.1 Relief Request. The licer.see has requested relief from exercising valves 1(2)S33-F011A, -F013B, reactor recirculation pump inboard seal water supply checks, -F017A, and -F0178, reactor recirculation pump outboard seal water supply checks, in accordance with.the requirements of Section XI, Paragraph IWV-3520, and proposed to verify closure (their safety position) during leak testing each refueling outage.

4.12.1.1.1 Licensee's Basis for Requesting Relief--These valves are in the reactor recirculation pump seal purge lines. The mechanical seals are kept clean and cool by a seal purge. The seal purge provides a continuous flow of clean, cool water from the control rod drive system.

It is highly desirable to maintain this flow at all times.

If +,he flow is interrupted, a backflow of water may carry foreign material into the seal which could result in rapid seal wear. The seal purgt line check valves are normally open during plant operation to allow cooling flow to the reactor recirculation pump seals.

During plant shutdown conditions, this flowpath is also maintained in operation for the same reasons. A leak rate test must be performed in order to verify the closure of these normally open check valves. This test is not possible during power operation because a flow of water is passing through the lines. These v.alves cannot 4

66

.~.

E be tested during cold shutdown due to the need to keep this flowpath in operation which precludes the ability of performing leakage rate testing.

This testing requires a large resource commitment which is not available during normally short cold shutdowns and involves significant setup time.

Performing these tests also involves additional radiation exposure.

These valves can be exercised only during refueling outages when the reactor i

recirculation pumps are shutdown and seal purge flow is not needed. This is the only practical time to perform this test without straining resources needed to return the unit to service.

ALTERNATE TEST:

The safety function of these check valves is to close to isolate the seal purge line. The leakage rate test during refueling outages proves the cicsure capability of these valves.

Flow during power operation demonstrates the opening capability.

4.12.1.1.2 Evaluation--These valves cannot be exercised closed during power operation because the loss of seal water flow could result in reactor recirculation pump seal failure or greatly reduced seal life.

These valves cannot be exercised during cold shutdowns because one of the reactor recirculation pumps is usually kept running and must be supplied with seal water. Additionally, these valves are not equipped with position indication and some of the required test connections are located inside 5

containment and may be inaccessible because the drywell is not routinely de-inerted each colc shutdown.

Based on the impracticality of full-stroke exercising these valves quarterly and during cold shutdowns and the burden on the licensee if these Code requirements were imposed, the alternate testing proposed should demonstrate proper valve operability and, therefore, relief may be granted from the exdecising requirements of Section XI as requested.

67

4.13 Standby Liquid Control System 4.13.1 Category A/C Valves 4.13.1.1 Relief Request. The licensee has requestei relief from exercising valve 1(2)C41-F007, standby liquid control inboard injection check, in accordance with Section XI, Paragraphs IWV-3410 and -3520, and proposed to full-stroke exercise it during refueling outages.

4.13.1.1.1 Licensee's Basis for Requesting Relief--This valve cannot be exercised during reactor operation nor during cold shutdown. To exercise this valve open, the system must inject into the vessel. System injection requires detonation and actuation of the explosive valves.

Subsequent replacement of the explosive valves would make the system inoperable, forcing a unit shutdown or delay of startup.

ALTERNATE TEST:

Exercise during reactor refueling.

4.13.1.1.2 Evaluation--This valve cannot be axercised during power operation because the only method available to exercise it open is to utilize system flow which would result in injecting boron solution into the reactor vessel which, in turn, would result in a reactor shutdown. The standby liquid control system t.annot be removed from service for flushing during power operation due to Technical Specification requirements. This valve cannot be exercised during cold shutdewn becauss extensive flushing is required to remove all traces of the boron solution to prevent its entry into the reactor coolant system. Additionally, one of the explosive valves must be removed or fired to provide a flow path.

Based o,n the impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, the alternate testing of full-stroke exercising this valve during refueling outages should demonstrate proper valve operability and, therefore, 68

relief may be granted from tha exercising frequency requirements of Section XI as requested.

4.13.2 Category B Valves 4.13.2.1 Relief Request. The licensee has requested relief from exercising valves 1(2)C41-F001A and -F0018, standby liquid control pump suctions, in accordance with the requirements of Section XI, Paragraph IWV-3410, and proposed to full-stroke exercise them during refueling outages.

4.13.2.1.1 Licensee's Basis for Requesting Relief--During the testing of these valves, the system is aligned so that a greater pressure exists on the downstream side of the F001 valves than on the upstream side. Opening the valves allows unborated water to backflow into the solution tank causing dilution of the boron concentration required by Technical Specifications. Any introduction of water into the solution tank would require sampling to verify proper concentration which involves a considerable amount of time in the preparation and analysis of the sample.

Should the solution tank be found out of specification, a plant shutdown would be required or plant startup delayed while adjustments to the solution and subsequent resample and analysis are being performed.

It is requested that the testing frequency for these valves be every refueling

)

outaga.

j l

ALTERNATE TEST:

Perform a full-stroke exercise and strote time during reactor refueling.

1 4.13.2.1.2 Evaluation--The system piping between each of these valves and the associated pump is not heat traced, therefore, a clean water head tank is installed to exert a slightly higher pressure on this section of piping to prevent entry of the boron solution while exercising the 69

valves.

If the boron solution were allowed to flow into the untraced piping, it could cool and solidify and could block the pump suction. Due to the relative elevation of the head tank, clean water would flow backwards through these pump suction valves, when opened, and into the standby liquid control' boron solution storage tank diluting the solution in the tank. The concentration of the solution is very rigidly controlled by the plant Technical Specifications, i.e., the solution r.ust be analyzed following any activity that could affect the boron concentration and must be within the limitations both prior to reactor startup-and during power operation. Technical Specifications require that the standby liquid control system be declared inoperable anytime the solution concentration is found to be out of specifications and this requirement could force a unit shutdown or delay reactor startup while the tank volume is returned to the proper boron concentration.

Based on the impracticality of comolying with the Code requirements and the burden on the licensee if those requirements were imposed, the-alternate testing of full-stroke exercising and stroke timing these valves during refueling outages when the standby liquid control system can be removed from service should demonstrate proper valve operability and, therefore', relief should be granted from the frequency requirements'of Section XI as requested.

i 4.13.3 Category C Valves 4.13.3.1 Relief Request. The licensee has requested relief from exercising valve 1(2)C41-F006, standby liquid control outboard injection check, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to full-stroke exercise it during refueling outages.

4.'13.' 3.1.1 Licensee's Basis for Requesting Relief--This valve cannot be exercised during reactor operation nor during cold shutdown. To exercise this valve open, the system must inject into the vessel.

System 70 4

injection requires detonation and actuation of the-explosive valves.

Subsequent replacemant of the explosive valves would make the system inoperable, forcing a unit shutdowr, or delay of startup.

ALTERNATE TEST:

)

Exercise during reactor refueling.

I 4.13.3.1.2 Evaluation--This valve cannot be exercised during power operation because the only method available to exercise it open is to utilize system flow which would result in injecting boron solution into the j

reactor vessel which, in curn, would result in a reactor shutdown. The standby liquid control system cannot be removed from service for flushing during power operation due to Technical Specification requirements. This valve cannot be exercised during cold shutdown because extensive flushing is required to removal all traces of the boron solution to prevent its ent y into the reactor coolant system. Additionally, one of the explosive valves must be emoved or fired to provide a flow path.

Based on the impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, the alternate testing of full-stroke exercising this valve curing refueling outages should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Section XI as requested.

4.14 Primary Contairment Ventilation System 4."4.1 Category A Valves 4.14.1.1 Relief Request.

The licer.see has requested relief from exercising valv'es 1(2)VP063A, 063B, 11;A, 1138, containment chilled water supply, 053A, 053B, 214A, and 1148, containment chilled water return, in 71

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.e

accordance with the requirements of Section XI, Paragraph IWV-3410, and proposed to full-stroke exercise and stroke time them during refueling outages.

4 14.1.1.1 Licensee's Basis for Requesting Relief--Closing any one of these isolation valves would prevent chilled water from reaching the primary containment cooling units. Operation of this system is essential to drywell equipment operability during power operation and is also necessary during cold shutdowns to maintain acceptable conditions in the drywell for maintenance personnel.

In cold shutdown the reactor system is normally maintained at so-e temperature below 200 F, but as warm as possible, except during refuel outages. Inis practice is consistent with minimal time expenditure for turnaround and return to power operation from an ur, scheduled cola shutdown. This condition will add heat to the drywell at a rate which will make the drywell inaccessible to personnel if the drywell coolers are not available.

This testing will require either additional reactor system cooldown or some amount of delay in completing the repair that necessitated the unit shutdown with the ultimate consequence of delaying the timely return to power operation. These valves should be-exercised only during refueling outages when the heat input to the drywell atmosphere is substantially reduced and when the probability of delaying a unit startup is minimal.

ALTERNATE TEST:

Perform a full-stroke exercise during refueling outages.

4.14.1.1.2 Evaluation--Failure of any one of thest valves in the closed posit [ ion while being test 2d would result in loss of one half of the containment cooling capacity. During power operation, the remaining cooling capacity may not be sufficient to maintain the containment air temperature below the limits specified in the Technical Specifications and 72

..,._-,.~,

plant shutdown would be required. Valve failure during cold shutdown could limit containment accessiblity to maintenance personnel due to high temperatures and could delay reactor startup.

Based on the impracticality of complying with the Code requirements and the burden on the licensee if those requirements were imposed, the alternate testing of full-stroke exercising and stiske timing these valves during refueling outages when the containment is cooled sufficiently to allow removing the containment coolers from service should demonstrate proper valve operability and, therefore, relief may be granted from the exercising frequency requirements of Sectier, XI as requested.

t 8

73

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1 i

e 9

9 9

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e 74

APPENDIX A VALVES TESTED OURING COLD SHUTOOWNS l

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APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation. These valves are specifi ally identified by the owner in accordance with Paragraphs IWV-3412 and -3522, and are full-stroke exercised during cold shutdowns and refueling outages. The reviewer has evaluated all valves in this Appendix and agrees with the licensee that testing'these valves during power operation is not practical due to the valve type, location, or system design. These valves either cannot or should not be exercised during power operation. These valves are listed belnw and grouped according to the system in which they are located.

1.

FEEDWATER SYSTEM 1.1 Category A Valves It is impractical to full-stroke exercise valves 1(2)821-F065A and

-F065B, reactor feedwater isolations, quarterly because the feedwater system is needed to maintain primary coolant inventory and would deprive the flow of feedwater *o the vessel, thus putting the plant in a less safe mode of operation (i.e., could result in a reacter trip). These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

2.

HIGH PRESSURE CORE SPRAY SYSTEM 2.1 Category A Valves Valve l'(2)E22-F004, high pressure core spray injection, cannot be exercised during power operation because if it was opened at rated pressure, and the ir, board testable check valve was to fail or leak, the low pressure piping could be subjected to reactor pretsure. This ):ould lift the low pressure piping relief valve and pre,'ca a flow path for react <.r water outside the primary system. Depending on the amount of check salve 77

leakage, the potential exists to severely overpressurize the low pressure piping.

The exercising of this valve during operation provides only single valve protection for the low pressure piping during the duration of the test, thus putting the plant in a less safe condition.

This valve will be full-stroke exercised and stroke timed during cold shutdowns and refue out ges.

It is impractical to full-stroke exercise valve 1(2)E22-F023, high pressure core spray suppression pool full flow test, during power operation.

This valve is partial-stroke tested quarterly with the pump operability run.

F,ill-stroke cycling this valve with the pump in operation is not possible since pump damage will occur due to pump runout.

Cycling the valve without the pump in operation will result in the drainirg of the associated piping systt m which renders the system inoperable for hours until it is refilled ant' vented.

The partial-stroke during the pump run is to the pump full flow position and, therefore, insures the valve can perform as needed during operation.

Timing the valve from this midposition is not repeatable.

This valve will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages when the consequences the required safety system unavailability has less impact on plant operations.

3.

LOW PRESSURE CORE SPRAY SYSTEM 3.1 Category A Valves Valve 1(2)E21-F005, low pressure core spray injection, cannot be exe cised during power operation because it is electrically interlecked shut at reactor normal operating pressure to protect the low pressure piping outside the drywell.

This valve will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

It is impractical to full stroke exercise valve 1(2)E21-F012, low pressure core spray suppression pool full flow test, during power operation.

This valve is partial-stroke tested quarterly with the pump operability run.

Fcil stroke cycling this valve with the pump in operation 78

is not possibla since pump damage will occur due to pump runout. Cycling the valve without the pump in operation will result in the draining of the 1

associated piping system which renders the system inoperable for hours until it is refilled and vented. The partial-stroke during the pump run is to the pump full flow position and, therefore, insures the valve can perform as needed during operation. Timing the valve from this midposition is not repeatable. This valve will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages when the consequences of the required safety system unavailability has less impact on plant operations.

~ i 4.

MAIN STEAM SYSTEM 4.1 Category A Valves It is impractical to full-stroke exercise valves 1(2)B21-F002A,

-F022B, -F022C, -F022D, inboard main steam isolation valves, -F028A, 0F0288, -F028C, and -F0280, outboard main steam isolation valves, during power operation because it requires isolating one of the four main steam l

lines.. Isolation of these lines. results in primary system pressure spikes, reactor power fluctuations, and increased flow in the unisolated steam lines. This unstable operation can lead to a reactor scram, and, as discussed in NUREG-0626, pressore transfents resulting from full-stroke testing MSIVs increase the chances of actuating primary system relief valves.

It is proposed that only partial-stroke testing be performed during power operation and that the valve be full-stroked and stroke timed during cold shutdowns and refueling outages. This partial-stroke exercising provides an accaptable means of verifying valve perforeance during plant operation without affecting safety margins.

This request clso contributes to the reduction of the relief valve challenge rate as recommended in,NUREG-0626.

ALTERNATE TEST:

Part-stroke exercise quarterly and perform a full-stroke exercise and stroke time during cold shutdown. The fail-safe operation of these valves will also be checked during cold shutdown since this is done co:ncident 79

will full-stroke exercising. The fail-safe testing of valves 1(2)B21-F022A, B, C, and D, however, will be completed only at cold shutdowns in which the primary containment is de-inerted since access to the valvos to perform this testing requires entry into the drywell.

(See Item 4.7.1.1).

Valves 1(2)E32-F001A, -F001E, -F001J, and -F0010, main steam isolation valve leakage control bleed valves, cannot be exercised during-normal operation because they are designed to operate when the main steam line pressure is naar atmospheric. Testing of these valves at normal steam line pressure has the potential for discharging live steam into the reactor building atmosphere. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

4.2 Category B Valves Valves 1(2)E32-F002A, -F002E, -F002J, -F002N, main steam isolation valve leakage control bleed valves, -F003A, -F003E, -F003J, -F003N, main steam isolation valve leakage control loop bypass valves, -F006, -F007,

-POO8, and -F009, main steam isolation valve leakage control bleed valves, cannot be exercised during normal operation because they are designed to operate when the main steam line pressure is near atmospheric. Testing of these valves at normal steam line pressure has the potential for discharging live steam into the reactor building atmosphere. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

5.

RESIDUAL HEAT REMOVAL SYSTEM 4

5.1 Category A/C Valves Valves '1(2)E12-F050A and -F0508, shutdown cooling return testable checks, cann'ot be exercised during power operation because during reactor power cperation a differential pressure of appro)imately 1000 psi may exist across these testable check valves.

The check valves are equipped with test operators, however, the operators are not able to function with such a 80

high differential pressure across the valve.

The valves will be full-stroke exercised against a reduced reactor pressure during cold shutdowns and refueling outages.

5.2 Category A Valves The following list of valves cannot be exercised during power operation because they are electrically interlocked shut at normal reactor operating pressure to protect the low pressure piping outside the drywell.

These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

1(2)E12-F008 - Shutdown cooling outboard isolation 1(2)E12-F009 - Shutdown cooling inboard isolation 1(2)E12-F042A - Low pressure coolant injection isolation 1(2)E12-F0428 - Low pressure coolant injection isolation 1(2)512-F042C-Lowpressurecoolantinjectionisolation 1(2)E12-F053A - Shutdown cooling return isolation 1(2)E12-F0538 - Shutdown cooling return isolation 1(2)E12-F023 - Reactor head spray isolation 1(2)E12-F099A - Shutdown cooling return testable check bypass 1(2)E12-F0998 - Shutdown cooling return testable check bypass 0

81

6 It is impractical to full-stroke exercise valves 1(2)E12-F024A,

-F0248, and -F021, residual heat removal loop A, B, and C full flow test, during power operation. These valves are partial-stroke tested quarterly with the pump operability run.

Full-stroke cycling these valves with the pump in operation is nat possible since pump damage will occur due to pump runout. Cycling the valves without the pump in operation will result in the draining of the associated piping system which renders the system inoperable for hours until it is refilled and vented. The partial-stroke during the pump run is to the pump full flow position and, therefore, insures the valve can perform as needed during operation. Timing the valve from this midposition is not repeatable.

These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages when the consequences of the required safety system unavailability has less impact on plant operations.

6.

REACTOR CORE ISOLATION COOLING SYSTEM 6.1 Category A Valves Valve 1(2)E51-F013, reactor core cooling injection isolation, cannot be exercised during power operation be'cause, during power operation, the RCIC piping is normally pressurized at 60 psig. One purpose of valve F013 is to isolate reactor pressure from the RCIC system.

Opening the valve 1

would result in a water hammer of the RCIC piping and the high reactor water pressure would cause damage to the low pressure piping on the suction side of the RCIC pump which is designed for a maximum pressure of 100 psig. The valve may be exercised during cold shutdowns when reactor pressure has been substantially reduced.

This valve will be full-stroke

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exercised and stroke timed during cold shutdowns and refueling outages.

Valves 1(2)E51-F064, residual heat removal steam condensing supply, and 2E51-F091,' Unit 2 -F064 bypass, cannot be exercised during power 1

operation. These valves are located at the interface of high and low pressure piping. Opening these valves during power operation would result in severe water hammer and thermal shock to the icw pressure piping. These valves are normally closed and do not need to open to provide a safety 82

function. Cycling these valves during power operation would require removing the RCIC System from service to avoid causing an inadvertent high flow isolation and to minimize any water hammer or thermal cycling effects. These valves may be stroked at cach cold shutdown when reactor water pressure and temperature have both been reduced. These valves will be full-stroke exercised and stroke tined during cold shutdowns and refueling outages.

Valves 1(2)E51-F008, reactor core isolation cooling outboard steam isolation, and -F063, reactor core isolation cooling inboard steam isolation, cannot be exercised during powsr operation. These valves are normally open to supply steam to the turbine driven RCIC injection pump.

Conservatively, these valves are left in the open position to insure tFat driving steam can be supplied to the turbine at all times during operation. These valves als-.rve as a primary containment isolation function.

LaSalle County Station feels that to close these valves during operation would place the operation of the system in an untenable condition.

Further, if either were to fail closed, it would render the RCIC system inoperable. These valves will be full-stroke exercised and stroke timed during enld shutdowns and refueling outages.

1 It is impractical to full-stroke exercise valve 1(2)E51-F019, reactor core isolation cooling minimum flow isolation, during power operation.

This valve is partial-stroke tested quarterly with the pump operability Full-stroke cy-ling this valve with the pump in operation is not run.

possible since pump damage will occur due to pump runout. Cycling the valve without the pump in operation will result in the draining of the associated piping system which renders the system inoperable for hours until it is refilled and vented. The partial-stroke during the pump run is to the pump full flow position and, therefore, insures the valve can perform as needed during operation. Timing the valve from this midposition is not repeatable.

This valve will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages when the consequences of

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the required safety system unavailabi'ity has less impact on plant i

operations.

l 83

7.

REACT 00.' WATER CLEANUP SYSTEM 7.1 Category A Valves

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Valves 1(2)G33-F001, reactor water clean

-F004, reactor water cleanup outboardup inboard suction isolation, water cleanup return isolation, cannot be 'exsuction isolation, and because the entire RWCU system must be i ercised during power operation valves can be closed.

noperable before.iny of these prevents thermal stratification of the watThis system the vessel.

ry and The system's operabilit er in the bottom head section.of prevent fuel cladding damage and excessive this required during vessel's bottom head section.

ermal stresses in the reactor ex9rcised and stroke timed during each coldTherefore, thes roke -

shutdown and refueling outages.

8.

PRIMARY CONTAINMENT PURGE SYSTEM 8.1 Category A Valves The following list of valves cannot b operation because they are administrativel e exercised dur,ing power power operation in accordance with thy required tu remain shut during Technical Specifications. These valves will be full stroke exe stroke timed during cold shutdowns and ref sed and ueling outages.

1(2)VQO26 - Suppression pool purge inlet 1(2)VQO27 - Suppression pool purge inlet 1(2)VQO29 - Orywell purge inlet 1(2)VQO30 - Drywell purge inlet 1(2)VQO31 - Suppression pool purge exhau t 1(2)VQ040 - Suppression pool purge exhau t s

s 84

1(2)VQ034 - Drywell purge exhaust 1(2)VQC36 - Orywell purge exhaust 1(2)VQ042 - Drywell nitrogen supply 1(2)VQ043 - Suppression pool supply 9

REACTOR BUILDING CLOSED COOLING WATER SYSTEV 9.1 Category A Valves Valves 1(2)WR-029, reactor building closed cooling water outboard drywell supply isolation, 1(2)WR-179, reactor. building closed cooling water inboard drywell supply isolation,1(2)WR-040, reactor building closed cooling water outboard return isolation, and 1(2)WR-180, reactor building closed cooling water inboard drywell return isolation, cannot be exercised during power operation because reactor recirculation pump operation requires a continuous cooling water flow from the reactor building closed cooling water system.

Exercising these valves during operation interrupts this flow from the reactor building closed cooling water system and could result in damage to the pump and thus place the plant in a less safe mode of operation. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

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APPENDIX B P&ID L'ISTING The P& ids listed below were used during the course of this review.

System P&ID Revision Containment Monitoring 156-1 G

158-1 F

156-2 H

158-2 G

156-4 C

158-4 8

92-2 0

138-2 0

Diesel Generator 87-1 U

I?4-1 N

87-2 S

134-2 R

Diesel Oil 85-3 S

132 N

L Fuel Pool Cooline 87-1 U

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134 1 N

87-2 S

134-2 R

91-1 G

131-1 F

i 98-1 T

144-1 N

Feedwater 57 M

118 K

Combustible Gas Control 130-2 L

High Pressure Core Spray 95 P

141 AD Drywell Instrumen'. Nitrogen 66-1 J

66-3 J

66-7 C

66-2 K

66-4 K

Low Pressure Core Spray 94 R

140 P

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System P&IO_

Revision Clean Condensate Storage 75-2 R

75-4 K

Main Steam 55-1 J

116-1 E

55-7 J

i 116-7 G

55-2 J

116-2 0

55-8 G

116-8 H

92-1 V

138-1 U

Nuclear Boiler 93-3 0

139-3 C

93-4 J

139-4 G

93-5 F

139-5 F

Primary Containment Vent and Purge 92-2 0

138-2 0

Control Rod Drive 100-2 K

146-2 H

100-4 8

146-4 B

r 100-3 F

146-3 E

i Reactor Building Floor and Equipmer.t Orains 91-4 N

137-4 L

4 Residual Heat Removal 96-4 V

142-4 P

96-1 U

142-1 P.

96-3 U

l 142-3 AC 96-2 11 142-2 R

87-2 S

134-2 R

87-1 U

134-1 N

91-3 0

137-3 A

90 i

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.f Reactor Core Isolation Cooling 101-2 V

147-2 S

101-1 Y

147-1 AD Reactor Recirculation 2

'R 139-2 M

93-1 T

139-1 K

2139-1 0

2139-2 0

2139-3 0

2139-4 0

2139-8 0

Reactor Water Cleanup 97-1 0

143-1 N

91-2 0

137-2 8

Service Air 82-3 J

-i 82 5 J

Standby Liquid Cor. trol 99 N

145 R

Primary Containme'nt Ventilation 86 T

133 5

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Primary Containment Purge 92-1 V

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Reactor Building Closed Cooling Water 90-2 J

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APPENDIX C IST PROGRAM ANDMALIES IDENTIFIED IN THE REVIEW 93

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APPENDIX C IST PROGRAM ANOMALIES IDENTIFIE0 IN THE REVIEW Inconsistencies and omissions in the licensee's program noted during the course of this review are summarized belcw. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

1.'

The licensee has requestea relief from measuring inlet pressure on the high pressure core spray water leg pump,1(2)E22-C003, in RP-02 and then has requested relief from the instrumentation full-scale range requirements in RP-09. The licensee should correct this inconsistency.

r 2.

The licensee has requested relief from measuring inlet pressure on the residual heat removal water leg pump,1(2)E12-C003, in RP-02 and then has requested relief from the instrumente' ion full-scale range requirements in RP-08. The licensee shouid correct'this inconsistency.

3.

The licensee should be required tu conduct the tests of the reactor core isolation cooling pump,1(2)E51-C001, in accordance with Section XI.

(See Item 3.7.1) 4.

The licensee should be required to develop a method to full-stroke exercise valve 1(2)E22-F005, high pressure core spray injection testable check, in accordance with Section XI.

(See Item 4.4.1.1) 5.

The licensee should be required to develop a method to full-stroke exercise valve 1(2)E21-F006, low pressure core spray injection testable check, in accordance with Section XI.

(See Item 4.6.1.1) 6.

The licensee should be required to measure the stroke time of valves 1(2)C11-D001-126 and -127, control rod scram inlet and outlet, or to 1

provide a relief request that explains why it cannot be done.

(See Item 4.9.1.1) l

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7.

The licensee should be required to individually measure the stroke times of valves 1(2)C11-F380 rnd -F388, control rod drive scram discharge instrument volume /ents, and -F381 and -F389, control rod drive scram discharge instrament volume drains, in accordance with the requirements of Section XI.

(See Item 4.9.1.2) i 8.

The licensee should be required to develop a method to full-stroke exercisc valves 1(2)E12-F041A, -F041B, and -F041C, residual heat removal injection testable checks, in accordance with Section XI.

(See Item 4.10.1.1) l 9.

The h'censee should be required to develop a method to full-stroke exercise valve 1(2)E51-F066, reactor core isulation cooling inboard testable check, in accordance with Section XI.

(See Item 4.11.1.1)

10. The licensee should be required to develop a method to ful?-stroke exercise valve 1(2)E51-F065, reactor core isolation cooling outboard testable check, in accordance with Section XI. (See Item 4.11.1.2) t

11. The licensee should review the safety-related fur.ction of valves 1(2)E51-F082 and -F084, reactor core isolation cooling turbine exhaust line vacuum breakers, for inclusion in the IST program since these valves must change position to perform a safety function. This item was inadvertently omitted from the review and, therefore, from the discussions during the working meeting.

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TECHNICAL EVALUATION REPORT. PUMP AND VALVE INSERVICE TESTING PROGRAM, LASALLE COUNTY STATION, UNITS 1 AND 2 l

g May 1988 T. L. Cook

. mi.e.:.. u en H. C. Rockhold

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• • .a May 1988

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• Mechanical Systems Evaluations Unit EG&G Idaho. Inc.

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P. O. Box 1625 A6812 Idaho Falls. ID 83415

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tiechanical Engineering Branch Office of Nuclear Reactor Regulation Technical Evaluation Report U.S. Nuclear Regulatory Comission

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Washington, DC 20555 a..... oru 2

r.,:v.m This EG&G Idaho, Inc. report presents the results of our evaluation of the LaSalle County Station, Units 1 and 2. Inservice Testing Program for pumps and valves that perform a safety-related function.

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