ML20154L968
| ML20154L968 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/15/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20154L966 | List: |
| References | |
| NUDOCS 8809270010 | |
| Download: ML20154L968 (7) | |
Text
..
/
'o UNITED STATES 1
NUCLEAR REGULATORY COMMISSION wasmNGTON, D. C. M56
\\,...../
SAFETY EVALUATION rep 0RT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF COMMONWEALTH EDISON COMPANY BYRON STATION, UNITS 1 AND 2 DOCKET NOS.: 50-454/455
1.0 INTRODUCTION
The Code of Federal Regulations, 10 CFR 50.55a(g), requires that inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Soiler and Pressure Vessel Code and applicable addenda, excep': where specific written relief has been requested by the licensee and granted by the Comission pursuant to 10 CFR 50.55a(a)(3)(1),(a)(3)(ii),or(g)(6)(1).
In requesting relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulties without a compensating ir.
7ase in the level of quality and safety, or (3) conformance with ctrtain requirements of the applicable Code edition and addenda is imprac'. cal for its facility.
TheRegulation,10CFR50.55a(a)(3)(1),(a)(3)(11),and(g)(6)(1),
authorizes the Comission to grant relief from these requirements upon making the necessary findings. The NRC staff's findings with respect to granting or not granting the relief requested as part of the licensee's IST Program are contained in the Safety Evaluation (SE) issued on the licensee's program.
The IST program addressed in this report covers the first ten-year inspection ir.terval from Semptember 16, 1985 to September 16, 1995 for Byron 1 and from August 21, 1987 to August 21, 1997 for Byron 2.
The licensee's program is described in a letter dated November 4,1982. This report is based on review of the licensee's IST program through Revision 6 for pumps and Revision 7 for valves submitted in a letter dated August 31, 1987.
The program is based on the requirements of Section XI of the ASME Code, 1980 Edition through the Winter of 1981 Addenda.
P PDC
,~ 2.0 EW lATION Tiie Regulation,10 CFR 50.55a(g)(4)(i), requires that during the initial 120 month interval, the IST program shall comply with the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 month prior to the date of issuance of the operating license. This corresponds to 1980 Edition through the Wintor of 1981 Addenda (80W81) for Unit 1 and 1983 Edition through the Sumer of 1983 Addenda (83S83) for Unit 2.
The licensee's IST pregiam which was submitted August 31, 1987 was developed using the 80W81 Code for both units and thus departed from the provisions 10 CFR Part 50.55a(g)(4)(1). By letter dated May 16, 1988, the licensee comitted to use the 83583 Code for both unf ts.
10 CFR 50.55a(g)(4)(iv) permits use of later, approved code editions and addenda subject to Comission approval.
Thus, the Comission approves the use of the 83583 Code for both unit 3 with the issuance of this Safety Evaluation.
However, the program that was reviewed was developed using the 80W81 Code.
In a letter dated July 29, 1988, the licensee stated that the differences between the 80W81 Code and the 83583 Code have a minimal effect on the Byron IST program.
The staff has reviewed the differences between the two codes and concludes that there are only minor additional changes in the area of inservice testing and that the licensee's IST program would not be affected by the use of the later edition and addenda.
The IST program and the requests for relief from the requirenents of Section XI have been reviewed by the staff with the assistance of its contractor, EG&G, Idaho, Inc. (EG&G).
In addition, EG&G and staff members met with licensee representatives on July 8 and 9, 1986, in a working session to discuss questions resulting from the retiew. The Technical Evaluation Report (TER) provided as Attachment 1 is EG&G's evaluation of the licensee's inservice testing program and relief riquests.
The staff has reviewed the TER and concurs with the evaluations and conclusions contained in the TER. A sumary of the pmp and valve relief request deteminations is presented in Table 1. The granting of relief is based upon the fulfillment of any comitments made by the licensee in its basis for each relief request end the alternative proposed testing.
Six relief requests were denied (TER sections 3.1.1, 4.1.1.1, 4.2.1.3, 4.2.2.1, 4.5.1.1 and 4.8.2.1) and two relief requests were granted with certain conditions (TER sections 3.3.1 and 4.8.1.1).
The licensee should refer to the specific TER section for a detailed discussion of these casas. These denials and conditions art listed in TER Appendix C and in 4
addition, Apperdix C lists other IST program anomalies which were identified during our review.
The licensee should resolve all the items listed in Appendix C in accordance with the staff positions.
Required program changes should be made within 90 days of receipts of this SER.
- 3.0 INSPECTION An inspection of the Byron 1 & 2 IST programs should be conducted by Region III. The inspection should focus on the adequacy of implementing procedures for the IST program, and satisfactory actions to resolve the items addressed in Appendix C of the TER.
4.0 CONCLUSION
Based on the review of the licensee's IST program and relief requests, the staff concludes that the IST program as evaluated and modified by this SER will provide reasonable assurante of the operational readiness of the pumps and valves covered by the IST program to perfonr 'beit safety related functions. The staff has determined that grant.ag relief, pursuantto10CFR50.55a(a)(3)(1),(a)(3)(ii),or(g)(6)(1),is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination the staff has corsidered the alternate testing being implemented, resulting hardships without a compensating increase in safety, or the impracticality of performing the required testing considering the burden if the requirements were imposed. The last column of Table 1 identifies the regulation under which the requested relief is granted.
During the review of the licensee's inservice testing program, the staff has identified certain misinterpretations or omissions of Code requirenents.
These items are summarized in the TER Appendix C.
The IST progran for Byron 1 & 2, through a submittal dated August 31, 1987, as revised by May 18, 1988 and July 29, 1988 letter comitments, is acceptable for implementation provided that the items noted above are corrected promptly.
Relief requests contained in any subsequent revisions may not be implemented without prior approval by HRC.
06/09/88
)*
BYRON STATION, UNITS 1 AND 2 l
SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC Valve 4.1.2.1 IWV-3521 Test Containment Verify operability Relief VR-2 frequency.
spray additive during refueling Granted /
checks:
outages by either (g)6(i) 1(2)CS020A and full flow or B
disassembly and inspection.
Valve 4.2.3 1 IWV-3521 Test Safety Full-stroke exercise Relief VR-3 frequency.
injection during refueling Granted /
pumps' outages.
(g)6(1) p discharge check valves:
1(2)S!8922A and B Valve 4.1.1.1 IWV-3521 and Containment Verify operability Relief VR-4 IWV-3412 Test spray ring during refueling Denied frequency.
header checks: outages by either 1(2)CS008A and full flow or B
disassembly and inspection.
Valve 4.1.2.2 IWV-3521 Test Containment Part-stroke Relief VR-4 frequency.
spray pump quarterly, verify Granted /
discharge operability during (g)6(i) checks:
refueling outages by 1(2)CS003A and either full flow or 8
disassembly and inspection.
Valve 4.2.1.1 IWV-3521 rid Accumulator Exercise with flow Relief VR-5 IWV-3412 'n' t discharge during cold Granted /
frequenc,y.
checks:
shutdowns if not (g)6(i) 1(2)S!8948A-D performed within the and last 9 months.
1(2)S!8956A-D Valve 4.2.3.2 IWV-3521 Test Safety Part-stroke exercise Relief VR-6 frequency.
injection pump quarterly, Granted /
suction full-stroke exercise (g)6(i) checks:
during refueling 1(2)S!8926 outages.
Valve Deleted VR-7
Page NC.
3 06/09/88 BYRON STATION, UNITS 1 AND 2 SER TABLE 1 SutNARY OF RELIEF REQUESTS RELIEF TER SECTIUN XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT ILENTIFICATION METHOD OF BY NUM8ER
& SUBJECT TESTING USNRC Valve 4.3.1.1 IWV-3411 Test umponent Exercise during Relief VR-8 Frequency.
cooling water refueling outages Granted /
to RCe :
and cold shutdowns (g)6(i) s 1(2)CC685, whtn the reactor 1(2):C9413A, coolant pumps are 1(2)CC9414, not running.
1(2)CC9416, i
1(2)CC9438 Valve 4.3.2.1 IWV-3521 Tast Component Verify reverse flow Relief VR-8 frequency.
cooling water closure during leak Granted /
supply to RCPs rate testing per (g)6(i) check valve:
IWV-3420 (at least
[
1(2)CC9486 once per two years),
Valve 4.4.1.1 IWV-3411 Test Seal water Exercise during Relief f
VR-9 frequency, supply to refueling outages Granted /
RCPs:
and cold shutdowns (g)6(i) 1(2)CV8100 and when the reactor 1(2)CV8112 coolant pumps are not running.
Valve 4.5.1.1 IWV-3411 Test Instrument air Exercise during Relief VR-10 frequency and to containment refueling outages Denied IWV-3415 fail isolation and during cold safe test, valves:
shutdowns on an 1(2)lA065 and undefined frequency.
1(2)lA066 Valve 4.8.2.1 IWV-3417(a)
Rapid actine Assign 2 second Relief VR-12 Stroke times, valves, stroke time limit, Denied upon exceeding limit increase test frequency and trend.
Valve 4.6.1.1 IWV-3412 Diesel Verify operability Relief VR-13 3413(b),
generator air monthly by Granted /
3417, and start valves:
comparison of air (g)6(1) 3522 Stroke 1(2)DG5182A-D, reciever pressures time and 1(2)DG5183A-D, before and after trend.
1(2)DG5184A-0, diesel start, and 1(2)DG5185A-D Valve Deleted VR-14
s v.
EGG NTA 8051 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BYRON STATION, UNITS 1 AND 2 Docket Nos. 50 454 and 50 455 R. S. Hartley H. C. Rockhold Published June 1988 Idaho National Engineering Laboratory EG1G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Under DOE Contract No. DE-AC07 761001570 FIN No. A6812
%'l*1Dh
~
o, CONTENTS 1.
INTRODUCTION.....................................................
1 2.
SCOPE............................................................
3 3.
PUM P T E S T I N G PR OG RAM.............................................
7 3.1 Essential Service Water System.............................
7 3.1.1 Relief Request.....................................
7 3.2 Diesel Generating System...................................
8 3.2.1 Relief Request.....................................
8 3.3 All Systems................................................
9 3.3.1 Relief Request.....................................
9 3.3.2 Relief Request.....................................
13 3.3.3 Relief Request.....................................
14 4.
VALVE TESTING PROGRAM............................................
19 4.1 Containment Spray System...................................
19 4.1.1 Category A/C Valves................................
19 4.1.2 Category C Valves..................................
20 4.h Safety injection System....................................
23 4.2.1 Category A/C Valves................................
23 4.2.2 Category B Valves..................................
28 4.2.3 Category C Valves..................................
30 4.3 Component Cooling System...................................
32 4.3.1 Category A Valves..................................
32 4.3.2 Category A/C Valves................................
34 4.4 Chemical and Vol ume Control Systems........................
35 4.4.1 C a t e g o ry A V a l v e s..................................
35 111
,a b
g TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BYRON STATION. UNITS 1 AND 2 1.
INTRODUCTION Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by Comonwealth Edison Company for its Byron Station, Units 1 and 2.
[
By a letter dated November 4,1982, Commonwealth Edison Company subniitted an IST Program for Byron Station, Units 1 and 2.
A working meeting with Comonwealth Edison Company and Byron Station, Units 1 and 2 representatives was conducted July 8 and 9, 1986 and conference calls were held on December 24, 1986 and July 09, 1987. The licensee's IST Program for pumps, Revision 6, and for valves, Revision 7, as revised by Comonwealth Edison Company and attached to S. C. Hunsader letter to NRC, dated August 31, 1987, was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety related with the requirements of the ASME t
Boiler and Pressiire Vessel Code (the Code)Section XI, 1980 Edition through t
Winter 1981 Addenda. Any IST program revisions subsequent to those noted l
above are not addressed in this technical evaluation report (TER). The NRC staff position is that required program changes, such as additional relief requests or the deletion of any components from the IST program, should be i
submitted to the NRC under separate cover in order to receive prompt l
attention, but should not be implemented prior to review and approval by the NRC.
I In their submittal, Comonwealth Edison Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine if the required testing is indeed impractical for the specific pumps and valves. This i
review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatgry Guide and Value/ Impact Statement titled "Identification of Yalves for Inclusion in Inservice Testing Program". The IST Program testing requirements apply only to I
1 l
h
_s
2 I
2.
SCOPE The EG&G Idaho review of the Commonwealth Edison Company, Byron Station, Units 1 and 2 inservice testing (IST) program for pumps and valves was begun in 1984. The program initially examined was Revision 2, dated November 11, 1982, which identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix B.
i 1
t The licensee's proposed IST program was reviewed by locating and highlighting the components on the appropriate system P&lDs and determining their function in the system. Then the licensee's proposed testing was evaluated to determine if it was in compliance with the ASME Code,Section XI, requirements. During the course of this review, questions and comments were made relative to unclear or potential problem areas in tSe l
licensee's ISI program. These were transmitted to the licensee in tne form
(
l of a request for additional information (RAI) which served as the agenda for the working r.eeting between the licensee, the NRC, and the EG1G reviewers.
I 1
Each pump and valve relief request was individually evaluated to l
determine if the licensee had clearly demonstrated that the Code 4
requiremerits are impractical for the identified system components, and to t
determine if the proposed alternate testing would provide a reasonable
[
indication of component operability giving due consideration to the burden on the licensea if the Code requirements were imposed.
Where the licensee's j
technical basis or titernate testing was insufficient or unclear, the l
licensee was requested to clarify the relief request.
The system FalD was also examined to determine whether the instrumentation necessary to make the f
identified measurements is available.
If, based on the unavailability of j
adequate instrumentation or the reviewers experience and system knowledge,
(
)
it was determined that it may not be possible or practical to make the l
).
measurements identified in the licensee's IST program, a question or comment l
was generated requesting clarification.
]
For pumps, it was verified that each of the seven inservice test quantities of Table IWP 3100-1 were indicated to be measured or observed.
I i
l l
3 1
I Further evaluation was performed on all valves in the program to i
determine that the identified testing could practically and safely be conducted as described.
If the licensee's 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 only a thermal relief function, were confirmed to be included in the IST program and tested in accordance with IWV-3510.
Safety related explosively actuated valves were verified to be included in the IST program and tested in accordance with IWV 3610.
2 Once all the components in the licensee's IST program had been identified on the Pal 0s and evaluated as described above, the P&lDs were examined closely by at least two trained and experienced reviewers to identify any additional pumps or valves that may perform a safety function which were not included in the licensee's program. The licensee was asked to reconcile any components that were identified by this process which were not included in the IST program. Also, the list of systems included in the 7
licensee's program was compared to a system list in the Draft Regulatory Guide and Value/ Impact Statement titled, ' Identification of Valves for Inclusion in Inservice Testing Programs". Systems that appear in the Draft i
Regulatory Guide list but not in the licensee's program were avaluated and, if appropriate, questions were added to the RAI.
l Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions were included 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 TER.
i At the completion of the review, the RAI was transmitted to the licensee, These questions were later used as the agenda for the working meeting with the licensee on July 8 and 9, 1986. At the meeting, each 5
2 I
t, A.
PUMP TESTING PROGRAM The Byron Station, Units I and 2, IST program submitted by the 1
Comonwealth Edison Company was examined to verify that all pumps that are included are subjected to the per: odic tests required by the ASFe Code',
Section XI,1980 Edition thiough Winter 1981 Addenda, except for those pumps identified below for which specific relief from testing has been requested and is sumarized in Appendix C.
Each Comonwealth Edison Company basis for requesting relief from the pump testing requirements and the reviewers' evaluation of that request is sumarized below, i
3.1 Essential Service Water System 3.1.1 Relief Reauest The licensee has requested relief from the IWP 3100 requirements of Section XI for measurement of differential pressure for the essential
)
service water makeup pumps, OSX02PA and B, and proposed to evaluate these pumps using pump discharge pressure.
3.1.1.1 Licensee's Basis for Reauestina Relief.
it is impractical to measure the inlet pressures of these pumps.
Instrumentation for directly measuring the inlet pressure for these pumps does not exist. These pumps are vertical well type p ups which take a suction from the river screen I
house forebay. The annual fluctuation between the highest and lowest river water is approximately two feet. This difference in suction pressure (approx. 0.9 psi) is less than the accuracy of the pump discharge pressure gage:
1 Gage Range Accuracy (1/2% of full scale)
OPI-SX054/55 0 300 PSIG 1.5 PSIG Installing system modifications to record suction pressure will not provide more accurate data for evaluating the performance of these pumps.
7
1 3.2.1.1 Licensee's Basis for Reauestina Relief. Thesi. pumps are positive displacement Diesel Oil Transfer Pumps. The pump differential pressure is not a factor affecting pump performance, but rather dependant only on the inlet pressure to the pump. As the pump discharge pressure is constant, and the inlet pressure varies with tank levei, the differential pressure is not a valid operational parameter. Using pump discharge pressure in lieu of pump differential pressure will provide meaningful pump performance data for evaluation of operational readiness of the Diesel Oil Transfer Pumps.
As an alternative, pump discharge pressure is a valid operational parameter. This will be used to evaluate the Diesel Oil Transfer Pumps I
performance.
3.2.1.2 Evaluation. These diesel oil transfer pumps are positive displacement type. Their outlet pressure is dependant on the pressure of the system into which they are pumping and is not affected significantly by l'
either inlet pressure (providing adequate NPSH exists) or flowrate. For these pumps differential pressure and flowrote are not dependant variables, l
as they are for centrifugal type pumps. Differential pressure is not a J
meaningful parameter in determining if hydraulic degradation is occurring.
Measurement of discharge cressure in lieu of differential pressure for these positive displacement pumps provides enough information to evaluate to i
determine the hydraulic condition of these pumps and presents a reasonable i
i alternative to the Code requirements.
i Based on the detertaination that the licensee's proposed alternative is essentially equivalent to the Code requirements, relief should be granted as requested.
)
)
3.3 All Systems 3.3.1 Helief Reauest i
ThelicenseehasrequestedrelieffromtheTable'INP31002 requirements of Section XI, for measurement of pump vibration in units of i
i
{
9 I
i I
1 i
velocity greater than 6 times the reference value or greater than.70 inches per second will require corrective actions to be performed on the affected component.
The OSX02PA and B pumps, due to their design, will experience vibration velocity readings that will normally exceed 0.4 inches per second. A vibration J this magnitude would fall into the "Alert" range of the ANSI /ASMt. OH 6, Table 61001 and would require "Doubling the Test Frequency." For this reason, the vibration data on these puups will be evaluated on a case by case basis, with comparisons to previous data closely monitored to verify that the vibration is not affecting pump operability.
This is in accordance with IWP-3230(c). Evaluation of data, to assign equipment to the alert or action ranges, will be done within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (per IWP 3220 of Section XI). This will be done using industry accepted vibration analysis equipment, such as a full spectrum analyzer.
Vibration measurements for all pumps will be obtained and recorded in velocity, inches per second, and will be broadband unfiltered peak measurements. The monitored locations 'for vibration analysis will be marked
~
so as to permit subsequent duplication in both location and plane.
The frequency response range of the vibration transducers and their readout system shall be capable of frequency responses from one-third minimum pump shaft rotational speed to at least one thousand hertz, The centrifugal pumps in the program will have vibration measurements taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing housing and in the axial direction on each accessible pump thrust bearing housing.
The vertical line shaft pumps in the program will have vibration measurements taken on the upper motor bearing housing in three orthogonal directions, one of which is the axial direction.
Measurements of vibration in mils displacement are not sensitive to small changes that are indicative of developing mechanical problems.
11
3.3.2 Relief Reauest i
The licensee has requested relief from the IWP 3100 requirement of Section XI for measurement of bearing temperature for the following pumps:
OCC0lP Component Cooling Pump 1(2)CC0lPA and B Component Cooling Pumps 1(2)D00lPA, B, C, and D Diesel 011 Transfer Pumps 1(2)CS0lPA and B Containment Spray Pumps 1(2)RH0lPA and B Residual Heat Removal Pumps OSX02PA and B Essential Service Water Makeup Pumps (Diesel)
OWO0lPA and B Control Room Chilled Water Pumps 3.3.2.1 Licensee's Basis for Recuestino Relief. These pumps' bearings are not provided with permanent temperature detectors or thermal wells.
l Therefore, gathering data on bearing temperature is impractical.
The only temperature measurements possible are from the bearing housing. To detect high bearing temperature at the bearing housing would require that the bearings in question be seriously degraded. Measurement of housing I
temperature on these pumps does not provide positive information on bearing condition or degradation. For example, the bearings on the essential l
service water pumps (0SX02PA, OSX02PB) and diesel oil transfer pumps I
(ID00lPA through D and 2000lPA through D) are cooled by the fluid pumped.
Therefore, any heat generated by degraded bearings is carried away by the cooling fluid and would nut be directly measured at the bearing housing.
No direct alternate test is proposed for bearing temperature. However, measurement of hydraulic parameters and vibration riadings do provide a more l
positive method of monitoring pump condition and bearing degradation. By measuring pump hydraulic parameters and vibration velocity, pump operability and the trending of mechanical degradation is assured.- Also, since these parameters (i.e., hydraulic parameters,and vibration) are measured quarterly, the pump mechanical condition will be more accurately determined l
than would be possible by measuring bearing temperature on yearly basis.
i 13 I
ultrasonic flowmeters whose accuracy is consistent independent of the range (and which may exceed the range requirements specified in the Code) for the j
following pumps:
Pumo Identification Function OCCOlP Component Cooling Pump 1(2)CCOlPA and B Component Cooling Pumps 1(2)D00lPA, B, C, and D Diesel Oil Transfer Pumps l
1(2)CV0lPAandB Centrifugal Charging Pumps OSX02PA and B Essential Service Water Mah up Pumps (Diesel) 1(2)SX0lPA and L Essential Service Water Pumps 3.3.3.1 Licensee's Basis for Reauestino Relief. The full scale range I
of ultrasonic flowmeters, used to collect Section XI flow data, exceed three times the refarence value.
3 Ultrasonic flowmeters provide an accurate means of measuring flow j
rate. They utilize a digital display whose accuracy is independent of the full-scale range. The ultrasonic flowmeter is well within the requirements of IWP-4110 and 4120, which refer to an instrument accuracy of plus or minus 02% of full-scale for an instrument with a range of three times the 4
reference value or less. The following examples will illustrate this r
point. The component cooling pumps (OCC0lP, 1/2CC0lPA, and 1/2CC0lPB) have a reference value of approximately 4500 gpm. Using the Code requirements, an instrument with a full-scale range of 13,500 gpm (3 x 4500 gpm), the acceptable instrument accuracy is plus or minus 270 gpm ( 02 x 13,500 gpm).
Using the ultrasonic flowmeter, with an accuracy of plus or minus 4*/. of the indicated reading, provides an instrument accuracy of plus or minus 180 gpm i
(.04 x 4500 gpm).
1 The diesel oil transfer pumps (l(2) 000lPA PD) have a reference value of approximately 25 gpm. Using the Code requirements, an instrument with a full-scale of 75 gpm (3 x 25 gpm) the acceptable instrument accuracy is plus 15 j
Based on the determination that the licensee's proposed alternative provides a reasonable alternative to the Code requirements, relief should be granted as requested.
P P
S 6
17
4.
VALVE TESTING PROGRAM The Byron Station, Units 1 and 2, IST program submitted by the Commonwealth Edison Company was examined to verify that all valves that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI 1980 Edition through the Winter 1981 Addenda, and the NRC positions and guidelines. The reviewers found that, except as noted in Appendix 0 or where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines.
Each Commonwealth Edison Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to the system and valve Category.
4.1
{&nt.g.Lnpent Sorty Systt_9 n
4.1.1 Cateaory A/C_ Valves 4.1.1.1 Eg. lief Re.qqnt. The licensee has requested relief from exercising valves, 1(2)CS00SA and B, containment spray (CS) ring header checks, in accordance with the requirements of Section XI, Paragraph IWV-3521, and proposed to verify valve operability by either utilizing full flow or by disassembly and inspection on a refueling outage frequency.
4.1.1.1.1 Licensee's Basis f_qr Peauestina Relief-These valves cannot be full flow tested during unit operation as water fro.T. the CS pumps would be discharged through the CS ring headers causing undesirable effects on system components inside containment.
Partial stroking of the 1/2CS008A, B valves using air does not provide an adequate arsurance of valve operability and may be detrimental for the following reasons:
a). There is no correlation between air flow and angle of disc movement.
19
perform a system full flow test each refueling outage to demonstrate valve operability.
4.1.2.1.1 Licensee's Basis for Reauettina Relief--The check valves in the spray additivo system cannot be stroked without introducing NaOH into the CS system.
1 i
As an alternative, these valves will be dismantled each refueling i
outage in order to demonstrate operi.bility.
In addition to this, they will I
be full flow tested once every five years. The full flow test will be pert'ormed in lieu of dismantling the valves, if desired. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
?
4.1.2.1.2 Evaluation -It is impractical to either full or part stroke exercise valves 1(2)CS020A and B quarterly during power operation or cold shutdewn since flow through these valves would result in the introduction of NaOH into the CS system. NaOH is a highly caustic, extremely corrosive chemical, which poses a serious threat to personnel and equipment.
Full-flow exercising of these valves can be performed by special test, however, this requires special test hook ups and necessitates flushing the system. This presents a safety hazard to operating personnel and would be burdensome for the licensee to perform during cold shutdowns. The licensee's proposal to demonstrate the full-stroke capability of these valves on a refueling outage frequency by either disassembly and inspection of check valve internals or by system full flow testing provides a reasonable alternative to the Code requirements.
Based on the determination that it is impractical to test these valves in accordance with the Code requirements, that the licensee's proposal provides a reasonable alternative to the Code requirements, and considering the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.
21
s.
Based on the determination that it is impractical to test these 4
valves in accordance with the Code requirements, that the licensee's proposed alternate testing frequency provides a reasonable assurance of operational readiness, and considering the burden on the licensee if the i
Code requirerents were imposed, relief should be granted as requested.
I 4.2 Safety iniection System 4.2.1 Cateaory A/C Valves 4.2.1.1 Relief Reauest. The licensee has requested relief from exercising valves 1(2)S18948A 0 and 1(2)S!8956A 0, accumulator discharge l
checks, in accordance with the requirements of Section XI, Paragraphs IWV 3411 and 3521, and proposed to full-stroke exercise these valves at i
least once every nine months during cold shutdowns by providing a surge i
volume in the pressurizer, ' burping the valves', and noting a change in
[
pressurizer level, f
i j
4.2.1.1.1 Licensee's Basis for Recuestina Relief--The accumulator check valves cannot be tested during unit operation due to the pressure j
differential between the accumulators (650 psig) and the reactor coolant j
system (2235 psig). Full stroke exercising of these valves could occur only l
)
with a rapid depressurization of the reactor coolant system.
[
i i
i i
Byron Station Technical Specifications require leak testing to be i
performed on these valves if the unit is in cold shutdown and if such leak l
rate testing has not been performed within nine months. Therefore, Byron Station will full stroke exercise (Ct) these valves on the same schedule.
l This will be accomplished by providing a surge volume in the pressurizer and "burping" the accumulator discharge valves. As a minimum, the accumulators will be discharged into the reactor vessel during refueling outages to perform full stroke exercise (Ct) of these valves.
Positive verification of
[
l valve operability will be by noting r. change in accumulator level.
Stroke i
1 exercising the check valves on the same schedule as their required Technical i
i
]
23 l
I I
o I
relief should be granted as requested provided the licensee can demonstrate that a full-stroke test is being perfomed when using the proposed method.
l 4.2.1.2 Relief Reauest. The licensee has requested relief from l
exercising the following valves in accordance with the requirements of Section XI, Paragraphs IWV 3412 and 3522, and proposed to full stroke l
exercise these valves with flow during refueling outages with the reactor j
1 vessel head removed.
a Valve Identification Function 1(2)S!8819A D Cold leg safety injection check valves.
1(2)SI8905A D Hot leg safety injection check valves.
i 1(2)S!8949A D Hot leg safety injection check valves.
j 4.2.1.2.1 Licensee's Basis for Reauestina Relief Byron Station l
I Technical Specifications require all Safety injection pumps and all but one l
Charging Pump to be inoperable during Modes 4, 5, and 6, except when the reactor vessel head is removed. This requirement minimizes the possibility l
of low temperature overpressurization of the Reactor Coolant System.
l Therefore, check valves 1(2)S18819A D,1(2)SI8905A D, and 1(2)S18949A 0, i
cannot be full stroke exercised during cold shutdowns as required by L
i IWV 3412 and IWV 3522.
i l
In addition to the stroke test exercise used to verify operational j
readiness of these check valves, the act of such stroking causes the
[
i necessity for Technical Specification required leak rate testing of these
[
j valves prior to unit criticality. This testing, in conjunction with ths stroke exercising of these check valves, adds approximately one week to the I
duration of any outage and additional radiation exposure to workers who must i
connect flowmeters and differential pressu?e gauges directly to pipes 4
1 containing radioactive fluids.
l g
d j
Byron Station's Technical Specifications require leak rate testing to
(
l be performed on these valves if the unit is in cold shutdown and if such j
leak rate testing has not been performed within nine months.. Stroke exercising of check valves 1(2)S!8819A D,1(2)SI8905A 0, and 1(2)S18949A D, 25 t
f i.
t
._-__,-,--,e_,._m--_-
- _- - ~ _- _,
s.
Valve Identification Function II2lS1885l{2,518841Aand8 Hot leg safety injection check valves.
Charging pump discharge to cold leg check valve.
1(2)S!8900A-D Charging safety injection check valves.
i
[
4.2.1.3.1 Licensee's Basis for Reauestina Relief--The full stroke exercising of check valves not stroked quarterly is required to be performed during cold shutdowns. However, the stroking of check valves 1(2)$18815, 1(2)S!8900A D, and 1(2)S18841A B, associated with the emergency core cooling system, during cold shutdowns, will induce thermal stresses on their respective reactor vessel nozzles as the reactor coolant system (maintained approximately 180 F) is injected with water from the refueling water storage tank (maintained approximately 65 F).
In addition to the stroke test exercise used to verify operational i
readiness of these check valves, the act of such stroking causes the i
necessity for Technical Specification required leak rate testing of these 1
valves prior to unit criticality. This testing, in conjunction with thd stroke exercising of these check valves, adds approximately one week to the j
duration of any cutage and additional radiation exposure to workers who must
)
connect flowmeters and differential pressure gauges directly to pipes containing radioactive fluids.
Byron Station's Technical Specifications require leak rate testing to be performed on these valves if the unit is in cold shutdown and if such leak rate testing has not been performed within nine months. Therefore, Byron Station will stroke exercise check valves 1(2)S18815, 1(2)S18900A 0, and 1(2)S!8841A and B on the same schedule, if plant conditions allow.
Stroke exercising the 1(2)SI8815, 1(2)S!8900A 0, and 1(2)S!8841A and B check valves on the same schedule a'i ' heir required Technical Specification
]
leak rate testing, as plant conditions allow, will adequately maintain tt.e system in a state of operational readiness without creating additional undue thermal stresses to the reactor vessel nozzles or unnecessary personnel radiation exposure.
27
s.
4.2.2.1.1 Licensee's Basis for Reauestina Relief--The full-stroke exercising of valves not stroked quarterly is required to be performed during cold shutdowns. However, the stroking of the Containment Sump Outlet Isolation Valves, 1(2)S!8811A and B, requires the section of the residual heat removal pumps to be drained, thus rendering one train of the system inoperable.
With one train of residual heat removal declared inoperable, Byron i
Station's Technical Specifications require two steam generators with a level greater than 41% (Unit 1) and 18% (Unit 2).
If the cold shutdown condition was necessitated by a secondary side steam generator problem, Byron Station's Technical Specifications would preclude such testing until such time as the steam generators had been refilled.
The full-stroke testing of the 1(2)SI8811A and B valves; in conjunction with system draining, refilling and venting of each train solely for the purposes of such testing, accounts for an additional six days of scheduling requirements for a unit cold shutdown outage. The alternate tuting during refueling outages will adequately maintain the system in a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
As an alternative. Byron Station will full-stroke exercise the Containment Sump Outlet Isolation Valves, 1(2)SI8811A and B, during refueling outages vice cold shutdown.
4.2.2.1.2 Evaluation-It is impractical to full-or part stroke r
exercise valves 1(2)SI8811A and B quarterly during power operation as this l
requires draining the suction piping for one train of residual heat removal and rendering it inoperable. The licensee has stated that with one train of f
residual heat removal inoperable (at cold shutdown) certain requirements exist with respect to the minimum level required in two of their four steam generators. However, the reviewer considers the probability of a cold shutdown resulting from secondary side steam generator problems in more than f
two steam generators quite remote and inconvenience is not an adequate 29 m
2 s.
shutdown would risk low temperature overpressurization of the RCS and is, therefore, not practical. Cooldown and depressurization of the reactor coolant system and removal of the reactor vessel head solely to facilitate full-stroke exercising these valves at cold shutdown (due to low temperature overpressurization concerns) would be time consuming, difficult, and extremely burdensome to the licensee.
Full-stroke axercising these valves i
utiliz(ng system flow during refueling outages when an adequate surge volume exists (i.e., when the reactor vessel head is removed) provides reasonable assurance of operational readiness and a reasonable alternative to the Code requirements.
Based on the impracticability of complying with the Code requirements, the burden on the licensee if the Code requirements were imposed, and considering the proposed testing, relief should be granted.
9 4.2.3.2 Relief Reauest,. The i mensee has requested relief from exercising valves 1(2)SI8926, safety injection pump suction checks, in accordance with the requirements of Section XI, Paragraph IWV 3521, and I
proposed to part-stroke exercise these valves quarterly and to full stroke exercise these valves on a refueling outage frequency.
4.2.3.2.1 Licensee's Basis vor Reauestina Relief Full stroke
)
exercising of the Safety Injection (SI) pump suction check valves, 1(2)S!8926, cannot be demonstrated during unit operation as the reactor 1
coolant syste pressure prevents the pumps from reaching full flow injection j
l conditions.
Performance of this test with the reactor coolant system intact l
l would lead to an inadverter.t overpressurization of the system.
The I
alternate method of protecting against overpressurization by partial
)
draining of the reactor coolant system (RCS) to provide a surge volume.is l
not considered a safe practice due to concerns of maintaint a adequate water i
level above the reactor core.
\\
As an alternativt the 1(2)S18926 valves will be partial-stroke tested l
i l
durirg periodic inservice tests with the SI pumps in the recirculation l
mode, Full-stroke exercising for these valves will be done during refueling i
f i
31 t
i
Oo Section XI, Paragraph IWV 3412, and proposed to full stroke exercise these valves during refueling outages and during cold shutdowns when the reactor coolant pumps are not in operation.
Valve Identification Function 1(2 CC685 Component cooling supply to reactor coolant pumps 1(2CC9414 Component cooling return from reactor coolant pumps 2 CC9413A 1(
Cumponent cooling supply to reactor coolant pumps 1(2)CC9416 Component co911ng supply to reactor coolant pumps 1(2)CC9438 Component cooling supply to reactor coolant pumps 4.3.1.1.1 Licensee's Basis for Reauestina Relief--Component cooling water flow to the reactor coolant pumps is required at all times while the pumps are in operation and for an extended period of time while in cold shutdown.
Failure of one af these valves in a closed position during an exercise test would result in a loss of cooling flow to the pumps and eventua1 pump damage and/or trip.
As an alternative, these valves will be exercised during cold shutdown,.
provided all of the reactor coolant pumps are not in operation. This testing period will be each refueling outage as a minimum, but no more frequently than once per quarter. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
4.3.1.1.2 Evaluation--These valves provide cooling water flow to the reactor coolant pumps, it is impractical to exercise these valves quarterly during operations, or during cold shutdowns when the reactor coolant pumps are in operation, since failure of one of these valves in the closed positicn could result in pump damage. The Itcensee's proposal, to exercise these valves during cold shutdowns when all the reactor coolant pumps are stopped and during refueling outages, provides a reasonable alternative to the Code requirements.
33
{
sections of piping, etc., and would be burdensome to the licensee to perform during cold shutdowns. The NRC staff position is that relief may be granted from the Code required testing frequency for check valves inside containment whose closure function can be "erified only by leak testing which is l
routinely performed at refueling outages. The licensee's proposal to verify i
this valves closure during leak testing per IWV 1420 provides a reasonable alternative to the Code requirements.
r Based on the impracticability of r.omplying with the Code requirements, the burden on the lic:nsee if the Code requirements were imposed, and the licensee's proposed testing frequency, relief should be f
granted as requested.
t i
4.4 Chemical and Volume Control System l
4.4.1 Cateoory A Valves 4.4.1.1 Relief Reauest. The licensee has requested relief from i
exercising valves 1(2)CV8100 and 1(2)CV8112, reactor coolant pumps' seal water returns, in accordance with the requirements of section XI, Paragraph IWV 3411, and proposed to full-strake exercise these valves during cold shutdowns when the reactor coolant pumps are not in operation and during refueling outages.
4.4.1.1.1 Licensee's Basis for Reauestina Pelief These valves cannot be tested during unit operation as seal water flow to the reactor coolant pumps is required at all times while the pumps are in operation.
Failure of one of these valves in the closed position during an exercise test would result in seal water return flow being diverted to the pressurizer relief tank (PRT) by lifting a relief valve upstream of the isolation valves.
As an alternative, these valves will be extreise tested during cold shutdown, providing all reactor coolant pumps are not in operation. This testing period will be each refueling outage as a minimem, but no more 35 i
o.
l instruments and valves inside the containment butiding. Stroke exercising of these valves would be impractical because if these valves failed in the
~
closed position during unit operation, instrumentation would not function properly and valves would stroke to their failure position, causing the loss
[
]
of support equipment and possibly a reactor trip.
[
i f
As an alternative, these valves will be exercised during cold shutdown, providing that all necessary equipment required for cold shutdown operations would not be affected. This testing period will be each refueling outage as l
j a minimum, but no more frequently than once per quarter. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
l 4.5.1.1.2 Evaluation -Exercising valves 1(2)lA055 and 1(2)lA066 quarterly during power operation is impractical because the loss of instrument air could seriously disrupt normal valve operations tnd possibly result in a reactor trip. The licensee's proposed alternate frequency, to j
full-stroke exercise these valves during cold shutdowns, when affected
(
equipment is not necessary, and during refueling outages, is not clearly i
defined and could bo interpreted in a non conservative man'ier, and l
therefore, is not a reasonable alternative to the Code requirements.
Further, the licensee has not provided a technical discussion to demonstrate j
~
the impracticality of performing this testing on a cold shutdown frequency.
{
i Since the licensee has not demonstiated that cold shutdown testing is impractical, relief should not be granted as requested.
l l
4 4.6 Diesel Generatina Syst e 4
I t
4.6.1 CA.tecorv BSc valves
[
I 4.6.1.1 Relief Recuest. The licensee has requested relief from i
l testing valves 1(2)DG5182A 0, 1(2)DG5183A D, 1(2)DG5184A-0, and 1(2)DG5185A-D, diesel generator air start valves, in accordance with the l
37 g
I 1
l 1
i.
will compare the air pressures contained in the receiver tanks both before and after the diesel generator start, thus verifying the operability of the air start control valves. The proposed testing methodology at the increased frequency satisfies the intent of the Section X! requirements without posing undue haidships or difficulties.
4.6.1.1.2 Evaluation Due to the short stroke times and the system application of these solenoid operated valves, it is impractical to obtain a direct stroke time measurement without significant system design changes. These valves function to admit starting air to the emergency diesel generators and the failure of one of these valves to open in a timely manner would be indicated by a pressure imbalance between the starting air receivers, and possibly, an increase in diesel generator start time.
Further, the Byron Station emergency diesel generators arc tested monthly rather than quarterly. The licensee's proposal to verify valve operability, by e.omparison of the air pressures inside the starting air receivers before anc immediately after diesel start each month, should furnish timely indica *. ion should degradation of these valves occur and provides a reasonable alternative to the Code requirements.
Based on the impracticability of the Code requirements, the burden on the licensee if the Code requirements were imposed, and the licensee's proposed alternate testing method and increased testing frequency, relief should be granted as requested.
4.7 Essential Service Water System 4.7.1 Cateaory B Valves 4.7.1.1 Relief Recuest. The licensee has requested relief from testing valves 1(2)SX101A, service water valves from the auxiliary feedwater pump lube oil coolers, in accordance with the requirements of Section XI, Paragraphs IWV-3413 and 3417, and proposed to verify valve operability during quarterly auxiliary feedwater pump surveillance testing, i
1 1
39
s 4.8 All Systems 4.8.1 Cateaory A Valves 4.8.1.1 Relief Reauest. The licensee has requested ralief from seat leakage measurements for all Unit 1(2) containment isolation valves in accordance with the requirements of Section XI Paragraph IWV-3420, and proposed to seat leakage test these valves in accordance with the requirements of 10 CFR 50, Appendix J.
4.8.1.1.1 Licensee's Basis for Reauestina Relief Primary containment isolation valves will be seat leik tested in accordance with a
For these valves Stction'XI testing requirements are essentially equivalent to those of Appendix J.
As an alternative, primary containment isolation valves will be seat leak tested in accordance with the Appendix J requirements of 10 CFR 50. No additional information concerning valve leakage would be gained by performing separate tests to both Section XI and Appendix J.
Therefore, overall plant safety is not affected.
4.8.1.1.2 Evaluation -The leak test procedures and requirements for containment isolation valves identified in 10 CFR 50, Appendix J essentially meet the Section XI Code requirements since it incorporates all the major elements of Paragraphs IWV 3421 through 3425 however, the 10 CFR 50, Appendix J, leak rate testing coes not trend leakage rates or take corrective actions based on individual valv0 leakage rates. Testing the containment isolation valves in accordant.e with 10 CFR 50, Appendix J, provides a reasonable alternative to the requirements of Section XI, Paragraphs IWV 3421 through 3425, however, the Itcensee must comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs
!WV 3426 and 3427, in order to obtain this relief.
Based on the determination that leak testing the containment isolation valves in accordance with the requirements of 10 CFR 50, 41
- O 4.8.2.1.1 Licensee's Basis for Reauestino Relief Minor timing inaccuracies, with small stroke times can lead to substantial increases (percent wise) in stroke times. For example, a valve with a stroke time of I second in an initial test, and 1.6 seconds in the subsequent test, has experienced an apparent 60% increase in stroke time.
If the accuracy requirements of IWV 3413(b) are utilized, it could be argued that stroke times between 1 and 2 seconds could constitute as much as a 100% increase in stroke time when, in fact, only a 0.2 second increase occurred. For instance, if the initial time was 1.4 seconds, (measured to the nearest second is 1.0 second) and if the next time is then 1.6 seconds, (measured to the nearest second is 2.0 seconds) the percent increase is 100*..
As an alternative, fast acting valves will be defined as those valves that normally stroke in 2 seconds or less. Data will be analyzed utilizing the g'Jidance set forth in IWV 3413(b). No trending of stroke time will be required, unless the 2 second fast acting time is exceeded. Upon exceeding 2 seconds, the test frequency shall be increased to monthly and trending of stroke times shall begin, until corrective action is taken, or the stroke time returns to less than or equal to 2 seconds. Upon~ exceeding the maximum stroke time lisc.J in the valve program tables for the above valve, con ective : tion shall be taken imediately in accordance with IWV 3417(b).
For small stroke times, the trending requirements are too stringent for the accuracies specified in the Code. The alternative specified will adeqeately maintain the system in a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
4.8.2.1.2 (valuation The Code requires the comparison of power operated valve stroke times from test to test.
For valves with short stroke times this comparison cay not be practical since a slight (.2 secono) change in stroke time may call for an increased frequency of testing though no degradation in stroke time has occurred (for valves with short stroke times the difference from test to test may be introduced by the timing method or the operator). Placing a maximun limiting stroke time of 2 seconds en the 43
g' O$
O e
APPENDIX A e
e G
+
(
6
(
n.
3 APPENDIX A VALVES TESTED DURING COLD SHUTDOWN The following are Category A, 8, and C valves that meet the exercising requira.ments of the ASME Code,Section XI, and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner in accordance with Paragraphs IWV 3412 and 3522 and 1re full-stroke exercised during cold shutdowns and refueling outages. All valves in this Appendix have been evaluated and the reviewer agrees with the licensee that testing these valves during power operation is not possible due to the valve type, location, or system design. These valves should not be full stroke exercised during power operations. These valves are listed l
below and grouped according to the system in which they are located.
1.
MAIN STEAM SYSTEM 1
1.1 Cateoory B Valves The closure of the main steam isolation valves, 1(2)M5001A 0, during i
unit operation would result in a reactor trip and safety injection actuation. To avoid this transient, these valves will be part stroke l
exercised every three months and full stroke exercising will be done during i
Mode 4 following, or preceding cold shutdown, per IWV 3412.
i 2.
THEMICAL AND VOLUME CONTROL SYSTEM i
s 2.1 Cateaory A and B Valves Closure of these letdown and makeup valves,1(2)CV112 B and C, 1(2)CV8105,1(2)CV8106,1(2)CV8152,and1(2)CV8160,duringnormalunit operation would cause a loss of charging flow which would result in a reactor coolant inventory transient, and possibly, a subsequent reactor trip. These valves will be full stroke exercised during cold shutdown as required by IWV 3412.
{
47 J
1
a-e.
5 i
flow. This would result in undesirable affects on the steam generators.
[
These valves will be full stroke exercised during cold shutdown as required l
by IWY-3412.
i 4.
RESIDUAL HEAT REMOVAL SYSTFM
[
i 4.1 Cateaory A Valves The 1(2)RH8701A and B and the 1(2)RH8702A and B valves are the isolation boundary between the residual heat removal (RHR) pumps and the RCS. Opening one of these valves during unit operation wil'. leave only one valve isolattag RHR from the high RCS pressure. This would place the plant in an undesirable condition. Therefore, these valves'will be full stroke exercised during cold shutdown, per IWV 3412.
i 4.2 Cateaory C Valves i
The residual heat removal pump discharge check valves, 1(2)RH8730A l
and b, cannot be full stroke exercised during unit operation due to the high
[
RCS pressure. These check valves will be part stroke exercised, however, on a quarterly basis and full stroke exercised during cold snutdown in accordance with IWV 3522.
3 5.
j
[
5.1 Cateoory B Valves i
l The reacter pressure vessel vent valves, 1(2)RC014A 0, cannot be stroke exercised during unit operation as they provide a pressure boundary between I
the reactor coolant systra and containment atmosphere. Failure of one of I
these valves in the open position would result in leaving only one valve as the high pressure boundary. These valves will be full stroke exercised when the RCS pressure is at a minimum during cold shutdown, per IWV 3412.
49
(
- m
[
I l **
l 2
i plant transient. These valves will be full stroke exercised during cold shutdown in accordance with IWV 3412.
i ThesafetyinjectionsystemSVAG(spuriousvalveactiongroup) valves, i
1(2)S18802A and 8, 1(2)$18806, 1(2)SI8809A and B, 1(2) SIB 813, 1(2)S18835, I
l and 1(2)$18840, cannot be full or part stroke exercised during unit operation. These valves are required by the Technical Specifications to be l
de energized in their proper positions during unit operation.
Stroking them would be a violation of the Tachnical Specifications as well as defeating the de energized SVAG valve principle. These valves will be full stroke
}
exercised during cold shutdown in accordance with IWV 3412.
8.2 Cateaory C Valves l
[
The check valves listed below cannot be full stroke exercised during operation as the the RHR pumps discharge pressure is significantly below that of the RCS operating pressure and flow cannot be established. These valves will be full stroke exercised during cold shutdown in accordance with IWV 3522.
Valve Identification Function L
1(2)S!8818AthruD RHR cold leg injection checks 1(2)$18958A and B RWST to RHR pump suction checks
[
t t
t i
l I
h t
51 l
l I
(~
e O
o be s
e e
J P
APPENDIX 8 I
I 53
i t e.
t APPENDIX B The 151 Boundary Drawings listed below were used during the course of this review.
System Drawina No.
Revision Main Feedwater M 36 1 Y
Auxiliary Feedwater M 37 AA Essential Service Water M 42 1 Y
Essential Service Water M 42 3 AB Essential Service Water M 42 5 T
Containment Spray M 46 A0 Offgas System Hydrogen Recombiners M 47 2 H
Waste Disposal Steam Generator Blowdown M 48 5 V
Waste Disposal Steam Generator Blowdown M 48 6 W
Make up Demineralizer M 491 U
Diesel fuel oil M 50 1 AC Fire Protection (Category 1)
M 52 1 N
Service Air M 54 2 N
Instruent Air M 55 2 T
Diagram of Reactor Ceolant Loop l M 60 1 A0 Diagram of Reactor Coolant M 60 5 V
Diagram of Reactor Coolant M 60 6 T
Safety injection M 61 1 AE Safety Injection M 61 2 Z
Safety injection M 61 3 V
I Safety injection M 61 4 U
Safety injection M 61 5 L
Safety Injection M 61 6 U
Residual Heat Removal H 62 AF fuel Pool Cooling and Clean up M 63 AK Chemical and Volume Control and M 64 1 Y
Boron Thereal Regeneration i
55
ao o
e o
e APPENDIX C t
i I
i I
r I
9 e
l l
i l
57
- q. r to APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Inconsistencies and omissions in the licensee's program noted during the course o' this review are sumarized below. The Itcensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
1.
The Boric Acid Transfer pumps 0AB03P, IAB03P, and 2AB03P are included in Byron Station FSAR, Table 3.9 15, as Active Pumps.
Paragraph 3.9.6.1, inservice Testing of Pump:, states that all pumps included in Table 3.9 15 require inservice testing.
Therefore, the Boric Acid Transfer pumps should be included in the Byron Station IST program and tested to the Code requirements.
2.
The reviewer agrees with the basis of pump relief requess PR 1 for all pumps, however, the essential service water make up oumps, OSX02pA and B, must have corrective action taken in accordance with the requirements of IWP 3230 when the vibration velocity measurements exceed.70 inches per second (see TER section 3.2.1),
3.
Pump relief request PR-3 (see TER section 3.1.1) proposes to evaluate the essential service water makeup pumps, 05X02PA and B.
util.tzing pump discharge pressure. Some method can and should be utilized to determine the pump inlet pressure (i.e., reasurement of the head of water above the pump suction) for calcu?ation of pump dif ferential pressure and evaluation of the pump's hydraulic performance.
4.
The licensee has included the power operated relief valves (PORVs) in their IST program as Category B valves and proposed to exercise these valves quarterly. The NRC staff's position is that the PORVs should be exercised prior to achieving the condition which 59
% a le frequency and has not provic'ed the conditions under which this testing will be performed this relief request should be denied.
9.
Valve relief request VR It (Sco TER section 4.8.2.1) addresses i
rapidactingvalves(i.e.,valvesthatnormallyoperatein2 i
seconds or less), however, the IST program valve list identifies
~
maximum stroke times for these valves of from 2 to 15 seconds.
If l
a maximum stroke time of 2 seconds has been placed on these valves l
then it should be reflected la the maximum stroke time section of the IST program valve list.
J W.her, the Itcensee's proposal to assign a fast-acting limit n >,econds and upon exceeding tnis limit to.acrease the test frequency to monthly and to trend the stroke times does not provide a reasonable alternative to the Code L
requirements,
)
i
- 10. Valve relief request VR 15 (ses TER section 4.2.1.3), r es to q
full-stroke exercise valves 1(.!)$18815, 1(2)S18841A and B, and l
1(2)$18900A D on a conditional basis during cold shutdowns.
[
i however, the conditions under which this testing are to take place
}
are not clearly defined. Furtter, in the absence of evidence to r
demonstrate exereiring these valves on a cold shutdown frequency i
is impractical, relief should not be granted, f
{
- 11. Valve relief reqvest YR 16 (see TER section 4.2.2.1) proposes to full stroke exercin the containment sump outlet isolation valves, l
1(2)518811A and 8. during refue' ling outages. The licensee has not
[
demonstrated the impracticality of performing this testing on a cold shutdown frequency and this reitef request should be denied.
r
- 12. Valve relief request VR 17 (see TER section 4.7.1.1) proposes to exercise valves 1(2)5X101A during monthly surveillances on the f
motor driven auxiliary feedwater purp lube oil coolers, however, I
4 l
the licensee has not described the testing method that will verify
)
valve operability. A regional inspector and/or NRR reviewer should verify that this testing verifies the operability of this valve.
l 0
p i
61 i
. Oi lo a
.. m e....s,.., ~..
......,,, u e.... w u y3,*o.. sa c.
'l';'.N;"
slBUOGRAPHIC DATA SHEET EGG-NTA-8051
......+. c o..
........a...,..
. u......
TECHNICAL. EVALVATION P2 PORT. PUM9 AND VALVE INSERVICE TESTING PROGRAM BYRON STATION UNITS 1 AND 2
...<....:..u........
s.+.
.. 4 g
June 1988 R. S. Hartley
. a... m.'.....
4..
H. C. Rockhold 1938 June
.2..
.,e
.........v...u......
....;,,n:......,......
Mechanical Systems Evaluaticns Unit EGAG Idaho. Inc.
- s..
7s..c.
P. O. Box 1625 Idaho Falls 10 83415 A6812 9,u...o.
4...
4.;;.......
Mechanical En ineering Branch Tectntical Evaluation Report Office of Nuc ear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, DC 20555
..........w,..
...w. 4, u This EG5G Idaho. Inc. report presents the results of our evaluation of the Dyron Station. Units 1 and 2. Inservice Testing Program for pumps and valves that perf 3m c safety-related function.
- .,.,.3,.,..
,s..................:.....w...;..
Unlimited
..............T,'
~
'. :...... e.....a'i.
Unclassified
~~
Unclassified
......:...;o i.
4.
. e ee