ML20195D417
| ML20195D417 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/27/1986 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20195D410 | List: |
| References | |
| NUDOCS 8606040201 | |
| Download: ML20195D417 (47) | |
Text
.
ENCLOSURE 2 SAFETY EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM LA SALLE COUNTY STATION UNIT 1 DOCKET NO. 50-373 ACKNOWLEDGEMENT This safety evaluation report was prepared with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idaho, Inc.) under contract to the U.S. Nuclear Regulatory Commission.
8606040201 860527 PDR ADOCK 05000373 P
CONTENTS P_ age 1.
INTRODUCTION....................................................
1 2.
PUMP TESTING PROGRAM............................................
2 2.1 All Pumps in the IST Program...............................
2 2.2 ECCS Water Leg Pumps.......................................
3 2.3 Diesel Fuel Oil Transfer Pumps.............................
4 2.4 Standby Liquid Control Pumps...............................
4 2.5 Pump Instrumentation.......................................
5 3.
VALVE TESTING PROGRAM...........................................
8 3.1 General Considerations.....................................
8 3.1.1 Exercising Check Valves.............................
8 3.1.2 Valves Identified for ',old Shutdown Exercising......
8 3.1.3 Con 'itions for Valve lesting During Cold Shutdowns...........................................
9 3.1.4 Application of Appendix J Testing to the IST Program.............................................
9 3.1.5 Valves Important to Safety..........................
9 3.1.6 Valves Which Perform a Pressure Isolation Function............................................
9 3.2 All Systems................................................
10 3.2.1 Rapid-Acting Valves.................................
10 3.2.2 All Primary Containment Isolation Valves............
10 3.2.3 Corrective Action...................................
11 3.2.4 Category A/C Excess Flow Check Valves...............
12 3.3 Diesel Generator...........................................
13 3.3.1 C a t e g o ry B Va l v e s...................................
13 3.4 Feedwater..................................................
14 3.4.1 Category A/C Valves.................................
14 3.5 High Pressure Core Spray...................................
15 3.5.1 Category B Valves...................................
15 3.5.2 Category C Valves...................................
16 l
iii
i Page_
3.6 Drywell Instrument Nitrogen.................................
17
)
3.6.1 Category A Valves....................................
17 3.6.2 Category C Valves....................................
19 i-3.7 Main Steam..................................................
21 3.7.1 Ca tego ry A Va l v e s....................................
21 i
3.7.2 Category B/C Valves..................................
22 j
3.7.3 Category C Valves....................................
23 1
3.8 Control Rod Drive...........................................
24 j
3.8.1 Category B Valves....................................
24 3.8.2 Category C Valves....................................
26 4
3.9 Residual Heat Removal.......................................
27 3.9.1 Category B Valves....................................
27 3.10 Reactor Core Isolation Cooling..............................
28 3.10.1 Category C Valves....................................
28 t
3.11 Standby Liquid Control......................................
28 I
3.11.1 Category A/C Valves..................................
28 3.11. 2 Ca tego ry B Va l ve s....................................
29 3.11. 3 Catego ry C Va l ve s....................................
30 3.12 Primary Containment Ventilation.............................
31
]
3.12.1 Category A Valves...................................
31 APPENDIX A............................................................
33 l
1.
CODE REQUIREMENTS--VALVES....................................
33
(
2.
CODE REQUIREMENTS--PUMPS......................................
33 ATTACHMENT B..........................................................
34 i
ATTACHMENT C..........................................................
35 1
j 1.
FEEDWATER....................................................
35 1.1 Category A Valves.......................................
35 4
3 2.
HIGH PRESSURE CORE SPRAY....................................
35 2.1 Category A/C Valves.......'.............................
35 1
iv 1
4 s
w,~ ~ -,,,,n,---wm-er,nv
,-n,-ev ~
-,--~een_em,,y
--,-,,w,,,,,,----,-,-.<--e.-a_.,----+-~.-,,-m,-
-w.---
gr
-m~--
-m-
\\
.Page 3.
LOW PRESSURE CORE SPRAY.....................................
35 i
3.1 Category A Valves......................................
35 3.2 Ca tego ry A/C Va l ve s....................................
36 4.
MAIN STEAM..................................................
36 4.1 Category A Valves......................................
36 4.2 Category B Valves......................................
36 5.
RESIDUAL HEAT REMOVAL.......................................
37 5.1 Category A Valves......................................
37 5.2 Category A/C Valves....................................
38 6.
REACTOR CORE ISOLATION COOLIN3..............................
38 l
i j
6.1 Category A Valves.....................................
38 6.2 Category A/C Valves....................................
39 1
l 7.
REACTOR WATER CLEANUP.......................................
39
{
7.1 C a te go ry A Va l v e s......................................
39 l
8.
PRIMARY CONTAINMENT PURGE...................................
39 8.1 Ca tego ry A Va l v e s......................................
39 f
9.
REACTOR BUILDING CLOSED COOLING WATER.......................
40 9.1 Category A Valves......................................
40 ATTACHMENT D..........................................................
41 J
!I l
1 i
i V
i
.,. __. -..... _ _ _ _......., _ ~ ~, - - _ _ - - _ _ _ _ _ -,
SAFETY EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM LA SALLE COUNTY STATION, UNIT 1 DOCKET NO. 50-373 1.
INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Commonwealth Edison Company for its La Salle County Station, Unit 1.
The working session with Commonwealth Edison Company and L-Salle, Unit 1, representatives was conducted on September 14, and 15, 1982.
The licensee's resubmittal dated February 18, 1983, including subsequent revisions to the program through October 11, 1985, were reviewed to verify compliance of proposed tests of Class 1, 2, and 3 pumps and valves whose function is impor-tant to safety with the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition, through the winter of 1980 Addenda.
In their resubmittal Commonwealth 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 whether they have significant risk impli-cations and whether the tests, as required, are indeed impractical.
The evaluations in this Safety Evaluation Report of the La Salle County Station, Unit 1, pump and valve inservice testing program and the associated relief requests were prepared by the NRC staff with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idaho, Inc.).
A summary of pump and valve Section XI testing requirements is provided in Appendix A of this report.
Valves that perform a containment isolation fur.ction but are not leak tested in accordance with Appendix J requirements are listed in Attachment B.
These valves should have been included in the IST program but were omitted by the licensee.
Appendix B also identifies full flow test valves that should have been included in the IST program but were omitted by the licensee.
Category A, B, and C valves that meet the requirements of the ASME Code,Section XI, and are not exercised quarterly are addressed in Attachment C.
A listing of P& ids used for this review is contained in Attachment D.
The IST program and the Technical Specifications should be in full agree-ment.
If a conflict is identified, the licensee shall comply with 10CFR50.55a (g)(5)(ii).
The Technical Specifications must be strictly and fully complied with until the amendment is approved by the NRC Staff.
1
k i
I 2.
PUMP TESTING PROGRAM
+
i l
The La Salle Unit 1, IST program submitted by Commonwealth Edison Company (licensee) was examined to verify that all Class 1, 2, and 3 pumps whose func-tion is safety related are included in the program and are subjected to the periodic tests required by the ASME Code,Section XI.
Our review found that these pumps are tested in accordance with Section XI i
except for those pumps identified below for which specific relief from testing has been requested.
Each Commonwealth Edison Company basis for requesting relief from the pump testing requirements and the NRC staff evaluation of that request is summarized below.
2.1 All Pumps in the IST Program i
2.1.1 Relief Request J
The licensee has requested specific relief from measuring bearing tempera-ture on all pumps in the IST program in accordance with the requirements of
]
Section XI and proposed to delete behring temperature measurements.
]
2.1.1.1 Code Requirement.
Refer to Appendix A of this report.
l 2.1.1.2 Licensee's Basis for Requestinc Relief.
Eeoring temperature measurements will not provide significant adcitional information regarding bear-ing condition than that already obtained by measuring vibration amplitude.
Measurement of vibration amplitude provides more concise and consistent infor-mation with respect to pump and bearing. condition.
The use of vibration ampli-3 tude measurements can provide information as to a change in the balance of i
rotating parts, misalignment of bearings, worn bearings, changes in internal i
hydraulic forces, and general pump integrity prior to the condition degrading i
to the point where the component is jeopardized.
Bearing temperature does
)
not always predict such problems.
An increase in bearing temperature most l
often does not occur until the bearing has deteriorated to a point where addi-tional pump damage may occur.
Bearing temperatures are also affected by the temperatures of the medium being pumped, which could yield misleading results.
Vibration readings are not affected by the temperature of the medium being pumped, thus the readings are more consistent.
i 2.1.1. 3 Evaluation. We agree with the licensee's basis and, therefore, i
feel that relief should be granted from the requirement of Section XI of meas-uring bearing temperature annually for all pumps in the IST program.
The 1
licensee has demonstrated that annual bearing temperature measurement is an unreliable method of de'.ecting bearing failure and we feel that deletion of this measurement will not affect the licensee's pump monitoring program.
j 2.1.1.4 Conclusion. We conclude that the licensee's proposal to meas-ure all pump parameters, except bearing temperature, should be sufficient to monitor pump degradation.
Based on the considerations discussed above we con-clude that the alternate testing proposed will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
l r
i 2
t
2.1.2 Relief Request The licensee has requested specific relief from measuring vibration ampli-tude on all pumps in the IST program in accordance with the requirements of Section XI and proposed to measure vibration in units of velocity.
2.1.2.1 Code Requirement.
Refer to Appendix A of this report.
2.1.2.2 Licensee's Basis for Requesting Relief.
Portable vibration moni-toring equipment allowing for the measurement of vibration velocity in inches per second is available at the plant site.
This measurement gives a more accur-ate determination of abnormal vibrations at frequencies other than shaft rota-tional speed.
The results of this testing will be evaluated using the " General Machinery Severity Chart" published by IRD Mechanalysis, Inc.
The alert range will be:
.314 in/sec. 1 V i.628 in/sec.
The required action range will be:
V >.628 in/sec.
2.1.2.3 Evaluation.
We agree with the licensee's basis in that vibration velocity measurements are superior to displacement vibration amplitude measure-ments for monitoring pump degradation; however, the proposed acceptance criteria for the vibration velocity measurements are not adequate to ensure proper corrective actions are taken if pump degradation occurs.
2.1.2.4 Conclusion. We conclude that relief should be granted from the requirements of Section XI for measuring displacement vibration amplitude for all pumps in the IST program and the licensee's alternate proposal of using vibration velocity measurements should be used.
Alternate acceptance criteria for vibration velocity measurements developed by the NRC staff in Table 2.1.2-1, should be used to replace the acceptance criteria proposed by the licensee.
This would result in necessary corrective actions being taken to ensure proper operability of the pumps in the IST program.
The IST program should be revised accordingly.
2.2 ECCS Water Leg Pumps 2.2.1 Relief Request The licensee has requested specific relief from measuring flow on the following water leg pumps: 1E22-C003, high pressure core spray, 1E21-C002, low pressure core spray,1E12-C003, residual heat removal, and 1E51-C003, reactor core isolation coolant, in accordance with the requirements of Section XI.
2.2.1.1 Code Requirement.
Refer to Appendix A of this report.
2.2.1.2 Licensee's Basis for Requesting Relief.
Flow is not a signiff-cant 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.
3' Because the design basis of the water leg pumps is maintenance of pressure, this is the parameter that will be considered for inservice testing.
3
2.2.1.3 Evaluation.
We agree with the licensee's basis and, therefore, conclude that relief should be granted from the Section XI requirement to measure flow on the water leg pumps for the high pressure core spray, low pressure core spray, residual heat removal, and reactor core isolation coolant systems.
The licensee has demonstrated that these pumps run against a shutoff head to maintain the discharge line of their associated system pressurized and very little, if any, flow occurs.
For this reason, we feel that verification of the proper pressure in the discharge lines of the associated system is an adequate demonstration of the operability of these water leg pumps.
2.2.1.4 Conclusion.
We conclude that 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.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of pump function intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
2.3 Diesel Fuel Oil Transfer Pumps 2.3.1 Relief Request The licensee has requested specific relief from measuring inlet pressure, differential pressure, discharge pressure, and flow rate on pumps 00001P, 10001P, and 10002P, diesel fuel oil transfer, in accordance with the require-ments of Section XI and proposed to calculate the flow rate of these pumps.
2.3.1.1 Code Requirement.
Refer to Appendix A of this report.
2.3.1.2 Licensee's Basis for Requesting Relief.
The purpose of these pumps is to move fue', oil into the day tank approximately ten times faster than the diesel engine consumption rate.
The exact flow characteristic of these pumps is not significant.
Also, there is no definable output pressure require-ment.
For there reasons, the best method of determining degradation trends in pump performance is to measure the flow rate by measuring the time it takes to increase to a certain level in the day tank.
2.3.1.3 Evaluation.
We do not agree with the licensee's basis and, therefore, feel that permanent relief should not be granted from the pump testing requirements of Section XI for pumps OD001P,10001P, and 10002P.
We agree that calculating the flow rate of these pumps may be the only pump monitoring possible due to the current system design and the absence of instrumentation.
2.3.1.4 Conclusion.
We conclude that the licensee should perform the l
necessary modifications to the diesel fuel oil transfer pumps prior to the end of the next refueling outage in order to test these pumps in compliance with Section XI requirements.
For the balance of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by the licensee.
Requiring the licensee to make these modifications prior to the next refueling 1
outage would impose unrecessary hardship on the licensee without compensating i
increase in the level of safety.
Taking into account the inservice tests that will be performed as well as the relatively short operational time until the next refueling outage, it is concluded that this interim relief will not endanger life or property or the common defense and security of the public.
l f
4
= _ _
2.4 Standby Liquid Centrol Pumps 2.4.1 Relief Request The licensee has requested specific relief from measuring inlet pressure i
and differential pressure on pumps 1C41-C001A and 1C41-C001B, standby liquid control, in accordance with Section XI.
2.4.1.1 Code Requirement.
Refer to Appendix A of this report.
2.4.1.2 Licensee's Basis for Requesting Relief.
During pump testing, l
the 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 l
correlate tank level to inlet pressure.
These pumps are positive displacement, therefore, the measurement of inlet pressure is not significant in judging pump performance.
Measuring the discharge pressure and the flow rate is adequate j
to detect changes in the hydraulic characteristics of the pumps.
2.4.1.3 Evaluation.
We agree with the licensee's basis and, therefore, feel that relief should be granted from the Section XI requirement to measure inlet pressure and differential pressure on pumps 1C41-C001A and 1C41-C0018.
These pumps are positive displacement pumps, therefore, changes in the inlet i
pressure have no effect on the discharge pressure or the flow rate of the pumps.
For this reason, we feel that calculating or measuring inlet pressure and differential pressure would not contribute meaningful data to utilize in monitoring pump degradation.
2.4.1.4 Conclusion. We conclude that the proposed alternate testing of
}
measuring pump discharge pressure and flow rate should provide sufficient information to adequately monitor pump degradation.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
2.5 Pump Instrumentation 2.5.1 Relief Request The licensee has requested specific relief from the pump instrumentation i
full-scale range requirements of Section XI for pumps 1E12-C002A, 1E12-C002B, 1E12-C002C, and 1E12-C003, residual heat removal and residual heat removal j
water leg, suction pressure gages and proposed to utilize existing i
instrumentation in the pump monitoring program.
I 2.5.1.1 Code Requirement.
The full-scale range of each instrument shall be three times the reference value or less.
(IWP-4120) 4 2.5.1.2 Licensee's Basis for Requesting Relief.
The reference values t
for the inlet pressures of the residual heat removal pumps A, B, and C are all l
P, h > psig.
> 7.5 The reference value of the in5et pressure of the water leg pump is 8 psig.
The full-scale range of the jnlet pressure gages for all four pumps, reads 0-250 psig.
The inlet pressure fc:r these pu.nps may attain a maximum pressure of 200 psig, therefore, gages with larger scale ranges are required to accommodate rises of pump suction pressure.
t i
l i
2.5.1.3 Evaluation. We agree with the licensee's basis and feel that relief should be granted from the instrumentation range, requirements therefore, i
of Section XI for pumps 1E12-C002A, 1E12-C002B, 1E12-C0020, and IE12-C003.
feel that the range of the existing pump instrumentation should We ciently accurate data to utilize in the pump monitoring program. provide suffi-agree with the licensee's use of wider range instrumentation in the applica-We also l
tions identified above to prevent instrument damage or inaccuracies due to overranging.
1 2.5.1.4 Conclusion.
existing instrumentation whose range is greater than 3 times refer should provide sufficient meaningful data to adequately monitor pump degradation.
Based on the considerations discussed above we conclude that alternate testing proposed will give reasonable assuran j
property or the common defense and security of the public.
4 2.5.2 Relief Request The licensee has requested specific relief from the pump instrumentation full-scale range requirements of Section XI for pump 1E22-C001, high pressure i
t core spray, suction pressure gage and proposed to utilize existing instrumentation in the pump monitoring program.
j 2.5.2.1 Code Requirement.
be three times the reference value or less.The full-scale range of each instrument shall (IWP-4120) 1
- 2. 5. 2. 2 Licensee's Basis for Requesting Relief 4
the inlet pressure of the high pressure core spray pu. The reference value for water from the suppression pool and 17.5 psig when drawing water from themp is 8 condensate storage tank.
i
-30" Hg to 100 psig, or about a 115 psig range.The full-scale range of the inl The range is necessary due to the configuration of this system because when the high pressure core spray pum i
is being stopped there is a spike in the suction pressure.
Such a pressure spike causes a su,ction pressure indicator with a smaller range to go out of l
calibration.
Therefore, a suction pressure gage with a larger scale is needed to enable the gage to remain in calibration due to the pressure spikes.
2.5.2.3 Evaluation.
We agree with the licensee's basis and therefore, feel that relief should be granted from the instrumentation range, requirements of Section XI for pump 1E22-C001.
We feel that the range of the existing instrumentation should provide sufficiently accurate data to utilize in the i
pump monitoring program.
instrumentation in this application to prevent instrument damage orWe j
inaccuracies due to overranging.
2.5.2.4 Conclusion. We conclude that the licensee's proposal to utilize existing instrumentation whose range is greater than 3 times reference value should provide sufficient meaningful data to adequately monitor pump i
degradation.
Based on the considerations discussed above we conclude that the i
alternate testing proposed will give reasonable assurance of pump operability 1
intended by the Code and that the relief thus granted will not endanger life i
or property or the common defense and security of the public.
A.
l 6
I
l TABLE 2.1.2-1 ALLOWABLE RANGES OF VIBRATION VELOCITY FOR PUMP TESTING PER SUBSECTION IWP Test i
Band No.
Test Quantity Acceptable Range Alert Range Required Action Range i
1 V When 01Vrl10.05 in/sec 0 to.075 in/sec 0.075 to.1 in/sec
>0.1 in/sec t
2 V When 0.05 in/sec 0 to.15 in/sec 0.15 to 0.2 in/sec
>0.2 in/sec I
t IVr 1 1 in/sec 2
l 3
V When.1 in/sec 0 to 0.2 in/sec 0.2 to 0.25 in/sec
>0.25 in/sec t
IVr 1 15 in/sec 3
4.
V When.15 in/sec 0 to 0.285 in/sec 0.285 to 0.314 in/sec
>0.314 in/sec t
IVr 1 25 in/sec 4
Definitions:
V = Reference velocity measurement (in/sec filtered peak)
V[=Surveillancetestvelocitymeasurement(in/secfilteredpeak)
Note:
The frequency response range of the vibration measuring transducers and their readout system shall be from one-half minimum pump shaft rotational speed to speed to at least 1,000 Hertz.
an.-
w-e m
e-ye--
-s--7 y
w T
3.
VALVE TESTING PROGRAM was examined to verify that Class 1, 2, and 3 valve
~
required by the ASME Code,Section XI, and the NRC Our review found that, except as noted in this Safety Evaluation Report where Code requirements and the NRC positions and guide and Section 3.1 of this report.
Each Commonwealth Edison Company basis for tion of that request is summarized below and grouped a valve category.
l 3.1 General Considerations 3.1.1 Exercising Check Valves safety function is to open are expected to be full-stroke exe disc position is not always observable, the NRC staff position is that veriff-Since the of the plant's safety analyses would be an adequate dem full-stroke requirement.
Any flow rate less than this will be considered partial-stroke exercising unless it can be shown that the check valve's disc position at the lower flow-rate would permit maximum required flow through the valve.
It is the NRC staff position that this reduced flow-rate method of of the differential pressure across the valve. demonstrating full strok t.
3.1.2 Valves Identified for Cold Shutdown Exercising The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation, and these valves are ccid shutdowns; therefore, the licensee is meeting the req ASME Code.
it is not necessary toSince the licensee is meeting the requirements of the ASME C licensee's IST program, grant relief; however, during our review of the these valves during power operation and that we agree with the licens basis.
It should be noted that the NRC staff differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode.
valves identified for testing during cold shutdowns, it is expected that theThat is, for However, when relief is granted to perform tests on a refue quency, testing is expected only during each refueling outage.
for extended refueling outages, tests being performed are expected to beIn addition, maintained as closely as practical to the Code specified frequencies.
4 I
8
I 4
3.1. 3 Conditions for Valve Testing During Cold Shutdowns Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:
1.
The licensee is to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> af ter shutdown, and continue until complete or the plant is ready to return to power.
i 2.
Completion of all valve testing identified for a cold shutdown frequency is not a prerequisite to return to power.
3.
Any testing not completed during one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to as closely as possible meet the Code specified testing frequency.
4.
For planned cold shutdowns, where ample time is available for testing all the valves identified for the cold shutdown test frequency in the IST program will be completed, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as noted above may be taken.
l 3.1.4 Application of Appendix J Testing to the IST Program 1
The Appendix J review for this plant is completely separate from the IST program review.
However, the determinations made by that review are directly 4
applicable to the IST program.
The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
3.1.5 Safety-Related Valves This review was limited to valves that perform a safety related function.
Safety-related valves are defined as those valves that are needed to mitigate the consequences of an accident and/or to shut down the reactor and to maintain the reactor in a cold shutdown condition.
Valves in this category would l
typically include certain ASME Code Classes 1, 2, and 3 valves and could j
include some non-Code class valves.
It should be noted that the licensee may have included valves whose function is not safety related in their IST program j
as a decision on their part to expand the scope of their program.
4 3.1.6 Valves Which Perform a Pressure Boundary Isolation Function All pressure boundary isolation valves and their classification and i
testing have been previously addressed in the NRC SER for La Salle Unit 1.
1 These pressure boundary isolation valves are individually leak-rate tested by the licensee in accordance with La Salle Unit 1 Technical Specification No. 3.4.3.2 and Table 3.4.3.2-1.
.i 1
9 i
3.2 All Systems 3.2.1 Rapid-Acting Valves 3.2.1.1 Relief Request.
The licensee requested specific relief from the power operated stroke timing requirements of all power operated, rapid-acting valves whose function is safety related in accordance with the requirements of Section XI and proposed to apply a maximum stroke time limit of 5 seconds to all power operated, rapid-acting valves, i.e., those valves with stroke times of less than 5 seconds.
3.2.1.1.1 Code Requirement--If, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 seconds or 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed.
In any case, any abnormality or erratic action shall be reported.
(IWV-3417(a))
3.2.1.1.2 Licensee's Basis for Requesting Relief--These valves are designed to stroke rapidly within a specified time range.
Verification that the valve strokes within the time range is essential, but due to the inaccuracies involved with measuring short time intervals, stroke time trending provides no useful information and may even lead to useless and unnecessary maintenance operations.
Therefore, the stroke times of these valves will not be trended, but will be verified to not exceed 5 seconds.
3.2.1.1.3 Evaluation--We do not agree with the licensee's basis be-cause we do not believe the Code requirements of IWV-3417(a) to be impractical and, therefore, feel that relief should not be granted from the stroke time measurement requirements of Section XI for all power operated, rapid-acting 1
valves whose function is safety related with stroke times of less than 5 sec-onds.
The NRC staff has determined that rapid-acting valves are defined as those valves with stroke times of two seconds or less and that valves with stroke times greater than two seconds should be tested in accordance with the requirements of Section XI.
3.2.1.1.4 Conclusion--We conclude that the licensee should apply the rapid-acting valve definition only to the power operated valves with stroke times of two seconds or less.
The valves that do not fit into this category should be stroke time tested in accordance with the requirements of Section XI.
3.2.2 All Primary Containment Isolation Valves 3.2.2.1 Relief Request.
The licensee has requested specific relief from leak testing all primary containment isolation valves in accordance with the requirements of Section XI and proposed to leak test these valves in accordance with 10 CFR 50, Appendix J.
I I
10
3.2.2.1.1 Code Requirement--Refer to Section XI, IW-3420.
3.2.2.1.2 Licensee's Basis for Requesting Relief--Primary containment, Category A, isolation valves will be seat leak tested and the results analyzed in accordance with Appendix J requirements of 10 CFR 50.
3.2.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the leak testing require-ments of Section XI for all primary containment isolation valves.
All con-tainment isolation valves that are Appendix J, Type C, leak tested have been included in the IST program as Category A or A/C valves.
The NRC staff has concluded that the applicable leak test procedures and requirements for con-tainment isolation valves are determined by 10 CFR 50, Appendix J.
Relief from Paragraphs IWV-3420 through IW-3425 for containment isolation valves presents no safety problem since the intent of IW-3420 through IW-3425 is met by Appendix J requirements, however, the licensee shall comply with Paragraphs IW-3426 and IW-3427.
3.2.2.1.4 Conclusion--We conclude that the proposed alternate method of leak testing containment isolation valves in accordance with the requirements of 10 CFR 50, Appendix J, meets the leak testing requirements of Section XI.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve leak-tight integrity intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.2.3 Corrective Action 3.2.3.1 Relief Request.
The licensee has requested specific relief from the corrective action requirements of Section XI for all valves in the IST program and proposed to utilize plant Technical Specifications to determine initiation of corrective action.
3.2.3.1.1 Code Requirement --If a valve fails to exhibit the required change of valve stem or disc position or exceeds its specified limiting value of full-stroke time by this testing, then corrective action shall be initiated immediately.
If the condition is not, or cannot be, corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared inoperative.
When corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup.
A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.
(IW-3417(b))
If a check valve fails to exhibit the required change of disc position by this testing, corrective action shall be initiated immediately.
If the condition is not, or cannot be, corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the check valve shall be declared inoperative.
When corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup.
A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.
(IW-3523) 11
O 3.2.3.1.2 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 correc-tive actions to be taken when valves fail to exhibit a required change of disc position.
These actions include requirements to take corrective action prior to plant startup should a failure occur during cold shutdown testing.
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 which state the minimum conditions 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 function are declared inoperable as soon as that condition has been verified, not after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period has elapsed.
For the above reasons, La Salle Unit 1 will evaluate the condition of each valve with respect to its safety function ad take the appropriate corrective action as stated in the Technical Specification / Limiting Condition for Operation.
3.2.3.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the corrective action requirements of Section XI, IWV-3417(b) and IWV-3523.
The licensee has demon-strated that a valve is declared inoperable immediately after failure rather than after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as allowed by Section XI and that plant Technical Specifi-cations are utilized to determine the schedule for corrective actions.
Addi-tionally, the La Salle Unit 1, Technical Specifications have been previously reviewed and approved by the NRC Staff.
3.2.3.1.4 Conclusion--We conclude that using plant Technical Specifications to establish limiting conditions for operation meets the intent of the requirements of Section XI and should ensure system operability.
Based on the considerations discussed above we conclude that the alternate method proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.2.4 Category A/C Excess Flow Check Valves 3.2.4.1 Relief Request.
The licensee has requested specific relief from exercising all excess flow check valves included in the IST program in accordance with the requirements of Section XI and proposed to full-stroke exercise these valves during refueling outages.
3.2.4.1.1 Code Requirement--Refer to Appendix A of this report.
3.2.4.1.2 Licensee's Basis for Requesting Relief--These excess flow check valves are designed to automatically close in the event of a down stream line rupture in which flow exceeds 6.5 gpm or if drywell pressure exceeds 1.69 psig.
Upon closing, these valves are designed to allow a controlled leakage of approximately 0.5 gpm.
The lines are also provided with flow restricting orifices which would limit the potential offsite exposure to well below the guidelines of 10 CFR 100.
Because exercising these valves requires that recirculation flow instrumentation and neutron monitoring instrumentation 12
be temporarily taken out of service, the optimum time for the functionability testing of these valves is during the routine vessel pressure test performed during each refueling outage.
These valves will be full stroke exercised and leak tested during each reactor refueling outage.
3.2.4.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for excess flow check valves.
The licensee has demonstrated that these valves cannot be exercised during power operation because various instru-ment sensing lines must be disconnected thus removing multiple reactor instru-mentation from service.
Those instruments provide reactor protection and control signals and cannot be removed from service without a possible 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.
3.2.4.1.4 Conclusion--We conclude that full-stroke exercising these valves during the performance of leak rate testing at refueling outages when multiple reactor protection and control instrumentation can be removed from service should demonstrate proper valve function.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve function intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.3 Diesel Generator 3.3.1 Category 8 Valves
~
3.3.1.1 Relief Request.
The licensee has requested specific relief from measuring stroke times of valves 00G-009 and 1DG-011, diesel generator cooling water strainers 0A and 1A backwash, in accordance with the requirements of Section XI.
3.3.1.1.1 C_ ode Requirement--Refer to Appendix A of this report.
3.3.1.1.2 Licensee's Basis for Requesting Relief--These valves open in response to an automatic backwash logic signal produced by an abnormally high differential pressure across the core standby cooling systems (CSCS) service water strainers.
These valves stroke very quickly, and because they are not manually controlled, an accurate stroke time measurement is very difficult to obtain.
Furthermore, the initiation time of this backwash feature is not considered a meaningful indicator of operational readiness.
of these valves to open upon receipt of a backwash signal is confirmedThe ability quarterly.
These valves will be full-stroke exercised but not stroke timed once per quarter.
3.3.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the stroke time measurement requirements of Section XI for valves ODG-009 and 10G-011.
The licensee has demonstrated that these valves respond to a service water strainer differential pressure signal only and, since manual valve controls are not installed, valve 13
\\
I
operation is unpredictable and accurate valve stroke time measurements cannot be taken.
3.3.1.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising these valves quarterly without measuring valve stroke time should be sufficient to demonstrate proper valve function.
Based on the considerations discussed above we conclude that the testing proposed will give reasonable assurance of valve function intended or the common defense and security of the public.by the Code a 3.4 Feedwater 3.4.1 Category A/C Valves 3.4.1.1 Relief Request.
exercising valves 1821-F010A and 1821-F010B, inboard feedwater c isolation checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety position) during each refueling outage.
3.4.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.4.1.1.2 Licensee's Basis for Requesting Relief--A leak rate test must be conducted in order to verify the closure of these normally open check valves.
This test is not possible during power operation or cold shutdown because a steady flow of coolant is passing through the feedwater lines.
outage when the feedwater flow is interrupted.These valves will be fu 3.4.1.1.3 Evaluation--We agree with the licensee's basis and therefore, feel that relief should be granted from the exercising requit of Section XI for valves 1821-F010A and 1821-F0108.
.its The licensee has demon-closure (their safety position) is leak testing.strated that, due to p with valve position indication and some of the required test connections areThe located inside containment.
3.4.1.1.4 Conclusion--We conclude that the proposed alternate at refueling outages should demonstrate proper valve opera will give reasonable assurance of valve operability intended Based on the that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.4.1.2 Relief Request.
The licensee has requested specific relief from exercising valves 1821-F032A and 1821-F032B, outboard feedwater containment isolation checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during each refueling outage.
14
i 3.4.1.2.1 Code Requirement--Refer to Appendix A of this report.
]
3.4.1.2.2 Licensee's Basis for Requesting Relief--A test operator is incorporated into the design of these valves which is capable of closing the valve through an angle of 15 degrees, and the valve is equipped with two position indication lights for reporting disc positions of approximately 85%
and 100% of full open.
These valves can be opened by feedwater flow only so a partial-stroke exercise is possible only when the reactor is at high power and the feedwater flow has completely opened the disc.
A full-stroke exercise of these valves may be performed when feedwater flow increases from a no-flow condition to a maximum-flow condition following each refueling outage.
An attempt will be made to partially-stroke these valves quarterly.
A full-stroke exercise will be performed each refueling outage.
3.4.1.2.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1821-F032A and 1821-F0328.
The safety position of these valves is shut to provide containment isolation of the reactor feedwater lines and, due to the design of the test operator and the position indication, the only method available to verify valve closure is leak testing.
3.4.1.2.4 Conclusion--We conclude that the proposed alternate testing of partial-stroke exercising these valves during high power operation and verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.5 High Pressure Core Spray 3.5.1 Category B Valves 3.5.1.1 Relief Request.
The licensee has requested specific relief from measuring the stroke time of valve 1E22-F319, high pressure core spray diesel generator cooling water strainer backwash, in accordance with the requirements of Section XI.
s 3.5.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.5.1.1.2 Licensee's Basis for Requesting Relief--This valve opens in response to an automatic backwash logic signal produced by an abnormally high differential pressure across the high pressure core spray diesel generator cooling water strainer.
This valve strokes very quickly, and because it is not manually controlled, an accurate stroke time measurement is very difficult to obtain.
Furthermore, the initiation time of this backwash feature is not considered a meaningful indicator of operational readiness.
The ability of i
this valve to open upon receipt of a backwash signal is confirmed quarterly.
This valve will be full-stroke exercised but not stroke timed once per quarter.
15
i
=
)
f 3.5.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the stroke time measurement requirements of Section XI for valve 1E22-F319.
The licensee has demonstrated that this valve responds to a cooling water strainer differential pressure signal only and, since manual valve controls are not installed, valve operation j
is unpredictable and accurate valve stroke time measurements cannot be taken.
i 3.5.1.1.4 Conclusion--We conclude that the proposed alternate j
testing of full-stroke exercising this valve quarterly without measuring valve stroke time should be sufficient to demonstrate proper valve function.
Based l
on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve function intended by the Code i
and that the relief thus granted will not endanger life or property or the
[
common defense and security of the public.
3.5.2 Category C Valves 3.5.2.1 Relief Request.
The licensee has requested specific relief from exercising valve 1E22-F016, high pressure core spray suppression chamber i
suction check, in accordance with the requirements of Section XI and proposed to full-stroke exercise this valve during refueling outages.
3.5.2.1.1 Code Requirement--Refer to Appendix A of this report.
i j
3.5.2.1.2 Licensee's Basis for Requesting Relief--The high pressure core spray system is demonstrated to be operable each quarter by taking a i
[
suction from and discharging back to the condensate storage tank.
Cycled condensate is reactor grade water, however, this is not true of suppression pool water.
This valve can be exercised by aligning the high pressure core spray pump suction to the suppression pool, however, allowing suppression pool water to enter the high pressure core spray system permits the possibility of cycled condensate contamination which would cause many of the unit's other systems to become contaminated.
This situation is undesirable at all times, J
but may be guarded against if tested during refueling outages.
Therefore, this i
valve will be full-stroke exercised each refueling during the high pressure core spray system alternate flow path test.
3.5.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements l
of Section XI for valve 1E22-F016.
The licensee has demonstrated that exercising this valve utilizing flow from the suppression pool could result in ll the introduction of low quality water into the cycled condensate system which, in turn, would upset the chemistry control of that system.
Loss of chemistry i
control in the cycled condensate system would require flushing of all other
]
systems supplied by cycled condensate to prevent introducing low quality water j
into the reactor vessel.
i j
3.5.2.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising this valve during refueling outages when the i
high pressure core spray system can be removed from service for complete flushing should demonstrate proper valve operability.
Based on the considera-tions discussed above we conclude that the alternate testing proposed will give j
i j
16 l
reasonable assurance of valve nperability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6 Drywell Instrument Nitrogen 3.6.1 Category A Valves
- 3. 6.1.1 Relief Request.
The licensee has requested specific relief from exercising and fail-safe testing valves lIN001A, lIN0018, nitrogen compressor drywell suctions, and IIN017, nitrogen compressor drywell supply, in accordance with the requirements of Section XI and proposed to full-stroke exercise and fail-safe test these valves during refueling outages.
3.6.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.6.1.1.2 Licensee's Basis for Requesting Relief--These valves cut off the supply and discharge side of the compressor from the drywell, they may be stroked closed only when the nitrogen compressor is shutdown.
- Normally, this occurs only during refueling outages because instrument nitrogen is needed for control of the main steam relief valves, the inboard main steam isolation valves, high pressure core spray, low pressure core spray, residual heat removal, reactor core isolation cooling, and the process sampling line on reactor recirculation.
The alternate instrument air emergency supply cannot be used during power operation or cold shutdown as it would contaminate the drywell nitrogen atmosphee.
Therefore, these valves will be stroked at each refueling outage when the drywell is de-inerted and the instrument nitrogen system is shut down.
3.6.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising and fail-safe testing requirements of Section XI for valves lIN001A, lIN001B, and lIN017.
The licensee has demonstrated that the drywell instrument nitrogen system would be lost if one of these valves failed shut while testing and could result in loss of control of valves needed for plant operation both during power operat-ion and cold shutdown.
Use of the alternate instrument air emergency sioply during power operation could result in plant shutdown due to the inability to maintain the drywell nitrogen concentration within Technical Specification limits.
Additionally, use of the alternate instrument air emergency supply could delay plant startup because the drywell is not routinely de-inerted each cold shutdown.
3.6.1.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and fail-safe testing these valves during refueling outages when the drywell instrument nitrogen system is removed from service should demonstrate proper valve operability.
Based on the considera-tions discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.1.2 Relief Request.
The licensee has requested specific relief from full-stroke exercising and fail-safe testing valves lIN074 and 11N075, drywell instrument nitrogen dryer purge, in accordance with the requirements of 17
Section XI and proposed to full-stroke exercise and fail-safe test these valves during refueling outages.
3.6.1.2.1 Code Requirement --Refer to Appendix A of this report.
3.6.1.2.2 Licensee's Basis for Requesting Relief--Exercising these valves can be done only when the nitrogen compressor is shut down.
- Normally, this occurs only during refueling outages because instrument nitrogen is needed for control of the main steam relief valves, the inboard main steam isolation valves, high pressure core spray, low pressure core spray, residual heat removal, reactor core isolation cooling, and the process sampling line on reactor recirculation.
The instrument air alternate emergency supply cannot be used during power operation or cold shutdown as it would contaminate the drywell nitrogen atmosphere.
Therefore, these valves will be stroked at each refueling outage when the drywell is de-inerted and the instrument nitrogen system is shut down.
3.6.1.2.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising and fail-safe testing requirements of Section XI for valves lIN074 and 11N075.
The licensee has demonstrated that the drywell instrument nitrogen system must be removed from service to test these valves and could result in loss of control of valves needed for plant operation both during power operation and cold shutdown.
Use of the alternate instrument air supply during power operation could result in plant shutdown due to the inability to maintain the drywell nitrogen concentration within Technical Specification limits.
Additionally, use of the alternate instrument air supply could delay plant startup because the drywell is not routinely de-inerted each cold shutdown.
3.6.1.2.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and fail-safe testir.g these valves during refueling outages when the drywell instrument nitrogen system is removed from service should demonstr4e proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.1.3 Relief Request.
The licensee has requested specific relief from exercising and fail-safe testing valve lIN031, Traversing Incore Probe (TIP) indexer purge supply, in accordance with the requirements of Section XI and proposed to full-stroke exercise and fail-safe test this valve during refueling outages.
3.6.1.3.1 Code Requirement--Refer to Appendix A of this report.
3.6.1.3.2 Licensee's Basis for Requesting Relief--This valve cuts off the supply and discharge side of the compressor from the drywell, it may be stroked closed only when the nitrogen compressor is shutdown.
Normally, this occurs only during refueling outages because the TIP indexers require a steady flow of dry nitrogen to prevent moisture accumulation and possible failure of the mechanism, thus preventing adequate core neutron monitoring.
The instru-ment air alternate emergency supply cannot be used during power operation or 18
cold shutdown as it would contaminate the drywell nitrogen atmosphere.
There-fore, this valve will be stroked at each refueling when the drywell is de-inerted and the instrument nitrogen system is shutdown.
3.6.1.3.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising and faii-safe testing requirements of Section XI for valve lIN031.
We agree that this valve should not be exercised during power operation or cold shutdown because the TIP indexers require a steady flow of dry nitrogen to prevent moisture accumu-lation and possible failure of the mechanism, thus preventing adequate core neutron monitoring.
3.6.1.3.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and fail-safe testing this valve dJring refueling outages when the drywell instrument nitrogen system is removed from service should demonstrate proper valve operability.
Based on the considera-tions discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.2 Category C Valves 3.6.2.1 Relief Request.
The licensee has requested specific relief from exercising valves 1821-24A, 1B21-248, 1821-24C, and 1821-240, main steam i1clation valve accumulator nitrogen supply checks, in accordance with the requirements of Section XI and proposed to verify valve closure during refueling outages.
3.6.2.1.1 Code Requirement--Refer to Appendix A of this report.
3.6.2.1.2 Licensee's Basis for Requesting Relief--Entry into the drywell is required to confirm the closure of these check valves.
Since the drywell atmosphere is normally inerted with nitrogen gas at all times except refueling outages, these valves may be exercised only during refueling outages when drywell entry is possible.
3.6.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1821-24A, 1821-24B, 1821-24C, and 1821-24D.
The licensee has demonstrated that, since these valves are located inside the drywell, they are inaccessible during power operation and cold shutdown due to l
the nitrogen atmospt.ere maintained in the drywell.
Additionally, these valves are not equipped with position indication.
3.6.2.1.4 Conclusion--We conclude that the proposed alternate testing of verifying valve closure during the performance of full-stroke exercising in accordance with Section XI during refueling outages should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus J
l 19
granted will not endanger life or property or the common defense and security of the public.
3.6.2.2 Relief Request.
The licensee has requested specific relief from exercising valves 1821-F040C, 1821-F0400, 1821-F040E, 1821-F040R, 1821-F0405, 1821-F040U, and 1821-F040V, automatic depressurization system accumulator nitrogen supply checks, in accordance with the requirements of Section XI and proposed to verify valve closure during refueling outages.
3.6.2.2.1 Code Requirement--Refer to Appendix A of this report.
3.6.2.2.2 Licensee's Basis for Requesting Relief--Entry into the drywell is required to confirm the closure of these check valves.
Since the drywell atmosphere is normally inerted with nitrogen gas at all times except refueling outages, these valves may be exercised only during refueling outages when drywell entry is possible.
3.6.2.2.3 Evaluation --We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1821-F040C,1B 21-F040D,1821-FC40E,1821-F040R, 1821-F0405,1821-F040U, and 1821-F040V.
The licensee has demonstrated that, since these valv03 are located inside the drywell, they are inaccessible during power operation and cold shutdown due to the nitrogen atmosphere maintained in the drywell.
Additionally, these valves are not equipped with position indication.
3.6.2.2.4 Conclusion--We conclude that the proposed alternate testing of verifying valve closure during the performance of full-stroke exercising in accordance with Section XI during refueling outages should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing ptoposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.2.3 Relief Request.
The licensee has requested specific relief from exercising valves lIN043 and IIN044, automatic depressurization system accumu-lator supply checks, in accordance with the requirements of Section XI and proposed to full-stroke exercise these valves during, refueling outages.
3.6.2.3.1 Code Requirement--Refer to Appendix A of this report.
3.6.2.3.2 Licensee's Basis for Requesting Relief--These valves are in the discharge side of the compressor to the drywell and they may be stroked closed only when the nitrogen compressor is shut down.
Normally,_this occurs only during refueling outages because instrument nitrogen is needed for control of the main steam relief valves, the inboard main steam isolation valves; high pressure core spray, low pressure core spray, residual heat removal, reactor core isolation cooling, and the process sampling line on reactor recirculation.
The instrument air alternate emergency supply cannot be used during power operation or cold shutdown as it would contaminate the drywell nitrogen atmosphere.
Therefore,'these valves will be stroked at each refueling outage when the drywell is de-inerted and the instrument nitrogen system is shut down.
20
3.6.2.3.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 11N043 and IIN044.
The licensee has demonstrated that the drywell instrument nitrogen system must be removed from service to allow full-stroke exercising these valves.
Loss of the instrument nitrogen system could result in loss of control of valves needed for plant operation both during power operation and cold shutdown.
Use of the alternate instrument air supply during power operation could result in plant shutdown due to the inabil-ity to maintain the drywell nitrogen concentration within Technical Specifica-tions limits. Additionally, use of the alternate instrument air supply could delay plant startup because the drywell is not routinely de-inerted each cold shutdown.
3.6.2.3.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising these valves during refueling outages when the drywell instrument nitrogen system is removed from service should demon-strate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.7 Main Steam 4
3.7.1 Category A Valves 3.7.1.1 Relief Request.
The licensee has requested specific relief from fail-safe testing valves 1821-F022A,1821-F022B,1821-F022C, and 1B21-F022D, in board main steam isolations, in accordance with the requirements of Section XI and proposed to fail-safe test these valves during cold shutdowns when the i
drywell is de-inerted.
3.7.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.7.1.1.2 Licensee's Basis for Requesting Relief--Full-stroke testing these valves during normal reactor operation requires isolating one of the four main steam lines.
Isolation of these lines results in primary system pressure spikes, reactor power fluctuations, and increased flow in the uniso-lated steam lines.
This unstable operation can lead to a reactor scram, and as discussed in NUREG-0626, pressure transients resulting from full-stroke testing main steam isolation valves (MSIVs) increase the chances of actuating primary system relief valves.
The MSIVs will be partial-stroke exercised quarterly during power operation.
This partial-stroke exercising provides an acceptable means of verifying valve performance during plant operation without affecting 3
safety margins.
This request also contributes to the reduction of the relief valves challenge rate as recommended in NUREG-0626.
These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shut-downs.
The fail-safe operation of these valves will also be checked during cola shutdown since this is done coincident with full-stroke exercising, how-ever, this can be completed only during cold shutdowns during which the primary containment is de-inerted since access to the valves to perform this testing requires entry into the drywell.
21
3.7.1.1.3 Evaluation--We agree with the licensee's basis, and therefore, feel that relief should be granted from the fail-safe testing requirements of Section XI for valves 1821-F022A, 1821-F0228, 1821-F022C, and 1 821-F0220.
These valves are located inside the drywell and, since access is required to verify the fail-safe testing, are accessible only during cold shut-downs and only when the drywell is de-inerted.
Therefore, fail-safe testing of these valves cannot be accomplished each cold shutdown because the drywell is not routinely de-inerted each cold shutdown.
3.7.1.1.4 Conclusion--We conclude that the proposed alternate testing of fail-safe testing these valvas during those cold shutdowns when the drywell is de-inerted to allow access should be sufficient to demonstrate proper valve fail-safe capability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.7.2 Category B/C Valves 3.7.2.1 Relief Request.,The licensee has requested specific relief from exercising valves 1821-F013C, 1821-F013D, 1B21-F013E, 1B21-F013R, 1821-F0135, 1821-F013U, and 1821-F013V, main steam automatic depressurization system (ADS)/
safety reliefs, in accordance with the requirements of Section XI and proposed to exercise these valves entering or following each refueling outage.
3.7.2.1.1 Code Requirement--Refer to Appendix A of this report.
3.7.2.1.2 Licensee's Basis for Requesting Relief--Vendor specifications for these ADS / safety relief valves require steam pressure behind the disc before cycling.
Thus, the plant must be in an operating or startup condition with the required steam pressure in the main steam lines.
Since the valves are located inside the drywell, it is preferable that they be exercised either preceding or following each refueling outage when the containment atmos-phere is de-inerted.
These valves will be exercised "in place" each refueling outage.
3.7.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1821-F013C, 1B21-F013D, 1821-F013E,:1821-F013R, 1821-F013S, 1821-F013U, and 1821-F013V.
These ADS / safety relief valves must be exercised at normal reactor temperature and pressure conditiens to assure pro-per valve operation, but reactor power transients produced as a result of testing may cause a reactor trip, therefore, testing should be done at very low reactor power levels to reduce the severity of the transient should a trip occur.
The drywell is de-inerted during refueling outages thus allowing access to these valves should valve maintenance be required as a result of the testing.
3.7.2.1.4 Conclusion--We conclude that the proposed alternate testing of exercising these valves entering or leaving a refueling outage when reactor power is low and the drywell is de-inerted should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
22
3.7.3 Category C Valves 3.7.3.1 Relief Request.
The licensee has requested specific relief from verifying "as-found" set points of safety relief valves 1B21-F013A,1821-F013B, 1821-F013 C, 1B21-F0130, 1821-F013 E, 1B21-F013 F, 1B 21-F 013G, 1B21-F013H,
1821-F013J, 1B21-F013K, 1B21-F013L, 1821-F013M, 1821-F013N, 1821-F013P, in accordance with the requirements of Section XI and proposed to exchange these valves with valves whose set point has been verified.
3.7.3.1.1 Code Requirement--Safety valve and relief valve set points shall be tested in accordance with ASME PTC 25.3-1976.
Bench testing, with suitable hydraulic or pneumatic equipment, or testing in place with hydraulic or pneumatic assist equipment, is an acceptable method under PTC 25.3-1976.
Valves so tested are not required to be additionally leak tested in accordance with IWV-3420.
(IWV-3512) 3.7.3.1.2 Licensee's Basis for Requesting Relief--It is impractical for La Salle Unit 1 to meet the requirements of IWV-3510 in that as-found set points for these safety relief valves cannot be determined.
The station has no on-site facility for testing safety valve set points.
Licensee's plans are to remove the safety relief valves from the system and ship them off site.
They will be rebuilt off site and the set point will be tested before they are sent back on-site.
The number of valves removed and replaced during refueling cutages will be determined by the schedule in IWV-3510.
3.7.3.1.3 Evaluation--We do not agree with the licensee's basis and, therefore, portions of this relief of the set point verification requirements of Section XI is not granted for valves 1821-F013A,1821-F013B,1B21-F013C, 1821-F013D, 1821-F013 E, 1821-F013 F, 1821-F013G, 1821-F013H, 1821-F013J,
1821-F013 K, 1821-F013 L, 1821-F013M, 1821-F013 N, 1B21-F013 P, 1B21-F013 R,
1821-F0135,1821-F013U, and 1821-F013V.
However, th; licensee has demonstrated that the proper test equipment is unavailable at the site and, for this reason, the safety relief valves must be removed and sent elsewhere for proper testing and overhaul.
We believe that off-site safety relief valve testing is an acceptable alternate method to verify valve set points due to the lack of on-site testing equipment.
The licensee has not addressed additional tests required by IWV-3513.
IWV-3513 requires that when any valve in a system fails to function properly during a regular test, additional valves in the system shall be tested as defined in this paragraph.
If any of these additional valves fail to function properly on test, then all valves in the system in this category shall be tested.
The NRC staff therefore requires that safety relief valves that are removed from service shall have the set points tested prior to startup from the outage during which they are removed and prior to being rebuilt in order to comply with IWV-3513.
In addition, if removed tested valves fail their set pressure test acceptance criteria, additional valves shall be removed and tested prior to restart in accordance with IWV-3513.
3.7.3.1.4 Conclusion--We conclude that the licensee is required to have set points tested prior to startup from the outage during which they are removed and prior to being rebuilt in order to comply with IWV-3513.
In addi-tion, if the tested valves that are removed fail their set pressure test accep-tance criteria, additional valves shall be removed and tested prior to restart in accordance with IWV-3513.
We conclude that this testing will give reasonable 23
assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.7.3.2 Relief Request.
The licensee has requested specific relief from exercising valves 1821-F037A1,1821-F037A2,1821-F037B1,1821-F03782,1B21-F037C1, 1821-F037C2, 1821-F03701, 1821-F03702, 1821-F037E1, 1821-F037E2, 1821-F037F1, 1821-F037F2, 1821-F037G1, 1821-F037G2, 1821-F037K1, 1821-F037K2, 1821-F037L1, 1821-F037L2, 1821-F037P1, 1821-F037P2, 1821-F037R1, 1821-F037R2, 1821-F03751, 1B21-F03752, 1821-F037V1, 1B21-F037V2, 1821-F037U1, 1821-F037U2,
1821-F037H1, 1821-F037H2, 1821-F037J 1, 1821-F037J 2, 1821-F037M1, 1821-F037M2,
1821-F037N1, and 1B21-F037N2, safety relief valve discharge line vacuum breakers, in accordance with the requirements of Section XI and proposed to manually full-stroke exercise these valves during cold shutdowns when the drywell is de-inerted.
3.7.3.2.1 Code Requirement--Refer to Appendix A of this report.
3.7.3.2.2 Licensee's Basis for Requesting Relief--These check valves have no external means of actuation for exercising.
The only practical method available for exercising these valves open is by manually pushing the disc from its seat using a small diameter rod.
Since this requires access to the valves which are located within the primary containment, the test must be deferred to cold shutdowns when the primary containment is de-inerted.
These check valves will be verified to swing to their full open position at cold shutdowns when the drywell is de-inerted.
3.7.3.2.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1621-F037Al, 1821-F037A2, 1821-F037B1, 1821-F037B2, 1821-F037C1, 1821-F037C2, 1821-F037D1, 1B2 1-F037D2, 1821-F037E1, 1821-F037E2, 1821-F037F1, 1821-F037F2, 1821-F037G1, 1821-F037G2, 1821-F037K1, 1821-F037K2, 1821-F037 L1, 1821-F037 L2, 1821-F037 P 1, 1821-F037P2, 1821-F037 R1, 1821-F037 R2,
1821-F037S1, 1821-F037S2, 1821-F037V1, 1821-F037V2, 1821-F037U1, 1821-F03702,
1821-F037H1,1B21-F037H2,1821-F037J1,1821-F037J2,1821-F037M1,1821-F037M2, 1821-F037N1, and 1821-F037N2.
These check valves are located inside containment, are not equipped with actuators or position indication, and drywell access is required to manually exercise them.
They are accessible only during cold shutdowns and only when the drywell is de-inerted, therefore, they cannot be manually exercised during each cold shutdown because the drywell is not routinely de-inerted each cold shutdown.
3.7.3.2.4 Conclusion--We conclude that the proposed alternate testing of manually full-stroke exercising these valves during those cold shutdowns when the drywell is de-inerted to allow access should be sufficient to demon-strate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the reliet thus granted will not endanger life or property or the common defense and security of the public.
3.8 Control Rod Drive 3.8.1 Category B Valves 3.8.1.1 Relief Request.
The licensee has requested specific relief from measuring stroke times of valves 1C11-F010, scram discharge volume vent, and 24
1C11-F011, scram discharge volume drain, in accordance with the requirements of Section XI.
3.8.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.8.1.1.2 Licensee's Basis for Requesting Relief--The system is designed such that the test circuit bleeds air from these air operated valves at a very slow rate, much slower than during normal operation of the valves.
Thus timing these valves during testing has no relevance and, because of the slow bleed rate, the test time repeatability is poor.
These valves will be full-stroke exercised without timing quarterly.
3.8.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the stroke timing requirements of Section XI for valves 1C11-F010 and 1C11-F011.
The licensee has demonstrated that, due to system design, these valves operate much more slowly when responding to a test control signal then when responding to a normal (reactor scram) signal. We feel that stroke time measurements taken while testing these valves would not be representative of valve condition and would not contribute meaningful data to utilize in monitoring valve degradation.
3.8.1.1.4 Conclusion--We conclude that full-stroke exercising these valves without stroke timing should be sufficient to demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the comrron defense and security of the public.
3.8.1.2 Relief Request.
The licensee has requested specific relief from testing valves 1C11-0001-126 and 1C11-D001-127, control rod scram inlet and outlet, in accordance with the requirements of Section XI and proposed to verify proper valve operation during the performance of individual control rod scram testing in accordance with plant Technical Specifications.
i j
3.8.1.2.1 Code Requirement--Refer to Appendix A of this report.
1 3.8.1.2.2 Licensee's Basis for Requesting Relief--There are 185 of each of the valves listed, i.e., ore 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 speci-fic values.
This insures that the above mentioned valves are functioning pro-perly.
Individual scram insertion tests will be performed per the Technical Specification frequency.
3.8.1.2.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the valve testing require-ments of Section XI for valves 1C11-D001-126 and IC11-0001-127.
These valves operate in pairs and cannot be exercised without causing the associated control rod to scram.
We feel that verifying proper control rod scram insertion times during the performance of control rod scram testing in accordance with the 25
testing specified in plant Technical Specifications paragraphs 3.1.3.3 and 3.1.3.4 is an acceptable alternate method to utilize to monitor valve degra-dation.
Individual scram testing is performed in accordance with Technical Specification Paragraph 4.1.3.2.
The frequency of individual scram insertion tests is:
- 1) 100% of control rod drives following core alterations or after a reactor shutdown greater than 120 days with reactor power equal to or less than 40% and 2) 10% of cor. trol rods at least once every 120 days of operations.
3.8.1.2.4 Conclusion--We conclude that the proposed alternate testing of verifying proper control rod scram insertion times during the per-formance of control rod scram testing in accordance with the Technical Specifi-cations identified above is an acceptable method for monitoring valve degrada-tion and demonstrating proper valve operability.
Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve opcrability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.8.2 Category C Valves 3.8.2.1 Relief Request.
The licensee has requested specific relief from exercising valve 1C11-0001-114, scram discharge header check, in accordance with the requirements of Section XI and proposed to full-stroke exercise this valve during the performance of individual control rod scram testing in accordance with plant Technical Specifications.
3.8.2.1.1 Code Requirement--Refer to Appendix A of this report.
3.8.2.1.2 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 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.
Individual scram insertion tests will be performed per the Technical Specification frequency.
3.8.2.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 1C11-0001-114.
This valve is located in the scram discharge line of each control rod drive and must operate properly to allow the associated control rod to meet the scram insertion time limit defined in the plant Technical Specifications.
We feel that verifying proper control rod scram insertion times during the performance of control rod scram testing in accordance with the testing specified in plant Technical Specifications Para-graphs 3.1.3.3 and 3.3.1.4 is an acceptable alternate method to utilize to full-stroke exercise this valve.
Individual scram testing is performed in accordance with Technical Specification Paragraph 4.1.3.2.
The frequency of individual scram insertion tests is:
- 1) 100% of control rod drives following core alterations or after a reactor shutdown greater than 120 days with reactor power equal to or less than 40% and 2) 10% of control rods at least once every 120 days of operations.
26
3.8.2.1.4 Conclusion--We conclude that the proposed alternate testing of verifying proper control rod scram insertion times during the performance of control rod scram testing in accordance with the Technical Specifications identified above is an acceptable method for monitoring valve degradation and demonstrating proper valve operability.
Based on the consid-erations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.8.2.2 Category C Valves Omitted from the IST Program.
The licensee has omitted from the IST program CRD-115, control rod drive charging water header check valve, and CRD-138 c oling water header check valve, for each of the 185 hydraulic control units (HCU) in the control rod drive (CRD) system.
The licensee's basis for omitting the check valves from the IST program is that testing is not necessary because of a modification to the CRD system.
This modification is the addition of a charging water low pressure scram which automatically scrams the system whenever the charging water pressure decreases below the scram setpoint.
The NRC staff does not agree with the licensee's basis for omitting these check valves from the IST program since the installation of a low pressure scram does not assure proper operability of individual check valves or identify valve degradation that would interfere with valve operation.
Accordingly, check valves CRD-115 and CRD-138 shall be included in the IST program as Category C valves.
However, relief from the testing requirements of Subsection IWV of Section XI of the ASME Code is granted because testing of the check valves during plant operation is impractical.
The check valves shall be tested as follows:
1.
In order to verify closure of check valve CRD-115 the test will be per-formed at refueling when the charging water header can be depressurized without a plant scram and when area radiation is sufficiently reduced to allow extended entry for testing.
Testing will be performed by depres-surizing the charging water header and monitoring individual accumulation pressure and alarm to verify that check valves CRD-115 have closed on reverse flow.
2.
In order to verify closure of check valve CRD-138 the test will be per-formed during integrated leakage testing per 10 CFR 50, Appendix J by venting of the cooling water header to verify that check valves CRD-138 4
have closed on reverse flow.
The NRC staff concludes that the alternate testing identified above will give reasonable assurance of the operability of check valves CRD-115 and CRD-138 intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.9 Residual Heat Removal 3.9.1 Category B Valves 3.9.1.1 Relief Request.
The licensee has requested specific relief from measuring stroke times of valves 1E12-F336A and 1E12-F336B, residual heat removal service water strainers backwash, in accordance with the requirements of Section XI.
27
3.9.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.9.1.1.2 Licensee's Basis for Requesting Relief--These valves open in response to an automatic backwash logic signal produced by an abnormally high differential pressure across the core standby cooling systems (CSCS) serv-ice water strainers.
These valves stroke very quickly, and because they are not manually controlled, an accurate stroke time measurement is very difficult to obtain.
Furthermore, the initiation time of this backwash feature is not considered a meaningful indicator of operational readiness.
The ability of these valves to open upon receipt of a backwash signal is confirmed quarterly.
These valves.will be full-stroke exercised but not stroke timed once per quarter.
3.9.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be gr' anted from the stroke time measurement requirements of Section XI for valves 1E12-F336A and IE12-F336B.
The licensee has demonstrated that these valves respond to a service water strainer differential pressure signal only and, since manual valve controls are not installed, valve operation is unpredictable and accurate valve stroke time measurements cannot be taken.
3.9.1.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising these valves quarterly without measuring valve stroke time should be sufficient to demonstrate proper valve operability.
i Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.10 Reactor Core Isolation Cooling 3.10.1 Category C Valves 3.10.1.1 Relief Request.
The licensee has requested specific relief from exercising valve 1E51-F030, reactor core isolation cooling suppression chamber suction check, in accordance with the requirements of Section XI and proposed to partial-stroke exercise this valve quarterly and to full-stroke exercise it during refueling outages.
3.10.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.10.1.1.2 Licensee's Basis for Requesting Relief--This check valve is partial-stroke exercised each quarter by the performance of a reduced flow test of the reactor core isolation cooling (RCIC) system alternate flow path.
The opening of this valve is confirmed by sustained suction pressure at the RCIC pump.
A quarterly full flow test is not performed for the alternate flow path because suppression pool water could potentially contaminate the cycled condensate system.
Each refueling outage a full flow test of the alternate flow path is conducted at which time this check valve is full-stroke exercised.
3.10.1.1.3 Evaluation--We agree with the licensee's basis, and therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 1E51-F030.
The licensee has demonstrated that, due to 28
system design, only partial-stroke exercising of this valve is possible during the quarterly pump test.
This valve cannot be full-stroke exercised quarterly because this would result in the introduction of low quality suppression pool water into the cycled condensate system which, in turn, would upset the chemistry control of that system.
Loss of chemistry control in the cycled condensate system would require flushing of all other systems supplied by cycled condensate to prevent introducing low quality water into the reactor vessel.
3.10.1.1.4 Conclusion--We conclude that the proposed alternate testing of partial-stroke exercising this valve quarterly and full-stroke exercising it during reactor refueling outages should be sufficient to demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.11 Standby Liquid Control 3.11.1 Category A/C Valves 3.11.1.1 Relief Request.
The licensee has requested specific relief from exercising valve 1C41-F007, standby liquid control inboard injection check, in accordance with the requirements of Section XI and proposed to full-stroke exercise this valve during refueling outages.
3.11.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.11.1.1.2 Licensee's Basis for Requesting Relief--This valve cannot be exercised during reactor operation or cold shutdown.
To exercise this valve open, the system must inject into the vessel. A system injection is not prac-tical during ncrmal operation or cold shutdown because the explosive charges would have to be detonated and the system taken out of service.
This valve will be full-stroke exercised during refueling outages.
i 3.11.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve IC41-F007.
The licensee has demonstrated that this valve cannot be exercised during power operation because the system cannot be removed from service for flushing.
This valve cannot be exercised during cold shutdown because extensive system flushing is required to remove all traces of the sodium pentaborate solution to prevent its entry into the reactor system.
Additionally, one of the explosive valves must be removed or fired to provide a flow path.
3.11.1.1.4 Conclusion--We conclude that the proposed alternate testing of full stroke exercising this valve during refueling outages when the standby liquid control system can be removed from service and flushed free of the sodium pentaborate solution should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended 29
by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.11.2 Category B Valves 3.11.2.1 Relief Request.
The licensee has requested specific relief from exercising valves 1C41-F001A and 1C41-F0018, standby liquid control pumps 1A and 18 suctions, in accordance with the requirements of Section XI and proposed to full-stroke exercise and stroke time these valves during refueling outages.
3.11.2.1.1 Code Requirement --Refer to Appendix A of this report.
3.11.2.1.2 Licensee's Basis for Requesting Relief--During the testing of these val.ves, the system is aligned so that a greater pressure exists on the downstream side of the suction valves.
Opening the valve causes dilution of the sodium pentaborate solution in the standby liquid control solu-tion tank.
Therefore, a chemical analysis of the solution will need to be 4
performed, as required by the Technical Specifications, to ensure that the concentration of boron in solution is within the required limits.
It is undesirable to perform this test during cold shutdowns due to the considerable length of time the testing procedure and chemical analysis requires.
These valves will be full-stroke exercised and stroke timed during refueling outages.
i 3.11.2.1.3 Evaluation--We agree with the licensee's basis, and therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1C41-F001A and 1C41-F0018.
The licensee has demon-strated that dilution of the standby liquid control solution tank occurs during exercising of these valves because the cycled condensate system is aligned to pressurize the pump suction piping thus preventing introduction of the sodium pentaborate solution into a line that is not heat traced.
The reactor must be shut down if the boron solution concentration does not meet the Technical Specification limits and must remain shutdown until the limits are met.
For this same reason, reactor startup cannot commence until the boron solution concentration limits are met, therefore, exercising these valves during cold shutdowns could delay plant startup.
3.11.2.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and stroke timing these valves during refuel-ing outages when the standby liquid control system can be removed from service should be sufficient to demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.11.3 Category C Valves 3.11.3.1 Relief Request.
The licensee has requested specific relief from exercising valve 1C41-F006, standby liquid control outboard injection check, in accordance with the requirements of Section XI and proposed to full-stroke exercise this valve during refueling outages.
3.11.3.1.1 Code Requirement--Refer to Appendix A of this report.
30
3.11.3.1.2 Licensee's Basis for Requesting Relief --This valve cannot be exercised during reactor operation or cold shutdown.
To exercise this valve open, the system must inject into the vessel.
A system injection is not practical during normal operation or cold shutdown because the explosive charges would have to be detonated and the system taken out of service.
This valve will be full-stroke exercised during refueling outages.
3.11.3.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 1C41-F006.
The licensee has demonstrated that this valve cannot be exercised during power operation because the system cannot be removed from service for flushing.
This valve cannot be exercised during cold shutdown because extensive system flushing is required to remove all traces of the sodium pentaborate solution to prevent its entry into the reactor system.
Additionally, one of the explosive valves must be removed or fired to provide a flow path.
3.11.3.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising this valve during refueling outages when the standby liquid control system can be removed from service and flushed free of the sodium pentaborate solution should demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.12 Primary Containment Ventilation 3.12.1 Category A Valves 3.12.1.1 Relief Request.
The licensee has requested specific relief from exercising valves 1VP063A and IVP113A, primary containment ventilation heat exchanger AA supply, and IVP053A and IVP114A, primary containment ventilation heat exchanger AA return, in accordance with the requirements of Section XI and proposed to full-stroke exercise and stroke time these valves during refueling outages.
3.12.1.1.1 Code Requirement--Refer to Appendix A of this report.
3.12.1.1.2 Licensee's Basis for Requesting Relief--Closing any one of these isolation valves would prevent chilled water from reaching the primary containment cooling unit.
The operation of the system is essential during power operation and is also necessary during cold shutdowns to maintain acceptable conditions in the drywell for equipment and maintenance personnel.
These valves will be full-stroke exercised and stroke timed during refueling outages when the heat input to the drywell atmosphere is substantially reduced.
3.12.1.1.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 1VP063A, IVP113A, IVP053A, and IVP114A.
The licensee has demonstrated that if any one of these valves failed shut while testing, cooling would be lost to the primary containment which could result in a reac-tor trip during power operation due to air expansion in the containment.
31
Cooling capability is also required during cold shutdowns because the drywell is not routinely de-inerted and ventilated each cold shutdown.
Additionally, the cooling system is maintained in operation during cold shutdowns when the drywell is oe-inerted to allow access to provide acceptable working conditions for maintenance personnel.
3.12.1.1.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and stroke timing these valves during refueling outages when drywell cooling can be secured should be sufficient to demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.12.1.2 Relief Request.
The licensee has requested specific relief from exercising valves 1VP0638 and IVP1138, primary containment ventilation heat exchanger AB supply, and IVP053B and IVP114B, primary containment ventilation heat exchanger AB return, in accordance with the requirements of Section XI and proposed to full-stroke exercise and stroke time these valves during refueling outages.
3.12.1.2.1 Code Requirement--Refer to Appendix A of this report.
3.12.1.2.2 Licensee's Basis for Requesting Relief--Closing any one of these isolation valves would prevent chilled water from reaching the primary containment cooling unit.
The operation of the system is essential during power operation and is also necessary during cold shutdowns to maintain acceptable conditions in the drywell for equipment and maintenance personnel.
These valves will be full-stroke exercised and stroke timed during refueling outages when the heat input to the drywell atmosphere is substantially reduced.
3.12.1.2.3 Evaluation--We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves IVP063B, IVP113B, IVP053B, and IVP114B.
The licensee has demonstrated that if any one of these valves failed shut while testing, cooling would be lost to the primary containment which could result in a reactor trip during power operation due to air expansion in the containment.
Cooling capability is also required during cold shutdowns because the drywell is not routinely de-inerted and ventilated each cold shutdown.
Additionally, the cooling system is maintained in operation during cold shutdowns when the drywell is de-inerted to allow access to provide acceptable working conditions for maintenance personnel.
3.12.1.2.4 Conclusion--We conclude that the proposed alternate testing of full-stroke exercising and stroke timing these valves during refueling outages when drywell cooling can be secured should be sufficient to demonstrate proper valve operability.
Based on the considerations discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
l 32
APPENDIX A 1.
CODE REQUIREMENTS--VALVES Subsection IWV-3411 of the Section XI Code requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IWV-3412(a).
IWV-3521 requires that Code Category C valves be i
exercised once every three months, with the exceptions as defined in IWV-3522.
IWV-3700 contains test requirements for active and passive valves.
The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3413(a), (b), and IWV-3417(a), (b).
In the above exceptions, the Code permits the valves to be tested at cold shutdown were:
1.
It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
2.
It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.
Subsection IWV-3413(b) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time.
2.
CODE REQUIREMENTS--PUMPS An inservice test shall be conducted on all pumps whose function is important to safety, nominally once each quarter during normal plant operation.
Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
When measurement of bearing temperature is required, each pump shall be run until the bearing temperatures stabilize, and then the quantities specified shall be measured or observed and recorded.
33
ATTACHMENT B During the course of the NRC staff review of the La Salle Unit 1, IST program we have identified the following valves that perform a containment isolation function.
However, they are either not included in the IST program or if they are included, they are not categorized A or A/C as appropriate and are not leak tested in accordance with 10 CFR 50, Appendix J, " Containment Isolation Valve Criteria."
j SYSTEM VALVE NUMBER VALVE CATEGORY High Pressure Core Spray IE22-F023 Not in Program Drywell Instrument Nitrogen
- 11N100, Not in Program IIN101 Not in Program Low Pressure Core Spray 1E21-F012 Not in Program Suppression Pool Water Level
- 1CM004, Not in Program Vacuum Breaker 1CM012 Not in Program Residual Heat Removal 1E12-F099A Not in Program 1E12-F099B Not in Program 1E12-F021 Not in Program Containment Monitoring 1CM022A B
1CM024A B
1CM025A B
1CM021B B
1CM023B B
1CM026B B
The IST program shall be revised accordingly.
During the course of the NRC staff review of the LaSalle Unit 1 IST program we have identified the following normally closed full flow test valves excluded from the IST program.
Test valves that are properly classified are exempt from the requirements of Section XI of the code.
However, during pump tests, these full-flow valves receive an isolation signal to shut when the system initiation signal is generated.
At this time, the test configuration is automatically secured and the system aligns to the reactor vessel injection flowpath.
The full-flow test valves perform a safety function since they must close in order to prevent a diversion of flow from the reactor vessel injection flowpath.
It is the NRC staff position that full-flow test valves in safety-related sys-tems shall be included in the licensee's IST program and tested in accordance with the requirements of Subsection IWV of Section XI of the ASME Code.
These full-flow test valves are:
j 34
n.-. -,, -
,,,-.--m,.
SYSTEM VALVE NUMBER High Pressure Core Spray IE22-F010 IE22-F011 IE22-F023 Low Pressure Core Spray IE21-F012 Residual Heat Removal IE12-F021 Reactor Core Isolation Cooling IE51-F022 IE51-F059 The IST program shall be revised accordingly.
35
ATTACHMENT C 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 specifically iden-tified by the licensee and are full-stroke exercised during cold shutdowns and refueling outages.
The NRC staff has reviewed all the valves in this attach-ment and agrees with the licensee that testing these valves during power operation is not practical due to the valve type and location or system design.
We believe that these valves cannot or should not be exercised during power operation.
We conclude that the proposed alternate testing of the Category A, B and C valves that are listed below are in conformance with Subsection IWV-3412 of Section XI of the ASME Code.
Testing these valves in accordance with the Code will give reasonable assurance of valve operability.
The valves are grouped according to the system in which they are located.
1.
1.1 Category A Valves Valves 1821-F065A and 1821-F065B, reactor feedwater isolations, cannot be exercised during power operation.
The feedwater system is needed to maintain l
primary coolant inventory and exercising them would deprive the vessel of the flow of feedwater which could result in a reactor trip.
These valves will be 4
full-stroke exercised and stroke timed during cold shutdowns.
2.
HIGH PRESSURE CORE SPRAY 2.1 Category A/C Valves Valve 1E22-F005, high pressure core spray testable check, cannot be exercised during power operation.
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, or its bypass test valve, may not properly reseat which would render it incapable of performing its isolation function.
Since the dry-well is inaccessible during power operation, the affected penetration would need to be isolated, causing the system to be unavailable for its emergency 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.
This valve will be full-stroke exercised during cold shutdowns when its isolation function is not required.
3.
LOW PRESSURE CORE SPRAY 3.1 Category A Valves Valve 1E21-F005, low pressure core spray injection, cannot be exercised i
during power operation.
This valve is electrically interlocked shut by normal operating differential pressure to protect the low pressure piping outside the drywell.
This valve will be full-stroke exercised and timed during cold shutdowns.
36
3.2 Category A/C Valves Valve 1E21-F006, low pressure core spray testable check, cannot be exercised during power operation.
Exercising this valve during reactor opera-tion requires opening the equalizing valve around it and then opening the valve.
If a system initiation were received at this point, the pumps would start and the injection valve would open.
The injection valve requires
<729 psi differential pressure across it to open, and the pump head would
_easily give that.
When the injection val've opens, should the check valve fail to close, or if it leaked, it would supply a path for reactor pressure to the low pressure piping of the low pressure core spray system.
A one inch relief valve set at 500 psi would relieve to the suppression pool and provide a loss of coolant flow from the reactor to the suppression pool, possibly overpres-surizing the low pressure piping if a system initiation is present.
- Also, opening this valve during reactor operation gives only one valve protection to the low pressure piping.
This valve will be full-stroke exercised during cold shutdowns.
4.
MAIN STEAM 4.1 Category A Valves Valves 1821-F028A,1821-F0288,1821-F028C, and 1821-F0280, outboard main steam isolations, cannot be full-stroke exercised during power operation.
Full-stroke testing these valves during normal reactor operation requires isolating one of the four main steam 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, pressure transients resulting from full-stroke testing main steam isolation valve: (MSIVs) increase the chances of actuating primary system relief valves.
The MSIVs will be partial-stroke exercised quarterly during power operation.
This partial-stroke exercising provides an 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.
These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns..The fail-safe operation of these valves will also be checked during cold shutdown since this is done coincident with full-stroke exercising.
Valves 1E32-F001A, 1E32-F001E, 1E32-F001J, and IE32-F001N, MSIV 1eakage control system inlets, cannot be exercised during power operation.
These valves are designed to operate when the main steam line pressure is near atmospheric.
Testing 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.
4.2 Category B Valves Valves 1E32-F003A, 1E32-F003E, 1E32-F003J, and 1E32-F003N, main steam lire discharge to the steam tunnel, cannot be exercised during power operation.
These valves are designed to operate when the main steam line pressure is near 37
i atmospheric.
Testing these valves at normal steam line pressure has the poten-tial for discharging live steam into the reactor building atmosphere.
These valves will be full-stroke exercised and stroke timed during cold shutdowns.
4 Valves 1E32-F002A, 1E32-F002E, 1E32-F002J, and 1E32-F002N, MSIV 1eakage control system inlets, cannot be exercised during power operation.
These valves are designed to operate when the main steam line pressure is near atmospheric.
Testing 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.
Valves 1E32-F006 and 1E32-F007, downstream MSIV leakage control system inlets, cannot be exercised during power operation.
These valves are designed I
to operate when the main steam line pressure is near atmospheric.
Testing these valves at normal steam line pressure has the potential for discharging i
live steam into the reactor building atmosphere.
These valves will be full-stroke exercised and stroke timed during cold shutdowns.
Valves 1E32-F008 and 1E32-F009, downstream main steam line discharge to the steam tunnel, cannot be exercised during power operation.
These valves are designed to operate when the main steam line pressure is near atmospheric.
Testing 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.
5.
5.1 Category A Valves l
Valves 1E12-F008, residual heat removal shutdown cooling suction outboard isolation, and 1E12-F009, residual heat removal shutdown cooling suction inboard isolation, cannot be exercised during power operation.
These valves are electrically interlocked shut by normal operating differential pressure to protect the low pressure piping outside the drywell.
These valves will be i
full-stroke exercised and timed during cold shutdowns.
Valves 1E12-F042A, 1E12-F042B, and 1E12-F042C, residual heat removal / low 4
pressure coolant injection outboard isolations, cannot be exercised during power operation.
These valves are interlocked closed with greater than 729 psid across them.
This would require t5.e low pressure coolant injection pumps to be running to cycle the valves.
If the valve was opened in this l
manner and the inboard testable check valve was to fail or leak, the low pressure piping would be subjected to reactor pressure.
This would lift the low pressure piping relief valve (500 psi) and provide a flow path for reactor pressure to the suppression pool.
The relief line is only a one inch line, which, depending on the amount of check valve leakage, has the potential to severely overpressurize the low pressure piping.
Exercising these valves provides single valve protection to the low pressure piping for the duration of the test.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valves 1E12-F053A and 1E12-F053B, residual heat removal / shutdown cooling return isolations, cannot be exercised during power operation.
These valves 38
O are electrically interlocked shut by normal operating differential pressure to protect the low pressure piping outside the drywell.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valve 1E12-F023, reactor vessel head spray isolation, cannot be exercised during power operation.
This valve is electrically interlocked shut by normal operating differential pressure to protect the low pressure piping outside the drywell.
This valve will be full-stroke exercised and timed during cold shutdowns.
5.2 Category A/C Valves Valves 1E12-F041A, 1E12-F041B, and 1E12-F041C, residual heat removal / low pressure coolant injection testable checks, cannot be exercised during power operation.
Exercising any one of these valves during reactor operation requires opening the equalizing valve around it and then opening the valve.
If a system initiation were received at this point, the pumps would start and the injection valve would open.
The injection valve requires <729 psi differential pressure across it to open, and the pump head would easily give that.
When the injection valve opens, should the check valve fail to close, or if it leaked, it would supply a path for reactor pressure to the low pressure piping of the residual heat removal system. A one inch relief valve set at 500 psi would relieve to the suppression pool and provide a loss of coolant flow from the i
reactor to the suppression pool, possibly overpressurizing the low pressure piping with an initiation signal already present.
Also, opening this valve during reactor operation gives only one valve protection to the low pressure piping.
These valves will be full-stroke exercised during cold shutdowns.
Valves 1E12-F050A and 1E12-F0508, residual heat removal shutdown cooling testable checks, cannot be exercised during power operation.
These valves are electrically interlocked shut by normal operating differential pressure to protect the low pressure piping outside the drywell.
These valves will be full-stroke exercised during cold shutdowns.
6.
REACTOR CORE ISOLATION COOLING 6.1 Category A Valves Valves 1E51-F008, reactor core isolation cooling turbine outboard steam isolation, and 1E51-F063, reactor core isolation cooling turbine inboard steam I
isolation, cannot be exercised during power operation.
These valves are norm-ally open to supply steam to the turbine driven reactor core isolation injection pump.
Conservatively these valves are left in the open position to ensure that driving steam can be supplied to this turbine at all times during operation.
These valves also serve a primary containment isolation function.
If either of these valves were to fail while testing, the reactor core isolation cooling system would be rendered inoperable.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valve 1E51-F013, reactor core isolation cooling (RCIC) injection, cannot be exercised during power operation.
The RCIC piping is normally pressurized at 60 psig during power operation.
One purpose of this valve is to isolate reactor pressure from the RCIC system.
Opening this valve would result in a 39
water hammer of the RCIC piping and the high pressure reactor water would cause damage to the low pressure piping on the suction side of the pump, which is designed for a maximum pressure of 100 psig.
This valve will be full-stroke exercised and timed during cold shutdowns when the reactor pressure is substantially reduced.
Valve 1E51-F064, residual heat removal steam condensing supply, cannot be exercised during power operation.
This valve is located at the interface of high and low pressure piping.
Opening this valve during power operation would result in severe water hammer and thermal shock to the low pressure piping.
This valve may be stroked at each cold shutdown when reactor water pressure and temperature have both been reduced.
This valve will be full-stroke exercised and timed during cold shutdowns.
6.2 Category A/C Valves Valve 1E51-F066, reactor core isolation cooling testable check, cannot be exercised during power operation.
This normally closed, testable check valve serves as the first isolation valve in the event of a system line break and is incorrectly classified as a Category C valve.
The f:RC staff requires that this valve be reclassified Category A/C.
Testing could be performed during power operation, however, a real possibility exists that this valve, or its bypass test valve, may not properly reseat which grould render it incapable of perform-ing its isclation function.
Since the dryvell is inaccessible during power operation, the affected penetration would r.eed to be isolated, causing the system to be unavailable for its emergency 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.
This valve will be full-stroke exercised during cold shutdowns when its isolation function is not required.
7.
REACTOR WATER CLEANUP 7.1 Category A Valves Valves 1G33-F001, reactor water cleanup inboard suction, 1G33-F004, reactor water cleanup outboard suction, and 1G33-F040, reactor water cleanup return, cannot be exercised during power operation.
The entire reactor water cleanup system must be inoperable before any of these valves can be closed.
This system maintains reactor water chemistry and prevents thermal stratifica-tion of the water in the bottom head section of the vessel.
This system is required to be operable during power operation to prevent fuel cladding reac-tions and to prevent thermal stresses in the bottom head of the reactor vessel.
Therefore, these valves will be full-stroke exercised and timed during cold shutdowns.
8.
PRIMARY CONTAINMENT PURGE 8.1 Category A Valves Valves IVQ026 and IVQO27, suppression chamber purge supply, cannot be exercised during power operation.
The plant Technical Specifications require that these valves remain shut du-ing power operation.
These valves will be full-stroke exercised and timed during cold shutdowns.
40 j
0 Valves IVQO29 and IVQO30, drywell purge supply, cannot be exercised during power operation.
The plant Technical Specifications require that these valves remain shut during power operation.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valves IVQ031 and IVQ040, suppression chamber purge exhaust, and IVQ032, IVQ031 bypass, cannot be exercised during power operation.
The plant Technical Specifications require that these valves remain shut during power operation.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valves IVQ034 and IVQO36, drywell purge exhaust, cannot be. exercised during power operation.
The plant Technical Specifications require that these valves remain shut during power operation.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valves IVQ042, drywell nitrogen inerting supply, and IVQ043, suppression chamber nitrogen inerting supply, cannot be exercised during power operation.
The plant Technical Specifications require that these valves remain shut during power operation.
These valves will be full-stroke exercised and timed during cold shutdowns.
9.
REACTOR BUILDING CLOSED COOLING WATER f
9.1 Category A Valves Valves 1WR-029 and 1WR-179, reactor building closed cooling water drywell supply, cannot be exercised during power operation.
Reactor recirculation pump operation requires a continuous cooling water flow from the reactor building closed cooling water system.
Exercising these valves dnciro operation interrupts this flow from the reactor building closed coo..1g water system and could result in damage to the reactor recirculation pumps.
These valves will be full-stroke exercised and timed during cold shutdowns.
Valves 1WR-040 and 1WR-180, reactor building closed cooling water drywell return, cannot be exercised during power operation.
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 reactor recirculation pumps.
These valves will be full-stroke exercised and timed during cold shutdowns.
l 41
O i
1 5
ATTACHMENT D 4
The P& ids listed below were used during the course of this review.
System P&ID NO.
Revision 4
Containment Monitoring M-156-1 G
M-156-2 H
M-156-4 C
CSCS Equipment Cooling Water M-87-1 U
M-87-2 R
t M-87-3 E
Diesel Oil M-85-1 S
Reactor Building Equipment Drains M-91-1 G
M-91-2 D
M-91-3 D
M-91-4 N
i Fuel Pool Cooling M-98-1 T
Feedwater M-57 M
Containment Combustible Gas Control M-130-2 L
High Pressure Core Spray M-95 P
i Drywell Pneumatic M-66-1 J
M-66-2 K
M-66-7 C
Low Pressure Core Spray M-94 R
4 Clean Condensate Storage M-75-2 R
Main Steam M-55-1 J
M-55-2 J
l M-55-7 J
i M-55-8 G
i Nuclear Boiler and Reactor Recirculation M-93-1 T
j M-93-2 R
j M-93-3 0
i M-93-4 J
M-93-5 F
Primary Containment Vent & Purge M-92-1 V
M-92-2 D
1 i
42
o System P&ID NO.
Revision Control Rod Drive M-100-2 K
M-100-3 F
M-100-4 B
Residual Heat Removal M-96-1 U
M-96-2 V
M-96-3 U
M-96-4 V
M-96-5 C
Reactor Core Isolation Coolant M-101-1 Y
M-101-2 V
Reactor Water Cleanup M-97 Service Air M-82-3 J
Standby Liquid Control M-99 N
Primary Containment Chilled Water M-86-1 T
Reactor Building Closed Cooling Water M-90-2 K
Cycled Condensate Storage M-74 Y
43