ML20202J128

Technical Evaluation Rept Pump & Valve Inservice Testing Program Shearon Harris Nuclear Power Plant

ML20202J128
Person / Time
Site:	Harris
Issue date:	11/30/1998
From:	Hartly R, Ransom C IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML18016A796	List: ML20202J116 ML20202J128
References
CON-FIN-J-2422 INEEL-EXT-98-01, INEEL-EXT-98-01008, INEEL-EXT-98-1, INEEL-EXT-98-1008, TAC-MA0815, TAC-MA815, NUDOCS 9902090043
Download: ML20202J128 (56)

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INEEIJEXT-98-01008 ATTACHMENT 2 l l \

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SHEARON HARRIS NUCLEAR POWER PLANT Docket No. 50-400 1

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l R. S. Hartley C. B. Ransom i

Published November 1998 Idaho National Engineering and Environmental Laboratory Nuclear Operations Support Programs Department Lockheed Martin Idaho Technologies Company Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-94ID13223 JCN-J-2422, Task Order 5, TAC No. MA0815 9902090043 990201 PDR ADOCK 05000400 P PDR 1

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l l ABSTRACT i

This Lockheed Martin Idaho Technologies Company (LMITCO) repon presents the ,

results of our evaluation of the Shearon Harris Nuclear Power Plant Inservice Testing Program l for pumps and valves whose function is safety-related.

l PREFACE This report is supplied as part of the " Review of the Proposed Alternative Testing and Relief Requests for the Shearon Harris Nuclear Power Plant Inservice Testing Program Second Ten Year Interval Which Require NRC Review" being conducted for the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by LMITCO, Nuclear Operations Support Programs.

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CONTENTS AB STRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii 1

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PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i i  ;

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1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l

2. SCOPE....................................................................3 l

3. PUMP TESTING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.1 Auxiliary Feedwater Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1

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4. VALVE TESTING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.1 Condensate Syste m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1

4.1.1 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l 4.2 Component Cooling Wate.- System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i i

1 4.2.1 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i I

4.3 Containment Vacuum Breaker System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.3.1 Category A/C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 i

4.4 Containment Spray System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 I

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-4.4.1 Category A/C Val ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 j.

4.5 Instrument Air System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.5.1 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.6 M ain S team Sy stem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.6.1 Category C Val ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.7 Safety Injection System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 4.7.1 Category A/C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 APPENDIX A-IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW . . . . . . . . . A-1 l APPENDIX B-IST PROGRAM ISSUES IDENTIFIED DURING THE SYSTEMS REVIEW . . . . B 1 APPENDIX C-DEFERRED TEST JUSTIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1 111 l

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SHEARON HARRIS NUCLEAR POWER PLANT

1. INTRODUCTION Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by the Carolina Power and Light Company (CP&L) for its Shearon Harris Nuclear Power Plant.

By a letter dated January 27,1998, CP&L submitted Revision 0 of their IST program for Shearon Harris Nuclear Power Plant. The program for the Second Ten Year Interval begins on February 2,1998 and continues to May 1,2007. The program was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety-related with the requirements of the 2

American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,1989 Edition.

This technical evaluation report (TER) does not address any IST program revisions subsequent to those noted above. Program changes involving additional or revised relief requests should be submitted to the U.S. Nuclear Regulatory Commission (NRC) under separate cover in order to receive prompt attention, but should not be implemented prior to review and approval by the NRC.

In its IST program, CP&L requests relief from the Code testing requirements for specific pumps and valves. These requests were evaluated individually to determine if the criteria in 10 CFR 50.55a for granting relief or authorizing alternatives are met for the specific pumps and valves. This review was performed utilizing the acceptance criteria and guidance of the following:

. Standard Review Plan, Section 3.9.6 Draft Regulatory Guide and Value/ Impact Statement titled " Identification of Valves for Inclusion in Inservice Testing Programs" Generic Letter.No. 89-04, " Guidance on Developing Acceptable Inservice Testing Programs"

. NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants" NUREG/CR-6396,." Examples, Clarifications, and Guidance on Preparing Requests for Relief from Pump and Valve Inservice Testing Requirements" Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756,

" Inservice Testing of Pumps and Valves," and Answers to Panel Questions on Inservice Testing Issues IST Program testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requirements.

Section 2 of this repon presents the scope of the Shearon Harris Nuclear Power Plant review.

Section 3 of this repon presents the CP&L bases for requesting relief from the OM Code 1

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requirements for the Shearon Harris Nuclear Power Plant pump testing program and Lockheed Martin Idaho Technologies Company's (LMITCO's) evaluations and conclusions regarding these requests. Section 4 presents similarinformation for the valve testing program.

i l Appendix A contains a listing ofinconsistencies and omissions in the licensee's program noted during this review. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

Appendix B contains a listing of issues identified during a review of the Chemical and Volume Control System (CVCS) and the Component Cooling Water (CC) system. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

Appendix C provides a brief description of the licensee'sjustifications for deferring tests to cold shutdowns or refueling outages.

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2. SCOPE The LMITCO staffreviewed the Shearon Harris Nuclear Power Plant inservice testing (IST) program pump and valve relief requests, cold shutdownjustifications, and refueling outage justifications. The staff specifically reviewed the Chemical and Volume Control System (CVCS), the Component Cooling Water (CC) system, and the Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS) for these systems. The staffidentified'on the plant's P&ID(s) each component in the CVCS and CC systems listed in the IST program and evaluated the test (s) designated in the i IST program to assess compliance with the applicable American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code test requirements. Following this review, the staff assessed the designated systems for completeness (to determine if additional components should have been included in the IST program). This review yielded a list ofissues that should be addressed by the licensee as summarized in Appendices A and B.

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3. PUMP TESTING PROGRAM The Shearon Harris Nuclear Power Plant IST program pump relief requests submitted by the Carolina Power and Light (CP&L) Company were examined to determine whether relief should be granted or alternatives authorized according to the requirements of 10 CFR 50.55a and NRC positions and guidance.

Each CP&L basis for requesting relief from the pump testing requirements and proposed altemative testing and the reviewer's evaluation of that request is summarized below.

3.1 Auxiliary Feedwater Pumps 3.1.1 Relief Request. Pump relief request, AF-PRI, requests relief from the full-scale range requirements specified in Part 6, Para. 4.6.1.2(a), for the motor driven Auxiliary Feedwater (AFW) Pumps, AFIA-SA and AFIB-SB, and proposes to measure the Code required parameters using the permanently installed instruments that exceed the full-scale range requirements.

3.1.1.1 Licensee's Basis for Requesting Relief 'Ihe permanently installed flowinstrument which is utilized to conduct the quarterly pump tests of the two motor driven auxiliary feedwater pumps (AFI A-SA and AFIB-SB) has a calibrated full scale range which exceeds a factor of three times their reference values. The full scale range of the instrument, FI-2172, is 0-200 gpm while the reference value of each pump is 51 gpm. FI-2172 is installed in a common pump recirculation line which is shared by both the two motor driven AFW pumps and the single turbine driven AFW pump. The indicator is sized to accommodate the combined restricted flows of all three pumps simultaneously. Although the full scale range of FI-2172 does not comply with Code requirements, its accuracy of 1% of full scale exceeds that which is required.

Even though FI-2172 does not meet the Code requirement for range,it is capable of providing an indicated accuracy at the refnence value that is superior to the minimum indicated accuracy that would be required by the Code. Based on the least accurate instrument that would theoretically be allowed by the Code, the minimum required indicated accuracy is +6%. (This fact is documented by NUREG-1482, paragraph 5.5.1.)

The indicated accuracy of FI 2172, as derived based upon the current reference values, is as follows:

Reference value = 51 gpm Full scale range = 200 gpm Instrument tolerance = 2 gpm ( 1% x 200 gpm)

Therefore the indicated accuracy is: 2 gpm / 51 gpm x 100% = 3.9%

As demonstrated, the indicated accuracy of FI 2172 is better than that which is theoretically allowed by the Code.

Proposed Alternate Testing: The existing permanently installed pump instrument is acceptable because the indicated accuracy is less than or equal to 6% as calculated at the reference value. No alternate testing or instrumentation will be utilized.

3.1.1.2 Evaluation-The purpose of the instrument quality and full-scale range requirements is to ensure that the test measurements provide information that is sufficiently accurate and repeatable to monitor pump condition and detect degradation. Using instruments that do not meet these requirements may inhibit the detection of pump hydraulic degradation. The licensee provided information on the installed instrumentation accuracies, reference values, and ranges and demonstrated that it is adequate to detect pump l

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degradation. Additionally, the licensee identified the burden of using test or portable instruments that meet l the Code requirements.

l NUREG 1482 provides guidelines for development and implementation of programs for IST of pumps and valves at nuclear power plants. Section 5.5.1, " Range and Accuracy of Analog Instruments" discusses situations where the range of permanently installed instrumentation is greater than three times the reference value but the accuracy of the instrument is more conservative than the OM Code. Under such circumstances, the NUREG indicates the NRC will grant relief when the combination ofrange and accuracy yields a reading at least equivalent to the reading achieved from the instruments that meet the Code requirements. l The installation and removal of temporary test gauges creates a hardship for the licensee. The use of temporary test gauges is undesirable due to the inherent risks associated with the breaking and re-assembly of mechanical connections, the additional calibration requirements associated with temporary instrumentation, and the additional man-hours required to install and remove the temporary mstrumentation.

Based or, the determination that the compliance with the Code full-scale range requirements for auxiliary feedwater pump flow instrument poses a hardship that is not compensated by a corresponding increase in safety and considering the licensee's proposed alternative to utilize existing plant instrumentation that is more accurate than the Code requirement and comply with all other related Code requirements for hydraulic testing of the auxiliary feedwater pumps, the alternative should be authorized according to 10 CFR 50.55a(a)(3)(ii).

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4. VALVE TESTING PROGRAM The Shearon Harris Nuclear Power Plant IST program submitted by the CP&L Company was examined to verify that all valves that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI,1989 Edition, and the NRC positions and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines. Each CP&L Company basis for requesting relief from the valve testing requirements and the reviewers' evaluation of that request is summarized below and grouped according to the system and valve Category.

4.1 Condensate System 4.1.1 Category C Valves 4.1.1.1 Relief Request. Valve Relief Request CE-VR1 requests relief from the exercising requirements of OM-10, Para. 4.3.2, for the check valves in the line from the condensate storage tank to the suction of the auxiliary feedwater pumps,1 CE-36,1 CE-46, and 1 CE-56, and proposes to include these valves  !

in a sample disassembly and inspection group and to disassemble and inspect one valve from the group each refueling outage on a rotating basis.

4.1.1.1.1 Licensee's Basis for Requesting Relief-These valves are in the auxiliary feedwater pump suction line from the condensate storage tank. These valves are dual plate check valves constructed by the same manufacturer, utilizing, the same materials and have the same service conditions. ICE-36 and 1CE-46 are 6 inch valves. ICE-56 is an 8 inch valve. The dual plate check valve is designed to block flow in only one direction and operate as a result of differential pressure. Two half-disc spring loaded plates are used as closure members hinged on a certral vertical single pin. A torsion spring is used to actuate the plates for positive closure.

The auxiliary feed water pumps have two sources of supply water. The condensate storage tank (CST) provides chemically treated condensate water and is the preferred source of water. The emergency service water (ESW) system is the alternate source and because it is not chemically treated it would be used only in an extreme emergency. The motor driven and turbine driven auxiliary feedwater pumps normally take suction from the CST via the common supply line. The safety function of these valves is to close to direct supply ESW system water to the suction of the auxiliary feedwater pumps when the CST is depleted.

It is not practical to verify closure of the subject check valves during power operation or during cold shutdowns. In order to verify closure of the subject valves, the CST would have to be drained and untreated ESW water would have to be introduced to the suction of the auxiliary feed water pumps. The ESW supply to the auxiliary feedwater pumps is normally isolated by two isolation valves for each connection between the auxiliary feedwater and ESW system. This prevents inadvertent leakage contamination of the auxiliary feedwater by impurities in the service water. Introduction of untreated water to the auxiliary feedwater system could negatively affect secondary plant water chemistry and could eventually cause damage to plant equipment. The use of non-intrusive techniques to conclusively verify closure of the subject valves as a result of cessation of pump flow is not considered practical due to the dual plate design of these valves.

Proposed Altemate Testing: A full-stroke closure of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04

" Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of similar design (manufacturer, model number and materials of construction) and have the same service conditions including valve orientation. 'Ihe only Position 2 criterion not met is the common size for all valves in the sampling group.1CE-36 and ICE-46 are 6 inch valves and 1CE-56 is an 8 inch valve. As identified in the NRC safety 7

evaluation / technical evaluation (page 38 dated April 27, 1988) of the HNP ist Ten-Year Interval IST Program, "Since all other factors are identical for these valves, the reviewer feels that even with the size disparity, these valves should be allowed to be grouped together because any failure mechanism should be common for all three valves."

Since the failure mechanism should be common for all three valves, only one of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected l for worn or corroded pans, and the valve disk will be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other two valves in this group will also be disassembled, inspected, and manually full-stroke exercised during the same i refueling outage.

4.1.1.1.2 Evaluation-Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing ... [ exercising a check valve with flow or a manual exerciser], disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and reliefis not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of cenain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves if it is performed in accordance with the requirements of Position 2.

Generic Letter 89-04, Position 2, states: "The sample disassembly and inspection program involves grouping similar valves and testing one valve in each group during each refueling outage. The sampling technique requires that each valve in the group be the same design (manufacturer, size, model number, and materials of construction) and have the same service conditions including valve orientation."

This relief request is for the check valves in the suction lines from the condensate storage tank to the

!wo motor driven auxiliary feedwater pumps and the turbine driven auxiliary feedwater pump. The licensee pcoposes to group these valves in a sampling group as permitted by GL 89-04, Position 2. However, since these valves are different sizes (6" and 8"), they do not meet the grouping criteria of the GL. Therefore, relief is necessary to group the 8" valve with the two 6" valves for sample disassembly and inspection as proposed.'

An essential element of the sampling concept is that the valves in a group be essentially identical and see identical service so they would degrade nearly identically and would accurately reflect the condition of each other. Therefore, when one valve of the group is inspected and found to be in good condition, this inspection would provide a high level of assurance that the other group valves are also in good condition.

Conversely,if the sampled valve is found to be degraded, the other group valves should have nearly identical levels of degradation. If for any reason, the condition of a valve in a sample group does not accurately reflect the condition of the other valves in the group, then the valves should not be grouped together for sampling

purposes.

l The licensee indicated that these valves are of siinitar design and that they have the same service i conditions. Because of these similarities; the subject valves should be affected by the same degradation

( mechanisms and display similar levels of degradation. These valves are in a standby system and do not

! normally experience flow. Generally, flow is only established through these valves during plant startup and shutdown, for the valves in the lines to the motor driven pumps, and during testing. Since these valves are almost always in the closed position in a standby system, the main factors that could affect degradation are corrosion and the wear that occurs when flow is established through them. Since the water used in all three l 8

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I of the affected flow paths comes from the CST, the corrosion rate for all three valves should be nearly  ;

identical. There is a difference in service conditions for these valves since the turbine driven auxiliary I feedwater pump is not used to maintain steam generator water level during plant startups and shutdowns, as are the motor driven pumps. However, this difference should not be great and should not result in a large disparity in the condition of the suction line check valves. Therefore, the condition of a sampled valve l should be similar to the condition of the other vsives in the proposed sample group. However, the licensee has not provided a detailed justification that de.nonstrates that the differences in valve size and service conditions would not cause differences in valve degradation mechanisms or rates that could preclude the l valves from being placed in the same sample group for disassembly and inspection.

I Long term authorization should not be provided for the licensee's proposed alternative. An interim period of one year or until the next refueling outage, whichever is shorter, is authorized to allow the licensee to develop the information tojustify placing valves of different sizes and of different service conditions in the same sample group. This information may include, but not be limited to, generic and plant specific test data, system operational data, design and maintenance information, and generic and plant specific failure information. The burden falls upon the licensee to demonstrate that valves of different sizes and slightly different service conditions should be included in the same disassembly and inspection group. The proposed alternative provides reasonable assurance of operational readiness for the interim period because the length of the interim period does not extend beyond the next refueling outage and these valves are only disassembled and inspected during refueling outages.

The staff has recently approved an alternate method for testing check valves at the Wolf Creek Generating Station in a safety evaluation dated November 26,1997. In the safety evaluation, the staff allows the use of Appendix II, Check Valve Condition Monitoring Program, included in ASME OM Code-1996 Addenda to the ASME OM Code-1995 Edition. Appendix II was authorized for use with a number of

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conditions and limitations including: (1) where the most frequently performed appropriate measure (test, examination, or preventive maintenance) extends beyond 60 months, performance, examination, maintenance history, and test experience from previous tests shall be evaluated tojustify the periodic verification interval; (2) the test or examination interval shall not exceed 120 months; (3) risk insights from other activities may be used when reviewed and approved by the staff to ensure that the testing, examination, or preventive measures taken are commensurate with each valve's safety significance; (4) check valve obturator movement will be tested or examined in both the open and closed direction to ensure unambiguous detection of functionality degraded check valves; (5) extensions of IST intervals will consider plant safety impact and be supported andjustified by applicable methods of trending to provide assurance that the valve is capable of performing its intended function over the entire interval;(6) initial IST interval extensions cf any valve must be limited to two fuel cycles or 3 years, and subsequent extended intervals must be limited to one fuel cycle per extension, up to 10 years; and (7) if the Condition Monitoring Program is discontinued, the testing and examination will revert back to the original ASME Code requirements. The staff considers that check valve issues can be addressed by adoption of a check valve condition monitoring program as provided in Appendix II of the 1995 ASME OM Code. The licensee should consider this approach in evaluating their Code check valve testing program at their site.

$ The proposed alternative to the Code check valve disassembly and inspection frequency requirements for the check valves in the auxiliary feedwater pump suction lines from the CST, ICE-36, ICE-46, and ICE-56, is authorized on an interim basis pursuant to 10 CFR 50.55a(a)(3)(ii), based on the determination that compliance with the specified requirements results in a hardship without a compensating increase in the level of quality and safety. The lyh of the interim period is one year or the next refueling outage, whichever is shorter. During the interim period, the licensee should develop detailed justification as to why these valves should be included in the same disassembly and inspection group. Alternatively, the licensee should consider use of Appendix II of the 1995 OM Code for condition monitoring of check valves.

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i 4.2 Component Cooling Water System 4.2.1 Category C Valves l 4.2.1.1 Relief Request. Valve Relief Request CC-VR1 requests relief from the full-stroke exercising l

requirements of OM-10, Para. 4.3.2, for the component cooling water (CCW) retum check valves from the '

gross failed fuel detector cooler, ICC-306 and ICC-307, and proposes to include these valves in a sample j disassembly and inspection group and to disassemble and inspect one valve from the group each refueling i outage on a rotating basis.

i 4.2.1.1.1 Licensee's Basis for Requesting Relief-It is impractical to verify a full-stroke closure exercise of the subject check valves during power operation, during cold shutdowns or refueling outages. These valves are 0.75 inch forged steel piston check valves. These valves are located in the return line from the gross failed fuel detector. During normal plant operation these valves are open to provide a flow path from the gross failed fuel detector cooler to the suction of the CCW pumps. In the event of a failure of the integrity of the non-safety related gross failed fuel detector cooler or associated components, two redundant components are provided on the inlet and return lines as required by the system design. The isolation function of the outlet line is performed by the active closure of ICC-3% and ICC-307.

Since the subject check valves are installed in series with no intermediate test connections to verify individual valve closure they carmot be tested with system flow under any plant conditions. It is not practical to verify the full stroke closure of these valves utilizing non-intrusive diagnostic methods due to their size.

Since the design of the system requires two valve isolation, and since it is not practical to test the pair of valves in accordance with the requirements of the Code, these valves shall be disassembled as described in section 4.1.1 of USNRC NUREG-1482 " Guidelines for Inservice Testing at Nuclear Power Plants."

Proposed Alternate Testing: A full-stroke closure exercise of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04 " Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of the same design (manufacturer, size, model number and materials of construction) and have the same service conditions including valve orientation and together consist of one group. One of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for worn or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other valve in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same mfueling outage.

4.2.1.1.2 Evaluation-The subject valves are simple check valves in the CCW return line from the gross failed fuel detector cooler. These valves do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise to the closed position is by observing a reverse flow differential pressure across the valves. It is impractical to verify a reverse flow differential pressure across these valves at any frequency because they are installed in series without test taps between them or the instrumentation necessary to make this verification. Verifying a full-stroke exercise closed of these check valves could only be accomplished if test taps and differential pressure instmmentation were installed in these lines. Since it is impractical to verify reverse flow differential pressure across these valves using conventional methods, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing ... [ exercising a check valve with flow or a manual exerciser), disassembly every refueling outage to verify operability of check 10

l valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance with the requirements of Position 2.

Based on the determination that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each group valve every refueling outage would result in hardship or unasual burden to the licensee without providing a compensating increase in the level of quality and safety and considering the licensee's proposed sample disassembly and inspection of l

check valves ICC-306 and ICC-307 is performed in accordance with the conditions specified in GL 89-04, l Position 2, the alternative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii).

l 4.2.1.2 Relief Request. Valve Relief Request CC-VR2, requests relief from the exercising requirements of OM-10, Para. 4.3.2, for the check valves in the CCW supply lines to the reactor coolant pump (RCP) thermal barriers, ICC-216,1CC-227, and ICC-238, and proposes to include these valves in a sample disassembly and inspection group and to disassemble and inspect one valve from the group each

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refueling outage on a rotating basis.

4.2.1.2.1 Licensee's Basis for Requesting Relief--It is impractical to perform a full-stroke closure exercise of the subject check valves during power operations, cold shutdown and refueling outages.

The subject check valves are located inside primary containment in the CCW supply lines to the individual RCP thermal barrier heat exchangers. These valves are not provided with external position indication.

One of the functions of the CCW system is to provide coolant to the three RCP packages, each consisting .

of one upper bearing lube oil cooler, one lower bearing lube oil cooler and one thermal barrier cooler. The thermal barrier is located between the turning vane diffuser and the pump shaft. During normal operation the thermal barrier heat exchanger is passive. The cooling and lubrication requirements for the RCP bearing and shaft seal assembly are supplied by seal injection water from the chemical and volume control system.

In accordance with plant procedures, CCW flow through the thermal barrier heat exchanger should be supplied at all times when reactor coolant system (RCS) temperature exceeds 200 F. In the event of a loss of seal injection, RCS water flows up through the thermal barrier heat exchanger to supply the radial bearings and shaft seal with water. The RCS water is cooled by the CCW circulating through the heat exchanger.

In the event of a failure of the integrity of the thermal barrier heat exchangers, the RCS leakage is required to be isolated by the closure of ICC-251, ICC-252 and the subject supply line check valves.

Testing of the subject valves is not practical during power operation and cold shutdowns. The only possible methods available to verify valve closure are by providing an alternate pressurized water source downstream of the valve and establishing a differential pressure across the valve disk, or by disassembly. Both methods would require entry into primary containment and draining significant sections of CCW piping. Testing during power operations is not practical since plant procedures require CCW flow to the thermal barrier heat exchanger at all times when RCS temperature exceeds 200'F. Testing during cold shutdowns is not practical since cooling water to the RCP thermal barriers and motor bearings must be isolated to perform the test. This would require all RCPs to be stopped.

Proposed Alternate Testing: A full-stroke closure exercise of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04 " Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of the 11

1 O

I I l same design (manufacturer, size, model number and materials of construction) and have the same service I

conditions including valve orientation and together consist of one group. One of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for wom or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other two valves in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same refueling outage.

4.2.1.2.2 Evaluation--The subject valves are simple check valves in the CCW supply lines to the RCP thermal barriers. These valves do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise to the closed position is by observing a reverse flow differential pressure across the valves. It is impractical to exercise these valves closed during power operation, because CCW flow is required to the thermal barriers whenever the RCS temperature is greater than 200 F. It is impractical to verify valve closure during cold shutdowns, because to perform this testing would require CCW flow to the RCPs be stopped and portions of the system to be drained. Stopping all three RCPs, draining portions of the CCW system piping, and establishing test conditions to verify a reverse flow differential pressure across these valves would be an involved process that would be burdensome to perform during cold shutdowns because it could delay startup from the shutdown. It is impractical to verify a reverse flow differential pressure across these valves at any frequency because they are installed in series with valves ICC-215, ICC-226, and ICC-237 respectively, and there are no test taps between the series valves or other means of making this verification. Since it is impractical to verify reverse flow closure of these valves using system flow, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing . . [ exercising a check valve with flow or a manual exerciser], disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance with the requirements of Position 2.

Based on the determistion that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each groep valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the level of quality and safety and considering the licensee's proposed sample disassembly and inspection of check valves ICC-216, ICC-227, and 1CC-238 is performed in accordance with the conditions specified in GL 89-04, Position 2, the alternative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii).

4.3 Containment Vacuum Breaker System 4.3.1 Categcry A/C Valves 4.3.1.1 Relief Request. Valve Relief Request CB-VR 1 requests relief from the safety and relief valve test frequency requirements of OM-1, Para.1.3.4.3(a), for the containment vacuum relief valves,1CB-3 and ICB-7, and proposes to verify their open and close capability and set pressure each refueling outage.

12

4.3.1.1.1 Licensee's Basis for Requesting Relief-These vacuum breaker check valves are self-actuated and are located inside the primary reactor containment. Due to their physical location, there is no practical means to verify the open and close capability and set pressure on a 6 month frequency as required by OM 1, Para 7.3.2.4(a). Relief from this requirement is requested since OM-1 does not provide any provision to defer testing if it is considered to be impractical.

These valves are 24" swing type check valves with no pressure or position sensing accessories. The valve disk is normally held in the closed position by the force of two springs mounted on the valve pivot shaft.

At a predetermined set pressure, an equilibrium exists where the seal area times set pressure are equal to and balanced against the spring, when the valve is closed. When a differential across the valve causes a torque about the shaft greater than that produced by these forces, the valve will open as long as this force remains greater than the closing force produced by the two springs. When the flow and differential pressure drops to the extent that they produce less torque than the two springs, the valve will close.

The only practical method to verify the open and close capability is to manually exercise the valve disk through a complete cycle. The Containment Vacuum Relief System is not provided with the means to actuate these valves to the open or closed position with flow. Since, these valves are normally seated by spring pressure, the only practical method to verify the setpoint of the valves is to use a calibrated spring scale to measure the force required to unseat the disk.

Each of these activities would require entry into primay containment at power which is impractical.

Containment entries during operational modes I through 4 are undesirable from a personnel safety standpoint due to the high radiation environment and the high ambient temperatures affecting work conditions.

Additionally, entry into containment during power operation is administratively controlled by a plant procedure with requirements to perform pre-entry airbome radioactivity and air quality samples, implementation of heat stress controls, control of materials, radiological controls, a containment closeout inspection, and a localleakage rate test of the applicable entry hatch seals.

Testing during non-planned cold shutdown periods is also impractical due to the requirement to enter containment and the need to build scaffolding to access the valves. Additionally,in order to complete the testing of the subject valves, test equipment to verify the opening setpoint must be installed and subsequently removed.

Proposed Alternate Testing: The subject valves shall be tested to verify their open and close capability and set pressure in accordance with the requirements of OM-1 each refueling outage.

4.3.1.1.2 Evaluation--The subject vacuum breaker valves are swing check valves with springs attached to the disks to keep the disks closed until sufficient differential pressure exists across the valves to cause them to open. These valves do not have remote operators or differential pressure indication, therefore, the only practicable method of exercising them and verifying set pressure is to access the valves and test them using a calibrated spring scale.

It is impractical to exercise these valves during power operation, because they are located inside of primary containment. There are several reasons that containment should not be entered during power operations to perform routine testing. The main reason that containment entry during power operations is impractical is personnel safety because of the high energy /high temperature systems and the high radiation levels present. This testing is also impractical during cold shutdowns because it involves setting up scaffolding and test equipment, which could require sufficient time that it could delay a return to power from the cold shutdown condition.

13

In NUREG 1482, the NRC staff acknowledged that it is impractical to test some components at the Code required intervals because of their location. Paragraph 2.5.1 states: "The required measurements or

! appropriate observations cannot be made because of physical constraints. Examples include a component l located in an area inaccessible during power operation...." Personnel safety considerations and administrative controls make the containment essentially inaccessible during power operation. Therefore,

it is impractical to test these vacuum breaker valves during power operation. Furthermore, the scope of preparation and setup to perform this testing make it impractical during each cold shutdown, be

ause setting up and performing this testing could delay retuming the plant to power.

An additional consideration is that in recent editions of the ASME OM Code, the Code Committee has changed the requirement to perform an operability test on primary containment vacuum relief valves from once every 6 months to "at each refueling outage or every 2 years, whichever is sooner, unless historical data requires more frequent testing"(see ASME OMc Code-1994, Appendix I, Para. I-1.3.7(a) and equivalent paras, from more recent Code editions).

I Based on the determination that testing these valves every six months during power operations is impractical because of their location inside the primary containment and testing them during cold shutdowns is also impractical because the necessary setup and preparation could result in delaying returning the plant to power, and considering that the proposal to test these valves each refueling outage should provide a reasonable assurance of valve operational readiness, relief should be granted for the subject valves in accordance with 10 CFR 50.55a(f)(6)(i), as requested by the licensee.

4.4 Containment Spray System 4.4.1 Category A/C Valves 4.4.1.1 Relief Request. Valve Relief Request CT-VR1, requests relief from the exercising requirements of OM-10, Para. 4.3.2, for the check valves in the containment spray pump discharge lines to the containment nozzles,1CT-53 and ICT-91, and proposes to include these valves in a sample disassembly and inspection group and to disassemble and inspect one valve from the group each refueling outage on a rotating basis.

4.4.1.1.1 Licensee's Basis for Requesting Relief-It is not practical to perform a full or part-stroke open exercise test of the subject valves during power operations or during cold shutdowns. These valves are 8 inch stainless steel swing check vaives. The subject valves are located inside the primary containment building, in the containment spray pump discharge lines to the containment spray nozzles.

The primary purpose of the containment spray system is to remove heat and fission products from a post-accident containment atmosphere. The containment spray system consists of two independent and redundant loops each containing a spray pump, piping, valves, spray headers and spray valves. The operation of the containment spray system is automatically initiated by the containment spray actuation signal (CS AS) which occurs when a containment pressure (Hl-3) signal is reached. Upon receipt of the CSAS, the containment spray pumps are started and borated water from the refueling water storage tank (RWST)(injection phase)

! or the containment recirculation sumps (recirculation phase)is discharged into the containment through the containment spray headers.

The subject check valves are normally closed during plant operation. These valves have a safety function to open to allow containment spray system water to discharge to the containment spray nozzles. Since, the subject check valves are located downstream of the full flow recirculation line test circuit, the only way to verify full or part-stroke exercise these valves to the open position would be by injecting a large quantity of I

14 l

l 1

l water into the containment utilizing the containment spray pumps. Spraying the containment could result in extensive damage to plant equipment located inside containment during all modes of plant operation.

The only practical method available to verify full-stroke opening capability is by disassembly and manually l exercising the valve disk. The use of non-intrusive techniques to conclusively verify opening of the subject  ;

valves would also require flowing large quantities of water into the containment building which is I impractical.

l Proposed Alternate Testing: A full-stroke opening exercise of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04 " Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of the same design (manufacturer, size, model number and materials of constmetion) and have the same service conditions including valve orientation and together consist of one group. One of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for worn or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not l capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other valve in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same refueling outage.

After the disassembly of the sul iect valves, these valves will be local leakage rate tested in accordance with the requirements of 10 CFR 50, Appendix J.

4.4.1.1.2 Evaluation--The subject valves are simple check valves in the containment spray pump discharge lines to the containment spray nozzles. These valves are located inside containment and do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise open is to pass maximum accident condition flow through the valves. The only flow path through these valves is into the spray nozzles and into the reactor containment, therefore, exercising these valves open with flow would result in spraying large quantities of water into containment. It is impractical to establish spray flow into the containment for testing during any plant mode, because this could result in damage to equipment and instrumentation. Full-stroke exercising the subject valves open with flow could only be accomplished if full flow test lines were installed downstream of the valves. Installing such test lines would be burdensome to the licensee and could result in reduced system reliability because of the increased chance of operator or equipment failure. Since it is impractical to exercise these valves open using conventional methods, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

i Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing . . (exercising a check l valve with flow or a manual exerciser], disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly i and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter l 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance l with the requirements of Position 2.

Based on the determination that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each group valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the 15

• 1 i

same design (manufacturer, size, model number and materials of construction) and have the same service conditions including valve orientation and together consist of one group. One of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for worn or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other two valves in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same refueling outage.

4.2.1.2.2 Evaluation--The subject valves are simple check valves in the CCW supply lines to the RCP thermal barriers. These valves do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise to the closed position is by observing a reverse flow differential pressure across the valves. It is impractical to exercise these valves closed during power operation, because CCW flow is required to the thermal barriers whenever the RCS temperature is greater than 200 F. It is impractical to verify valve closure during cold shutdowns, because to perform this testing

. would require CCW flow to the RCPs be stopped and portions of the system to be drained. Stopping all three RCPs, draining portions of the CCW system piping, and establishing test conditions to verify a reverse flow differential pressure across these valves would be an involved process that would be burdensome to perform during cold shutdowns because it could delay startup from the shutdown. It is impractical to verify a reverse flow differential pressure across these valves at any frequency because they are installed in series with valves ICC-215, ICC-226, and ICC-237 respectively, and there are no test taps between the series valves or other means of making this verification. Since it is impractical to verify reverse flow closure of these valves using system flow, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

I Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing ... (exercising a check valve with flow or a mam.al exerciser), disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-N grants relief to use sample disassembly and inspection ofcheck valves ifit is performed in accordance with the requirements of Position 2.

Based on the determination that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each group valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the level of quality and safety and considering the licensee's proposed sample disassembly and inspection of check valves ICC-216, ICC-227, and ICC-238 is performed in accordance with the conditions specified in GL 89-04, Position 2, the attemative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii),

i 4.3 Containment Vacuum Breaker System 4.3.1 Category A/C Valves 4.3.1.1 Relief Request. Valve Relief Request CB-VR 1 requests relief from the safety and relief valve test frequency requirements of OM-1, Para.1.3.4.3(a), for the containment vacuum relief valves,1CB-3 and ICB-7, and proposes to verify their open and close capability and set pressure each refueling outage.

L L

12

4.3.1.1.1 Licensee's Basis for Requesting Relief-These vacuum breaker check valves are self-actuated and are located inside the primary reactor containment. Due to their physical location, there is no practical means to verify the open and close capability and set pressure on a 6 month frequency as required by OM-1, Para 7.3.2.4(a). Relief from this requirement is requested since OM-1 does not provide any provision to defer testing ifit is considered to be impractical.

These valves are 24" swing type check valves with no pressure or position sensing accessories. The valve disk is normally held in the closed position by the force of two springs mounted on the valve pivot shaft.

At a predetermined set pressure, an equilibrium exists where the seal area times set pressure are equal to and balanced against the spring, when the valve is closed. When a differential across the valve causes a torque about the shaft greater than that produced by these forces, the valve will open as long as this force rernains greater than the closing force produced by the two springs. When the flow and differential pressure drops to the extent that they produce less torque than the two springs, the valve will close.

The only practical method to verify the open and close capability is to manually exercise the valve disk through a complete cycle. The Containment Vacuum Relief System is not provided with the means to actuate these valves to the open or closed position with flow. Since, these valves are normally seated by spring pressure, the only practical method to verify the setpoint of the valves is to use a calibrated spring scale to measure the force required to unseat the disk.

Each of these activities would require entry into primary containment at power which is impractical.

Containment entries during operational modes 1 through 4 are undesirable from a personnel safety standpoint due to the high radiation environment and the high ambient temperatures affecting work conditions.

Additionally, entry into containment during power operation is administratively controlled by a plant procedure with requirements to perform pre-entry airborne radioactivity and air quality samples, implementation of heat stress controls, control of materials, radiological controls, a containment closeout inspection, and a local leakage rate test of the applicable entry hatch seals.

Testing during non-planned cold shutdown periods is also impractical due to the requirement to enter containment and the need to build scaffolding to access the valves. Additionally,in order to complete the testing of the subject valves, test equipment to verify the opening setpoint must be installed and subsequently removed.

Proposed Alternate Testing: The subject valves shall be tested to verify their open and close capability and set pressure in accordance with the requirements of OM-1 each refueling outage.

4.3.1.1.2 Evaluation- The subject vacuum breaker valves are swing check valves with springs attached to the disks to keep the disks closed until sufficient differential pressure exists across the valves to cause them to open. These valves do not have remote operators or differential pressure indication, therefore, the only practicable method of exercising them and verifying set pressure is to access the valves and test them using a calibrated spring scale, it is impractical to exercise these valves during power operation, because they are located inside of primary containment. There are several reasons that containment should not be entered during power operations to perform routine testing. The main reason that containment entry during power operations is impractical is personnel safety because of the high energy /high temperature systems and the high radiation levels present. This testing is also impractical during cold shutdowns because it involves setting up scaffolding and test equipment, which could require sufficient time that it could delay a return to power from the cold shutdown condition.

13

t In NUREG 1482, the NRC staff acknowledged that it is impractical to test some components at the Code required intervals because of their location. Paragraph 2.5.1 states: "The required measurements or appropriate observations cannot be made because of physical constraints. Examples include a component located in an area inaccessible during power operation... " Personnel safety considerations and administrative controls make the containment essentially inaccessible during power operation. Therefore, it is impractical to test these vacuum breaker valves during power operation. Furthermore, the scope of preparation and setup to perform this testing make it impractical during each cold shutdown, because setting up and performing this testing could delay returning the plant to power.

An additional consideration is that in recent editions of the ASME OM Code, the Code Committee has changed the requirement to perform an operability test on primary containment vacuum relief valves from once every 6 months to "at each refueling outage or every 2 years, whichever is sooner, unless historical data requires more frequent testing"(see ASME OMc Code-1994, Appendix I, Para.11.3.7(a) er:d equivalent paras. from more recent Code editions).

Based on the determination that testing these valves every six months during power operations is impractical because of their location inside the primary containment and testing them during cold shutdowns is also impractical because the necessary setup and preparation could result in delaying returning the plant to power, and considering that the proposal to test these valves each refueling outage should provide a reasonable assurance of valve operational readiness, relief should be granted for the subject valves in accordance with 10 CFR 50.55a(f)(6)(i), as requested by the licensee.

4.4 Containment Spray System 4.4.1 Category A/C Valves 4.4.1.1 Relief Request. Valve Relief Request CT-VR1, requests relief from the exercising requirements of OM-10, Para. 4.3.2, for the check valves in the containment spray pump discharge lines to the centainnent nozzles,1CT-53 and 1CT-91, and proposes to include these valves in a sample disassembly and inspection group and to disassemble and inspect one valve from the group each refueling outage on a rotating basis.

4.4.1.1.1 Licensee's Basis for Requesting Relief-It is not practical to perform a full or part-stroke open exercise test of the subject valves during power operations or during cold shutdowns. These '

valves are 8 inch stainless steel swing check valves. The subject valves are located inside the primary containment building, in the containment spray pump discharge lines to the containment spray nozzles.

The primary purpose of the containment spray system is to remove heat and fission products from a post-accident containment atmosphere. The containment spray system consists of two independent and redundant loops each containing a spray pump, piping, valves, spray headers and spray valves. The operation of the containment spray system is automatically initiated by the containment spray actuation signal (CSAS) which occurs when a cortainment pressure (HI-3) signal is reached. Upon receipt of the CSAS, the containment spray pumps are started and borated water from the refueling water storage tank (RWST) (injection phase) or the containment recirculation sumps (recirculation phase) is discharged into the containment through the containment spray headers.

The subject check valves are normally closed during plant operation. These valves have a safety function to open to allow containment spray system water to discharge to the containment spray nozzles. Since, the subject check valves are located downstream of the full flow recirculation line test circuit, the only way to i

verify full or part-stroke exercise these valves to the open position would be by injecting a large quantity of .

14

i l 1

water into the containment utilizing the containment spray pumps. Spraying the containment could result in extensive damage to plant equipment located inside containment during all modes of plant operation.

\ l l I The only practical method available to verify full-stroke opening capability is by disassembly and manually exercising the valve disk. The use of non-intrusive techniques to conclusively verify opening of the subject valves would also require flowing large quantities of water into the containment building which is i impractical.

l l

Proposed Alternate Testing: A full-stroke opening exercise of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic <

Letter 89-04 " Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of the same design (manufacturer, size, model number and materials of construction) and have the same service conditions including valve orientation and together consist of one group. One of the subject valves shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for worn or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other valve in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same l refueling outage.

After the disassembly of the subject valves, these valves will be local leakage rate tested in accordance with the requirements of 10 CFR 50, Appendix J.

4.4.1.1.2 Evaluation--The subject valves are simple check valves in the containment spray i pump discharge lines to the containment spray nozzles. These valves are located inside containment and do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise open is to pass maximum accident condition flow through the valves. The only flow path through l these valves is into the spray nozzles and into the reactor containment, therefore, exercising these valves open with flow would result in spraying large quantities of water into containment. It is impractical to establish spray flow into the containment for testing during any plant mode, because this could result in damage to equipment and instrumentation. Full-stroke exercising the subject valves open with flow could only be accomplished if full flow test lines were installed downstream of the valves. Installing such test lines would be burdensome to the licensee and could result in reduced system reliability because of the increased chance of operator or equipment failure. Since it is impractical to exercise these valves open using conventional methods, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing . . (exercising a check valve with flow or a manual exerciser), disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance with the requirements of Position 2.

Based on the determination that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each group valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the 15

.____________.._q l

, l l

- level of quality and safety and considering the licensee's proposed sample disassembly and inspection of

) heck valves ICT-53 and ICT-91 is performed in accordance with the conditions specified in GL 89-04, i

, ~ Position 2, the alternative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii).

]

4.5 Instmment AirSystem i 4.5.1 Category C Valves l

i 4.5.1.1 Relief Request. Valve Relief Request IA-VR1, requests relief from the exercising i

' requirements of OM-10, Para. 4.3.2, for the series instrument air check valves in the lines to the j accumulators for the containment vacuum relief system outside isointion valves, IIA-786, IIA-787, j IIA-788, and 1IA-789, and proposes to verify the closure of these series check valves as a pair in accordance l with NUREG 1482, Section 4.1.1.

)

_ 4.5.1.1.1 Licensee's Basis for Requesting Relief--It is impractical to perform a full stroke closure exercise of the subject check valve during power operation or during cold shutdowns. The 0.75 inch boundary check valves isolate the non-safety related instrument air supply lines to the safety related air accumulators for the containment vacuum relief system outside containment isolation valves ICB-2 and

~ lCB-6.

The primary function of the vacuum relief system is to assure the structural integrity of the containment building as a result of an inadvertent actuation of the containment spray system which causes a partial vacuum inside containment. Makeup air from outside of the containment will flow in to containment when ICB-2 and/or ICB 6 open when containment pressure (vacuum) reaches a predetermined setpoint (-1.0 in w.g.).

The instrument air system provides air to butterfly valves ICB-2 (TK 1 A SA) and ICB 6 (ITK IB SB) actuator accumulators. The butterfly valves (ICB-2 and ICB-6) fail-closed upon loss ofinstrument air and use the air accumulators for three strokes. Each of tl.: instrument air supply lines to the accumulators contains two simple check valves in series with no intermediate test connections for individual valve closure verification. These valves provide isolation in the event of a failure of the non-safety related instrument air supply. Only one check valve is required in order to meet the safety class interface criteria of ANSI N18.2a .

-1975 " Revision and Addendum to Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactors" as referenced in the HNP FSAR. It is not practical to verify the full-stroke closure of these valves utilizing non-intrusive diagnostic methods due to their size. As identified in section 4.1.1 of USNRC NUREG-1482 " Guidelines for Inservice Testing at Nuclear Power Plants", "if only one of the two valves is credited in the safety analysis, then verification that the pair of valves is capable of closing is acceptable for  :

IST. If reliefis requested on this basis, both valves must be included in the IST program and be subject to  !

equivalent quality assurance criteria." i

' Proposed Altemate Testing: 'Ihese valves shall be tested as pairs as identified in section 4.1.1 of  :

USNRC NUREG-1482 each refueling outage since only one of the two valves is required by the system  !

design. Pair #1 will consist of valves IIA-786 & llA-787. Pair #2 will consist of valves 11A-788 and llA-789. These valves and the air accumulators are presently tested as a pair by a pressure decay test of the i subject valves and associated accumulator.

Since all of the subject valves are ASME Section III Class 2 valves, they will have equivalent quality  ;

assurance requirements. l 16

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4.5.1.1.2 Evaluation--There are no provisions for verifying th'at either of these series valves is capable of closing. There are no installed test taps or other provisions for individual valve tests. The only indication of a problem would be the failure of both valves in the series. The Code requires that check valves with a closure function be individually verified to close. However, these valves are a special case in that they are redundant valves and only one valve of a series is actually necessary to perform the pairs closed safety function.

The NRC has previously determined (see NUREG 1482, Section 4.1.1) that both series valves must be included in the IST program and operationally tested as a pair to prevent reverse flow. Upon observing leakage, the licensee must disassemble, inspect, anc repair or replace both valves as necessary before they are returned to service.

Based on the determination that it is impractical to individually exercise these series check valves according to the Code exercising requirements at any frequency, the burden on the licensee of making system modifications to permit this testing, and considering that verifying their closure as a pair and repairing or replacing both valves upon evidence ofleakage through the pair should provide reasonable assurance that they are capable of performing their safety function in the closed position, relief should be granted in accordance with 10 CFR 50.55a(f)(6)(i) from the Code requirement to individually exercise these valves to the closed position. The licensee's proposal comports with the guidance in NUREG 1482 and provides a reasonable alternative to the Code requirements.

4.6 Main Steam System 4.6.1 Category C Valves 4.6.1.1 Relief Request. Valve Relief Request MS-VRI, requests relief from the exercising requirements of OM-10, Para. 4.3.2, for the check valves in the steam supply lines to the turbine of the turbine driven auxiliary feedwater pump, IMS-71 and IMS-73, and proposes to include these valves in a sample disassembly and inspection group and to disassemble and inspect one valve from the group each refueling outage on a rotating basis.

4.6.1.1.1 Licensee's Basis for Requesting Relief--It is impractical to verify a full-stroke close exercise of these valves during power operations or during cold shutdowns due to the lack of the necessary test connections to verify valve closure.

During plant operation, one of the purposes of the main steam system is to deliver steam from the secondary

, side of the steam generators to the main turbine throttle valves at the required steam conditions. Two 6-inch l supply lines located upstream of the main steam isolation valves are provided on steam lines B and C for the l operation of the auxiliary feedwater pump turbine.

l l The auxiliary feedwater system serves as a backup system for supplying feedwater to the steam generators l when the main feedwater system is not available. In order to provide steam to the auxiliary feedwater pump turbine, the lines from both the B and C steam generators have a motor-operated valve, check valve, and then come together into a common header.

These check valves perform a sWty function in the closed position to provide a redundant isolation to upstream motor operated valve (IMS-70 and 1MS-72) in the event of an upstream main steam line break.

This function would ensure adequate steam supply to the auxiliary feedwater pump turbine in the event of a failure of the upstream motor operated valve to close.

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I i During plant operation, the steam supply the auxiliary feedwater pump turbine is normally isolated. The auxiliary feedwater turbine driven pump is tested on a 31 day frequency in accordance with the HNP Technical Specifications which provides a only a partial stroke exercise of the subject valves to the open position due to the auxiliary feedwater pump being circulated to the CST during normal plant operation. In order to verify a part stroke exercise of the subject valves to the open position (as required by the code),

steam can only be supplied to the auxiliary feed pump turbine from one supply source which requires that the upstream motor-operated valve for the idle steam supply line be isolated. During this test, closure l verification of the check valve is not possible since there are no test connections between the subject check valves and the upstream motor-operated valves to monitor the pressure upstream of the subject check valves.

The use of non-intmsive techniques to verify closure of the subject valves by isolating steam Cow (cessation of flow)is not considered practical due to the high temperature of the steam and the need to remove insulation.

Proposed Alternate Testing: Full-stroke closure of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04

" Guidance On Developing Acceptable Inservice Testing Progams." The subject valves are of the same design (manufacturer, size, model number and materials of constmetion) and have the same service '

conditions including valve orientation and together consist of one group. One of the subject valves shall be ,

disassembled each refueling outage. During valve disassembly,the valve internals will be visually inspected  !

for worn or corroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other valve j in this group shall also be disassembled, inspected, and manually full-stroke exercised during the same '

refueling outage.

4.6.1.1.2 Evaluation--The subject valves are simple check valves in the steam supply lines to the turbine for the turbine driven auxiliary feedwater pump. These valves do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise to the closed position is by observing a reverse flow differential pressure across the valves. It is impractical to verify a reverse flow differential pressure across these valves at any frequency because there are no test taps between these valves and the upstream isolation valves. Verifying a full-stroke exercise closed of these check valves could only be accomplished if test taps were installed in these lines to permit connection of differential pressure instrumentation. Since it is impractical to verify reverse flow differential pressure across these valves using conventional methods, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

Paragraph 4.3.2.4(c) of OM 10 allows that "As an alternative to the testing . . (exercising a check valve with flow or a manual exerciser), disassembly every refueling outage to verify operability of check valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance with the requirements of Position 2.

Based on the determination that check valve disassembly and inspection during refueling outages is authorized by OM-10 and that disassembly and inspection of each group valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the level of quality and safety and considering the licensee's proposed sample disassembly and inspection of 18 l

check valves IMS-71 and IMS-73 is performed in accordance with the conditions specified in GL 89-04, Position 2, the alternative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii).

4.7 Safety injection System l 4.7.1 Category A/C Valves 4.7.1.1 Relief Request. Valve Relief Request SI-VRI, requests relief from the exercising <

l requirements of OM-10, Para. 4.3.2, for the check valves in the discharge lines from the safety injection l l

accumulators to the RCS loops, ISI-249,151-250, ISI 251, ISI-252,1S1-253, and 1S1-254, and proposes to j include these valves in two sample disassembly and inspection groups and to disassemble and inspect one  !

valve from each group every refueling outage on a rotating basis.

4.7.1.1.1 Licensee's Basis for Requesting Relief--It is impractical to full or pan-stroke exercise these valves during, power operation or during, cold shutdowns. The normal operating pressure of the safety injection accumulator is insufficient to inject water into the RCS (approximately 2235 psi) during normal plant operation. The subject check valves are 12 inch, stainless steel swing check valves located in the safety injection accumulator cold leg injection lines.

The passive safety injection system cold leg accumulators are pressure vessels normally filled with a 2400 to 2600 ppm boron solution and pressurized with nitrogen. The safety injection accumulator tanks normally '

contain approximately 925 cubic feet of water and 525 cubic feet of nitrogen pressurized to between 585 to 665 psi. One accumulator is connected to the cold leg of each reactor coolant loop and is normally isolated by two check valves in series. Additionally, a normally open and de-energized motor-operated valve is located upstream of the subject check valves. In the event of a large break, the reactor coolart system is rapidly depressurized and a high flow rate is required to limit possible core damage. The accumulators will automatically discharge when the RCS pressure falls below that of the accumulator. One safety function for the subject valves is to open to allow safety injection accumulator inventory to flow to the reactor coolant system as described above.

Proposed Alternate Testing: A full-stroke opening exercise of the subject valves will be verified by a sample disassembly and inspection program as outlined in NRC Staff Position 2 in USNRC Generic Letter 89-04 " Guidance On Developing Acceptable Inservice Testing Programs." The subject valves are of the same design (manufacturer, size, model number and materials ofconstruction) and have the same service conditions including valve orientation and together consist of two groups.

Group #1 consists of the check valves closest to the safety injection accumulators (1S1-249,151-251 and 1SI-253). Group #2 consists of the check valves closest to the reactor coolant sysem (1SI-250, ISI-252, and 1S1-254). One of the subject valves in each group shall be disassembled each refueling outage. During valve disassembly, the valve internals will be visually inspected for worn orcorroded parts, and the valve disk shall be manually exercised. If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of the valve internals, the other two valves in the specific group shall also be disassembled, inspected, and manually full-stroke exercised during the same refueling outage. Valves will be part stroke open exercised after reassembly.

4.7.1.1.2 Evaluation--The subject valves are simple check valves in the discharge lines from the safety injection accumulators to the RCS loops. These valves do not have position indication, therefore, the only practicable conventional method of verifying a full-stroke exercise open is by passing maximum accident condition flow through the valves. The only full flow path through these valves is into the RCS cold legs. It is impractical to inject water into the RCS during power operations because the RCS pressure is 19

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I much higher than the pressure in the safety injection accumulators. The accumulators are normally filled with a 2400 to 2600 ppm boron solution, therefore it is impractical to inject this solution into the RCS during cold shutdowns since it could cause delays in returning the plant to power operation. Injecting full safety injection flow into the RCS during periods when the reactor is cold (<200"F) is not practical because it could cause or contribute to a low-temperature overpressurization of the RCS. Since it is impractical to verify that these valves full-stroke open using conventional metheds, the licensee's proposal to disassemble and inspect them may be the only practical method to verify their full-stroke capability.

Paragraph 4.3.2.4(c) of OM-10 allows that "As an alternative to the testing ... [ exercising a check  ;

valve with flow or a manual exerciser], disassembly every refueling outage to verify operability of check i valves may be used." Therefore, check valve disassembly and inspection is permitted by the Code and relief is not required. However, the Code requires each valve to be disassembled and inspected each refueling outage. Generic Letter 89-04, Position 2, permits a sampling program to be used for the disassembly and inspection of certain check valves. The Generic Letter states: "Where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups ofidentical valves in similar applications may be employed." Generic Letter 89-04 grants relief to use sample disassembly and inspection of check valves ifit is performed in accordance with the requirements of Position 2. t Base? 4 -letermination that check valve disassembly and inspection during refueling outages is authorizeo ( * 'O and that disassembly and inspection of each group valve every refueling outage would result in hardship or unusual burden to the licensee without providing a compensating increase in the level of quality and safety and considering the licensee's proposed sample disassembly and inspection of check valves 1 SI 249, ISI-250,1S1-251, ISI-252,1S1-253, and 1 SI-254 is performed in accordance with the conditions specified in GL 89-04, Position 2, the alternative should be authorized in accordance with 10 CFR 50.55a(a)(3)(ii).

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Inconsistencies and omissions in the licensee's program noted during the course of this review are l summarized below. The licensee should resolve these items in accordance with the evaluations conclusions, ,

! and guidelines presented in this report.

1. Several of the containment isolation valves (CIVs) in the licensee's IST program (e.g., IFW-159,

-217, and -277) are identified as Category B or C rather than Category A or A/C valves. Review

! the function of these valves and categorize them in accordance with position 10 of GL 89-04, as appropriate.

l l; 2. The justification portion ofIA-CSJ1 for valve IIA-819 does not provide the necessary detail. The '

L reviewers agree that cold shutdown is the appropriate test frequency for this valve, however, in

!_ subsequent submittals of the IST program the CSJ should be expanded to identify the specific vital l

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i functions that could be disrupted by operation of this valve. NUREG-1482, Section 2.4.5, provides '

guidance on preparing CSJs and ROJs.

3. Refuelingjustification CB-ROJ 1 addresses an extended test frequency for excess flow check valves.

The reviewers agree that refueling outage is the appropriate test frequency for these valves.

However, the justification is vague about the actual test method that is employed and the test equipment that must be installed. The equipment used and method employed should be described in more detail in any future submittal. See also, NUREG-1482, Section 2.4.5.

l- 4. Refueling justification CS-ROJ1 addresses several RCP seal water and normal charging check

( valves. The reviewers agree that refueling is the appropriate test frequency for these valves.

l However, much of thejustification section may not apply to valve ICS-477. The specific technical l justification describing the impracticality of testing valve ICS 477 either quarterly or during cold shutdowns should be included in the ROJ in subsequent IST program submittals.

5. Refueling justification CS-ROJ6 addresses the reactor coolant system (RCS) normal charging l isolation valve bypass valves ICS-493 and 774. The ROJ identifies the valves as normally closed, but the valve table lists them as normally open. Also, the valve table identifies only a stroke open l test, but ROJ6 talks about containment entry to verify valve closure. The IST program should be revised to correct these inconsistencies and to describe how valves ICS-493 and -774 are individually verified to close.

6. Refueling justification CS-ROJ7 addresses the boric acid gravity feed line manual isolation and

!. check valves ICS-525 and -526. The specific technicaljustification describing the impractica'ity i

of testing valve ICS-526 during cold shutdowns should be included in the ROJ in subsequent IST l program submittals.

l l' 7. Refuelingjustification CS-ROJ8 addresses the charging line and pressurizer spray line check valve.

However, the ROJ is missing an alternate test section. The ROJ should be revised to include the alternate testing performed on these valves.

! 8. Refuelingjustification DW-ROJ l addresses the demineralized water supply to primary containment valve, IDW-65. The justification identifies the reasons that it is impractical to verify the reverse I

flow closure of this valve quarterly or during cold shutdowns, however, nojustification is provided n for not exercising the valve open more frequently than during refueling cutages. The licensee should l

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i either revise this ROJ to justify deferral of the open exercise test until refueling outages or they l should exercise this valve open at the Code required frequency.

l l 9. Refueling justification FP-ROJ1 addresses the fire water supply check valves, IFP-349 and -357.

Thejustification identifies the reasons that it is impractical to verify the reverse flow closure of these valves quarterly or during cold shutdowns, however, nojustification is provided for not exercising j the valves open more frequently than during refueling outages. The licensee should either revise this ROJ tojustify deferral of the open exercise test until refueling outages or exercise these valves open at the Code required frequency.

10. Refueling justification SI-ROJ1 addresses various category C RCS injection check valves. These l valves perform a safety function in the closed direction, however, the " Deferred Test Justification" section of the ROJ does not provide a justification for not verifying the valves closed quarterly or during cold shutdowns. The licensee should either revise this ROJ tojustify deferral of the close exercise test until refueling outages or exercise these valves closed at the Code required frequency.

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APPENDIX B

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IST PROGRAM ISSUES IDENTIFIED DURING THE SYSTEMS REVIEW e.

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IST PROGRAM ISSUES IDENTIFIED DURING THE SYSTEMS REVIEW The INEEL staff reviewed the Chemical and Volume Control System (CVCS) and Component Cooling Water (CCW) system. The staff identified each component in these systems listed in the IST program on the plant P&lD and evaluated the test (s) designated in the IST program to assess compliance with the applicable American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code test requirements. Related extended test intervaljustifications, technical positions and relief requests were also assessed. Following this review, the staff assessed the systern for completeness (to determine if additional components shot.ld have been included in the IST program). This review yielded the following list ofissues that should be addressed by the licensee.

Chemical and Volume Control System

1. The IST program. Section 5.2, Valve Table Format, defines the types of tests. included in those definitions, on pages 20 and 21 of 145, are definitions of the close stroke-time (STC), open stroke-time (STO), close exercise (SC), and open exercise (SO) tests. The SC and SO tests address all exercising requirements of OM-10, Para. 4.2.1. However, the STC and STO tests specifically address only the stroke timing requirements of OM-10, Paras. 4.2.1.4 and 4.2.1.8. These tests are only a subset of the requirements applicable to power operated valves such as valve ICS-492 (on page 44 of 145). If the STC and STO designations are intended to meet all of the code requirements for exercise tests (OM-10, Para. 4.2.1) in addition to the stroke time requirements of OM-10, Paras.

4.2.1.4 and 4.2.1.8, the definitions should be revised.

2. Check valve ICS-167 on valve table page 39 of 145 is listed under the "OM Cat" column as "A/C" however, upstream isolation valves 1CS-165 and -166 are categorized "B." If the volume control tank (VCT) outlet isolation or check valves are incorrectly categorized, the licensee should make the appropriate corrections to the IST program.

3. Valves ICS 168 through -171 are listed as normally open passive valves that perform a safety function in the open position. The only test identified for these valves is a remote position indication verification test (PIT) once every 2 years. These passive valves should be repositioned every 2 years to verify their remote indication in the closed position as required by OM-10, Para. 4.1.

4. Valves ICS-217 through -220 on valve table page 41 of 145 are listed as having an open and close safety function. However, the " Test Type" column does not list a stroke-time or exercise test in the open direction. The licensee should exercise and stroke-time test these valves in the open direction in accordance with OM-10, Para. 4.1.2.a.

5. Valve ICS-235 on valve table page 41 of 145 is listed as having an open and close safety function.

However, the " Test Type" column does not list a stroke-time or exercise test in the open direction.

The licensee should test this valve in the open direction in accordance with OM-10, Para. 4.1.2.a.

6. Valve ICS-238 on valve table page 41 of 145 is listed as having an open and close safety function.

However, the " Test Type" column does not list a stroke-time or exercise test in the open direction.

The licensee should test this valve in the open direction in accordance with OM-10, Para. 4.1.2.a.

7. Valve 1CS-283 on valve table page 41 of 145 is an air-operated valve that fails open, however, the

" Safety Pos" column indicates that ICS-283 has a close safety position. The IST program B-3

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information may be incorrect or this safety related valve may fail to its non-safety position upon loss of actuator power. The licensee should determine if the IST program information is correct or if changes are needed. I 1

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8. Valves ICS-341,-382, and -423 on valve table page 42 of 145 are listed as having an open and close safety function. However, the ' Test Type" column does not list an exercise or stroke-time test for the open direction. The licensee should test these valves in the open direction in accordance with OM-10, Para. 4.1.2.a.

9. Valve ICS-480 on valve table page 43 of 145 is listed as having an open and close safety function.

l However, the " Test Type" column does not list a stroke-time or exercise test in the close direction.

l The licensee should test this valve in the close direction in accordance with OM-10, Para. 4.1.2.a.

10. For valves ICS-483, -486, -488, -491. -497, and -500 listed on valve table page 44 of 145, the discussion contained in CS-ROJ8 does not include a description of the alternate close direction testing that the licensee proposes to perform at the refueling outage frequency. The licensee should )

revise CS-ROJ8 to identify the alternate testing that will be performed on these valves. For i example, it should be explained how verification of obturator movement or travel as specified in OM-10, Para. 4.3.2.4(a) is accomplished during the close exercise test for valves 1CS-488 and -491.

I1. Valves 1CS-487 and -562 listed on valve table pages 44 and 45 of 145, respectivdy, are air-operated valves that have a passive close safety function and also fail in the close direction. Tinc "Tesi Type" column does not list a fail stroke closed exercise test (FSC) as required by OM-10, Para. 4.2.1.6.

OM-10 does not exempt passive valves from fail-safe testing as indicated by Note 1 of Table 1,

" Inservice Test Requirements," therefore, the IST program should be corrected to include this test.

12. Valve table page 44 of 145 indicates that valve 1 CS-487 is a 2 inch globe valve, and that valves 1CS-488 and -491 'are 3 inch check valves. However, P&ID 2165-S-1303, grid position C-3 does not show a piping reducer between these valves. Either the P&ID is in error or the valve table is incorrect. The appropriate corrections should be made to address this issue.

13. Valve ICS-492 on valve table page 44 of 145 is listed as having an open and close safety function.

However, the " Test Type" column does not list a stroke-time or exercise test in the open direction.

The licensee should test this valve in the open direction in accordance with OM-10, Para. 4.1.2.a.

14. The discussion contained in CS-ROJ6 indicates that check valve ICS-774 is " spring loaded to restrict opening during normal operation." This would indicate that the normal position for series valve ICS-493 is also closed. However, the " Normal Position" indicated by CS-ROJ6 and valve table pages 44 and 45 of 145 is open for both valve 1CS-493 and -774. This apparent inconsistency in the IST program should be corrected.

15. Valves 1CS-559 and -563 listed on valve table pages 44 and 45 of 145, respectively, are air-operated plug valves that have a passive open safety function and also fail in the open direction. The " Test Type" column does not list a fail stroke open exercise test (FSO) as required by OM-10, Para.

4.2.1.6. OM 10 does not exempt passive valves from fail-safe testing as indicated by Note 1 of Table 1," Inservice Test Requirements," therefore, the IST program should be corrected to include this test.

16. Valves 1CS-745 and -753 listed on valve table page 45 of 145 are listed as having an open and close safety function. However, the " Test Type" column does not list a stroke-time or exercise test in the B-4

open direction. The licensee should test these valves in the open direction in accordance with OM-10, Para. 4.1.2.a.

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Component Cooline Water System

l. Motor-operated gate valves 1CC-176, and -202 listed on valve table page 29 of 145 are indicated as being CIVs. However, the valve table lists the "OM Cat" for these valves as "B." The licensee should review the function of these valves to determine if they should be classified as category "A"

-and be leak-rate tested to verify that the appropriate leakage criteria is met.

2. Relief valves ICC-186, and -194 listed on valve table page 29 of 145 are indicated as being CIVs.

However, the valve table lists the "OM Cat" for these valves as "C." The licensee should review the function of these valves to determine if they should be classified as category "A/C" and be leak-rate tested to verify that the appropriate leakage criteria is met.

3. Valve !CC-337, on P&lD 2165-S5-1322, Coordinates 3-5, is not in the IST program. The licensee should review the function of this valve to determine if its fail safe operation is a required safety ,

function. Ifit is a required function, the valve should be included in the IST program and be tested '

to the Code requirements.

4. Valve ICC-202 on P&ID 2165-S-1321, Coordinates B-10,is not in the IST program. The licensee should review this valve to determine ifit performs a safety related function. Ifit performs z. safety related function, the valve should be included in the IST program and be tested to the Code requirements.

General Note l

1. Our review of the CVCS and CCW systems revealed that few, if any, manual valves from these systems are included in the IST program (manual valves in some other systems are included in the program). In NUREG 1482, Section 4.4.6, the NRC clarified their position on manual valves. This section reads in part: "The Code includes manual valves that meet the scope requirements of 10 CFR 50.55a. To comply with the Code. exercising requirements for a manual valve must be in accord with applicable IST requirements of IWV or OM-10 if the manual valve is credited in the safety analysis for being capable of being repositioned to shut down the plant, to maintain the plant in a safe shutdown condition, or to mitigate the consequences of an accident.... Applicable inservice tests could include exercising (but not stroke timing), leak testing, and position indi:atio.n verification, at the frequency specified in the code, as practical. Passive manual valves ti,a: have position indication would be subject to position indication verification." The licensee should verify that the Shearon Harris Nuclear Power Plant IST Program is in compliance with the NRC position on manual valves.

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• APPENDIX C DEFERRED TEST JUSTIFICATIONS 2

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, i APPENDIX C DEFERRED TEST JUSTIFICATIONS l

The INEEL staff reviewed the licensee's IST program to assess compliance with the applicable l American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code requirements for deferred test justifications. The following section' summarizes the licensee's proposed test interval extension and justification for extension to cold shutdowns or refueling outages and is organized by plant

- system. Inconsistencies or omissions related to deferred test justifications are addressed in Appendices A and B.

AUXILIARY FEEDWATER Submittal AF CSJ1 providesjustification to extend the test frequency for Category B feedwater preheater bypass isolation valves, I AF-102, I AF-64, and 1 AF 81. Each of these valves will be exercised in the close direction and the fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: These six inch valves are normally open to supply approximately 18 to 20% of the normal feedwater flow to the steam generators via the auxiliary feedwater nozzles. This function is intended to reduce steam generator tube vibration by redistribution of feedwater now. Exercising these valves closed quarterly during

. normal operation would interrupt normal feedwater flow rates possibly causing steam generator transients which would have a significant undesirable effect on plant operations. The valve's control circuitry is not

. provided with partial stroke capability.

- Submittal AF-CSJ2 provides justification to extend the test frequency for Category C auxiliary feedwater 1 pump discharge check valves, I AF-16 and 1 AF-31. These valves will be exercised in the close and open l directions during cold shutdown periods.

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Basis: Normally closed, full stroke open and closed exercising requires operating the motor driven auxiliary feedwater pumps and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the hot steam generators during normal operation results in thermal shock to the feedwater piping and associated nozzles. Allowing excessive thermal transients on the feedwater piping and nozzles could lead to their premature failure due to thermally induced stress cracking. In addition, to test auxiliary feedwater during normal operation would require starting the auxiliary feedwater pumps and securing the normal feedwater system flow which would have an adverse effect on steam generator water level control potentially causing a forced plant shutdown. Part stroke exercising in the forward direction during normal operation would result in the same consequences as full flow exercising. Quarterly pump testing is done through the pump recirculation lines and the downstream flow control valves automatically close so that the pumps are essentially isolated from each other and reverse flow closure of these pump discharge check valves cannot be verified until full auxiliary feedwater flow is injected into the Steam Generators.

Submittal AF-CSJ3 providesjustification to ebend the test frequency for Category B auxiliary feedwater pump pressure control valves,1 AF-19 and 1 AF-34. These valves will be exercised in the open direction and the fail-safe open operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally throttled, the position of valves l AF-19 and 1 AF-34 is automatically modulated during pump operation to protect against run out conditions. Testing of these valves would require the use of control logic defeating methods, such as temporary jumpers. Defeating the control logic associated with C-2

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these valves to facilitate testing would render them incapable ofperforming their modulating function should an auxiliary feedwater initiation signal occur during testing.

Submittal AF CSJ4 providesjustification to extend the test frequency for Category C motor driven auxiliary feedwaterpump discharge check valves,1 AF-201,1 AF-202,1 AF-203,1 AF-54,1 AF-73, and 1 AF-92. These valves will be exercised in the open direction during cold shutdown periods.

Basis: Normally closed, full stroke open exercising requires operating the motor driven auxiliary feedwater pumps and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the hot steam generators during normal operation results in thermal shock to the feedwater piping and associated nozzles. Allowing excessive thermal transients on the feedwater piping and nozzles could lead to their premature failure due to thermally induced stress cracking. In addition, to test auxiliary feedwater during normal operation would require starting the auxiliary feedwater pumps and securing the normal feedwater system flow which would have an adverse effect on steam generator water level control potentially causing a forced plant shutdown. Part stroke exercising in the forward direction during normal I operation would result in the same consequences as full flow exercising. (Valves I AF-201, I AF-202, and 1 AF-203 are verified closed quarterly).

Submittal AF CSJS provides justification to extend the test frequency for Category C turbine driven auxiliary feedwater pump discharge check valves, I AF-117, I AF-136, l AF-142, I AF-148, I AF-204, I AF-205, and 1 AF-206. These valves will be exercised in the open direction during cold shutdown periods. j Basis: Normally closed, full stroke exercising open requires operating the turbine driven auxiliary feedwater pump and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the hot steam generators during normal operation results in thermal shock to the feedwater piping and associated nozzles. Allov.ing excessive thermal transients on the feedwater piping and nozzles could lead to their premature failure due to thermally induced stress cracking. In addition, to test auxiliary I feedwater during normal operation would require staning the auxiliary feedwater pumps and securing the l normal feedwater system flow which would have an adverse effect on steam generator water level control l potentially causing a forced plant shutdown. Part stroke exercising in the forward direction during normal operation would result in the same consequences as full flow exercising. The only source of steam to the ,

steam driven turbine is from the main steam system. To operate the turbine requires that the steam generators l be producing sufficient steam to drive the turbine.The control of steam generator water level when producing steam is much more critical than during the refilling process when the motor driven pumps are tested. To .

perform flow testing during steam production would have a significant impact on steam generator waterlevel control on all three steam generators possibly resulting in a reactor trip. Additionally, full flow testing should be performed at a point when sufficient steam pressure has been established to minimize a delay in plant restart. (Valves 1 AF-204,205, and 206 are verified closed quarterly). l Submittal AF ROJ1 provides justification to extend the test frequency for Category C preheater bypass check valves, I AF-103, I AF-65, and 1 AF-84. Each of these valves will be closure verified during refueling outages.

Basis: Normally open, the only system design provisions for verification of reverse flow closure of these check valves would require the complete isolation of feedwater to a generator. This method for closure '

verification involves isolation of the main feedwater, then opening the upstream power operated valve, then verifying a differential pressure exists across the valve seat by measuring upstream pressure during the auxiliary feedwater pump full flow test. Test instrumeraation must be installed to perform this test method.

The only other means to demonstrate proper valve closure capability is by manual exercising during disassembly at refuel outage per OM-10, para. 4.3.2.4(c). NUREG-1482, Section 4.1.4 states, " . The NRC C-3

has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. ".

CONTAINMENT VACUUM BREAKERS Submittal CB ROJ1 providesjustification to extend the test frequency for Category C containment pressure excess flow check valves, PDT-01CB PDT-7680Al, PDT-01CB PDT-7680A, PDT-01CB PDT-7680B1, PDT-OlCB PDT-7680B, and PDT-01CP-PDT-01CP-761IS. Each of these valves will be closure verified during refueling outages.

Basis: These excess flow check valves are located outside containment in instrument sensing lines. These valves are normally open by spring force and close with high flow from a downstream instrument line break.

The upstream side of these check valves is open to containment atmosphere at negative pressure and does not have test connections. Closure verification of these valves requires installation of test equipment (such as vacuum pump and hoses) to provide How. NUREG-1482, Section 4.1.4 states, "... The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. ".

COMPONENT COOLING WATER Submittal CC-ROJ1 providesjustification to extend the test frequency for Category A/C CCW supply and return from RCPinboard containment isolation check valves, ICC-211, ICC-250, and ICC-298. All valves will be closure verified during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing. Valves ICC-250 and ICC-298 will be full-stroke exercised in the open direction during refueling outages. Valve ICC-211 is full-stroke exercised in the open direction quarterly.

Basis: ICC-211 is normally open and ICC-250 and ICC-298 are normally closed. Testing these valves quarterly during power operation and during cold shutdowns of short duration is not practical due to the intermption of cooling water flow to the RCPs required to align for the test configuration. These check valves are located inside primary containment serving as inboard containment isolation valves and are not provided with position indication. The only method available to verify reverse flow closure capability of these check valves is by interrupting their normal process functions and performing seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry in order to verify their closure capability. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG-1482, Section 4.1.4 states,"... The NRC has determined that the need to setup test equipment is adequate justification to defer backDow testing until a refueling outage.. ".

Submittal CC-ROJ2 providesjustification to extend the test frequency for Category C residual heat removal (RHR) heat exchanger, fuel pool heat exchanger, seal water heat exchanger, letdown heat exchanger, vent condenser, recycle evaporator condenser, and distillate cooler check valves, ICC-556, ICC-558,1CC-561, ICC-563, ICC-565, ICC-567, ICC-569, ICC-571, and ICC-573. All valves will be full-stroke exercised in the open direction during refueling outages.

Basis: These valves are normally open simple check valves (functioning as thermal relief valves) located on various heat exchangers cooled by CCW system. During normal operation, the heat exchanger outlet valves are either throttled or closed to the extent that the ther'nal relief check valves are normally open.

However, no permanent plant instrumentation exists to verify How through the check valve. The only positive means of verifying the valves are open is to install temporary non-intmsive test equipment.

NUREG-1482, Section 4.1.4 states, "... The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. ".

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t Submittal CC HOJ3 providesjustification to extend the test frequency for Category A and Category B CCW supply to RCPs, CCW return from RCP thermal barriers, CCW return from RCP motor bearing cooler, and CCW return from RCPs isolation valves,1CC-207,1CC-208,1CC-249,1CC 251,1CC-252,1CC-297, and ICC-299. All valves will be stroke timed in the close direction during refueling outages when the RCP's can be removed from service.

Basis: Normally open, these are the containment isolation and block valves located in the RCP thermal barrier and bearing oil cooler lines. Testing these valves quarterly during power operation and during cold shutdowns of shon duration is not practical due to the interruption of cooling water flow to the RCPs.

Failure for these valves to open subsequent to closure would result in a complete loss of cooling water flow to the RCPs. A loss of cooling water for more than a few minutes could result in extensive damage to the pumps and pump motors and potentially cause a plant trip. Westinghouse Document 1 B5710- 100-07A states that cooling water must be provided to the pumps at all times when the RCS temperature is above 2000F.

Plant procedures indicate that it is desirable to operate the pumps during cold shutdown and that at least one RCP be operating when RCS temperature is > 160 degrees F. Testing during cold shutdown is not practical since cooling water to the RCP thermal barriers and motor bearings must be isolated to perform the test. This would require all RCPs to be stopped. NUREG-1482, Section 3.1.1.4 indicates the need to stop RCPs is adequate justification to defer testing to refuel outages.

CONDENSATE Submittal CE CSJI provides justification to extend the test frequency for Category C CST to motor driven auxiliary feedwater pump inlet check valves, ICE-36, ICE-46, and ICE-56. These valves will be partial-stroke exercised open quarterly, and full-stroke exercised in the open direction during cold shutdown periods.

Basis: Normally closed, full stroke open testing requires operating the auxiliary feedwater pumps and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the hot steam generators during normal operation could result in thermal shock to the feedwater piping and associated nozzles. Allowing excessive thermal transients on the feedwater piping and nozzles could lead to their premature failure due to thermally induced stress cracking. In addition, to test auxiliary feedwater during normal operation would require staning the auxiliary feedwater pumps and securing the normal feedwater system flow which would have an adverse effect on steam generator water level control potentially causing a forced plant shutdown. Quarterly pu~mp testing is done through the pump recirculation lines at less than full flow conditions.

CONTAINMENT PURGE Submittal CP CSJI providesjustification to extend the test frequency for Category A containment pre-entry purge valves,1 CP-1,1 CP-4,1 CP-7, ami ICP-10. Each of these valves will be exercised in the close direction and the fail safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally closed, these 42 inch valves are maintained in the locked closed position during power operation and are tagged out of service. The only time the active function of the valves must be operable is  ;

during modes 5 or 6 when containment closure (core alterations) is required and the valves are in operation i for containment purge. In accordance with OM-10, paragraph 4.2.1.7, these valves will be exercised within 3 rronths prior to the time they are required to be operable during refueling outages. Each valve's passive function of maintaining containment integrity applies to modes 1-4 and will be tested in accordance with 10  ;

CFR 50, Appendix J.

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4 CHEMICAL & VOLUME CONTROL Submittal CS-CSJ1 providesjustification to extend the test frequency for Category A and Category B reactor coolant letdown and charging line isolaiion valves, ICS-1, ICS-2, ICS-11, and ICS-238. Each of these valves will be exercised in the close direction and the fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

I Basis: Normally open, there valves are located in the normal letdown and charging lines to the RCS. l Exercising these valves closed quarterly during normal operation would interrupt normal RCS charging or letdown flow which could cause pressurizer level control transients potentially resulting in a reactor trip.

Failure of a letdown valve in the closed position coincident with normal charging flow could result in a high RCS waterlevel trip. Additionally, closure of ICS-238 would isolate charging flow to the regenerative heat l exchanger resulting in high letdown temperatures. Reestablishing flow to the heat exchanger could lead to thermal shocking resulting in premature failure. The control circuitry associated with these valves is not l provided with partial stroke capability.

Submittal CS-CSJ2 providesjustification to extend the test frequency for Category B charging flow control and charging line isolation valves, ICS-231 and ICS-235. Valve ICS-231 will be exercised in the open direction and the fail-safe open operation on loss of actuator air supply will be verified during cold shutdown periods. Valve ICS-235 will be exercised in the close direction during cold shutdown periods.

Basis: 1CS-231 is normally throttled and 1CS-235 is normally open. These valves are located in the normal l charging line to the RCS. Exercising these valves quarterly during normal operation would intermpt normal RCS charging flow which could cause pressurizer level control transients potentially resulting in a reactor trip. The interruption of normal charging flow would also result in high letdowr. temperatures. The control I circuitry associated with these valves is not provided with partial stroke capability. l Submittal CS-CSJ3 provides justification to extend the test frequency for Category B VCT outlet isolation and charging pump suction valves, ICS-165, ICS-166, ICS-291, and ICS-292. Valves ICS-165 and ICS-166 will be exercised closed during cold shutdown periods. Valves ICS-291 and ICS-292 will be exercised in the open and close direction during cold shutdown periods.

Basis: ICS-165 and ICS-166 are normally open and ICS-291 and ICS-292 are normally closed. These j isolation valves are located in the charging pump suction supply lines from the VCT and the refueling water storage tank (RWST). These valves are designed with interlocks which prevents both sets of valves from i simultaneously being in the same position. Therefore, exercising these valves quarterly would result in I aligning the RWST to the suction of the charging pumps. This alignment would allow RWST inventory, I with its high boric acid concentration, to be injected into the RCS via the charging line and the RCP seals causing power fluctuations and possible plant shutdown. The control circuitry associated with these valves is not provided with partial stroke capability.

Submittal CS-CSJ4 provides justification to extend the test frequency for Category C boric acid transfer pumps to the charging / safety injection pumps (CSIP) supply check valve, ICS-279. This valve will be l exercised in the open direction during cold shutdown periods.

Basis: Normally closed, this check valve is located in the supply line to the charging pump suction header from the boric acid filter. Forward flow exercising this check valve quarterly during power operation would require injecting a highly concentrated boric acid solution from the boric acid storage tanks into the RCS via the operating charging pump. Injecting a highly concertrated boric acid solution into the RCS would result in severe power fluctuations and the possible shutdown of the reactor Partial stroke exercising this check valve wou!d result in the same consequences as full stroke exercising.

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l Submittal CS CSJS providesjustification to extend the test frequency for Category C RWST to CSIP suction supply check valve, ICS-294. This valve will be exercised in the close direction during cold shutdown periods. Open testing will be performed as stated in CS-ROJ3.

Basis: Normally closed, this simple check valve is located in the supply line from the RWST to the charging pump's suction header. The valve is not provided with position indication and has no design provisions (such I as test connections) to facilitate reverse exercising. To verify reverse flow closure capability quarterly during l power operation would require opening the downstream power operated valves to allow the check valve to communicate with the static pressure of the VCT. Furthermore, aligning the RWST to the charging pump's suction header would allow injection of the highly borated solution contained in the RWST into the RCS via the charging pumps. This RCS injection from the RWST would result in severe power fluctuations and possible plant shutdown.

l l

Submittal CS CSJ6 provides justification to extend the test frequency for Category C CSIP supply check valves from RHR heat exchangers, ICS-775 and ICS-776. Both valves will be exercised in the open and  ;

close direction during cold shutdown periods. '

Basis: Normally closed, these simple check valves are located in the supply lines from the RHR heat exchangers to the charging pump's suction header and are utilized during the recirculation phase of emergency core cooling. Forward exercising these check valves would require starting the associated RHR pump, opening upstream power operated valves 1 RH-25 and 1 RH63, and establishing flow through the RHR heat exchangers from the RWST to the charging pump suction header. This is not possible during power operation. This flow path would not only upset the normal charging and letdown Dow rates but would also result in severe power fluctuations and plant shutdown due to the injection of the highly borated contents of the RWST into the RCS via the charging pumps. Partial exercising these check valves to the open position would result in the same consequences as full exercising. The system piping containing these valves has no design provisions (such as test connections) to facilitate reverse exercising. The valves do communicate with static pressure from the VCT. However, test connections are not provided for differential pressure measurement between the check valves and the upstream normally closed power operated valves. Reverse Dow closure capability is best able to be verified when the charging pumps can be removed from service and an abnormal RHR system alignment can be established.

Submittal CS CSJ7 providesjustification to extend the test frequency for Category B and Category C normal and attemate charging line isolation valves, and alternate charging line check valves, ICS-480, ICS-483, ICS-486, and ICS-492. Valve ICS-480 will be exercised in the open direction and the fail safe open operation on loss of actuator air supply will be verified during cold shutdown periods. Valve ICS-492 will be exercised in the close direction and the fail-safe open operation on loss of actuator air supply will be verified during cold shutdown periods. Valves ICS-483 and 1CS-486 will be exercised in the open direction during cold shutdown periods. Close testing for 1CS-483 and ICS-486 will be performed as stated in CS-ROJ1.

Basis: Normally closed, exercising valves ICS-480, ICS-483,1CS-486 quarterly during power operation has been determined to cause thermal cycling of the alternate charging path piping which could lead to premature failure. This problem has been documented by Westinghouse in letter CQL-90-562, dated 09/27/90. Likewise, the normally open normal charging line isolation valve ICS-492 cannot be exercised since this would require Dowing through the attemate path to avoid isolation of normal charging and letdown l Dow, These valves will be tested on a cold shutdown frequency. Partial stroke exercising of the alternate charging line check valves would result in the same consequences previously discussed. The control circuitry associated with the Category B valves is not provided with partial stroke capability.

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Submittal CS CSJ8 provides justification to extend the test frequency for Category A/C VCT outlet check  ;

valve, ICS-167. This valve will be exercised in the close direction during cold shutdown periods.  !

Basis: Normally open, this simple check valve is located in the discharge piping from the volume control tank (VCT) to the charging pump's suction header. Reverse exercising this check valve quarterly during

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power operation would require isolation of the VCT outlet piping, interruption of normal charging flow, and the realignment of the charging pumps suction to the RWST as the alternate supply source. Interrupting i normal RCS charging flow could cause pressurizer level control transients potentially resulting in a reactor trip. Realignment to the RWST as the charging pump's alternate supply source would allow RWST inventory, with its high boric acid concentration, to be injected into the RCS via the normal charging line and the RCP pump seals causing severe power fluctuations and possible plant shutdown.

Submittal CS ROJ1 provides justification to extend the test frequency for Category NC RCP seal water l injection, seal water return & excess letdown, and CVCS normal charging line check valves, ICS-344,1CS-385, ICS-426, ICS-471, and ICS-477. All valves will be closure verified during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing. Valve ICS-471 will be full-stroke exercised in the open direction during refueling outages. All other valves will be full-stroke exercised in the open direction quarterly.

Basis: ICS 344 and ICS-385 are normally open and ICS-426 and ICS-471 are normally closed. These simple check valves are located inside primary containment serving as inboard containment isolation valves and are not provided with position indication. The only method available to verify reverse flow closure capability of these check valves is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry and the interruption of the valves' normal process functions in order to verify their closure capability. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment in<ide primary containment. Performing this test activity during cold shutdowns is not desirable due to personnel hazards and ALARA concerns and the requirement to shut down and restart the RCPs. Plant procedures indicate that it is desirable to operate the pumps during cold shutdown and that at least one RCP be operating when RCS temperature is > 160 degrees F. l Submittal CS-ROJ2 providesjustification to extend the test frequency for Category C CSIP discharge check valves,1CS-178,1CS-192, and ICS-206. These valves will be partial-stroke exercised in the open direction quanerly and full-stroke exercised in the open direction during refueling outages. All valves are full-stroke exercised in the close direction quarterly.

Basis: Normally open/ closed, these charging pump discharge check valves cannot be verified for full flow operability quarterly during normal operation. Normal charging flow is automatically controlled by downstream flow control valve (ICS-231)in response to RCS operating conditions. Injecting full flow into the RCS quarterly during normal operation would require realigning the flow through safety injection lines.

This flow would cause an increase in reactor coolant pressure because letdown capacity is less than safety injection capacity. This is considered an ESF actuation which is prohibited by normal operations. Full flow I exercising these valves at cold shutdown could result in low-temperature overpressurization of the RCS due to the lack of sufficient expansion volume necessary to establish the design accident flow rate.

Submittal CS-ROJ3 provides justification to. extend the test frequency for Category C RWST to CSIP suction supply check valve,1CS-294. This valve will be panial-stroke exercised in the open direction during cold shutdowns and full-stroke exercised in the open direction during refueling outages. Valve 1CS-294 will be full-stroke exercised in the close direction as stated in CS-CSJ5.

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i Basis: Normally closed, this check valve is located in the supply line from the RWST to the charging pump's suction header. ' Verification of forward flow operability quarterly during power operation would require injecting RWST water into the RCS Aligning the RWST to the charging pump's suction header would cause injection of the highly borated solution contained in the RWST into the RCS via the charging pumps. This RCS injection from the RWST would result in severe power fluctuations and possible plant shutdown.

Partial stroke exercising this check valve quarterly during normal operation is prevented for the same reasons as full flow exercising. Full flow exercising these valves at cold shutdown could result in low-temperature over pressurization of the RCS due to the lack of sufficient expansion volume necessary to establish the design accident flow rate.

Submittal CS ROJ4 provides justification to extend the test frequency for Category A RCP seal water injection and seal water retum & excess letdown containment isolation valves, I CS-341, ICS-382, ICS-423, 1 1CS 470, and ICS-472. These valves will be stroke timed in the close direction during refueling outages.

Basis: Normally open, exercising these valves closed quarterly during normal operation would require interrupting seal water flow to the RCP shaft seals. The interruption'of seal water flow to the RCP shaft seals is not practical during power operation due to the potential of causing damage to the seals. Exercising these valves closed during cold shutdowns, if the RCS were pressurized, or filled above the seal package level, could allow the RCS to flow through the pump seals. This flow could introduce particulates suspended in i the RCS into the pump seals which would accelerate seal wear potentially resulting in premature failure.

Testing these valves at refueling outages when the RCS drained to a level below the RCP seal packages  !

would preclude damage to the seals.  !

Submittal CS ROJ5 provides justification to extend the test frequency for Category C RCP seal water injection check valves, ICS 348, ICS-349, ICS 389, ICS-390, ICS-430, and ICS-431. These valves will be full-stroke exercised in the close direction during refueling outages.

Basis: These simple check valves are the Class I to 2 class boundary isolation check valves located inside the missile barrier inside primary containment. The valves are not provided with position indication nor are they provided with individual test connections. The installed test connections are located on either side of the pair of checks, but not between. The only method available to verify reverse flow closure capability of these check valves with flow is as a pair. The only viable method to verify individual closure is by non-intrusive techniques. This technique (RT) requires the installation of test equipmen and isolation of the area during the process. This method would require containment entry and the interruption of the valves' normal process functions in order to verify their closure capability. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. Plant procedures indicate that it is desirable to operate the pumps during cold shutdown and that at least one RCP be operating when RCS temperature is > 160 degrees F. Performing this test activity during cold shutdowns is not desirable due to personnel hazards and ALARA concerns and the requirement to shut down and restart the RCPs.

Submittal CS ROJ6 providesjustification to extend the test frequency for Category C RCS normal charging isolation valve bypass check valves, ICS-493 and ICS-774. These valves will be full-stroke exercised in

the open direction during refueling outages.

Basis: These check valves provide thermal over pressure protection for the regenerative heat exchanger

! when it is isolated Valve ICS-774 is spring loaded to restrict opening during normal operation, otherwise l - the valves are both simple check valves. These normally closed valves are located inside the reactor

containment. During power operation, this portion of the system is pressurized by normal charging. Testing

these valves would require isolation of the normal, alternate charging, and pressurizer spray flow paths. Due to system configuration and location of test connections, the only method to verify closure would require a C-9

containment entry and installation of test equipment. Testing during normal operation is not practicable due to ALARA concerns. Testing during ccid shutdown is not practicable due to the need to setup test equipment. NUREG-1482, Section 4.1.4 states, ". . The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. ".

Submittal CS ROJ7 providesjustification to extend the test frequency for Category B and Category C boric acid gravity feed line check valve and boric acid gravity feed line manual isolation valve, ICS-525 and 1CS-526. These valves will be full-stroke exercised in the open direction and ICS-526 will full-stroke exercised in the close direction during refueling outages Basis: These normally closed system isolation valves are located in the boric acid gravity feed line to the charging / safety injection pumps and may be used to supply water directly from the Boric Acid Tank to the suction of the CSIPs via gravity feed,if the Boric Acid Pumps are not operable. This flow path is optionally required to be operable per T.S. 3.1.2.1 in Modes 4,5 and 6. Opening manual isolation valve ICS-526 during normal operation would negate redundant isolation between charging pump suction and boric acid 1 subsystem. In addition, the boric acid subsystem pressure is not sufficient to open check valve ICS-525 ,

during normal and cold shutdown operation because normal charging pump suction pressure is greater than l boric acid tani head pressure.

Submittal CS ROJ8 provides justificadon to extend the test frequency for Category C, RCS alternate l charging line, pressurizer auxiliary spray line, and RCS normal charging line check valves, ICS-483, ICS-486, ICS-488, ICS-491, ICS-497, and ICS-500. These valves will be full-stroke exercised in the open direction during refueling outages. CS-ROJ8 did not include the proposed alternate testing.

Basis: These simple check valves are the Class I to 2 class boundary isolation check valves located inside the missile barrier inside primary containment. During power operation, this portion of the system is pressurized by normal charging. Testing these valves would require isolation of the normal, alternate charging, and pressurizer spray flow paths. Due to system configuration and location of test connections, the only method to verify closure would require a containment entry and installation of test equipment.

Testing during normal operation is not practicable due to ALARA concerns. Testing during cold shutdown is not practicable due to the need to setup test equipment. NUREG-1482, Section 4.1.4 states, ". . The NRC has determined that the need to setup test equipment is adequate justification to defer backDow testing until a refueling outage...".

CONTAINMENT SPRAY Submittal CT ROJ1 providesjustification to extend the test frequency for Category A/C containment spray pump discharge to nozzles check valves, ICT-53 and ICT-91. These valves will be stroked closed during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing. Open testing will be performed as stated in CT-VRI.

Basis: Normally closed, these check valves are located inside primary contaimnent serving as inboard containment isolation valves and are not provided with position indication. The only method available to verify reverse now closure capability of these check valves is to perform a seat leakage test. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG-1482, Section 4.1.4 states,"...The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

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o DEMINERALIZED WATER Submittal DW ROJ1 provides justification to extend the test frequency for Category A/C demineralized water supply to primary containment check valve,1DW-65. This valve will be full-stroke exercised in the open direction during refueling outages and will be stroked closed during refueling outages in conjunction with 10 CFR 50, Appendix J. Type C leak rate testing.

Basis: Normally closed, this check valve is located inside primary containment serving as an inboard containment isolation valve and is not provided with position indication. The only method available to verify reverse now closure capability of this check valve is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore,it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG-1482, Section 4.1.4 states, ". . The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. "

FIRE PROTECTION Submitt.al FP ROJ1 providesjustification to extend the test frequency for Category A/C Gre water sprinkler supply check valves, IFP-349 and IFP-357. These valves will be full-stroke exercised in the open direction during refueling outages and will be stroked closed during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing.

Basis: Normally closed, these simple check valves are locate %ide primary containment serving as inboard containment isolation valves and are not provided with position indication. The only method available to verify reverse flow closure capability of these check valves is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG 1482, Section 4.1.4 states, " . The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage.. ".

MAIN FEEDWATER Submittal FW CSJ1 provides justification to extend the test frequency for Category B feedwater line isolation valves to S/Gs, IFW-159, IFW-217, and IFW-277. Each of these valves will be partial-stroke exercised in the close direction quarterly and full-stroke exercised closed during cold shutdown periods.

Fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally open, full stroke closed exercising the feedwater isolation valves quarterly during normal operation would result in a loss of normal feedwater flow to the associated Steam Generator except for that provided by the auxiliary feedwater line. Isolation of normal feedwater flow during power operation could potentially cause a severe steam generator level transient which could result in a plant trip, and would initiate an auxiliary feedwater system actuation signal unnecessarily. The feedwater isolation valves are provided with partial stroke capability.

Submittal FW CSJ2 provides justi6 cation to extend the test frequency for Category C feedwater injection to S/G check valves, IFW-158, IFW-216, and IFW-276. These valves will be exercised in the close direction during cold shutdown periods.

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- ., 1 Basis: Normally open, full stroke closed exercising the feedwater injection check valves is not possible l quarterly during power operation due to the necessity of isolating normal feedwater flow to the associated Steam Generator. Isolation of feedwater flow during normal operation would cause a loss of steam generator level control resulting in a plant trip. The normal method to verify reverse flow closure is to perform a leak test or establish a differential pressure across the valve seat. This can only be performed during cold shutdowns when a differential pressure may be established across the valve seat by allowin,g steam generator head pressure to communicate with the downstream side of the valve seat while simultaneously measuring line pressure upstream of the seat.

INSTRUMENT AIR Submittal IA CSJ1 provides justification to extend the test frequency for Category A instrument air supply )

to containment valve, IIA-819. This valve will be stroke timed closed and the fail-safe close operation on i loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally open, instmment air supplies a number of components inside contaimnent which are dependent upon instrument air to remain operable for support of normal plant operation. Exercising this valve to the closed position quarterly during normal operation would deprive these components of their normal actuating air supply. Since the largest majority of these components have no backup air supply, component realignment or a loss of sensing capability is likely to occur upon interruption of their air supply.

Loss of operability or mispositioning of these components could result in operating transients and a possible forced plant shutdown. The control circuitry for this valve is not provided with partial stroke capability.

Submittal IA ROJ1 provides justification to extend the test frequency for Category A/C instrument air supply to containment check valve, IIA-220. This valve will be full-stroke exercised in the close direction during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing.

Basis: Normally open, this check valve is located inside primary containment serving as an inboard containment isolation valve and is not provided with position indication. The only method available to verify reverse flow closure capability of this check valve is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore,it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primay containment.

NUREG-1482, Section 4.1.4 states, "... The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

MAIN STEAM Submittal MS CSJ1 provides justification to extend the test frequency for Category B main steam isolation valves (MSIVs),1MS-80,1MS-82, and IMS-84. Each of these valves will be partial-stroke exercised in the close direction quarterly and full-stroke exercised closed during cold shutdown periods. Fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally open, full stroke closed exercising of these valves during normal operation isolates one line of steam flow to the turbine. Isolation of a main steam header would cause a severe pressure transient in the associated main steam line possibly resulting in a forced plant shutdown. Additionally, closure of an MSIV, at power, could potentially result in challenging the set point of the main steam relief valves causing inadvertent lifting. Reducing power level to perform testing without causing a transient would significantly impact plant operations and power production. These valves are provided with partial stroke capability.

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Submittal MS CSJ2 provides justification to extend the test frequency for Category C main steam to AFW l turbine check valves, IMS-71 and IMS-73. Each of these valves will be partial-stroke exercised in the open  !

direction quarterly and full-stroke exercised open during cold shutdown periods. Close testing will be performed as stated in MS-VRI. {

Basis: Normally closed, full Dow stroke open exercising of these check valves would require running the Auxiliary Feedwater Pump Turbine at full flow conditions. This is not possible quarterly during power operation as the only flow path that could handle the necessary auxiliary feedwater flow (the feedwater flow that would demand the minimum required steam flow)is into the steam generators. This could result in thermal shock to the feedwater piping and nozzles. The quanerly pump test is performed with flow through a minimum flow line and is not a full flow test.

REACTOR COOLANT Submittal RC-CSJ1 provides justification to extend the test frequency for Category B pressurizer power operated relief valves (PORVs),1RC-114, IRC-116 and 1RC-118. Each of these valves will be stroke timed in the open and close directions, and fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: Normally closed, the PORVs are controlled by the pressurizer overpressure protection system, which j automatically opens two of the three valves at a preset pressure. At power, set pressures are established to limit undesirable opening of the spring-loaded pressurizer safety valves. The PORVs are relied upon during reactor startup and shutdown to protect the RCS from potential low temperature over pressurization transients. In the event of a steam generator tube rupture, the PORVs may be required to open for accident mitigation by providing a means for rapid manual depressurization of the RCS. Due to the high probability for the PORVs to sti k in the open position or failure to provide a leak tight barrier when closed, quarterly exercising during power operation is not practical. In accordance with Generic Letter 90-06, and the guidelines provided in NUREG-1482, Section 4.4.1, these valves will be tested on the way to cold shutdown during Modes 3 or 4 prior to LTOPS operation in Mode 5 or 6 at startup, and during Modes 3 or 4 upon return to power.

Submittal RC-CSJ2 provides justification to extend the test frequency for Category B reactor vessel head i vent valves, pressurizer steam space vent valves, and vent path valves to the containment and the PRT, IRC-900 through 1RC-905. Each of these valves will be stroke timed in the open and close directions, and fail-safe close operation on loss of actuator air supply will be verified during cold shutdown periods.

Basis: These hydraulic assisted pilot operated valves were installed subsequent to the TMI accident, and serve as the RCS high point vent valves. Their intended function is to provide reactor head venting capabilities during a natural circulation cool-down evolution. The valves are routinely useo during cold shutdown to provide a path for RCS venting. Technical Specification 3.4.11 requires that one venath from the reactor pressure vessel head and one vent path from the pressurizer be operable an t .:n during operation. Testing of these valves quarterly during power operation, with subsequent fad re in ven position, could result in uncontrolled blowdown of RCS inventory to the pressurizer pM t,4. or containment atmosphere should the downstream block valves inadvertently open or experience wv ssive leakage. Experience of this condition precipitated NLS-87-247 on 11/23/1987 and subsequent License Amendment NPF-63 #4 to remove the quarterly test requirements from T.S.3.4.11. Further evidence of this condition related disparity is addressed by ASME 81-BVP-39 (April of 1981) " Spurious Opening of Hydraulic Assisted Pilot Operated Valves". The control circuitry associated with these valves is not provided with partial stroke capability.

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i Submittal RC ROJ1 provides justification to extend the test frequency for Category A/C RMW to PRT isolation valve check valve,1 RC-164. This valve will be full-stroke exercised in the close direction during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing. This valve will be exercised open quarterly.

Basis: Normally closed, this simple check valve is located inside primary containment serving as an inboard containment isolation valve and is not provided with position indication. The only method available to verify ,

reverse flow closure capability of this check valve is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would req uire containment entry

. in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG-1482, Section 4.1.4 states, "... The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

I Submittal RC ROJ2 provides justification to extend the test frequency for Category A/C nitrogen and instrument air inlet check valves to PORV accumulator tanks, IRC-174, IRC-176, ISI-444, and ISI-446.

l These valves will be full-stroke exercised in the close direction during refueling outages.

Basis: Normally open/ closed, these simple check valves are located in the normal instrument air and l nitrogen supply lines to the actuating air accumulators serving the two safety related PORVs, both of which are inside primary containment. The valves are not provided with remote position indication. To verify reverse flow closure capability of these check valves would require isolating and the depressurization of the instrument air and nitrogen supply headers for an extended period of time, and performing an accumulator l pressure decay test. This test activity would require containment entry in order to verify valve closure.

l Routine containment entry cannot be made quarterly during power operation due to high radiation levels and l the potentially harsh environment inside primary containment. The reverse closure test is not practical during  ;

l cold shutdowns since the PORVs are required to be available during cold shutdowns to prevent low temperature over pressurization of the RCS.

l LOW HEAD SAFETY INJECTION i i r .

l Submittal RH CSJ1 provides justification to extend the test frequency for Category A RCS hot leg to RHR I

pump valves,1 RH-1,1 RH-2,1RH39, and 1 RH-40. Each of these valves will be full-stroke exercised during cold shutdown periods.

. Basis: Normally closed, these RCS pressure isolation valves are located in the RHR pumps suction supply lines from the RCS hot legs. Exercising these valves quarterly during power operation is not possible due to the presence ofinterlocks which prevent their opening unless RCS pressure has been reduced to below 363 psig. This design feature prevents inadvenent over pressurization of the associated train of RHR.

Defeating these interlocks to facilitate testing, with subsequent seat leakage of the inline valve, could lead to an inter-system LOCA by exposing the low pressure RHR system to the high pressure reactor coolant l system. Partial valve exercising is precluded for the same reasons as full stroke exercising.

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SERVICE AIR Submittal SA ROJ1 provides justification to extend the test frequency for Category C service air to l containment check valve, ISA-82. This valve will be full-stroke exercised in the close direction during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing.

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Basis: Normally closed, this check valve is located inside primary containment serving as an inboard containment isolation valve and is not provided with position indication. The only method available to verify C - 14

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reverse flow closure capability of this check valve is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore,it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation

. due to high radiation levels and the potentially harsh environment inside primary containment.

N1JREG-1482, Section 4.1.4 states, "... The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

i HIGH HEAD SAFETY INJECTION Submittal SI CSJ1 provides justification to extend the test frequency for Category A/C and Category C l

safety injection check valves,151-134 through I SI-137, I SI-346, I SI-347,1 SI-356 through I SI-358, and I SI-l 81 through ISI-83. Each of these valves will be stroked open during cold shutdown periods. j l

. Basis: Normally closed, these simple check valves are located in either the low head and/or high head safety injection flow paths to the RCS cold legs or hot legs. Full stroke exercising open of those check valves located solely in the low head safety injection flow path (ISI-346,347,356,356 and 358) can only be performed by injecting RHR flow into the RCS. Establishing this flow path quarterly during normal operation is not possible. The low pressure RHR pumps are unable to develop sufficient discharge head to overcome the higher RCS operating pressure. Full stroke exercising open of those check valves which are also located in the high head safety injection flow path could be performed utilizing the high pressure charging pumps. However, establishing this flow path would require utilizing the RWST as the supply source and injecting large quantities of highly borated water into the RCS. This would also cause a large thermal transient at the RCS nozzle. This is not practical quarterly during normal operation due to the ,

potential of causing pressurizer level control problems and severe power fluctuations possibly resulting in )'

a reactor trip. Partial stroke exercising these check valves quarterly during normal operation is prevented for the same reasons as for full exercising Submittal SI-CSJ2 provides justification to extend the test frequency for Category A low head safety i injection to RCS loops valve, 151-359. This valve will be full-stroke exercised during cold shutdown {

periods. j Basis: .Normally closed, this motor operated valve serves as the second high pressure boundary barrier  ;

I between the RCS and the low pressure piping of the Residual Heat Removal System. The valve is placed in the open position when switching from the cold leg to hot leg recirculation mode of safety injection. To prevent opening during normal operation the valve is electrically disconnected per Tech. Spec. 4.5.2.8 and administratively maintained closed. Exercising this valve quarterly during normal operation could cause over pressurization of the RHR System piping and result in an inter-system LOCA condition. The control circuitry associated with this valve is not provided with partial stroke capability. Even if possible, partial stroke exercising would result in the same consequences as full exercising. i Submittal SI CSJ3 providesjustification to extend the test frequency for Category A/C accumulator fill from RWST check valve,1S1-182. This valve will be stroked open during cold shutdown periods.

I Basis: Normally open/ closed, this check valve is located inside primary containment serving as inboard containment isolation valve for the safety injection (SI) accumulator fill line. It is not provided with position

' indication. Stroke open verification of this check valve requires feed and bleed of the SI accumulators and l monitoring for a level increase orinstallation of non intrusive flow instrumentation to verify flow. Testing using the SI accumulator feed and bleed method is not practical during normal operation because it would require unnecessary cycling of equipment to obtain a detectable level increase (ref. NUREG-1482. Section 2.5.4). NUREG-1482, Section 3.1.1 states, "...(check valves that can be stroked quarterly, but must be C - 15

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1 monitored by a non-intrusive technique to verify full stroke, may be fullstoke tested during cold shutdowns l or refueling outages if another method of verifying full-stroke exists at these plant conditions.. "

l Submittal SI ROJ1 provides justification to extend the test frequency for Category C RCS cold and hot leg injection check valves, and RCS cold leg alternate injection check valves, ISI-8 through ISI-10,1S1-104 through ISI-106,1S1-127 through 1S1129,151-138, and ISI-72 through ISI-74. Each of these valves will be full-stroke exercised in the open and close direction during refueling outages.

l Easis: Normally closed, full stroke exercising open can only be performed by injecting water into the RCS utilizing the RWST as the supply source. Design accident injection How rate cannot be established through these valves when the reactor coolant system is at normal operating pressure. The normal operating pressure of the RCS would prevent the flow rates that can be achieved when the RCS is depressurized, as it would l be in the case of a large break LOCA. Therefore, these valves cannot be full-stroke exercised open quarterly i during power operations. Partial-stroke exercising these valves during power operations would inject cold i water, which has bypassed the regenerative heat exchanger, into the RCS thermally shocking the injection piping and nozzles which could cause premature failure of these system components. Also, establishing injection flow into the RCS could cause reactivity, temperature, pressure, and pressurizer level control transients which could result in c reactor trip. Exercising these valves during cold shutdowns when the RCS is not vented or open to the atmosphere would inject into the RCS when there is marginal expansion volume and could result in low-temperature over pressurization of the RCS.

Submittal SI ROJ2 providesjustification to extend the test frequency for Category B high head and alternate high head safety injection to the hot leg, and alternate high head safety injection to the cold leg valves, ISI-107, ISI-52, and 151-86. These valves will be full-stroke exercised in the open and close direction during refueling outages.

Basis: Normally closed, full stroke exercise open of these valves during power operation would result in flow through the injection flow paths into the RCS hot legs when 151-86 and 107 are opened, and into the RCS cold legs when SI-52 is opened. Aligning this flow path would allow the injection of relatively cold water, which has bypassed the regenerative heat exchanger, into the RCS potentially thermal shocking the injection piping and nozzles which could cause premature failure of these system components. Opening these valves would also allow an increase in charging / injection flow potentially causing reactivity, temperature, pressure, and pressurizer level control transients which could result in a reactor trip. At cold shutdown one charging pump remains in service per T.S. 3.5.3 when RCS temperature is <335 degrees F.

Exercising these valves to the open position during cold shutdown would allow substantial increased flow into the RCS when there is marginal expansion volume to accommodate the additional flow for the test period. This increased flow could cause a low temperature over pressure condition in the RCS. The control circuitry associated with this valve is not provided with partial stroke capability. Even if possible, partial stroke exercising would result in the same consequences as full exercising.

Submittal SI ROJ3 provides justification to extend the test frequency for Category A/C accumulator fill from RWST and accumulator and PORV nitrogen supply check valves,151-182 and ISI-290. These valves will be full-stroke exercised in the close direction during refueling outages in conjunction with 10 CFR 50, Appendix J, Type C leak rate testing.

Basis: Normally open/ closed, these check valves are located inside primary containment serving as inboard containment isolation valves and are not provided with position indication. The only method available to verify reverse flow closure capability of these check valves is by seat leakage testing. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry in order to verify their closure capability. Routine containment entry cannot be made I quarterly during power operation due to high radiation levels and the potentially harsh environment inside l

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primary containment. NUREG-1482, Section 4.1.4 states,"...The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

Submittal SI ROJ4 provides justification to extend the test frequency for Category C RHR pump suction supply from RWST check valves, ISI-320 and ISI-321. These valves will be full-stroke exercised in the close direction during refueling outages and stroked open quarterly.

Basis: These valves are normally closed. A proper backseat test involves pressurization of the piping downstreain of each check valve by a high capacity external pressure source. Pressurization from the opposite safety train is not possible due to check valves on the pump discharge line upstream of the nearest crossoverline. These discharge check valves would potentially mask a non-functional suction check valve.

Performing this test during cold shutdown is considered burdensome without a commensurate increase in the level of valve reliability due to the necessity of utilizir, woorary test equipment and the extent of the test boundary which could delay plant restart. Additionally, this test activity could impact the ability to maintain the plant at cold shutdown under normal conditions due to the necessity of having one train of RHR operating in the shutdown cooling mode. The only time that a high volume pressurization source to these vues exists, without impacting system operation, is during refueling outages when the refueling cavity is flooded and the plant is lined up en residual heat removal. At this time the static head from the refueling cavity will exceed that of the RWST thereby providing a reverse differential pressure across ISI-320 and ISI-321. Monitoring of RWST level over a specified period of time will provide adequate demonstration of reverse flow closure capability.

Submittal SI-ROJS provides justification to extend the test frequency for Category A/C and Category C SI low head to RCS hot leg, RCS hot leg injection, LHSI to cold leg injection, LHSI to RCS cold leg, and RCS cold leg injection check valves,1S1-134 through 1S1-137, ISI-346, ISI-347,1S1-356 through ISI-358, and ISI-81 through 1S1-83. These valves will be full-stroke exercised in the close direction during refueling outages. Open testing will be performed as stated in SI-CSJ1.

Basis: These normally closed valves are located inside the reactor containment. During power operation, this portion of the system is pressurized to reactor pressure. No installed plant instrumentation exists to validate or monitor inservice conditions. Due to system configuration and location of test connections, the only method to verify closure would require a containment entry and installation of test equipment. The installation of test equipment would require breaching the isolation requirements for the reactor coolant pressure boundary. Testing during normal operation is not practicable due to ALARA concerns. Testing during cold shutdown is not practicable due to the need to setup test equipment. Reference NUREG-1482, Section 4.1.4 states, ". . The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing until a refueling outage...".

SERVICE WATER Submittal SW ROJ1 provides justification to extend the test frequency for Category A/C service water supply to containment fan coil units check valve, ISW-233. This valve will be full-stroke exercised in the close direction during refueling outages in conjunction with 10 CFR 50, Appendix J. Type C leak rate testing.

Basis: Normally open, this simple check valve is located inside primary containment serving as an inboard containment isolation valve and is not provided with position indication. The only method available to verify reverse flow closure capability of this check valve is to stop normal service water flow to primary containment and perform a seat leakage test. The test connections utilized to perform seat leakage testing are located inside containment. Therefore, it would require containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operation due to high radiation levels and the potentially harsh environment inside primary containment. NUREG-1482, Section 4.1.4 states, C - 17

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"...The NRC has determined that the need to setup test equipment is adequatejustification so defer backflow testing until a refueling outage...".

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