ML20203E530
| ML20203E530 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/13/1998 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9802270073 | |
| Download: ML20203E530 (26) | |
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.. .? ~ ~ c-PECO NUCLEAR A Unit of PECO Energy N N N N r )1 February 13,1998 Docket Nos. 50-277 50 278 License Nos. DPR-44 DPR 56 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Third 10 Year Interval inservice Testing (IST) Program
References:
- 1) Letter from T. N. Mitchell (PECO Energy Company) to U. S. Nuclear Regulatory Commission (USNRC), dated May 8,1997
Dear NRC Officials:
In the Reference i letter, PECO Energy Company (PECO Energy) provided )f for your review and approval the relief requests and an alternative plan associeted with the third, ten year-interval, inservice Testing (IST) Program for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. In the ,
Reference 2 letter, PECO Energ extended the second interval IST Program g
dates to provide additional time or implementing program revisions, and to provide tie USNRC staff additional review time. The purpose of this letter is to provide additional information as dircussed in a confsrence call between PECO Energy and the USNRC staff on January 13,1998. In our January 13, 1998 conversation, the USNRC staff requestec that the excess flow check valves be specifically listed and separated between a refueling outage justification and a generic valve relief request. Relief Requests GVRR-2 and 02-ROJ-1 have been revised to satisfy this request. Relief Request GVRR-2 was previously approved for the second, ten year-interval for PBAPS, Units 2 and 3 as discussed in the Reference 3 letter.
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Also attached is new Relief Request GVRR 7. Relief Request GVRR 7 was inadvertently omitted from the Reference 1 letter. Relief Request GVRR-7 was previously approved as GVRR-4 for the second, ten year-interval in the i Reference 4 letter. Additionally, Rollef Request 10 VRR-1 has also been revised to delete one sentence.
Attached are updated Appondices C and D to the Reference 1 letter. The complete appendices are being submitted due to changes in the page numbers. Revisions to the relief requests are highlighted with revision bars in the right hand mugin.
If you have ar.y questions, please contact us.
Very truly yours, Director Licensing Attachment cc: H. J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident inspector, PBAPS 1
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APPENDlX C VAINE INSERVICE TESTING PROGRAM RELIEF REQUESTS
PilAPS 2 & 3,IST Progrem i Spec. M 710, Rev.7 Appendix C Page 1 of 13 l GliNERIC val.Vli RELIEF RI: QUEST GVRR 1 Valve (s): Active Manuallsolation Valves Category: 11 l' unction: Manual isolation valves wluch are required to change position in order to accomplish a safety function.
'lest Requirements: Active Category !! valves shall be tested nominally every 3 months as required by ISTC 4.2.1.
liasis for Relief: 'lhese manual valves perform an actise safety function as defined in the Scope of ISTC Para.1.1, and therefore require full-stroke exercising per the requirements of ISTC 4.2.1.
Ilowever, due to the simplicity of manual valve design, the limited nurnber of failure modes, and historical data from the second 10-year interval, full stroke exercising on a quarteily frequency is considered burdernome without a commensurate increase in the level of quahty and safety. Additionally, the vahes are located in a non-harsh service environment making tnem less prone to degradation.
Alternate 'lcsting: As an alternative to the testing requirements of the Code, PilAPS proposes to establish a full-stroke exercise frequency of once every 2 years for those active manual valves provided with remote position indication, and once every 5 years for those active manual valves not provided with position indication. The proposed alternate test frequency will provide adequate assurance of valve operability without compromising plant safety.
i PDAPS 2 & 3,IST Program I Spec. hl 719, Rev,7
, Appendix C Page 2 cf l3 l GENERIC VALVl! RELIEF REQUEST . GVRR 2 ;
- Valves: XFC 2(3)-02 007A(ll) XFC 2(3)-02-023A(D,C,D)
XFC.2(3)-02 025 XFC.2(3)-02 062A(D,C,D)
XFC.2(3)02-064 A(ll,C,D) XIC 2(3)-02 305A(II)
XFC 2(3) 02 021 A,C XFC 2(3)-02-011 XFC 2(3) 12 066A(II) XFC.212 80457L(ll)
XFC.2(3).13 055A(II) XFC 2(3)14-031 A(D)
XIC 2(3) 23 037A(ll)
XI C.2(3) 02 031D(C,D,1!,G,ll J.K.M,N,P,R.T,U,V,W)
Category: A, C Testing Requirement (s): Check valves shall be exercised nominally every 3 months as required by ISTC 4.5, liasis for Relief: Excess flow check valves (EFCW) are installed on instrument lines penetrating containment to minimize leakage in the event of an instrument line failure outside the containment in accordance with Regulatory Guide 1.11. The EFCV is a spring loaded '
ball check valve. Since the system is normally in a static condition, the valve ball is held open by the spring. Any sudden increase in flow through the valve (i.e. line break) will result in a differential pressure across the valve which will overcome the spring and close the valve. Functional testing of valve closme is accomplished by venting the instrument side of the valve while the process side is under pressure and verifying the absence of leakage through the vent.
The testing described above would require the removal of the associated instrument or instruments from service on a quarterly basis. Removal of any of these instruments from service outside of a scheduled refueling outage or a controlled system outage may cause a spurious signal which could result in a plant trip, an inadvertent initiation of a safety systern, loss of decay heat removal and'or the defeating of safety interlocks.
l Testing of EFCVs can be performed during a scheduled system outage when appropriate plant administrative procedures and controls are utilized to ensure plant safety. System outages are performed in order to enhance system performance and maximize system availability. 'lhey are scheduled on a less than quarterly frequency (typically once an operating cycle). Taking system outages quarterly solely for the purpose of EFCV testing would result in reduced system availability and increased risk to the plaet.
NUREG 1482, Section 3.1.2 recommends minimizing equipment out of service time.
The additional assurance of operational readiness afforded through surveillance testing must outweigh the impact on plant safety incurred when removing equipment from service.
in Section 4.1.4 of NUREG 1482, the USNRC approves the deferral of backflow testing of check valves to refueling outages when the testing requires the installation of test equipment. 'the intent of this request is the same in that EFCV testing requires a plant evolution which should be avoided unless appmpriate plant administrative controls are in place.
As discussed in NUREG 1482, the staff recommends that the basis for relief address whether: (1) the proposed alternative gives an acceptable level of quality and safety (2) compliance would result in a hardship without a compensating increase in the level of safety, or (3) complying with Code requirements is impractical. Two of these criteria, and the basis for meeting the criteria are provided below:
- See 02-ROJ l for a list of EFCVs tested during refueling outages.
' PDAPS 3 & 3,IST Program Spec. M 710, RevJ Appendix C Page 3 of 13 l !
1he propstdahernative gives an accentable level of auality and safety.
A review of NPRDS industry failure data for the Dragon excess flow check valves, which is the manufacturer of the valves used at PilAPS, reveals only 7 failures. The 7 failures break down as follows; 2 were a result of an IST surveillance which failed to met the acceptance criteria for leakage, I was an indication (limit switch) problem, and 4 were leakage caused by a bad gasket. Iloth IS'. failures occuned at Peach Bottom. A thorough review of Peach llottom excess Om, check valve test history has shown that the 2 NPRDS failures above are the only 2 since 1980. One of the failures,1.1 ppm measured leakage, was due to dirt on the seating surface of the valve; the other,4.0 gpm measured leakage, was due to a defective seating surface in the manual bypass portion of the EFCV. These are 2 independent failures which have not been repeated.. Further, this review of surveillance test history shows evidence of no time based failure mechanisms or chronic failures associated with the excess now check valves. Although the testing of the EFCVs w.s performed on the previous refueling cycle frequency (approximately 18 months), testing of the El CVs has been perfonned since 1993 on a 24 month refueling outage frequency. Therefore, performing the testing of the EFCVs on a 24 month frequency is appropriate.
Cumn11ance would result in a harahin without a compgnantine increase in safety.
Personnel safety would decrease if EFCV testing would be performed on a quarterly basis during plant operation without an appropriate system outage. During power operation, the process side of the EFCVs is nonnally high pressure (>$00 psig) and'or high temperature (>200'F) and highly contaminated reactor coolant. Testing EFCVs during system outage windows with the appropriate administrative procedures and controls applied will ensure personnel safety.
Additionally, testing at a frequency greater than once per operating cycle would also result in increased radiation dosage and reduced system availability without any compensating increase in safety, improvements in work planning and scheduling have resulted in a signincant reduction in outage duration at Peach llottom. As a result of'hese improvements, EFCV testing has become an outage critical path activity. Due to the large number of EFCVs and the plant conditions required to perform the testing (reactor pressure > $00 psig), testing all the valves during refueling results in an outage duration increase of approximately 2 days. Ilased on current replacement power costs, this equates to an expenditure of
$900,000 per year for the life of the plant.
In order to reduce this level of burden, extensive programmatic and procedural controls are used during system outages to ensure that the impact on plant safety is understood prior to removing equipment from service. This process is consistent with industry practice and NRC guidance, and has been recognized as an effective method of controlling the impact of plant activities on safety. During a refueling c,utage, the constraints on tesources are at a premium, and the climination of work which can be safely performed in:lependent of these constraints is both practical and pmdent, in summary, considering the extremely low failure rate, personnel and plant safety concerns, and the high monetary cost of testing during refueling outages, EFCV testing at a frequency greater than once per operating cycle and exclusively during refueling outages is impracticable and results in a hardship without a compensating increase in the level of safety.
l l PilAPS 3 & 3,IST Program t
Spec. M.710, Rev.7 >
Appendix C Page 4 of 13 l ,
Alternate Testing: Functional testing will be performed once per operating cycle during system outages when appropriate plant administrative controls are in place.
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Pil APS 2 & 3,IST Psogram Spec. M 710 Rev.7 Appendix C Page 5 of 13 l GENERIC val.YE REllEF REQUEST . GVRR 3 GVRR 3 is included in Appendix C as a means of documenting the alternate test plan to invoke the use of the 1990 ASME OM Code. It does not represent a deviation from the requirements of ASME OM.1990, Paragraph IS1C
4.3.2. Yalve(s)
Containment Isolation Valves Category: A Test Requirements: Category A valves that do not provide a reactor coolant system pressure isolation function must be analyred in accordanet, with paragraph ISTC 4.3.3(e), and corrective action for these valves must be inade in accordance with paragraph ISTC 4.3.3(0, as stipulated in 10 Cl R 50.55(a)(b)(2)(vii).
Alternate Test Plan: 10 CFR .s0.55a(3) states that proposed alternatives to the requirements of paragraphs (c, (d), (c), (0, and (g) of 10 CFR 50.55: may be used if the applicant demonstrates that proposed alternatives would provide an acceptable level of quality and safety.10 CFR 50.55a(0(4)(ii) requires that inservice tests must comply with the requirements in the latest edition and addenda of the Code incorporated by reference in paragraph (b) of 10 CFR 50.55(a). Paragraph (b) currently references the use of the ASME Iloiler and Pressure Vessel Code,Section XI, Division I,1988 Addenda through the 1989 Ed. tion.
As an additional condition specified in $0.55a(b)(2)(vil), when using Subsection IWV of the 1988 Addenda through the 1989 Edition, leakage rates for Category A containment isolation valves that do not provide a reactor coolant system pressure isolation fuaction must be analyred in accordance with paragraph 4.2.2.3(c) of part 10, and corrective actions must be made in accordance with paragraph 4.2.2.3(0 of part 10 of ASMIVANS!
OMa.1988 Addenda to ASMluANSIOM 1987.
PECO Energy Company proposes to use ASME OM Code.1990 in lieu of the ASMG Section XI, Division 1,1988 Addenda through 1989 Edition, which invokes the use of ASMIVANSI OMa.1988 Addenda to ASMIVANSI OM 1987 Parts 6 and 10 and ASME/ ANSI OM.1987 Part 1.
ASME W. Code.1990 provides an acceptable level of qual;ty and safety in that ihe reqmtemenu of OM 1990 are the same as in the ASMIVANSI OMa.1988 Addenda.
Additionally, use of ASME OM 1990 eliminates the additional conditions specified in 50.55a(b)(2)(vii) for leakage rate analysis and corrective action requirements for Category A containment isolation valves that do not provide a reactor coolant system pressure isolation function. Leakage of containment isolation valves is controlled by the PilAPS Primary Containment Leak Rate Test (PCLRT) Program. His program ensures that if a valve is identified with excessive leakage, corrective actions are taken to ensure the leakage is maintained below the containment integrity limits specified by 10 CFR 50, Appendix J and the Technical Specifications, ne PilAPS PCLRT Program includes owner specified acceptance criteria for individual valves and groups of valves Corrective maintenance is initiated when the measured leakage rate exceeds the owner specified limit. As always, the operability of a valve or valve combination which exceeds the owner specified limit is evaluated in accordance with PECO Nuclear procedures.
PilAPS 3 & 3,IST Program !
Spec. M 710, Rev.7 l Appendix C Page 6 of 13 l GENERIC val.VE RELIEP REQUEST . GVRR 4 Valve (s): Containment 1 solation Check Valves CllK-2(3)-0/4-028A,11 Cl!K 2(3)-07C-4(5)0144 CilK.2(3)-06 096A Il CliK 2(1) 07C-4(5)0145 CllK 2(3) 07C-4(5)0142 CIIK 2(3) 13C-50 CilK 2(3)-07C-4(5)0143 CIIK 7(3)-23C-65 Category: A, C Test Requirementswanu : Check valves shall be exercised nominally every 3 months as required by ISTC 4.5.
Ilasis for Relief: These check valves perform a safety function in the closed direction as containment isolation valves. The only means available to exercise these check valves in the clo ed direction is by leak testing. PilAPS currently performs leak rate testing at the frequency allowed by Option 11 of 10 CFR $0 Appendix J. Reverse uercising these check valves by performing seat leakage testing at the frequency allowed by the Primary Containment Leak Rate Test (PCLRT) Program provides adequate assurance the valve is closing properly. In the absence of good performance history, Option 11 limits the test frequency to 30 months, liased on the current 2 year operating cycle, this would require testing at a 2 year frequency (valves are tested during refueling) which is the same frequency which would be invoked for these valves via e Refueling Outage Test Juttincation since reverse exercise testing requires the installation of test equipment. Performing seat leakage testing to satisfy reverse exercising requirements at a frequency greater than that required by the PilAPS (PCLRT) Program is burdensome without a commensuinte increase in quality and safety.
Alternate Testing: These check valves will be exercised i's the closed direction during the perfomiance of leak rate testing in accordance with the frequency speci0ed by the P11APS PCLRT Program.
PilAPS 3 & 3. IST Progrs.m Spec. M.710, Rev.7 Appendix C Pa$c 7 of 13 l GENERIC VALVE RELIEF REQUEST . GVRR.5 Vahe(s): Administratively Controlled Category 11 Passive Manual isolation Valves llV.2(3)10-081 A,11 llV.2(3).14-014A, il llV.2(3) ll.018 Category: 11 Test Requirements: Category !! passive valves shall receive position indication verification as specified in ISTC Table 3.61.
Ilaus for Relief: These category 11 passive manual valves are installed in a safety related flow path and perform a passive safety function in the open position, llowever, they are adtninistratively controlled in their safety related position by maintaining them in the locked open position and are prevented from closure during all plant operating conditions when the associated system is required to be operable. The valves are considered ruaintenance valves and are placed in the closed position to either facilitate seat leakage testing of upstream containment isolation valves or to perform system rnaintenance without draining down reactor vessel water level. When opened, subsequent to closure, system alignment procedures ensure the valves are properly positioned with locks reapplied.
Alternate 'lesting: Rernote position indication verification will not be performed on the category B passive manual valves identified above.
i PBAPS 2 & 3,IST Program Spec. M 710, Rev.7 Appendix C Page 8 of 13 l GENERIC VALVE RELIEF REQUEST . GVRR-6 Valve (s): Rapid Acting Power Operated Valves Catepry: A, B f
Test Requirernents: Valves that stroke m less than 2 seconds may be exempted from paragraph ISTC 4.2.8(d). In such cases the maximum limiting stroke time shall be 2 seconds. This s requirement is specified in paragraph ISTC 4.2.8(e).
Itasis for Rehef: For rapid actuating power operated valves, PBAPS proposes to utilize a maximum limiting stroke time of 5 seconds in heu of the 2 second criteria specified in ISTC 4.2.8(e). 'lhese valves generally are small air and solenoid operated valves which, because of their size and actuator types, stroke very quickly. Operating history on this type of valve indicates that they generally either operate immediately or fail to operate.
The intent of the aferenced testing requirement is to trend valve stroke time as a means of detecting valve degradation. Due to human response time variations, comparison of stroke times to a reference stroke time or utilizing the maximum lindg rtroke time of 2 seconds could lead to declaring a valve inoperable when it is functioning normally.
Assigning a maximum limiting rtroke time of 5 seconds to power operated valves which stroke in <5 seconds or utilizing the acceptance criteria specified in ISTC 4.2.8(d) for those rapid acting valves which normally stroke close to 5 seconds provides adequate assurance that valve degradation will be detected prior to its inability to accomplish itr design safety function.
Alternate Testing: A maximum limiting stroke time of 5 see will be t p;cified for each rapid actuating power operated valve, if the valve stroke; in 5 see or less, it will be considered acceptable and no con:ctive action will be required. If the valve exceeds 5 seconds, appropriate corrective action will be taken. For those power operated valves which stroke at or close to the 5 second limit, PBAPS may apply the acceptance criteria specified in ISTC 4.2.8(d), which allows not more than 150% change in stroke time when compared to a reference value.
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PilAPS 2 & 3. IST Program Spec. M 710, Rev,7 Appendix C Page 9 of 13 l GENERIC VALVE RELIEF REQUEST - GVRR */
Valve (s): VRV 2-13C-139A,B,C,D VRV 2 23C-140A,D,C,D VRV.3-13C 139A,D,C,D VRV 3-23C 140A,B,C,D i
Category: C Test Requirements: E-ercise in the forward and reverse directions nominally every 3 months as required by ISTC 4.5 liasis for Relief: These check valves, which function as vacuum relief valves, perform a safety function in the open direction to prevent siphoning of suppression pool water into the turbine exhaust line due to steam condensing when the liigh Pressure Coolant injection (IIPCI)
! and Reactor Core Isolation Cootmg (RCIC) systems are shutdown. These valves also perform a safety function in the closed direction to prevent back flow ofIIPCI and RCIC turbine exhaust steam through the vac.um breaker lines.
The valves are installed in series-parallel and were not provided with air operators to facilitate testing (exercising). The piping configurations in the llPCI and RCIC systems do not allow for individual testmg of these valves. All valves shall be included in the IST Program as discussed in NUREG 1482, Section 4.1.1, Alternate Testing: The above valves will be tested quarterly in the forward and reverse directions as a unit.
Forward exercise testing will be performed by verifying the turbine exhaust lines are drained. Valve closure will le verified by monitoring the llPCI and RCIC turbine exhaust vent high temperature m rms located upstream of the valve assemblies. liigh temperature alarms will indicate steam'le2kage past the valves.
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l PflAPS 2 & 3,IST Progr:m Spec M 710, Rev.7 l Appendix C Page 10 of 13 l VALVE REl.lEF REQUEST - 03A VRR 1 System: liydraulic Control Unit Valve (s): CV-2-03A 13126AA thru IIC CV-3-03A-13126AA thru llc CV 2-03A 13127AA thrullC CV 3-03A 13127AA thru llc CllK 2-03A 13114AA thru llc CilK 3-03A 13114AA thru !!C Category: B (CV 2(3)-03A 13126AA thru llc, CV 2(3)-03A 13127AA thru llc)
C (CilK-2(3)-03A-13114AA thru llc)
Function: Control rod drive scram valves.
Test Requiremer:ts: Exercise, stroke time, and fail-safe test nominally every 3 months as required by ISTC 4.2.1.
(CV 2(3) 03A 13126AA-+11C, CV 2(3)-03A 13121AA* llc)
Exercise in the forward direction nominally every 3 months as required by ISTC 4.5.
[ClIK 2(3).03A.13114AA-+1iC) llasis for Relief: These valves are located on the hydraulic cor. trol units for the control rod drives, whose function is to rapidly insert the control rods on a signal from the reactor protection system for reactor scram initiation. The proper functioning of these valves as a usat is most practically verified by perfonning an actual scram test and measuring control rod insertion times.
- Alternate Testing: The control rod scram insertion time testing required by Technical Specification 3.1.4 will be performed in lieu of the OM Code required test ng.
' DART testing may be used in lieu of sciem iesertion time testing post maintenance. See Tech. Spec. SR 3.1.4.3 Bases.
PBAPS 2 & 3,IST Program Spec.14 710, Rev.7 Appendix C Page 11 of 13 l VALVE REl.lEF REQUEST VRR 1 System: Residualllent Removal Valve (s): CIIK-2 10-183 A, B CllK-3-10-183A, B CllK 210-184A, B CIIK 310-184A, B Category: C Function : Residualllent Removal'LPCI Stay fill supply check valvea.
Testing Requirement (s): Individual valve exercise in the reverse direction nominally every 3 months as required by ISTC 4.5.
Basis foi Relief: The above stay fill check valves are installed in pairs (series arrangements) with no provisions for individual valve testing (i.e. CIIK 10-183 and CilK 10-184 are in series).
The valves function, in series as a pair, to prevent loss of RilR inventory to the stay-fill system in the event of a stay-fill system failure and to maintain the discharge piping of the LPCI system in a filled condition to prevent water hammer upon system initiation as required by T.S. 3.5.1. Therefore, both valves in series shall be included in the IST l Program as directed by NUREG 1482 Section 4.1.1. The only way to verify closure of these valves is by perfonning a leak or prenurization test. Lioth methods require the installation of test equipment. Testing these valves daring power opention would render the stay fill system inoperable, requiring entry into the associated limiting condition for operation (LCO). Testing these valves during cold shutdown could delay plant restart due to the necessity of utilizing temporary test equipment.
Alternate Testing: Valves will be tested as a pair in the reverse direction during refueling outages. Both valves in the pair will be considered inoperable if testing indicates the valves do not close on reverse flow.
Spec. M-710, Rev.7
. Appendix C Page 12 of 13 l VALVE RELIEF REQUEST - 33 VRR 1 System: Emergency Service Water Valve (s): MO-0-33-0498 Category: B Function: Provide isolation of ESW return to the normal heat sink Test Requirements: Exercise and stroke time nominally every 3 months as required by ISTC 4.2.1 Basis for Relief: The function of this valve is to isolate the ESW Sptem discharge to create a closed loop system for emergency heat sink operation. MO-0-33-0198 is the only power operated valve in the ESW System single discharge line to the Conowingo Pond. When the valve is in the full open position, the ESW System is aligned in its normal configuration and is OPERABLE. When MO 0 33-0498 is closed, an ESW pump and a booster pump are started providing the required flows to all safety.related equipment served by ESW.
Ilowever, the ESW booster pumps do not meet separation criteria requirements and cannot be relied upon to support the ESW pumps in maintaining system design flow rates to safety related equipment served by the ESW system in the event of a design basis accident. Failure of MO-0-33-0498 in the closed positi on could result in flow rates to components served by ESW to fall below their design values. Exercising this valve to the closed position during power operation, with a subsequent failure to reopen, would render the ESW system inopera'.,le. Testing shall be deferred to at least once each year when river temperature is less than or equal to 53' F (PECO Calculation PM-0989). At this temperature, adequate heat removal is provided to the safety related equipment dependent upon ESW without reliance on the support of the ESW booster pump when ESW is aligned to the emergeng heat sink. The deferral of testing this valve is acceptable per the discussion pn,vided in NUREG-1482, Section 3.1.1.
Alternate Testing: MO-0-33-0498 shall be full stroke exercised tested and stroke timed annually when river temperature is less than or equal to 53* F.
PIIAPS 2 & 3,IST Program Spec. M 710, Rev.7 Appendix C Page 13 of 13 l VALVE RELIEF REQUEST 33 VRR 2 Systchi: Emerge. icy Service Water Valve (s): AO-0-33-0241 A,11,C,D Category: 11 Function: Provide isolation of ESW cooling wates flow to the diesel generator air cooler jacket water cooler and lube oilCooler Test Requirements: Stroke time results shall be compared to the initial reference values for the determination of stroke time acceptance criteria per ISTC 4.2.o.
liasis for Relief: ne function of these air operated valves is to isolate the ESW cooling water flow to the diesel generator air coeler, jacket water cooler, and lube < 1 cooler and must open to allow tiow, Dese air operated valves are provided with mechanical stops to allow adjustment of stroke length. The valve stroke lengths are adjusted, or flow balance verified, at a frequency of at least once ever > 6 weeks as river temperature changes to ensure the proper amount of cooling flow is provided to each diesel generator. Frequent flow b.ilancing is performed as a result of commitments made i t response to GL 8913.
This activity results in frequent failures to meet the acceptance criteria specified in ISTC 4.2.8 and thus requires subsequent corrective action per the requirements of ISTC 4.2.9(b). Due to the level of test activity associated with these valves, degradation would be detected without applying the stroke time acceptance criteria specified in ISTC 4.2.8.
In addition, although not considered skid-mounted, the valves are also verified to be functioning pronerly by virtue of satisfactory diesel generator testing.
Attemate Testing: Limiting values of stroke time shall be established in accordance with ISTC 4.2.4 and corrective actions shall be performed in accordance with ISTC 4.2.9(a). The stroke time acceptance criteria specified in ISTC 4.2.8 shall not be applied.
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- APPENDIX D l
l VALVE NSERVICE TESTING PROGRAM REFUELING OUTAGE TEST JUSTIFICATIONS i
PBAPS 2 & 3,IST Progr:m Spec. M 710, Rev.7 Appendix D Page 1 of 9 l REFUELING OUTAGE TEST JUSTIFICATION - Ol ROJ !
System: Main Steam Valve (s): RV 2-02-071 A, B, C, G, K RV 3-02-07I A, B, C, G. K Category: B, C Function: Depressurization of the RCS to allow for low pressure coolant injection.
Testir.g Requirement (s): Quarterly exercise and stroke time.
Deferred Test Justification: If any of these valves fail to re-close after testing, the plant would be placed in a LOCA condition. In addition, a study (BWR Owner's Group Evaluation of NUREG-0737, item II. K.3.16, Reduction of Challenges and Failures of Relief Valves) recommends that the number of ADS openings be reduced as much as possib!c. Based on this study and the potential for causing a LOCA condition, exercise testing of the ADS valves will be performed during restart after refueling.
Also, a direct metLod to stroke time the ADS valves is not available since the control room indication only reflects ADS Relief Valve pilot valve position, and not the actual valve disc position. An alternate indirect method to stroke time the ADS valves la available which includes timing the pilot valve and observing plant parameter changes.
Partial Stroke Testing: Partial stroke exercising cannot be performed for the same reasons mentioned above.
Alternate Testing: Exercise during restart after refueling. Stroke time test during restart after refueling by timing the interval between pilot valve initiation and observable plant parameter changes.
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PBAPS 3 & 3,IST Program Spec. M 710, Rcv.7
, Appendix D Page 2 of 9 l REFUELING OUTAGE TEST JUSTIFICA CON . Ol ROJ-2 Systm Main Steam Valve (s): VRV 2-02-8096A, B, C, D, E, F,0, II, J, K, L VRV.3-02-9096A, B, C, D, E, F, G, II, J, K, L VR%2-02 307 A, B, C, D, E, F, G, II, J, K, L VRV 3-02 307A, B, C, D, E, F,0,11, J, K, L Category: C Function: Main Steam Safety / Relief valve tailpipe vacuum breaker.
Testing Requirement (s): Quarterly exercise in the forward and reverse directions.
Deferred Test Justification: Testing these vacuum breaker / check velves requires entiy into primary containment.
During power operation, ti.e containment atmosphere is inert with nitrogen gas limiting access to emergencies only, in addition, high radiation levels during power operation prohibit containment entry. During cold shutdowns when the containment is not de-inerted, testing is not practical for the same reasons as stated above. In the unlikely event that the containment is de-inerted during an unplanned cold shutdown, containment access is limited to those activities necessary to place the piant in a safe candition, cr return the plant to power operation.
Partial Stroke Testirg: Pa tial stroke exercising cannot be performed for the same reasons mentioned above.
Altemate Testing: Forward and reverse exercising will be verified during all refueling outages.
Pf3APS 2 & 3,IST Program Spec. M 710, Rev.7
- Appendix D Page 3 of 9 l REFUELING OUTAGE TESTJUSTIFICATION 02-ROJ l
- Valyc(s): XFC 2(3)-02-008A(")
XI C 2(3)-02-015A(b, XFC 2(3)-02-017A(13)
XFC-2(3)-02-019A(II) XFC-2(3)-02-02113(D)
XFC-2(3)-02 027 XFC-2(3)-02-033 XFC-2(3)-02-037A(13) XFC-2(3)-02 073A thru 11 Category: AC Function: Restrict or limit the loss of reactor coolant subsequent to an instrument line break outside r primary containment.
Test Requirements: Check valves shall be exercise nominally every 3 months as required by ISTC 4.5.
11 asis for Relief: Excess flow check valves (EFCV) are installed on instrument lines penetrating containment to minimize leakage in the event of an instrument line failure outside the containment in escordance with Regulatory Guide 1.11. The EFCV is a spring loaded ball check valve. Since the system is normally in a static condition, the valve ball is held open by the spring. Any sudden increase in flow through the valve (i.e. line break) will result in a differential pressure across the valve which will overcome the spring and close the valve. Functional testing of valve closure is accomplished by venting me instrument side of the valve while the process side is under pressure and verifying the absence of leakage through the vent.
The testing described above would require the removal of the associated instrument or instruments from service on a quarterly basis. Removal of any of these instruments from service outside of a scheduled refueling outage or a controlled system outage may cause a spurious signal which could result in a plant trip, an inadvertent initiation of a safety system, loss of decay heat removal and'or the defeating of safety interlocks.
sonnel safety would decrease if EFCV testing would be performed on a quarterly dsis during plant opeTation without an appropriate system or refueling outage. During power geration, the pmcess side of the EFCVs is normally high pressure (>$00 psig) and/or high temperature (>2000F) and exposed to highly contaminated reactor coolant.
Testing EFCVs during system outage windows or refueling outages with the appropriate adininistrative p,ocedures and controls applied will ensure personnel safety, in summary, considering the extremely low failure rate, personnel and plant safety concerns, and the high monetary costs of quarterly testing, EFCV testing at a frequency greater than once per operating cycle is impracticable and would result in unnecessary hardship without a compensating increase in the level of valve reliability and plant safety.
Alternate Testing: Functional testMg will be performed once per operating cycle during refueling outages when appropriate plant administrative controls are in place.
- See GVRR-2 for a list of EFCVs tested during system outages.
, PBAPS 3 & 3, IST Program Spec. M 710, Rev,7
, Appendix D Page 4 of 9 l REFUELING OUTAGE TEST JUSTIFICATICN 02G-ROJ l System: Reactor Vessel Level Instr. Reference Leg Backfill System Valve (s): CIIK 2-02G-23450A, B CilK 3-020 33450A, B CitK 2-02G 23431 A, B CIIK-3 020 33451A, B
, CliK-2-02G-23462A, B CIIK 3-02G 33462A, B CIIK-2-02G-23463A, B CHK 3 02G-33463A, B Category: A, C Function : Control Rod Drive supply to the Reactor Pressure Vessel itstruraent Condensing Chambers itNation.
Testing Requirement (s): Exercise in the reverse direction quarterly.
Deferred Test Justification: Exercise testing of these check valves requires system valve isolation and the use orc test rig to introduce flow toward the check valve in the reverse direction. This increases the possibility of air infiltration to the system wl.ich could result in ECCS or RPS safety system actuation due to spurious level indications.
During refueling, air infiltration is teduced because the system is backfilled through system head chambers and the CRD system. Backfill of the system could not be performed during normal power operation because of the requirements for availability of the CRD and RPV level system at this time. Additionally, the valve movement required to perform thi= test increases the risk of a pressure spike on the reference leg which could result in the initiation of a plant transient.
In addition to the plant safety concerns, personnel safety concema must be considered since the process side of these valves is normally high energy (>500 psig) during normal power operation. Personnel safety risks are considerably minimized when testing is performed during refuelinF outages, l
, Extension of the test interval to refueling outages for check valves verified closed by leak testing has been approved by the NRC in Section 4.1.4 of NUREG 1482.
Partial Stroke Testing: Partial stroke exercising cannot be performed for the same reasons mentioned above.
Alternate Testing: Valves will be exercised in the reverse direction during refueling outages.
PBAPS 2 & 3,IST Program j Spec. M 710, Rev.7 Appendix D Page 5 0f 9 l REFUELING OUTAGE TEST JUSTIFICATION . 07 ROJ l Valve (s): SV 2(3)-07D-2(3)671F Category: A Function: Containment isolation.
Test Requirements: Exercise, stroke time, and fail safe testing nominally every 3 months as required by ISTC 4.2.1.
Deferred Test Justification: SV.2(3)671F are normally open solenoid operated valves located in the CACS sample line from the torus high volume purge exhaust line to the CAD /CAC analyzer. He valves have NO safety function in the open position. Their normally open position allows representative sampling of the purge exhaust air to monitor oxygen concentration.
This non-safety related function is not required for accident mitigation. H e s .ves perform an active safety function in the closed position to maintain primary containment integrity. They rnust be capable of automatic closure, if open, upon receipt of a Group
!!! isolation signal he valves receive power from a safeguard ac emergency power source and fail to the closed position upon loss of power.
Due to their 'ocation, testing these valves presents personnel safety and ALARA concems (i.e., the reactor building on top of the torus is a contaminated area lacking a platform from which to gain access safely). These solenoid operated valves wquire the installation of external non-intrusive test equipment (gauss probe and ac.,ustic sensor) locally to facilitate stroke timing. The installation of temporary test equipment quarterly and during cold shutdowns is burdensome without a compensating increase in the level of quality and safety. Testing the valves at least once cach operating cycle provides adequate assurance of operational readiness.
SV.2(3)671F are exercised during performance of 10 CFR 50 Appendix B leak testing.
This testing verifies the valves will perform their required safety function (containment isolation). The valves are also exercised during performance of routine CAD /CAC system testing. This additional testing provides added assurance of operational readiness.
Altemate Testing: Exercise, stroke time, and fail-safe testint will be performed once per operating cycle.
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i
' Spec. M 710, Rev.7- ;j
-*- Appendix D -
Page 6 of 9.- l .
REFUELING OUTAGE TEST JUSTIFICATION ill ROJ l I 4
Systemr Standby Liquid Control Valve (s): CliK 2 L 016 CIIK 3 ll-016 CliK 2 ll-017 CIIK 3 ll-017 -
1 ~
Category:. A, C [CIIK 2(3) 11016] :
C (CilK 2(3)-11-017]-
- i Function
- -Standby liquid control injection checks - inside/outside primary containment. j Testing Requirement (s): Exercise in the forward direction.-
Deferred Test Justification: - Verifying forward flow operability requires firing a squib _ valve and injecting water into
- the Reactor Coolant System using the standby liquid control pumps, injection of borated
- water during operation wih result in a reduction in power. Additionally, introduction of 2
relatively colder water into the Reactor Coolant System will cause a thermal cycle (shock) which can result in the premature failure of system components (piping). Since -
the firing of squib valves requires valve disassembly to replace valve internals, firing should be minimized. Therefore, forward flow testing of the check valves will be _
, petformed during SLC injection testing as required by Technical Specifications (T.S.
3.1,7). Also, firing squib valves should be minimized as mentioned above, and replacing squib valve internals at cold shutdown could delay plant start up, Partial Stroke Testing: Partial stroke exercise testmg cannot be performed for the same reasons stated above.
Alternate Testing: Forward flow operability for CilK-2(3)-11016 and CIIK 2(3)-11017 will be verified at refueling during SLC injection testing.
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PDAPS 2 & 3,IST Program Spec. M 710, Rev.7 Appendix D Page 7 of 9 l REFUELING OUTAGE TEST JUSTIFICATION - 13C-ROJ l System: Reactor Core Isolation Cooling Valveis): CliK 213C 38 CllK 3-13C-38 Category: C Function : RCIC Barometric Condenser Vacuum Pump Discharge Check Valve To The Torus.
Testing Requirement (s): Exercise in the reverse direction.
Deferred Test Justification: nese check valves are not equipped with local or remote position indication. The only way to verify closure of these valves is by performing a leak test, or by using a pressurization test method. Both methods require removing RCIC from service to install test equipment.
De RCIC system is a high pressure cooling system which provides an additional margin of safety to the reactor during accidents and transients which do not fu?ly depressurize the reactor. la urder to support maximum availability of this reactor cooling safety system, testing will be deferred to refueling outages when the system is not required for reactor coolant injectioa.
Extension of the test interval to refueling outages for check valves verified closed by leak testing has been approved by the NRC in Section 4.1.4 of NUREG 1482.
Partial Stroke Testing: Cl!K-2(3)-13C 38 does not have a forward exercise test requirement (no safety function in the forward direction) but is implicitly tested quarterly as part of the skid during RCIC operability testing. Testing in the reverse direction will not be performed quarterly.
Alternate Testing: Valves will be exercised in the reverse direction during refueling outages.
PBAPS 2 & 3,IST Program Spec. M-710 Rev.7
, , . Appendix D Page 8 of 9 l REFUEL.ING GUTAGE TESTJUSTIFICATION - 21 ROJ-01 Sysum: Post Accident Sampling Valve (s): Cl!K 2-2140252 Cl!K 3 2150252 Category: C Function : Post accident liquid sample return line to the suppression pool.
Testing Requirement (s): Exercise in the reverse direction nominally every 3 months as required by ISTC 4.5.
Position Justification: These check valves are not equipped with local or remote position indication. The only way to verify closure of these valves is by performing a leak test, or by using a pressurization test method.130th methods require the installation of test equipment.
Extension of the test interval to refueling outages for check valves verified closed by leak testing has been approved by tFe NRC in Section 4.1.4 of NUREG 1482.
The testing of these valves is considered beyond the scope of 10 CFR 50.55.a due to its categorization of C" which indicates that seat leakage is inconsequential to the valve performing its design safety function. This is consistent with the NRC's recommendation and discussion provided in NUREG 1482, Section 4.4.2. Ilowever, because the valve provides a backup isolation capability to the suppression pool water seal, it shall be included in the IST program as Category "C" and tested pursuant to the requirements of ISTC during refueling outages.
Altemate Testing: Val;" will be exercised in the reverse direction during refueling outages.
0 PDAPS 3 & 3,IST Program Spec. M-710, Rev.7
. . . . Appendix D Page 9 of 9 l REFUE!JNG OUTAGE TEST JUSTIFICATION . 23C-ROJ-01 System: liigh Pressure Coolant Injection Valve (s): CIIK 2 23C-56 CllK 3 23C 56 Category: C Function : IIPCI Turbine Exhaust Drain To Suppression pool Check Valve.
Testing Requiement(s): Exercise in the reverse direction.
Peferred Test Justification: These check valves are not equipped with local or remote position indication. The only way to verify closure of these valves is by performing a leak ;est, or by using a pressurization test method. To perform either of these tests,1) the system must be blocked which renders the llPCI system inoperable, and 2) test equipment must be installed. For these reasons, quarterly testing during power operation is not practicable, and testing during cold shutdown could delay plant startup due to the necessity of utilizing temporary test equipment.
The llPCI system is designed to pump water into the reactor while it is fully pressurized and provides emergency core cooling in the event of a small break LOCA which does not cause a rapid depressurization of the reactor. In order to support maximum availability of this ECCS, testing will be deferred until refueling when the system is not required for high pressure coolant injection capability and no impact exists on plant startup activities.
Extension of the test interval to refueling outages for check valves verified closed by leak testing haGeen approved by the NRC in Section 4.1.4 of NUREG 1482.
Partial Stroke Testing: Forward exercising is performed quarterly during the llPCI operability test; quarterly exercise testing in the reverse direction will not be performed.
Alternate Testing: Valves will be tested in the reverse direction during refueling outages.
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