ML20203F021

Technical Evaluation Rept for Calvert Cliffs Nuclear Power Plant,Units 1 & 2,Baltimore Gas & Electric Co, Third 10-Yr Interval Pump & Valve Inservice Testing Program

ML20203F021
Person / Time
Site:	Calvert Cliffs
Issue date:	11/26/1997
From:	Dibiasio A BROOKHAVEN NATIONAL LABORATORY
To:	NRC (Affiliation Not Assigned)
Shared Package
ML20203E948	List: ML20203E943 ML20203E974 ML20203F021
References
CON-FIN-J-2402 TAC-M98523, TAC-M98524, NUDOCS 9802270181
Download: ML20203F021 (75)

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-ATTACHMENT: 2 TECHNICAL EVALUATION ~ REPORT '

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Calvert Cliffs Nuclear Power Plant-s Units 1 and 2:

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Baltimore Gas and Electric Company '

c o : Third Ten-Year Interval Pump and Valve Inservice Testing Program Do$ket Number:150-317 & 31'8

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. Prepared by:l A. M. DiBiasio Department of AdvancedTechnology;

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. J. Colaccino, NRC Technical Monitor' Ace Division of Engineering -.

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I ABSTRACT his report presents the results of Brookhaven National Laboratory's evaluation of the relief requests, cold shutdown and :efueling outage justifications and, for selected systems, a review of the scope of the C&ert Cliffs ASME Section XI Pump and Valve Inservice Testing Program, e

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TABLE OF CONTENTS 111 ABSTRACT 1

1.0 INTRODUCTION

2.0 PUMP IST PROGRAM RELIEF REQUESTS 2

2.1 Safety injection and Containment Spray Pumps 2

7 2.2 Auxiliary Feedwater Pumps 11 2.3 Charging Pumps 12 2.4 Saltwater Pumps 3.0 VALVE IST PROGRAM RELIEF REQUESTS 15 15 3.1 Safety and Relief Valves 19 3.2 Containment Spray and Safety 1 Qection System 4.0 VALVE TESTING DEFERRAL JUSTIFICATIONS 24 25 3.0 IST SYSTEM SCOPE REVIEW 6.0 IST PROGRAM RECOMMENDED ACTION ITEMS...........

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7.0 REFERENCES

Appendix a Valve Testing Deferral Justification Evaluation 35 e

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o Tv.hnical Evaluation Report Pump and Valve Inservice Testing Program e

Calvert Cliff

1.0 INTRODUCTION

Contained herein is a technical evaluation of American Society of Mechanical Engineers (ASME)

Section XI pump and valve inservice testing (IST) program relief requests submitted by Baltimore Gas and Electric Company (BGE) for its Calven Cliffs Nuclear Power Plant. he Calven Cliffs Plant, Units 1 and 2, are Combustion Engineering (CE) Pressurized Water Reactors (PWR) that began commercial operation in May 1975 and April 1977, respectively.

BG3 submitted Revision 0 of the nird Ten-Year Interval 1nservice Testing Program on April 30, 1997 (Ref.1). Revision 1 of the program was submitted on October 1,1997 in response to a conference call held September 4,1997 between the NRC, BGE and BNL regarding Revision 0 (Ref. 2). His program revision su persedes all previous submittals. The third ten year interval extends from January 15,1998 to J anuary 14,2008. He licensee states that this program is based on the itquirements of the 1989 Edition of the ASME Section XI Code.

Title 10 of the Code of Federal Regulations,650.55a1(f) requires that inservice testing of ASME Code Class 1,2, and 3 pumps and valves be performed in accordance with Sectiou X1 of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific relief has been requested by the licensee r.nd granted by tae Commission pursuant to 650.55a 1(a)(3)(i),

(a)(3)(ii), or (f)(6)(i). Section 50.55a 1(f)(4)(iv) provides that inservice testing of pumps and valves may meet the recuirements set fonh in subsequent editions and addenda that are incorporated b reference in paragraph (b) of 650.55a, subject to the limita* ions and modifications listed, and su ect to Commission approval. In rulemaking to 10CFR50.55a, effective September 8, 992 (see Federni Re mter. Vol. 57, No.152, page 34666), the 1989 Edition of ASME Section XI was incorporate 4 into paragraph (b) of i 50.55a. De 1989 Edition provides thst the rules for inservice testing of pumps and valves are as specified in ASME/ ANSI CMa-1988 Part 6 and 10, and OM-1987 Part 1.

De review of the relief requests was performed utilizing the Standard Review Plan, Section 3.9.6; Generic Letter 89-04 " Guidance on Developing Acceptable Inservice Testing Programs;"

the Minutes of the Public Meeting on Generic Letter 89 04, and Suppleinent to the Minutes; NUREG-1482; NUREG/CR-6396; and the recently published summary of the public workshops held in January and February 1997 on IST (References 8-14). The IST Program reguirements a) ply only to component (i.e., pump and valve) testing and are not intended to provide a basis to c 2ange the licensee's current Techmcal Specifications for system test requirements.

Section 2 of this report resents the eight pump relief requests requirir g review, and Brookhaven National Laboratory's (3NL) evaluation. Pump relief request PR-07 was deleted and the tenth pumn relief request concems the use of errata contained in the 1989 Addenda of the ASME Operation and Maintenance (OM) Standanis. Ap?roval to use this errata is not required. Similar information it presented in Section 3 for seven re:Jef requests for the valve testing program. Two valve relief requests address valves that are not ASME Code Class or are not regtured for safe shutdown. As discussed in NUREG-1482, Section 2.2, NRC approval is not required. nree relief requests are authorized by Position 2 of Generic leuer 89-04. Relief reguests that are authorized by Generic Letter 89 04 are not specnically evaluated in this Techmcal Evaluation Report. However, any anomalies associated with the relief requests are addressed in Section 5 of the r port. One valve relief request has been withdrawn.

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Seedon 4 and AWh A contain the evaluadon of BOE'sh@*tions to defer valve tasting to cold shutdowns or refueling outages.- Section 5 summarizes the secommende<! actions for the liaaaaae, resultin p from the relief reguest and defened testing justification evaluations, and the review of the IS1 Program scope for selected systems. BNL recommends that the lineanae resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this soport.

2.0 PUMP IST PROGRAM RELIEF RE, QUESTS In accordance with 650.55a, BGE has submitted ten relief requests for ps at Calvert Cliffs which are sub toinservice testin, une the requirernents of ASME tion XI. De relief reguests have reviewed to veri; their technical basis and determine their acceptability. Eight sehef requests, abag with the tec evaluation by BNL, are summarized below. Relief No. PR-10 requests relief to use errata to Figure 1 of OMa 1988, Past 6 that was in OHb 1989. No approval is sequired to use errata to the 1989 Edition of Seedon XL Request PR-07 has been withdrawn by the licensee.

1.1 Safety In'ection and Containment Spray Pumps 2.1.1 Relief Request PR 01, LPSI Pumps -

Reh'efRequest: De licensee requests relief from the requirements of the OMa-1988, Past 6,15.1 and 5.2(c) which requires flowrate and pressure to be determined and compared to their respeedve reference values nominally every three months, where system sesistance cannot be varied.

ProposedAfrernare Tesdng: Delh=a has proposed to com measurements ofpressure and vibration to their reference values quarterly. Flowrate will be verified to be greater than the minimum Dow requirement. During testing performed at col shutdowns or sefuelir.,;; pressure, Dowrate, and vibration will be socorded ar.'d evaluated in accordance with 15.2(b).

"During quarterly testing of the LPSI pumps, flow is routed through Licensee's Basis)br Relief; ion line retuming borated water to the refuelin water tank (RWT).

a minimum flow stcirculat His recirculation flowpath is capable of passing a flowrate approximatel percent of that at the pump design operating point. A flow instrument is installed on this ation piping; however, there is concern regarc ing the practice of throttling under minimum flow condidons with the potential for causing pump damage. In addition, aydraulic pump test data at or near a pump's shutoff head provides litde information as to the mechanical condidon of a pump.

NRC Genede Letter 89 04, Position 9. (Reference 2.7), allows aLaintion of minimum flow test line Dowrate measurements providing inservice tests are perfonned during cold shutdowns or refueling under full or substantial flow conditions where pump flowrate is recorded and evaluated.

He proposed alternate testing is consistent with the philosophy and the intent of Posidan 9.

Dese pumps are standby p, umps and little degradadon is expected with nespect to hydraulic perfonnaace during operanonal periods when the pumps are idle. Dus, the alternate testing will provide adequate monitoring of these pumps with respect to the applicable Code requirements to ensure continued operability and availability for acci&nt mitigation."

Emhusic It is impraedcal to test the low y.s-safety injection (LPSI) pumps at full-flow ouring operation because the low head produced by these pumps cannot overcome the reactor 2

4 neae pumps can only be tested during operadon utilizing a minimum In Generic Immer 8904, Posidon 9, the NRC detennined that in cases where flow can only be established through a non-instrumened minimum flow path during quarterly pump tesdn g and a path exists at cold shutdowns or refuelint outages to perform a test of the pump under fu l or substantial flow conditions, the incrW interval is an acceptable alternadve to the Code requirements. During the deferred test, pump differendal pmssure, flow rate, and bearing vibradon measurements must be taken and during the quanarly testing at least pump differential presswe and vibration must be measwed.

Referring to the licensee's request, it appears that although there is an instrumened Dow path during the quanerly testing, the licensee will only measure flowrate quarterly to verify that k is greater than the minimum required. Plowrate will not be evaluated against a reference value and the licensee will not take any conective actions based on the Dowrate. OMa 1988 Part 6, requires -

Dowrat to be measured and concedve actions taken quaneriy if the measured value is in the alert or required action range. In the requests' basis, the licaneae states that there is a concern for poundalpemp damageif the ps are throtded during minimum flow conditions. De subject mmps are tested using a t' res stance test circuit. The Code,15.2(c), addresses dds situadon.

.e., where the systesn resistance cannot be varied, and requires that flowrate and pressure be determined and compared to their respective reference values. Derefore, no throtding would be required.

Ahhough, Generic letter 89-04, Posidon 9 only addresses the situation where the minimum Dow line is uninstrumented, as discussed in NUREG-1482 Appendix A Question Group 48, the NRC would prefer a more comprehensive est performed at some reduced test frequency rather than relying only on the minimum Gow test that is performed quarterly. Tests employms the minimum flow recirculation lines " produce data of marginal value and provide little confidence in the continued operability of the pump." De pumps are operated in that region of the pump curve near shutoff head conditions where large changes in flow are associated with small changes in differential pressure, and deviations in pump hydmulic parameters may go undetected. Plow meassements taken under these operaung conditions are not m=ily a meaningful est for mmp operational readiness because the test flow rae is a small fracdon of rated pump flow.

V.wsignent of pressure and vibration quanerly should provide adec tuate indication of these standby pumps' operational readiness quanerly, with a more compre sensive test at full flow condinons performed at cold shutdowns or refueling. De licensee proposed alternative to measme and take concedve action quanerly on differential pressure and vibration, and then at cold shutdowns or refueling, measure and take conective action on flow rate, as well as differendal pressee and vibration, would provide an acceptable level of quality and safety. *Ilarefore,it is maandad that the altemauve be authorized in accordance with 10CFR50.55a(a)(3)(i).

De 1994 Addenda of the ASME OM Code has not yet been endorsed by the NRC in the reguladons, however,it should be noted that the comprehensive pump test revision included in the 1994 Addands of the OM Code requires standby centrifugal pumps to have their speed and Dowrat or differendal pressure measured quarterly; and speed, flowrate, differential pressure, and vibradon measured every two years. Pa. lated to this revision are more restrictive p**=

crheria and instrument accuracy requuements.

When test mrarneters are in the alert range, the Code requires the test frequency to be doubled.

His incluc es pump testing perfonned dunng cold shutdowns or refueling outages. De licenseo 3

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is referred to Reference 14 Item 3.3.5, re garding the NRC's recommendation on performance of corrective action when pumps are in the a;ert range during the test at refueling.

2.1.2 Relief Request PR 04, HPSI Pumps ReliefRequest: The licensee requests relief from the requirements of the OMa-19g8, Part 6,15.1 and 5.2(c) which requires flowrate and pressure to be determined and compared to their respecdve reference values nominally every three months, where system resistance cannot be varied.

i Propossd Alternate Testing: De B~a= has proposed to compare measumments of pressure and vibration to their reference values quarterly. F]owratie will only be verified to be greater than the minimum flow requirement. During testing performed at cold shutdowns oriefueling; pressure, Dowrate, and vibration will be recorded and evaluated in accordance with 15.2(b).

Ikensee's Basis)br Relief: "During quarterly testing of the HPSI Pumps, the pumps cannot develop sufficient discharge pressure to overcome RCS pressure and allow flow throuJ the h

safety injection line. Hus, d uring quarterly testing of the HPSI pumps, flow is routed through a minimum flow recirculadon line retuming boric acid solution to the refueling water tanks. His recirculation Dowpath is capable of passing a Dowrate somewhat less than 10 percent of that at the pump design operstingpoint. A flow instmment is installed on this recirculation piping; however, there is concern regarc mg the practice of throttling under n.inimuin flow conditions with the potential for causing pump damage. In addition, hydraulic pump test data at or near a pump's shutoff head provides little information as to the meanM condition of a pump.

During cold shutdown conditions, full flow operation of the HPSI pumps to the RCS is restricted to preclude RCS system pmssure transients due to mass addition

• hat could result in eMag the pressure-temperature limits specified in the Technical Specifications (LTOP), unless the RCS is de-pressurized and the pressuruer manway is rernoved. However, under certain circumstances it is possible to line-up the HPSI pumps so that they take their suction from the RCS to preclude mass addition and a resulting pressure tranniant.

NRC Generic Letter 89-04, Position 9, (Reference 2.7), allows elimination of minimum flow test line flowrate measurements providing insenice tests are performed during cold shutdowns or refueling under full or substantial flow conditions where pump flowrate is recorded and evaluated.

he proposed altemale testing is consistent with the philosophy and the intent of Position 9 "

Evaluarion: It is impractical to test the high pressure safety injection (HPSI) pumps at full flow during operation bacause the head produced by these pumps cannot overcome the : tactor coolant sy ure. Dese pumps can only be tested dunng operation utilizing a sninimum Dow 4

In Generic Letter 89 04, Position 9, the NRC determined that in cases where flow can only be established through a non-instmmented minimum flow path during quarterly pump testinJ and a path exists at cold shutdowns or iefueling outages to perform a test of the pump under fu'l or substantial flow conditions, the increased interval is an acceptable alternative to the Code requirements. During the deferred test, pump differential pressure, flow rate, snd bearing vibration measurernents must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.

Referring to the limaw's request,it appears that although there is an instrumented Dow path during the quarterly testing, the U~aw will only measure flowrate quarterly to verify that it is greater than the minimum required. Flowrate will not be evaluated against t eference value and 4

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the licensee will not take any corrective actions based on the Dowrate. OMa.1988 Pan 6, requires flowrate to be measured and conective actions taken quarterly if the measured value is in the alert or required action range. In the requests' basis, the licensee states that there is a concem for pc:ential pump damage if the pumps are thrcttled during minimum flow conditions, ne subject aumps are tested using a fixed resistance test circuit. De Code,15.2(c), addresses this situation, 2., where the sy: tem res! stance cannot be varied, and requires that flowrate and pressure be determined and compared to their respective reference values. Therefore, no throttling would be required.

Although, Generic letter 89-04, Position 9 only addresses the situation where the minimum flow line is uninstrumuted, as discussed in NUREG-1482, Appendix A, Question Group 48, the NRC would prefer a more comprehensive test performed at some reduced test frequency rather than relying only on the minimum flow test that is performed quarterly. Tests employmg the minimum flow recirculation lines " produce data of marginal value and provide little cnaMwe in the continued operability of the pump." He pumps are operated in that region of the pump curve near shutoff heed conditions where large changes in flow are nW4 with small changes in differential pressure, and deviations in pump hydraulic parameters may go undetected. Flow measurements taken under these operatmg conditions are not necessarily a meaningful test for pump operational readiness because the test flow rate is a small fraction of rated pump flow.

Measurement of pressure and vibration quarterly should provide adec unte indication of these standby pumps' operational readiness quarterly, with a more compreiensive test at full flos conditions performed at cold shutdowns or refueling. De licensee proposed alternative tr measum anj take corrective action quarterly on differential pressure and vibration, and then at cold shutdowns or refueling, measure and take corrective action on flow rate, as well as differential pressure and vibration, would provide an acceptable level of quality and safety. Therefore,it is recommended that the altemative be authorized in ac.:ordance with 10CFRSO.55a(a)(3)(i).

De 1994 Addenda of the ASME OM Code has not yet been endorsed by the NRC in the regulations, however, it should be noted that the comprehensive pump test revision included in the 1994 Addenda of the OM Code requires standby centrifugal pumps to have their speed and flowrate or differential pressure measured quarterly; and speed, flowrate, differential pressure, and vibration measured every two years. Related to this revision are more restrictive acceptance criteria and instmment accuracy requirements.

When test aarameters are in the alert range, the Code requires the test frequency to be doubled.

His incluces pump testing performed during cold shutdowns or refueling outages, ne licensee is refened to Reference 14, Item 3.3.5, regarding the NRC's recommendation on performance of cornetive action when pumps are in the alen range during the test at efueling.

2.1.3 Relief Request PR-06, Containmtnt Spray Pumps ReflefRequest? The licensee requests relief from the requirements of the OMa-1988, Part 6,15.1 and 5.2(c) which requires flowrate and pressure to be determined and compared to their respective reference values nominally every three months, wir~ system resistance cannot be varied.

Proposed Altemate Testing: Helicensee has proposed to com measurements of pressure and vibration to their reference values quarterly. Flowrate will on1 be verified to be greaer than the minimum flow requirement. During testing performed at col shutdowns or refueling, pressure, flowrate, and vibration will be recorded and evaluated in accordance with 15.2(b).

Ilcensee's Basisfor Relief "During quarterly testing of the containment spray pum?s, flow is routed through a minimum flow recirculation line retuming borated water to the refue ing water 5

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tank (RWT)to avoid ping wate; through the spray headers and sp

' g down containment with barated water. Nrecuculation flowpath is capaoie of passing a f wrate approximately 3 l

percent of that at thepump 6esign operating point. A flow instrument is installed on this recirculation piping however, there is concem regarding the practice of throttling under minimum flow conditions with the potential for causing pump damage. In addition, hydraulic pump test a

data at or near a pump's shutoff hand provides dttle infonnation as to the mechanical condition of a i

Pump, I'

NRC Generic letter 89 04, Position 9, (Reference 2.7), allows alimlantion of minimum flow test line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling under full or substetial flow conditions where pump flowrate is recorded and evaluated.

De proposed alternate esting is consistent with the philosophy and the intent of Position 9.

p requ it for the running LPSI pin line-up.Yowever, ires substitutinfow is approx!==iaty 30[gp Performing full-flow estinf)of a CJ normal SDC l

the shutdown cooling (SD i

and a CS pump provides only approximately 1500 gpm. Therefore, this test can only be safely performed after enough time has elapsed since shutdown to allow the decay heat rate to substantially riimtalah Dese pumpa are standby pumps and lit:le degradation is expected with respect to hydraulic performance during operational periods when the pumps are idle. Hus, the attemate testing will provide adequate monitoring of these pumps with respect to the applicable Coe requirements to ensure continued operability and availability for accident mitigation."

Ewduanors: It is impactical to test the containment y(CS) pumps at full-flow during operation because th a would require cpraying down t containment with borated water. Dese j

pumps can only be ested duting operanon utilizing a minimum 11< w recirculatic.n line.

l In Generic letter 89 04, Position 9, the NRC determined that in cases where flow can caly be established through a non-instrumented minimum flow path during quarterly pump tesdn and a path exists at cold shutdowns or refue' ting outages to perform a test of the pump under fr.1 or substantial flow conditions, the increased interval is an acceptable altetnative to the Code requirements. During the defened test, pump differential pressure, fiow rate, and bearing vibution measurements must be taken and during the quarterly testing at least pump differential l

pressu:e and vibration must be measured.

i Referring to the licensee's request, it appears that althwgh there is an instrumented flow path during the quanerly testirg, the tieaa-will only measure flowrate quarterly to verify that it is greater than the mmimum required. Flowrate will not be evaluated against a referena value and i

the Lie =aa will not take any conective actions based on the flowrate. OMa-1988 Part 6, requires i

flowrate to be measured and conective actions taken quarterly if the measured value is in the alert or required action range. In the requests' basis, the licensee states that there is a concem for potential pump damageif the

'ups are throttled duth g minimum flow conditions. De subject mmps are tested using a f' resistance est circuit. The Code,15.2(c), addresses this situation,

e., where the system resistance cannot be varied, and requires that flowrate and pressure be determined and compared to their respective reference values. Derefore, no throttling would be seguired.

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Although, Generic letter 89 04, Position 9 only addresses the situation where the trinimum flow line is uninstrumented, as ri!=~~4 in NUREG-1482, Appendix A, Question Group 48, the NRC would prefer a more comprehensive test perfonned at some reduced test frequency rather l

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than relyirg only on f ninimum flow test that is performed quarterly. Tests employing the minimum flow recuetuation lines "pmduce data of marginal value and provide lin:e eM*nce in the continued operability of the pump." he pumps are operated in that region of the pump curve near shutoff head conditions where large changes in flow am associated with small changes in differential pressure, and deviations in pump hydraulic parameters may go undetected. Flow measurements taken under these operatmg conditions are not necessarily a meaningful test for pump operational readiness h:cause the test flow rate is a small fraction of rated pump flow.

Measurement of pressure and vibration quarterly should provide adecluste indication of these standby pumps' operational readiness quarterly, with a more compre sensive test ct full flow conditions performed at cold shutdowns or refueling. He licensee proposed altemative to

.:neasure and take corrective action quarterly on differential pressure and vibration, and then at cold shutdowns or refueling measure and take corrective action on flow rate, n well as differeatial pressure and vibration, would provide an acceptable level of quality and safety. Derefore,it is recommended that the altemative be authodzed in accordance with 10CFR50.55a(a)(3)(i),

s De 1994 Addenda of the ASME OM Code has not yet been endorsed by the NRC in the regulations, however,it should be noted that the comprehensive pump test re d.. icludedin the 1994 Addenda of the OM Code requires standby centrifugal pumps to have theu.ged and Dowrate or differential pressure measured quarterly; and speed, flowrate, differential pressure, and vibration measured every two years. Related to this revision are more restrictive acceptance criteria and instmment accuracy requuements.

When test carameters are in the alert range, the Code requires the test frequency to be doubled.

His inclucies pump testing performed during cold shutdowns or refuelinb outages he licensee is refeard to Reference 14, Item 33.5, regarding the NRC's recommendation on performance of corrective action when pumps are in the alert range during the test at refueling.

2.2 Auxiliary Feedwater Pumps 2.2.1 Relief Request PR-02, Steam Driven AFW Pumps ReflefRsquest: ne licensee requests relief fmm the requirements of the OMa-1988, Part 6,15.1 and 5.2(c) which requires flowrate and pressure to be determined and compared to their respective reference values nominally every three months, where system resistance cannot be varied.

Proposed Altemate Testing: he licensee has proposed to com

' measurements of pressure and vibration to their reference values quarterly. Flowrate will o be verified to be greater than the minimum Dow requirement. During testing performed at col shutdowns or refueling; pressure, Dowrate, and vibration will be recorded and evalced un accordance with 15.2(b).

Licensee's BasisforRelief: " Full or substantial flow testing of these pumps is not practical during plant operation at power due to the potential for thermal shock of the steam gercrator nozzles or intemals. Rus, during quarter y testing of the AFW pumps, flow is routed through a minimum flow recirculation line returning condensate to the cond ensate storage tank and the respweve munp suction line. His recirculation flowpath is capable of passing a flowrate somewhat ess than 10 pacent of that at the pump design operating point. A flow instrumentis however, there is concem regarding the practice of throttling installed on this recirculation piping;h the potential for causing pump damage. In addition, under minimum flow enditions wit hydraulic oump test data at or near a pump's shutoff head provides little information as to the mechanicalcondition of apump, i

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During cold shutdown conditions steam may or may not be available for turbine operation depending on the circumstances of the cold shutdown. It is e.ot desirable to use auxiliarf steam for this purpose.

MRC Generic Letter 89 04, Position 9 (Reference 2.7), allows elimination of minimum Tw test line flowrate measurements providing inservice tests are performed during cold shutdov tefueling under full or substantial flow conditions where pump flowrate is ocorded and ev.aunted.

Ibe proposed alterns e testing is consistent with the philosophy and the intent of Position 9.

Dese pumps are standby pumps and little degradation is expected with respect to hydraulic performance during operational periods when the pumps are idle. Hus, the alternate testing will provide adequate monitoring of these pumps with res to the applicable Code requirements to ensure continued operability and availability for acci t mitigation."

Emfuadont It is impractical to test the auxiliary feedwater (AFW) ?urrps at full flow during operation because of the potential for thermal shock and damage to t w steam generator nozzles and reactor intemals. Dese pumps can only Le tested during operation utilizing a rninimum flow recirculation line.

In Generic Letter 89 04, Position 9, the NRC determined that in cases where Dow can only be established through a non instrumented minimum flow pau during quarterly pump testing and a path exists at cold shutdowns or iefueling outeges to perform a test of the pump under full or substantial flow conditions, the increased interval is an acceptable altemative to the Code requirements. During the defened test, pump differential pressure, flow rate, and bearing vibration mecsurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.

Referring to the licensee's request, it appean that ahhough there is an instrumented flow path during the quarterly testing, the licensee will only measure flowrate quarterly to verify that it is greater than the mirumum requhed. Flowrate wi'l not be evaluated against a reference value and the licensee will not take any corrective actions based on the flowrate. OMa-1988 Part 6, requires flowrate to be measured and conective actions taken quarterly if the measured value is in the alert or required action range. In the requests' basis, the licensee states that there is a concem for potential pump damage if the pumps are throttled during minimum flow conditions. De subject

? umps are tested using a fixed resistance test ciscuit. De Code,15.2(c), addresses this situation, 2., where the system resistance cannot be varied, and requires that flowrate and pressure be determined and compared to thelirespective reference values. Derefore, no throttling would be required.

Although, Generic Lee.er 89 04, Position 9 only addresses the situation where the minimum flow line is uninstrumt.nted, as discussed in NUREG-1482, Appendix A, Question Group 48, the NRC would prefer a more comprehensive test performed at some reduced test frequency rather than relying only on the minimum flow test that is performed quarterly. Tests employing the minimum Gow recirculation lines " produce data of rnarginal value and provide little confidence in the continued operability of the pump." he pumps are operated in that region of the pump curve near shutoff head conditions where large changes m flow are associated with small changes in differential pressure, and deviations in pump hy,draulic parameters may go undetected. Flow measurements taken under these operatmg conditions are not necessarily a meaningful test for pump operational readiness because the test Dow rate is a small fraction of rated pump flow.

Measurement of pressure and vibration quarterly should provide adecuate indicatiou of these standby pumps' operational readiness quarterly, with a more compre tensive test at full flow 8

i,

l conditions performed at cold shutdawns or refueling. De licensee proposed altemative to measure and take corrective action quarterly on differential p essure and vibration, and then at cold shutdowns or refueling, measure and take corrective setion on flow rate, as well as differential pressure and vibration, would provide an acceptable level of quality and safety. 'Iherefore, a is I

recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(i).

%e 1994 Addenda of the ASME OM Code has not yet been endorsed by the NRC in the regulations, however, it should be noted that the comprehensive pump test revision included in the 1994 Addenda of the OM Code requires standby centrifugal pumps to have their speed and flowrate or differential pressure measured quanerly; and speed, nowrate, differential pressure, and vibration measured every two years. Related to this revision are more restrictive acceptance criteria and insuument accuracy requirements.

When test ters are in the alert range, the Code requires the test frequency to be doubled.

Hisinclu pump testing performed during cold shutdowns a refueling outages. De licensee is referred to Reference 14, Item 3.3.5, re ganiing the NRC's recommendation on performance of corrective action when pumps are in the a' ert range during the test at refueling.

2.2.2 Relief Request PR 03, Motor Driven AFW Pumps ReliefRequest: he licensee requests relief from the requirements of the OMa-1988, Part 6,15.1 and 5.2(c) which requires flowrate and pressure to be determined and compared to their respective reference values neminally every three months, where system resistance cannot be varied.

Proposed Afternate Testing: he licensee has pmposed to com are measurements of pressure and vibration to their reference values quanerly. Eowrate will o be verified to be greater than the minimum flow requirement. During testing performed at col shutdowns or refueling; pressure, flowrate, and vibration will be recorded and evrJuated in accordance with 15.2(b).

Ucensee's Basisjbr Relief: " Full or substantial flow testing of these pumps is not praedcal during plant operation at power due to the potential for thermal shock of the steam generator nczzles or intemals. Rus, during quarter) y testing of the AFW pumps, flow is routed through a minimum flow recirculation line retuming condensate to the cond ensate storage tank and the respective ymp suction line. nis recirculation flowpath is capable of passing a flowrate somewhat ess than 10 yrcent of that at the pump design operating point. A flow instmmentis installed on this recircu ation pipinp however, there is concem regarding the practice of thmttling under minimum flow conditions with the p'otential for causing pump damage. In addition, hydraulic pump test data at or near a pmnp s shutoff head provides little information as to the mechanical condition of a pump.

NRC Generic I.etter 89-04, Position 9, (Reference 2.7), allows elimination of minimum flow test line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling under full or substantial flow conditions where pump flowrate is recorded and evaluated.

%c proposed alternate testing is consistent with the philosophy and the intent of Position 9.

Rcse pumps are standby pumps and little degradation is expected with respect to hydraulic performance during operanonal periods when the pumps are idle. Rus, the altemate testing will provide adequate monitoring of these pumps wiuh respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation "

9

Ewaluation: It is impractical to test these pumps at full-flow during operation becane of the potential for therrual shock and damage to the steam generator nozzles and reactor internals Rese pumps can only be tested during operation utilizing a minimum flow recirculation line.

In Generic Letter 8944, Position 9, the NRC determined that in cases where flow can only be established through a non-instrumented minimum flow path during quarterly pu'np testing and a path exists at cold shutdowns or refueling outages ta perform a test of the pump under full or substantial flow conditions, the increased interval is an acceptable alternative to the Code requirements. During the deferred test, pump differendal pressure, flow rate, r.nd bearing vibration measurements must be taken and during the quanerly testing at least pump differential pressure and vibration must be measured.

Referring to the licensee's request, it appears that shhough there is an instrumented Dow path during the quarterly testing, the licensee will only measure flowrate quarterly to verify that it is greater than the mmimum required. Flowrate will not be evaluated against a reference value and the licensee will not take any corrective actions based on the Dowrate. OMa-1988 Part 6, requires Dowrate to be measured and conective actions taken quarterly if the measured value is in the alert or required action range. In the requests' basis, the licenseo states that there is a concern for potential piunp damage if the pumps are throttled during minimum flow conditions. De subject oump; am tested using a fixed resistance :est circuit. He Code,15.2(c), addresses this situation,

..e., where the systern resistance cannot be varied, and requires that flowrate and pressure be determined and compared to their respective reference values, herefore, no throttling would be required.

Ahhough, Generic Letter 89-04, Position 9 only addresses the situation where the minimum Dow line is uninstrumenteJ, as discussed in NUREG 1482, Appendix A, Question Group 48, the NRC would prefer a more comprehensive test performed at some reduced test frequency rather han relying only on the minimum flow test that is performed quanerly. Tests employing the minimum flow recircult.: ion lines " produce data of marginal value and provide little emMnce in the continued operability of the pump." he pumps are operated in that region of the pump curve near shutoff head condit%ns where large changes in flow are associated with small changes in differential pressure, ano deviations in pump hydraulic parameters may go undetected. How measurements taken under these operatmg conditions are not necessarily a meaningful test for pump operational readiness because the test flow rate is a small fraction of rated pump flow.

Measurement of pressure and vibration quanerly should provide adecluate indication of these standby pumps' operational readirr.ss quarterly, with a more compre sensive test at full Dow conditions performed at cold shuthwns or refueling. De licensee proposed alternative to measure and take corrective action quarterly on differential pressure and vibration, and then at cold shutdowns or refueling, measure and take corrective action on flow rate, as well as differential pressure and vibration, would provide an acceptable level of quality and safety. Derefore, it is recommended that the allemative be authorized in accordince with 10CFR50.55a(a)(3)(i).

He 1994 Addenda of the ASME OM Code has not yet been endorsed by the NRC in the regulations, however, it should be noted that the comprehensive pump test revision included in the 1994 Addenda of the OM Code requires standby centrifugal pumps to have their speed and Dowrate or differential pressure measured quarterly; and speed, flowrate, differential pressure, and vibration measured every two years. Related to this revision are mom restrictive acceptance criteria and instrument accuracy requirements.

When test carameters are in the alert range, the Code requires the test frequency to be doubled.

His incluces pump testing performed during cold shutdowns or refueling outages. The licensee 10

j 4

l is refened to Reference 14. Item 3.3.5, re 'arding the NRC's recommendation on performance of l

conecdve action when pumps are in the aIert range during the test at refueling.

2.3 Charging Pumps i

2.3.1 Relief Request PR 05, Vibration Measurement Frequency Response Range 4eliefRequest: m licensee requests relief from the requirernt4ts of the OMa 1988, Part 6, 14.6.1.6, which tequires the frequency respnse range of the vibration measuring transducers and abeir re6dout system be fmrn one-third mmunum pump shaft rotational speed.

ProposedNiemase Tesdng: The licenae has proposed to use cunent instrumentadon with a i

frequency response range from 4 Hz.

1 licensee's BasirforRelief: "The rotational shaft speed of the char ging pumps is 209 rpm relating to a rotational frequency olapproximately 3.48 Hz. In order to satafy tae requirements of Pa apraph 4.6.1.6, a vibration measurement system capable of measuring vibradon to a lower i

liminns frequency of 1.16 Hz. would be required.

h instruments cunently being used at Calvert Cliffs have a lower fregeency limit for reliable, accurate measurement of 4 Hz. 'Ihis instrumentation is " state-of the art" industrial grade, high quality equipment. Satisfying the Code requirements with respect to frequency response would i

require the 9====y procurement of new and more sophisucated equipraent beyred that i

latanM by the Code.

Monitoring lower frequeneles (leas than rotational s

) is performed primarily for the ;nirpose of Mag oil whirl or whio in joumal bearings.

Calvert Cliffs charging pumps mam bearings use oil mist lubricated roller bearings that are not susceptible to the ci whip or whirl h

P ernnana i

1 Other conditions that could result in low frequency vibratian (less than shaft speed) are included in the general category of mechanical " rub" which is not conshiered to be significant from the aspect of pump degradacon. 'Ihus,it ern be deduced that the instrumentation currently in use is adequate i

for determining purnp degradation that may manifest itself in increased vibration.

In addidon to the ASME pump"tesdng, Calvert Cliffs also has implemented a " Rotating Machinery Vibration Monitoring Program that meludes periodic vibration monitorin,g of the charging pum ps.

'Ihis program is inclusive and encompasses a wider range of vibration ana'yses at several enuca1 pump and motor taratiana

• Ihe data derived from this expanded progmm along with the IST vibration data will provide a high degree of assurance that significant pump degrsdanon will not go undiscovered."

t l

LNaluaaion: OMa-1988, Part 6 requires that the frequency response range of the vibration maamring transducers e nd their readout system be from one bird minimurn pump speed to at least 1000 Hz.Section XI previously required that the frequency response range of the readout system be imm one-half minimum speed to at least maximum pump shaft rotational speed (IWP-4520(b)).- 'Ihis change was made by the ASME OM Code Committees in order ta more adequately envelop all potential noise contributors that could indicate degradation. 'Ibe lower limit of the range is to allow for detection of problems such as bearing oil whirl and im of bearings.

b 1

11 i

4 l

e operate at very low speeds (i.e., at 3.48 Hz). The licensee has proposed to

'Ibe chargg pum continue g vi on instrumentation with a lower frequency limit of 4 Hz. 'this instrumentation cannot measure subharmonic vibratien or vibration at the mnning speed for the charging pumps.

'Ihe neciprocating charging pumps have oil-mist lubricated roller main bearings. As discussed by the limam these bearm3s are not subject to oil whip or whirl pbenomena. Rotor or seal rub is another type of problem found at subharmonic vibrataon levels. Additionally, loose seals and bearings, bearing and coupling damage, poor shrink fit, torsional critical, and bearing-support sesonence are also indicated m subharmonic levels. Problems such as unbaia

. loose unpeller, bent shaft, bearings accentric, and shaft out of round may be detected at immp running speed (Ref.16). 'Ihe licensee should ensure that the problems detected at runnng speed and at subharmonic levels are adequately==aa==ad usmg the proposed instrumentation. Consultadon with the pump manufacturer would provide additional basis for this sequest.

'Ihe licensee has stated that this instrumentation is " state of the art" and that compliance with the Code would require unn-y procurement of equipment beyond that intended by the Code.

The licensee has not provided sufficient information on the hardship or unusual difficulty associated with complying with the Code, and has not demonstrated that there is not a compensating increase in the level of safety. Numerous utilities have gxur.d and utilize vibration measuroment equipment that have frequency response ranges down to 1.54 bz. (e.g.,

Monticello). It appears, based on the licensee's previous IST Program submittal (Ref.15), which s instrumentation reads accurately from 3 hr, that the licer.aec has, states that the chargmg pump'd the vibration instrumentation. 'Iberefore, it is sw=n~adad that since thelastinterval, replace relief be denied. The licensee should procure new equipment that meets the Code requirennents, or revise and resubmit the relief request to addreas the specific hardship and how the proposed alternative provides an acceptable level of safety.

'the licensee mendons in the basis that they have implemented a ' Rotating mew ~y Vibration Monitoring Prr gram" that includes periodic vibration monitoring of the charging pumps. '!he licensee states that "this program is sclusive and encompasses a wider range of vibration analyses at several critical pump and motor locations." 'Ihe licensee, however, dves not discuss what range of frequency this program encompasses and whether spectral analysis is used.

Im:nedite compliance would result in a hardship because of the time required to procure new instrumentation. 'Iherefore,it is recommended that the altemate proposed byihe icensee be authorized,in accordance with 10CFR50.55a(s)(3)(ii), for an interim period of one year to allcw the licensee either to procure new equipment that meets the Code secluvements or revise and resubmit the velief request. 'Ihe proposed testing provides reasonab e assurance of operational acadiness of the chargmg pumps in the interi:n period because these normally operaung pumps are tested quarterly and the majority of the modes of pump degradation could be detected with existing vibration instrumentation, except for the subharmonic and first harmonic modes.

2.4 Saltwater Pumps 2.4.1 Relief Request PR-08, Measuremt.nt of Vibration rand Hydraulle Performance Limits Reh'efRequest: The licensee requests relief from the sequirements of OMa-1988, Part 6,14.6.4 and 5.2(d), which require vibration measurements to be taken on the upper motor hwring housing for venical line shaft pumps and which specify the hydraulic limits at which correr c<e action is required.

12

4 1

4 Preposed Ahernase Testing: 'Ibe licensre has proposed to use the requirements for centrifugal

> umps to measure vibration,i.e., on each accessible pump bearing housing and pump thmst i

maring housing, and to establish the hydmulle performance limits.

i aragraph b9% meet the strict definition of a vertical line sh Ucer.see's Basis rRe "Ihese re such a pump is descdbed as "a vertically suspen j

stated in 1482 where the pump driver and pumping element are connected by a line shaft within an j

pump,ing column which contains the pump bearings, mandng ump bearing vibration enclos measurements impracticable" with the ex on of theim cahty of measuring pump 1.

vibration. 'Ihese s are mountedin a itlocated the intake stmeture with pump 4

i orientatica such that take suction throus the intake structure floor with the drive motor mounted on an elevated above the pump and connected to the purnp via a vertical shaft.

'Ihis design allows pump operation in the event of flooding.

j NUREG 1482 states that the basis for the more restrictive hydraulic acceptance criteria for vertical i

line shaft pumps it due to "mherent deficiencies in vibmtion testing." In this case there are no restrictions to performing vibration measurements as assumed by the Code for normal pamo i

configuration (nonvertical line shaft pumps). Thus, with the ability to adequately momtor pump vibradon,it is not a~*

y to apply the more restrictive hydraulic acceptance enteria. Clearly, 4

the more resnictive limits are not required in this case to meet the Code requirement of assessing pump operational raadi=="

I l

l Evaluadon: Section XI previously established the same hydraulic and mechanical performance l

limits for both cenulfugal and positive displacement pumps. Additionally,Section XI did not l

specifically addreas the vibration measurement location for vert' cal line shaft (VIE)

'Ihe i

ASME OM Code Commluce revised the pump requirements in OMa 1988, Part 6.

specifically addresses the measurement of V13 pump vibration. As discussed by Mr. J. "

in NUREGCP4111 (Ref.17), vibration tor these pumps is required to be measured motor bearing housing, since "the only accessit,le beanns for this type of pump is or, motor bearing, as the pump bearings a:e generally under water." Specific, more stringent, hydraulic limits we:e put into Part 6 for VLS pumps since "there are inherent deficiencies in vibration testing, and degradation will be identified sooner through changes in hydraulic parameters." It appears that the Code rec uirements for VLS pumps were established on the basis that the pump beanngs were not accessib e and that the motor bearings on which vibration measurernents are taken we:e located at a significant distance from the impellers and the pump bearings. In Question 14 in the Panel Discussion found on page 134 of NUREG/CP 0111, one of the panelist states that the more stringent criteria for VLS pumps whose casings are not submerged and are accessible for vibranon monitoring would not apply since the inethod of j

vibration rneasurement is essentially the same as centrifugal pumps. However, the p==lia states that it would have to t e evaluated on a case-by case basis. Tz ASME OM Code Committees have recently undertaken review of this issue of accessibilityrmaccessibility in VLS pumps.

i Based on the fact that the pump bearings are accessible for vibration measurement in these vertical line shaft centrifugal pumps and that these readings would provide ' formation on the m~+**al degradation of the pum ) equivalent to centrifup pumps, and conddering that imposing the sencier vertical line shad pump hydraulic critena may result in these pumps entering the alert and required action range more frequently, which would result in a hardship without a compensating i

increase in the level of quality or safety, it is recommended that the licensee's proposal to take l

measurements and corrective actions based on the requirements for centrifugsi pumps be authoriacd in accordance with 10CFR50.55a(a)(3)(ii).

13 m

Re#efRequest: de uest PR 09, Vibration Measurement Frequency Res(Part 2.4.2 Relief R nse Range licensee requests relief from the requirements of t se OMa-198 14.6.1.6, which requires the frequency response range of the vibration measuring transducers and their readout system be from one-third mirumum pump shaft rotational speed to at least 1000 henz (Hz).

4 i

i Proposed Aherrure Tesang: 'the licensee has proposed to use cunent instru=>aMon with a j

frequency response range from 4 Hr.

IJeansee's BasisjbrRe#ef: "Ihe speed of the saltwater cooling (SW) pumps is approximately 585 rpm relating to a rotauonal frequency of 9.75 Hz. In order to sathfy the requuements of l

Paragraph 4.6.1.6, a vibration measurement spiem capable of measuring vibration to a lower limiting frequency of 3.25 Hz. would be requued.

'Ihe instruments cunently being used at Calvert Cliffs have a lower frequency limit for reliable, accurate measurement of 4 Hz. This instrumentation is " state-of the art" industrial grade, high quality equipment. Satisfying the Code requirements with respect to frequency response would aquire the uruemry pmeurement of new and more sophisucated equipment beyond that i

intended by the Code.

Monitoring lower frequencies (less than rotational speed) is performed primarily for the purpose i

of detecting oil whirl or whip in journal bearings. Other conditions that could result in low l

frequency vibration (less than shaft speed) are included in the general category of mechanical

" rub" which is not considered to be sijnificant from the aspect of purip degradation. These pumps cre provided with grease lubricated roler bearings that are not susceptible to oil-relatui vibration problems.

Vibration measurements taken on theae ps with instruments capable of monitoring freqwadu

~

to 4 Hz. will satisfy the intent of the Co that of reading vibration at frequencies "just" less thaa L

one-half the rotating figersy.

I In addition to the ASME pump" testing, Calvert Cliffs also has implemented a " Rotating Mal =y Vibration Monitoring Program that meludes periodic vibration monitoring of the saltwater pumps. Ihis program is inclusive and encompasses a wider range of vibration analyses at several l

l critical pump and motorlocations."

Ewaluation: 'Ihe saltwater pumps cperate at low speeds (i.e., at 9.75 Hz). OMa 1988 Part 6 -

requires that the frequency response range of the vibration measuring transducers and their readout system to be from one third ~nimum pump speed to at least 1000 Hz.Section XI previously required that the frequency response range of the readout system be from one-half mmimum speed i

to at least maximum pump shaft rotational speed. 'Ihis chan p was made by the ASME OM Code Corunittees in onier to more adec untely envelop all potentia, noise contributors that could indicate degradation. 'Ihe lower limit of tse range is to allow for detection of problems such as bearing oil whirl and looseness of bearings.

'Ibe sah water cooling pumps are vertically driven centrifugal pumps that have grease lubricated roller bearinga. As discussed by the licensee, these bearings are not subj*ect to oil whip or whirl phenomena. Rotor or seal rub is another type of problem found at subharmonic vibration levels.

Additionally, loose seals and bearings, bearing and coupling damage, poor shrink 6t, torsional critical, and bearing-support resonance are also indicated in subhannoruc levels (Ref.16). The i

14 i

~y

1 H== bas proposed to continue using vibration instrumentation with a lower frequen limit of-4 Hz. His instrument would cover vibration frequencies down to 41% of runnm

. De

- licensee's proposed alternative wculd prodde adequate indication of subhannorde problems.

Req uiring compliance with the Cede requirements (i.e.,

ulting the purchase and use of new pment) woulo present a bdship without a compensa increase in the level of uality or i

. Derefore, it is recomaW that the alternative be approved in accordance wa 1

.55a(s)(3Xil).

3.0 VALVE IST PROGRAM RELIEF REQUESTS j

in accordance with 950.55a, BOE has submitted twelve relief requests (Request VR-04 was -

withdrawn). Ten requests are for specific and generic valves at the Calvert Cliffs Plant that are i

subject to inservice testing under the requirements of ASME Section XI. Relief VR-06 addresses valves that are not required to achieve a safe shutdown. Relief vest

-12 addresses non ASME Code Class valves. As discussed in NUREG-1482, on 2.2, reliefis not required for plants licensed with hot standby as the safe shutdown condition, or for valves that are non ASME Code Class. De remainin ten relief req uests have been reviewed to verify their l

technical be '.s and determine their ility. Relief Requests VR-05,10 and 11 are approved in accordance with Generic Letter 89

, Position 2. De seven relief requests that are not i

authorized by Generic Leuer 89-04 are summarized below, along with the technical evaluation by

BNL, 3.1 Safety and Relief Valves 3.1.1 Relief Request VR 01, Test Accumulators ReliefReguest: De licensee requests relief from the requirernents of the OM-1987, Part 1, j

18.1.2.2 which requims that a mmimum accumulator volume be used for set ure testing Class 2 and 3 safety and relief valves used for compressDie fluid service, than steam, and specifies the formula to calculate this minimum volume.

t l

Proposed Afrernare Tesang: he licensee has proposed to use the requirements in the 1990 Edition of the OM Code, including the 1994 Addenda, which requires the volume of the accumulator drum and the pressure source flow rate be sufncient to determine the valve set i

pressure.

l Ucensee's BasisforRelief: "De accumulator volume uirementis not required for simple determination of the valve set pressure, nis was reco by the ASME Code Comminee and corrected in more recent versions of the OM Code."

Evolution: OM-1987, Part 1,18.1.2.2 requires the set pm est accumulator have a minimum volume ual to the valve capacity (Cubic fee */second) multiplied by the time open (seconds),

divided b 10. Unlike ASME Section III, Part I and the O!W Code do not requue the verification 4

of valve capacity, ont the set pressure. Based on an inarpretation submitted to the ASME OM Committee concernin the requirements of Part 1, the committee reviewed the requirements of 18.1.2.2 and its basis.1he Code Committee considered the requirements to be overly 4

conservative and na-* ily prescriptive, he Code was revised in the 1994 Addenda (OMc) to delete the prescri ve requuements and to require that the volume and the pas.we source flow rate be suiBeie it to termine the valve set pressure. Compliance with the Part I requirements would require a calculation for each valve and possibly requiring resizing the accumulator drurn.

De use of the OM Code, OMc-1994,118.1.2(b) provides an acceptable means of performing set a

i 15

Attachmerd 1-S..wnary of Pump and Valve Relief Requests Calvert CMfs Nuclear Power Plant Relief 711R Code Requirement Equipment Proposed Alternate Method ofTesting NRC Actio.:

Request No.

Section Identification Part 10,14.2.1, Saltwater air Exercise valves during refueling.

Approval not required.

VR-12 Test frequency cominas Valves are not ASME to Instrument Code Class.

Air manual valves, I-IA-6 728,2-iA-314,317,and 1110 VR-13 3.1.4 Part 1,18.1.1.4, Pressurizer Test valves at normal operating Alternate approved in Test insulation Safety conditions valve body temperature accordance with requirements Valves,1(2)-

profile without valve insulation.

10CFR50.55a(aX3Xi),

RC-200 and with prmisions.

l 201-RV I

L

+s l

pressure tests. Derefore,it is recommended that the mw's' altemative be authorized in r

accordance with 10CFR50.55a(a)(3)(i).

7 3.1.2 Relief Request VR-02, Thermal Equilibrium ReliefRequest: De liccam requests generic relief from the requirements of the OM 1937. Part 1.18.13.4 which requires that the test method be such that the temperature of the valve body be known and stabih' zed before commencing set pressure testin g, with no change in measured ternperature of more than 10 degree F in 30 mmutes for liquLd service valves.

he licensee has proposed to use the requirements in the 1995 Proposed Alternate Testing:ich does not require verification of thermal equilibrium for valves Edition of the OM Code wh g

are tested at ambient temperature using a test medium at ambient temperanue.

Ucentre's Basisfor Relief: "For testing under normal prevailing ainbient conditions with the test medium at approximately the same temperanut, the requirement for verifying temperature stability is inappropriate and an ineffective use of resources. There is little or no consequeme of any minor changes in ambient ternperature.

This has been identified by the OM 1 Code Working Group and the ASME Code Comn:ittees and is reflected in the latest version of the Code (OM Code-1995) Paragraphs I 8.1.2(d) and I l

8.13(d)."

Evaluathn: As discussed in NUREG 1482, Section 43.9, the clarification provided in the 1994 Adkeda to the 1990 OM Code (or 1995 Edition) conceming the uirement for thermal equilibrium for valves tested at ambient temperature uring a test

'um at ambient temperatu't,

)

mty be used without NRC approval; reliefis not required, ne licensee should, however, reference the uw of this position (i.e., NUREG-1482, Section 43.9) in the IST Program.

RcFefReque:r: % quest VR 03, Alternate Test Mediae licensee requests generic re 3.1.3 Relief Re e

1,18.1.2.1 and 8.13.1, which require safety and relief valves to be tested with their normal system operating fluid and temperature for which they are designed, and 18.1.1.1, which requires valves c esigned to operate on steam be tested with saturated steam. Altemate india may be used provided the requirements of183 are met.

De licensee has proposed to test these valves in accordance with Part Proposed Alternate Testkq:l be tested at ambient chop temperatures without a temperature 1,except that the valves wil correlation as required by183.

"These valves are nonnally installed on various systems throughout Ucensee's Basisfor Relief:ial variations in ambient conditions as well as system opemting the plant. Based on potent conditions,a discrete design /o g tem true cannot cally be determined for cach valve. Obviously, itis im cal to test valve at mul le operating conditions.

Based on input from valve manufacturers, typically safety valve setpoints vary inversely with t'e temperature of the valve. Thus it can be deduced that measuring a valve's setpoint at the lowest temperaune that a valve is expected to experience when its protection is required will ensure adequate protection at the elevated tempemtures. Clearly this is a conservative application of the Code requirement.

16 r

i

i

'Ihe only adverse concem is that of the potendal for pmmature lifting of a valve. Although this is of some limited operational concem, in no case does it pose a significant safety concern.

Evaluanon: OM Part 1,18.1.1.2 and 8.1.13 mquire valves to be tested with their normal system F

operatin i fluid and temperature for which they are designed, and 18.1.1.1 requires valves desipet to operate on steam be tested with saturated steam. Alternate media may be used, prtmded the requirernents of183 are met. Additionally, Part I requires the ambient temperature of the operating environment of the valve be simulated during the set pressure test. Ahernate ambient temperatures may be used, but the requirements of183.2 and 833 must be met. Part 1, i

183 squires the establishment of a correlation and certificatioa of the correlation procedure.

4 The licensee has requested generic relief. Generic relief from these requirements would not be appropriate. Each valve's application must be evaluated. 'Ihe request should identify the W test and design process and ambient ternperatures (or ranges of temperatures) of each valve. The li 'ensee states hapt)bviously, it is impractical to test the valve at multiple operating conditions."

l

- I. Is not obvious why it is irnpractical to test the valve at muldple operaung conditions or to develop a correlation for a number or range of operating conditions.

j

'Ibe licensee states that " based on input from valve manufacturers, typically safety valve setpoints vary inversely with the temperature of the valve." 'Ihis may be true for the majority of the valves, however, there are cases where e relationship is not valid. 'Ihe ASME OM Part 1 Working i

Group has recently reviewed 2 issue and could not validate this assumption based on input from i

at least one valve manufacturer. 'Ihe licensee should msum that this assumption is true for all the i

L valves (i.e., for each manufacturer, model, and whether the valve is insulated or not) that are the l

subjectof thisrequest.

I Additionally, the licensee has stated that premature lifting of a valve does not pose a significant safety concern. 'Ihe licensee should provide an evaluation of this concem for each valve. Each evaluation should specifically consider the integrity of the yessure retaining boundary that would 7

be violated if the valve orematurely lifted, the system's ma eup capability, and any other safety issues (e.g., the potential for overcoolire the RCS if the main steam safety valves were to prematurely lift). The Li~ a= should tiscuss the safety significance of each valve.

In conclusion, generic relief cannot be recommended. 'Ihe licensee should com ply with the Code l

requirements or resubmit the request provid!ng specific information dim =~I amve for each l

va ve. 'Ibe licensee is referred to Ref.14, Question 2.4.7.

3.1.4 Relief Request VR 13, Pressuriser Safety Valves ReliefRequest: The licensee requests relief from the requirements of the OM 1987, Part 1 18.1.1.4 which requires valves that are insulated in service to be insulated during testing.

7 i

edAhemare Tesang: The licensee has proposed to test these valves in a vendor testing lab vL ve body temperature profile a-*

y to simulate normal operating conditions. No i

at insuladon will be installed.

Ucasee's Basisjbr Relief: " Changes in safetyhelief valve body temperature can change the lift 4

setpoint mammed during inservice testing. Changes in ambient temperature or modifications to ia=1mian also may change the lift setpomt by virtue of the resulting effect on the valve body pewiv 'Ihe purpose of Paragraph 8.1.1.4 is to ensure the effect of temperature variations are minimbed. Requiring insulation to be installed during testing is clearly i:: tended to also ensure the valve body's temperature, and therefore its performance, is similar to snat under normal i

17 i

j l

?

t opemeing cir-M Calvert Cliffs its determined the normal +. erg temperature prorde for the pmasuriser safety valves by instrumcating each valve body at severa locations and acording empirical data during normal operadon.

4

1. A Recently, Calvert Cliffs commissioned esdng using the valves' actual operatinj temperature pmfde at a national vendor's tesdng facility to determine the impact of havmg the msulanon j

removed versus installed during testing of the pressurizer safety valves. *Ihis testing showed tiist pressuriser safety valves which have had their setpoints satisfactorily verified in-situ will perform i

i sadsfactorily two years later in a laboratory setting if the valve body s actual operadng tanperature j

profile is recreated. 'Ihe test was conduced using two valves adjusted to their respective setpoints j

(which differby only 65 psi).

i h first series of ests was performed with each valve uninsulated. Prior to setpoint esdng, each valve was thermally stabilized at the specified temperst.na prorde to match normal operating l'

naadidans 'Ihe valves performed within their as-found setpoint tolerance, f

'Ibe second series of tests was performed with each valve insulated (using the actual insuladon

. from the plant normally installed on each valve). Prior to setpoint testing, each valve was thermally stabilized. However, due to the test configuration, the valve could not be thermally stabilized at the actual opwating tem zrature prorde. Instead,it could only be stabilized at a higher l

temperature. The overad impact of t se higher temperatum prorde is that the lift pressure for the j

valves is lower than when at the correct temperature prorde. This is a non conservative enor

%=. if the valves were adjusted to lift at their operating setpoint under these conditions, they would then be set to lift by as much as approximately 2% high when returned to their normal plant

~

jnstalladan

'Ihe third series of tests was perfonned with each valve insulated and with the ambient temperature

[

being varied. 'Ibe variations in ambient temperatum had litde effect on the valve's lift pressure.

l Because of difierences in the test configuration and the normal plant configuration, the vendor was unable to stabilize the w.lves' temperature ?rorde when insulated consistent with the one =w mad l

for nonnal plant operadng conditions. Rat ser, the temperatures measured at all the points'being l-monitood, most notably the uppt and lower bonnet, were higher.

F l

• Ihe higher tem wrature profile for the insulated valves in the testing configuration w TJ l

t+:== when estalled in the plant, these valves are attached to lonJ runs of piping with numerous associated piping supports which serve as heat sinks for t te valves, but m the test facility these long runs of pipmg are no longer anached. In the plant, these heat sinks allow the valves to stabilize at a lower emperature prorde even when insulated, as cornpared to the i

temperature profiles when insulated in the vendor test facility. Additionally,dy t forced ventilation in the field increases the heat tansfer out of each valve bo i

l insulation for the same ambient tempetature what compared to the stagnant conditions present in the testconfiguration.

l In other words, the heat input and heat output of the insulated valves in a stagnant envirmment cannot be halannad in the testing facility until the valves are hot enough to create the necessary heat transfer rate through the insulation reeded to offset the heat input. Smce the heat transfer out of

(

the valve to the anschad piping is lost, moet heat output through the insulation is requu' ed. The effect is additiona'ly aggravated by the lack of forced ventilation. As a result, the valves stabilize at a high temperature and the lift pressure measured was lower (by as much as approximately 2%)

4 with the valves insulated and at these higher temperatures."

f 18 b

p i

).

Evolmadon: 'Ihe Code, Pan 1,18.1.1.1 requires valves that are designed to operate on steam to be set ure tested with saturated steam. Paragraph 8.1.1.4, requires that the test method shall be that the temperature of the valve body be known and stabilized before commencmg set pressure testin g. Valves that are insulated in service shall be insulated in like manner during be testing. Addit.onally,18.1.1.5 requims the ambient temperature of the operating environment simulated during the set pressure test. The Code does not reqaire the determination or replication of the normally operating valve body temperature >rofile, however,it appears that the intent of the Code is to require replication of the operating condtions during the test to the extent reasonable.

As stated by the Li-based on test results, the nonna! operating valve body temperature cannot be established in the test facility when testing using saturated steam at the normal operating tembmwe with the insulation installed due to the lack of adjacent heat sink ofa ower tempemture test media would re9uire a conelation. 'Ihe limie's proposal will i

sunulate the actual temperature profile expenenced during normal plant operation, and provides an alternate to the Code requirements. Compliance with the Code would cause the l

ts to be adjusted non conservatively. 'Ihe proposed alternative provides an acceptable level of ty and safety and it is recommended that the attemative be authorized in accordance with 1

.55a(a)(3)(i). The licensee should ensure that any modifications to the piping system or environmental systems (HVAC) are reviewed and evaluated to ensure that the temperature profib is not affected such that the testing performed would be invalid.

1 3.2 Containment Spray and Safety Indection Systern 7

3.2.1 Relief Request VR-07, SIT Discharge Check Valves ReuefRequest: 'Ihe licensee requests relief frorn t ie requirements of the OMa-1988, Part 10, t

i 14.3.2, which requires check vafves to be exercised nominally every three months, except as provided by 14.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.4.

ProposedNternate Tesang: The licensee has proposed to exercise these valves each refueling l

outage, using non-intrusive test methods to verify full stroke. If test results are inconclusive or the valve does not full stroke, di-mbly and inspection in accordance viith Generic Letter 89-l 04, Position 2 will be performed. Addidonally, sample disassembly and inspection may be used, l

in lieu of full stroke exercising using non-intrusives, to minimize radiation exposure when l

refueling outage conditions warrant, or when check valve maintenance is already planned.

I Ucearet's r Re#ef: "Ihese are simple check valves that have no extern'al means to exercise thern.

g them requires forcing water from the safety injection tar.ks to the reactor 4

coolant system.

nonnal operation, RCS pressure is higher than safety irijection tank -

we therefore, opening is not possible. Dunng cold shutdown periods, " dumping" a safety

.njection tank is also not practical due to the plant conditions and the extensive system parations j

required for the evolution. During refueling outages, it is possible to "dum >" each mjection tank to exerciseeach check valve. However, Dow indicanon is not availab e and full gn flow cannot be achieved due to the slow opening tirne of the S!T discharge MOV's. 'Iherefore, the ability of each check valve to full-stroke can only be confirmed using non-intrusive monitoring' 1

W ye (Due to their service conditions, these check valves cannot remain instnanented.)

Ewamimi: OM Part 10,14.3.2 requires check valves to be exercised quarterly. If full-stroke exercising during plant operation or cold shutdowns is impractical,it may be limited to full, stroke during afuelag outages. The licename has discussed how exercising during power operation is impractical due to the safety inje6..lon (SI) system pressure being lower than the RCS pressure.

19

l i

i Additiona3y, full-stroke exercising these valves during cold sh'utdowns is also impraedcal due to

[

the need to set up test equipment and the fact that the test could delay plant startup. Reliefis not required in order to defer testing to refueling outages based on the impracdcality of performing the test at power operadon and cold shutdowns.

i h 16-has propor using non-intrusive testing (NIT). Reliefis not required because this est method is consit ered an acceptable "oher positive means " in accordance with Part 10, 143.2.4(a). 'Ibe NIT must be repeatable and qualified, as discussed in Generic Imtter 89-04, Position 1. 'Ibe use of non intrusive test methods on each valve every refueling outage, as proposed by the licensee, is acceptable in accordance with the Cede. As discussed in NUREG-14s2, Socnon 4.1.2, check valves may also be tested using NIT on a sampling basis.

'Ibe NRC's position is that check valves should be tested with Dow, if praedcal (See discussion in Reference 14, Question 23.23). If tesdng with flow is impraedcal, disassembly and !==a~ sn is an acceptable altamative. If following the dump of the safety in'

'on tank (SIT),non-intrusive l

test data is inconclusive or the valve did not ful:y stroke open, tJy and la=ra tion would j

be an

• te corrective action, since refillina the SIT and performing a retest would be impractical on the extensive test set up anc the potential for delaying plant startup. 'Ihe vd ve would be required to be declared inoperable firrt if the valve failed to exhibit the required change of obturator posidon.

The tiaan-has also pmposed ' he use of sam ple disassembly and inspeedon in lieu of exercising t

l with Dow to minimize personnel exposure. T w use of disassembly and inspecuan l

interchangeably with NIT is not acceptable because the licensee may not be able to determine l

degradation given the extended test / inspection intervals. Additionally,it would appear that i

persanasi radiation exposure during valve disassembly and != Won would exceed any exposure related to the use of non-intrusive techniques. 'Ihe licensee would need to demonstrate on a valve f

specific basis the impractical condidon due to radiation m=% NUREG-1482, Seedon 2.5.1 provides guidance on what information should be providet Addidonally, the licensee has l

prtnosed sample disassembly and iaWon when check valve maintenance is already plumed.

Ja t ds case, testing with flow would not be impractical, and should be performed first.

Maintenance shou d not be considered a substitute for a Code required test. As discussed in L

NUREG-1482, Ap pendix A, Question Groups 11 and ' 4, disassembly and inspection is an option only where l ull stroke exercising cannot pracudy be performed by flow or by other ave means. 'Ibe licensee should perform exercising of these valves in axordance with the

'Ihe licensee's request to utilize sample disassembly and inspection is not authorized in accordance with Generic Letter 89-04, Position 2, unless testing with Dow is impractical *Ihe licensee would need to &-w==t the basis for the determination that using flow or other practical means is impractical. As discussed in NUREG 1482, Section 4.1.2, the use of non-intrusives is l

not mandated. However, the NRC encounges the use of these techniques, where Acel.

3.2.2 Relief Request VR 08, SIT and SI Pump Discharge Check Valves

. ReliefRequest: 'Ibe licensee requests relief from the requirements of the OMa-1988, Part 10, 143.2, which requues check vafves to be exercised nominally every three months, except as provided by 143.2.2,43.23,4.3.2.4, and 43.2.5.

Proposed Airemare Tesdag: 'Ihe licensee has proposed to exercise these valves each refueling 1

outage, using non-intrusive test methods to verify full stroke. If test results are inconclusive or the valve does not full stroke, dienwrnbly and inspection in accordance with Generic Letter 89-04, Position 2 will be performed. Additionally, sample disassembly and lampa-@n may be used.

l 20 L

5

~-,

in lieu of full-stroke exercising using non intrusives, to minimize radiation exposure when-refueling outage conditions warrant, or when check valve maintenance is already planned.

licensee's Basis r Relief: "Ihese are simple check valves that have no external means to exercise them.

' g them requires forcing water from the safety injection tanks to the macter coolant system.

uring normal operation RCS pressure is higher than safety injection tank aressure therefore, opening is not possible. Durmg cold shutdown periods, " dumping" a safety mjection tank is also not practical due to the plant conditions and the extensive system tions required for the evolution. During refueling outages,it is possible to " dump" each

• tion tank to exercise each check valve. However, flow indication is not availah e and full flow cannot be achieved due to the slow opening time of the SIT discharge MOV's. Herefore, the abili of each check valve to full-stroke can only be confirmed using non-intrusive monitoring Des.

Alternatively, these check valves may be full stroked using the discharge of a low pressure safety injection pump. However, since the check valves have no external position indication, verifying their full-stroke open and closed, still requires non intrusive monitoring techniques. Due to their service conditions, these valves cannot remain instmmented and it is not considered practical to instrument them during a cold shutdown paiod."

Evaluadon: OM Part 10,14.3.2 regt' ires check valves to be exercised quarterly. If full-stroke exercising during plant operation or cold shutdowns is impractical, it may be limited to full-stroke during refueling outages. The licernee has dimeA how exercising during power operation is im practical due to the safety injection systern pressure being lower than the RCS pressare.

Additionally, full stroke exercising these valves during cold shutdowns is also impractical due to the need to set up test equ!pment and the fact that the test could delay plant startup. Reliefis not required in order to defer testing to refueling outages based on the impracticality of performing the test at power operation and cold shutdowns.

The licensee has proposed using non intrusive testing (NIT) Reliefis not required kan-this test method is consid cred an acceptable "other positive means," in accordance with Part 10, 14.3.2.4(a). he NIT must be repeatable and qualified, as discussed in Generic Letter 89-04, Position 1. The use of non-intmsive test methods on each valve every refueling outage, as proposed by the licensee,is acceptable in accordance with the Code. As discussed in NUREG-1482, Section 4.1.2, check valves may also be tested using NIT on a sampling basis.

De NRC's position is that ch'eck valves should be tested with flow, if practical (See discussion in Reference 14, Question 2.3.23). If testing with flow is impractical, disassembly and inspection is an acceptable altemative. If following the dump of tne safety injection tank (SIT), non-intrusive test data is inconclusive or the valve did not full -stroke open, diutembly and inspection would be an appropriate conective action, since re the SIT and performing a retest would be impractical based on the extensive test set up an the potential for delaying plant startap. The valve would be required to be declared inoperable first if the valve failed to exhibit the required change of obturator position.

De licensee has also proposed the use of sample disassembly and inspection in lieu of exercising with flow to minimize personnel exposure, he use of disassembly and inspection interchangeably with NIT is not acceptable because the licensee may not be able to determine degradation given the extended test /inmection intervals. Additionally, it would appear that personnel radiation exposure during valve disassembly and inspection would exceed any exposure related to the use of non-intrusive techniques. he licewa would need to demonstrate on a valve 21

l specific bacis the impraedcal condidon due to radiation ex ;.osure. NiiREG 1482, Section 2.5.1 provides guidance on what infonnadon should be providet. Additionally, the licensee has propowl sample di-nbly and inspection when check valve maintenance is already v.anned.

a t ais case, testira with flow would not be impractical, and should be performed fimi.

Maintenance shou,d r ot be considered a substitute for a Code required test. As dheussed in NUREO 1482, Apiendix A, Question Groups 11 and 15, disassemh!y and inspection is an option only where h stroke exercising cannot practically be performed by flow or by other tive means. De licenace should perform exercising of thesewives in accordance with the

. De !W's request to utilize sample disassembly and inspection 4 not authorized in e

accordance with Generic letter 89 04. Position 2, un ss testing with flow is impractical. De licensee would need to document the basis for the determinadon that using flow or other practical means is impractical. As discussed in NUREO 1482, Seedon 4.1.2, the use of non.intrusives is not mandated. However, the NRC encourages 0.e use of these techrdques, where practical.

3.2.3 Relief Request VR 09, St PIVs ReliefRequest he licensee requesu relief frorn the rquirements of OMa 1988, Part 10, 14.2.2.3(a), which requirer Category A valves to be leak tested at least once every 2 years.

Proposed Alsemase Tesdnv %e licensee has proposed to test these valves on a schedule in accordance with the perfonnarsce hand requirements of 10CFR50, Appendix J. Option B. No addidons! testi2g will be performed.

Ucenste's Basisfbr Re'.*rft %akage testing of these valves for both pur>oses is done concurrently using the same p"rocedures und tie same acceptance critena. %:ently, BO&E has o >ted to conver6 to " Option B c'.he Appendix J Testing Program whereby valves tint have a h story of good performance with respect to their leak tight integrity, may be tested rat a frequency less than the two yetts required by Appeadix J and Part 10. The Part 10 requirements to continue te perform seat leakage tesdng at 2 year intervals for containment iroladon vdves which also provide ;: teactor coolant systern pressure isolation function would essentially eliminate the benefit of applying Option B to these vanes and would subject these valves to unnecessary leak testing even when they meet Option B criteria for extending the Appendix J testing frequency. (It should be noted that local leak rate testing the y valves requires a reduced RCS inventory condition.)

%c consequences of failure t'yross leakage) of one of these vdves is not significant fro:n the aspect of accident severity, he is tyco valve isolation between the L.PC1 piping and the reactor coolant systems. Note that these are gate valves that are typically not subject to catastrophic failure when statically closed.

Based on past performance of these valves and other issues discussed above, leakage tesdag of tulued by Option B is adequate to ensure the continued these valves at an extended frequer as operability and reliability of these v

EvalmN: De Code rec u:res leak testing of Categcry A valves, with leak 0,ht functioas besides containment isolat.on, at least once every two years. nc licensee has preposed testing these reactor coolant pressure isolation valves (PIVs) on a schedule in accordance with Appendix J. Opdon B. Appendix J, Option B allows Type C testing of containtnent isolation valves (CIVs) to be performance based. Regulatory Oulde 1.163 restricts Type C test 5g to a maximum interval of five yekts.

7Y Uo b requires that the test medium be soecified by the owner and arons requirements in hit 10,14.2.2.3(b)(4) for leakage tetts involving pressure diffe:entist i L ser than function

--__--.---m____

a i

i pressus differendals.Section XI, IWV 3423(f) >reviously a: lowed a cornistion to use an i

ahernam medium. However, the ASME OM Coc e Commitees deleted this opdon in Part 10, cidngin their white that cormlations were not supported by in. field test data. As dir:ussed l

l in Refonnoe 14, on 2.8.8, it is not acceptable to perform one test for a CIV, that is also a l

PN,using a ation for low pressure air to high pressure water.

l b licenses states that leakage tesdng of these valves, which provide isoladon between the reactor i

coolant and the shutdown cooling system, for both CW and PlV purposes is done concurantly using the eme procedures and the same acceptance criteria. In their response ts Generic Imiter 87 06 (Ref.18), the licensee committed to test these pressure isoladon volves using the local leak 4

rat test in accordance with 10CFR50 Appendix J each refueling outage and has_provided the acceptance criteria for each valve in accm, therefore no correlation is required. T w iloensee has 4

proposed testing the P!Vs in accordance with A dix J, i.e., with air or nitrogen at the calculated peak containment internal gare re to adesign basis accident.

i Tne Standard Technical S socificadons (Ref.19) require tesdng of P!Vs at least every 18 months, opened by Cow or exercised to ensure tight reseadng. performed on a typical refueling cycle. l m addition, tesdag must be The leakagelimit of 0.5 inch of hes to each va.ve, m basis or LCOis the to 5 spm maximum ap >intersystem LOCAs as a alealbat contrib nominalvalve diameter thatidentified pCantia 1975 Reactor Safety Stu to die risk of core melt, dominant accident sequeme in the intersystem L5CA category is the failure of the low pressure portion of the shutdown coolinj (SDC) system outside conminraant.

'!he 11aaaaae's Technical Specifications, however, do not f aclode requirements for PNs.

l l

• Ihe licensee has not discussed the hardship or unusual difficuiry with performing the P!V test refueling. Testing the valves as PIVs could be performed with water, thereby negadng the for draining the water from the system. It is recommended that the request for rehef be denied because t u extended test interval is not undfled given the safety significance of the potential for a intersystem LOCA kn the safety on system, an accident mitigadon system, and the alae of the valves (i.e.,12 inch). While exten g the CIV leakage testing is already acceptable under the provisiens of OM Part 10, the Code includes no provisions for leak testing PIVs at intsevals beyond ence every 2 years. The licensee should cor.tinue to perform leakage testing every 2 years.

The licensee has only requested tellsf from the Code test frequency requirements.1herefore, it is L

assumed that the licensee is complying with the utrements of Part 10,14.2.2, except for h 4.2.2.3(a). This wouki include the anal ofleakage rates and corrective action req ts of14.2.2.3 (e) and (f). The licensee ould submit a request for reliefif these requimments areimpractical.

Additionally, the LWa-has indicated in the Valve Tanles that these valves are passive closed valves and has not specified an exercise in the closed direction. 'Ihese valws are containment isoladon valves and would appear to have an active closed function during shutdowns when shutdown cooling was in operation. The licensee should review the funcuon and testing requirements for these valves.

I 4

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4.0 VALVE TESTING DEFERRAL JUSTIFICATIONS Baldmore Oas and Electic Company has submitted 59 jusdficadons for deferrh valve tesdng.

1 tions document the impracticality ofleadng 196 valves quarterly,in both units j

)

'Ihese

,and 36 valves during

..nus or cold shutdowns (counting valves c1 i

Twejdn=daan were to verify their technical basis.

l 1

As discussed in Generic Lauer 91 18 (Ref. 20), it is not the intent of IST to cause unwarranted alant shutdowns or to unruussadly challenge other safety 6ystems. Generally, those tests i

personnel har. potential for a plant tri), or damage to a system or compo avolving the ards are not consideM practical Ramtving one train for testing or en a

Technical Sr+:! -:W limidag condidon of operadon is not suf5cient basis for not I

the requinuftests, unless the tesdng renders systems inoperable for extended oftime (Reference NURBO 1482, Section 3.1.1). Other factors, such as the effect on plant safety and the dif5culty of the test, m6y be considered.

i v lves, whose failure in a non<enservative position during exercising would cauw a loss of a

system function, such as non redundant valves in lines (e.g., a sin,gle ine from the RWST or i

accumulator discharpe), or the RHR pump discharge crossover vsL vSn for plants whose licensley basis assumes that all four cold legs are being supplied by water from at least one purnp, shoulc t

not be exercised dudng condidons when the system is required to be operable. Ohr valves may fall into this category under certain sytte:u configuations or plant operating modes, e.., when 1

l one train of a redundant BOCS system is inoperable, non. redundant valves in the rama train should red be cycled because their failure would cause a total loss of system function, or w i

ons valve in a containment penetration is open and inoperable. the redundant valve abould not be i

exercised during this system configuration, BNL's evaluadon of each deferraljusdfication is provided in Appendix A. 'Ihe anamaH=

i associated with the Wne justincations are provided in Secdon 5.12 of this TER.

l 1

i i

I 4

i 24

5.0 IST SYSTEM SCOPE REVIEW l

h soview performed for this *IER did not include verificadon that all pumps and valves /

within the scope of 10 CFR 50.55a and Section XI are contained in the IST Progmm, and did not ensure however, plicable testing requirements have been idendfied. 'Ihe IST Program z was, that allap reviewed for selected systems. The pumps and valves in the auxiliary feec water, compnent cooling water, and chemical and volume control systems were reviewed against the requmnents of Serion XI and the regulations. The UFSAR was used to determine if the specified valve categories and valve functions were consistent with t'te plant's safety anal ne review results showed compliance with the Code, except for the following items reg the auxiliary feedwater system. 'Ihe lic+asee should review these items and make changes to the l

. where ap wopriate. Addidonally, the licensee should verify that there are not similar s with the ST Program for other systems.

(a) Valve AFW 4550 CV is an air opemtad valve with a fall close funedon denoted on the P&ID, bo'vever, the IRT Program does not require a fall safe test. Additionally, this i

- valve, which is the et u, unt valve between Units 1 and 2,is identified as a passive i

close valve. The chut w 3 in series, AFW 190, has no safety function to close.1he licensee should ensure that there is no requirement for unit isolation once the air cge ;.;d valveis opened.

(b) Normally closed manual valve MS 107 is not included in the IST Program. This valve is opened to provide main atsam to No.12 steam driven AFW pump turbine. The check valve downstream of the manual valve, MS 108,is included in the IST Program and has a safety function to o zn. The liwnsee should review the function of the manual i

valve. As discussed in hUREG-1482, Section 4.4.6, manual valves are required to be tested in accordance with Part 10 if the valve is cmdited in the safety analysis for being cappMa of being reposidoned to shutdown the plant, or to mitigate the consequeaces of an l

ace'. hat.

i (c) Check valves AFW 129,130,193,194,199, and 200 are the AFW tion check

)

j valves into the steam generators.1he IST Program only identifies a function to l

open. The licensee should review the funedon of these valves to ensure that the valves are not required to isolate the steam genemton, for example in the case of a pipe rupture.

Additionall, there are no containment isolation valves identified for penetrations 21 or 22 in theist ram. Although no Type C test would be required, pursuant to Appendix l

A, Criterion 5, at least one containment isolation valve is required. Fifure 5 10 of the SAR identifies control valves CV-4511 and 4512, check valves AFW499 and 200, and locked closed manual valves AFW-163 and 165 as the containment isolation valvea. The control and check valves are only idendred with an acdve open function. It would appear i

that these valves also have an active safety funedon to close to provide containment isolation capabilities. The licensee should review the function and classification of these valves.

a I

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6.0 IST PROGRAM RECOMMENDED ACTION ITEMS Inconsistencies, omissions, and required IW acdons idendned during the review of the 1

licensee's third interval Innervice Testin g Program are summarized below.1he licensee should L

resolve theae kerns in accordance with tie evaluations presanted in this report.

4

}

l 6.1 In BCE's IST Program submittal lener, Reference 1, the licensee states that "after the Impet ved Technical Specificadons arc

> roved, we will implement relief requests as allow wi b 10CFR50.55a. Specificall,10CFR50.55a(fX5Xiv) allows up to one full year l

followin piementation of each requv to demonstrate that a Code requirement is 4

i impracd The licensee further states that where redefis required, the updated IST Program requirements will not be fully implemented undl the hRC approves each speci6c relief request or the Improved Technical Specificadon. On page three of the subminalletter the licensee states "We have concluded that a pump or valve test requirement by the Code

]

or addendaisimpracdcal when:

i The requimnent cannot be met due to plant or system design or configuradon; i

i The requirement would result in an addidonal use of resources without a compensadng increase in the level of quality or safety; or, Compliance with the utrer ant would result in hardshi or unusual dif5culty

[

without a compensatin increase in the level of quality aad safety."

t l

NUREG 1482, Seedon 6 discusses the use c f the revised standard technical specificadons. There is a distinction between requests for relief where the Code requirements are impractical (Le.,10CFR50.55a(fX6)(i)) and uests for approvalof ahemates (i.e.,10CFR50.55a(aX3)). As discussed in the

,linaamaan implemendng the revised standard technical specifications will not need prior approval to implement rec uests for relief where the Code requirements are impractical. However, I

where the Coc e reg uirements are practical and the licensee is proposing an alternate I

(10GR50.55a(s)(JXi) or (ii)), implementation may not begin until authorized by the Dimetor of the Of5cc of Nuclear Reguladon. Only the first item identined by the linaaeam in the subminal letter would be considered by the NRC as impractical, i.e., design limitations or physical constraints. R utrements that result in a hardship or unusual difficulty are not considered impracti 1he NRC would review these requests pursuant to (aX3)(i) or (ii). As stated in NUREG-1482, Section 3.3.3, the regulations do not allow

. a licensee to continue with a previous program undl the NRC has reviewed the requests for I

the next interval. After the start of the new interval, the Code requirements must be met (including for those components where an ahemate is proposed, but is not yet authorized),

unless the requirernents are impractical or an alternate is authorized by the namralamian 6.2 Seedon 5.4 of the IST Program discusees tesdag intervals and states that a 25 percent o

extension may be applied to the test schedule as allowed by plant technical apadwaae As discussed in nub 31-1482, Section 3.1.3, the 25 percent extension v;ould not, I

bowever, be applied to safety and relief valve testing in accordance with Part 1.

l 6.3 The note in the legend for the Pump Tables indicates that if the tabk contains a "YES," the parameter is measured, evaluated and recorded per the Code, and if"NO" is indicated, the parameter is measured in a manner not strictly specified by the Code, and the assochted 26

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relief mquest is noted. De actual table indicates "YES" for a number of pump paranneters i

that are not measured or evaluated in accordance with the Code, e.J., the charg ng pumps' dischargepressure (PR 07). Additionally, a "NO"is indicated in t se speed column for the Service % ater and Salt Water Cooling pumps. A "N/A" would appear more appropriate, i

6.4 When pump test parameters are in the alen range, the Code require; the test frequency to be dou bled, his includes testing performed during cold shutdowns or refueling outages,...

such as proposed in PR 01,2,3,4 and 6. De licensee is neferred to Reference 14. Item 3.3.5, regarding the NRC's recommendation on perfonnance of corrective action when pum ps are in the alert range during the test at refueling. (TER Sections 2.1.1,2.1.2, 2.1.1, 2.2.1, and 2.2.2)

I h 11censee should ensure that the roblems detected at running speed and at subharmonic l

6.5 '

levels are adequately ata**ud usin the proposed vibration instrumentation for the l

charging sumps (PR.05). Consul tion with the pump manufacturer would provide l

additiona bass for thh request.

J ne licensee has stated that the charging pump vibration instrun,entation h " state of the an" and that complis.nu with the Code would require unnecessary procurement of equipment beyond that intended by the Code. De licensee has not provided sufficient information on 4

the hardship or unusual difficulty associated with complymg with the Code and has not demonstrated that there is not a compensating increase in the level of safety. Numerous utilities have procured and utilize vibration measurement equipment that have frequenc response ranges down to 1.5 2 hr. (e.g., Monticello), it appears, based on the licensee

>revious IST Program submittal (Ref.15), which states that the charging pump's I

astrumentation reads accurately from 3 hz., that the L%aw has, since t se last interval,

)

replaced the vibration instrumentation. Derefore, it is recommended that relief be denied.

(

ne limnsee should procure new equipment that meets the Code rec ulrements or revise and recubmit the relief request to address the specific hardship and iow the proposed ahemative provides an acceptable level of safety.

4 i

ne licensee mentions in the basis that they implement a " Rotating M@taary Vibration l

Monitoring Program" that includes periodi:: vibration monitoring of the charging pumps, i

ne licensee states that "this program is inclusive and encompasses a wider range of vibration analyses at several critical pump and motor locations." he licensee, however, i

does not discuss what range of frequency this program encompasses and whether spectral analysis is used.

i it is recommended that an intesim period of one year be allowed for the licensee either to procure riew equipment that meets the Code requuements or revise and resubmit the relief request. (TER Section 2.3.1)

Relief is not hutred'to use the positions included in NUREG-1482, Section 4 6.6 requested in l

the IST Program. (TER Section 3.1.2) 6.7 De licensee has requested generic reliefin VR 03 concerning relief valve test condition correlation requirements. Generic relief would not be appro)riate, Each valve's application must be evaluated. De request should identit tse specific test and design process and ambient temperamres (or ranges of temperatures) of each valve. De licensee states that "Oi,viously, it is impractical to test the va,ve at multiple operating conditions."

I 27

---

a,in=+ww

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.-m-m-..r,-wr,-=

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-- - =,==maww av -

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=g-w-+--w---

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-w

+w

- em o e s e-y-_w e,,w--w-=--r reg-mi

- +

e e---

e&*

It is not obvious why it is impractical to tes; the valve at multiple operating conditions or to develop a correla' ion for a number or range of operating conditions, e

he liceusee state: that " based on input from valve manufacturers, typically safety valve setpoints vary inversely with the temperature of the valve.." nis may be true fcr the majority of the valves, however, there are cases where this relationship is not valid. De ASME OM Part 1 Working Group has recendy reviewed this issue and could not validate this assumption based on input from at least one valve manufacturer, ne licensee should 1

ensure that this assumption is true for all the valves (i.e., for each manufacturer, model.

and whether the valve is insulated or not) that are subject of this request.

the licensee has stated that prernature lifting of a valve does not pose a Additionally,fety concern. De licensce should provide an evaluation of this con significant sa each valve. Each evaluation should specifically consider the integrity of the preasure retaining boundary that would be violated if t!r, valve prematurely lifted, the systern's makeup capability, and any other safety issues (e.g., the potential for overcooling the RCS if the main steam safety valves were to prematurely lift). De licensee should discuss the safety sign!ficance of each valve.

In conclusion, generic relief cannot be recommended, ne licensee should comply with the Code requirements or resubmit the request providing specific infortnation discussed above for each valve. De licensee is referred to Ref.14, Question 2.4.7. (TER Section 3.1.3) 6.8 ne licensee has proposed in VR 13 to test the pressurizer safety valves in a vendor testing lab at the valve body temperature profile necessary to simulate normal operating conditions. No insulation will be installed. De licensee should ensure that any modifications to the piping system or environmental systems (HVAC) are reviewed and evaluated to ensure that the tem )erature profile is not affected such that the tesdng performed would be Owalid. (TER Section 3.1.4) 6.9 he licensee has pro posed using noa intrusive testing (nit). Relief is not required because this test method is considered an acceptable "other positive means,"in accordance with Part 10,14.3.2A(a). The NIT must be repeatable and qualified, as discussed in Generic Letter 89-04, Position 1. De use of non intrusive test methods on each valve every refueling outage, as )to?osed by the licensee, is acceptable in accordance with the Code. As discussed in N JREG 1482, Section 4.1.2, check valves may also be tested using NIT on a sampling basis, ne licensee has also proposed the use of samp:e diuwmbly and inspection in lieu of exercising with flow to minimite personnel exposurt in VR-07 and 08. The use of disassembly and inspection interchangeably with NIT is not acceptable because the licensee may not be able to deterrnine degradation given the extended testrmspection it would appear that personnel radiation exysure during valve intervals. Additionally, ion would exceed any exposure related to tx use of non int disassembly and inspect techniques. De licensee would need to demonstrate on a valve spectTe basis the impractical condition due to rediation exposure. NUREO 1482, Section 2.5.1 provides guidance on what information should be provided. Additionally, the licensee has proposed sample disassembly and inspection when check valve maintenance is al'eady planned. In this care, testing with flow would not be impractical, and should be performed first. Maintenance should not be considered a substitute for a Code required 28

}

test. As discussed in NUREG 1482, Appendix A, Quesdon Groups 11 and 15, disassembly and inspection is an option only where full stroke exercising cannot; i

l practically be )*rformed by flow or by other positive means, ne licensee should perform exercising of t gese valves in accordance with the Code. De licensee's request to utilize san pie disassembly and inspection is not authorized in accordance with Ocneric letter 89-04, Position 2 unless testing with now is impractical. De licensee would need to document the basis for the determination that using flow or other practical means is impractical. (TER Sections 3.2.1 and 3.2.2) q l

6.10 in VR 09 the licensee has not discussed the hardship or unusual diniculty with perfonning the PIV test every refueling. Testing the valves as PIVs could, as is typically done, be perfonned with water, thereby negating the need for draining the water from the system.

j 11 is recommended that VR 09 be denied because the extended test interval is notjusdfied given the safety significance of the potential f or a intersystem LOCA in the safety injection system, an accident mitigation system, and the size of the valves (i.e.,12 inch). De j

heensee should continue to perform leakage testing of the shutdown cooling PIVs every 2 years.

)

ne licensee has only requested relief from the Code test fre; uency requirements.

herefore, it is assumed that the licensee is complying with t ie requirements of Part 10, 14.2.2, except for paragraph 4.2.2.3(a) his would melude the analysis ofleakage rates and corrective action requirements of14.2.2.3 (e) and (f). He licensee should submit a j

request for reliefif these requiranents m impractical i

j Additionally, the licensee has indicated in the Valve Tables that the shutdown cooling PIVs/CIVs a passive closed valves and has not specified an exercise in the closed direction. Dese valves a containment isolation valves ard would appear to have a active closed function during shutdowns when shutdown cooling was in operation. He LW abould review the function and testing requirements for these valves. (TER Section 3.2.3)

J 6.11 in Relief Requests VR 05,07,08,10 and !!, the licemee has proposed to utilize Generic i

Letter 89 04 Position 2 and has idendfied in the requests valves from both units. It is assumed that there a two valve groups per request (i.e., one for each unit). If the groups contain valves from both units, the licensee is referenced to Section 4.1 of NUREG 1482.

De guidance for grouping similar check valves contained in Po>ltion 2 of Generic Leuer 89 04, including group size, must be met.

6.12 Valve Tds Deferal Justification anomalies:

l (a) De licensee has not provided a basis in justification CSJ 3 for deferring closure verification to cold shutdowns. De justification should be revised to address the basis for deferring this exercise. As discussed in NUREG 1482, Apiyndix A, Question Group 24, 4

exercising the valve open is not a preren,uisite in order to venfy the vaht's closure capability.

4 a

(b) De Valve Tables indicate that valves 1(2) CVC 228 will be partially stroked quarterly.

Justification CSI 7, however, states that it is impnctical to partial stroke these valves during operation. Additionally, the Valve Tables indicate that the valves will be exercised closed at cold shutdowns, while the basis of justification CSJ 7 states that the valves will be confinned closed quarterly. De licensee should conect the Valve Tables or justification accordingly.

29 b

• -+w e

e---enrww-r-,

mmww*eww-.-

s,w,emww-----r r

4 -vr

---%--i+v--- - - - ---wwsw--

'gv-f y

?

l (c) Check valves 1(2) CVC 251 are nonnally closed and only have a safety function to close. De licensee states in jusdfication CS) 8A that "any leakage of concentrated boric acid past CV512 into the VCT will affect reae:ivity and cause a reactor power transient."

Valve CV512 is a 3 inch globe valve, his $ype of valve normally provide.s excellent seat leak tightness. It is not apparent that verifying closure of CVC 251 will cause a significant

]

sower transient due to leakage past a globe valve. His leakage could be tempered by njecting reactor makeu p water directly into the charging pump suedon or into the VCT.

j Additionally, boric acid h batch added during power operadon.

De licensee states that when boric acid is added to the VCT during power operadon "the

)

operstors are required to verify the plant response by checking the appropriate parameters, i

includin g VCT fevel, VCT pressure, and bode acid flow rate, nis effectivel verifies i

CVC251 is adog untely closed." his test does not aypear to adequately C VC 251is closed. Normally closed valve CV 210X, and choc c valves, CVC 244 and 7 arein senes.

ne licensee should review the test method and revise the justification accordingly.

i l

(d) ne licensee ha: not provided a basis in jusdfication CSJ.9 for deferdng valves 1(2).

CVC 257 closure verification to cold shutdowns. De justification should be revised to address the basis for deferring this exercise. As discussed in NUREG 1482, Apmodix A,

)

Question Group 24, exercising the valve open is not a prerequisite in order to ver fy the valve's closure capability.

}

(e) *lh licensee states that is im practical to exercise 1(2) CVC-186 quarterly in j=in= dan i

CSJ 14, because some flow is divened through valve 1(2) CVC-435. Dem is a manual l

valve,1(2) CVC 188 in sedes with valve 1(2)-CVC 435, that could be Isolated in order to i

full stroke enemise 1(2) CVC 186. De licensee should pmvide a discussion of the impracticality of exercising this valve by manually closing 1(2) CVC 188.

(f) De licensee states in CSJ 15 that valves 1(2) CVC 435 cannot be exercised open j

because the normal charging lineu ) would be isolated resulting in level transients, and would not be considered prudent c udng normal plant operation. Flow through the 2 inch i

bypass would not appear to cause ~aere pressunzer level transients and plant shutdown.

At least one other CE PWR (Palix.oes) full stroke exercises this valve quanerly. De licensee should reevaluate the practicality of full stmke exercising these valves quanarly.

(g) ne licensee state:in CSJ 27 that the test for verifying closure of valves 1(2) MS 103 and 106 is '%xtremely cumbersome and req uires extensive system realignment and i

resources and an extended

'od dudng which the associated AFW pump is out of service." It appears that w t each AFW pum p is tested, the other pump s associated 2

main steam caeck valve is closed. Without adc itional information on the test method used, the basis for deferring testing is inadequate.

(h) Justifications CSJ 29 and RFJ 01 are based on the need to open the valves before rforming the back leakage tests. Per NUREG 1482, Appendix A, Question Group 24, t Considerations, if a valve perfonns a safety function only in the closed posinor, demonstration of a stroke o )en before verification of closure is not required by tbe Code.

his guidance is aho incluc ed in Section 5.3 of the licensee's IST Program. %ese justifications are for valves that are not ASME Code Class 1 2 or 3

)Q 4

i i

i

0) Jusdfications CSJ 34,35 and 36 dhcuss the irnpraedcality of tesdng dur ng power 8

I j

operadon, however, the Valve Tables indicate that the valves will be full stroke exercised durm refueling. De " cold shutdown" justification does not discuss the impracticality of j

tesdn the valves during cold shutdewns. Additionally, the licensee has not >tevided i

j tion for deferring closure verification in CSJ 34. De licensee shouk revise the j

Table orjustifications accordingly.

~

i (j) Justifications RFh6,7,8,9 and 10, state that the test is impractical to perform "every outage during normal operation or during cold shutdown periods." Dese sentences appear to be aconect. DeaejustElcations a for non ASME Code Class valves.

(k) De licensee has not discussed in CSh37 the impracticality of performing a closure test quanedy, ne Valve Tables ident!fy that the valves will be exercised closed during cold shutdowns. De Valve Tables or lustification should be avised accordingly.

+

0) De basis forjustification CSh39 states that the valves will be verired closed cuanedy.

ne Valve Table, however, indicates that the valves will be full stroke exercised c osed at cold shutdowns, ne licensee i.hould exercise /vedfy closure quarterly, or provide additional informadon to jusdfy deferring this test to cold shutdowns.

(m)In the bads for CSJ-40, the licensee states that the valves will be artial stroke exercised whenever the associated HPSI pum p is run to fdl a safety oction tank. In the

)

i Valve Table, the licensee indicates that the va) ves will be partial-exercised quanarly.

I If the HPSI pump is not rur, quanedy to fill the SITS, then the justification should, provide l

additional ira ormation to su pport the bases that annial stroke exercising is im acal to perform quanedy. De bat s of CSb34 states t ut these valves will be stroke exercised open quanerly ad whenever the HPSI pump is operated to the SITS.

I (n) It does not appear to be impractical to verify closure of the valves identified in CSb42 during power operat!on. De test connections are located outside containment and thcre is no restriction to opening one CIV unless the other CIV is inoperable (See discussion in i

NUREG 1482, Section 3.1.l(2)). De licensee has stated that there is a concem with radiation exposure, however, the licensee has not provided specific infonnation as discussed in NUREO 1482, Section 2.5.1. De licensee has stated that these valves m opened relatively infrequently and for a short duration. De licensee should note that I

valves need not be considered active if they a only temporarily removed from their safety position for a short pedod of time, as discussed in NUREO 1482, Section 2.4.2. If the valve is routinely repositioned during power operation it would be considered active, ne licensee should review the classification of these valves and, if necessary, mvise the IST j

Program to include quanerly testing, or provide additional jusdfication.

sl-(o) ne licensee states in CSJ 43 that "In order to open these valves, the containment spray

> umps must be o serated with injection into t% containment spray headers." However, it is a

tical to ful stroke exercise the CS pump discharge valves in any operational mode l

2 the containment spray header. These valves are discussed in Cold Shutdown Justification Number 43, however, in the Valve Tables, these valves = identified as being full stroke exercised during refueling. De IW does not discuss how or when the -

valves will be tested in the justification. However, as diacussed in Relief R uest PR 06 addressing the containment spray pumps, the CS pumps (and the associated ' harge check valves) can be full flow tested substituting the CS pumps for the LPSI pumps in 31

l shutdown cooling lineup after sufficient decay heat has been removed. It appears that i

these valves will be full stroke exercised duntm cold shutdowns of sufficient length. The licensee should provide additional information :n this CSJ to support deferring quarterly testing.

H to open one of the associated overbord valve pairs.y to cpen valves (p) The LMm states in CSJ 44 that the normal wa Itis not apparent from the P&ID whether the valves can be opened using the override handswitch HS 5149, without o pdng a valve pair. Provided that the valves cannot be operated using HS 5149, the i

s. temative provides full stroke exercising to the open posidon during cold shutdowns in accordance with OM Part 10,14.2.1.2(c). The licensee should ensure that the valves cannot be operated using HS 5149 such that,the valve pairs would not be opened.

(q) The licensee's basis for deferdng testing in RFJ !I is that a LCO would need to be t

entered for an extended period of time pro ubly in excess of 3 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). As discussed in NUREG 1482, Section 3.1.2, a r.yluire< entry into a 140 to perform IST would not l

sustify deferring testing until a cold shutdowa or refueling. With one diesel rator 4

l

noperable during operation, Calvert Cliffs Tech Spec 3.8.1.1 requires both s be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Tech Spec 3.8.1.2 only requhes one EDO to be operable during 3

cold shutdowns and refueling. Additionally, the acensee states that resting quartedy a

would result in increased run thne on the compressors and the potential for air system contamination. This does not ap to be sufficient basis for deferring te.itin to refueling. On review of the -

Starting Air PalD,it appears that the supp header j

could be depressurized through SV 10247 and 10275 and the silencers use<. r air dryer regeneration. Testing in this manner would probably not require the air receivers or EDOs 80 be declared ino mable. The licensee should review the test method and revise the request according' y. Additionally, for the subject valves, the Valve Tabie incorrectly identifies the Refueling Justification Number as RFJ 08.

i 6.13 The system scope review results showed compliance with the Code, except for the following items regarding the auxiliary feedwater system. The licenser enould review these items and make changes to the IST Prograrn, where ap wopriate. Additionally, the licensee should verify that there are not similar problems witi the IST Program for other systems (TER Section 5.0).

(a) Valve AFW 4550-CV is an air operated valve with a fall close function deno'ed on the P&ID, however, the IST Program does not require a fall safe test. Additionally, this l

valve, which is the cross-connect valve between Units 1 and 2, is identified as a passive close valve. 'D : heck valve in series, AFW 190, has no safety function to close. The licensee shousa ensure that there is no requirement for unit isolation once the air-operated valve is opened.

(b) Nonnaliy closed manual valve MS-107 is not included in the IST Program. This valve is opened to provide main steam to No.12 steam driven AFW pump turbine. The check valve downstream of the manual valve, MS 108,is included in the IST Program and 1

has a safety function to o mn. The licensee should review the function of the manual valve. As discussed in hUREG 1 W, Section 4.4.6, manual valves are required to be tested in accordance with Part IL the valve is credited in the safety analysis for being capable of being repositioned to shutdown the plant, or to mitigate the consequences of an accident.

l.

32 m-.

.m.-

- - +

e.-w.

---

...-.----_me--------.-----,~%'-.---------

-. - - --...-m--.

--.---,-.,,-,.v.,*-.-,m-

,m

+=w#

.--~w,-,a m r.

--w---*

i l ',

P a

(c) Check valves AFW 129,130.193,194.199, and 200 are the AFW injection check j

valves into the steam generators. The IST Program only identifies a sa% function to open. 'the licensee should review the function of these valves to ensure oat the valves are 1

not required to isolate the steam generators, for example in the case of a pipe rupture.

Additionally, there are no containment isolation valves identified for penetrations 21 or 22 in the IST Program. Although no Type C test would be required, pursuant to Appendix A, Criterion 57, at least one containment isolation valve is required. Fi rure 5 10 of the SAR idendfies control valves CV-4511 and 4512, check valves APN499 ano 200, and locked closed manual valves AFW 163 and 165 as the containment isolation valves. The control and check valves are only idendfied with an acdve open funedon. It would appear i

that these valves also have an active safety function to close to provide containment l

isolation capabilities. The licensee should seview the function and classification of these i

valves.

7.0 REFERENCES

l 1.

"Ihird Ten Year Inservice Test Program for Safety Related Pumps and Valves," C. Cruse, i

BOE, to NRC Document Control Desk, June 30,1997 2.

" Response to Questions on the Third Ten Year Inservice Test Program for Safety Related Pumps and Valves," C. Cruse, BOE, to NRC Document Control kak, October 1,1997.

3.

'Iltle 10, Code of Federal Regulations, Section 50.55a, Codes and Standards.

l 4.

ASME Boller and Pressure Vessel Code,Section XI, Rules for Innervice Inspection of Nuclear Power Plant Components,1989 Edition.

a 5.

ASME/ANS1 OM 1987 Part 1."R uirements for Inservloe Perfonnance Testing of NuclearPower Plant Pressure Relief vices."

6.

ASME/ ANSI OMa 1988, Part 6," Inservice Testing of Pumps in Ught Water Reactor Power Plants."

s 7.

ASME/ ANSI OMa-1988, Part 10 " Inservice Testing of Valves in Light Water Reactor 2

Power Plants."

1 8.

Standard Review Plan, NUREO 0800, Section L.9.6, Inservice Testing of Pumps and l

Valves, Rev. 2, July 1981.

9.

NRC Generic letter 89 04, " Guidance on Develop *mg Acceptable Inservice Testing i

Programs," April 3,1989.

10.

Minutes of the Public Meetings on Generic letter 89 04, October 25,1989.

4 11.

Su >plernent to the Minutes of the Public Meetings on Generic letter 89 04, September 26,.

1911.

12.

NUREG 1482,"Ouldelines for Inservice Testing at Nuclear Power Plants," April W95.

13.

NUREO/CR-63%," Examples, Clarifications, and Guidance on Preparing Requests for Relief from Pump and Valve Inservice Testing Requirements," February 1996.

33 i

o 14.

Memo to File," Summary of Public Workshops held in NRC Regions on inspection Procedure 73756, ' Inservice Testing of Pumps and Velves,' and Answers to Panel Questions on Inservice Tesdng Issues," from J. Colaccino, NRC, July 18,1997.

Letter from R. Capra, NRC, to 0. Creel, BOE, "Second Ten Year Inservice Inspection Testing Program-Calvert Cliffs Nuclear Power Plant, Units I ud 2 TAC Nos. 64976 and 64977," dated September 20,1990.

1 16.

Pump Handbook, IJ. Karassik, McGraw Hill Book Company,19'/6 17.

NUREG/CP-0111 Proceedings of t!.e NRC/ASME Symposium on Valve and Pump Testing, October 1990.

18.

Letter from ). 'Ilerman, BGE, to R. Capra, NRC, " Response to Generic Letter 87 06,

" Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves," July 7,1987, 19.

Standard Techr.! cal Specifications, Combustion Engineering Plants, Ser:mber 1992.

20.

NRC Generic Letter 91 18,"Information to Ucensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," November 7,1991.

21.

NRC Generic letter 90-06, " Resolution of Generic Issue 70, ' Power Operated Relief and Generic issue 94, ' Additional Low Temperature Valve and Block Valve Reliability' Water Reactors,' Pursuant to 10CFR50.54(f)," June Overpressure Protectior, for Ught-25,1990.

i

4 Appendix A-Evatusties' of Calvert Cliffs' Yelve Testing Deferral Justifications Deheral Vahe i larms#s Justif% slam fur Deferring Vahe Emerdsing Proposed Evaluarson of f Ire==re's Juefication Ahcramme No.

1demelfirestre Testtag C$J-7 IG).AFW-101 "These see sisqde check veives w!ik so external aram of esercifig:

Per:teVahe R b isegwactical to fd-cr L" M exerdse and 1G).AFW-thus te caly practical incans of opening these vahes is to operate each TsNes,these these vahes opes quarterly because.C,.:, cuid pump discharg* g to te seene gene:at.as. D shg plant cperation at vahes are feB I auxiliary feedwater flow would be beconced laso i

116 o

power this is not practkal due to the potential for theneal shock of Ibc strokecaerdsed the stessa genernears wisch cooki poecatsaBy resak AFW Pese 11 stemma generasar aoszies or Internals. During quarterty testing of the openandc!caed

% dsmage to the seemme generaeor ami nnede (21)and12G2)

AFW pumps, flow is mused through a munimean fkrer reckeulatico line atcxt!

rmaec6ans due to thersnal shock. Additiceally, Dischsge bnaiching off upseensa of these check valves that trigras c'enermemar to shutdowns.

duringopenelon the % 0-- ppiping mayactbe l

CheckVahes te madruemie storage tank and the respeedve purp's sectice line, tus.

presaarted med the need to set up eququneet utskss partial flow exerdsing is abo kapracticz!. In adesion, Die sparterty k kapracsical to verify closure quanerfy.

sesting does not pressurke the common discharge header, tus verifying the closure of the chedr vehe at the discharge of the idle pump h not De steenuthe provides fd-satite exerdsing !c possible wkhout an extenske change la t%e systems vehe Ibsesqn. His the open and closed posidou duing cold sheerbwss is consheest w!sh abe pos 60s stated hi NU'eEG.1432. Paragr1ph in accordance with Oh! Part 10.143.2.2 (c).

i i

i 2.4.5."

j I

CSJ-2 1(2).AFWG "Ibese me slauple check vahes with no extental steans of excrdsing; Perthe Yahe It h impracsical to Ts!!- or gartial-stroke exerdse L^

and 1G)-AFW-thus the caly practical unans of opemog these vahes is to operase esi:h Tables,these these vatw:s spes quarterly tecause sels:ively cnid 130 peep discharging e the mesma generneors. Dwing plant operation at vahes are fur ' -malary feedwaar fkra wouk! te inert 4=vd laen pe=r his is not pracscal due to te potemial for tenmal shock of me sers2exesched te==== generseers nics enend posemiany resuti AFWDisdnerge scenen generator soczles and intersels. During qw_,;i esting of the cpes atcdd ki damage to te sa:aan generasor and acede t

so Seessa AFW pumps, flow k routed through a adnisnuma flow Jecirculmelon line sheedrses.

ra==artinae due to tennai shocr.

Generseers br==rhang off spatreast of tese cher* vahes tha rteams maar===ar so

[

t CheckVahes te n= dreamer storage tank and the n.Wm pesagfs secd(wi Eme, thus Tse shermative provides fuB-secke exerching to the open posidos(1 Mcok!sbandownsin partial flow exerdsing is aho is mal:al. This is consistent wit te amonhece wie F.st 10.143.2.2(c).

paaltion mased in NUltEG-1482, Paragnph 2A 5 "

~

r

)

l 4

s.

i

~

i.

35

?

= - - -

. - =

J

\\

CSI-3 1(2)-AFW-123 "These me died vehes wth no essernal mienne of cauching; tus te Per te Vahe k is herractical to full-er partsel-serde enerdw-l emiy practical meses of speming these vehes is to operuse each pump TaNes, these tese vehes open gusterly ter=mer selashely cold l

AFW Phnp 13 encharghg to te scene generseurs. Durhg phs cyaanica a poner wahes me fuB-ammary ferdwaw How wekt be hooduced hop

-l

+

(23)Disdierge his !s not prereirma due to te potensial for terusal shock of te steam struteemesdsed the samme genermars whidi could peeenanEy resuk I

f%r* Vahes generator =w* orimeerants. Dwmg quenerly tesehg of the AFW cpen and domed in dunage to te mar== genernew and marrie pumiya, Hour is suused through a minusum flow sederalaelos Ilse at cnid r==mardamm due to therumi shtek.

luenching off at tese terr

• vehes est resurns commermanar to the sheedowns.

remadrammar storage tank med te w 4 pesup's section line,thus The sessemehe provides full-sede wQ to e

partial flow enacising is also imiprarwral 1his is consiseent whk te the open poshion denug cold stoutdowns in I

poeidca seated in NUREG-1482, Paragraph 2.4.5."

scoordance with OM Part 10.143.2.2 (c).

l

[

The Ecumee has not provided a basis fer deferrbg the ematise ckmed to cohl demeawns. The

[

juseScation should be sevised to address the hesis for deferrung this enrcsse. As dwassed in

[

NUREG-1482, Apper@x A Quest on Group 24 esercising the vahe open is not a prerequisiet in i

order to verify he valve's closure capaNiity.

~

CSJ-4 1(2).AFW-190 "fbene ase simple dieck vehes whh no essernal nicans of enerdsing:

PertheVahe It is

• A " so full-er pardal-sede enadse i

tus te caly prececal steams of openeg these vehes is to operase each TaNes,tese thesevahes quenedy because,J J, cdl Unit 1(2) AFW pump disrem ging to te steen genersoors. During plant operation at vahes are full-ammary feedwaeer flow would be immoduced into f

Cross-commect poww his is set peacecal due to te poarmad for termal shr-^ M te smoke enached te==== generseers whid could peerstneRy resuk j

Cher* Vahes seeman genersoor moedes orinterneh. Dunng quanerty sessing n..:

open at cold in damuge to the steam pand acezie l

AFW pumps, flow is scused through a seinismen flow sechtshamna Ihme skuedowns.

mamarsoms due to therund shock.

br==rting off upseesen of tese chedt vehes Get sensus rendammmer to i

due en-desemer storage tank and the.@, pesq(= section Ene, thus The aherenthe prowht s fisl3.sarette excrdsing to L

1' partial flow enescising is abo imiprarwrml This is reanimerne wit te te open posinom during cold shutdowns in poskien enmand in NUREG-1482, Paragraph 2.4.5."

acconhece whh OM Part 10.143.2.2 (c).

I CSJ-5 1(2).AFW-193, "These me simple check vahes wkh no external meses of me i, Per theVahe k is imprartiras to fall-or panial-seeke ent:the s

1(2)-AFW-194, tus due caly precekal empen, of enacising is to operuse cada pump TaNes,tese tese vahes quene1y serimme,J

.J, cold 1(2FAFW-199 diert=ging to the,are= generusers. During plant operselon at power vehes are fuB-maaillary feedweser flow would he immodard ines and 1(2).AFW-his is not practical due to te poeemeal for termal *w* of te steam secheenadaed te seems generasors whkt conht poseneasy sesak 200 genermaarmardes orimessels. Durhg quenedy ar ame of the AFW open atcold in emesace to te mar== generseer and moerle punaps, flow is scused through a minismen flow federadadam Ilme skuebwes.

tw=martione due to thennet shock.

AFW S/G brandning off upseeum of tese chpr* Vahes $st securas credrummer to i

Supply Chedt te awedensman storage temk and te,#; m peng(s section Eme, tus The sharanehe psevides full-stoke enadsing to Vahts punist flow enesdaing is also imiprareir=I 'Inis is,nmaamares wien te

• he open peshion e srmg cold shundowns ha -

penison sessed im NUREG-1482, Phragraph 2.4.5."

samatmum widi OM Put 10,143.2.2 (c).

u

l CSJ-6 1(2FCYC-162 "Dese are shaple chedt vehes wish so==== of nothug obenraer

' Per the Vahe ! k is *,--- 1 " ao fur-or partal-semke exercbe positiam nor for asseust 2sercising. Exerdsing abese vehes in the c nneut Tables, thes :

sheer va*ves quenerly ber=== istis. ion of these a

vahes would requ se me cterging purnps to'ahe VCrOuset dreedon requires reasymw=r of the CVCS systems trid st3thr; te vahes are fuB-a twr* vehes

=eneina of te chargh pumps so an ahernsee scure of wuser or securing samkeesendsed succion from me R%T or beric acid storage tanks i

e,a puesps. During plant operamon th would dhrupt sie CVCS syseeni closed at cold which could cause pressuriser level aruf rescate beimnoe whh the panemist for cesstag severe,., - 6 lewt a===amse shutdones.

power eraneless due so the insert =*is= ef f

or resceor coolant =mireamp baron comerneration variations. Parmal-stroke concentraced borte acht, resulting le possitde plant eseedsing of these vahes presens se sanne risks and praticans that are shutdown or trip.

asancesarrt with fur-smoke -w ttaus k 12 sho act feasible during l

operation. This is commi ame sith the position sessed in NUIWG-1482,

'Ibe shermative provides full-stroke w W to l

Paragraph 2.4.5."

the closed posidan denng crsid shutdowns in l

accordance with OM Part 10.14 3.2.2 (c).

CSI-7 1(2 -CVC-228 "mese are simple chedt vahes with no mieses of modng obearator Per the Vahe it is L.,.di.J to full-or partal-seeke exercise i

position mor for unanumi exactshg. Exerciseg these vahes in the open Tables, these these vahes open quanerty because the charging asy Greedon requires rensigment of me Cycs syseem ud in,eason of vehes are fun-pumps weesd be requerd so take sucnon from me l

Beration annermerased beric acid Ir:to te vencear cookset syseeni via the charging seekeentsemed boric acid storage tasks whida could cause

[

j Graview Tted pumps. During plant operadon this could disrupt the CVCS system open and dosed pressaker levet and renesor power trans' nes due so I

Chedtvahes beinace wiei me posenunt for camshg severe presswiser level emissents atcold she buorheesi of concenmated boric add, l

or resceor coolant W beson concertration vadations. Partial stroke shi.edowns, and resulting in possible plant skuedown or erip.

exerdsing of these vahes presemis se same risks and probsenis est me me pensi-annarina, e wish fag.seroke enerdsing. thus it is also not fensible dunng senkee erched The alterumhe provides fur-seeke exercising to i

cperadon. Then-vehes can be antirmed closed (==sicamy sessed) quenerly.

me open poshion during cold skuesowas in quenesty. This is consiseent wies the posioon stated in NUREG-1482, ac:ordance with OM Pat 10.143.2.2 (c).

Paragraph 2.4.5."

The Vahe Tables, however, indicaec that these I

vahes wat te peniany-seuked quenerty.

l AdtEtionaEy, the VaheTables indeczee that the i

vahes win tie exertmed closed at cold shee$ownz,

[

whue se beds of the jusufication states that me vahes wat be connnned closed quanerty. The Ervens.* should conect te Vahe Tab 8-s or i

^~:*--- accordagly.

37 i

i i

CSJ.8 1(2FCYC-235 "fbese are simple decit vehes wie no ammes of modng obenrator Per she Vahe R is ", -:'- : to fis5-or partial-senke emerdse l

l p rir-sies.es.g. ns s.g tese v wesia ee-rabies. -

- va,ves -,se. ny - e u e ngh.

l Emmyscy mecdom nquires i=jer*in of cemenerased kwie acht ines te warent vehes me fa5-pumps waaid te segumes to aihe er*= from te j

Berndom Quedt cooluut sysema via te charging yemps. During plan operados tids sacheenesdeed baric acid senrage maks wid& cmuid cause i

Vahes could darupt ue CVCS syssess balsace wien the ponensist for causing open atcaid psesamtser levet and scarsor power a-dr=an due to j

g sevese pessenmar kvet==dr=== or sencair==a.=e maim.up bo, simodowns.

ee e== mar *= etascemamed boric add, a=r-artilos varianoms. Pk-h enerdsing of asese vehes r==animp In possible pient skuedown er trip.

i pesents me same rkks sad prdar-= est me==na=d wie fem sarmhe i

enadslag, tus k is also act feasible durtag opermairm hisis The sluramshe provkees fuB-sercke exerdsing to f

mumiem wie te posiden sensed im NUREG-1482, Paragr:yli 2A.5."

the open poshion during cold shutdowns :n

[

accerduse whh OD4 Part 10,14.3.2.2 (c).

[

CSJ.

1(2FCVC-251 "Verifring the abitty of this <: heck vehe to close requires applybg a Ptrthe Vahe These check vehes are monmag closed and cafy y

SA back-pressee. The only sour:r of a bedt9 essure during manuel Tables,tese have a safety funcsion to dose. De licensee senses

{

Dr=I=rwaBred opermion is a beric add pump (temporarily instaning a test pump enti:

vahes areisE-shot"any Irener of ew=rnarased boric acid east Wa::rSeppfy quener is not cocsidered pacdcal). However, the boric acid pump smokecaerdsed CY512 imeo lhe VCr wiE affect M.;y arsi to VCTCheck diertnege psessure is high enough to create a come:m vegading possible domed amid came a scarent power transiest

• Vahe CV512 is Vahes n,*ege past CV512 imeo te VP.f(since there are no isolation vehes skuedowns.

a 3-inch globe vehe. His type of vahe seuseity between CV512 sad the VCT). Under arretres meditkus wkh CV210Y provides ermtemt seat leak ighemess. k is not open, sent trempe past CV5121meo the VCTdoes not present a concern appenst that vertrying closure of CVC-251 will 1=r==, enough boric acid wlE selft vesch the chargeg pump sucson.

cause a sigadican power transiest due to leakage i

However, during power operation, any leakage of==rnarmoed beric add put a globe vehe. shis leskage could be tempesed past CV512 been te VCT wul anect seacevity and cause a se= rear power by injetsing se=rwir naheep waner direcdy Imeo te l

erandr= Pm eenmore, a me feet cyde popesses and less borte acid is charging pump s=r*= or imeo se VCr.

l l

seguised in the RCS, te ingacs of such a M.2 changes wBI become Atmair==my,beste acid is best added shring power 1

i amore pen =r-arvd his is a=dmar=e widi te posiden mased in opermeir=

NURBG.1482, Paragrapti 2A.5.

I I

De Ihmssee somets shot ahem boric acid is milded to i

Whem====ared baie add is beach added to te VCTdwhg power the VCTduring power opermeion "Ibe operators see operusion, te operusers are seguind to verify er pint sesponse by seguised to venfy te pimet response by chedtag diecksmg te appopdsee p===rarrn, hcomens VCrieve,VCr me approphne paramesen_ imeinems CT ieve:,

v pessure, and baric add Sow ruse. His A 4, verines CVC251 is VCTpensee, and boric acid flon rase. His j

adrupmaray domed. ARer each adrenk= cf a n=rwumemend boric acsd to the effecchesy verMies CVC251 is adr.pmarly closed

• VCT,de=I=rmalised weser is used to flush the piping. His sackes opes, his test does act appear to adrepmarly verify CVC251.Dereic% over the coarse of endi quarter, eis check valve is CVC-251 is closed. NonumEy closed valve CV-at least parMeuled open and closed seveal ri-re However, siste te 21GK, and chedt vahes,CVC-244 and 247, me in i

{

degree of MC3 boreales d,cu=

as te fuel cyde pogresses, the sestes.

I a

sreguacyof adensa=r =ssedborteaddieseVCralsodecsenses. m is un proceess to add a=r-ar=d boric acid so me VCT solely for me De ur-shone se,iew me testanemodams 2

purpose of,a _ _W CVC251."

sevise meJusencasion scawcesty.

i 38

[

~

i I

4

i i

1 i

CSI-9 1(2KVC-237

• Pasm1 ming these vehes sequbes semNgument of the CVCS sygeems and Ptr the Vahe k is heprerenrni to fur-er partal-seeke enesche shN$ng te== rein = ef te darging pommys to the sefuetbig water serage Tshles,tese these vehes open queresty har===P she charging i

RWT to ammk (RWD. During plant aperselon this could enrupt the CVCS vehes sue fuB-pumps would be segebed so aske ownin= hem te

(

Omrging Pemy sysum talance west te ran==ss=I for causing sevest psessuriser level sedeenacised RWT whis conid came psessutmer level and I

socikr, rwrer

====a

= or sencesc==n== maksi, benen --n== ion verkdoms.

epen andcsosed sencer power summiemn due so me ime-aw*= or 3

l Vahes Pardsigenhe execising of these vehes psesemes et samme risks ed atcuid

<=======esd barte acid, sesshing in peesde ytant i

pechtemas sket ase===nremand wtgi fug-suche esercishg thus k is abo eh=*enons, shutdown er tip.

f not fessade destas operseios. This is r===nearm with the posidan sensed im NUREG.1482, Paragraph 2.4.5."

The shernshe ymides fur-seeke enescising to l

the open pasielen during cold sheadowns in l

mecordusoe wie OM Part 10,143.2.2 (c).

i l

The r==

hasnotpsovidedabasisfordefesring u

the enesdse closed so cold skuedowns. The i

Jussir'ensLw shn=ht be sevised to addsess te horis ter desauring this eneedse. As escussed la j

1N1482. Apprenew A.QuesecaGrcup24 j

I enescising te vahe open is not a preseguesiee in l

l esder to verify ihe wahe's classe capalmhty.

{

\\

CSJ-10 1(2)CVC-501-

• Emescising ihese vs~ves sequhes a major sealignarmt of te CVCS Ptr he Vahe k is hapsureiret so fiell-er persal-seche encycree 3

MOV sysseum. Durtug plant operadon this could disrupt the CVCS syssen Tables,these lhese vaht t quarterly betzune annual meheup flow balmace win the pe==ss=8 for causag sevat psessuriser levet tr===Aa===

vahes are fut-wouhl be incessupeed resuleng in pressurteer level l

VCTOusht and a plant shutdown. Pantal-seeke enacimag of tese vahes psesans seekeenacued

====Arma If shernsee miley sowces were

[

isolation te samme sisks and psobleans that ase amanruarmi wie fuB4eelse closedatcold learnemed Le., the RWTor boric acid sensage Vahes enestleing, thus k is also not feasible dureig opernelon. This is shutdoses.

auts, sencsor power hansients due to stic f

===a=a m wies the posklan sameed im NUREG-1482, Paragraph 2.4.5."

imena=rena= ef <==r==ar==d boric acid c auld sesult s

la PoesNde phet W er tip.

[

l 1he ahes.andse psowides fdi-seeke enaddag to j

te closed posialan during cold ehmanwes he l

l l

acconkmee wie OM Part 10.14.2.1.2 (c).

4 l

i l

i

s CSJ-9 1(2}CVC-257 Txercising these valves requhs realignment o~ the CVCS system and Per the Valve It b knreactical to fun-or partal-strtte exercle ahining the section of the chargirg pu nps to the efueling waer sacrage Tables, these these valve = cren quarerty because the charging RWT to tank (RWD. During plant wu icit this conM disr:rpt the CVCS valves are fu!!-

pumps would be reqmred to take suctico from the Charging Pump system balance with the potential for causing severe p.

La level stmke Jxd R%Twhich cxmM cacse p Lu level and Suction Check transients or reactor cxxcnt m:*e-up truun concentration variations cien and dosed resciar power L ea due to the iniitivdk-u Valves Partial 4troke excrdsmg of tiese valves presents the same risks and at cold ccmcentrated beric acid, resching in gossible plant problems that are assoc!aed with full-stroke exercising. thus it is abo suG n;.

Guidu ortrip.

r at feasible darsg operation. This is consisent with the position stated in NUREG.1432. Paragraph 2.4.5."

The ahernati e trovides full-strate exercising to the cien position during cold shutdowns in accordance with OM Part 10.143.2.2 (c).

"Ihe licensee tras rxx prtmded a basis for deferring the exerdse cloeed to cold shutdowns. The justification shouM be revtsed to address the tutsis for deferring this exenise. As discussed in NUREG-1482. Appendix A. Question Cwoop 24, exercising the valve open is not a pr sequisin-in order to verify the valve's closure capability.

CSJ-10 1(2}CVC-501-

" Exercising these valves requires a major realignmer:t of the CVCS Per the Valve it is impractical to run or partial. stroke exercise MOV system. During plant operation this conM disrupt the CVCS system Tables, these these valves quarterly tecause normal makeup flow talance with the potential for causing severe pressurizer level transients valves are fuD-would te LiuW resulting in,,

us level VCI' Outlet and a plant soe-o. Partial-stroke excreismg of these valves presents stroke exercised trarments. If shemate rsakeup sources were Isolation the same risks and p oblems that are as ociated with fuB-stmke cloa!acold

.6udmai. Le., the R% Tor twic acid storage Valves exercising. thus it is also not feasible during operation. This is shutdowns.

t:mks, reacta power trarments due to the r=l<rm rith the positloc stated in NUREG-1482, h syeit 2.4.5."

inbud=G,> of s=ma.m 4 tale acid could result in possible plant shutdown or trip.

The a:;mm.A rovides full-stroke exercising to t

the closed position during cold shutdowns in zu.v Jm.w with OM Part 10.14.2.1.2 (c).

39

.x CSI-9 l@CVC-257

" Exercising these valves requires realignment of the CVCS synem and Per the Valve It b imsvacucal *o feri-or partial-strrte exercise shining the moeden of the charging pumps to the refuelh g we -mge Tables. these these valves open quanerty tecame the charging RWT to tank (RWD. During plant cperation this conM disrupt the CVCS valves are fuD.

pumps would te requred to take suchon from the Ch-rging Pump systan balance with the potential for causmg severe 5 La level stroke M

RWTwhich cooM cause p Lu level and Section Check transients or reactor coolant makcHrp baron concentracon d dais.

cgen and closed reactor power transie:sts due so t! e incududb> of Valves Partial-stroke exercising of these valves pesats the same risks and at cold concentrated tvric acid, resulting in possible plant problems that are associated with full-stroke exerching. thus k is aho s!medo ms.

shutdown or tr!p.

not feasible during w.Guo. Thh is cmsistent with the position stated in NUREG.1482. Paragnph 2.4.5."

The shernative provides fun-stroke extreising to the cree position during ccM s!mtdosw in su.u.La4 with OM Part 10.143.2.2 (c).

The Ilcemee bss nct provxkd a basis for deferring the exercise closed to coM shutdowns. The justification shouM te revised to address the basis Icr deferring this excrose. As discussed in NUPIG.1482. A;Tendix A.QueshonGroup24 exerosing the valve open is not a prerequisite in order to verify the valve's closure capability.

CSJ-10 1(2) CVC-501-

" Exercising these valves requires a major realignment of the CVCS Per the Valve It is impracucal to fun-ce partial-stroke exercise 6 I

MOV system. Dtning plant operation this couM disrupt the CVCS system Tables, these these valves quarterly tecause normal makeup ncn telance with tir: potential for causmg severe pessurizer kvel transients valves are full-would te 'mau.nid resulting in p Rs level VCT Outlet od a plant shutdown. Partial-s:roke exer:ising of these valves presents stroke exerosed transients. If ahemate makeup sources were Isolation the same risks and pvv;mm that are assotsated with fu!I-stieke closed at cold inu uduud Le., the RWT or boric acid storage Valves exercising, thus it is aisu r.;;'-- **- f.;.~aig ope ation. This is shutdowns.

tanks. reactor power transerts due to the consistent with the position stated in NUREG-1482. Paragrarti 2.4.5."

introduction c(concencated boric acid cold result in possible plant shutdown or trip.

The thernative povides fu!1-stroke exercising to tic closed position during cold shutdowns in mu.,a.s with OM Part 10.14.2.1.2 (c).

39

i

\\

)

i I

CSF-11 1(2>CVC-SO4-

"Dahs asumi pImat episadam, darging pump sucdom is tous the Per theVaise kis hapsac0 cal so fur.or etache l

MOV VCT wedi anhemp wour supp5ed tem demehmendised water. ShomId de Taldes,ikse theme vehes guarns y. Reecear power mandemns e

VCr level demesse to SS, these valves aum<.usscaBy open mult she VCT vehes useinB-due to te brm

=r4= ef <=rw=m=end boria acM a

(

RWTes escamrge valves, MOV-501, dose so amuse a --al==== supply of sucheenesched tems te RWr could sesuk in possilde plant I

Charring Pump herased waar to me darghis punaps. E els west to ocy a the sedy spen.M etmed skuedown er erly.

l m

Smedan sangen of an =nrem=e vehe domme wouN be segebed haar in te anrieur ataild l

1=namsh-seemarts when mamsdening te darging pump

• so the bedr scid shr1 poses.

The aberusehe provides fun-seeke enadsing so Vahes matemp esuks for emergoucy horasion. Note that these vahes de act the open dad rk=rd pasieon dunng cold s%ualowes j

=W close en a 5IAS. These vehes are monummy opened is accesumace widi OM Part 10,14.2.1.2 (c).

j wiele ese hour fo5 ewing a SIAS to agow te chargimE Pum'ps # take i

ascales tems te RWT to de psessr;%e te RC3 to te ehmednum cooEng f

whideur spon te loss of te hedoc sysseus wie er witout== usary j

i spray.

l l

Enesdaing eese vehes couM seemit in an I=han==aa ke te bosom h of te sencour<=nh==a makeiy and a possitie =Arminable

}

sencearpowerer==alme Parduf sarche entscisingof thesevalvespaesemos ee same risks and permar== est are==varimang wiei fag.serele

====4mI=y thus k is she not fe==ma darkg operasion.1 bis is

}

rnnminnene widi te posiden saused in NUREG-1482, Paragraph 2.4.5."

CSJ-12 1(2) CVC-184 "Itese sue simple deck vehes widi no external usemos of eneedsing er Pt:IbeVahe k is hepracskal to futeache these vehes open posidan ladir=en= 1 hey ase snaked open during mesent dessing pump Tables,these er rinand quenesty har=== of te posessimi for a f

Regnersehe aperaeios and earlag Wj seselag of the charging pumps. The pump vehes se h5-pressedser level mammient II st could cause she plant HeatEndanger tesdag opens 1/2M184 adequesely en pass te Sour seguised by the seeleenesdeed to erip.

ChargingIntet appIkaMe anrid==s ammtyses for sencser annames --h==p however, els is open sad etend CheckVahes

<===Idumed so be a part-stralee test since te nowrene k less dann est atcold The sleessedve provides fu1% exerdsing to l

seguind for case flesti. The Ilowrase seguised for case Amuh rument be shumbow's.med the open med rh=ad posinom during coht i

darged to te RCS dartug manuel epandon as k weedd sequise all=== mist me penimi-shundowns, and persini-esehe enacising quenerfy l

sysmus emMaps and Immly sesuk k =drei mhar pressedner level secheenesdeed in accoedmace wies OM Part 10,14.3.2.2 (b).

====I=a= Verfytag clamme of tese vehes seguises a shundown of die quenedy.

dargingpumpswektwouldseminoen--=v==na psemurtserseven i

massiest and phmt shusense.1 tis mise wadd pInce emeesehe eerami erdes en sysema equipmens due no seernes and espring darging anc iendown flour.1 tis is <=== amer =e wtai ghe posiden same.d in NUREG-1482, Passempli 2.4.5. AdedomeBy. emory ines eis run dertag pIcit l

mpesaden would sesult la sigsMkant pememmet endind-esposee "

I 4

i 40 l

l l.

~

C33-13 1(2>CVC 135 "Itene samme <sesed vehes open seen imMains ammary psessustser ytrteVahe kis -pareir=8sehe erpanies.meheen@

a r

l sysay. In to cuest of a esti leg nresk, te safety a=f==d== puuspo can Tables, these mese vehus spen quaramly har==== emeter wear l

Ammemry k$ses Isso te psessedser via eis Ilme for cose fh-e vehes me fmE-weddbekugad-=dimmelhe -

_ _ _ _ whist r

Ppessedser seclueemesdsed comid muse a ItCS psessuse t===Is=4 med SprayCheck

• Itese sue skapte check vehen wie ao edussi meus of eneedshg er spen andcsosed pseudsMysesukinammage es te usuale vshes poshism.m m,. enesesangeesevehennoseopenposidenwomed acmed a--=rm== ene se eenmal shock.

a

.egebe khhdem ef===m-y psessurher spray now and hjecdom of add shmadowns.

i wiser kno se psessmear spesy samase phchg signiRemmt mennel seus k is hepr=*WE se verth et vehes' abEky e l

em me spray sue sad sprey --* as wes - - my mamaning chue gemedy mar---d se kck da===m d

,j es amend anseer of eenant cycles snowed for me pessudeer --*=

inse--===ah-and me need to set up non-Sect a evoludse condd miso sesmit h an uma,=irahae scarew psesmee leerushe testequipuiest.

l mamelent sad the pettinimi ytsat shmadows er tip. Since they cammet te smeted spen dudas openson. k is seno not passene se make er ne naammeve psestees Ess seche enadming to l

seawese verary csomme er mese vehes. Punkt samking of aese vehes te spen and clemed posidan eming cold semedowns i

psesens ee amuse sees ed pienemas em use===n*==8 wie seu is noemesmee wie ou Past 10.p.3.2.2 (c).

sueIdsg. thus k is sIso sat Simsete enhg ap--h-

[

l i

Due a te sysmus eseAguadom. imemHH-s h*- estas to i

vedry enharcseck vehe's ensame spam ausmoon of Row. Delag cold l

senadown pedoes. ee vehen as te tuer--==a se punk monimoushe

{

l vennessam es seie csomme: newever. eme no meir i=rman-in ne commenant ad egespuesa undumsons, esse vahes e==== nemam ham--a aenhasamusoper*== Aedessansy.nassumeness l

een emet gamur escing samus apassam is 6mpraescas ese is me l

j emeenhey===-aadissom apasse which womu te expu===a s

j nas is --m=== wie me posteos samed h psuiteG-14g2. Parserspes I

t 2A.5 and 3.1.1.

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i SALPINPUT o

FACILITY NAME:

Calvert Cliffs Nuclear Fower Plant Unr.s 1 and 2

SUMMARY

OF REVIEW / INSPECTION ACTMTIES This SALP input is for the Calvert Cliffs Nuclear Power Plant Units 1 and 2, inservice Testing Program third ten year interval for pumps and valves. The review was performed by the Mechanical Engineering Branch with assistance from its contractor, Brooklaven National Laboratory, t

NARRATIVE DISCUSSION OF LICENSEES PERFORMANCE Two relief requests were denied and several require further action by the licensee. There are several recommendations identified in the TER. In addition, the contractor conducted an IST scope review on several systems against 'he requirements of the ASME Code and the regulations. The review revealed three items that potent! ally were not in compliance with the Code requirements,

-With the exception of the above items, the licensee has maintained a focus on safety in the development of their IST p.ogram.

ORIGINATOR:

J. Colaccino DATE: December 19g7 ENCLOSURE 2

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C33-14 H2>CVC-186 "Itsee se shipts clieck vehus wth me enemmel mens of enesdaing er PerlheVahe It is huyerzekel to iestry the vehes* sbley e j

med 10>CVC-yesidum haemdsa.13ey se suuhed spem dustmg W ausdag of Tluides.1 and c9ese qmmeerly baraus of te lack of heemmed 187 14CVC-518 CV and IGCVC-5194V.as weg as te darght pumps. 2CVC-196 sue W and she mood a set upmem-When IGCTC-519 CV is c$esed. Ilow cum pens aseugh efter 1/2-Sudhoche kurushe testegulyment.

Chespag CVC 186 (s4kh is k sestes wie,1/2-CVC-518 CV) er bypass asemed enesdesdepen i

Oisek V dves es desed 1/2CVC 519CV essuch 1/2CVC-435 sad een pass meddecedat 1he ahsmusse psesides vesIAcutan etcleeuse

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esempi 1/2CVC-187 (whie is in sestes wie 1/2-CVC-519 CV arJ eld darbs cate skuelswas in senesdence wie 004 Past It24WC-435). TheseGese, k is h est 1/2CVC-186 (and 1/2-steaduwes,med 10,14.3.2.2 (c).

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CVCA15) se euly pmmemaked estag gunnedy tesling. When 1/2-me punimi-i CVC-518CV is closed. Sow muust suas esendt If2 CVC 187 (wMch seche *===4=ad The Ers==u' senses est h W es Asil-seehe l

k la sedes wie 1/2CVC-519CV and 1/2CVC-435) stesuch it is geseedy.

• ===i=> H2FCVC-186 eram gunnesty,h

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======d es spat equug hasween ymmRel vadves 1/2CVC-519CV sad some now is evened esempi vehe 1/2-CVC-435.

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IGCV 435.1ha=8=== 1/2CVC-187 in dub emeted destag guetedy Yahes 1 med 2-These h a saamat vehe. (1)2-CVC-188 im nestes

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eesst ' ;Jmos esse is ao===r==haa types soupee asemed 1/2 CVC-CVC-187 me wie inhe 1(2FCVC-435, est esute te imeensed h i

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Sun-sesehe esdwto Asp seateemadse(I)2-CVC-196. The emesdsedare Etensee stemtd puuvide a estameise afIlie

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1 A to te system comAgmuden, ammadIIrisms lannumemendem emises to genelymed amep-res,. shy of enesdaing als 2* vdue by l

l vesWy etter dedt gehe% casome spoe====h= et Asur. Dudug eeld fie emete mammesy cessing (1)2 CVC-ISR.

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shundsee pedoes, te vehes am te husemessed es puedt memboushe caudsedclused instandem ef near dessse: hemeser. ese se meer incadem ia ne ateen i

esmemimment ud egulpmeng u=mmes=== esse vaha commet samalm sh=memenes. '

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huanmenteddurtugassuaalap==d=== Adellemony,husammendag een ese genner essess seend ar==='== is *=y==*=' ese ** **

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emeenshe pensames saamass emposse whkh wouse te apedmeed.

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ltis is esasissut weih es peeldom sensed be PIUREG-1452, Passesuphs I

2.4.5 sad 3.1.1."

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CSI-17 1(2)CVC-515-l

• Closing chher of these vehes during operation would resek is severe Fer the Vahe it is WeskM to full-or -JM,.A w A e

CVand 1(2)-

guesaurber level er CVCS systeen..ansieses wkh the potential for a TaNes,these these valves qamrserfy because c(gresserizer icvel CYC-516-CV phaa trip. Im =6thrina such an opersion would Cause unpnmary valves are fuB-transients wkh the poecntaal for a piam trip.

thermaal cycles en the R _- a Heat E- ' p sad, he general,is senke M

LeadowsStop mot a pr=*me actica la the conext of plant operation. If either valve and fail. safe De altermathe grovides full-stroke exercising to Vahes faiint to se epen, am espedoed plant sbandown would be stquired. Partial tessedclosed a the closed position and fasTsafe testing durmg cold -

csosme of mese vahes pesents the same rhks sud probiens est me cxsd shoekmns in accordance wkh OM Put IR aasncinnat with fan closure, thus k is also not feasible dereg operation.

sheedow"s.

14.2.1.2 (c).

His is evenitarnt with the position sented in NUREG-1482. Paragraph 2.4.5.-

CSJ-18 1(2)CVC-$17-

" Opening these vahes would reseit in irnosuon of auxifiery rMs Per the Valve It is isnpractical to full-or gam-s & exo A CV spray flow and lajectson of cold water into ther 6 spray no nle TaNes,these these valves quarterfy trcause cooler water would placing significant thermal seress on the spray line and spray arwvle. as valves are InB-be introduced into the presserhers which could Auxiliary weII as annermarily consemre; the limited number of thermal cycles smokeexercised cause a kCS pressure transient reseMng in a plant Pressuruer allowed for ther 6 marzks. Such an evolution could resak in an cpnand trip and potenuaHy could result in darnage to the Spray thie

- - -4 venrewr-un transient and a posentini plant sheedown ckmed, and fail-nozzle connections due to thermal shock.

Stop Vahes or trip. Partial smoking of these vahes presents the same rbks and safe sessed at problesna that me associssed wkh feII stroking-thus, k is.sso not cold The abernative grovides fail-stroke exercising to feasiNe during operation. His is consiseent with the position stated le shrAdowns, the open and closed positson and fail-safe testing r

NURB3-1482. Paragraph 2.4.5."

durmg cold sheadowns in accordance wkh OM Part 10.14 2.1.2 (c).

CSJ-19 1(2)-CC-3832-

"Ibene mornemily.oren vehes provide flowpaths for coolleg water Per the Vahe it is isnpractical to fail-or gdM,. A exdh CVmai1(2)-

(normal cnoling) to and f>oan so the control red drive awrhanisms.

Tables, these these valves, dy due to the p-dial for vahes me fan-equ.pnem damage ressions frtan tsointing the CC.3833.CV re rwr cooiset panpa, and me se=rinr - M seemn generneor suppern.

oosing say of aese valves dereg piam operation at power win sette a

coonns water supply.

knerruptcoonna owsadcause

~_..,;anddamagesomeassori a-a manfra.s.e n

C-. m Cooling components. Shoeid ary one of these vahes faa to re.open aner tested closed a De anernative povides rart-seuke exercising to Containment closure, an inupassar plant shutdown or trip ed cooldown would cx)Id the closed position and falsafe testing danng cold Supply /Rearn fonow. Paniel closure of mese vahes presents the same risk as fun skuedowns.

shoulownsin accordance wkh OM Pat IR Valves closure; thus it is aho not feasiNe denng operation. Dis is cosesiseent 14.2.1.2 (c).

l with the posittee stated al NUREG-1482. Paragraph 2.4.5.

l Additionnity, consiseest wkh NUREG 1482. Paragraph 3.1.1.4 I

component coat;ng rr===h rw heat loads (such rW RCPS) w(E not j

M be secared solely to test these control vahes "

CSJ-20 1(2KPA-

"These vehes see normally Inr**d shut wkh power remmied b Modes 1-PertheVahe Evaluationmm.wM Vahesarenot ASME 1410.CV,1(2)-

4 perTarede=8 Specificados 3.6.1.7.They are only required to stroke in TaNes,these Code Class 1.2 or 3.

CPA-1411-CV.

Modes 5 and 6 h ee event of a refueling W Dudag all other vehes are fuB-1(2KPA-snodes of opendon, tey -min closed and ase es===d=uy passhe. E sertte M

1412.CV and comenimment purge is esesNished darkg a cold skuedown period, een and faE-afe 1(2XPA-eese vehen wEl be sarche **d however, eey are act necessar9y wedclosed at cold skuedowns 1413-CV opened destag end cold skue$own period. Nose that, if they are act when j

opened they runnin in teir safety poodca and are act required to be Con:minment opernNe wie respect to their a: somatic closme Ai. It is contakunent BuildingPurg::

undesirable to serone these valves dunns each cok! shukbwe shim purgeis Supply /Fdens excesP5e operados can damage te senBag surfams of tese vahes me!

estaNishedand Isolation..

cause degradseios of the vahe's lenk-tight capability which would result at re.%elirrg.

Vahes in addidonal testing, annimeemance, mid cold shutdows extension.

Therefore. eese vehes will be smoke seset during each refueling outage and datog cr sa shutdown periods whenever contunnent pwge is estsNished. Pardal closure of these vahes presents the same risks and probians shut me amaramt wieb fun closure; thus k h sho act feasible during operation.1 bis is consheent wkk the :W4aa stated in NUREG-1482 Paragrark2.4.5.(N01E: FollowingcompeetiontIESP94-205 she outboard purge vahes wlE be ehminated and the lines wiB be blanked in Modes 1-4 to provide comminment integrky.) Note hat tese vehes me mot wkhin the ASMEASI class boundaries."

CSJ-21 1(2)-HP-6903-

"Inese mannnEy rin=t vehes are required so semain closed during power PertheVahe Evaluation not.4'.;d. Valves are not ASME MOV operation per Calvert CIlfIs Technical Specifications. If a vehe were to TaNes,these Code CIsss I,2, or 3.

fall be te open posities during tesung, then prknary containment vahes are fuE-HydrogenPurge ineegrky would depend on a single rhar* vehe (112-HP-104) heside serokeeserched Supply comeshament whose position cannot be verified. In this case, a plant rir=d ar cold Isolation shutdown would Illuely be required. This is consistest wit the poshion shuelowns.

Vahes sented in NUREG-1482, Paragraph 3.1.1(2). Neee est these valves are agg wiele the ASMEn$1 cles basadsries*

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CSJ-22 l lCZFFW-130 "Ibese monsapy.open rowet -alves povide flowpaths for monmal PertheValve It is L,.d.m* 30 Jy closure of these valves and1(2FFW.

feedweser flow ts the serum generseort Dey done to isoiese the *e=

Tables,these quenesty beanne testing would nesuk tw a piam valves are fa8-trip.

133 generneurs and the non Code ponions of te main feedweser sysean to serefteenacmed pevent back-leakage of seemmi generator hvemeory imeo the amie Steamn feedwsaw system when te mais feedwater puunps trip os a ESFAS closed acold The altersamve provides full.senke exerciseg to skuedowns.

the closed position during cold skuedowns in Generseer signal ami te feedweser h=bes depeasurine.

.u.4.u. wkh OM Part 10.143.2.2 (c).

Feedwseer Supply N+

Enescising eese vehes to te dosed poshion requires securing feedwseer Vahes fbw to se associated steam generator. Dwing nonnat piset opermson at power. this would sesakin a severe plant transient and trip. Partial closure of these valves presents the same risks and problems that ars namaried wish fuE closure; thus, it is also not feasible during operatson.

This is consistemt with the position stated in NUREG-1482. Paragraph 2.4.5."

CSJ-23 1(2).FW.4516-

"Ibese monumRy< pen valves provide flowpaths for sonnel feedwseer Per theVahe Itis 6 Adcalto full-ormiL!-b:s exeds.c 3

MOV and 1(2)-

flow so the seesse generneors. They close on SGIS to isolate the seena Tables,abese these valves quenerly because testing would (for valves are faE-fan-stroke) or could (for partaal-stroke) result in a FW.4517-MOV genersoors as initigate the effects of a seenaline break, to isolate the non-Code pornoms of the annia feedweer system, and to prevent hrtimirnee stroke ax4 plant arip.

s*sen of seems semeranor inventory heo the semin feedwsner syssem. In the clonedacold Gemensor evenst of a stemma generator tube leak. eey wooid be closed by the shuidowr.s.

The alternative svovides full-stroke extrening to the closed position during cok! sheadowns b I edwseer opersoor to prevent over.feeeng the affecsed seemas gemensor.

accordance wkh OM Part 10.14.2.1.2 (c).

e Supply Isolauon "A (cheing) these vehes wie resuk in seemrkg Feedweser flow to Vahes the assarissed seessa genannor. During moramal plust operation a power, his would sesult is a severe plant transient and trip. Paniel closure of tese valves wEl cause severe trussients in seesnt generstar wseer level with the posendal for a plant trip. Partial closure of these vehes pesans me same rbbs and pobiens est me assoried wie fort closure; thus, k is also not feasible during pimat operation. This is consissat wini se poshion stated in NUREG-1482. Paragnyk 2.4.5."

CSI-24 1(2).IA-2085-

" Closing these velves wlH isolate instrumment air to te r-aminunent and PertheVahe Evaluation mot required. Valves are not ASME CV secure operseing air to several contposents critical for pimit operation Tables,tese Code Class 1.2, or 3.

hcimens e penserher spray commet vahes. If me vehe were to fan in vehes me fan-m t'meninmeme the closed penklon, a plant skuedown would be required. Panial closure seekeczescised Aircontrol of eene vahes pesents me same rist as f E closure; aus, k is also not nur fas. safe Vahes feasible during operation. His is ev= l ame wkh te ponhboa waard in testedclosed at NUREG-1482, Paragrupt 2.4.5. Note that these vehes are act within cold shuelowns.

the ASME/ISIches boundaries."

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CSI-25 1(2NA-2066

"! bene are containssent isolation valves dar nuexiome on CIS. In the Per thevahe E,.a==elam not requbed. Vahes are not ASME

,l MOV course of an arretar k may be seguired to axrnee CYCS vehes CVC-Tables,these Code Class I,2, or 3.

517 CV,CYC-518-CV.and CYC-519CV for core finah or =**my sud vehes are fo3-('amashumens vehes k tie PASS system, thus re open'ng these vahes would also be smok enerdsed Air Supply segeted. Note that tirse vehes are act within the ASMFASI dass open anddosed mcold Vahes br9auksles.

rbuedowns.

Oosing these valves isoisses operatsng air to several components critical forplant operm'en including the yn.6 spray comeret vahes.

oosing aese valves win isoisse insernnent air so the coniainment. rr the vnhe were to fi2 in IEe clocad position, a plant shutdowa would 12 required. Panial closese of these vehes presents the same risk as fnB

(.

. desure; thus, k is also not Ft:asible during operation. ' Ibis is consistent with the posleka sented in NURF'2 1482, Paragraph 2.4.5.*

CS)-26 1(2WS.4043-

"Ibes c eves close on CSAS and SGIf to prevent the unrestriceed Ptr the Valve it ir, knpractka a, fnE-stroke exercise these valves CV and 2[1).

release of

• men from nrdtiple steam generators in the event of an Tables, these quarterly because testing would sensk in a plant MS-4048#V upstream *=mline impeure and to isolate the steam genersoors in the valves are fuB-trip.

event of a LOCA, enema generator tube rupture, or downstream steandine senkeesercised niale Sneans repa.s Wher dosed, they provide isolanon of the uneh: sed mam closed atcold "Ibe ahernathe provides full-smoke exercising to Isolation gervator thus mouring an adequese supply of seesen Fr AFW perup i - L.. and the closed position during cold shutdowns an '

Valves turbine opersalon. 'Ibese val,es sue seso required in

• N per are partial-m '.A esercising q.arterlyin accordance (MSIVs)

Tedesical SpecifL1nhas Para. 4.7.1.5 (ITS 3.7.2.1).

smokeexestised with OM Part 10,14.2.1.2 (b).

quarterfy.

l During plant openske at power, this closure of any of shese rahes l

would sesult in a major plant transient and a turbine awl rentsor plant erip. nw.se vehes me provided whh the capabiBty of partial smoke (closure) enerdsing whkh can be perfonned at pcwer wkbout jeopwrdizing plant opernelon. " Ibis is consis ent weh the poshiot la NURBO-1482, Paragraph 2.4.5."

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47

C5J-27 1(2985-1E "Itece ase shaple cd.eek vehes wie ac attemet mams of enudslag:

Ptr theVahe k is heprucskal to fuB-seeke enadse these vehes and 1(2985-eus, the caly praesical means of opening these valves is to opusse c:st Tables,these opem quenerly har==P ee hooducdom of 106 _

seemmHirhen AFW pump diantarging to the deem ges,erseers. I;uE vehes see fuB-stimehely cgoter water Dom the CSTcouhl seche emesdelag of tese vehes seguises operastag each steam 4 hen socineeneedsed posemelaBy sesult in d===ge ta lhe s'P"" Bemaanor l

M alm Seer,

AFW pump at esE sederut now ens requiring==i=== seeman fkw e open andcksed mondes due to termal shar* ine gennafy IkakoAPW te turtime. During plant opuasion at yower, els is not pracdesi due to nacold seselug ofIhe AFW punips k te whimune now pump nutismes ne posemeni er eenwal *=* of ee samum Semesseur =ne sad shak=ns,and usade wound not smay opra se seems vehes.

Check Vahes natuaals. During arsertedy testing of the AFW pisaps, flow is roused me partial-l enough a minkaan now seekeuhtion Ihne; thus, partial flow exacishg smokeeneedsed 1te sleernmelve provides fur-smoke emerdsing to usly is pe=r*=t The test for verifying closuse is v Mj quartsty.

ee open position during cold skuedowns, and cumbenoese and sequhes eve =dve system seal:g enent and resources and part'ai-earche enadsing quarterly in acconimate an ex -lad period thming which te assochaed AFW pump it out of whit OM Part 10,14.3.2.2 (b).

e servke lbum, k also is not pr=r*=t during piset operankri. His is r=dssame wie the position sented in NUREG-1482, Paragraph 2.4.5.

The licensee senses shut the test for verifying closureis M, cumbersome and sequres Alternativdy, these rM vnhes aury be nombintrushely neonitend extenske systems realignment and sesowces and an doing fud-flow tesfag of the AFW puutps when sach sessing is exerment period doing which te amar=4=aaer AFW performed during a cold shundown period. Hvaever, due to melt service pump is out of service." It appears shot when each exiaditions, these rear

• vaM can not sesmain baserucaented dwing AFW pump is na.aart the other pump's associated rear

• vehe is closed. Without additional marrael operulon. Esserumemelag them epch quarter would presamt personnelhaamsds due to the'..JWation sad service condiennne infonastics on te test =rehruf used, te besta for (addiciamany,it is unlikely they could be hmeramented during every cold deferring lessing is I=-laryme.

shmeawa), sad k is ont Ikely the steam flow shrough skese eter* vehes resulting froma AFW pump =Iminem now teag is sufflear=r ao fMI stroke dese checttvahes."

CSJ-28 1(2)-MS-10g.

"Ibese me shople rear

• vehes wth no external espana of enesdelag:

Fez theVahe It is imipractical to fwE-smoke exacise these vehes and 1(2)MS.

eus, the only precekal unrama of opening these valves is en operase er A Tables, these opes quenerfy har==e te imepwtudr= of 110 seesmHkhen AFW pamp discharging to the seems generators. Ibl vahes are fwB-seisthe y cooler water Seat the CST could sache e=deing of aese vehes sequhes ependag each seemmehen nrateexadsed pos-d myresumiadamage=te== generator AFW pump at fut arves-e fkm ens seguiring annimuma seensa now w open atadd mar *e due to eenmal shock. The quenerfy Mais seems me turbine. During phat o;rension at power, his is not pracdet due to shoukmas, sad aesting of te AFW pumps b ee micimuma now HendereAFW te potendet for eenmal aw* of ee stesse generaeor = area auf meperdel-mode wouhl not fuGy-open ne scese vahes.

Pianp T ubines heatraals. During quenedy testing of the AFW puseps, now is scused smokeemesdsed ChedtVahe

• ough a manhm== now sechrmanh= nee; eus, perdel now exaching gunnedy.

De alemanshe provides fuM-seche enesching m only is pr=r*=a 1 tis is commiseer* vie the posidos sesed h NU'tBG-ee opre posidos dwing cold stundowns, and l-1482, Paragnph 14.5."

punisi smote emadsing quenesty in acoudmace wie OM Part IC,141.2.2 (b).

I l

48 J

CSJ-29 0 N2-344 and "Ihese ese single caeck valves wth as exemuel means of enerdshg er Pershe Vahe Evan=mina act seguised. Vahes are not ASME 0N2-34T penales imamsann; ens, verrylag me sleky of tese chedt vahes to TaMen, mese Code Cines 1.2, er 3.

csose segshes eonashouma necess m e-ra-eum apen, fonowed t. a vahes se res-Nksegen teck-lemmage sess. Sgd necess is act ynusical en a seusine 9esis during sueleeneedsed Sq,sy no penn epasses at power. nese esck vehes me normany esosed and ceasedascase Sasseylajecdos easy need es paeans meer aceve caeume senahn in me event as arrad=e skuedones.

TanksOmened cusased during almogen addetson to the STIS. His is a sehehesy ChedtVahes beegseat opension and ese eCshort durselen. A&ehlmany, gyse reart vahes see in series wth 1151/91,1/2 51492,1/2 51-493, & 1/241 l

l 494. His poshion is en= miens wie est set for2 in NUREG.1482, l

Paragraph 2.4.5. Note est dere vehes me not wkhis se ASMEllS1 chesbousomhs."

CSJ-30 1(2).RC-16 "Enese vehes see seminisersehely comereged in te csoned pooletan to Per meVahe k is kapir=I to fsil-er penial-smelne eserdse SV and 1(2)-

prewst hadvertest operadon. Since mese me Class t racearconhet Tables,eene eene vehes gunnerty tecumse tesdag darks fower l

RC-1%SV syneen innhahm vehes, falhae of a vehe to close er:eakage tonowing vahes me fus-opension couMJeopardhe te integrky of te RCS csmane couM resuk in a ines of coolam' in excess of me uses -pne-d smeneenadsed pessee bounday.

s a

Ptessuriser by te Plant Tecksical Sped 8teselons necessioning a g?mmt aimaamwn.

openand VentVahes Perthernsore, faleur of she vdve o huesensa a secur; e lhe fully cioned renand andfaB-De sherquehe povides felleerslee eserchW to position foBowing enesdain; could IE6fy sesult I w.osemismuut emery safe sessedat she opes and rinand position sud fail-safe sesehg at power er a pInsi abunker.. Partial-serche eneedsing of eene vahes cold during cold shutdowns in accoudencu wfeb OM Part presemes er same rhts ano pseMens shot me meanramand wie fier earche skuedowns.

10,14.2.1.2 (c).

eneseising; thus, k is seso not frwdhia during operation. Dis is enemi-me wth me poshion seated in NtIREG.1482, Paragnph 2.4.5."

CSJ 31 1(2).RC-10nE-

'Due to dymemie flow casuRelons in the sencane ennamme syssess under PersheVahe k is imprarearm! to fuu-sareine exercise these vehes CV and 1(2)-

sonnel seresshag en=Mame sepesemble fuB-emelee test sesults for :htse TaNes,eese guanarly because the teet wouhl result in a RCS RC-100F C'l varves me not poselble; thus, tese vehes can caly be tested during ceId vahes are fis5-psessuse deaesse which ceald cause a eransiest er ehmedawn periods when sesNe test comettons can be estaleshed. (these sereineenereised plant skuedown.

Ptesember ev=mstres amensam securing RCP s and depessurhing me RCS, boe of andfaB-ense ildi anhimbe ver mennes in Sour through, and effensdal psesnue sessedrinand at De sleerusehe povides $sil-sereine enerdsing to <,

a Spray Valves aates, these vehes which could affect their perforw*ance.) Addisin=asy, celd the s4nand poohion and fab-sese tesdag during cold f-fun. seeking mese vehes wtue ne p ast is pea.orised wel cause skuedones,and messowns, and punh8-smehe exertbing gunnerty q

signancya sad -==ra s* --ene r=n= symem pensee e-.n, men mepenial-la acconkmee wie OM Part 10,14.2.1.2 (b).

Dese vehen me pne-serehed en an esW tesis in enter m amhnann seekeensched psesehse cebuel; whee es pImmt is peesurised. His is comslesent wis.

quarterty.

es poshion smeed in NUREG-1482, Parayaph 2.4.5."

C$f-32 ) tabitC-105-

"Inesevahusmeopenedasneededtoveutrr gasestrupped PerheVahe

'ItbimpracticaltofluB-er,.C _J er scase

%Vand 1(2)-

h es==renr vessel hemd dudag sammal secteutnelos to =h==r* case Tables Gese theme vehes quartesty becumse tesdag during power i R:-104-SV coolks. If opened during ar*M'me seconry, they wlE sespnse se clashg vehes are Em3-opension couldjegenNee te t.gr'ey of the RCS h ender to conserie senceur n=hms leventory. Tesdag is segebed per setteeserdned pressuse boundary.

RectorVessel ibdmical Speetkaales 4A13.1 (f13 Technicut Requbessemes Maarmi).

openand cene,tsadth5-1te shamedve pnnddes f:di-strate eneselslag to VentVahes 1hese vehes are almdmisernshely comeroBed in ibe renana poshium to sese e t ec open and can=ad peeldom md thB-safe testing a

presesainadvertent operadam Simee tese are Class 1 sencsormah=r cuid durtug cold skuedewes k anxesdence with OM Pat syseems lananden vahes, faBue of a vehe to close er leakage sonowleg shsidowen.

10,14.2.1.2 (c).

closure could seemit in a loes of coalmet is excess of the Endts hsposed by he Pimet Technicsi $pecificadoes =*reedsadas a plant ihmtawa.

~

Perthersmose, lhilure of he vehe to heuresa a seemre to the fJiy closed I posiden followleg esercising could IBely resmit in a r=enimmene entry at power er a penet skuedows. Panial-sercke esercising of these vehes presones te same risks and prettsas that are associated with fee-stroke exercising, thus k is also not feasilde during operation. This is en=de=s wie 6e posidos saled in NUREG.14s2, Paragupt 2.4.5."

CSJ-33 1(2)-RC402-

"Inese vahes provide overpsessure psotecsion for the senceor moient PertheVahe ibe PORVs are locased downsecam of the block ERV and 1(2)-

syness wN Elting a pressertarr safety (shese are vs.h-abet to the Taides, these vehes. Thesefose, enescising tese vehes wul act RC-404-ERV psessertner safety vehes and are not cs ume in de FSAR. abhough vehes are foe-direcdy sesult is wacsor coolant psessure transients.

Tb=e ar=8 5pecificaeic m allow csediting a PORV frv a lismised tisse ifIbe queleeserched However, ghes the single failure of the PORY ERYPt ser-presserteer vapor veut gut is hoortrutde). Also, they protect the seactor open, full-sale block valve. k k inspractical to czecise these Opsaner1temef coolant syneam Deus over, -_ _

- * -whenthestectormolsetsystem sessed and ses-vehes gunnerty. Generic temer 9046 (Ref.21)

Vahes is cooled does toless een MPT(L10P).

point teseed at senses shot testing of tme PCRVs should not be cold perfommed during power operados due to ele rhk nh r thE. er pare-smoking of mese vehes deitag power amension ens senadowns.

assors=.s wie chenemging mese vahes in mis e--man-causemismuksetand.==r-v==marresenorcontenm==-d =m-Addelonally, such seekhg makt also seseit in te failure of one of these vehen so nesent propesty which wo id tend to syseemdequipmustemense, The sherumihe provides Iwi-suche exacising to seduced phet selistdaty, and a poesitde plant skuedown.1 tis is the open posiolon and faH-safe sessing during cold en shame ute te posidos eased in MMEG 1482, Pungraph 2.4.5."

shutdowns k accenkmee wie OM Pat 10, 14.2.1.2 (c).

i k%

3o I

f\\ggy ~ ~ ~

~

i

I Per the Valve It is knpractkal to full-seeke exercise these vahes CSJ-34 1G) SI-113, "Ibese check vehes open to pouvide flowpmes for HPSI inso the reactor 1G) SI-123, coolant syssem.1 bey close to prevent eversion of LPSI into the HPSI Tables, these open during plant operanon because she HPSI 1(2) SI-133, braneres and can serve as an optional neactor coolen pressure isolation valves are Ten-pump escharRe pressure cannot overcome the RCS and 1(2)-51-143 vehe.

smoke excretsed pressure. The licensee has included shese vahes hi open andooned a Cold Shutdown Justification, hou;ver, the Vahe HPS1Hender 1tene are simp > dedt vehes with no mesas of external position atrefuella and Tatdrs inecame that these vnhes will be fur-samke j

Isolation Chedt bdkzelon or operation. In order to open these vahes, the HPSI pumps are pernal-exercised daring refueling. The Joseficanos does Yahes must be operased with helection into the reactor coolant system. " Ibis smuke 6,4 not discuss the impr.cticality of testmg these cannot be pertonred denng pant operation at power because normal quarterly.

valvo der;ng cold shutdowns.

RCS pressare is above the shut-off head of the HPSI pumps. RCS l

pressee cannot be lowered sufficiently to pt. 2k fuu-stmke testing these AdStionsfly, the licensee has not mC,:

vahes unless te plant is shut down. These vahes ase part-stroited justincanon fordeferrmg closure verification of exercised open quarterly and whenever the assnriseret HPSI pump is these vahes. The licenne should revise the Table operated to GE the safety i$ction tanks. Thh h coniseent wkh the orJustincmion accumngly.

poskion stated in NUREG-1482, Parag sph 2.4.5."

CSJ-35

14) S1-401 and "Ibese check vehes open to provide flowpaths for water from the RWrs Pertic Valve it is impractical to fuB-seeke exucise these valves 1(2)-51-410 or antainment sumps to the HPSI pumps during SIAS or RAS.

Tables, these open during plant operuuon because the HPSI valves are full-pump dsdiarite pressure cannot evercome the RCS HPSI Pump These are shaple reen* vahes with no means of external position samke exercised pressure. The bcensee has included these valves in Suction Chedt indicadon or opershon. In order to open these valves, the HPSI pumps open at a Cold Shutdown Justification, however, the Valve Vahes suust be operated with inlection into the reactor coolant syseesn.1 bis sefuel'ng and Tables indicate that these vahes wiR be fuM-stroke cannot be perfonned during p'- it operation it power beasase nonnel are partm'.

exercised drum refueling. The Joseficanon does RCS pressure is above te shut-off head of the HPSI pumps, RCS seekeexerched not discuss the..o.iicalky c(sesnog these pressure cannot t s lowered scfliciently to pennk fv8-smoke testing these quarterly.

vaives during cold shutdowns. The licer see should vahes unless she plant is shut down. "Ibese vehes are part-stroked revise the Table or Justification accordingly.

exercised quarterly. This is musistent with the poskion armeret in NUREG-1482, Paragraph 2.4.5."

CSJ-36 1(2)-SIA05, "Ibese chedt va:ves open to provide flowpaes for water from the HPSI Per the Valve k is knpraulcal to fun-stroke exercise these vehes 1(2)-SI414, pumps to the HPSI discharge headers during $1AS or RAS.

Tables, these open duing plant operation became the HPSI I

and 1(2)-SI-427 va!ves are fuB-pump escharge pressure cannot overcome se RCS These are simple diedt valves wkh no nicans of external position smukeexerched pressure. The Bcensee has included these valves hi HDSlPump bdication or operation. In order to open diese vehes the HPSI penps open at a Cold Sheedown Justification, however, the Valve DhcharBe must be operated with blection into the atactor cooient system. "Ihis refuehng mal Tables indcsee that these vshes wiB be ful:-seeke CheckVahes cannot be pa._/ during plant operation a power bemuse nonnel are pernal-eneseised dwing sefuelag. The Jusdficaem does RCS pressure is above the shut-off head of the HPSI pumps. RCS smokeexerdsed not discue the lampracticality of tesdag these pressee cannot be lowered sufficiency so permk fun-seroke testing these quarterly.

vehes daring cold skuedowns. The licensee s%ould vahes unless te plant is shut down. These vakes are part-stroked revise the Table or Justefkation accordngly.-

excrelsed quarterly.1 Dis is ansiseest with the poskion sensed ha NURBG-1482, Paragrsph 2.4.5."

51 I

t I

C3J.37 1(2),33434and "1tese vehes opm a povide nowpons than te IPSI pumps so the Per teVahe -

k is kuprarearnt so fuB-smoke emescise these vehes 1(2).5I-446 low psussure impardam hender.11ey dose to pever; sechcubake Aow Tables.Ibese open quenerly h the LPSIpump m=*arge esough an ime pump and.a.n-

= now mee est m ms advenesy vehes me fus-psessure- -ae o nemme me acs psessee.

secteenesdeed j

LPSIPump kupers te edBouhemess of the apessehs pump.

epamandclosed 1te shenashe porides,Z _M enescising Dimetargs ne*Vshes 1tese me staph ched vehes wie no ensensi mamme of enadslag, das sa cons gementy med IW.esehe enecising to me open enacinhag (open) segehes operadas al131 pump at full now mus skuedowns,and postdon dart.ag told skuedowns in mem4 mar

• wie hjecsing hem the seactor amaamm systems. At power opesatlas, this is me panhl-OM Part 10,14.3.2.2 (b)..

not poseshie t=e=== ee IESt ymmps cannot develop sunHeat dhcharge secheenadsed The n==== bas not however.mer-mard the u

pressee to ovesense seersor consent syseemi psessee. 'these vehes me gunnerfy.

g _^E " emesdsed quanerty. This is consistemt wie te poshion leprardrm.:ry of r ".,

'., a closure test smeed ia NUREG.1482, Paragnph 2.4.5."

quanerty. The Vahe Tatdes idemefy that the vehes wW be exerched closed during cold skuedowns. "Ibe VaheTables orJustincasion should be sevised scarqEngly.

CSJ-38 1(2Hii-639-

"Inese vehes provide nowpees for snimiusuut flow prosecdon. When Per s'mYahe h is* y --- 1 :toexercise6esevehesquenerfy MOV and 1(2).

power is ressmed, linse vahes close on a RAS to blodt recirniadam

' Tables,these due to the ; _rW for pump damage and syssent SI-660440V Dow tout seemming to the RWT.

vehes are fee-failure if the vehes should fait closed during secheenached tesdag.

l St Pump Mini-lmme of elder of these vehes ischees de mir%nues recirculados r*=ad at cold Flow Return so fkywpee for a5 ee BCCS pumps hcm tee mains causing mR safety abnedowns.

The shamadve provides fuu-seche enescising RWTIsolados injection and comesismunt spray pumps to be inoperable. Failure of dais,g cold shshwes in acceed==re wie OM Pat Yahes either of eese vahes in the closed position dwing esting wit pehlhir 10.14.2.1.2(c).

How enough me h fiew sedrculation lines for all of the safety hjeedom sad e spray pumps. Due no me potabsby of Gamage ahnmid etse pumps be isaned and opended la this enedhire (no How),enestsingof tesevahesstemIdonlybe

'duringcold ahmanse pelods wheS eene peups me not requhed tobe opemMe.

Pareas doene of eese vehes pesens me same rtshs and pobiens est are n=maelmand wkh ist closuse; thus, it is also not feasible stulag operados.1 tis posidos is

• with est of NUREG.1482, l

Paragraph 3.1.1 (1)."

e 52

)

CSI-39 1(2)-51 114 "Ibene sonnany<losed check vdves open to provide flowpaths for Per the Valve it is impractical to fun.strt*e exo& these vehes 1(2).SI.124, barseed weser front the LPSI pumps to each of the RCS cold legs. Dey Tables, tese quanerty because th LPSI pianp dhocharge 1(2).51 134, close to isolate the LPSI syrtest frorn the HPSI lajection headers to valves are full-pressure cannot overcome the RCS pressure.

and 1(2)41-144 prevent diversion of HPSI flow ::: the low y,we LPSI piping woke exercised and ions through the assodated relief valve and casa serve as an gtional

<5en armiclosed De afternative provides partial-seeke exercising LPSIHender seactor coolmat pressure isolation valve.

at cold quart rty and full-stroke exercising to the open shutdowns, m.1 poution during cold shutdowns in accordance with Isolation Check are partial-OM " art 10,14.3.2.2 (b).

Vahes Dene are shnple chedF elves with no external means of exercising, thus exercising (op requires operating a LPSI pump at full flow and smoke exercised injecting into the reactor coohnt system. At power operation, this is quenerfy.

De basis for this justification sentes that these it not possible breanee the LPSI pumps cannot develop sufficient disci rge valves wlII be verified closed.p..uif. Tie Valve Table, however, indicates that these valves will be pressure to overcome seactor coolant system presw~.e. Dese valves ee full-stroke exercised closed at cold shutdowns. De part stroked exercised and verified closei quarterty. His is consistent wit % the position stated in NUREG-1482, Paragraph 2.4.5."

scensee should exercise / verify closure cw-actly, or ;

I provide additional information tr,jusdfy deferring this test to cold '..:.;u a.

CSJ.40 1(2).St.118.

"Icese valves provide flowpaths for borated water frera the HPSI and Per the Valve I:!s impractical to exuA the valves fully open 1(2).51 128, LPSI pumps to each of the RCS cold legs. They close to isolmee the Tables,these quarterly because the LPSI pump discharEc 1(2).SI.138, safety inlcction sysetas from the stactor coolant system. They also serve valves are full-pressure cannot oveicome the RCS pressure.

and 1(2).SI-148 as pressure isoistion valves (P!VS) during normal operation.

stroke M

open rad closed in the basis for the deferral, the licensee states that SafetyInjection Dene are simple check vehes with no external operneor for exe.cising, at cold the va*ves wiH be partial-stroke exercised whenever HeaderIsolation thus C.,;(open):equires operatmg a LPSI punp at fwR flow sid shutdowns,and the assorinard HPSI pump is run to fill a safety Check Valves hajecting into the reactor coolant system. At power operation this is not are partial-injection tank. In tLe Valve Table, the beensee possibk brenmee the LPSI pumps cannot develop sufficient discharge strokeexercised indicates that the valves will be partial-stroke prwure to overcome reactor coolant system pressaut. These valves me quanerty.

ssM quanerly. If the HPSI pump is not run l

part.seroked exesdsed open when:ver the sawvinsed HPSI pump is run to quenerly to fill the STPs, then thejustafication j

l ftp a safety injection tank sul verified closed quarterly. This is should provide additional infonnation in supporf manhnene with the poskian mased in NUREG.1482, Paragraph 2.4.5."

the bases that partial-smoke exercising as knpractical to perfona quenerfy. The basis of CSJ-34 sentes that these valves wBI be partial-I saroke exercised open quanerfy ad whenever the HPSI pumpis operated to fin the SITS.

(

i 53 t

~

l o

CS;41 1(2>S:458-Ikese norunny choed vahes are opened tonenmar sinadown cooling.

Per theVahe k is imiprocucal to full-or penial-smoke emesdse MOV and 1(2).

TaNes, tese te vehes opem quenerty due to the poetrtial for j

$1452-Mov nese are pressee i= nam *= vehes which lookse ne high pressee RCS vehes are fee-equipment damage em to ovesguessuhasion.

piping fem me now w = dawn coomms piping. ney are secheesemsed m

meer nr**d wkh RCS presume and csanot be opened a power. Pantal-open atceM De shernedve provides fuM-eache esatising to Soc Reems a

HenderInnassann suche eseedslag of eene vehes psesents the same problenes est are shumbums.

the open position during coM sweaivwas in Vahes

== mar *and wkh fuB-samue caercishg: thus, k is also not feashle during acxxudence widi OM Part 10,14.2.1.2(c).

f opendon. His is r=mmamarme wkh me poskien seated in NUREG-14s2, Paragraph 2.4.5 "

CSJ-42 1(2)-51-491 "Dese vehes close to essee the imeegdty of the safety 4pament prusure Per she Vahe Dese monumEy renant rter* vehes me larmant

{

1(2)51-492, han=dary of te safety inlection syseesa.

TaNes, these inside amen==rme and provide isolution between

}

1(2)-51-493, vehes are fsE-the Si and niengen systems. Two conesiassent l

and 1(2)31-494 Dese checit vehes me nonmag closed and only need to perform meir seroleenescised helados vehes (a check vahe sad an air operated t

y acthe cloose functlan h she event an accident requiring See StTs is closed ataid vehe) are larmaal upsereams of me suisect vahes.

l Safety hqardn=

imaniment whee almogen pressure en one of the Stis is being incremed.

shutdowns.

k does not appear to be isnprwtical to veri ~y TankNimogen (Aashirmany, tese chedt vehes are in series wie O-N2-344 & 0-N2-closure of Ihese vahes during power operation.

l leiet rhm*

347.) Since eis is a selethely infrequent and short duration evolution De test connerssoas see Inement amende j

Vahes affectirg only one SIT st a timie, tesung these check vahes t,anerly ennemi==rme and these is no seseriction to opening l

would signifksetly increase the ilme during which the plant is dependem

' cae CIV, unless the oder CIV is inoperable (See upon their seshe closure fianction. Sede a test would also incycase the discussion in NUREG-1482, Secelom 3.1.l(2)).

l thne during which me ad-amiesrathely comerMed upseemn ennem3== rat he licreare has stated that these is a concern wiga 7

lenamelan mamel vehes (1/2-CV-612,622,632, & 642) are open. More radiation expomme, however, the tirenere has not

[

9equent testing wouhl seguire increened personnel rudimenn ewpn==e med psovided specific intonamnens as dier==eri in present more eequent aan-e=== in widch posendal component faihme or NUREG-1482 Sar*E== 2.5.1.

human error could effect the operabitty o a StT and place te plant ha a r

very short-duration arenne mamar=,me Dis is enmaaempen whh she he Erw==== bas saaed est these vehes are opened i

posillos sented h NUREG 1482, Paragraph 2.4 5."

reladwely inerequendy and for a semit durath,n.

m ne i==. shouM acee est vehes need not be -

mashiered acthe if eey see only temporarily erunoved firent their safety poshion for a short period of time, as amar===ad h NUREG-1482,

[

Secelon 2.4.2. If the vahe is sr= sanely l

s*pe=l*=~' darks power operation k would he

[

eensidaedacthe. ne ce mar shouMveview the s

chasificados of tese vehes and,if s'reemary.

l l

sevise me tST riognan io imenia g=aaty eesthg.

t orp, ovide adadomat - "-

f I

54

f C3J-43 10)J8-313and h me shaple dwck vahes wie ao meses of external posidan PerteVahe The Ilcrasee sestes est"he order to open these 4

~

1(2)43-323 ladirmerus or opuselor. In order to open these vehes, the w-kment Tables,these vahes, abe h spray pumps snust be valves me fuB-opermoed whh i=jereien beo the camanissneer spesy spray puseps siest be operseed wkh injecalon into she e==ama===*=s spray cassetsusene n =dr=s. nisis==draarableaskwoukisesakin sprayinge==a===i mard sarcheemmelsed headers " However, k is hepr=r*=r to full-seroke Spray Pump barated wasarime te aa= aman,me sesuhing in equipment n====minadam open at exacise these vehes in any oper=d=rar made Dimeberge a:d demune. The cheeshonent spray pump deart=rge bypass Emes do not sefleeliqr and using me comenismunt spray header. These vehes ChecitVahes snow sufficient flow to full-streke these vahes during quenerly pump are partial-are disosseed in Cold Shutdown Juselfloselos sesehg. Dese vehes are part-sereked geenerly. "this is constrtent wish sockeesercised Numter 43, however. in the Yahe Tables, tese.

she poshion sessed in NUREG.1482, Paragraph 2.4.5."

quenerly.

vehes me idradrhi as being feh-seeke emesdsed during refueling. The Ecensee does not discuss how orwhen me vnhes win be sessedin me Joselfication. However, as disenssed in Relief Request PR 06 addressing the coh sprzy.

pumps, mese v2hes esa be furtarw sessed subselasting the CS puesps for the LPSI pumps in shutdown cooling Eneup aner sufficiens decay heat has been renieved. k appears est mese valves was be fur-seroke exercised during cold skuedowns of srflicient length. The Bcensee shoeirl provide adokiones information in this CSJ to support deferring genreerlysessing.

O b %

l 55 LMGE

CSF44

10) SW-5I#-

"Ikese

,i-avehes scanda closed to holume the 11 (211 perIbe Vahe De Ikrosee smees that the nommel way to opem CY sakwater supply headers Semi te Bnergency Overbaani sekwater Tables,tese these vehes is to opes one of the vehe pairs. k is

=--

vehen are fun.

not apparest frasi te P&lD whesher the vehes m-*-se nowpmes as es key la erder to emane sonnat now of Essagency sakwaser is malassised n she componemes sua best G

. cooled by secheestuded carr "ue opened astre te everride headswitch HS-Sakwater me 11 Ql) sahwaser trains Under Emergency Overband opensioam, open atceid 5I@, wieout openhg 3 vahe pair. As evalunged standowns.

In CSI 45, !t is lepractical to opense 4ese vaim Diederge to eey see apened to provkle proper ovesteenf Gowpmes.

If k segelses one of the three vehe pairs to be Bay Innesdam Vahe Opension of ee:m vehes is lied to opermeios of the timee vehe pairs opened due ;o a loss of syseem fuscalon.

CV5155 & CV51.% CV5165 & CV5166, and CV5177 & CV5178.

De== man way to sarche CV5149 is to open one of these vahe pairs Addisicammy, k is impranied to opense these vehes wide the backup altogen tanks ghes de using the agucpriate handswitch. However,enth of these vahe pairs is aparated fnet a single handswitch and prevemeing thema f em opening in test setup. Derefera, provided that the vahes enkt so opense CV5149 alone would regehe placing eeni in as commot be operused adag HS.5149, she sheradve annermel a._ --- (e it, securias air so near an===rs or insomning provides fun.smete a: = ee open posidam Jumpers la ths vahes' esmeni circuit). Opening of any cf these vehe dartr.g cold shutdowns in acconimace wish OM Part pairs during plant opandom e -swer 1r act acapanide (see CSI-45).

10.14.2.1.2(c) The lirw= man should ensure est she vehes cssmot be operased using HS-5149 such l

Dese vahes also have a back up 2%eg=a boede avataide for esmergency that she vahe pairs would act be opened.

l operadam However, te stae of IIJs skrogen botlle is such that there is caly sumcient ses for appromismaety w vehe smokes. nas wouht marwanannae seplacing she wurte aber each test. More kuportamely, he a

nimogen bosele is not,.

' tied so te vehe acesseor. Seeldag tese vehes widt almogen seguires E Jennina of as air jumper and presure segatmor. kumulag te airjumper and sepische te aloegen boede gennerty incesses she pomadas for damagtes pipimphubing enamareines aut is considmed a handship ameiswer wie NUREG-1482 haenn 3.1.1."

l m

56 1

'.i.s

2

• i CSJ-45 IQ) 5W-5155-

"Itese wnuaRy dened vehes seemia ein==t to isolene te 12 (22)

Perthe vahe k is "

- M no escudse the vehes inevidmeny

,,j

' CV and 10). -

ashwaser dis &arge hendes teen me 11 Q1) adtwsner supply hadas, at Tath these

,parterey due m aest seamp and the seed to secuse air SW-5156 CV she Emagocy Ovutomed dhr*=ge nowpme anspa===ss between the vehes are fuB-or lassall jum6yvs. k is aho hupracdcal e Servke Water Hem Endangers. Cw.a Coo 5ag Heat Enchangers, smokeenesdeed eseedse me vahes as pairs ha emme ir ske vehe j

L serviceweer and socs Pamp Rooma Air coolers, so ensuse me mornini cocess waner o m a cons pair smaed duries e test. bon unies of sehweser m

i HeatEmmenger now is==hadmad a te==pam-s= and heat endagets cooleOy me saadawns.

cochig sysse wouhl he dwined hapueble and a i

l 11 (21) 1101) sekwuser mains. ney me opcmed when coolks is requbed in me lossofsyneeminacdo womhioccur.

E merg s y emergencyovutood dueup.

I Ovahome me ahenmehe provides enadshg doing cohl

[

sypassVaives and pair of vahm is operased een a single humwisch and seiner shundowns k socord-a wie OM Part 10, i

J vehe in each pair can he hatvidueny opened v toast pheing me emer

t..2.1.2(c).

1(2Mw-5165-vahe h as shamas enangerados (e s-. seeming air no me - nr cvand 1(2).

Insamingjumpers in a vahe commet chess,). Execising any of these SW-5166 cv vehe pairs antes phet opendon at power unir snow signaricant 1,ypass now tetween me brukes at de FA heat endanger or component

=*. Depeness on sekwaarleader presswe, not dhr*=ge now mom Coo mus W aner me 12 r22) hmer couhl he immerma luto te 11 (21) supply header, or HeatFadanger aqpply now Dom the 11 (21) header coukt bypass each M heat 11.(21) endanger er mer sal gmas leu see 12 (22) discharge header. h einer t

R, case, now hetween me seawann h-*=: womht eguiacenty de,ade me l

Ovatoed.

heat semoval capedty of dm heet endangers or coolers supplied by the BypassVahes 11 Q1) saltwaarher_kss.

1(2; 4W-517/.

Aldhanamuy, whet mese vahes are oper the two smitwer hadas are j

e CVsad 10)-

not im*p-der As a sesult, tot saltweter headNs are mesidered j

SW-517sOf inoperable and te plant is placed in a short-derados acnion msnmeme shoshl ary vehe pak fe" to se ciate aAr being opmed, te sakwaar ECCS Pump systema womid no insger semake espatde of perfomalmg les safety D=re=

Rooms Air in view of me assedened slagte fansre sequhemeen:n, Gr:setry Cooler 11 Q1) -

====Immimp a phet skuedown and moldown.

Famergency Overtumsd Parital opening of esse valves paesemos the ygne sisit m Ital openhg.

BypassVahes aus it is sino not feasPAe during opandna "Inis is a==hame widt en posider: saheed in NURBG 1481, Paragraph l

2.4.5."

^

l 4

I i

9 4

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CSI-46 1(2bSRW-323, "Itess sorrePly< pen valves povide skewynes for nonnel coollag weser Per the Vehe k is impanaksi to enadse these aorumBy epem 1(2>$RW-324, seems hous non em:abt ruunynames in the turbine buikling crkical to Tabbs,tese vehes closed gesnerfy darks power opesation te r== sam-na yension of et gemaating plant. They close to leolate the vahes are fa5-hre===e this would result in a plant skuedown and and 1(2FSRW-a 325 son <Isened searm piping toma te *===ri=I load seems piping during am sercheesesdeed pon=ss=I damage to componemes such as ne archa=, whos dea turbine buBeng headers are Innhand cinsonsicold corgtesser vacuss peamp, ev=dramese hnnawr ServloeWreer

.h nan w es.

pump, ge serstor. Seed puuny, and almogen Reasrs fsoon Closing any of tese vehen during phna operados at poner seguises comparors.

webine ineenupdag coceng now soms ne ambine manniertes sad -are a-BalhBag Oseck n-pn=rme 'stis would ski-an,ey sesuk in a plant shutdown and The steerselhe povides fuf. h enesching to makendas aus e uange to phet equipment. Pudst domme of drse se ehmad poshion during coM skuedowas in s

Vahes vehes presemes te same risk as imE c%sure; t, kis also not feasible an== amer => whh OM Pet 10,14.3.2.2(c).

durlag opension.1 bis is an=miss=r whh the posillom stated im NUREG-I 1482, Paragraph 2A.5."

CSJ.47 IW4RW-

"Itese monmally-open vehes provide Hoqieshs for normk moling waner Per she Valve k is imprart: cal to exercise monamily open vehes 1600.CV,1(2)-

to non e===es=I ce-pn==== in the turbine building aitical to the TatWes,lhese SRW-1600 and 1637CT dosed quarr.fy during

===t== art operados of the generating piset. They close on a STAS to valves are fuB-power operation h this would gesult in a SRW-1637- '

CV,1(2FSRW.

Isolete arma==sha heat loads and ensee e%=se cooBag weser Anw to sueleenadsed phet shutdown and potential damage to 1638-CV,and crhical heatloads. Dwing e areww when te ambine tulding h*=ters closed and fmB-ampe-its such a se condenser vacuum pump, art, isolmeed, these vahes must close to isolmse me non-classed piring safe nessedat av=*=nese booseer pump, pesersoor, feed pump.

1(2).SRW-l cold and misogen congwessors.

1639.CV sous the attestlandpiping.

shuidowns.

ServiceWaser Cloc.g any of tese vehes dertag plant operation at power wiB 1he abernathe provides full-seroke C 6 to Supply to imeenupe cocemg now to the tubine assinaries and assadened she ch=ad poshion during med senadowns in companema This wouhl v i==nasy resuk la a phet sheidown and accordsace wkh OM Part 10,14.2.1.2(c).

m Tubine Banding ombessins and esmage to equipment. Panimi clonne of tese vehes presenta the samme shk as full cloeure; ees, It is also set feasilde during Evmamadn= not regelred for vehes 1(2) SRW-1638, opennha. %In is===ha=e wkh the posklos sessed in NURBG-1482, 1639. Inese vehes are not A3ME Code Class 1.

Paragraph 2A.5. Noes that some of these vehes are act widde the 2, or 3.

j ASMFASIcines bounderles."

RFJ-1 1(2FHP-104 "Inese ese simple reart vehes wkh no extemmi asenes of esercishg or PerteValve Evehmaana scr.segelred. Vahes are act ASME posiden andar=sarus; thus vertrylmg te aldtty of eese check vehen to Thbles, these Code Class 1,2, r 3.

HydgemPese dose sequkte rummal====a access to enestine tems ope, fonoe,;d by a vehes me fus-Supply Check to 1-leskage test (which surgebes lastuistion of a binsk flange).1 bis is smoteestudsed not pracskst during ar===I opeat on and is also not an=mbered pracskal rian-Iat i

Vahes during a cold shutdoive pertod.1 tis agers wie te NRC posidos per sefueling.

NURBG.1482, Paragraph 4.1 A. Note that these vehes me not wielm S

te ASMFASIcbsboederles."

58 1.

RFJ-2 1-IA-337and "Inese are ammE sprhs-landed pisaan-type chedt vehes wie no exeermal Per theVahe Evaluation not requbed. Vahes are not ASME 2-IA-175 posidan Indirmalam or other means of easily vedfyhg their poestion.

TaNes, these Code Class 1,2, or 3.

vahes are fuM-hetnamenAir Operaden ernumusnes alreperused c:stros vehes in c=amammwns during earckeenescised Supply to nonnat operssion, inclueng quenerty serventuace testing et seiersed air-ren=d at rassahmest spesseed costsat vehes he costelumsent, verifles the ab51ty of diese check

.JJ: g..

Isoissionrwr*

vehes to opes en an ongobs basis.

~

Vahes Dese are no sneens of verifyheg their ability to fisR. stroke closed other than by perfber&1g a bedt seat leakage test In order to do this,6e spenessa side o: r,ach diedt vehe samst be lensmand and a test ensmareine asnowed glucogh which a t flow can be asemamed ashg a lesit ram s

sanninar after passing bedt Arcash the check vahe. However, tids seenres at least one, and somedmes the only, flowpath for safety *1 air to the downsereaut air loads. Verifying closure of these alves sequkes enmanimmwns access W a hadt-leakage test. Such access is not practicrl on a rcuthe basis during piant operation at power. The connemsnine and naamrees==+d so secure insawnent air it, me comedament to perndt esting darks cold sheidown periods wooid be an annusonsbiebusdenwieno

_ " anininplantsafety.

De muniber of insenament air vehes, the complex sfseem sealignments, the meessity of restoring and replacing numerous test connection caps, mid the difncuhy of lastaning, removing, and relocaths a flow laserussent and leak rase smonitor to test each cLeck vahe is munideved imprareir=1 ao perform during nonnai operadon or durhg cold shendown cedads. nas is cammina-e wie NUREG-1482 Sections 3.1.1 and 4.1.4.

Nose est these rewr* vehes we not wkbin the ASMFilS1 class l

l l

l I

~

s "Itese are smaB siir' g4andra pietre4ype chedt vehes widi no enesual PerdieVahe Euntuation not required. Ya!ves me not ASME RFJ-3 1-IA450and a

24A-310 '

posMon andleastna or odier means of esoRy verifyhg their postolon.

Tables, disse Code Omss 1,2, or 3.

i Due to tear sins, design, med system ceangernelon, they cammet be non-vehes are fuB-I Noruud Air herushely N sackeenerbed Supply to cfaseda Coassimmeur.

Tna:e me no meeems of vertfying eeft abdity e Isli-streke closed other refueling.

Aklaende than by peribnaing a bedt seat leakage test. In order to do this, glae ChedtVahes sysuvan side of ende rhedt vehe seest be lenhard and a test conneeslaa se noved stucogh which air now can be ammsured using s kalt rate

[

micelear aner aering back drussi stie eter* vehe. Verifying clamme of j

l tese vahes myses Innemsine of the monnat air supply to critiral systeen i

l rW heside ransmissarer Alibougsi these is a.,+.p,,ppsy or n

l air scored la te anuncienna enneminewme air receber, failuse e seenre die i

morunni supply to service h a thnely mass==r could sesult in eqelpesent I

falhue and plam shutdown. Also, die badap air supply is capeNe of psovhEnp air to only a lbahed munber of critical loads.

)

l

'Ine mundier oflaserisuse air valves, the complex sysean. ".--

l the armanty of seanoving and sepladog meneraus test amenervina caps, j

and the difflealty of hisaalEng, sessoving, and selocating a flow l

laseruaunt and iesit rate manninnr to test endi chedt vehe is cessidesed kuprerew to perform during perusal opmaion or during cold shusdown periods. 'Ilds 4 <===Immne widi NUREG-1482 Sections 3.1.1 and 4.1.4.

Note est thr u chedt vuhes me act widnin the ASMEASI class

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RFJ-4 1.IA-721,1-IA-

"These see maan spring 4an&st phton type cLA vehes with no external Per deValve Eveleadon not rupsired. Valves are not ASME 722,2-IA-741, tosidan hdimdn= or osber me=== cf easily verifying tacir position.

Tables, these Code Class I,2, or 3.

and2-IA-743 Dee to their alae, design, and syneens configuradon, they cannot be non-vat 7:s are fn5-stroke MxJ letrmhely amanhored.

open andclosed SakwaterAir Comipressor

'Ihare are so means of verifying their ability to fuB-stroke open other atrefseling.

(SWAC) than passing the nequired a;r flow in the forward duecdon. This cat only Discharge be achieved by chher holating the moranal non-safety-seamand arnwoes of ciect vahe air and operadng the downsmeana air loads shnehaneously. However, w2; aR the downstress A knds sismuitaneously is not typically practical Ahermathely, the forward flowrase through each check valve may individman; memared. In enkt to do this, the downsteun side of each check vehe most be hoisted and a test connection reasoved timoegh which air flow can be memamed using a flow instri acnt after passhg IIncogh the check vehe These check vahes are part stroked open whenewrtheSWACh aretoperated.

There are no sneens of vestfyhg their shEity to fun-stroke closed other than by perfonshg a bedt seat lentrare test. In order to do this, the spearenas side of each check valve noust be isohsed and a test connection nescred through which air flow can be snessued osing a leak rate awmaant after passing back IIrough the check valve.

De aesnber of lastrunnent air vahes, the commplex systent reaugaments, the mity of removing and.Weg nurnerous test connection caps, and the difncidty of lastalheg. resnoving, and relocating a flow husrasunt sad leak rase amonhor to test each check valve is considened impow*3 cal to perfona daring monnat operation or during cold sholdown periods. "llds is amminamr wkh NUREG-1432 Sections 3.1.1 and 4.1.4.

Note that these check vehes are not wkhin the ASME/ISI chans 61

-.=.

~.. - - _.. -

RFJ-S 1-1A-1333,1-i "Ibese >se mane springJandad piston-type star + vehes wish no exaernal Per the Vahe Evaluation mot regdred. Vahes are act ASME 1A-1338,2-1A-poshied amarasen= or scher aseems of easily verif>bg their position.

Tables,these Code Class 1.2 or 3.

1801,and 2-IA-Due to deir sise, design, and systema configuration, they==we te non-vehes are fisE-1106 Imerushely ann =hr=ed.

semite esercised rin-d at Nonnel NSR)

'these sue no atums of ves6fying teir shelly as ibil-senhe closed oeer refueling.

hueruneet Air een by perhoudsg a bedt seat leakage test. km enter to do Ilds, the Supply Check upsereams side of each rear

• vehe snest be isolseed and a test connection Vahes reasoved ihmugh which air flow can be====ed using a leak race man =har aner passing back through the deck vehe.

NUNMdM 8e Ms% rM%

l Ihe seemity of resnoving and repiadag emnerous test connection caps, 6

andmearnastyofi-a n'as reunoving.andrekcsensanow

> sad nesk rane anonnor to nest each deck vehe is co==i+.ed j

hupreceital to performa during nonnel operation or during cold shutdown periods. Des is consiseest wie NUREG 1482 Ser*= 3.1.1 and 4.1.4.

Noen est tese check vehes me not wkhin the ASMEAS1 class

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m._

s.,

RFM 1-IA 729,1-IA-

~1tese me amas agrbg-loaded pistom-type dedt vehes wie no external per theVahe Evahamina act required. Vahes are act ASME 732,2-IA-300, posidos Indirrtum a seer mesms of easRy verifylag Iheir posiden.

Tables,tese _

Code Chas 1.2, or 3.

sad 2-IA-301 Das to their sima, design, and systema coungenstom, they e===re be ace '

vehes see fmB-herushelymomhmed.

sercheenesked InsommestAir open madnename l

Sapplyto lhes see as meses W valrylag their abilley to fmB-stehe open ether atreReeling, AFWSupply -

than 3,assing the requbed air flow h the forward dhec$om. 'Inis can cuty muisue pardel-i vahesCneck be maleved by einer isoiseng me aanmai son-safetyehmed sommes of sedeenesdeed l

Vahes -

air and opendag te downsmens air loads ? '

---4. However, quenedy.

aperedng nu me sownsmens airloads :-

--- i ns nu typicany 1

prmream8 Alerasshely. she forwent flowrese duongh end dedt vat s may imaddesmy =r=P==ed. k order to es eds, me downseems side of j

este reinter vahe must be isolmeed and a test h semioved enomsk i

which air Sour ces be arrmed using a flow baser==mr=4 aner passing dmeugh eedeckvehe.

I

'Ibem ase no meesus or verifytag meir abElty to inII-seete coord r4er esa by perimming a back ser11eakage test. In order to de this,.ae I

arememan side of each check vehe meest be isoleted and a test==marenne sensored trough which air flow com be meessed mehg a leak rate '

mannhnr Sher passing back arough die Chedt vahe.

f i'

'Desdag esse vehes requins signincast stAlguement of the air supplies to me AFW Sow coment vehes, ancher.g secadag me safety.Maard air supply to each set of AFW Bkxitag vehes and Flow Cameral valves (cme set at a dune). The air lead =s/ssfety scheed accummuistors ase comAgered such est ene of the two AFW Bkna.ag vahes in each AFW FlowIAgissuppuedbyWairh Asa sesnit, Isohdog one amfety-seissed air accumudator isolates air to one AFWBloddagveheineach AFWIiowleg. Simeete AFWBloddag vseves es spea, mis wombs seemn h m-had especity of me AFW supply syseum to sespond to an ASFAS h te event seems genermor innessine shouH be seguimd. "Itesedase,at AFW19eur IAqs woeld be madmedW

• Ibg ammher of lmsbemNd air vehen, es compEct syssum sM5gegnemas.

[

ee annemsky of nanoving and seplacing ausmescus test cometettom caps,

[

and me dMHruhy of helmEng, sessoving, and relotadug a Bow hummment med leuk suec anmLe es nest and starer vehe is en==adaed kapracskal to pesfoss every emerge dartog sound opernelon or eartog cohl shutdown pelods.1 tis is enmaha=* wth NURBG.M82 Seedoms 3.1.1 and 4.1.4. 84eee est these rear

• vehes are not withs me

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ASMPASIclassboundaries" i

63 i

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e RM-7 1-1A 730and 2 "Inese me ammE sydmg4anded phson-type eter* vahes wie no exeruni PersheVahe ' Evaluatioc not nquhed. Vahes are not ASME IA-315A position leecsdom or ogher meses of easily verifybg shar poeldon.

Tables, thean Code CL 1.2, or 3.

1 InsenumentAir.

Due e erJr slae, design, and syssen conHguration, they cannot be non-vehes ar:fuB-senteexerdsed inannhely manhnsat.

esosedst supper e AFW thr*

'Incue sue no seems of vedrying their abWty a fs5.sante renmut other refue'ing.

Vahes een by peribrusing a bedt seat leakage test. In order to do this, the upsereams side of endt chedt vehe asust be isolacd and a sent en==an*=

sessoved through whictisir now can be miessured asing aleak race nannhnr aner praing back shrough the chedt vahe.

4 "Ine muster oflesenament air vehes, she exunplex syneesi renEgnments, she nameby of nunoving and apIndag numerous ac:t annenion caps, andthedifRosityof amesenimp removing andrelocatingaflow inseveemt and neak nee =nnhar so oest each tar

• vehe is considaed imprecekst to perfonn every cuenge dudng nonnel operusion or derbs cold skuedown pedods. lnis is copel*=r with NUREG-1482 Sections 3.1.1 and 4.1A.N est these check vehes are act widda the ASMESSIdsesin stes."

RM-8 1.IA-736,1-1A-

"Ibese are scanE s.a -g-loaded pisson-type chedt vehes widi no external Perthe Vahe Eve 8=mine not required. Vahes are not ASME 738,2-IA-304, pnakinn imsencasan= or oeber sWens of easily verifylmg '. heir position.

Tables, these Code Class 1,2, or 3.

and 2-IA.'05.

Due to Ibetr she, design, and syseest comHguration, they cannot be non-valves are fuB-secteexached inerushety mortored.

closedat Insenument Air Supply to 1tese are no sneens of verifybg their ablHty to Adl.seroke closed other refueling.

AFW Systems then by peribnabg a back seat leakage test. In enter to do Ilds, the Vahe upseream side of endi chedt vehe must be enesand and a oest en==cr* Inn s

Arnumstaars seasoved through which air flow can be measured ashg a leak saae

~

f'har* Vahes

=n=hnr aber passing back through die chPrit vahe.

• Ine manter oflesenument air vehes, the complex swskun senEgmuses as, the necessity of wasoring amo spiacing ammaeus nest a==r* Inn cape, and the difRculty of lasemIIsg, reasovhs, and velocadag a Sow inser==rme and leak mee =nahre ao C1t each diedt vehe is en=mbened kupratskal to patens every cue g during normal opeados or Aning cold ahmednwn pelods. 'Ihis is en-ehema wkh NURBG.1482 Secelons 3.1.1 and 4.1 A. Note est these char

• valves are act witin the ASMEASIclassbounderfs."

64

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RFt-9 1-1A 1432,1-

'Itece are amma spring 4anded pisenswype ched: vehes widi no exeernal PertheVahe Evateados not requbed. Vahes are not ASME 4

1A-1448,24A-peeldom h er ehr men.s of essey verifying their position.

Tables,these Code Oass 1,2, or 3.

1213,and 21A-Due es their sine, deelga, sad syseesa enongeselon, they cannot be non-vahes are fuB-1228 leerushely==hnet.

~

somesercised renarut at InsanoneetAir These see no aseems of vestfylmg their abElty to Ass earefte closed asher refueling.

~

Supply to tan by psforming a back seat leakage test. In erder to do Ibis, the 4070 F M 1A ignereams side of each check vehe aus be enama,vt and a aest comaecdon s

Air semuned slucugh which air.h can ~oe ar===est using a leak rate Ammmelannes maalant aner passing back through the check valve.

checkVahes

'the number et insenament air vehes, the complex syseest renEgunnests, the mercanity of reasoving and repiscing sumerces test manection caps, need tie dlfRculty of lautaillrg, sessoving, sad relocadog a flow immerumurms and leset rese reanimr to test each riwv* vahe is considesed l'Apressical to perfonn every cuesse daring suusal operados or daring cold sht*dours pedots.1 bis is a=esen-e with NUREG-1482 Seokms

}

3.1.1 and 4.1 A. Picae &at diese check whes are act within die l

ASMEllS1classbounderten" j

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e RFJ-1-IA-1444,1 "These are amnE sprhg-loaded piston-typ -tedt vehen widi no external Perthe Vahe Evaluahon act seguimi. Vahes se not ASME 1

10 IA-1460,2 IA-position marmainsorolherseemseofensh; 4",:

theirposition.

Tables,these Code (%=a 1,2, or 3.

a 1203,and 21A-Due no their aime, design, and systemi coaGgunsion, they means be non-vahes are fimE-r 1220 hanshefy unmaarmed. These me no ammes of verifybg their abiky no arckeenemmed fisE essake open other tan passhg the sequbed air fiow in se forwant, cpen andrenant l

InsinonentAir qErection. This esa only be achieved by either isolating the mennel non-at refIseNag.

Supply no safety 4elmeed sources of air and operadng the downseresen air loads l

t Steams Supply shouhaseously. However, openslag all the downstremas air loads Vahe thr*

almanhaar smaly is not typicaEy prar*m3 Ahernathely, the forward Val es flowrase almoegh each rewr* vahe misy individually airemmed. In enter so do this, he downsteams side of each chedt vahe anst be isolated and a test connecdos semoved drough which air flow can 1m =r===ed using a fkr.y inser==res aber passing through the diedt vahe.

1here are no sneens of vedfying their abDity to fimE-streke closed other than by perforadng a back seat leakage nest. b order so do Ibis, the upsteam side of each chedt vehe noust be lenienne and a gest rammar*=

runoved through wHeh air flow can be =a===ed ashg a lealt saae mnmannt aber passing bedt enough the chedt vehe.

{

The ausber of lastnmaent air vahes, the complex systemi seeBgnements, ihe % of remuning and repiscing ammuroes test a==ar*= caps, and the difnamity of i==eenleg semmoving, and relocating a Jow leser-meme and leak rese =nnianr so oest each chedt vehe is mumlelened f

kept"*"' 10 perfonn every "JWenge d Wing Normal Opesstion er deflag

[

cold ahmtawn pedods. This is er=anent wkh NUREG.1482 Sections 3.1.1 and 4.1A. Note het these riert valves are act wkhin the ASMEASIcismsboundaries" I

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RFJ-11 IAl DSA-33 "Itese vesses close to hohne te non-safety pode air suppibb [

PermeVahe The th += man's basis for deemstag sesehg is shut a W I IA2-DSA 46, when to ED air campsessors ase act operaths.

Taides,aese IXX) wouM seed as be seemed for as *===d=8 IA2 DSA-38, valves are fisE-peded of thee (probsidy b excess of 3-4 hours),

v andIA2,OSA.

These me simple chedt vehes wie no external seeses of eneselshg or serokeenadsed Asa=r===ad in NURBO-14g2 hain= 3.1.2, a

46..

posidos =dicada=* thus,.J,",;closme of tese vehes segebes a closedat seguired essay hite a LCO se personn IST would a

bee.aestsee est. Due to me systems mangerados and se hek of vest sefsetag.

actjeudfy deferring tesehg undt a cold skuedows lAIAA2 vehen, personnbg see a test seguires seenpument of te sardag

• orsessens,. Wie one dieselgesamorinoperable -

soergemey seeshes ses ideeding de ne of one seccher. nas wooid sesset in se (Note: De dudag operadon, Cahat CHffs Tech Spec 3.8.1.1 Diesel plant eagerlag a lf0 casuBelon for an extended period of sinne (psobably VaheTaide seguires both EDGs be sessored wieta 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Genussar la esass of 3-4 hours). In considerados of the staff aspport and tiene inconectly Tech Spec 3.8.1.2 only seguires one 1:DG to be t

(EDG)Starthg se====se nf this test, teethg quarterty and at cold al=minsen fsequencies is identines the operside durhg cold shusdowns and refueEng.

AirReceber imprecalcal and would impore an excesshe benien on the plant staff.

Refuehng Additionally, the licensee senses that testing checkvahes Aandoestly,segmane,-

- -==!=,.-

---- of eene

• J sdncados gunneriy would sesak in laaensed sun ene on ne necehas womki resuk in signiacandy inesessed run-eme on me Nanberas asenessors and te posuutal for air system

===acimad air compessors and inaesses se p*=nas of commeksdas RFJ-Og).

ev=m==d== dam Deredoes not appeartobe i

ne EDG Staning AirSyseenC*

sumcicat basis 9ar defaring tesdag to sefee3ng.

On sevn=w of ee EDG Seursing Air PAID, k appears est me supplyhemercased be depressudaed through SV-lG247 seus 10275 and the sina==s used for air dryersegeneradon. Tesdag h t

i ek-weekspobsteynotsegehe emair I

secchess or EDGs to be deciered inoperable. The Boensee ahn=ht seriew the test metod and sewhe meseguestaccongngly.

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