ML20206C903

Submits Formalized Response to Draft SER & Comments Re Inservice Testing Program for Pumps & Valves & Forwards Revised Relief Requests & Figure VRR-4

ML20206C903
Person / Time
Site:	Point Beach
Issue date:	04/02/1987
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Colburn T Office of Nuclear Reactor Regulation
References
CON-NRC-87-36 VPNPD-87-140, NUDOCS 8704130188
Download: ML20206C903 (19)

Text

- ---~n -

i l%sconsin Electnc eamcome 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE,WI 53201 (414)221-2345 VPNPD-87-140 NRC-87-36 April 2, 1987 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D. C. 20555 Attention: Mr. T. G. Colburn, Project Manager Project Directorate 1 Gentlemen:

DOCKETS 50-266 AND 50-301 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

• POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated January 16, 1987, a Draft Safety Evaluation Report (SER) and Technical Evalatuion Report addressing our Inservice Testing Program for Pumps and Valves and associated requests for relief from certain specific requirements were forwarded for our review and comment. On March 16, 1987, a meeting between Wisconsin Electric Power Company (represented by Messrs. G. R. Sherwood, T. G. Staskal, S. W. Pullins, and R. D. Seizert) and the Nuclear Regulatory Commission staff (represented by Messrs. T. G. Colburn, J. Huang, and G. Baschi) was conducted at your offices in Bethesda to discuss these reports and associated NRC staff comments. This letter is provided to formalize our response to your Draft SER and associated comments. The order of our responses corresponds to the order of your exceptions and staff comments.

Revised relief requests are included as Attachment 1. Figure VRR-4 is included as Attachment 2 to help clarify Item 4 of this submittal.

1. MEASUREMENT OF PUMP VIBRATION VELOCITY VICE MEASURING PUMP VIBRATION AMPLITUDE, PUMP RELIEF REQUEST 9 We had requested relief from measuring vibration amplitude on all pumps in the IST program and proposed to measure vibration velocity. Allowable ranges of vibration velocity were also proposed which would determine whether the measured velocity was acceptable or whether the measured velocity would be cause for alert or required action, since the Code does not prescribe allowable vibration velocities, g 0704130100 870402 1 *1 9 PDR ADOCK 05000266 PDR p

Document Control Desk April 2, 1987-Page 2 NRC Exception and Comment No. l-

,1 The Draft SER found our proposed alternative of measuring vibration velocity to be-acceptable provided that the allowable ranges of vibration velocity to be used were those specified in Section~2.1.2.1.1 of the Technical Evaluation

. Report. For ranges of vibration velocity greater than those i specified, we would be required to measure pump vibration amplitude in accordance with the requirements of Section XI.

I

Response

We withdraw our relief request and will continue to measure vibration amplitude in accordance with the IWP-3100 require-ment of Section XI. Based on vibration velocity data obtained to date from our pumps and the ongoing efforts of ASME to develop vibration velocity criteria, in OM-6,

" Inservice Testing of Pumps," we believe that the' allowable ranges of vibration velocity suggested by the Draft SER are too restrictive. To exceed the allowable limits specified in the Technical Evaluation Report would not necessarily be indicative of vibration severity which is abnormal.

2. PUMP FLOW RATE MEASUREMENT FOR RESIDUAL HEAT REMOVAL PUMPS, CONTAINMENT SPRAY PUMPS, SAFETY INJECTION PUMPS, AND AUXILIARY FEEDWATER PUMPS, PUMP RELIEF REQUEST NOS. 3, 4, 5, AND 6 i

We requested relief from measuring pump flow rate during quarterly pump tests for the residual heat removal pumps, the containment spray pumps, the safety injection pumps and the auxiliary feedwater pumps.

NRC Exception and Comment Nos. 2, 3, 4, and 5 The Draft SER maintains that pump flow rate must be measured in order to assess pump hydraulic performance, and that the lack of installed instrumentation is not an adequate long-term justification for not making this Code required measure-ment. Therefore, the Draft SER suggested that we make modi-fications to the residual heat removal system, the contain-i ment spray system, the safety injection system and the auxil-

iary feedwater system in order to be able ta measure pump flow rate quarterly. The modifications are to be completed prior to the end of the next refueling outage.

i f

4 4

t-

l l

Document Control Desk April 2, 1987 Page 3 l

4

Response

Our requests for relief from measuring pump flow rate as part of the quarterly inservice testing of the residual heat j pumps, the containment spray pumps, the safety injection pumps, and the auxiliary feedwater pumps remain the same as previously submitted. Additional information is provided to help clarify our relief requests.

Inservice testing of the residual heat removal pumps, the containment spray pumps, the safety injection pumps, and the auxiliary feedwater pumps is performed quarterly near shutoff head while on minimum recirculation flow. During these tests, all pump parameters required by IWP-3100, with the exception of flow rate, are measured by instrumentation loca-ted on the pumps or on each pump's recirculation loop. Pump flow rate data is not obtained quarterly because no instru-mentation is provided to measure the flow rate within each I pump's minimum recirculation loop. The minimum recirculation I loop is a fixed flow path to remove internally generated heat from the pump while it is operating at or near shutoff head conditions. Approximately 10% or less of design flow can be passed through this line.

A pump's system flow rate is a meaningful parameter to indi-cate pump performance when the pump is operating at or near design conditions. However, it is not practical to shut down the reactor every three months in order to establish the con-ditions necessary to measure system pump flow rates for any of the four systems. Therefore, pump flow rates through the respective systems are measured and recorded for each of the residual heat removal pumps, the safety injection pumps and the auxiliary feedwater pumps durins each unit's refueling and maintenance outage while operating at or near design conditions. Full system flow rate testing is not performed for the containment spray pumps because to do so would entail spraying down the containments.

In order to provide consistency with the testing requirement of the Code that pump flow rates be measured quarterly, the NRC staff has suggested modifications to the design of the residual heat removal system, the containment spray system, the safety injection system, and the auxiliary feedwater

,i system to provide flow rate measurement capabilities on each of the pumps recirculation loops. To measure these centri-fugal pumps' flow rates while aligned to pump only through the minimum recirculation loops provides superflous data for i

s r- , , , . , - -,,---,,,+-n--,,.,---,,-w-, --r-- - . - . - , -.,---..y,, w y.--, - - - - - , , . , , ,- ,,y-,---,-----,,,,p--,

4 Document Control Desk April 2, 1987 Page 4 the purpose of trending the hydraulic performance of these pumps. Pump head for centrifugal pumps operating at or near shut off head conditions is relatively constant up to about 10% to 15% of design flow rate. As flow is strictly depen-dent on pump head and system hydraulic resistance, changes in pump head in a fixed resistance system provides adequate.

information as to the hydraulic condition of the pump. Flow rate data for the pumps while operating near shutoff head would not enhance our ability to trend pump performance beyond our current capabilities. Therefore, we believe a quarterly minimum recirculating flow rate measurement is not in keeping with the technical intent of the Code; it would merely satisfy the periodicity requirement to measure each pumps' flow rate quarterly.

Aside from there being no technical basis to modifying the systems, we believe the modifications suggested in your draft evaluation would be backfits which would require NRC analysis in accordance with the provisions of 10 CFR 50.109. The design requirements for construction of the residual heat removal pumps, safety injection pumps, containme:tt spray pumps, and auxiliary feedwater pumps and the respective piping systems did not include flow rate measurement capa-bilities while operating in the recirculation mode. Although ASME Code,'Section XI, 1977 Edition through Summer 1979 Addenda, Article IWP-3000, Inservice Test Procedures, requires that the flow rate be measured as part of the inser-vice test program, to require such modifications at this time would be contrary to 10 CFR 50.55(g)(4) which states, "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility,' components (including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 shall meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and addenda that become effective sub-sequent to editions specified in paragraphs (g)(2) and (g)(3) of this section and are incorporated by reference in para-graph (b) of this section, to the extent practical within the limitations of design, geometry and materials of construc-tion of the components." In part, the purpose and intent of 10 CFR 50.55a(g)(4) is expressed in the Commission's State-ments of Consideration, (41 FR 6256) which states "... Some of the more significant changes to 10 CFR 50.55a(g) from the proposed rule are: ... b. To eliminate the misconception that the design of components needs to be continually modi-fled and to provide a consistency between the design require-ments for inspectability and the design requirements for con-struction, the provision on design requirements for inspec-

. i

' Document Control Desk April 2, 1987 Page 5 4

. tability of components has been changed to refer to the same code edition which is applied to the construction of such components." Because of the intent of 10 CFR 50.55(a)(g), we believe the provisions of 10 CFR 50.109(a)(4) which allow the 4

Commission to omit the backfit analysis and the demonstration j that the standard that the backfit must provide a substantial  ;

increase in the overall protection of the public health end safety are not applicable. Modifications can be required only when the analysis shows that there is a substantial increase in the overall protection of the public health and safety or common defense and security to be derived from the I pump flow rate measurement modifications and the direct and

~

t .

indirect costs of implemenation are justified in view of the l increased protection. We believe that analysis will show that there will be no such increase in the overall protection of the health and safety or the common defense and security '

and that any direct or indirect cost of implementation is not justified.

3. PUMP FLOW RATE MEASUREMENT FOR THE SERVICE WATER PUMPS, PUMP RELIEF REQUEST NO. 7 1

We requested relief from measuring pump flow rate as required by the quarterly pump inservice testing program in accordance with IWP-3000 of Section XI for the service water pumps.

NRC Exception and Comment No. 6 The Draft SER found the requests for relief from measuring pump flow rate for the service water pumps to be unaccep-table. The NRC staff position.is that pump flow rate must be measured in order to assess pump hydraulic performance, and that the lack of installed instrumentation is not an adequate long-term justification for not making this Code required measurement. Therefore, the Draft SER suggested modifica-tions to the service water system in order to be able to measure pump flow rate quarterly. The modification is to be completed prior to the end of the next refueling outage.

Response

Our relief request remains as previously submitted. For the same reasons as stated in our response in Item 2, we believe that the modification to the design of the service water system in order to provide consistency with the testing requirement of the Code constitutes an unwarranted backfit.

. However, of our volition, we are investigating modifications of the service water system to provide system flow rate j measurement capability. The service water system is differ- .

l l

Document Control Desk April 2, 1987 Page 6 i

ent than the other four systems for which flow rate measure-ment relief requests were submitted in that generally two of the six pumps are always operating at or near design condi-tions to provide the required system heat removal capability.

However, the existing instrumentation configuration does not measure or allow derivation of the total system flow rate.

Therefore, if the service water system can be reasonably modified to provide the measurement of the system flow rate of each of the six service water pumps, then the data would enhance our testing program and capability to monitor the performance of the service water pumps.

An engineering review of the service water system will be conducted within the next nine months to determine the feasibility of installing flow instrumentation on the ser-Vice water system. By January 15, 1988, we will provide the results of this evaluation.

4. PERIODICITY TO DISASSEMBLE, INSPECT, AND MANUALLY FULL STROKE EXERCISE VALVES 842A, 842B, 867A, AND 8678, VALVE RELIEF REQUEST NO. 4 We had proposed to disassemble, inspect, and manually full-stroke exercise the accumulator discharge (842A and 842B) and combined accumulator / safety injection discharge

(867A) check valves once every ten years and to pactial-stroke exercise the valves on a cold shutdown frequency in lieu of the requirements of Section XI, IWV-3400 and 3500.

NRC Exception and Comment No. 7

, The Draft SER maintains that valve disassembly, inspection and manual stroking is an acceptable alternate testing method to full-stroke exercising check valves that cannot be full-stroke exercised with system tlow. However, the Draft SER also stated that our proposed disassembly frequency was not in accordance with the staff guidelines which prescribe a refueling outage frequency. Accordingly, it was suggested that we test these valves on a refueling outage frequency either individually or on a group sampling basis.

Response

~ Figure VRR 4-1 (Attachment 2) is provided to help clarify the following discussion about the function, maintenance history and proposed relief requested in regards to the safety injec-tion accumulator check valves. Valves 842A, 842B, 867A, and i

Document Control Desk April 2, 1987

Page 7 867B will stroke open if the SI Accumulators were to dump their contents to the reactor coolant system. Valves 867A and 867B will stroke open when the high head safety inspec-tion pumps are supplying water to the reactor coolant system.

Additionally, valve 867B will stroke open anytime RHR cool-down is initiated. Check valves 842A, 842B, 867A, and 867B are identical 10" stainless steel, Darling swing check valves. The eight identical valves of Unit 1 and Unit 2 operate under similar service conditions.

Since 1977, valves 842A, 842B, 867A and 867B have been par-tially stroked open at least annually during the transition from hot shutdown to cold shutdown. By reducing reactor coolant system pressure in a controlled manner to a pressure which is less than that of the SI accumulators, the differ-ential pressure across the check valves is sufficient to open the valves and initiate flow into the reactor coolant system from the.SI accumulators. Although the flow rate through the check valves is not the design flow rate, it does verify freedom of movement of the valve disc to a partially open position.

Since 1974, valves 867A and 867B have been stroked open each annual refueling outage during the full-flow testing of the high head safety injection pumps. The flow of one SI pump, at approximately 80% of design capacity (700 gpm), is direc-ted through each of these valves separately. Although full design flow through the check valves is not achieved during this test, sufficient flow is passed to stroke the valve substantially and verify freedom of disc movement.

Since each unit was placed into commercial operation, approximately~16 years ago, valve 867B has also been stroked open at least annually during initiation of cooldown on RHR.

During conditions requiring RHR, approximately 2,200 gpm are passed through the valve. This flow rate is sufficient to fully stroke the valve open.

i Over the last 16 years we have observed nothing which would be indicative of a problem that would inhibit any of the check valves' ability to stroke fully open. The 867A check valves on both units were opened and inspected after j approximately six years of service due to suspected seat

! leakage. In both cases, seating surface wear was observed j but no problems were noted with either valve's ability to

, stroke open freely.

i i

The successful operation of valves 867A and 867B for more than 32 reactor years indicates that the valves are reliable. The occurrence of multiple generic failures within

.i the group of eight identical valves is unlikely.

Document Control Desk April 2, 1987 Page 8 Because of their elevation and their proximity to the resi-dual heat removal connection to the reactor coolant system, Valves 867B and 842B cannot be opened and inspected unless the entire core is unloaded and the reactor coolant system is drained to the elevation of the reactor vessel nozzles.

The need to achieve this plant condition is rare. It has only occurred once for Unit 1 and once for Unit 2. To achieve the required plant condition and to disassemble and inspect Valve 842B would require approximately five addi-tional critical path days. Valves 867A and 842A in both units are at an elevation and location such that they can be opened for inspection during normal refueling outages without impacting a normal refueling outage schedule.

Because of the additional outage time which would be required to disassemble and inspect valve 842B, our alter-nate testing program for the eight valves does not include full-stroking or disassembly and inspection of Valve 842B.

We believe that based on the maintenance history to date of all eight identical valves, the partial stroke testing of Valve 842B, and the testing program for the other six valves provides sufficient assurance that Valve 842B will perform its design function.

Based on the above discussion, we are proposing the alter-nate testing for the safety injection accumulator check valves outlined in our Valve Relief Request No. 4.

5. EXERCISING THE CONTAINMENT SPRAY CHEMICAL ADDITIVE TANK VACUUM BREAKERS (VALVES 840A AND 840B), VALVE RELIEF REQUEST NO. 5 Since in-place testing of Valves 840A and 840B is undesirable due to the nature of'the spray additive solution and the system arrangement, to fulfill the testing requirements of IWV-3520 would require valve removal. However, to maximize system availability we had proposed not testing the valves at operation or during cold shudowns. Alternatively, we had proposed exercising these valves during reactor refueling outages.

NRC Exception and Comment No. 8 The Draft SER found the relief request acceptable provided

- that the additional information which was provided during the November 1 and 2, 1983, working meeting is formally

documented.

i

-~. --_-

s Document Control Desk April 2, 1987 Page 9

Response

Upon further review, we determined to withdraw our Valve Relief Request No. 5. Since Valves 840A and 840B are relief devices with a specific relief setpoint, they can and will be tested in accordance with the requirements of IWV-3510 of Section XI.

6. LIMITING VALUE OF FULL STROKE TIME FOR RAPID ACTING VALVES, VALVE RELIEF REQUEST NO. O We had requested relief from the power operated valve timing requirements of Section XI, Paragraphs IWV-3413(b) and (c) for all safety related rapid acting valves. Measuring the stroke time for rapid acting valves in accordance with the requirements is not practical since highly sophisticated timing device and valve modifications would become necessary.

In addition, slight deviations in stroke times that would be encountered under normal conditions would result in exceeding code allowable limits due to the very restrictive band within this time range. We had identified the rapid acting valves in our IST program to be those with a maximum stroke time of 4.5 seconds. As an alternative to the Code requirements, we proposed that these valves be timed to the nearest one-half second. If an increase in stroke time of 1.5 seconds greater than the previous test is experienced, then the test fre-quency shall be increased to once each month until corrective action is taken.

NRC Exception and Comment No. 9 The Draft SER found our request for relief and alternative criteria to be unacceptable and reiterated that we should measure the stroke times of all safety related power operated valves with a maximum limiting stroke time of 2 seconds or less in accordance with the requirements of Section XI, IWV-3413(c).

Response

The steam isolation valve to the auxiliary feed pump turbine, TTV-2082 is the only valve which is a rapid acting valve with a maximum limiting stroke time of 2 seconds or less. The normal stroke time for TTV-2082 is less than one second.

However, measuring the stroke time for TTV-2082 in accordance with the requirements of Section XI, IWV-3413 is not practi-cal since highly sophisticated timing devices and valve

modifications would be required. Alternatively, we propose

Docu' ment Control Desk April 2, 1987 Page 10 measuring the stroke time of TTV-2082 to the nearest one-half second. No trending will be performed. If the stroke time exceeds 2.0 seconds, the valve will ima declared inoperable and the limiting conditions of operation of Technical Specification 15.3.4 will apply.

See Attachment 1, Valve Relief Request No. O.

7. ADDITIONAL PUMPS AND VALVES TO BE INCLUDED IN THE POINT BEACH IST PROGRAMS NRC Exception and Comment No. 10 Section XI, IWV-1100 states that all valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident should be tested to the require-ments of Section XI. Therefore, additional components and valves are listed in the Draft SER to be included in the Point Beach IST programs and be tested in accordance with the ASME Code,Section XI.

Response

We believe that inclusion of all of the additional items listed in the Draft SER is inappropriate because some are outside the scope of the testing requirements described in the Code of Federal Regulations and ASME Code,Section XI.

In accordance with 10 CFR 50.55(a),. inservice testing pro-grams are to verify the operational readiness of pumps and valves whose function is required for safety. The inservice testing program for Point Beach Nuclear Plant Units 1 and 2 encompasses our " nuclear safety related" pumps and valves.

These pumps and valves are those which are required to function to bring the plant to a safe hot shutdown condition or to mitigate the consequences of an accident. Point Beach Nuclear Plant Units 1 and 2 are hot safe shutdown units.

Therefore, we believe that our inservice testing program is of the same scope as required by 10 CFR 50.55(a) and ASME Code,Section XI. To include the cold shutdown condition in the scope of the inservice testing program expands the scope of the testing program outlined in the Regulations and Code and is contrary to the previous NRC staff evaluations of our program.

e Docu' ment Control Desk April 2, 1987-

'Page 11 The items listed in your draft safety evaluation are indivi-dually discussed below:

a. Safety Injection Valves, 856 A & B, RHR Section from the RWST We agree that MOV-856A and MOV-856B should be included in the program. Therefore, we will stroke test MOV-856A and MOV-856B in accordance with the provisions of IWV-3000.

b. Safety Injection Valves, 857 A & B, Safety Injection Pump Suction from RHR (High Head SI Recirculation Suction Valves)

We will open and shut Valves 857A and 857B during each refueling outage, noting stem travel. Our testing pro-gram will note that this test is outside the scope of ASME Code,Section XI, and that the acceptance criterion for power operated valves is not applicable to these manual valves. It should be noted that failure of either or both of these valves will not hinder the unit's ability to supply high head or low head safety injection or the unit's ability to provide low head safety injec-tion recirculation of the containment sump.

c. Valves 871 A and B, Containment Spray Pump Suction From RHR These valves were apparently mistakenly listed in the Draft SER. They are already included in our IST program,

d. Component Cooling Water Pumps, Pll A and Pil B The component cooling water pumps are not classified as safety related. Therefore, the component cooling water pumps should not be included in our IST program.

e. Emergency Diesel Generator Fuel Oil Transfer Pumps and All Active Inline Valves to Supply the Day Tank The inventory of diesel fuel necessary to mitigate an accident or to shut down a unit to a safe condition is contained within the day tanks and base tanks for each engine. The combined capacity of the tanks will allow each engine to operate at rated load for at least four hours. If the ability to make up either diesel generator day tank through the normal means becomes unavailable, the tanks may be filled by gravity drain from the bulk

m z- -

Document ControlLDesk -

April 2, 1987 Page 12 .,

storage. tanks or from a tank truck through the local emergency fill connections. -The fuel oil transfer system was modified to provide the-ability to fill the day tanks by gravity drain in 1985. The emergency diesel generator fuel oil transfer system pumps and valves-located-between the bulk storage tank and the day tanks are not safety related. Therefore,cthe emergency diesel generator fuel oil transfer pumps and active inline valves to supply.the

' day tanks should not be included in our IST program.

f. Charging Pumps P2A, P2B, and P2C and All Active Inline Valves in the Pressurizer Auxiliary Spray Line These components do not perform t.. safety related func-tion. Therefore, the' charging pumps and all active inline valves in the pressurizer auxiliary spray line should not be included in our IST program.

In addition to the above responses to your numbered exceptions, the-frequency to open and inspect safety injection check valves 858A, 858B, 862A, and 862B have been changed to correspond to NRC guidelines. See Attachment 1, Valve Relief Request Nos. 8 and 9.

~Thank you for the opportunity to review and provide comment on the Draft Safety Evaluation. Please contact us if you have any questions in regard to our response.

Very truly yours, flg'G C. W. Fay Vice President

' Nuclear Power Copy to NRC Resident Inspector Regional Administrator, Region III-

--m 9

b e

e i

ATTACHMENT 1

\

REVISED RELIEF REQUESTS t

r-

~

VALVE RELIEF REQUEST NO. O System: Main Steam, Units 1 and 2 Component: TTV-2082 Category: B~

t Class: 2~

Funct' ion: Isolates steam to auxiliary feed pump turbine for 1&2P29 t

~ Test c Requirement: Section XI - Division 1 I= IWV-3413 Power Operated Valves The stroke time of all power-operated valves shall be measured to the nearest second or 10% of the maximum allowable stroke time, whichever is less, whenever such a valve is full-stroke tested.

If an increase in stroke time of 25% or more from the previous test for valves with stroke times greater than 10 seconds or 50% or more for valves with stroke times less

- than or equal. to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed. In any case, any abnormality or erratic action shall be reported.

Basis For Relief: Heasuring the stroke time for TTV-2082 per the requirements of IWV-3413 is not practical. Highly sophisticated measurement devices and valve modifications would be necessary to accurately measure the stroke time of this fast

~

acting valve (normal stroke time less than one second). In addition, slight deviations in stroke times that would be encountered under normal' conditions would' result in exceeding code. acceptance criteria due to the very restrictive band within this time range.

i i

Alternate Testing: The stroke time of TTV-2082 will be measured to the nearest 4

one-half second. No trending will be performed on this

, valve. If the stroke time of this valve exceeds 2.0 seconds,-the valve will be declared inoperable and appropriate action will be taken.

Status: Submitted for review Document:

Y 'g

~

VALVE RELIEF REQUEST NO. 4

- System: Safety injection, Units 1 and 2.

Component: 867A, 842A, 842B

• Category: A/C Class: 1 867A 2 842A6B Function: Valves 867A, 842A, and 8428 open with differential pressure to provide flow from the SI accumulators and/or the SI pumps to the reactor coolant system during an accident. These valves are normally shut. In the shut position, these valves also serve as reactor coolant system pressure isolation 4 valves.

' Basis For Relief: During normal operation, safety injection pump discharge pressure of 1500 psig or accumulator pressure of 760 psig is not sufficient to overcome reactor coolant system pressure.

Full or partial stroke testing is, therefore, not possible.

3 During cold shutdowns, partial or full stroke testing via the use of the accumulators or safety injection pumps is not 4

allowed so as to prevent the possibility of a low temperature overpressurization event.

A full stroke test by dumping the accumulator to the reactor coolant system could be possible during refueling, when the reactor vessel head is removed, but the volume and flow rate required for the test could damage core internals.

There would also be the possibility of forcing a nitrogen bubble through the reactor coolant system and refueling cavity resulting in possible safety implications which makes

. -this testing concept inadvisable.

Alternate

. Testing: The following alternate testing will be conducted on the SI accumulator check valves.

1. A partial stroke test of 867A, 867B, 842A, and 842B will be conducted during the transition from hot shutdown to cold shutdown. This will be considered a cold shutdown test. This test will not be performed if it will disturb an " Event V" valve which is not required to be tested within the associated cold shutdown. At a minimum, however, this test will be performed once every i refueling outage.

l

r_

Page 2 VALVE RELIEF REQUEST NO. 4 (Cont.)

2. A seat leakage test of 867A and 867B will be conducted in accordance with Technical Specification 15.3.16,

" Reactor Coolant System Pressure Isolation Valve Leakage Tests."

3. A seat leakage test will be performed quarterly coincident with the SI pump tests on 842A and 842B. A seat leakage rate of 5 gpm or less will be considered acceptable.

4. A full stroke test of 867B will be conducted once each cold shutdown while on RHR cooling.

5. Once within each 120-month inspection interval, valves 1-867A, 1-842A, 2-867A, and 2-842A will be opened and their discs will be checked to verify freedom of movement. The inspection will be staggered such that one valve from the group of four (includes both Unit 1 and Unit 2 valves) will be opened and inspected approximately every two to three years.

If a condition is discovered during the inspection of a given valve that would have prevented it from stroking fully open, the inspection sample will be expanded. A second identical check valve in the same unit will be opened and inspected. Also, during the next refueling outage on the opposite unit, the sister valve to the

, inoperable valve will also be inspected. If a second valve is found inoperable in the expanded sample, all five remaining check valves from the group of eight will be inspected. The group of eight check valves includes 1-842A, 1-842B, 1-867A, 1-867B, 2-867A, 2-867B, 2-842A, 2-842B.

I If the inspection must be expanded to include all eight valves, the inspection of those valves in the unit which is not in a refueling shutdown condition shall be performed during the next regularly scheduled refueling shutdown.

Status: Submitted for review Document:

e e-VALVE' RELIEF REQUEST NO. 8 System: Safety Injection, Units 1 and 2 Component: 858-A & B Category: C Class: 2 Function: Valves open with differential pressure to provide flow path from refueling water storage tank to the spray pump suction. Normally shut.

Test j Requirement: Exercise these valves every three months.

Basis For Relief: .These check valves can only be full stroke tested during a

' full-flow test of the spray pumps. A full-flow test of the spray pump would require actual spraying of borated water through the spray nozzles in containment.

Alternate Testing: This valve will be partial stroke exercised during the containment spray system test required in the Technical Specification.

These valves will be disassembled and inspected once every five years. The inspections will be staggered such that one valve from'the group of two will be inspected every two to

-three years. If a condition is discovered during an inspection that would have1 prevented the valve from stroking

, fully open, the inspection semple will be expanded. The second identical valve in the'same unit will be inspected during that same refueling outage.

i, l Status: Submitted for review Document:

i i

r i

. - . . . _ . , . _ ..=, . , . . _ . . _ . , , , - . . . , _ - , . _ . , . , , . , - , , , , _ _ , _ - - . . . . . - _ - . _ . . . . . .. . - - . - . - .

u VALVE RELIEF REQUEST NO. 9 f System: Safety Injection, Units 1 and 2 Component: 862-A & B Category: A/C Class: 2 h- Function: Valves open with differential pressure to provide flow path from the spray pumps to the containment spray nozzles.

l Normally shut. In the closed position, this valve serves as a containment isolation valve, t

, Test t'

Requirement: Exercise the valves every three months.

i Basis For

Relief: These check valves can only be full stroke tested during a full-flow test of the spray pumps. A full-flow test of the

, spray pumps would require actually spraying borated water through the spray nozzles in containment. Partial stroke i testing _of these valves could also result in spraying containment; thus, will not be performed.

-Alternate

-Testing: These valves will be disassembled and inspected once every five years. The inspections will be staggered such that one valve from the group of two will be inspected every two to three years. If a. condition is discovered during an inspection that would have prevented the valve from stroking-

) fully open, the inspection sample will be expanded. The second identical valve in the same unit will be inspected during that same refueling' outage.

Seat leakage testing of these valves will be performed in

~ ~

accordance with 10 CFR 50, Appendix J. _

l Status: Sdbmitted for review Document:

l l

a ATTACHMENT 2

'~

F/GURE VRR 4-/

_SI ACCurruLA7'OR CNECK VAL VES SI ACCVM

., a h

fnon sz evnes h E.

QJ

$$fSIes 'd '/i >d 8474 8424 8W4 4

SI ACCVM 69 of PHR SVPPLY

(

- FRCM sr WMPS LOOP 8 c oe.c 2.s;g /g 8678

/

g928

)Q ggg i

i l