ML20207D035
| ML20207D035 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/30/1988 |
| From: | Hartley R, Rockhold H EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20154L966 | List: |
| References | |
| CON-FIN-A-6812 EGG-NTA-8051, NUDOCS 8808120363 | |
| Download: ML20207D035 (67) | |
Text
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ECG NTA 8051 e
TECHNICAL EVALVATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BYRON STATION, UNITS 1 AND 2 l
Docket Nos. 50 454 and 50 455
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R. S. Hartley H. ;, Rockhold 4
Published June 1988 Idaho National Engineering Laboratory EGnG Idaho, Inc.
'I Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Under DOE Contract No. DE AC07 761001570 i
FIN No. A6412 l
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4 ABSTRACT This EG1G Idaho, Inc., report presents the results of our evaluation of the Byron Station, Units 1 and 2, Inservice Testing Program for pu ps and valves whose function is safety related.
FOREWORD This report is supplied as part of the "Review of Pump and Valve Inservice Testing Programs for Operating Reactors (!!!)" program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EGnG Idaho, Inc.,
Mechanical Systems Evaluations.
The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20 19 05 02, FIN No. A6812.
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i Docket Nos. 50 454 and 50 455 4
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i CONTENTS INTRODUCTION....................................................
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P.?? i!STIN3 PROGRAM............................................
7 3.1 Essential Service Water System.............................
7 3.1.1 Relief Request.....................................
7 3.2 Diesel Generating System...................................
S 3.2.1 Relief Request.....................................
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j 3.3 All Systems................................................
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3.3.1 Relief Request.....................................
9 3.3.2 Relief Request.....................................
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L 3.3.3 Relief Request.....................................
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VALVE TESTING PROGRAM............................................
19 4.1 Containment Spray System...................................
li 4.1.1 Category A/C Valves................................
19 4.1.2 Category C Valves..................................
20 4.2 Safety injection System....................................
23 4.2.1 Category A/C Valves................................
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4.2.2 Category B Valves.................................
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4.2.3 Category C Valves..................................
30 4.3 Component Cooling System...................................
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I 4.3.1 Category A Valves..................................
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i 4.3.2 Category A/C Valves................................
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u 4.4 Chemical and Vol ume Control Systems........................
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4.4.1 Categ3ry A Valves..................................
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i 4.5 Instrument Air System......................................
36 4.5.1 Category A Valves..................................
36 4.6 Diesel Generating System...................................
37 4.6.1 Category B&C Valves................................
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4.7 Essential Service Water System.............................
39 4.7.1 Category B Valves..................................
39 4.8 All Systems................................................
41 4.8.1 Category A Valves..................................
41 4.8.2 Rapid Acting Valves................................
42 APPENDIX A VALVES TESTED DURING COLD SHUTDOWN........................
45 APPENDIX B P110 AND FIGURE LIST......................................
53 APPENOI A C 1: ' PROGRAM ANOMALIES 10ENTIFIE0 DURING THE REVIEW........
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TECHNICAL EVALUATION REPORT PUMD AND VALVE INSERVICE TESTING PROGRAM
!#0N STATION. UNITS 1 AND 2 1.
INTR 00VCTION Centained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted b) Commonwealth Edisen Company f:e its Sfron Statien, Units 1 and 2.
By a letter dated November 4,1982, Comonwealth Edison Company sucmittec an IST Program for Byron Station, Units 1 and 2.
A working meeting with Comonwealth Edison Company and Byron Station, Units 1 and 2 re;resentatives was conducted July 8 and 9, 1986 and conference calls were held on Decemcer 24, 1986 and July 09, 1987. The licensee's IST Program for purps, Revision 6, and for valves, Revision 7, as revised by Commonwealth Edison Company and attached to S. C. Hunsider letter to NRC, dated August 31, 1987, was reviewed to verify compliance of proposed tests of pumps and l
valves whose function is safety related with the requirements of the ASME Boiler and Pressure Vessel Code (tne Code),Section XI, 1980 Edition through Winter 1981 Addenda. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER). The NRC l
staff position is that required program changes, such as additional relief j
requests or the deletion of any components from the IST program, should be submitted to the NRC under separate cover in order to receive prompt attention, but should not be implementad prior to review and approval cy the i
NRC.
j in their submittal, Commonwealth Edison Company has requested relief from the ASME Code testing requirements for specific, pumps and valves and these requests have been evaluated individutlly to determine if the required testing is indeed impractical for the specific pumps and valves. This review was performed utilizing the acceptance criuria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/ Impact l
Statement titled ' Identification of Valves for inclusion in Inservice Testing Program'. The IST Program testing requirements apply only to 1
cceponent testing (i.e., pumps and valves) and are not intended to provica the basis to change the licensee's current technical specifications for system test requirements.
Section 2 of this report presents a discussion of the scope of this review.
Section 3 of this report presents the Byron Station, Units 1 and 2.
relief reques'ts and EG&G's, evaluations and conclusions regarding these requests for the pump testing program. Similar information is presented in Section 4 for the valve testing program.
This TER, including all relief requests and component identification numbers, is applicable to Units 1 and 2.
The Unit 2 designctor has been placed in parentheses to minimize repetition, i.e., 1(2) SIS 815.
Category A, B, and C valves that meet the requirements of the ASME Code,Section XI, and are not exercised quarterly are addressed in Appendix A.
A listing of P&lDs and Figures used for this review is contained in Appendix B.
i incor.sistencies and omissions in the licensee's program noted during the course of this review are listed in Appendix C.
The licensee should i
resolve these items in accordance with the evaluations, conclusions, and i
guidelines presented in this report.,
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SCOPE The EG1G Idaho review of the Commonwealth Edison Company, Byren Stati:9 Units 1 and 2 inservice testing (ISI) program for pumps and valves was tegun in 1984 The program initially examined was Revision 2. dated Nove-ter !!, 1932, which identified the licensee's proposed testing of safety related pu ps and valves in the plant systems listed in Appendix E.
The Itcensee's proposed IST program was reviewed by locating and highlighting the components on the appropriate system Pl!Ds and determining their function in the system. Then the licensee's proposed testing was evaluated to determine if it was in compliance with the ASME Code,Section XI, requirements. During the course of this review, questions and comments were made relative to unclear or potential problem areas in the licensee's ISI program. These were transmitted to the licensee in the form of 3 request for additional information (RAI) which served as the agenda for the working meeting between the licensee, the NRC, and the EG1G reviewers.
Each pump and valve relief request was individually evaluated to determine if the licensee had clearly demonstrated that, the Code requirements are impractical for the identified system components, and to 1
determine if the proposed alternate testing would provide a reasonable indicatien of component operability giving due consideration to the burden on the licensee if the Code requirements were imposed. Where the licensee's technical basis or alternate testing was insufficient or unclear, the licensee was requested to clarify th allef request. The system P110 was also examined to determire whether the instrumentation necessary to make the identified measurements is available.
If, based on the unavailability of adequate instrumentation or the reviewers experience and systen knowledge, it was determined that it may not be possible or practical to make the measurements identified in the licensee's IST program, a question or comment was generated requesting clarification.
For pumps, it was verified that each of the seven inservice test quantities of Table IWP 31001 wsre indicated to be measured or observed, f
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For those test quantities that were not being measured or observed quarterly in accordance with the Code, it was verified that a request for rklief frem the Code requirements had been submitted.
If testing was not being performed in accordance with the Code and a relief request had not been submitted, the licensee was requested to explain the inconsistency in the
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The review of the proposed testing of valves verified that all appropriata ASME Code testing for each valve is performed as required. The proposal was evaluated to determine if valvss, judgc6 to be active Category A, B, and/or C (other than safety and relief valves), would be exercised quarterly in accordance with !W 3410 or 3520.
If any active safety related valve is not full stroke exercised quarterly as required, then the licensee's justifica* ion for the deviation, either in the form of a cold shutdown justification or a relief request, was examined to determine its accuracy and adequacy. The proposed alternate testing was also evaluated to determine if all testing was being performed that can reasonably be cerformed on each valve to bring its testing as close to compliance with the
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Code requir,ements as practical.
For valves with remote posittori indication, the reviewer conf ttmed that
'he valve remote position indication is identified to be verified in accordance with IW 3300. The reviewer verified that the licensee had assigned limiting values of full stroke times for all power operated valves in the IST prograa, as requi;ed by IW 3413. For valves having a fail safe actuator, the reviewer confirmed that the valve's fail safe actuator is identified to be tested in accordance with IW 3415.
I Ear.h check valve was evaluated to determine if the proposed testing would verify its ability to perform its safety function (s). Extensive systen knowledge and experience with other similar facilities is employed to determine whether the proposed tests would full-stroke the check valve disks cpen or verify their reverse flow closure capability, if tnere was any doubt about the adequacy of the identified testing, questions were included in the RAl.
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Further evaluation was performed on all valves in the program to determine that the identified testing could practically and safely be ccnducted as described If th;r licensee's ability to perform the testing was in doubt. 4 Question was formulated to alert the licensee to the sus:Ectec proble9 Safety related safety valves and relief valves, excluding those that
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and tested in accordance with !WV 3610.
Once all the components in the licensee's IST program had been toentified on the P&!Ds and evaluated as described above, the P&l0s were examined clesely by at least two trained and experienced reviewers to identiff any acditional pumps or valves that may perform a safety function which were not included in the licensee's program. The licensee was asked to reconcile any components that were identified by this process which were not included in the IST program. Also, the list of systems included in the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/ Impact Statement titled, *!dentification of Valves.for Incit.sien in Inservice Testing Programs". Systems that appear in the Draft Regulatory Guide list but not in the licensee's program were evaluated and, if appropriate, questions were added to the RAI.
Additionally if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their part experiences, questions were included in the RAI to clarify those areas of doubt. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this TER.
At the completion of the review, the RAI was tra'saitted to the n
licensee. These questions were later used as the agenda for the working meeting with the licensee on July 8 and 9. 1966. At the meeting, each l
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J question and coment was discussed in detail and resolved as follows:
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The licensee agreed to make the necessary IST program corrections or changes to satisfy the concerns of the NRC and their reviewers, b.
'The licensee provided additional information or clarification about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change is required.
c.
The item remained open for the licensee to investigate further anc propose a solution to the NRC.
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The item remained open for further investigation by the NRC.
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The item remained open for further investigation and discussion by both the NRC and the licensee.
The licensee responded to the RA! and the working meeting discussions in their revised program resubmittals dated September 30, 1986 and August 31, 1987. The program changes were identified and evaluated to determine whether they were acceptable and if not, they contribute'd to the items that 4
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remained open from the meeting.
I, This TER is based on information contained in the submittals, and on information obtained during the working meeting and conference calls which j
took place during the reviw process.
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PUMP TESTING PROGRAM The Eyron Station, Units 1 and 2, IST program submitted by the C:- :ratalth Edison Co pany was examin2d to verify that all pue:s that are in:luded are subjected to the periodic tests required by the ASME Cede.
Se: tion X!,1950 Edition through Winter 15.181 Adoenda, es. cept for those pu ;s identified below for which specific reliei' from testing has been requested and is su.-arized in Appendix C.
Each Commonwealth Enson Company basis fer requesting relief from the pump testing requirements and the reviewers' evaluation of that request is summarized below.
3.1 Essential Service 4 Ltr,,5Y5te9 3.1.1 Petief Recuest The licensee has requested rt: lief from the IWP.3100 requirements of Section XI for measurement of differential pressure for the essential i
service water makeup pumps, OSXC2PA and B, and proposed to evaluate these pu ps using pump discharge pressure.
3.1.1.1 Licensee's Basis for Raouestino Relief, it is imprtctical to measure the inlet pressures of these pumps.
Instrumentat19n for directly i
measuring the inlet pressure for these pumps does not exist. These pumps are vertical well type pumps which take i suction from the river screen house forebay. The annual fluctuation between the highest and lowest river water is approximately two feet. Ynts difference in suction pressure (approx. 0.9 psi) is less than the accuracy of the pump discharge pressure l
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t Gage Range Accuracy (1/2% of full scale)
OPI.SX054/55 0 3M PSIG 1.5 PSIG Installing system modifications to record suction pressure will not provide more accurate data for evaluatino the performance of these pumps.
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As an alternative, these pumps will be evaluated using pump discharge pressure.
Inlet pressure will not be measured on these pumps.
3.1.1.2 Evaluation. The purpose of establishing reference values of measurements for operating pumps is to provide a basis for evaluating (by comparis('l of values) the hydraulic condition of these pumps to determine if they are degrading to the point where they may not be available to perform their saf6ty function. These essential service water makeup pumps are vertical submerged type pumps with no installed instrumentation for inlet pressure measurement. Qirt.cl pump inlet pressure is imoractical to measure without significant system cesign changes. However, some method could be utilized, such as the measurement of the head of water above the pump inlet, to provide a determination of the inlet pressure available to the pump.
This in turn can be used te calculate pump differential pressure and when used with the other measured parameters aid in the detection of pump degradation. Measurement of pump discharge pressure alone as proposed is likely to be non conservative when compared to the Code requirement to measure pump differential and, therefore, presents an unacceptable alternative to the Code requirements.
Based on the determination that some method of inlet pressure and differential pressure measurement is practical, that the licensee's proposed alternative does not provide a reasonable alternative to the Code requirements, and considering the minimal burden on the licensee if the Code requirements were imposed, relief should not be granted as requested.
3.2 Diesel Generatina System 3.2.1 Relief Recuest The licensee has requested reitef from the IWP 3100 requirement of Section XI for measurement of differential pressure for the dissel generator oil transfer pumps, 1(2)D00lPA, 1(2)D00lPS, 1(2)D001rc, and 1(2)D00lPD, and proposed to evaluate these pumps using pump discharge pressure.
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3.2.1.1 Licensee's Basis for Recuestino Relief. These pumps are positive displacement Diesel Oil Transfer Pumps. The pump differential pressure is not a factor affecting pump performance, but rather dependan enly en the inlet pressure to the pump. As the pump discharge pressure is constant, and the inlet pressure varies with tank level, the differential pressure is not a valid operational parameter. Using pump discharge cressure in lieu of pump differential pressure will provide meaningful pu p perfer ance data for evalt,ation of operational readiness of the Diesel Oil Transfer Pumps.
As an alternative, pump discharge pressure is a valid operational para eter. This will be used to evaluate the Diesel Oil Transfer pumps performance.
3.2.1.2 Evaluation. These diesel oil transfer pumps are positive displacement type. Their outlet pressure is dependant on the pressure of the system into which they are pumping and is not affected significantly by' either inlet pressure (providing adequate NPSH exists) er flowrate. For these pumps differential pressure and flowrate are not dependant variables, as they are for centrifugal type pumps. Differential pressure is not a eeaningful param.eter in determining if hydraulic degradation is occurring.
Measuremer.t of discharge pressure in lieu of differential pressure for these positive displacement pumps provides enough information to evaluate to determine the hydraulic condition of these pumps and presents a reasonable alternative to the Code requirements.
Based on the determination that the licensee's proposed alternative is essentially equivalent to the Code requirements, relief should be granted as requested, i
3.3 All Systeen 1
3.3.1 Relief Recuest ThelicenseehasrequestedreiteffromtheTable'IsP31002 requirements of Section XI, fer measurement of pump., vibration in units of 9
displacement and proposed to measure vibration in units of velocity and comply with the ANSI /ASME OH 6, Oraft 8, requirements of Table 61001 and Figure 61001 for all pumps in the IST program with the exception of the essential service water make up pumps, OSX02PA and B, for which relief is also requested from the increased test frequency requirement of CM 6 Section 6100, 3.3.1.1 Licensee's Basis for Recuestina Relief. The measurement of pump vibration is required so that developing problems can be detected and repairs initiated prior to a pump becoming inoperable. Measure ent of vibration only in displacement quantities does not take into account frequency which is also an important factor in determining the severity of the vibration.
The ASME Cods minimum standards require measurement of the vibration amplitude in mils (displacement). Byron Station proposes an alternate
,nrogram of measuring vibration velocity (inches per second) which is more comprehersive than that required by Section XI. This technique is an j
industry accepted method which is much more meaningful and sensitive to small changes that are indicative of developing mechanical problems.
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velocity measurements detect not only high amplitude vibration, that indicate a major mechanical problem, such as misalignment or unbalance, but also the equally harmful low amplitude, high frequency vibration due to bearing wear that usually goes undetected by simple displacement measurements.
The allowable ranges of vibration and their associated action levels will be patterned after the guidelines established in ANS!/ASME OM 6 Oraft 8. Table 6100 1 and Figure 6100 1.
These ranges will be used to assess equipment operational readiness for all components except the essential service water make up pumps. OSX02PA and 8.
The acceptable performance range will be < or to 2.5 times the reference value, not to exceed.325 inches per second. The alert range, at which time the testing frequency would be d'oubled, will be > 2.5 to 6 times
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the reference value, not to exceed.70 inches per second. Any vibration 10 i
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velocity greater than 6 times the reference value or greater than.70 incnes per second will require ccrrective actions to be performed on the affected ccmconent, The OSX02PA and B put;s. due to their design, will ex;erience vibratic-valccity readings that will normally exceed 0.4 inches per second. A vitraticn of this magnitude would fall into the "Alert" range of the M SI/ASME CM 6, Table 6100 1 and would require "Doubling the Test i
Frecuency," For this reason, the vibration data on these pumps will te evaluated on a case by case basis, with comparisons to previous data closely monitored to verify that the vibration is not affecting pump operability.
This is in accordance with IWP 3230(c). Evaluation of data, to assign equipment to the alert or action ranges, will be done within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (per IWP 3220 of Section XI). This will be done using industry accepted vibration analysis equipment, such as a full spectrum analyzer.
Vibration measurements for all pumps will be obtained and recorded in velocity, inches per second, and will be broadband unfiltered peak eeasurements. The eenitored locations for vibration analysis will be rarked f
so as to permit subsequent duplication in both location and plane.
The frequency response range of the vibration transducers and their readout system shall be capable of frequency responses from one third minimum pump shaft rotational speed to at least one thousand hertz.
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l The centrifugal pumps in the program will have vibration measurements taken in a plane approximately perpendicular to the rotating shaft in two I
orthogonal directions on each accessible pump bearing housing and in the axial direction on each accessible pump thrust bearing t.ausing, i
The vertical line shaft pumps in the program will have vibration measurements taken on the upper motor bearing housing in three orthogonal directions, one of which is the axial direction.
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Measurements of vibration in mils displacement are not rinsitive to small changes that are indicative of developing mechanical problems.
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Therefore, the proposed alternate method of measuring vibration amplitude in inches /second provides added assurance of the continued operation of the pump 3.
3.3.1.2 [y,a l u a t i o n. Utilizing vibration velocity measurements rat'er than vibration displacement measurements has been demonstrated to provide better indication of pump degradation.
guidelines for measuring vibration velocity and determining the allowable ranges and action levels are acceptable to the NRC as an alternative to the requirements of Section XI (for vibration measurements in units of displacement) provided that the licensee complies with all of the OM 6 vibration measurement requirements except those for which specific relief has been requested and granted.
d The essential service water make up pumpu, OSX02PA and B due to their design and application, would normally exceed the ' Alert' range value of l
CM 6 and doubling the test frequency may not provide significant additional l
information for use in determining pump degradation, however, an upper limit i
tull be placed on vibration velocity measurements and corrective action must be taken upon exceeding this limit.
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i Based on the determination that the licensee's proposed alternative testing method is equivalent or superior to the Code requirements, relief should be granted from the Code requirements as requested for all pumps in l
the !$T program with the exception of the essential service water make up pumps 05102PA and 8.
Further, relief should be granted from the increased
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test frequency for the essential service water make up pumps resulting from their normal operation in the ' Alert Range' of ANSI /ASME OM 6, Oraft 8, i
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provided that when the vibration velocity measurements reach the ' Required Action Range' values, corrective action is taken in accordance with the requirements of IWP 3230.
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3.3.2 Relief Decuest hM licensee has re;uested relief from. the IWP 3100 requirement cf Se:'ien X! fer reasure ent of bearing temperature for the following pu ;s:
CCCOIP Component Cooling Purp 1(2)CColFA and B Component Cooling Pumps 1(2)D00!PA, B, C, and 0 Diesel Oil Transfer Pumps 1(2)C$0lPA anc B Containment Spray Pumps 1(2)RH019A and B Residual Heat Removal Pumps CSX02PA and B Essential Service Water Makeup Pumps (Olesel)
OWO0lPA and B Control Room Chilled Water Pumps 3.3.2.1 Licensee's Basis for Raouestina Relief. These pumps' bearings are not provided with permanent temperature detectors or thermal wells.
Therefore, gathering data on bearing temperature is impractical. The only tenceratute measurements possible are from the bearing housing. To detect high bearing tet;erature at the bearing housing would require that the bearings in question be seriously degraded. Measurement of housing temperature on these pumps does not provide positive information on bearing condition or degradation. For example, the bearings on the essential service water pumps (05X02PA, 05X02PB) and diesel oil transfer pumps (ID00lPA through 0 and 2000lPA through 0) are cooled by the fluid pumped.
Therefore, any heat generated by degraded bearings is carried away by the cooling fluid and would not be directl,y measured at the bearing housing.
No direct alternate test is proposed for bearing temperature. However, measurement of hydraulic parameters and vibration readings do provide a more positive method of monit%'i.ag pump condition and bearing degradation. By measuring pump hydraulic parameters and vibration velocity, pump operability and the trending of mechanical degradation is assured.. Also, since these parameters (i.e., hydraulic parameters,and vibration) are measured
,l quarterly, the pump mechanical condition will be more accurately determined than would be possible by measurint bearing temperature on t yearly basis, 13
3.3.2,2 Evaluation. Annual bearing temperature measurement for these pu*ps would present a hardship for the licenses since there are no installed temperature detectors and the measurement of bearing housing temperature is subject to environmental factors which challenge the predictability of the measurement.
Bearing temperature measurrxents taken from the bearing housings would be more indicative of th9 ambient teeperature of the purp's environment 'than of the bearing's condition and would not provide a significant contribution to the determination of pump operability. Also, j
the Code specifically exempts temperature measurement for pump bearings in the main flow path (i.e., the service water and diesel fuel oil transfer pumps).
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Further, the Itcensee has elected to use the measurement of vibration in units of velocity rather than displacement amplitude. Vibration 1
measurements in units of velocity are more sensitive to smail changes in pump performance which can be indicative of developing mechanical problems.
These velocity measurements detect the high amplitude vibration that can i
indicate major mechanical problems such as unbalance or misalignment.
These velocity measurements also detect the low amplitude, high frequency vibration caused by bearing wear that usually goes undetected by si.mple displacement measurements.
I Since the licensee has elected to utilize the more predictive j
measurement of vibration velocity amplitude on a quarterly basis, the i
deletion of annual bearing temperature measurements will not adversely 5
affect the detarsination of pump operational readiness and provides a f
reasonable alternative to the Code requirements, l
Based on the determination that meeting the Code requirements would be i
a hardship for the licensee without a compensating increase in the level of safety, relief should be granted as requested.
I 3.3.3 Relief Raouest i
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The licensee has requested relief from the instrument full scale range l
requirement of Section XI. Paragraph !WP 4120, and proposed to utilize
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l ultrasonic flow eters whose accuracy is consistent independent of the range (and which may exceed the range requirements specified in the Code) for the fellcair; pu ;s:
h r !dentificatier Functien C;;;;F Corponent Cooling Pump 1(2)CC01FA anc B Component Cooling Pumps 1(2)C00lPA, B, C, ar.d 0 Diesel Oil Transfer Pumps 1(2)CVOlPA and B Centrifugal Charging Pumps OSXC2PA and B Essential Service Water Makeup Pumps (Diesel) 1(2)SCIPA and B Essential Service Water Pumps 3.3.3.1 Licensev's Basis for Recuestina Relief. The full scale range of ultrasonic flowmeters, used to collect Section XI flow data, exceed three ti es the reference value.
l Ultrasonic flowe.eters provide an accurate means of measuring flow j
rate. They utilize a digital display whose accuracy is independent of the i
full scale range. The ultrasonic flowmeter is well wit,hin the requirements of IWP 4110 and 4120, which refer t', an instrument accu-acy of plus or minus 02*. cf full scale for an instrument with a rangt,f three times the reference value or less. The following examples will illustrate this point. The component cooling pumps (0CCOlP, 1/2CCOlPA, and 1/2CC0lPB) have a referenct value of approximately 4500 gpm. Using the Code requirements, j
an instrument with a full scale range of 13,500 gpm (3 x 4500 gpm), the I
acceptable instrument accuracy is plus or minus 270 gpm (.02 x 13,500 gpm).
Using the ultrasonic flowseter, with an accuracy of plus or minus 4% of the indicated reading, provides an instrument accuracy of plus or minus 180 gpm
(.04 x 4500 gem).
The diesel oil transfer pumps (l'(2) 0001PA.PO) have a reference value of approximately 25 gpm. Using the Code requirements, an instrument with a
.,i full scale of 75 gpm (3 x 25 gpe) the acceptable instrument accuracy is plus 3
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'l or minus 1.5 gpm (.02 x 75 gpm). Using the ultrasonic flowmeter with an
.I accuracy of plus or minus 4% of indicated reading will provide an instru. ent accuracy of plus or minus 1.0 gpm (.04 x 25 gpm).
Use of an ultrasonic flowmeter, with tottlizer and integrator feature, instead of other instruments allowed by IWP.4110 and 4120, will provide more precise and accurate flow measurements.
As an alternative, ultrasonic flowmeters. with digital readouts and
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totalizer features will be utilized to obtain Section XI flow data.
3.3.3.2 Evaluatiga. The Code requires an instrument accuracy of plus or minus 2% of the full scale range for the instrument used to measure flowrate and that the full scale range of the instrument be three times the reference value or less. The licensee has proposed to utilize ultrasonic flowmeters with an accuracy of plus or minus 4% of the indicated reading.
independent of the full scale range (which may exceed three times the reference value), which can provide measurements within the "Acceptabit Instrument, Accuracy' requirements allowed by Table IWP.4110 1.
j A wide variation in flow rates may be encountered during pump testing and it can be advantageous to have a flow meter with accuracy independent of range, as well as an expanded range.
Installation of flow rate instrumentation that meets the Code requireetnts (full scale equals three times the reference value) may not be as accurate as the instrumentation p
that the licensee has proposed to utilize. For instance the Code would allow the use of a meter with a full sca's range of 300 gpm for a pump with a reference flow rate equal to 100 gpe. Therefore, the Code would allow an instrument with a full scale range of 300 gpa to be accurate to plus or minus 6 gpe at the reference value of 100 gpe. A reading on the ultrasonic flowmeter would indicate 100 gpa with an accuracy of plus or minus 4 gem.
l Therefore, the licensee's proposal to uttitte flowrate instrumentation with an accuracy, independent of range, of plus or minus 4% is essentially equivalent to the Code requirements.
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Based on the determination that the licensee's proposed alternative
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- vides a reasonable alternative to the Ccde requirements, relief should te granted as re:wested, i
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VALVE TESTING PROGRAM Tre E ren Station, Units 1 and 2, IST program subm.itted by the f
C:- :..ealin Edis n Com;&ny was examined to verify that all valves that are 1*:b:ed M the program are subjected to the periodic tests recaired ej tre A!"E C::e Section X!, 1980 Edition through the Winter 1951 Addenda, and the N:C csitiens and guidelines. The reviewers found that, except as r:'e: i' A::eadix 0 or where specific relief from testing has been recuested, thte val,es are tested to the Code requirements and the NRC positions and guidelines. Each Co monwealth Edison Company basis for reauesting rel4ef fret the valve testing requirements and the reviewer's evaluation of that I
request is sum.marized below and grouped according to the system and valve Category.
4.1 Containment Scray System 4.1.1 Cate ery A/C Valves 4.1.1.1 celief Re uest. The licensee has requested relief frem exeretsing valves, 1(2)C5008A and B, containment spray (CS) ring header checks, in accordance with the requirements of Section XI. Paragraph IW 3521, and proposed to verify valve operability by either utilizing full flow or by disassembly and inspection on a refueling out49e frequent.
i 4.1.1.1.1 Licensaw's Basis for Raouestina Relief..These valves cannot be full flow tested during unit operation as water from the CS pumps would be discharged through the CS ring haaders causing undesirable effects l
on system components inside containment.
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Partial stroking of the 1/2C5004A B valves using air does not provide an adequate assurance of valve operability and say be detrimental for th!
following reasons:
a). There is no correlation between air flow and angle of disc movement.
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b). Venting and draining the appropi* tate piping quarterly may cause deposition of boric acid residue which could in turn promote binding of the check valve internals.
As an alternative, the 1(2)CS008A and B valves will be eithsr full flow tested, or dismantled to demonstrate operability each reNeling outage.
This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
l 4.1.1.1.2 Evaluation Valves 1(2)C5008A and B are containment isolation valves in the supply lines to the containment spray headers.
It is impractical to 'ull stroke exercise these check valves quarterly during operation since flow through these valves would spray into the containe.ent snd could dsmage equipment. Provisions exist to verify the full stroke capability of these valves with flow utilizing piping spoolpiece hook ups and the containment spray pumps during cold shutdowns. The licer,see has proposed to exercise these valves by either disassembly and inspection or a full flow test on a refueling outage frequency, however, the licensee has 4
f not provided the basis that demonstrates that full flow testing cannot be performed during cold shutdowns. Therefore, the licensee's proposal to I
demonstrate the full stroke capability of these valves by performing valve disassembly and inspection or a full flow test on a refueling outage l
frequency does not provide a reasonable alternative to the Code requirements, i
Since the licensie has not demonstrated that cold shutdown testing is impractical, relief should not be granted as requested.
4.1.2 Catsacrv C Valves j
4.1.2.1 Relief Reauest. The licensee has requested relief from
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exercising valves 1(2)C5020A and I, containment spray (CS) NaOH additive checks, in accordance with the requirements of Section XI, Paragraph !WV 3521, and proposed to disassemble and inspe:t these valves or 1
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perfcrm a system full flow test each refueling outage to demonstrate valve c;erability.
4.1.2.1.1 Licensee's Basis for Decuestina Celief The che:k val.es in the spray additive syst m cannot be stroked without introducing NaCm into the CS system.
As an alternative, these valves will be dismantled each refuelin; cutage.in orcer to demonstrate operactitty.
In addition to this, they will te f all flew tested once every five yr;ars. The full flow test will be perf:rred in lieu of dismantling thri valves, if desiret. This alternative will ade vately maintain the systra. in a state of operational readiness, wht!e not sacriYicing the safety of the plant, by testing the valves as often as safely possible.
4.1.2.1.2 Evaluation It is impractical to either full or part stroke exercise valves 1(2)C5020A and B quarterly during power c;eration or cold shutdown since flow through these valves would result in tr.e introduction of NAT' into the CS system. NaOH is a highly caustic, extremely corrosive chemical, which poses a serious threat to personnel and equipment. Full flow exercising of these valves can be performed by special test, however, this requires special test hook ups and necessitates flushing the system. This presents a safety hazard to operating personnel and would be burdensome fer the licensee to perfom during cold shutdowns. The I
licensee's proposal to demonstrate the full stroke capability of these valves on a refueling outage frequency by either disassembly and inspection of check valve internals or by system full float testing provides a reascnable alternative to the Code requirements.
Based on the determination that it is impractical to test these valves in accordance with the Code requirements, that the licensee's proposal provides a reasonable alternative to the Code requirements, and considering the burden on the licensee if the Code requirements wert
.f imposed, relief should be granted as requested, i
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4.1.2.2 Relief Reouest. The licensee has requested relief from exercising valves, 1(2,1CS003A and B, containment spray (CS) pump discharge checks, in accordance with the requirements of Section XI.
Paragraph IWV 3521, and proposed to verify valve operability bj part stroke exercising these valves quarterly and by disassembly and inspection or full flow testing on a refueling outage frequency.
4.1.2.2.1 Licensee's Basis for Recuestina Relief These valves cannot be full flow tested during unit operation as water from the CS pu ps would be discharged through the CS ring headers causing undesirable effects on system components inside containment.
As an alternative, the 1(2)CS003A and B valves will be partial stroke tested during the quarterly. pump surveillance and full flow tested, or dismantled, to demonstrate operability, each refueling outage. This alternative will adequately maintain the system in a state of operational readiness, while not sacrtftcing the safety of the plant, by testing these valves as often as safely possible.
4.1.2.2.2 Evaluation Valves 1(2)CS003A and B are containment spray pump discharge checks in the supply lines to the containment spray headers.
It is impractical to full stroke exercise these check valv e quarterly during operation beca.'se full flow through these valves would result in spray flow into the containment vessel and could cause equipment damage.
!eposition of the Code requirements would necessitate significant j
system modifications. A small pump test line is available and during quarterly pump testing allows a part. stroke exercise of these valves with i
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flow. The Itcensee's proposal, to perform a part stroke exercise of these j
valves quarterly during pump surveillance testing, utilizing the I
i recirculation flow path, and further, to perform a full flow test or valve i
disassembly and internals inspection on a refueling outage frequency to demonstrate their full stroke capability, provides a reasonable alternative j
to the Code requirements.
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Based on the determination that it is iepractical to test these vahes in accordance with the Code requirements, that the licensee's
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- alternate testing frequency provides a reasonable assurance of c;eraticeal resciness, and considering the burden on the licensee if the 3:e re:;tremts were impcsed, relief should be granted as re;;ested.
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4.2 Safety Inteetien system 4.2.1 Cate:ery att valves 4
4.2.1.1 Relief Decuest. The licensee has requested relief from exercising valves 1(2)$!!948A D and 1(2)S!8956A 0, accumulator discharge checks in accordance with the requirements of Section XI, Paragraphs N',' 2411 anc 3!21, and proposed to full stroke exercise these valves at least once every nine months during cold shutdowns by providing a surge volu e in the pressurizer, ' burping the valves', and noting a change in l
pressurizer lesel.
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a.2.1.1.1 Licensee's Basis for Recuestina Relief The accumulater check valves cannot be tested during unit operation due to the pressure differential between the accumulators (650 psig) and the reactor coolant systen (2235 psig). Full stroke exercising of these valves could occur only ith a rapid depressurization of the reactor coolant system.
Byron Station Technical Specifications require leak testing to be 3
perfermed on these valves if the unit is in cold shutdown and if such leak rate testing has not been performed within nine months. Therefore, Byron 4
Station will full stroke exercise (Ct) these valves on the snee schedule, j
This will be accomplished by providing a surge volume in the pressuitrer and
' burping' the accueulator discharge valves. As a minimus, the accumulators will be discharged into the reactor vessel during refueling outages to perform full stroke exercise (Ct) of these valves. Positive vertftcation of valve operability will be by noting a change in accumulator level, Stroke exercising the check valves on the same schedule as their required Technical b
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9 30ecification leik rate testing will adequately maintain the system in a state of operational readiness without causing unnecessary personnel radiation exposure.
4.2.1.1.2 Evaluction It is impractical to full or part stroke exercise the accumulator discharge check valves 1(2)S!8948A 0 and 1(2)S!8956A D quarterly during power operation since the reactor coolant systerr (RCS) pressure is much higher than accumulator pressure and flew i
through th,ese valves cannot be established. Valves 1(2)S!8948A 0 can te at least part stroke exercised during cold shutdown by "burping" the accumulator discharge isolation valves into a surge volume in the RCS pressurizer. However, some positive method an1 be used to verify flow through these valves, such as timing the rate of accumulator level decrease.
The reviewer believes that a full stroke exercise of these valves can be achieved durteg refueling outages by rapidly discharging the accumulators into the depressurized RCS with an adequate surge volume available (i.e..
with the reactor vessel head removed); flow rate can be calculated by timing the decrease in accumulator level. The NRC staff position is that demonstration of check valve full stroke utilizing flow requires the maximum flow rate taken credit for in any of the plant's safety. analyses be passed, and verified, through the valve. This is an extremely high flowrate for these accumulator discharge check valves (>10,000 gpm) and the reviewer believes that this would be difficult to achieve (ess,tetally during cold shutdowns); however, if the licensee is able to demonstrate that this flow is passed through these valves then this would constitute a full stroke.
The licensee's proposal, to full stroke exercise these valves during cSid shutdowns, if not performed within the last nine months, provided this testing verifies the actual full stroke capability of these valves in accordance with the MtC staff's position described above would provide a reasonable assurance of operational readiness.
Based on the impracticability of complying with the Code requirements, and considering the licensee's proposed testing frequency, 1
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t relief should be granted as requested provided the licensee can demonstrate that a full stroke test is being performed when using the proposed eethed.
4.2.1.2 Deli?f Reevest. The licensee has requested relief fr v exercising the following valves in accordance with the require?ents of Se:tien XI, Paragraphs !W 3412 and 3522, and proposed to full stroke exercise these valves with flow during refueling outages with the reactor vessel head removed.
Valve Identificatien Function 1(2)S!8819A D Cold leg safety injection check valves.
1(2)$1890!A 0 Hot leg safety injection check valves, 1(2)S!!i45A D Hot leg safety injection check valves.
4.2.1.2.1 Licensee's Basis for Recuest% Relief 8yron Station Te:hnical Specifications require all Safety injection pumps and all but ene
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Charging Pump to be inoperable during Modes 4, 5, and 6, except when the reactor vessel head is removed. This requirement minimizes the possibility of low temperature overpressurization of the Reactor Coolant System.
Therefore, check valves 1(2)$18819A-0, 1(2)$18905A 0, and 1(2)S!8949A 0, cannot be full stroke exercised during cold shutdowns as required by IW 3412 and IW 3522.
In addition to the stroke test exercise used to verify operational readiness of theso check valves, the act of such stroking causes the necessity for Technical Specification required Idak rate testing of these valves prior to unit criticality. This testing, in conjunction with the stroke exercising of these check valves, adds approximately one week to the duration of any outage and additional radiation exposure to workers who must connect flowmeters and differential pressure gauges directly to pipes l
containing radioactive fluids.
Byron Station's Technical Specifications require leak rate testing to i
be performel on these valves if the unit is in cold shutdown and if such leak rate
.ing has not been performed within nine months.. Stroke exercising of check valves 1(2)$18819A 0, 1(2)$18905A 0, and 1(2)$18949A D, 25
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can only be performed in mode 6 with the reactor vessel head removed. Full stroke exercising of these check valves will be performed as plant conditions allow, but at a minimum frequency of once each refueling outage.
Stroke exercising check valves 1(2)$18819A 0, 1(2)S!S90!A 0, and 1(2)S18949A 0, at least once per reactor refueling will insure compliance with Byron Station Technical Specifications and minimize the possibility of low tcmperature overpressurization of the reactor Coolant System.
4.2.1.2.2 Evaluation..It is impractical to devnstrate the i
full stroke capability of valves 1(2)Sl8819A 0, 1(2)$18905A 0, and 1(2)518949A 0, during cold shutdewns utilizing flow since this could po'se the risk of low temperature overprc:surization of the reactor coolant systa.
These valves receive th'eir flow from high pressure sources and I
should cnly be full stroke exercised utilizing flow when a sufficient surge volume is available (i.e., when the reactor vessel head is removed).
Cooldown and depressurization of the reactor coolant system and removal of.
the reactor vessel head solely to facilitate full stroke exercising these valves at cold shutdown (due to low temperature overpressuritation concerns) l wculd be extremely time consuming, difficult, and burdensome to the licensee. The licensee's proposal to full stroke exercise these valves during refueling outages with the reactor vessel head removed should provide l
a reasonable assurance of operational readiness.
Based on the impracticability of complying with the Code requirements, the burden on the licensee if the Code requirerents were teposed, anj considering the proposed testing, relief should be granted 45 requested.
4.2.1.3 Rallaf Ranuest. The licensee has requested relief from exercising the following valves in accordance with the requirements of Section T.1, Paragraphs IW 3412 and 3522, and proposed to full stroke exercise these valves during cold shutdowns if greater than nine months have passed since thi last test.
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Valve Identification Function 1(2)$18$15 r.harging pump discharge to cold leg Check valve.
1(2)$!6541A and B riot leg safety injection check valves.
1(2)$liKCA 0 Charging safety injection check valves.
4.2.1.1.1 Lhwee's Basis for Recuestine celief The full strne exercising of check valvas not stroked quarterly is required to be perfer e:
during cold shat h ns. However, the stroking of check valves 1(2)$!!$15.
1(2)$!!9CCA 0, and 1(2)!!!!41A B, associated with the emergency ccre coelic; system, during cold shutdowns, will induce thermal stresses on their respective reactor vessel nozzles as the reactor coolant system (maintained apprcximately 180 F) is injected with water from the refueling water storage tank (maintained approximately 65 F).
In addition to the stroke test exercise used to verify operational reaciness of these check valves, the act of such stroking causes the necessity for Technical Specification required leak rate testing of these valves prior to unit criticality. This testing, in conjunction with the stroke exercising of these check valves, adds approximately one week to the duration of aay outage and additional radiation exposure to workers who must connect flowmeters end differential pressure gauges directly to pipes containing radioactive fluids.
Byron Station's Technical Specifications require leak rate testing to be performed on these valves if the unit is in cold shutdown and if such leak rate testing has not been performed within nine months. Therefore, Byrcn Station will stroke exercise check valves 1(2)S!8815, 1(2)S!8900A 0.
and 1(2)S!8841A and B on the same schedule, if plant conditions allow.
Stroke exercising the 1(2)$14415, 1(2)$18900A 0, and 1(2)$18841A and B check valves on the same schedule as their required Technical Specificatien leak rate testing, as plant conditions. allow, will adequately maintain the system in a state of operational readiness without creating additional undue thereal stresses to the reactor vessel nozzles or unnecessary personnel radiation exposure.
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4.2.1.3.2 Evaluatien.. Valves 1(2)$18815, 1(2)SISS41A and S, anc i
1(2)S!8900A.0, are reactor coolant system pressure isolation valves. The act of opening any of these valves invokes a leak rate test per Byron Station Technical Specifications.
It is impractical to full or part streke exercise these valves quarterly during power operations as this would require charging cold water through the reactor vessel injection no::les causing significant thermal stresses. The licensee has stated that the performance of leak rate testing on these valves (due to exercising the valves) during cold shutdowns will result in additional radiation er posure to workers, however, has not provided any indication of the specific levels involved that would justify the extansion of the testing interval for these valves.
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l The licensee's proposal to exercise these valves during cold shutdowns l
if not performed in the previous nine months with tre stipulation "as plant
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conditions allow' is unacceptable since this is an ambiguous statement and,
can te interpreted in a non conservative manner. The fact that plant Technical Specifications require these valves to have a leak test performed during cold shutdowns, if such testing has not been performed in the
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previous nine months, is not an adequate technical justification for extending the exercising frequency. Further, thermi stress considerat*
t for a temperature difference of approximately 115 degrees F do act sv.~.o warrant an extension of the testing frequency to that proposed. Therefore, the licensee has not demonstrated that testing these valves curing each cold j
shutdown is impractical.
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Since the licensee has not demonstrated that cold shutdown testing j
is trpractical, relief should not be granted as requested.
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4.2.2 Catenarv R Valves l
J 4.2.2.1 Rollef Reaggit. The Itcensee has requested relief fros exercising valves 1(2)$1MllA and B, containment sump outlet isolations, in I
accordance with the requirements of Section II, Paragraph IWV 3412, and l
proposed to full stroke exercise these valves on a refueling outage j
frequency.
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l' 4.2.2.1.1 Licensee's Basis for Reauestina Relief--The ful1-stroke exercis 99 of valves not stroked quarterly is required to be pe formed during cold shutdowns. However, the stroking of the Containment Sump Outlet Isolation Valves, l',1)S!8811A and B, requires the suction of the residual heat removal pumps to be drained, thus rendering one train of the system inoperable.
With one train of residual heat removal declared inoperable, Byron Station's Technical Specifications require two steam generators with a level greater than 41% (Unit 1) and 187. (Unit 2).
If the cold shutdown conditicn was necessitated by a secondary side steam generator problem, Byron Station's Technical Specifications would preclude such testing until such time as the steam generators had been refilled.
The full-stroke testing of the 1(2)S18811A and B valves; in conjunction with system draining, refilling and venting of each train solely for the purposes of such testing, accounts for an addition:1 six days of scheduling requirements for a unit cold shutdown outage. The alternate testing during refJeling outages will adequately maintain the system ir. a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
l As an alternative, Byron Station will full stroke exercise the Containment Sump Outlet Isolation Valves, 1(2)S!8811A and B, during refueling outages vice cold shutdown.
4.2.2.1.2 Evaluation It is impractical to full or part stroke exercise valves 1(2)$18811A and B quarterly during power operation as this requires draining tha suction piping for one train of residual heat removal and rendering it inoperable. The licensee has' stated that with cne train of residual heat re6. oval inoperable (at cold shutdown) certain requirements exist with respect to tha minimum level required in two of their four steam generators. However, the reviewer considers the probability of a cold shutdown resulting from secondary side steam generator problems in more than two steam generators quite remote and inconvenience is not an adequate 29
i justification for an extension of the testing interval from that required by the Code.
The licensee has not demonstrated that it is impractical to exercise these valves during cold shutdowns. Therefore, the licensee's proposal does not provide a reasonable alternative to the Code requirements.
i Since the licensee has not demonstrated that cold shutdown testing is impractical, relief should not be granted as requested.
i 4.2.3 Catecory C Valves 4.2.3.1 Relief Raouest. The licensee has requested relief from exercising valves 1(2)S!8922A and 8, safety injection pumps' discharge checks, in accordance with the requirements of Section XI, Paragraph IWV 3521 and proposed to full-stroke exercise these valves on a refueling outage frequency.
4.2.3.1.1 Licensee's Basis for Raouestina Relief. These check valves cannot be full flow (full-stroke) tested during operation as the shutoff head of the safs y injection pumps is lower than the reactor coolant system (RCS) pressure, e3rformance of this test with the RCS depressurized, but intact, could lead to inadvertent overpressurization of the system.
The alternate method of protecting against overpressurization by partially draining the RCS to provide a surge volume is not considered a safe practice due to concerns of maintaining adequate water level above the reactor core.
As an alternative, these valves will be full stroke tested during refueling outages as a minimum, but no more frequently than once per quarter. This alternative will adequatoly maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
4.2.3.1;2 Evaluation It is impractical to full or part stroke exercise valves 1(2)S!8922A and B during power operation since RCS pressure is above the shutoff head of these pumps and flow cannot be estabitshed through them. A full or part stroke exercise of these valves during cold 30 J
shutdown would risk low temperature overpressurization of the RCS and is, therefore, not practical. Cooldown and depressurization of the reactor coolant system and removal of the reactor vessel head solely to facilitate full-stroke exercising these valves at cold shutdown (due to low temperature over;ressurization concerns) would be time consuming, difficult, and extremely burdensome to the licensee. Full-stroke exercising these valves utilizing system flow during refueling outages when an adequate surge volu e exists (i.e., when the reactor vessel head is removed) provides reasonable assurance of operational readiness and a reasonable alternative to the Ccce requirements.
Based on the impracticability of complying with the Code requirements, the burden on the licensee if the Code requirements were imposed, and considering the proposed testing, relief should be granted.
4.2.3.2 Relief Reouest. The licensee has requested relief from exercising valves 1(2)S!8926, safety injection pump suction checks, in accordance with the requirements of Section XI, Paragraph IWV 3521, and proposed to part stroke exercise these valves quarterly and to full stroke exercise these valves on a refueling outage frequency.
4.2.3.2.1 Licensee's Basis for Raouestina Relief -Full stroke exercising of the Safety injection (SI) pump suction check valves, 1(2)S!8926, cannot be demonstrated during unit op1 ration as the reactor coolant system pressure prevents the pumps from reaching full flow injection conditions. Performance of this test with the reactor coolant system intact would lead to an inadvertent overpressurization of the system. The alternate method of protecting against overpressurization by partial draining of the reactor coolant system (RCS) to provide a surge volume.is not considered a safe practice due to concerns'of maintaining adequate water level above the reactor core.
As an alternative, the 1(2)!!Ss26 valves will be partial stroke tested during periodic inservice tests with the Si pumps in the recirculation mode. Full stroke exercising for these valves will be done during refueling 31 t
outages as a minimum, but no more frecuently than once per quarter. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safaly possible.
4.2.3.2.2 Evaluation -These valves can be part stroke exercised quarterly utilizing the recirculation flow path during safety injection pump testing.
It is impractical to full-stroke exercise valves 1(2) SIS 926 during power operation since RC3 pressure is above the shutoff head of the SI pumps and the recirculation line will not pass the flow required to full stroke exercise these valves. Full stroke exercising these valves is also impractical during cold shutdown as passing the necessary flow would require a large surge volume, and could cause low temperature overpressuritation of the RCS. Cooldown and depressurization of the reactor coolant system and removal of the reactor vessel head solely to facilitate full stroke exercising these valves at cold shutdown (due to low temperature overpressurization concerns) would be time consuming, difficult, and extremely burdensome to the licensee. Part stroke exercising these valves quarterly and full-stroke exercising these valves during refueling outages, when an adequate surge volume exists for the RCS (i.e., when the reactor vessel head is removed), provides a reasonable assurance of operational
'dinass and a reasonable alternative to the Code requirements.
Based on the impracticability of complying with the Code requirements, the burden on the licensee if the Code requirements were imposed, and considering the proposed testing, reitef should be granted.
4.3 Comoonent Coolina System 4.3.1 httaory A Valves 4.3.1.1 Relief Raouest. The licensee has requested relief from exercising the following valves in accordance with the requirements of 32 1
Section XI, Paragraph IWV 3412, and proposed to full-stroke exercise these valves during refueling outages and during cold shutdowns when the reactor
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Valve identification Function 1(2)CC6S5 Component cooling supply to reactor coolant purps 1(2)CC9413A Componant cooling return from reactor coolant pumps 1(2)CC9414 Compo ent cooling supply to reactor coolant pumps 1(2)CC9416 Component cooling supply to reactor coolant pu s 1(2)CC9a38 Component cooling supply to reactor coolant pumps 4.3.1.1.1 Licensee's Basis for Recuestina Relief Component cooling water flow to the reactor coolant pumps is required at all times while the pumps are in operation and for an extended period of time while in cold shutdown. Failure of one of these valves in a closed position during an exercise test would result in a loss of cooling flow to the pumps and eventual pump damage and/or trip.
As an alternative, these valvss will be exercised during cold shutdown.
previded all of the reactor coolant pumps are not in operation. This testing period will be each refueling outage as a minimum, but no more frequently than once per quarter. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
4.3.1.1.2 Evaluation Thess valves provide cooling water flow to the reactor coolant pumps.
It is imp'ractical to exercise these valves quarterly during operations, or during cold shutdowns when the reactor coolant pumps are in operation, since failure of one of these valves in the closed position could result in pump damage. The licensee's proposal, to exercise these valves during cold shutdowns when all the reactor coolant pumps are stopped and during refueling outages, provides a reasonable alternative to the Code requirements.
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Besed on the determination that the Code requirements are impractical, the licensee's proposed alternate testing frequency, and giving due consideration to the burden on the licensee if the Code requirements are i.tposed, relief should be granted as requested.
4.3.2 Cateaory A/C Valves 4.3.2.1 Relief Reauest. The licensee has requested relief from exercising valves 1(2)CC9486, component cooling return from reactor coolant pump checks, in accordance with the requirements of Section XI, Paragraph IWV 3521, and proposed to full stroke exercise these valves during refueling outages during seat leakage testing.,
4.3.2.1.1 Licensee's Basis for Reauestina Relief Component cooling water flow to the reactor coolant pumps is required at all times while the pumps are in operation and for an extended period of time while in cold shutdown. Failure of one of these valves in a closed position during an exercise test would result in a loss of cooling flow to the pumps and eventual pump damage and/or trip.
As an alternative, check valves 1(2)CC9486 will be stroke tested (Ct) closed on the same frequency as the seat leakage test per IWV 3420.
This frequency is at least once per two years, to be perfor:ued during refueling outages. Stroke exercising check valves 1(2)CC9486 on the same schedule as their leak rate testing will adequately maintain the system in a state of operational readiness without causing unnecessary personnel radiation exposure or possible damage to the Reactor Coolant Pumps.
4.3.2.1.2 Evaluation--This check valve is in the component cooling water supply to the reactor coolant pumps inside the containment.
Verification of the reverse flow closure for this valve requires a pressure source on the downstream side of this valve, and some test configuration to detect leakage through the valve (i.e., leak testing per IWV 3420).
Performance of this test necessitates shutting off cooling flow to the reactor coolant pumps, making test connections inside containment, isolating 34
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sections of piping, etc., and would be burdensome to the licensee to perfor-during cold shutdowns. The NRC staff position is that relief may be granted fren the Code required testing frequency for check valves inside containcer.t wnese closure function can be verified only by leak testing which is rcuttnely performLJ at refueling outages. The licensee's proposal to verify this.alv'es closure during leak testing per IWV 3420 provides a reasonable alternative to the Code requirements.
Based on the impracticability of complying with the Code recuirements, the burden on the licensee if the Code requirements were ieccsed, and the licensee's proposed testing frequency, relief should be granted as requested.
4.4 Chemical and Volume Control System 4.4.1 Catecory A Valves 4.4.1.1 Relief Reauest. The licensee has requested relief from exercising valves 1(2)CV8100 and 1(2)CV8112, reactor :oolant pumps' seal water returns, in accordance with the requirements of Section XI, Paragraph IWV 3411, and proposed to full stroke exercise these valves during cold shutdowns when the reactor coolant pumps are not in operation and during refueling outages.
4.4.1.1.1 Licensee's Basis for Recuestina Relief These valves cannot be tested during unit operation as seal water flow to the reactor coolant pumps is required at all times while the pumps are in operation.
Failure of one of the e valves in the closed position during an exercise test would result in +al water return flow being diverted to the pressurizer relief tar.L (PRT) by lifting a relief valve upstream of the isolation valves.
As an alternative, these valves will be exercise tested during cold shutdown, providing all reactor coolant pumps are not in operation. This testing period will be each refuelir.g outage as a minimum, but no more 35
frequently than once per quarter.
This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
4.4.1.1.2 Evaluation -Valves 1(2)CV8100 and 1(2)CV8112 are containmet isolation valves in the return line from the reactor coolant pump se; -
it is impractical to exercise these valves quarterly during reactor ecolant pump operation as failure of one of these valves in the closed position would result in forcing the system relief valve,1(2)CV8121.
to ope'n diverting seal water flow to the pRT generating large quantities of liquid radwaste. This would be burdensome to the licensee. The licensee's proposal to full stroke exercising these valves during cold shutdowns, provided that the reactor coolant pumps are not in operation, and during refueling outages, provides a reasonable alternative to the Code requirements.
Based on the impracticability of complying with the Code
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requirements, the burden on the licensee if the Code requirements were imposed, and considering the licensee's proposed alternate testing frequency, relief should be granted as requested.
4.5 Instrument Air System 4.5.1 Cateaory A Valves 4.5.1.1 Relief Reauest. The licensee has requested relief from exercising valves 1(2)lA065 and 1(2)lA066, instrument air containment isolation valves, in accordance with the requirements of Section XI, Paragraphs !WV-3411(a) and 3415, and proposed to full stroke exercise these valves during cold shutdowns, when this does not disrupt cold shutdown operations, and during refueling operations.
4.5.1.1.1 Licensee's Basis for Reauestina Relief Stroke testing of these valves during plant operation would isolate the air operated G
36
instruments and valves inside the containment building. Stroke exercising of these valves would be impractical because if these valves failed in the closed position during unit operation, instrurentation would not functicn pro:erly end valves would stroke to their failure position, causing the loss of support equipment and possibly a reactor trip.
As an alternative, these valves will be exercised during cold shute:v.r..
prc,iding that all necessary equipment required for cold shutdown operations would not be affected. This testing period will be each refueling outage as a mininum, but no more frequently than once per quarter. This alternative will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant, by testing the valves as often as safely possible.
4.5.1.1.2 Evaluatien Exercising valves 1(2)lA065 and 1(2)!A066 quarterly during power operation is impractical because the loss of
~
instrument air could seriously disrupt normal valve operations and possibly result in a reactor trip. The licensee's proposed alternate frequency, to full stroke exercise these valves during cold shutdowns, when affected equipment is not necessary, and during refueling outages, is not clearly defined and could be interpreted in a non conservative manner, and therefore, is not a reasonable alternative to the Code requirements.
Further, the licensee has not provided a technical discussion to demonstrate the impracticality of performing this testing on a cold shutdown frequency.
Since the licensee has not demonstrated that cold shutdown testing is impractical, relief should not be granted as requested.
4.6 Diesel Generatina System 4.6.1 Caltagry B&C Valves 4.6.1.1 Relief Reauest. The licensee has requested relief from testing valves 1(2)0G5182A 0, 1(2)DG5183A 0, 1(2)DG5184A.D. and 1(2)0G5185A 0, diesel generator air start valves, in accordance with the 37
requirements of Section XI, Parecraphs IWV-3412, 3413(b), 3417, and 3522, and proposed to verify valve operattlity during performance of the monthly diesel generator operability surveillance.
The licensee has provided in addition to their basis the following discussion:
"These valves are not within the scope of ASME Code.
Section XI, Subsection IWV requirements. However, the requirements for stroke timing and trending of the valves associated with the diesel cir start system are being mandated by the NRC as an augmented testing requirement pursuant to 10 CFR 50.55(a)'g). Therefore, valves associated with the diesel air start system shall be d ercis d to the position required to fulfill their function during plant operation per IWV 3412 and 3522.
Additionally, the stroke testing of power operated valves shall be measured to the nearest second and such stroke times trended to document continued valve operational readiness per IWV 3413(b) and 3417".
4.6.1.1.1 Licensee's Basis for Raouestino Relief.-The monthly diesel generator testing program, outlined in Byron Station's Technical Specifications and implemented by station operating procedures, exceeds the intent of the quarterly valve testing program which would be required by ASME Code,Section XI. Additionally, the stroke timing of solenoid operated valves associated with the Diesel Air Start System is impractical due to the fast actuation of these valves.
As an alternative, the performance of Byron Station's diesel generator operability monthly surveillance will verify the operational readiness of the valves associated with the Diesel Air Start System. This surveillance testing will require the recording of the air pressures contained in both trains A and B of the Diesel Generator Air Start receiver tanks both before and imediately after diesel generator start. By the comparison of these values between trains, the satisfactory operation of the power operated and self actuated check valves associated with tha Diesel Air Start System can be adequately demonstrated.
Proper valve operation will be demonstrated on a monthly basis by the verification of diesel generator air start capability. Such verification 38 i
will compare the air pressures contained in the receiver tanks both before and af ter the diesel generator start, thus verifying the operability of the air start control valves. The proposed testing methodology at the increased fre;uency satisfies the intent of the Section XI requirements without posing undue hardships or difficulties.
4.6.1.1.2 Evaluation Due to the short stroke times and the syste 3; plication of these solenoid operated valves, it is impractical to obtain a direct stroke time measurement without significant system design changes.
These valves function to admit starting air to the emergency diesei generators and the failure of one of these valves to open in a timely manner would be indicated by a pressure imbalance between the starting air receivers, and possibly, an increase in diesel generator start time.
Further, the Byron Station emergency diesel generators are tested monthly rather than quarterly. The licensee's proposal to verify valve operability, by comparison of the air pressures inside the starting air receivers before-and ie. mediately after diesel start each month, should furnish timely indication should degradation of these valves occur and provides a reasonable alternative to the Code requirements.
Based on the impracticability of the Code requirements, the burden on the licensee if the Code requirements were imposed, and the licensee's proposed alternate testing method and increased testing frequency, relief should be granted as requested.
4.7 Essential Service Water Systen 4.7.1 Catacorv 8 Valves 4.7.1.1 Relief Raouest. The licensee has requested relief from testing valves 1(2)SX101A, service water valves from the auxiliary feedwater pump lube oil coolers, in accordance with the requirement. of Section XI, Paragraphs !WV 3413 and 3417, and proposed to verify valve operability during quarterly auxiliary feedwater pump surveillance testing.
39
i 4.7.1.1.1 Licensee's Basis for Recuestina Reliaf -1(2)SX101A are
.l the essential service water outlet isolation valves for the Unit 1/2 motor driven auxiliary feedwater pump lube oil coolers. These valves are completely encapsulated per design and do not have local or remote position indicators which could be used to time the valve stroke.
As an alternative, 1(2)SX101A will be verified to open during each quarterly ASME surveillance of the motor driven auxiliary feedwater pumps.
In addition, these valves are stroked monthly during the auxiliary feedwater I
pump surveillances required by Byron Technical Specifications. These valves I
will be stroke exercised to their required safety positions each month during the motor driven auxiliary feedwater pump surveillances. This i
testing will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant.
4.7.1.1.2 Evaluation -Que to the encapsulated design of this valve, and because this valve has no local or remote position indication, it is impractical to directly observe the valve stem for positf on indication or to time thq valve stroke. The position of this valve may be determined by observing lube oil temperatures, when the auxiliary feedwater pump is running, however, no practical method can be used to accurately determine stroke time without system modification. The licensee's proposal to verify that the valves are stroking during monthly pump surveillances would be more r
conservative than the Code required frequency and presents a reasonable alternative to the Code requirements.
Based on the impracticability of the Code requirements, the burden on the licensee if the Code requirements were imposed, and the licensee's l
proposed alternate testing method and frequency, relief should be granted as requested.
I 40
4.8 All Systems 4.5.1 Catecerv A Valves 4.8.1.1 Relief Recuejt. The licensee has requested relief from seat leakage measurements for all Unit 1(2) containment isolation valves in accordance with the requirements of Section XI, Paragraph IWV 3420, and ceccesed to seat leakage test these valves in accordance with the requir.ements of 10 CFR 50, Appendix J.
4.8.1.1.1 Licensee's Basis for Recuestino Relief Primary containment isolation valves will be seat leak tested in accordance with 10 CFR 50, Appendix J.
For these valves, Section'XI testing requirements are essentially equivalent to those of Appendix J.
As an alternative, primary containment isolation valves will be seat 1eak tested in accordance with the Appendix J requirements of 10 CFR 50. No additional information concerning valve leakage would be gained by performing separate tests to both Section XI and Appendix J.
Therefore, overall plant safety is not affected.
4.8.1.1.2 Evaluati n-The leak test procedures and requirements 2
for containment isolation valves identified in 10 CFR 50, Appendix J essentially meet the Section XI Code requirements since it incorporates all the major elements of Paragraphs IWV 3421 through 3425, however, the 10 CFR 50, Appendix J, leak rate testing does not trend leakage rates or take corrective actions based on individu,.1 valve leakage rates. Testing the containment isolation valves in accordance with 10 CFR 50, Appendix J, provides a reasonable alternative to the requirements of Section XI, Paragraphs !WY 3421 through 3425, however, the'licinsee must comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs IWV 3426 and 3427, in order to obtain this relief.
Based on the determination that leak testing the containment isolation valves in accordance with the requirements of 10 CFR 50, 41
Appendix J, is essentially equivalent to the requirements of IWV-3421 through 3425, relief should be granted from the requirements of IWV 3421 through 3425. However, the licensee must adhere to the requirements of Section XI, Paragraphs IWV 3426 and 3427, Analysis of Leakage Rates and Corrective Action Requirements in order to obtain this relief.
4.8.2 Raoid Actina Valves 4.8.2.1 Relief Recuest. The licensee has requested relief frem comparison of stroke times for the following listed valves in a:cordance with the requirements of Section XI, Paragraph IWV 3417(a), and proposed a fast acting stroke time limit of 2 seconds; upon exceeding 2 seconds, the testing frequency shall be increased to monthly until corrective action is taken, or the valve strokes in two seconds or less, further, no comparison of stroke times will be performed.
Valve Identification Function 1(2)CV8152 RCS letdown containment isolation valves 1(2)CV8160 RCS letdown containment isolation valves 1(2)MS001A D Main steam isolation valves 1(2)M5018A 0 Main steam power operated relief valves 1(2)PR066 Process radiation monitor return to containment isolation valves 1(2)RE9157 Reactor coolant drain tank gas to radwaste containment isolation valves 1(2)RE9159A and B Reactor coolant drain tank gas to radwaste containment isolation valves 1(2)RE9160A and B Reactor coolant drain tank gas to radwaste containment isolation valves l
1(2)RY8033 Pressurizer relief tank N2 supply containment isolation valves 1(2)S0005A 0 Steam generator sample isolation valves 1(2)S18871 Si test line containment isolation valves 1 2)S!8880 Accumulator nitrogen supply isolation valves f
1 21518888 51 test line containment isolation valves 1 2)PS228A and B Process sampling supply containment isolation t
1(2)PS229A and B Process sampling supply containment isolation 1(2)PS230A and B Process sampling return containment isolation 1(2)RC014A D Reactor vessel head vents 42 i
l l
4.8.2.1.1 Licensee's Basis for Reouestino Relief--Minor timing inaccuracies, with small stroke times can lead to substantial increases (percent wise) in stroke times. For example, a valve with a stroke time of I second in an initial test, and 1.6 seconds in the subsequent test, has experienced an apparent 607. increase in stroke time.
If the accuracy recuirements of IWV 3413(b) are utilized, it could be argued that stroke times bet.een 1 and 2 seconds could constitute as much as a 1007 increase in stroke time when, in fact, only a 0.2 second increase occu. red. For instance, if the initial time was 1.4 seconds, (measured to the nearest second is 1.0 second) and if the next time is then 1.6 seconds, (measured to the nearest second is 2.0 seconds) the percent increase is 100f.,
As an alternative, fast acting valves will be defined as those valves that normally stroke in 2 seconds or less. Data will be analyzed utilizing the guidance set forth in !WV 3413(b). No trending of stroke time will be required, unless the 2 second fast acting time is exceeded. Upon exceeding, 2 seconds, the test frequency shall be increased to monthly and trending of stroke times shall begin, until corrective action is taken, or the stroke time returns to less than or equal to 2 seconds. Upon' exceeding the maximum stroke time listed in the valve program tables for the above valve, corrective ac+1on shall be taken imediately in accordance with IWV 3417(b).
For small stroke times, the trending requirements are too stringent for the accuracies specified in the Code. The alternative specified will adequately maintain the system in a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
4.8.2.1.2 Evaluation The Code requires the comparison of power operated valve stroke times from test to test. For valves with short stroke times this comparison may not be practical since a slight (.2 second) change in stroke time may call for an increased frequency of testing though no degradation in stroke time has occurred (for valves with short stroke times the difference from test to test may be introduced by the timing method or theoperator). Placing a maximum limiting stroke time of 2 seconds on the 43
above listed valves, which the licensee has stated normally stroke in 2 seconds or less, is considered by NRC to provide a reasonable alternative to the Code requirements. However, upon xceeding this 2 second limit the licensee should declare these valves inoperable and perform corrective action per IWV 3417(b).
The licensee has proposed that upon exceeding the 2 second limit; the testing frequency will be increased to monthly and valve stroke times will be trended'until the stroke time returns to less than or equal to 2 seconds or corrective action is taken. These valves would be declared inocerable only if the stroke times listed in the IST program are exceeded. The st'roke time limits listed in the IST program for these valves may be as high as 15 seconds. Allowing a valve that normally strokes in 2 seconds or less to degrade to the point where its stroke time exceeds 15 seconds, prior to declaring the valve inoperable and taking corrective action, is not acceptable as an alternative to the Code requirements.
Increasing the test frequency, to once a month, and trending the stroke times for these rapid-acting valves does not' provide a reasonable alternative to the Code requirements since it does not adequately address the cause of the change in stroke time.
Based on the determination that the licensee's proposed alternative does not provide a reasonable alternative to the Code requirements, relief should not be granted as requested.
44
APPENDIX A S
- e 45
APPENDIX A VALVES TESTED OURING COLD SHUTOOWN ine following are Category A, B, and C valves that meet the exercising recuire ents of the ASME Code,Section XI, and are not full stroke exercised e,ery three months during plant operation. These valves are specifically identified by the owner in accordance with Paragraphs IWV 3412 and 3522 anc are full-strons exercised during cold shutdowns and refueling outages. All valves in this Appendix have been evaluated and the reviewer agrees with the i
licensee that testing these valves during power operation is not possible due to the valve type, location, or system design. These valves should not be full stroke exercised during p wer operations. These valves are listed below and grouped according to the system in which they are located.
i 1.
MAIN STEAM SYSTEM 1.1 cateaory B Valves The closure of the main steam isolation valves, 1(2)MS001A 0, during unit operation would result in a reactor trip and safety injection actuation. To avoid this transient, these valves will be part stroke exercised every three months and full stroke exercising will be done during i
Mode 4 following, or preceding cold shutdown, per IWV 3412.
2.
CHEMICAL AND VOLUME CONTROL SYSTEM 2.1 cateaory A and a valves
]
Closure of these letdown and makeup valves, 1(2)CVil2 8 and C, 1(2)CV8105,1(2)CV8106,1(2)CV8152, and 1(2)CV8160, during normal unit operation would cause a loss of charging flow which would result in a reactor coolant inventory transient, and possibly, a subsequent reactor i
trip. These valves will be full stroke exercised during cold shutdown as required by IWV 3412.
]
47 j
2.2 Catecorv B and C Valves The testing of any emergency boration flow path valves during unit operation is not practical. Strob testing the boric acid injection isolation valves, 1(2)CV8104, and check valves, 1(2)CV8442, the refueling water storage tank (RWST) to chemical and volume control (CV) pu p suction check valves,1(2)CV8546. the residual heat (RH) to CV pump suction j
isolation valves, 1(2)CV8804A, or the RWST to CV pump suction isolation valves, 1(2)CV1120 and E, could result in over boration of the reactor coolant syst>v (RCS), resulting in a cooldeun transient. Aligning the system in this configuration, even for a short duration, is therefore, unacceptable. These valves will be full-stroke exercised during cold shutdown in accordance with !WV 3412 and 3522.
2.3 Cateaory C Valves The centrifugal charging pump discharge check valves, 1(2)CV8481A and B, cannot be full stroke exercised during unit operation. Due to the high reactor coolant system pressure during operation the high flowrate necessary cannot be established through these valves t'o verify their full stroke
[
capability. These check valves will be part stroke exer ~cised, however, on a quarterly basis and full stroke exercised during cold shutdown in accordance with IWV 3522.
t l
3.
MAIN FEE 0 WATER SYSTEM i
3.1 Cateaory B Valves Main feedutor isolation valves,1(2)FWOO9A 0, cannot be full stroke exercised quarterly during power operation as feedwater flow would be terminated and could cause a reactor trip. These valves will be part stroke exercised during power operation and full stroke exercised during cold shutdown as required by IWV 3412.
Valves 1(2)FWo39A 0, main feedwater to auxiliary feedwater isolation salves, cannot be stroke exercised during unit operation as closure of these valves would result in termination of the waterhamer prevention feedwater 48
ficw. This would result in undesirable affects on the steam generators.
These valves will be full stroke exercised during cold shutdown as required Of !WV 3412.
4 RESIDUAL HEAT REMOVAL SYSTEM 4.1 Cateaory A Valves The 1(2)RHS701A and 8 and the 1(2)RH8702A and B valves are the isolation boundary between the residual heat removal (RHR) pumps and the RCS. Opening one of these valves during unit operation will leave only one valve isolating RHR from the high RCS pressure. This would place the plant in an undesirable condition. Therefore, these valves will be full-stroke exercised during cold shutdown, per IWV 3412.
4.2 Cateaory C Valves The residual heat removal pump discharge check valves, 1(2)RH8730A and B, cannot be full stroke exercised during unit operation d M to the high RCS pressure. These check valves will be part stroke exercised, however, on a quarterly basis and full stroke exercised during cold shutdown in accordance with IWV 3322.
5.
REACTOR COOLANT SYSTEM 5.1 Cateaery B valves The reactor pressure vessel vent valves, 1(2)RC014A 0, cannot be stroke exercised during unit operation as they provide a pressure boundary between the reactor coolant system and containment atmosphere. Failure of one of these valves in the open position would result in leaving only one valve as the high pressure boundary. These valves will be full stroke exercised when the RCS pressure is at a minimus during cold shutdown, per IWV 3412.
e 49 I
.g
- -,> - ~ - - - - - - - - - -
6.
PRIMARY CONTAINMENT PURGE SUPPLY SYSTEM 6.1 Cateoorv A Valves The primary containment purge supply and exhaust valves, 1(2)VQ001A and B and 1(2)VQ002A and B, cannot be exercised and stroke timed during unit operation. These 48 inch valves are the only isolation points between the containment atmosphere and the environment. Stroke exercising these valves at any time other than made 5 or 6 would be a violation of the Byron Technical Specificitions. These valves will be full stroke exercised during cold shutdown, in accordance with IWV-3412.
7.
AUXILIARY FEE 0 WATER SYSTEM 7.1 Cktecory C Valves The auxiliary feedwater check valves,1(2)AF001A and B,1(2)AF003A and B, 1(2)AF014A H, and 1(2)AF029A and B, cannot be full-stroke exercised during unit operation, as this would induce potentially damaging thermal stresses in the upper feedwater nozzle piping. The 1(2)AF001A and B, and 1(2)AF003A and B. valves will be part-stroke exercised during operation, and all valves will be full stroke exercised during cold shutdown.
8.
SAFETY INJECTION SYSTEM 8.1 Cateaory B Valves i
The high head injection isolation valves, 1(2)S!8801A and B, cannot be full stroke exercised during unit operation. These valves isolate the charging system from cold leg injection. Opening them during operation would enable charging flow to pass directly into the RCS, bypassing the regenerative heat exchanger. The temperature difference of the charging flow and the RCS could result in damaging thermal stresses to the cold leg nozzles as well as causing a reactivity change which would, in turn, cause a t
50
(
I
plant transient. These valves will be full-stroke exercised during cold i
shutccon in accordance with iWV 3412.
t The safety injection system SVAG (spurious valve action group) valves.
1(2)S!!802A and 8, 1(2) SIS 806, 1(2)S18809A and 8, 1(2)S18813, 1(2)S18835, and 1(2)S183 0, cannot be full or part stroke exercised during unit operation.
These valsas are required by the Technical Specifications to be ce energized in their proper positions during unit operation. Stroking the9 would te a violation of the Technical Specifications as well as defeating the de energized SVAG valve principle. These valves will be full stroke exercised during cold shutdown in accordance with IWV 3412.
8.2 Cateaory C Valves The check valves listed below cannot be full-stroke exercised during operation as the the RHR pumps discharge pressure is significantly below that of the RCS operating pressure and flow cannot be established. These valves will be full stroke exercised during cold shutdown in accordance with IWV 3522.
Valve Identification Function 1(2)$18818A thru 0 RHR cold leg injection checks l
1(2)S18958A and B RWST to RHR pump suction checks 1
4 l
1 4
e 51 a
i
9 4
F h
e APPENDIX 8 B
4 0
5 53
APPENDIX B The IS! Boundary Drawings listed below were used during the ccurse of tnis review.
Syste.
Drawina No.
Revisien Main Feedaater M 36 1 Y
Auxiliary Feed.ater M 37 AA Essential Service Water M 42 1 Y
Essential Service Water M 42 3
'AB Essential Service Water M 42 5 T
Containment Spray M 46 40 l
j Offgas System Hydrogen Recombiners M 47 2 M
Waste Disposal Steam Generator Blowdown M 48 5 V
Waste Disposal Steam Generator Blowdown M 48 6 W
l Make up Demineralizer M 491 0
Ciesel Fuel oil M 50 1 AC Fire Protection (Category-1)
M 52 1 N
Service Air M 54 2 N
Instrument Air M 55 2 T
Diagram of Reactor Coolant Loop l M 60 1 A0 Diagram of Reactor Coolant M 60 5 V
s Oiagram of Reactor Coolant M 60 6 T
Safety injection M 61 1 AE Safety injection M 61 2 Z
Safety Injection M 61 3 V
i Safety Injection M 61 4 V
l j
Safety injection M 61 5 L
Safety Injection M 61 6 V
Residual Heat Removal M 42 AF
]
Fuel Pool Cooling and Clean up M 63 AK i
Chemical and Volume Control and M 64 1 Y
Boron Thermal Regeneration 1
$5 1
i
\\
1 i
j
l System Drawina No.
MLi,g3 l
Chemical and Volume Control and M 64 2 Y
Boron _ Thermal Regen'eration i
Chemical and Volume Control and M 64-3 AE Boron Thermal Regeneration Chemical and Volume Control and M 64 4 AG Boron Thermal Re-ineration Chemic;il and Volume Control and M 64 5 AB Boron Thermal Regeneration j
Boric Acid Processing M 65 5 AG '
Component Cooling M 66 1
, AA i
Component Cooling M 66 2 W
Component Cooling M 66 3 AB l
Process Sampling (Primary and Secondary)
M 68-1 Y
j Reactor Building and Containment M 70 1 5
i Equipeent Orains and Vents to Radwaste Process Radiation Monitoring M 78 6 A
i Process Radiation Monitoring M 78 10 L
l Integrated Leak Rate Test M 105 1 N
Integrated Leak Rate Test M 105 3 C
I Control Room Chilled Water System (WO)
M 118 1 T
i Containment Chilled Water System (WC)
M ll8 5 S
i i
i 4
]
l i
1 4
56
}
i
I l
t 1
1 APPENDIX C 1
)
1 l
i l
i 1
e e'
i 6
0 I
57
APPENDIX C IST PROGRAM ANCMALIES 10ENTIFIED DURING THE REVIEW I
Inconsiste h ies and omissions in the licensee's program r.oted during tne course of this review are summarized below. The *icensee should resche these ite s in accordance with the evaluations, conclusions, and guidelines presented in this report.
)
1.
The Boric Acid Transfer pumps OAB03P, IAB03P, and 2AB03P are included ir Byron Station FSAR, Table 3.9 15, as Active Pumps.
Paragraph
.9.6.1, Inservice Testing of Pumps, states that all pumps incitJed in Table 3.9-15 require inservice testing.
Therefore, the Boric Acid Transfer pumps should be included in the Byron Station IST program and tested to the Code requirements.
2.
The reviewer agrees with the basis of pump relief request PR 1 fo'r all pumps, however, the essential service water make up pumps, OSX02PA and B, must have corrective action taken in'accordance with the requirements of IWP 3230 when the vibration velocity measurements exceed.70 inches per second (see TER section 3.2.1).
3.
Pump relief request PR 3 (see TER section 3.1.1) proposes to evaluate the essential service water askeup pumps, OSX02PA and B.
utilizing pump discharge pressure. Some method can and should be utilized to determine the pump inlet pressure (i.e., measurement of the head of water above the pump suction) for calculation of pump differential pressure and evaluation of the pump's hydraulic performance.
4.
The licensee has included the power operated relief valves (PORVs) in their IST program as Category B valves and proposed to exercise these valves quarterly, The MC staff's position is that the PORVs should be exercised prior to achieving the condition which i
59
l l
requires them to be operable and the exercising frequency should be on the approach to the cold shutdown corottien and prior to the time when these valve; are required to be operable for low temperature overpressurization protection.
5.
Valve relief request VR 1 (see TER section 4.8.1.1) proposes a satisfactory alternative to the Code requirement for seat leakage l
measurements on all affected valves, however, the seat leakage measurements must be evaluated and corrective action taken per the Analysis of Leakage Rstes and Corrective Action requirements of Paragraphs IWV 3426 and 3427.
l 6.
Valve relief request VR.4 (see TER section 4.1.1.1) requests relief from the exercising frequency for valves 1(2)CS008A and B and proposes to perform either a full flow test or valve disassembly and internals inspection on a refueling outage frequency. The licensee has not demonstrated the impracticality of performing this testing on a cold shutdown frequency.
7.
In valve relief request VR 5 (see TER section 4.2.1.1) the licensee 'u proposed to full-;troke exercise 'the accumulator outlet che a valves 1(2)S!8948A 0 and 1(2)SI8956A 0 at cold shutdowns, if not performed in the previous nine months. These valves can be full stroke exercised by timing the rate of decrease af accumulator level and enrapolating the flow rate through the valves, however, this flow rate is quite high and the reviewcr feels that a regional inspector and/or NRR reviewer should be present for this testing to ensure that these valves are full stroke exercised in accordancir with the Code requirements.
]
8.
In valve ralief request VR 10 (see TER section 4.5.1.1) the licensee has proposed to exercise valves 1(2)!A065 and 1(2)!Aoi6 4
during cold stutdowns, on a non specific frequency, and during refueling outages. Since the licensee has not proposed a specific 1
i
--. ~
frequency and has not provided the conditions under which this testing will be performed this relief request should be denied.
9.
Valve relief request VR 12 (see TER section 4.8.2.1) addresses rapid acting valves (i.e., valves that normally operate in 2 seconds or less), however, the IST program valve list identifies maximum stroke times for these valves of from 2 to 15 seconds.
If a maximum stroke time of 2 seconds has been placed on these vahes then it thould be reflected in the maximum stroke time section of the !$T program valve list. Further, the licensee's proposal to assign a fast acting Ilmit of 2 seconds and upon exceeding this limit to increase the test fra.1uency to monthly and to t.'end the stroke timcs do^ not
. ' reasonable alternative to the Code requirements.
- 10. Valve relief request VR IS (see TER section 4.2.1.3) proposes to full stroke exercise valves 1(2)Slti915, 1(2)S18841A and B, and 1(2)S!8900A 0 on a conditional basis during cold shutdowns, however, the conditions under which this testing are to take place are not clearly defined. Further, in the absence of evidence to demonstrate exercising these valves on a colfi shutdown frequency is impractical, relief should not be granted.
l
- 11. Valve relief request VR 16 (see TER section 4.2.2.1) proposes to
)
full stroke exercise the containment sump outlet isolation valves, l
1(2)S!8811A and b, during refueling outages. The licensee has not
{
demonstrated the impracticality of performing this testing on a i
cold shutdown frequency and this relief request should be cenied.
- 12. Valve relief request VR 17 (see TER section 4.7.1.1) proposes to exercise valves 1(2)SX101A during monthly surveillances on the motor driven auxiliary feedwater pump lube oil coolers, however, the licensee has not described the testing method that.will verify valve operability. A regional inspector and/or NRR reviewer I
should verify that thi testing verifies the operability of this valve.-
61
Docket hos.:
50-454/455 ENCLOSURE 2 SYSTEMATIC ASSESSMENT OF LICENSEEE PERFORMANCE SALP REPORT LICENSEE: Comon ealth Edison Company PLANT: Byron Station, Units 1 ano 2 REVIEWER:
K. Derresey FUNCTICNAL ACTIVITY: Review of Licensee's IST Program (TAC NOS. 56201/63241)
(1) h nagement involvement in Assuring Quality Licensee management involvement appeared to be adequate.
Rating Category: 2 (2) gpreach to Resolution of Technical Issues from a Safety Standpoint Licensee runagement appearea to have an adequate understanding of the technical issues.
Rating Category: 2 I
(3) Responsiveness to NRC Initiatives l
Licensee providea timely responses.
Rating Category: 2 i
(4) Staffing i
Meetings and other contacts with the licensee were staffed with competent personnel.
4 Rating Category: 2 (5) Reportine and Analysis of Reportable Events N/A (6) Training and Qualifications N/A j
.1 (7) Enforcement History 1
i N/A i
l 1
..w.................
...:............u.........
?,*/*d d' SISUQGRAPHIC OATA SHEET EGG-NTA-8051
.46.g...t* 0 gg.....g,s.sg
...,a......
TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM, 81RON STATION, UNITS 1 AND 2
. :......:..... i:
x,.. -
I June 1988 R. S. Hartley
......:.* i...:
H. C. Rockhold "ca'-
June g
1988
....;...26.4.........................<.4.
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Mechanica* Syste.ns Evaluations Unit EG&G !cano. I'c.
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P. O. Box 1625
!cano Falls 10 9341$
A6812
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Mechanical En ineering Branch Office of Nuc ear Reactor Regulation Technical Evaluation Report U. S. Nuclear Regulatory Ce nission
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Washington DC 20555
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This EG8G Idaho. Inc. reoort presents the results of our evaluation of the Byron Station. Units 1 and 2. Inservice Testing Program for pumps and valves that perform a safety-related function.
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