ML20207H351
| ML20207H351 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/30/1986 |
| From: | Lyon R, Rockhold H EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20207H357 | List: |
| References | |
| CON-FIN-A-6811 EGG-NTA-7441, NUDOCS 8701070512 | |
| Download: ML20207H351 (90) | |
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EGG-NTA-7441 TECHNICAL EVALUATION REPORT .
PUMP AND VALVE INSERVICE TESTING PROGRAM CATAWBA NUCLEAR STATION, UNITS 1 & 2 s Docket Nos. 50-413 and 50-414 R. E. Lyon H. C. Rockhold Published November 1986 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under 00E Contract No. DE-AC07-76ID01570 FIN No. A6811
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o- l' ABSTRACT This EG&G Idaho, Inc., report presents the results of cur evaluation .
of the Catawba Nuclear Station, Units 1 & 2, Inservice Testing Program for safety-relatad pumps and valves. .
FOREWORD This report is supplied as part of the " Review of Pun;p and Valve Inservice Testing Programs for Operating License Plants", program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing A, by EG&G Idaho, Inc., NRR and I&E Support.
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The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-40-41-2, FIN No. A6811.
I Docket Nos. 50-413 and 50-414 l
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. I CONTENTS
- 1. INTRODUCTION ..................................................... 1
- 2. PUMP TESTING PROGRAM ............................................. 3 2.1 General Relief Requests .............................<....... 3 2.2 Nuclear Service Water Pumps ................................. 5
- 3. VALV E TESTI NG P ROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1 General Relief Requests ....................,................. 6 3.1.1 Trend Analysis on Rapid Acting Valves ............. 6 3.1.2 Power Operated Valves ............................. 7 3.1.3 Leak Rate Analysis and Corrective Action .......... 8 3.2 Auxiliary Feedwater System .................................. 9 3.2.1 Category C Valves ................................. 9 3.3 Diesel Generator Engine Cooling Water System ................ 12 3.3.1 Category C Valves ................................. 12 3.4 Boron Recycle System ........................................ 13 3.4.1 Category A/C Valves ............................... 13 3.5 Reactor Coolant System ...................................... 14 3.5.1 Category A/C Valves ............................... 14 3.6 Ice Condenser Refrigeration System .......................... 15 .
3.6.1 Category A/C Valves ............................... 15 3.7 Safety Injection System .. .................................. 16 3.7.1 Category A/C Vai,es ............................... 16 3.7.2 Category C Valves ................................. 23 3.8 Containment Spray System ......'.............................. 28 3.8.1 Category C Valves .... .......................... 28 4
3.9 Chemical and Volume Control Syster ....................... 33 3.9.1 Category A/C Valves ............................... 33 3.9.2 C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 iii
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. t 3.10 Containment Valve Injection Water System .................... 37 3.10.1 Category C Valves ................................. 37 3.11 Interior Fire Protection System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 3.11.1 Category A/C Valves ............................... 39 3.12 Nuclear Service Water System ..........................'...... 40 3.12.1 Category A/C Valves ............................... 40 3.13 Main Steam to Auxiliary Equipment ........................... 40 3.13.1 Category C Valves ................................. 40 3.14 Breathing Air System ........................................ 42 3.14.1 Category A/C Valves ............................... 42 3.15 Die sel Generator Engine Starting Ai r System . . . . . . . . . . . . . . . . . 43 3.15.1 Category B Valves ................................. 43 3.15.2 Category C Valves ................................. 44 3.16 Instrument Air System ....................................... 45 3.16.1 Category A/C Valves ............................... 45 3.16.2 Category C Valves ................................. 46 3.17 Containment Purga System .................................... 47 3.17.1 Category A Valves ................................. 47
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3.18 Station Air System .......................................... 48 3.18.1 Category A/C Valves ............................... 48 3.19 Containment Hydrogen Sample and Purge System ................ 49 3.19.1 Category A/C Valves ............................... 49
-3.20 Makeup Demineralized Water System ........................... 50 3.20.1 C a t e g o ry A/C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 3.21 Perscanel Airlock .. ........................................ 51 3.21.1 Category A Valves ................................. 51 3.21.2 Category A/C Valves ............................... 51 3.22 Component Cooling Water System .............................. 52 3.22.1 Category A/C Valves ............................... 52 iv
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.- t APPENDIX A--NRC STAFF POSITIONS AND GUIDELINES ........................ 54
- 1. Full-Stroke Exercising of Check Valves ...................... 55
- 2. Valves Identified for Cold Shutdown Testing ................. 55
- 3. Conditions for Valve Testing During Cold Shutdown ........... 56
- 4. Category A Valve Leak Test Requirements for Containment Isolation Valves ............................................ 56
- 5. Application of Appendix J Testing to the IST Program - .... ... 57
- 6. Safety-Related Valves ....................................... 57
- 7. Active Valves ............................................... 57
- 8. Rapid-Acting Power Operated Valves .......................... 58
- 9. Valves Which Perform a Pressure Boundary Isolation Function .................................................... 58
- 10. Pressurizer Power Operated Relief Valves .................... 62 APPENDIX B--VALVES TESTED DURING COLD SHUTDOWNS ....................... 63 APPENDIX C--P&ID LISTING .............................................. 67 APPENDIX D--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW ........ 71 APPENDIX E--VALVES TESTED DURING COLD SHUTDOWNS--DETAILS .............. 74
- 1. AUXILIARY FEEDWATER SYSTEM .................................. 75 1.1 Category B Valves ...................................... 75 1.2 Category C Valves ...................................... 75
- 2. F E E DWAT E R S Y S T EM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 2.1 Category B Valves ...................................... 76
- 3. REFUELING WATER SYSTEM .......l.............................. 76 3.1 Category C Valves ...................................... 76
- 4. COMPONENT COOLING WATER SYSTEM .............................. 76 4.1 Category B Valves ...................................... 76
- 5. REACTOR COOLANT SYSTEM ...................................... 77 5.1 Category B Valves ........,............................. 77
- 6. RESIDUAL HEAT REMOVAL SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78 6.1 Category A Valves ...................................... 78 l 6.2 C a te g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78 6.3 Category C Valves ...................................... 78 v
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. u 7.1 SAFETY I NJ ECTION SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 7.1 Category A/C Valves .................................... 79 7.2 Ca t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
- 8. CHEMICAL AND VOLUME CONTROL SYSTEM . . . . . . . . . . . . . . . . . .. . . . . . . . . 82 8.1 C a t e g o ry A V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 8.2 C a t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
- 9. NUCLEAR SERVICE WATER SYSTEM ................................ 83 9.1 Category B Valves ...................................... 83
- 10. MAIN STEAM SYSTEM ........................................... 84 10 .1 Ca t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
- 11. INSTRUMENT AIR SYSTEM ....................................... 55 11.1 Category A Valves ...................................... 85 e
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. e TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM CATAWBA NUCLEAR STATION, UNITS 1 & 2
- 1. INTRODUCTION Contained herein is a technical evaluation of the pump and" valve inservice testing (IST) programs submitted by Duke Power Company (DPC) for its Catawba Nuclear Station, Units 1 & 2.
The licensee'.s IST program for Unit 1, Revision 0, was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety-related with the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition through the Winter 1980 Addenda. Those items not in complisnce were discussed during a working meeting with Duke -
Power representatives on December 18 and 19, 1984. The licensee has submitted modifications to his program for Unit 1 through Revision 12 and has also submitted, with changes through Revision 3, a program for Unit 2.
As part of the revision, he has updated to a later version of the Code (1983 Edition through the Summer 1983 Addenda). In their IST submittals, Duke Power Company has requested relief from the ASME Code testing requirements for specific pumps and valv,es and these requests have been evaluated individually to determine whether the tests, as required, are indeed impractical. The NRC staff position is that required program changes, such as additional relief 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 shculd not be l implemented prior to review and approval by the NRC. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER).
This review was performed uts11 zing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and l
Value/ Impact Statement titled " Identification of Valves for Inclusion in l
l' Inservice Testing Programs." These IST Program testing requirements apply 1
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. e only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current technical specifications system test requirements.
Unless otherwise stated, evaluations apply to the programs for both '
Unit 1 and Unit 2, and the unit designation has'been dropped from the component number. Where evaluations are specific to one unit it will be so identified and the unit designation will be included in the component number.
The NRC staff's positions and guidelines concerning inservice testing requirements are provided in Appendix A.
Category A, B, and C valves that meet the requirements of the ASME Code,Section XI, but are not exercised quarterly are listed in Appendix Be A listing of P& ids used for this review is contained in Appendix 0.
Inconsistencies and omissions 'n the licensee's IST program noted during the course of this review are listed in Appendix D. The licensee should resolve these items in accordance with the evaluations, and conclusions, and guidelines presented in this report.
The details of valve cold shutdown testing justifications are included in Appendix E.
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- 2. PUMP TESTING PROGRAM The Catawba, Units 1 and 2, IST programs submitted by DPC were examined to verify that all pumps that are included in the programs are subjected to the periodic tests required by the ASME Code,Section XI, except for those pumps identified below for which specific relief from testing has been requested and as summarized in Appendix D. Each DPC basis for requesting relief from the pump testing requirements and the reviewer's evaluation of that request is summarized below.
2.1 General Relief Requests 2.1.1 Relief Request -
The licensee has requested relief from measuring pump static sucticn pressure on pumps that are already in operation at the time of testing in accordance with the requirements of Section XI, Paragraph IWP-3400(b).
2.1.1.1 Licensee's Basis for Requesting Relief. The purpose for measuring pump suction pressure prior to starting a pump is to ensure adequate NPSH is available. Some pumps may already be running to support
- normal plant operation when the pump test is run. Since a pump may,already
. be in service, NPSH requirements have been met. It is unnecessary to stop an operating pump only to measure static suction pressure.
Pump suction pressure, prior to and folicwing startup, will be
- measured for pumps which are not currently in operation at time of test.
Pump suction pressure with the pump running will be measured for pumps which are currently in operation at time of test.
2.1.1.2 Evaluation. The reviewer agrees with the licensee that adequate NPSH can be demonstrated by the fact that the pump is operating properly.
2.1.1.3 Conclusion. The reviewer concludes the proposed alternate testing for pumps already in operation should be sufficient to demonstrate 3
f proper operability of these pumps and, therefore, relief should be granted from the requirement of Section XI to measure pump static suction pressure if that pump is already in operation.
2.1.2 Relief Request y The licensee has requested relief from the accuracy requirements of.
l_ Section XI, Paragraph IWP-4110, for vibration amplitude measurements and has proposed to measure vibration with portable instrumentation.
2.1.2.1 Licensee's Basis for Requesting Relief. Catawba has no permanently installed vibration instrumentation. Portable instruments used I
to measure vibration amplitude have an accuracy of 111% full scale.
Vibration will be measured utilizing portable instrumentation with an accuracy of 111% full scale.
2.1.2.2 Evaluation. The reviewer disagrees with the licensee's basis
! because the NRC position on measuring Section XI parameters requires that the necessary instrumentation be installed or obtained and the lack of sufficiently accurate instrumentation is not an adequate technical justification for granting relief. The NRC staff has determined that 'the
_ measurement accuracies identified in Table IWP-4110-1 should be achieved
, for these pumps in order to provide reasonable assurance of their
' continuing operational readiness.
I 2.1.2.4 Conclusion. The reviewer concludes that the licensee should j measure pump vibration amplitude within the accuracy requirements of Section XI. Suitable instrumentation or other means should be provided by the licensee in order to do so. The licensee should be required to obtain suitably accurate instrumentation prior to the end of the next refueling
{ outage. For the balance of the period of the current fuel cycle, interim relief should be granted to test the pumps as proposed by the licensee.
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2.2 Nuclear Service Water Pumps 2.2.1 Relief Request The licensee has raquested relief from the annual bearing _ temperature measurement for the nuclear service water pumps in accordance with the requirements of Section XI, Paragraph IWP-3300, and has proposed to utilize the quarterly vibration amplitude measurement to determine bearing condition.
2.2.1.1 Licensee's Basis for Requesting Relief. There is no j instrumentation installed to measure pump bearing temperature and no
- meaningful data can be obtained from bearing housing surface temperature measurements. Bearings are cooled by pump flowing medium and are r inaccessible. ,
The mechanical condition of the pump bearings will be determined from vibration amplitude measurements which will be obtained quarterly.
2.2.1.2 Evaluation. The reviewer agrees with the licensee that, since the bearings are cooled by the pump flowing medium, the bearing temperature will vary with the temperature of the coolant and will not be
! an accurate indication of bearing condition.
. 2.2.1.3 Conclusion. The reviewer concludes that the licensee's proposal to measure all parameters except bearing temperature for the nuclear service water pumps should be sufficient to monitor pump degradation and, therefore, relief should be granted from the requirement of Section XI.
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- 3. VALVE TESTING PROGRAM The Catawba Nuclear Station, Units 1 and 2, IST programs submitted by-Duke Power Company were examined to verify that all valves inc]uddd.in the programs are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. The reviewer found that, except as noted in Appendix 0 or where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines summarized in Appendix A of this report. Each Duke Power Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to system and valve' category.
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i 3.1 General Relief Requests 3.1.1 Trend Analysis of Rapid-Acting Valves 3.1.1.1 Relief Request. The licensee has requested relief from the trend analysis requirements of Section XI, Paragraph IWV-3417(a), for all power operated, rapid-acting valves whose function is safety-related and proposed to apply a maximum stroke time limit to all power operated,
! , rapid-acting valves, i.e., those valves with stroke times of less than or equal to 2 seconds.
3.1.1.1.1 Licensee's Basis for Requesting Relief--Fast-acting valve stroke times (those with stroke times of 52 seconds) will not be
. trended. Since stroke times are only measured to the nearest second (per I'WV-3413(b)) it is difficult to screen out variables which can influence stroke times of 52 seconds.
Trend analyses will not be performed on valves with stroke times of
$2 seconds. Corrective maintenance will be initiated if stroke time
. exceeds maximum specified time.
3.1.1.1.2 Evaluation--The reviewer agrees with the licensee that rapid-acting valves are difficult to stroke time using presently available l
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l methods of measurement and the results are subject to variation due to influences other than valve condition. (Also see Paragraph A.8 of Appendix A of this report.)
3.1.1.1.3 Conclusion--The reviewer concludes that the proposed alternate method of assigning a maximum stroke time to valves with stroke times of less than or equal to 2 seconds should provide meaningful data to adequately monitor valve degradation and, therefore, relief should be granted from the stroke time trending requirements of Section XI.
3.1.2 Stroke Time for power Operated Valves 3.1.2.1 Relief Request. The licensee has requested relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413(a),-
for power operated valves and proposed to measure stroke time from limit ,
switch to limit switch.
3.1.2.1.1 Licensee's Basis for Requesting Relief--Catawba's Operator Aid Computer Response Time Testing Program measures response time between limit switch actuations, rather than from the initiation of the actuating signal. The only way to time the valve using the actuating signal as the initiating point is through the use of some manual means, such as a stop watch. More consistent and repeatable results can be obtained by timing the valve from limit switch to limit switch.
Valves will normally be timed from limit switch to limit switch. In cases w,ere this is not practical, timing will be manually done from initiation of the actuating signal.
3.1.2.1.2 Evaluation--The reviewer agrees with the licensee's
! basis concerning the stroke time methodology for valves which are monitored by the Operator Aid Computer Response Time Testing Program and that l
measuring response time between limit switch actuations using this procedure will give more accurate results than manual timing from the actuating signal.
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3.1.2.1.3 Conclusion--The reviewer concludes that the proposed alternate method of measuring valve stroke time from limit switch to limit switch provides information which is basically equivalent with that required by Section XI and should provide meaningful data to adequately monitor valve degradation and, therefore, relief should be granted from the
,N requirements of Section XI.
3.1.3 Leak Rate Analysis and Corrective Action 3.1.3.1 Relief Request. The licensee has requested relief from the leak rate analysis and corrective action requirements of Paragraphs IWV-3426 and IWV-3427 of Section XI and proposed to utilize the total Type C leak rate limit and a fixed valve leak rate limit to determine the need for corrective action. -
3.1.3.1.1 Licensee's Basis for Requesting Relief--During critical path testing, it may be desirable to exempt certain valves from the leakage limits established by IWV-3426 and the trending requirements of IWV-3427 provided total Tech Spec leakage rates for Type C tests are within limit.
1 Valves may be exempted from the requirements of IWV-3426 and IWV-3427 provided:
- 1. Valve leak rate test is a critical path item leading te return to power operation,
- 2. Total Type C leak rate is within Tech Spec Limits, and
- 3. Valve leak rate does not exceed'15D standard cubic feet / day.
(300 Standard Cubic feet / day for check valves.)
In addition, these valves will have corrective maintenance performed to reduce the leak rate during the next outage of sufficient duration.
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1 3.1.3.1.2 Evaluation--The reviewer does not agree with the licensee's basis because the NRC staff position is that the intent of Paragraphs IWV-3421 through IWV-3425 is met by 10 CFR 50, Appendix J, testing requirements, however, the licensee must still comply with the Analysis of Leakage Rates and Corrective Action requirements o{
Paragraphs IWV-3426 and IWV-3427. (Also see Paragraph A.4 of Appendix A of this report.)
3.1.3.1.3 Conclusion--The reviewer concludes that the licensee should revise their IST program to comply with the NRC staff position described above and in Paragraph A.4 of Appendix A of this report and that relief should not be granted from these requirements of Section XI.
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3.2 Auxiliary Feedwater System 3.2.1 Category C Valves i
3.2.1.1 Relief Request. The licensee has requested relief from exercising valves CA8, CA10, and CA12, auxiliary feedwater non-safety
- suction isolations, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to verify valve closure by pressurization during refueling outages.
3.2.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be verified during refueling by pressurizing valves and measuring leakage.
3.2.1.1.2 Evaluation--The reviewer agrees with the licensee's basis in part because, due to plant design, the only method available to verify valve closure (their safety-related position) is pressurization testing. This test method cannot be utilized during power operation because the auxiliary feedwater pump associated with each valve must be removed from service while each valve is being tested. However, the 9
licensee has not provided sufficient justification as to why this pressurization test cannot be performed at a cold shutdown interval.
3.2.1.1.3 Conclusion--The reviewer concludes that the licensee should verify valve closure at a cold shutdown interval in order to
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demonstrate proper valve operability.
3.2.1.2 Relief Request--The licensee has requested relief from exercising valves CA171 and CA172, auxiliary feedwater suction from the nuclear service water system checks, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to partial-stroke the valves quarterly and to implement a sampling disassembly program during refueling outages.
3.2.1.2.1 Licensee's Basis for Requesting Relief--Full-stroking these valves would result in feeding dirty water into the steam generators as the only full flow path is to the steam generators. Valves can be partial-stroked quarterly using the test line to the auxiliary feedwater pump sump.
Check valves will be exercised (partial-stroke) to the position required to fulfill their function every 3 months. During each refueling, one of the two check valves will be disassembled and the disk will be mechanically exercised. The next refueling the other valve will be
. disassembled, such that both valves will be tested in a two refueling time period. Should one valve fail to stroke acceptably, the other valve will also be disassembled.
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3.2.1.2.2 Evaluation--The reviewer agrees with the ifcensee's basis because these valves cannot be exer'ised c during power operation or cold shutdown without introducing service water into the suction piping of the emergency feedwater pumps and from there into the steam generators.
l The service water contains impurities which would upset the secondary water chemistry and could cause chemical stress damage to the steam generators.
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Additienally, the NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of, construction) and must have the same service conditions. Additionally,at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that' group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the interrals between these tests. This relief request should contain all pertinent historical maintenan::e data on each valve, including the inspection and maintenance
- , data obtained at each disassembly / inspection and manual full-stroke.
, Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.2.1.2.3 Conclusion--The reviewer concludes that the proposed alternate testing of partial-stroke exercising these valves quarterly and a sample disassembly program during refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the full-stroke exercising requirements of Section XI.
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3.3 Diesel Generator Engine Cooling Water System 3.3.1 Category C Valves 3.3.1.1 Relief Request. Thelicenseehasrequestedrelie{fr'om exercising valves KDE and KD21, diesel generator engine cooling water checks, in accordance with the requirements of Section XI, Paragraph IWV-3522, and proposed to verify proper cooling during diesel generator tests and. disassemble and examine each valve during each refueling outage.
3.3.1.1.1 Licensee's Basis for Requesting Relief--No method exists of directly verifying valve movement. Valves will be verified to operate during monthly Tech Specs Diesel Test (PT/1/A/4350/02A, B - Diesel '
Generator A, B Operability Test) by verifying proper cooling is supplied i
-during diesel run.
r In addition, the valves will be disassembled (as required by IE Bulletin No. 83-03) during each refueling and the mechanical integrity of ,
the valve internals verified.
4 3.3.1.1.2 Evaluation--The reviewer agrees that, due to plant
- design, the only way to verify valve opening is to monitor proper diesel
. generator cool ing and to periodically disassemble the valves and verify the .
integrity of the internals. Additionally, the NRC staff has concluded that
- a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
r A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire I
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group has been tested.' If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that l group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual . full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. Thisreliefrequestshouldcontainallpertinenthistorickl maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual. full-stroke.
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
l 3.3.1.1.3 Conclusion--The reviewer concludes that the proposed ,
alternate testing of verifying pruper diesel generator cooling, supplemented by valve disassembly during refueling outages, should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.4 Boron Recycle System )
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. 3.4.1 Category A/C Valves 3.4.1.1 Relief Request. The licensee has requested relief from exercising valve NB262, boron recycle system containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and
-3520, and has proposed to leak-rate test this valve during refueling l outages. ,
3.4.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
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Valve closure will be verified during performanc of leak rate testing during refueling.
3.4.1.1.2 Evaluation--The reviewer agrees with the Itcensee
' that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. Thisv'diveis located inside containment and is not equipped with position indication.
3.4.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.5 Reactor Coolant System 3.5.1 Category A/C Valves 3.5.1.1 Relief Request. The licensee has requested relief from exercising valve NC57, pressurizer relief tank makeup containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to leak-rate test this valve during refueling outages.
3.5.1.1.1 Licensee's,3 asis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
1 Valve closure will be verified during performance of leak rate testing
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! during refueling.
3.5.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
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3.5.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.6 Ice Condenser Refrigeration System 3.6.1 Category A/C Valves .
3.6.1.1 Relief Request. The licensee has requested relief from exercising valve NF229, ice condenser glycol pump discharge line containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to leak-rate test' this valve during refueling outages.
3.6.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be ur;/ied during performance of leak rate testing j during refueling.
3.6.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
3.6.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve j operability and, therefore, relief should be granted from the exercising requirements of Section XI.
15
3.7 Safety Injection System 3.7.1 Category A/C Valves 3.7.1.1 Relief Request. The licensee has requested relie,f from exercising valves NI60, NI71, NI82, and NI94, the accumulator /SI/RHR cold leg injection checks, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to partial-stroke the valves at cold shutdown and to implement a sampling disassembly program to verify full-stroke capability. ,
3.7.1.1.1 Licensee's Basis for Requesting Relief--These valves cannot be full- or part-stroke exercised during power operation since safety injection pump discharge pressure (approximately 1520 psig) cannot -
cvercome reactor coolant system pressure.
Each check valve will be exercised (partial-stroke) to the position required to fulfill its function at cold shutdown. During each refueling, one of the four check valves will be disassembled and the disk will be mechanically exercised. The next refueling,-a different valve in this
- group will be disassembled, and so on, such that all four valves will be tested within a four refueling time period. Should any one valve fail to
- stroke acceptably, the remaining three valves will also be disassembled.
l 3.7.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve full-stroke capability is disassembly and mechanical exercising. The i safety injection system does not develop sufficient pressure to overcome reactor system pressure during power operation and insufficient expansion volume exists to allow full flow at cold shutdowns which could result in a low-temperature overpressurization.
f l The NRC staff has concluded that a valve sampling l disassembly / inspection utilizing a manual full-stroke of one disk is an acceptable method to verify a check valve's full-stroke capability. The 16
sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound;(no loose or corroded parts).
_ A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke. '
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.7.1.1.3 Conclusion--The reviewer concludes that the proposed
' alternate testing of partial-stroke exercising at cold shutdowns and sample disassembly and mechanical exercising at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.1.2 Relief Request. The licensee has requested relief from exercising valve NI48, nitrogen supply to accumulators containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and 3520, and proposed to leak-rate test this valve during refueling outages.
l 17
3.7.1.2.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be verified during performance of leak rate testing during refueling.
3.7.1.2.2 Evaluation--The reviewer agrees with the Itcensee that, due to plant design, the only method available to verify valve ,
closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
3.7.1.2.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the e'xercising requirements of Section XI.
3.7.1.3 Relief Request. The licensee has requested relief from exercising valves NI59, NI70, NI81, and NI93, accumulator discharge checks, ,
in accordance with the requirements of Section XI, Paragraphs IW-3410 and
-3520, and proposed to partial-stroke the valves during approach to or startup from cold shutdown and to implement a sampling disassembly program
, to verify full-stroke capability.
l 3.7.1.3.1 Licensee's Basis for Requesting Relief--These valves cannot be full- or part-stroke exercised during power operation since cold leg accumulator pressure (approximately 450 psig) cannot overcome reactor coolant system pressure. During cold shutdown, exarcising these valves could result in a low-temperature overpressurization of the reactor coolant l system.
During approach to or startup from cold shutdown, these valves will be i
partial-stroked by opening the associated cold leg accumulator isolation valve and noting the decrease.in level. During each refueling, one of the four check valves will be disassembled and the disk will be mechanically 18 l
exercised. The next refueling a different valve in this group will be disassembled, and so on, such that all four valves will be tested within a four refueling time period. Should any one valve fail to stroke acceptably, the remaining three valves will also be disassembled.
3.7.1.3.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve full-stroke capability is disassembly and mechanical exercising. The accumulators do not have sufficient pressure to overcome reactor system pressure during power operation and, at cold shutdown, accumulator discharge could result in a low-temperature overpressurization of the reactor coolant system.
The NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an ,
acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled,
! inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
19
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.7.1.3.3 Conclusion--The reviewer concludes that the proposed alternate testing of partial-stroke exercising during approach to or
^
startupfromcoldshutdownsandsampledisassemblyandmechanicEl exercising at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.1.4 Relief Request. The licensee has requested relief from exercising valves NI124, NI128, NI156, NI157, NI159, and NI160, safety injection to hot leg recirculation checks, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to -
full-strcke exercise these valves during refueling outages.
3.7.1.4.1 Licensee's Basis for Requesting Relief--Valves cannot be full- or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system. Safety injection pump discharge pressure (~1520 psig) cannot overcome reactor coolant system pressure. During cold shutdown, these valves cannot be full- or partial-stroke exercised since this could result in a low-temperature g overpressurization of the reactor coolant system.
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.
3.7.1.4.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only available full flow path is into the l
! reactor coolant system. At power, safety' injection pump pressure is too low to overcome reactor coolant system pressure and exercising these valves with flow at cold shutdown could result in a low-temperature overpressurization of the reactor coolant system.
l 20
3.7.1.4.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising these valves at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.1.5 Relief Reauest. The licensee has requested relief'from exercising valves NI165, NI167, NI169, and NI171, safety injection to cold leg checks, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to full-stroke exercise these valves during refueling outages.
f 3.7.1.5.1 Licensee's Basis for Requesting Relief--Valves cannot be full- or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system. Safety injection >
pump discharge pressure (~1520 psig) cannot overcome reactor coolant system pressure. During cold shutdown, these valves cannot be full- or partial-stroke exercised since this could result in a low-temperature overpressurization of the reactor coolant system.
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.
. 3.7.1'.5.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only available full flow path is into the reactor coolant system. At power, safety injection pump pressure is too low to overcome reactor coolant system pressure and, at cold shutdown, exercising these valves with flow could result in a low-temperature overpressurization of the reactor coolant system.
l 3.7.1.5.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising these valves at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
l 21 1
- 3.7.1.6 Relief Request. The licensee has requested relief from exercising valves NI248, NI249, NI250. NI251, NI252, and NI253, upper head injection accumulator to reactor vessel checks, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and has proposed a sample disassembly program at refueling outages.
3.7.1.6.1 Licensee's Basis for Requesting Relief--Valves cannot be full- or partial-stroke exercised during power operation since upper head injection accumulator pressure (approximately 1250 psig) cannot overcome reactor coolant system pressure. Valves cannot be full- or partial-stroke exercised during cold shutdown since this could result in a low-temperature over pressurization of the reactor coolant system.
During each refueling, one of the 8" check valves (1NI250,1NI251, -
INI252, or INI253) and one of the 12" check valves (1NI248 or INI249) will be disassembled and the disk will be mechanically exercised. The next refueling, a different valve in each group will be disassembled, and so on, such that all four 8" valves will be tested within a four refueling time period and both 12 valves will be tested within a two refueling time period. Should any one valve fail to stroke acceptably, the remaining valves in that group will also be disassembled.
3.7.1.6.2 Evaluation--The reviewer agrees,with the licensee
,that, due to plant design, the only method available to verify full-stroke capability is disassembly and mechanical exercising. The accumulator does not have sufficient pressure to overcome reactor system pressure during power operation and, at cold shutdown, accumulator discharge could result in a low-temperature overpressurization of the reactor coolant system.
The NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an
( acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of 22
construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corrodedparts).
A different valve of each group is required to be disasse bled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking ,
of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical ~
maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.k.1.6.3 Conclusion--The reviewer concludes that the proposed
- alternate testing of sample disassembly and mechanical exercising at
. refueling outages is the only available testing method and should l demonstrate proper valve operability and, therefore, relief should be granted the exercising requirements of Section XI.
3.7.2 Category C Valves
- 3.7.2.1 Relief Request. The l'icensee has requested relief from i
exercising valvo NI12, centrifugal charging pump discharge check, in accordance with the requirements of Section XI, Paragraph IWV-3520, and has proposed to full-stroke exercise it at refueling outages.
l 23
3.7.2.1.1 Licensee's Basis for Rcquesting Relief--Using a centrifugal charging pump to provide flow to IN112 would result in injecting borated water into the reactor coolant system through the cold leg injection lines. This would result in thermal shock to the reactor coolant piping. During cold shutdowns, exercising this valve could result '
! in a low temperature o'verpressurization of the reactor coolant s'ystem.
1 Check valve will be exercised (full-stroke) to the position required to fulfill its function at refueling.
3.7.2.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only full flow path is into the reactor coolant system. At power, this flow could result in a thermal shock to the piping. At cold shutdown, it could result in a low-temperature overpressurization of the reactor coolant system.
3.7.2.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising this valve at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.2.2 Relief Request. The licensee has requested relief from exercising valves NI15, NI17, NI19, NI21, NI351, NI352, NI353, and NI354,
, centrifugal charging pump loop injection checks, in accordance with the requirements of Section XI, Paragraph IW-3520, and proposed to full-stroke exercise them at refueling outages.
3.7.2.2.1 Licensee's Basis for Reouesting Relief--Operating these valves would require using a centrifugal charging pump to provide flow which would result in injecting bora'ted water into the reactor coolant system thereby causing thermal shock to the reactor coolant piping. During cold shutdowns, exercising this valve could result in a low-temperature overpressurization of the reactor coolant system.
24 i
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.
3.7.2.2.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only full flow path is into the, reactor coolant system. At power, this flow could result in a thermal shock to the piping. At cold shutdown, it could result in a low-temperature overpressurization of the reactor coolant system.
3.7.2.2.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising these valves at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.2.3 Relief Request. The licensee has requested relief from exercising valve nil 01, safety injection pump suction from refueling water storage tank check, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to partial-stroke it quarterly and to full-st oke exercise it during refueling.
3.7.2.3.1 Licensee's Basis for Requesting Relief--Valves cannot be full-stroke exercised during power operation since.the only full flow path discharges into the reactor coolant system. Safety injection pump i , discharge pressure (-1520 psig) cannot overcome reactor coolant system pressure. During cold shutdown, this valve cannot be full-stroke exercised since this could result in a low-temperature overpressurization of the reactor coolant system.
Check valve will be exercised (partial-stroke) to the position required to fulfill its function every 3 ' months and exercised (full-stroke) to the position required to fulfill its function during refueling.
3.7.2.3.2 Evaluation--The reviewer agrees with the licensee j that, due to plant design, the only full flow path is into the reactor 25 t
i
coolant system. Safety injection pump discharge pressure is not high enough to overcome reactor coolant system pressure during power operation.
During cold shutdown, operation of the pumps could result in a low-temperature overpressurization of the reactor coolant system.
3.7.2.3.3 Conclusion--ThereviewerconcludesthattEeproposed alternate testing of partial-stroke exercising the valve quarterly and full-stroke exercising it during refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of.Section XI.
3.7.2.4 Relief Request. The licensee has requested relief from exercising valves NI116 and NI148, safety injection pump discharge checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and. , .
proposed to full-stroke exercise them at refueling outages.
3.7.2.4.1 Licensee's Basis for Requesting Relief--Valves cannot be full- or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system. Safety injection pump discharge pressure (~1520 psig) cannot overcome reactor coolant system pressure. During cold shutdown, these valves cannot be full- or partial-stroke exercised since this could retElt in a low-temperature overpressurization of the reactor coolant system.
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.
3.7.2.4.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only flow path is into the reactor coolant
]
system. Safety injection pump disc'.large 'pressure is not high enough to overcome reactor coolant system pressure during power operation. During j cold shutdown, operation of the pumps could result in a low-temperature overpressurization of the reactor coolant system.
}
26 3
- - - . - - - - ,,~~----n,-----..-.. - - - - - , - - - . . , - - - - , - - - - , - - - - . ... c.--n-- -.n--- ,----n., -- . - - - , -
3.7.2.4.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising the valves during refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.7.2.5 Relief Request--The licensee has request'ed relief from exercising valve NI342, safety injection pump suction from residual heat removal pump check, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to partial-stroke it quarterly and to full-stroke exercise it during refueling. -
3.7.2.5.1 Licensee's Basis for Requesting Relief--Valve cannot be full-streke exercised during power operation since the only full flow j path discharges into the reactor coolant system. Safety injection pump '
discharge pressure (approximately 1520 psig) cannot overcome reactor ,
coolant system pressure.
Valve cannot be full-stroke exercised during cold shutdown since this could result in a cold overpressurization of the reactor coolant system.
l Check valve will be exercised (partial-stroke) to the position l required to fulfill its function every 3 months and exercised (full-stroke) to the position required to fulfill its function at refueling.
i l 3.7.2.5.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only full flow patn is into the reactor coolant system. Safety injection pump discharge pressure is not high enough to overcome reactor coolant system pressure during power operation.
l During cold shutdown, operation of the pumps could result in a low-temperature overpressurization of the reactor coolant system.
l 3.7.2.5.3 Conclusion--The reviewer concludes that the proposed alternate testing of partial-stroke exercising the valve quarterly and i
27
i full-stroke exercising it during refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.8 Containment Spray System 3.8.1 Category C Valves 3.8.1.1 Relief Request. The licensee has requested relief from i
exercising valves NS13, NS16, NS30, NS33, NS41, and NS46, containment spray header checks, in accordance with the requirements of Section XI, Paragraph IW-3520, and has proposed a sample disassembly program at refueling outages.
3.8.1.1.1 Licensee's Basis for Requesting Relief--To full- or partial-stroke these valves, flow from the containment spray or residual heat removal pumps would have to be initiated. This would result in spraying water through the spray nozzles into containment.
During each refueling, one of the six check valves will be
! disassembled and the disk will be mechanically exercised. The next .i refueling, a different valve in this group will be disassembled, and so on,
- such that all six valves will be tested within a six refueling time period. Should any one valve fail to stroke acceptably, the remaining five
~
valves will also be disassembled.
! 3.8.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify full-stroke capability is disassembly and mechanical exercising. To full- or partial-stroke these valves with flow would result in spraying water through the spray nozzles into containment.
- The NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an l
28
acceptable method to verify a check valve's full-stroke capability. The I sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of l construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally soundTno loose or corroded parts). !
A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage. . .
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief
- request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
' Photographs should be provided of the valve "as found" internals, noting
! particularly any anomalies encountered.
~
i
~
3.8.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of sample disassembly and mechanical exercising at refueling outages is the only available testing method and should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.8.1.2 Relief Request (Unit 1 Only). The itcensee has requested relief from exercising valves INS 4 and INS 21, containment spray pump suction checks, and INS 98 and INS 99, containment spray pump discharge checks, in accordance with the requirements of Section XI, 29
Paragraph IW-3520, and has proposed to partial-stroke each valve with flow quarterly and to disassemble and mechanically full-stroke each valve at refueling.
'3.8.1.2.1 Licensee's Basis for Requesting Relief--These. valves
~'
l cannot be full-stroke exercised since the only full flow path is to the spray headers which would result in spraying containment.
4 4 Check valves will be exercised (partial) to the position required to fulfill their function every three months and will be disassembled and mechanically exercised at each refueling.
3.8.1.2.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method of testing valve operability .
with flow is partial-stroke exercising through the recirculation test line. To full-stroke exercise these valves with flow would require spraying water through the spray nozzles into containment. Therefore, the only practical method of full-stroke exercising these valves is disassembly and mechanical exercising.
The NRC staff has concluded that a valve sampling d'isassembly/ inspection utilizing a manual full-stroke of one disk is an acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the
~
same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled,
. inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that :he disassembled valve's i
30
full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking of all'the check valves in the group, the licensee may submit'a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.8.1.2.3 Conclusion--The reviewer concludes that the proposed-alternate testing of partial-stroke exercising with flow quarterly and disassemb'ly and mechanical exercising at refueling should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI. ,
3.8.1.3 Relief Request (Unit 2 Only). The licensee has requested relief from exercising valves 2NS4 and 2NS21, containment spray pump suction checks, and 2NS98 and 2NS99, containment spray pump discharge checks, in accordance with the requirements of Section XI, Paragraph IW-3520, and has proposed to partial-stroke each valve with flow
. quarterly and to implement a sample disassembly program at refueling outages.
3.8.1.3.1 Licensee's Basis for Requesting Relief--These valves cannot be full-stroke exercised since the only full flow path is to the spray headers which would result in spraying containment.
Check valves will be exercised (partial-stroke) to the position required to fulfill their function every three months. During each refueling, one of the 8" check valves (2NS98, 2NS99) and one of the 12" 31
check valves (2NS4, 2NS21) will be disassembled and the disk wtll be mechanically exercised. The next refueling, the other valve in each group will be disassembled, and so on, such that both valves within each group will b6 tested within a two refueling time period. Should any one valve fail to stroke acceptably, the other valve in that group will also be disassembled. ".
3.8.1.3.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify full-stroke capability is disassembly and mechanical exercising. To full-stroke these valves with flow would result in spraying water through the spray nozzles into containment.
The NRC staff has concluded that a valve sampling .
disassembly / inspection utilizing a manual full-stroke of one disk is an acceptable method to verify a check valve's full-stroke capability. The sampling t3chnique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled,
' inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical 32
_ _ - t
maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.
3.8.1.3.3 Conclusion--Thereviewerconcludesthatthhproposed i alternate testing of sample disassembly and mechanical exercising at refueling outages, along with quarterly partial-stroke exercising, is the only available testing method and should demonstrate proper valve operability and, therefore, relief should be granted from the exercising
, requirements of Section XI.
3.9 Chemical and Volume Control System 3.9.1 Category A/C Valves ,
3.9.1.1 Relief Request. The licensee has requested relief from exercising valve NV874, standby makeup pump discharge line containment j isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and -3520, and proposed to leak-rate test this valve during refueling outages.
3.9.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal. Valve closure will be verified during performance of leak rate testing during refueling.
3.9.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is ' leak testing. This valve is located inside containment and is not equipped with position indication.
3.9.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak 33
rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.9.2 Category C Valves .
q 3.9.2.1 Relief Request. The Itcensee has requested relief from exercising valve NV254, refueling water storage tank outlet check, in
. accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to partial-stroke this valve at cold shutdowns and full-stroke exercise it at refueling.
3.9.2.1.1 Licensee's Basis for Requesting Relief--Valve cannot be full or partial-stroke exercised during power operation as this would -
increase the reactor coolant system boron inventory and possibly cause plant shutdown. This valve cannot be full-stroke exercised during cold shutdown since this could result in a cold overpressurization of the reactor coolant system. Check valve will be exercised (partial-stroke) to .
the position required to fulfill its function at cold shutdown and exercised (full-stroke) to the position required to fulfill its function at refueling.
3.9.2.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, this valve can be full-stroke exercised only at
' refueling outages. Full- or partial-stroke exercising at power could result in a change in reactor coolant system boron concentration and the resulting transient could result in a plant shutdown. In addition, the only full flow path is into the reactor coolant system, therefore, full-stroke exercising at cold shutdown could result in a low-temperature
! overpressurization of the reactor coolant' system.
3.9.2.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of partial-stroke exercising at cold shutdowns and 34
full-stroke exercising at refueling should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.9.2.2 Relief Request. The licensee has requested relief from '
exercising valves NV270 and NV290, centrifugal charging pump ' outlet checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to partial-stroke exercise the valves quarterly and full-stroke exercise them at refueling.
3.9.2.2.1 Licensee's Basis for Requesting Relief--Valves cannot
- be full-stroke exercised during power operation. The only full flow path is through the boron injection tank into the reactor coolant system. This would cause an increase in reactor coolant system boron inventory and .. .
possibly cause plant shutdowa. Valves cannot be full-stroke exercised during cold shutdown since this could result in a cold overpressurization of the reactor coolant system.
Check valves will be exercised (partial-stroke) to the position required to fulfill their function every three months and exercised (full-stroke) to the position required to fulfill their function at refueling.
3.9.2.2.2 Evaluation--The reviewer agrees with the licensee that the only full flow path is through the boron injection tank and into the reactor coolant system. During power operation, this would result in an increased boron concentration in the reactor coolant system and a possible plant shutdown. During cold shutdown, full flow exercising could result in i
a low-temperature overpressurization of the reactor coolant system.
i t
3.9.2.2.3 Conclusion--The reviewer concludes that the proposed alternate testing of partial-stroke exercising each quarter and full-stroke exercising at refueling should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
35
. - ~ _ . _ - - , , - - - . . - _ _ - - - _ - _ - . - - _ , . - . _ _ _ - _ - - , , . . _ . . -
'3.9.2.3 Relief Request. The licensee has requested relief from exercising valve NV813, centrifugal charging pump suction from residual heat removal pump check, in accordance with the requirements of Section XI, Paragraph IW-3520, and proposed to partial-stroke it at cold shutdowns and full-stroke exercise it at refueling.
3.9.2.3.1 Licensee's Basis for Requesting Relief--Valve cannot be full-stroke exercised during power operation since the only full flow path discharges into the reactor coolant system. This would cause an increase in reactor coolant system boron inventory and possibly cause plant shutdown. Valve cannot be partial-stroke exercised during power operation. Use of the partial-stroke flowpath (through the miniflow line to the seal water heat exchanger) would:
- 1. Cause an increase in the boron concentration in the volume i
control tank which is the normal source of makeup water for the positive displacement charging pump. This would cause an increase in the reactor coolant system boron inventory and possibly cause plant shutdown, i 2. Cause the return path for the reactor coolant pump seal water to be deadheaded due to the miniflow path pressure. This would result in loss of cooling to the seals and cause possible pump j ,
damage.
Valve cannot be full-stroke exercised during cold shutdown since this could result in a low-temperature overpressurization of the reactor coolant system.
Check valve will be exercised (partial-stroke) to the position required to fulfill its function during cold shutdown and exercised (full-stroke) to the position required to fulfill its function during i refueling, i
36 l
3.9.2.3.2 Evaluation--The reviewer agrees with the licensee that the only full flow path is into the reactor coolant system. During power operation this would result in an increased boron concentration and possible plant shutdown, while at cold shutdown it could result in a low-temperature overpressurization. Partial-stroke testing during power operation would also result in boron concentration variations and, in addition, could cause equipment damage.
3.9.2.3.3 Evaluation--The reviewer concludes that the proposed alternate testing of partial-stroke exercising at cold shutdown and full-stroke exercising at refueling should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.10 Containment Valve Injection Water System 3.10.1 Category C Valves 3.10.1.1 Relief Request. The licensee has requested relief from exercising valves NW6 and NW63, containment valve injection water surge chamber inlet checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to exercise these valves at refueling.
3.10.1.1.1 Licensee's Basis for Requesting Relief--Operating these valves would result in placing dirty water in the NW System.
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling (NW surge chamber can be drained and isolated at this time).
3.10.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, operation of these valves will result in the introduction of dirty water into the containment valve injection water 37
system which could cause corrosion of the system. These valves will be full-stroke exercised at refueling outages when the surge chambers can be drained and isolated from the system.
3.10.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising these valves at ref6eling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.10.1.2 Relief Request. The licensee has requested relief from
! exercising the below listed containment valve injection water system check valves in accordance with the requirements of Section XI,
- Paragraph IWV-3520, and proposed to exercise them at refueling.
INW17 INW21 INW24 INW27 INW37 1NW40 INW43 INW47 1NW50 INW53 INW70 INW74 1NW77 INW80 INW83 INW86 INW89 INW92 INW95 1NW98 1NW101 INW107 INW109 INW111 INW114 1NW120 INW121 through INW136 INW138 INW139 1NW140 1NW141 INW147 1NW148 1NW159 INW160 INW163 1RW164 INW168 INW169 INW171 INW172 INW178 1NW179 INW183 INW184 1NW188 INW189 1NW193 INW194 1NW196 INW197 1NW201 INW202 INW205 1NW206 1NW209 1NW210 INW213 INW214 INW218 INW219 INW223 INW224 INW230 INW231 INW235 1NW236 INW240 INW241 INW245 INW246 3.10.1.2.1 Licensee's Basis for Requesting Relief--Normal plant conditions will not allow these check valves to operate since the valves fed by the NW system are in systems which are normally pressurized with flow passing through them. To operate the check valves, normal system pressures would have to be bled off in order to allow NW pressure to open the check valves. This is not possible d'uring normal plant operation.
Check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.
3.10.1.2.2 Evaluation--The reviewer agrees with the licensee that, in general, valves which are fed by this system are pressurized with 4
38
. a flow during normal operation, thus preventing flow through the check valves. In general, this is also true during cold shutdown. In order to exercise these valves to the open position, it is necessary to depressurize the interfacing systems and allow flow through the check valves. In most cases, this can only be done during refueling outages.
- r.
3.11.1.2.3 Conclusion--The reviewer concludes that the proposed alternate testing of full-stroke exercising these valves at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.11 Interior Fire Protection System 3.11.1 Category A/C Valves .
3.11.1.1 Relief Request. The licensee has requested relief from exercising valve RF392 and RF448, interior fire protection system containment isolation checks, in accordance with the requirements of ,
1 Section XI, Paragraphs IWV-3410 and -3520, and proposed to leak rate test these valves during refueling outages.
3.11.1.1.1 Licensee's Basis for Requesting Relief--System design doesnotprovideanyindication/orverifyingvalveclosureuponflow reversal. Valve closure will be verified during performance of leak rate
' testing during refueling.
l 3.11.1.1.2 Evaluation--The reviewer agrees with the licensee l
that, due to plant design, the only method available to verify valve closure (their safety-related position) is leak testing. These valves are ,
i located inside containment and are not eqbipped with position indication.
3.11.1.1.3 Conclusion--The reviewar concludes that the proposed alternate testing of verifying valve closure during the performance of leak a
39 i
-v.-.,, ,,n- _ - - - -
, , , , , , , - . - , ,.-----..--------.-_,--,n.,,.. . - , , - - - - .- --- - -- -
rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.12 Nuclear Service Water System e,
3.12.1 Category A/C Valves 3.12.1.1 Relief Request. The licensee has rq ueste,d relief from exercising valves RN405 and RN438, nuclear serviceIwater containment isolation checks, in accordance with the requjrements of Section XI, Paragraphs IWV-3410 and -3520, and proposed s'ileak rate test these valves during refueling outages.
3.12.1.1.1 Licensee's Basis for Requestino Relief--System design does not provide any indication for v'erifying valve closure upon flow reversal. Vah e closure will be verified during performance of leak rate testing during refueling.
3.12.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (their safety-related position) is leak testing. These valves are located inside containment and are not equipped with position indication.
l 3.12.1.1.3 Conclusion--The reviewer concludes that the propc(M alternate testing of verifying valve closure during the performance ofY eak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising l requirements of Section XI.
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3.13 Main Steam to Auxiliary Equipment i 3.13.1 Category C Valves 3.13.1.1 Relief Request. The licensee has requested relief from exercising valves SA3 and SA6, main steam supply to auxiliary feedwater I
40
pump turbine checks, in accordance with the requirements of Section XI, Paragraph IW-3520, and proposed to verify valve opening at a quarterly interval and to implement a sample disassembly program at refueling to verify valve closure.
3.13.1.1.1 Licensee's Basis for Requestina Relief--5hstem design does not provide any indication for verifying valve position. Verification of ability to pass flow will be demonstrated quarterly by verifying one main steam header at a time is capable of operating the turbine driven auxiliary feedwater pump. Verification of ability to prevent reverse flow will be performed during refueling. During each refueling one of the two check valves vill be disassembled and the disk will be mechanically exercised. The next refueling the other valve will be disassembled, such that both valves will be tested within a two refueling time period. Should ,
any one valve fail to stroke acceptably, the remaining valve will also be l disassembled.
3.13.1.1.2 Evaluation--The reviewer agrees with the licensee that the proposed valve opening test will show that each valve will individually pass design basis flow. Although this may not assure full-stroke opening, it is in accordance with the NRC staff position (see ParagraphA.1). Additionally, the sample disassembly procedure proposed to verify valve closure will also ensure full-stroke open capability.
The NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of one disk is an acceptable methof to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
41
A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that 4
group must also be disassembled, inspected, and manually full-stroked at '
the same outage.
Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting a change of the intervals between these tests. This relief request should contain all pertinent historical maintenan:e data on each valve, including the inspection and maintenance data obtained at each disassembly / inspection and manual full-stroke.
Photographs should be provided of the valve "as found" internals, noting '
particularly any anomalies encountered.
3.13.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of quarterly verifying design basis flow and a sample disassembly program to verify full-stroke capability (both open and closed) should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
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3.14 Breathing Air System i -
3.14.1 Category A/C Valves -
3.14.1.1 Relief Request. The licensee has requested relief from exercising valve VB85, breathing air containment isolation check, in accordance with the requireu nts of Section XI, Paragraph IWV-3410 and
-3520, and proposed to leak rate test this valve during refueling outages.
3.14.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal. Valve closure will be verified during performance of leak rate testing during refueling.
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3.14.1.1.2 Evaluation--The reviewer agrees with the ifcensee that, due to plaat design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve fs located inside containment and is not equipped with position indication.
q 3.14.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve '
operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.15 Diesel Generator Engine Starting Air System 3.15.1 Category B Valves 3.15.1.1 Relief Request. The licensee has requested relief from exercising VG25, VG26, VG27, VG28, VG69, VG70, VG71, and VG72, starting air to diesel generator solenoid operated valves, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and 3413(b), and proposed to verify operation during the monthly Technical Specification diesel test.
3.15.1.1.1 Licensee's Basis for Requesting Relief--Valve design does not provide any indication of position. Failure of this valve to
' perform its required function will result in increase in start time of diesel generator during performance of monthly Tech Spec Surveillance Requirement 4.8.1.1.2.a.4.
Valves will be verified to operate during monthly Tech Spec Diesel Test (PT/1/A/4350/02A,B - Diesel Generator A, B Operability Test) by verifying diesel starts within the required time. In addition, during cold shetdown a test will be performed which verifies the diesel is able to start within the required time with one starting air bank disabled at a time. The test will be performed twice, first with one bank disabled, then with the opposite bank disabled.
43
3.15.1.1.2 Evaluation--The reviewer agrees that these valves are constructed such that direct observation of valve operation is impossible.
The only method currently available to verify proper operation is to monitor the emergency diesels for acceptable starting times during the monthly Technical Specification tests. Added assurance of valv,c operability is provided by cold shutdown tests wherein the tests are ;
conducted with one air bank disabled. This provides verification that each bank individually has the capability to start the diesal generator within the required time.
3.15.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve operation by monitoring acceptable
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diesel generator start times should demonstrate proper valve operability and, therefore, relief should be granted from the exercising and stroke '
timing requirements of Section XI.
3.15.2 Category C Valves 3.15.2.1 Relief Request. The licensee has requested relief from exercising valves VG15, VG16, VG29, VG30, VG31, VG32, VG59, VG60, VG73, VG74, VG75, and VG76, starting air to diesel generator checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to verify operation during the monthly Technical Specification
, diesel test.
3.15.2.1.1 Licensee's Basis for Requesting Relief--No method exists of directly verifying valve movement. Failure of one valve to operate will result in increase in start time of diesel generator during performance of monthly Tech Spec Surveillance Requirement 4.8.1.1.2.a.4.
Valve will be verified to operate during monthly Tech Spec Diesel Test (PT/1/A/4350/02A, B - Diesel Generator A, B Operability Test) by verifying diesel starts within the required time. In addition, during cold shutdown a test will be performed which verifies the diesel is able to start within 44
v the requirad time with one starting air tank disabled at a time. The test will be performed twice, first with one bank disabled, then with the opposite bank disabled.
3.15.2.1.2 Evaluation--The reviewer agrees that thes,e valves are
~
constructed such that direct observation of val've operation is fmpossible.
The only method currently available to verify proper operation is to monitor the emergency diesels for acceptable starting times during the monthly Technical Specification tests. Added assurance of valve i operability is provided by cold shutdown tests wherein the tests are conducted with one air ba".t disabled. This provides verification that each bank individually has the capability to start the diesel generator within the requirad time. ,
3.15.2.1.3 Conclusion--The reviewer concludes that the proposed 3 i
alternate testing of verifying valve operation by monitoring acceptable diesel generator start times should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.16 Instrument Air System 3.16.1 Category A/C Valves 3.16.1.1 Relief Request. The licensee has requested relief from exercising valve VI79, instrument air containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and
-3520, and proposed to leak rate test this valve during refueling outages.
3.16.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
1-1 i Valve closure will be verified during performance of leak rate testing during refueling ~.
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3.16.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
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, 3.16.1.1.3 Conclusion--The reviewer concludes that tke. proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should oe granted from the exercising requirements of Section XI.
3.16.2 Category C Valves 3.16.2.1 Relief Request. (Unit 2 only) The licensee has requested '
relief from exercising valves 2VI367 and 2VI368, PORV supply from instrument air checks, in accordance with the requirements of Section XI, Paragraph IW-3520, and proposed to verify valve closure during performance of PORV Technical Specification surveillance testing.
3.16.2.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be verified during performance of Tech Spec Surveillance Requirements 4.4.9.3 every 18 months.
3.16.2.1.2 Evaluation--The reviewer agrees that it is not f practical to exercise these valves during power operation because the valves and the necessary test connections are located inside containment and the valves are not equipped with position indication; however, the licensee has not provided any justification as to why they cannot be exercised during cold shutdowns.
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l 3.16.2.1.3 Conclusion--The reviewer concludes that the licensee j should test these valves during cold shutdowns.
3.16.2.2 Relief Request. (Unit 2 only) The licensee has requested
' relief from exercising valves 2VI369 and 2VI370, PORV supply from nitrogen accumulator checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to verify valve operation during performance of PORV Technical Specification surveillance testing.
3.16.2.2.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve operation when passing flow.
Proper valve operation will be verified during performance of Tech .- ,.
Spec Surveillance Requirements 4.4.9.3 every 18 months.
3.16.2.2.2 Evaluation--The reviewer agrees that the only way to exercise these valves is to operate the PORVs, and this is not to be done during power operation. (See Paragraph A.10.) However, the licensee has not provided any justification as to why these valves cannot be exercised during cold shutdowns.
3.16.2.2.3 Conclusion--The reviewer concludes that the licensee should test these valves during cold shutdowns. .
3.17 Containment Purge System 3.17.1 Category A Valves 3.17.1.1 Relief Request. The licensee has requested relief from exercising valves VPIB, VP2A, VP3B, VP4A, VP6B, VP7A, VP8B, VP9A, VP10A, VP11B, VP12A, VP13B, VP15A, VP16B, VP17A, VP188, VP19A, and VP208, containment purge supply and exhaust isolations, in accordance with the I requirements of Section XI, Paragraph IWV-3410, and proposed to test them whenever they are cycled for another purpose.
47
3.17.1.1.1 Licensee's Basis for Requesting Relief--Technical l l
Specification 3.6.1.9 requires these valves to be sealed closed during Modes 1-4.
Valves will be exercised (full-stroke) to the position required to
~
fulfill their function, stroke timed, and fail safe operation verified whenever the valves are cycled, and the elapsed time since the previous test has been three months or greater.
3.17.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to Technical Specification requirements, these valves must remain closed in operational Modes 1 through 4; however, the licensee has not provided any justification as to why they cannot be exercised on a regular cold shutdown program. .
3.17.1.1.3 Conclusion--The reviewer concludes that the licensee should test these valves during cold shutdowns.
3.18 Station Air System 3.18.1 Category A/C Valves 3.18.1.1 Relief Request. The licensee has requested relief from exercising valve VS56, station air containment isolation check, in accordance with the requirements of Section XI, Paragraphs IWV-3410 and
-3520, and proposed to leak rate test this valve during refueling outages.
3.18.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow i reversal.
i Valve closure will be verified during performance of leak rate testing l during refueling.
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i 3.18.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
3.18.1.1.3 Conclusion--Thereviewerconcludesthattiieproposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI, i 2.19 Containment Hydrogen Sample and Purge System 3.19.1 Category A/C Valves .
3.19.1.1 Relief Request. The licensee has requested relief from .
exercising valves VY11 and VY16, containment hydrogen purge inlet and outlet containment i,c'.ation checks, in accordance with the requirement:, of
~
Section XI, Paragraphs IWV-3410 and -3520, and proposed to leak rate test l
these valves during refueling outages.
3.19.1.1.1 Licensee's Basis for Requesting Relief--System design does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be verified during performance of leak rate testing during refueling.
3.19.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve -
l closure (their safety-related position) is leak testing. These valves are located inside containment and are not equipped with position indication.
l 3.19.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak l
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l . . .. . . .. ._ _ . _ - - -
rate testing at refueling outages should demonstrate proper valve l operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.20 Makeup Demineralized Water System ,
3.20.1 Category A/C Valves 3.20.1.1 Relief Request. The licensee has requested relief from exercising valve YM121, demineralized water containment isolation check, in a cordance with the requirements of Section XI, Paragraphs IWV-3410 and
-3520, and proposed to leak rate test this valve during refueling outages.
3.20.1.1.1 Licensee's Basis for Requesting Relief--System desigrf does not provide any indication for verifying valve closure upon flow reversal.
Valve closure will be verified during performance of leak rate testing j_ during refueling.
3.20.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is
, located inside containment and is not equipped with position indication.
l 3.20.1.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak l rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
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1 3.21 Personnel Airlock 3.21.1 Category A Valves 3.21.1.1 Relief Request. The licensee has requested rel,ief from exercising valves IASV5080 and IASV5160, personnel airlock air' supply line containment isolations, in accordance with the requirements of Section XI, Paragraph IWV-3410 and -3413(b), anc proposed to assess valve operability by verifying valve's ability to pass / prevent air flow.
3.21.1.1.1 Licensee's Basis for Requesting Relief--Valve design does not provide any indication of position.
Valve will not be stroke timed. Valve operability and fail safe -
actuation is verified quarterly by verifying valves ability to pass / prevent ,
air flow. In addition, there is no remote position indication to verify since indicating lights only indicate whether or not power is supplied to the solenoid.
3.21.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to valve design, the only way to verify proper valve operation is to verify the valve's ability to pass / prevent air f1'ow. In addition, FSAR table 6.2.4-1 indicates that valve closure (its safety related position) is also verified by a Type C leakage test.
3.21.1.1.3 Conclusion--The reviewer concludes that the proposed l
alternate testing of verifying valve operability and fail safe actuation quarterly and verifying valve closure by the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be oranted 'from the exercising and stroke timing requirements of Section XI.
3.21.2 Category A/C Valves 1
3.21.2.1 Relief Request. The licensee has requested relief from exercising valves IACV5340, IACV5350, IACV5360, IACV5370, IACV5380, l 51 l
4 and IACV5390, personnel airlock containment isolation checks, in accordance with the requirements of Section XI, Paragraph IWV-3520, and proposed to leak rate test these valves during refueling outages.
3.21.2.1.1 Licensea's Basis for Requesting Relief--System design
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does not provide any indication for verifying closure upon flow ' reversal.
Valve closure will be verified during performance of leak rate testing during refueling.
3.22.2.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (their safety-related position) is leak testing. These valves are located inside containment and are not equipped with position indication. - c 3.22.2.1.3 Conclusion--The reviewer concludes that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
3.22 Component Cooling Water System 3.22.1 Category A/C Valves l
l 3.22.1.1 Relief Request. The licensee has requested relief from exercising valve KC340, reactor vessel support and RCP coolers isolation j check, in accordance with the requirements of Section XI,
! Paragraphs IWV-3410 and -3520, and proposed to leak rate test this valve during refueling outages.
3.22.1.1.1 Licensee's Basis for Requesting Relief--System design.
does not provide any indication for verifying valve closure upon flow l
rn ersal. Valve closure will be verified during performance of leak rate testing during refueling.
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3.22.1.1.2 Evaluation--The reviewer agrees with the licensee that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is located inside containment and is not equipped with position indication.
3.22.1.1.3 Conclusion--The reviewer concludes that t e proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability and, therefore, relief should be granted from the exercising requirements of Section XI.
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s APPENDIX A 9
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APPENDIX A NRC STAFF POSITIONS AND GUIDELINES Full-Stroke Exercising of Check Valves ,
1.
The NRC's position was stated to the licensee that check valves whose safety function is to open are expected to be full-stroke exercised. Since tne disk position is not always observable, the NRC staff position is that verification of the maximum flow rate through the check valve identified in any of the plant's safety analyses would be an adequate demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown that the check valve's disk position at ' he t lower flow rate would permit maximum required flow through the valve. It is the NRC staff position that this reduced flow rate method of demonstrating full-stroke capability is the only test that requires measurement of the differential pressure across the valve.
- 2. Valves Identified for Cold Shutdown Exercising The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation,.and these valves are specifically identified by the licensee and are full-stroke exercised i during cold shutdowns; therefore, the licensee is meeting the requirements
'of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it is not necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it is not practical to exercise these valves during power oeration and that we agree with the licensee's basis.
It should be noted that the NF ifferentiates, for valve testing purposes, between the cold shutdowa ie and the refueling mode. That is, for valves identified for testing curing cold shutdowns, it is expected 4
that the tests will be performed both during cold shutdowns and each refueling outage. However, when relief is granted to perform tests on a 55 i
refueling outage frecuency, testing is expected only during each refueling outage. In addition, for extended outages, tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies.
- 3. Conditions for Valve Testing During Cold Shutdowhs Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:
- a. The licensee is to commence testing as soon as the cold shutdown condittun is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power. .
- b. Completion of all valve testing is not a prerequisite to return to power.
- c. Any testing not completed during one cold shutdow'n should be i performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.
- d. For planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test
- frequency in the IST program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
- 4. Category A Valve Leak Test Requirements for Containment Isolation Valves (CIVs)
All containment isolation valves that are Appendix J, Type C, leak tested should be included in the IST program as Category A or A/C valves.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, Appendix J. Relief from Paragraphs IWV-3421 through -3425 (1983 Edition
, 56
through Summer 1983 Addenda) for containment isolation valves presents no safety problem since the intent of these paragraphs is met by Appendix J requirements, however, the licensee must comp'y with.the Analysis of Leakage Rates and Corrective Action requirements of Paragraphs IWV-3426 and
-3427. Based on the considerations discussed above, the NRC staff'has concluded that the alternate testing proposed will give reasonable assurance of valve leak-tight integrity as required by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
- 5. Application of Appendix J Testing to the IST Program The Appendix J review of this plant is completely separate from the IST program review. However, the determinations made by that review are directly applicable to the IST program. The licensee has agreed that, ,
should the Appendix J program be amended, they will amend their IST program accordingly.
- 6. Safety-Related Valves The review was limited to valves whose function is safety-related.
Valves whose function is safety-related are defined as those valves that are needed to mitigate the consequences of an accident and/or to shut down
, the reactor to the cold shutdown condition and to maintain the reactor in a cold shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-Code class valves. It should be noted that the licensee may have included valves whose function is not safety-related in their IST program as a decision on their part to expand the scope of their program.
- 7. Active Valves t
The NRC staff position is that active valves are those for which changing position may be required to shut down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.
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Included are valves which respond automatically to an accident signal, such as safety injection, and valves which may be optionally utilized but are subject to plant operator actions, such as service water supply to the steam generators and valves utilized to establish long term recirculation following a LOCA. ,
- 8. Rapid-Acting Power Operated Valves The NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less. Relief from the trending requirements of Section XI (Paragraph IWV-3417(a), 1983 Edition through Summer 1983 Addenda) presents no safety concerns for these valves since variations in stroke time will be affected by slight variations in the response time of the personnel performing the tests. However, the staff -
does require that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.
- 9. Valves Which Perform a Pressure Boundary Isolation Function The following valves have been identified by the licensee as pressure boundary isolation valves and have been categorized accordingly:
Valve Function Category ND1B Hot leg suction isolation A N02A Mct leg suction isolation A ND36B Hot leg suction isolation A ND37A Hot leg suction isolation A NI59 Accumulator discharge check A/C NI60 Safety injection header check A/C NI70 Accumulator discharge check A/C NI71 Safety injection header check A/C NI81 Accumulator discharge check A/C 58
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Valve Function Category NI82 Safety injection header check A/C NI93 Accumulator discharge check A/C NI94 Safety injection header check A/C NI124 SI hot leg injection check A/C NI125 RHR hot leg injection check A/C NI126 Hot leg injection check A/C NI128 SI hot leg injection check A/C NI129 RHR hot leg injection check A/C NI134 Hot leg injection check A/C NI156 SI hot leg injection check A/C ' "
NI157 Hot leg injection check A/C NI159 SI hot leg injection check A/C NI160 Hot leg injection check A/C NI165 SI cold leg injection check A/C NI167 SI cold leg injection check A/C NI169 SI cold leg injection check A/C NI171 SI cold leg injection check A/C
'NI175 RHR cold leg injection check A/C NI176 RHR cold leg injection check A/C NI180 RHR cold leg injection check A/C NI181 RHR cold leg injection check A/C NI248 UHI injection check A/C NI249 UHI injection check A/C NI250 UHI injection check A/C NI251 UHI injection check A/C 59
Valve Function Category NI252 UHI injection check A/C NI253 UHI injection check A/C NI391 Accumulator /RHR injection check bypass A NI392 . Accumulator /RHR injection check bypass A NI393 Accumulator /RHR injection check bypass A NI394 Accumulator /RHR injection check bypass A NI395 SI injection check bypass A NI396 SI injection check bypass A' NI397 SI injection check bypass A
' ~
NI398 SI injection check bypass A The following valves appear to perform a pressure isolation function, however, they are not categorized A or A/C and are not individually leak tested. In accordance with guidance from the Committee to Review Generic Requirements (CRGR) on July 24, 1985, backfitting of non-Event V PIV leak testing at operating reactors may not be appropria*e. Therefore, pending review and approval by CRGR of a PIV testing plan for operating reactors, leak testing of tnese valves which are not listed in the licensee's
~
Technical Specifications,' is not to be involuntarily imposed on the
~
licensee. The licenses should be advised of his option to continue leak testing only his current technical specification list of PIVs until further notice.
Valve Function NI15 SI Loop A' cold leg injection check NI17 SI Loop B cold leg injection check NI19 SI Loop C cold leg injection check NI21 SI Loop D cold leg injection check 60
Valve Function NI351 SI Loop A cold leg injection check NI352 SI Loop 8 cold leg infection check NI353 SI Loop C cold leg injection check NI354 SI Loop D ccid leg injection chec'k I
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- 10. Pressurizer Power Operated Relief Valves The NRC has adopted the position that the pressurizer power operated relief valves should be included in the IST program as Category B valves
~
and tested to the requirements of Section XI. However, since the P0RVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that routine exercising during power operation is "not practical" and, therefore, not required by IWV-3412(a).
The PORVs' function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low-temperature overpressurization conditions and should oe exercised prior to initiation
' ~
of system conditions for which vessel protection is needed.
The following test schedule is recommended:
- a. Full-stroke exercising should be performed at each" cold shutdown or, as a minimum, once each refueling cycle.
- b. Stroke timing should be performed at each cold shutdown or, as a minimum, once each refueling cycle.
. c. Fail-safe actuation testing should be performed at each cold -
shutdown.
- d. The PORV block valves should be included in the IST program and tested quarterly to provide protection against a small break LOCA l
l should a PORV fail open. ,
The licensee has included the PORVs and the associated block valves in the IST programs and is testing them in accordance with the at,ove guidelines,
- a. The staff position described in Section A.3 regarding cold shutdown testing is not applicable to the PORVs; however, in the case of frequent cold shutoowns, testing of the PORVs is not required more often than each three months.
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APPENDIX B 5
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APPENDIX B The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke-exercised every three months during plant operation. Thesevai[resare specifically identified by the owner in accordance with Paragraphs IWV-3412 and -3522 and are full-stroke exercised during cold shutdowns and refueling outages. Exercising these valves during power operation is not practical due to the valve type, location, or system design. These valves either cannot or should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.
System Valve Identification Function i Auxiliary Feedwater CA37 Auxiliary feedwater to CA41 steam generators check CA45 valves CA49 CA53 CA57 CA61 CA65 b
2CA149 Main / Auxiliary Feedwater
~ b 2CA150 cross connects b
2CA151 b
2CA152 Feedwater CF33 Main feedwater isolation CF42 from steam generators CFS1 CF60 Refueling Water FW28 Residual heat removal FW56 system suction check valve Component Cooling Water KC320A Reactor coolant drain tank KC332B heat exchanger isolation KC333A l
KC3388 Miscellaneous equipment
! KC424B isolation KC425A l
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System Valve Identification Function Reactor Coolant NC32B Power operated relief NC34A valves NC36B NC250A Reactor head vent NC251B -:'
NC252B NC253A Residual Heat Removal ND1B RHR suction from hot leg N02A isolation -
ND368 ND37A ND32A RHR cross connect isolation N065B ND10 RHR pump discharge checks ND4A
, Safety Injection NI125 .
RHR hot leg injection NI129 checks NI126 NI134 NI175 RHR cold leg injection NI176 checks NI180 NI181 nil 008 SI pump suction from RWST
- isolation NI1478 SI pump miniflow to RWST isolation NI162A SI pump cold leg injection isolation INI438A" Nitrogen supply to PORV INI439B" isolation NI173A RHR recirculation to cold NI1788 leg isolation NI183B RHR recirculation to hot leg isolation NI9A Charging pump discharge to nil 0B cold leg isolation 65
l System Valve Identification Function Safety Injection NI184B RHR suction from (Continued) NI185A recirculation sump isolation Chemical and Volume NV15B Letdown heat,qxch' anger Control inlet isolation NV89A RC pump seal water return NV918 isolation NV188A Volume control tank outlet
. NV1898 isolation NV312A Normal charging line NV314B isolation NV2028 Charging pump miniflow NV203A line isolation .. ,.
NV2528 Charging pump suction from NV253A RWST isolation Nuclear Service Water RN49A Nonessential supply and RN50B return isolation RN51A RN528 RN437B Lower containment supply RN484A and return isolation RN487B
_ Main Steam SM1 Main steam isolation SM3 SMS SM7 Instrument Air VI77B Instrument air containment isolation i
- a. Unit 1 only.
- b. Unit 2 only.
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s APPENDIX c epp 9
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APPENDIX C The P& ids listed below were used during the course of this review.
System P&ID Revk'sion Steam Generator Blowdown (BB) CN-1580-1.0- 6 Auxiliary Feedwater (CA) CN-1592-1.0 7 CN-1592-1.1 3 Feedwater (CF) CN-1591-1.1 4 Diesel Generator Engine CN-1609-3.0 2
c Component Cooling (KC) . CN-1573-1.0 6
. CN-1573-1.5 4 CN-1573-1.1 3 CN-1573-1.3 5 Spent Fuel Cooling (KF) CN-1570-1.0 4 Boron Recycle (NB) CN-1556-2.0 3 Reactor Coolant (NC) CN-155'3-1.1 5
. CN-1553-1.3 4 Residual Heat Removal (ND) CN-H61-1.0 5
! CN-1561-1.1 1 Ice Condenser Refrigeration (NF) CN-1558-2.0 3 Safety Injection (NI) CN-1562-1.0 3 CN-1562-1.1 3 CN-1562-1.4 4 CN-1562-1.2 3 CN-1562-1.3 3 Nuclear Sampling (NM) CN-1572-1.0 3 CN-1572-1.1 2 CN-1572-1.4 3 Containment Spray (NS) CN-1563-1.0 5 Chemical and Volume Control (NV) CN-1554-1.0 6 CN-1554-1.1 4 CN-1554-1.6 3 1
68
System P&ID Revision Liquid Radwaste (WL) CN-1565-2.0 5 CN-1565-2.4 3 CN-1565-2.1 5 Control Air Chilled Water (YC) CN-1578-2.0 4-CN-1578-2.2 -:;2
- Makeup Demineralized Water (YM) CN-1601-3.1 4 1
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A APPENDIX D e
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APPENDIX D IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW
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Inconsistencies and omissions in the licensee's program not'ed during the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclus %ns, and guidelines presented in this report.
- 1. Relief should not be granted for the licensee's proposal to use less accurate portable' instrumentation to measure pump vibration amplitude. (See Paragraph 2.1.2.)
- 2. Relief should not be granted for the licensee's request for relief from the leak rata analysis and corrective action requirements of Section XI, Paragraphs IWV-3426 and IWV-3427.
(See Paragraph 3.1.3.1.)
i
- 3. The licensee should be required to verify the safety position (closed) of valves CA8, CA10, and CA12, auxiliary feedwater pump non-safety suction checks, during each' cold shutdown. (See Paragraph 3.2.1.1.)
- 4. The licensee should be required to excercise valves 2V1367, 2V1368, 2VI369 and 2VI370 at cold shutdowns. (See l Paragraphs 3.16.2.1 and 3.16.2.2.)
- 5. The licensee should be required to excercise the containment purge system valves on a regulai cold shutdown schedule. (See Paragraph 3.17.1.1)
- 6. The licensee's program for Unit 2 includes a valve 2MIMV5231 but.
a corresponding valve is not included in the Unit 1 program. It appears that this may be an incorrect listing for Unit 2, but L there is insufficiert information available to make a determination.
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- 7. The licensee's program for Unit 1 includes relief request Hi7 for valves INI438A and 1NI439B. The Unit 2 program has the corresponding valves but the valve list does not reference relief request H17 nor is H17 included in the relief request section.
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APPENDIX E We e
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APPENDIX E The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke' exercised every three months during plant operation. These valv'es are specifically identified by the owner in accordance with Paragraphs IWV-3412 and -3522 and are full-stroke exercised during cold shutdowns and refueling outages. The reviewer has evaluated all valves in this Appendix and agrees with the licensee that testing these valves during power operation is not practical due to the valve type, location, or system design. These valves either cannot or should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located. -' -
- 1. AUXILIARY FEEDWATER SYSTEM 1.1 Category B Valves Valves 2CA149, 2CA150, 2CA151, and 2CA152, main feedwater bypass flow isolations, cannot be exercised during power operation because the Westinghouse 0-5 steam generator design requires these valves to be used for main feedwater flow. Closure of these valves would isolate this. flow,
, possibly resulting in severe transients in the steam generators. These valves will be exercised to the fail safe position required to fulfill their function and stroke timed during cold shutdown.
1.2 Category C Valves Valves CA37, CA41, CA45, CA49, CA53,'CA57, CA61, and CA65, auxiliary feedwater to steam generator checks, cannot be exercised during power operation because exercising these valves would result in feeding cold water into the steam generators. This is not desirable during power operation since flow through these valves would unnecessarily thermal shock the steam generator feedwater nozzles. These check valves will be i exercised (full-stroke) to the position required to fulfill their function at cold shutdown.
75
- 4
- 2. FEEDWATER SYSTEM 2.1 Category B Valves Valves CF33, CF42, CF51, and CF60, main feedwater inlet to steam generators isolations, cannot be exercised during power operatibn because closing these valves during power operation is considered impractical from an operating viewpoint. Closure would isolate feedwater to the steam generator which may result in a' severe transient in the steam generator, possibly causing a unit trip. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
- 3. REFUELING WATER SYSTEM .
3.1 Category C Valves Valves FW28 and FW56, residual heat removal system suction checks, cannot be exercised during power operation because they can only be full-stroke tested with the residual heat removal pump operating at full flow in recirculation to the refueling water storage tank. To do this requires closing one of the cold leg injection cross-tie vflves and opening the manual valve (IND33) leading back to the RWST. Based on Design 2ngineering and Westinghouse evaluation, this renders both trains of ND inoperable. This is not allowed by Technical Specification 3/4.5.2 in Modes 1-3 since both trains are required to be operable. Technical Specification 3/4.5.3 requires one train of ND to be operable in Mode 4.
Full-stroke testing will be performed durirg cold shutdown. These valves will be partial-stroke exercised quarterly.
- 4. COMPONENT COOLING WATER 4.1 Category B Valves Valves KC320A, KC3328, and KC333A, reactor coolant drain tank heat exchanger isolations, cannot be exercised during power operation because 76
. a failure of one of these valves in the closed position during testing would inhibit the flow path through the reactor coolant drain tank heat exchanger. This would result in boiling of the water in the reactor coolant drain tank resulting in excess heat in containment. This increased heat load could cause unit shutdown due to exceeding Tech Spec containment temperature limits. These valves will be exercised (full-stroke) t'o the position required to fulfill their function and stroke timed during cold shutdown.
Valves KC3388, KC424B, and KC425A, miscellaneous equipment isolations, cannot be exercised during power operation because failure of one of these valves in the closed position during testing would inhibit flow to the reactor vessel support coolers, reactor coolant pump motor bearing coolers, reactor coolant pump thermal barriers and steam generator blowdown heat e ,
exchangers. This action could result in unit shutdown and possible damage to the vessel and reactor coolant pumps. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
- 5. REACTOR COOLANT SYSTEM 5.1 Category B Valves Valves NC328, NC34A, and NC368, PORVs, cannot be exercised during power operation. The current NRC position concerning pressurizer power operated reliefs (Branch Technical Position RSB 5-2) is that they should be full-stroke exercised during cold shutdown versus quarterly during power operations due to the high probability of their sticking open. These valves will be exercised (full-stroke) to the position required to fulfill their function, stroke timed, and failsafie actuation verifted during cold shutdown.
Valves NC250A, NC251B, NC252B, and NC253A, reactor head vents, cannot be exercised during power operation because opening one of these valves during power operation increases the potential for a LOCA since only one 77
valve would be isolating the reactor coolant system from the pressurizer relief tank. These valves will be exercised (full-stroke) to the position reoutred to fulfill their function and stroke timed during cold shutdown.
- 6. RESIDUAL HEAT REMOVAL SYSTEM -
6.1 Category A Valves Valves ND1B, ND2A, ND368, and NO37A, residual heat removal system suction from hot leg isolations, cannot be exercised during power operation because they have been provided with an interlock which prevents their i opening when reactor coolant system pressure is above approximately 425 psig. These valves will be exercised (full-stroke) to the position
! required to fulfill their function and stroke timed during cold shutdown. -
'~
6.2 Category B Valves Valves ND32A and ND658, residual heat removal. cross connect isolations, cannot be exercised during power operation. Based on Design Engineering and Westinghouse evaluation, closing one of these valves renders both trains of residual heat removal inoperable. This is not allowed by Technical Specification 3/4.5.2 in Modes 1-3 since both trains are required to be operable. Technical Specification 3/4.5.3 requires one train of ND to be operable in Mode 4. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke
< timed during cold shutdown.
l 6.3 Category C Valves Valves ND10 and ND44, residual heat removal pump discharge checks, cannot be exercised during power operation because they can only be full-stroke tested with the residual heat removal pump operating at full flow in recirculation to the refueling water storage tank. To do this requires closing one of the cold leg injection cross-tie valves and opening the manual valve (IND33) leading back to the FWST. Based on Design 78
s ,
s Engineering and Westinghouse evaluation, this renders b th trains of ND inoperable. This is not allowed by Technical Specification 3/4.5.2 in Modes 1-3 since both trains are required to be operable. Technical Specification 3/4.5.3 requires one train of ND to be operable in Mode 4.
These valves will be exercised (partial-stroke) by operating the residual
^
heat removal pump is minimum flow mode every 3 months. DuringfWPtesting of the residual heat removal pumps at cold shutdown, these valves will be exercised (full-stroke).
- 7. SAFETY INJECTION SYSTEM 7.1 Category A/C Valves Valves NI125, NI129, NI126, and NI134, residual heat removal hot leg .
) injection checks, cannot be full- or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system. Residual heat removal pump discharge pressure (approximately 210 psig) or safety injection pump discharge pressure (approximately 1520 psig) cannot overcome reactor coolant system pressure. These check valves will be exercised (full-stroke) to the position required to fulfill their function at cold shutdown.
Valves NI175, NI176, NI180, and NI181, residual heat removal cold leg injection checks, cannot be full- or partial-stroke exercised during power
' operation since the only flow path discharges into the reactor coolant' I system. Residual heat removal pump discharge pressure (~210 psig) cannot overcome reactor coolant system pressure. These check valves will be exercised (full-stroke) to the position required to fulfill their function at cold shutdown.
7.2 Category B Valves Valve nil 00B, safety injection pump suction from RWST isolation, cannot be exercised during power operation because failure of this valve in the closed position during testing would render both trains of safety 79 i
injection pumps inoperable. This valve will be exercised (full-stroke) to the position required to fulfill its function and stroke timed during cold shutdown.
Valve NI147B, safety injection pump miniflow to RWST isolation, cannot be exercised during power operation because failure of this valv'e in'the closed position during testing would result in loss of miniflow path for both trains of safety injection pumps. This would result in pump damage due to dead heading the safety injection pumps in the event of a safety injection signal with reactor coolant pressure above 1520 psig (safety injection pump discharge pressure). This valve will be exercised (full-stroke) to the position required to fulfill its function and stroke timed during cold shutdown.
Valve NI162A, safety injection pump cold leg injection isolation, cannot.be exercised during power operation because failure of this valve in the closed position during testing would result in loss of cold leg injection flow from the safety injection pumps rendering both trains of safety injection inoperable. This valve will be exercised (full-stroke) to the position required to fulfill its fun" ' 9 and stroke timed during cold shutdown.
Valves INI438A and INI439B, nitrogen supply to PORVs isolations,
~
cannot be exercised during power operation because they are interlocked ,
'c.losed when reactor coolant system temperature is above 300*F. These l valves will be exercised (full-stroke).to-the position required to fulfill their function and stroke timed during cold shutdown.
Valves NI175A and NI1788, residual heat removal recirculation to cold leg isolations, cannot be exercised during power operation. Based on Design Engineering and Westinghouse evaluation, closing one of these valves renders both trains of residual heat removal inoperable. This is not allowed by Technical Specification 3/4.5.2 in Modes 1-3 since both trains are required to be operable. Technical Specification 3/4.5.3 requires one l
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,, - - - _ . - . _ . - - . . - ._--,--..-_..----..~,s. . . , , , , _ . , . , - - . - _ - , _ _ . . - - - . - . - - . _ - _ - - - . - - - _ _ . _ _ _ . _ - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - - -- _ -
train of ND to be operable in Mode 4. These valves will be exerciseu (full-stroke) to the position required to fulfill their function and stroke timed during cold shuedown.
Valve NI1838, residual heat removal recirculation to hot leg isolation, cannot be exercised during power operation. Based on. Design Engineering and Westinghouse evaluation, in order for a train of ND to be !
operable to pe: form its ECCS function, it must be able to discharge into all four cold leg injection lines. This is in the event of single train failure. With this additional valve open, one ND pump could then be aligned to all four cold leg injection paths plus two hot legs. This has the potential of allowing pump runout during an ECCS actuation. This valve will be exercised (full-stroke) to the position required to fulfill its function and stroke timed during cold shutdown. ,
Valves NI9A and nil 08, charging pump discharge to cold leg isolations, cannot be exercised during power operation because that would result in flow of non preheated water through the injection lines and thermal shocking of the injection nozzles. These valves will be exercised' (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
Valves NI1848 and NI185A, residual heat removal suction from
~ ~
recirculation sump isolations, cannot be exercised during power operation.
'To prevent water from entering lower containment when cycling these valves, piping downstream must be drained. This results in making one train of ECCS inoperable for an extended period of time until completion of the test, refilling the piping, and realignment of isolation valves. Also, the i large amount of potentially contaminated water that must be drained is a
! major Health Physics and Radwaste Chemistry problem. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
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- 8. CHEMICAL AND VOLUME CONTROL SYSTEM 8.1 Category A Valves 1
Valve NV158, letdown heat exchanger inlet isolation, cannot be exercised during power operation because failure of this valve'in the' closed position during testing would result in loss of pressurizer level control and could result in plant shutdown. This valve will be exercised (full-stroke) to the position required to fulfill its function and stroke timed during cold shutdown. .
8.2 Category B Val'ves Valves NV89A and NV91B, reactor coolant pump seal water return ,
isolations, cannot be exercised during power operation because closure of one of these valves during power operation would inhibit seal water flow across the reactor coolant pump seals. This would result in damage to the pump seals. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
Valves NV188A and NV189B, volume control tank outlet isolations, l cannot be exercised during power operation because closure of one of these j valves during nornial unit operation would isolate the normal suction for
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l the charging pumps. Alternate suction paths would result in increasing the
' reactor coolant system baron inventory and could result in plant shutdown.
l In addition, seal water for the reactor coolant pumps would be inhibited.
This may result in damage to the reactor coolant pump seals. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
.au e Valves NV312A and NV3148, normal charging line isolations, cannot be exercised during power operation because closure of one of these valves
! during power operation would isolate charging flow to the reactor coolant i
system. This could result in loss of pressurizer level control and cause
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l plant shutdown. These valves will be exercised (full-stroke) to the l position required to fulfill their function and stroke timed during cold shutdown. !
Valves NV202B and NV203A, charging pump miniflow line isolations,
~
cannot~ be exercised during power operation because failure of on'e of these valves in the closed position during testing would isolate the centrifugal charging pumps miniflow line. This path must remain open in the event of a LOCA until the operator verifies a primary side break at which time the valves are closed. In the event of a secondary side break, the miniflow path must remain open in order to prevent possible dead heading and damaging the centrifugal charging pumps. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown. .
Valves NV252B and NV253A, charging pump suction from RWST isolations, cannot be exercised during power operation. If one of these valves were to fail in the open position during testing, the FWST would be aligned to the suction of the charging pumps. This would result in an increase in F S boron inventory and could result in a plant shutdown. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
- 9. NUCLEAR SERVICE WATER SYSTEM l
9.1 Category B Vah g
- Valves RN49A, RN508, RN51A, and RN52B, noiessential supply and return isolations, cannot be exercised during power operation because failure of one of these valves in the closed positiori during testing would result in
! loss of nuclear service water flow to the upper and lower containment ventilation units, incore instrument room ventilation units, reactor coolant pump motor coolers, and other misc. loacs. Tech Spec limits on containment temperature could not be maintained without cooling water to I
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the containment ventilation units. Possible damage to reactor coolant pumps might occur. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
Valves RN437B, RN484A, and RN487B, lower containment supp19. and' return isolations, cannot be exercised during power operation because failure of one of these valves in the closed position during testing would result in loss of, nuclear service water flow to the reactor coolant pump motor coolers. This would result in unit shutdown and possible damage to the reactor coolant pumps. These valves will be exercised (full-stroke) to the position required to fulfill their function and stroke timed during cold shutdown.
- 10. MAIN STEAM SYSTEM 10.1 Category B Valves Valves SM1, SM3, SMS, and SM7, main steam isolations, cannot be exercised during power operation because closure of these valves during power operation could introduce a severe transient in the main steam lines which could cause a unit trip. These valves will be partially stroked at least once per 92 days per PT/1/A/4250/01 (Main Steam Isolation Valve j
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Movement Test). In addition, valves will 'oe exercised (full-stroke)~to the position required to fulfill their function, stroke timed, and fail safe actuation verified at cold shutdown.
- 11. INSTRUMENT AIR SYSTEM 11.1 Category'A Valves l
Valve VI778, instrument air containment isolation, cannot be exercised during power operation because failure of this valve in the closed position during testing would result in loss of instrument air supply to valves and controls within containment. This would result in loss of normal reactor 84
coolant letdown, containment ventilation unit controls, normal air supply to the power operated relief valves, etc., thereby possibly causing unit shutdown. This valve will be exercised (full-stroke) to the position required to fulfill its function and stroke timed during cold shutdown.
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