ML20209B847
| ML20209B847 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Diablo Canyon |
| Issue date: | 12/12/1984 |
| From: | EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML082410749 | List:
|
| References | |
| FOIA-86-197 NUDOCS 8704280526 | |
| Download: ML20209B847 (77) | |
Text
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APPENDIX I SAFETY. EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM DIABLO CANYON NUCLEAR POWER PLANT UNIT 1 The review contained in this Appendix was prepared with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idahc, Inc.) under contract to the U.S. Nuclear Regulatory Commission.
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8704280526 870417 PDR FOIA HOLMES86-197 PDR d
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CONTENTS Pagg 1.
INTRODUCTION.....................................................
1-1 2.
PUMP TESTING PROGRAM.............................................
2-1 2.1 Pump Testing Frequency......................................
2-1 2.2 Pump Vibration Measurements.................................
2-2 2.3 Pump Flow Measurements......................................
2-4 2.4 Pump Inlet and Differential Pressure Measurements...........
2-8 3.
VALVE TESTING PROGRAM............................................
3,
3.1 General Considerations......................................
. 3-1 3.1.1 Exercising of Check Valves...........................
.3-1 3.1.2 Valves Identified for Cold Shutdown Exercising.......
3-2 3.1.3 ' Conditions for Valve Testing During Cold Shutdowns............................................
3-2 3.1.4 Category A Valve Leak Test Requirements for Containment Isolation Valves (CIVs)................. 3 3.1.5 Application of Appendix J Testing to the IST Program.............................................
3-3 3.1.6 Valves Whose Function is Important to Safety.........
3-3
~
3.1.7 Valves Which Perform a Pressure Boundary 1
Isolation Function..................................
3-4 3.1.8 Pressurizer Power Operated Relief Valves.............
3-5 3.2 Auxiliary Feedwater System..................................
3-6 i
3.2.1 Category C Valves....................................
3-6 j
3.3 Turbine Steam Supply System.................................
3-7 3.3.1 Category C Valves....................................
3-7 3.4 Reactor Coolant System.....
3-9 3.4.1 Category A/C Valves.................................
3-9 3.5 Chemical and Volume Control System................
3-10 3.5.1 Category A/C Valves............................
3-10
- 3. 5. 2-Category C Valves.............
3-11 i
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C6NTENTS(continued)
Page
~ 3.6 Safety Injection System.....................................
3-13 3.6.1 Category A/C Valves..................................
3-13 3.6.2 Category B Valves....................................
3-18 3.6.3 Category C Valves....................................
3-23 3.7 Re sidual Heat Removal Sy stem................................
3-31 4
3.7.1 Category B Valves....................................
3-31 3.7.2 Category C Valves....................................
3-33 3.8 Containment Spray System....................................
3-34 3.8.1 Category A/C Valves.................................
3-34 3.8.2 Category B Valves..................................
3-35 3.8.3 Category C Valves.................................. 37 3.9 Component Cooling Water System..............
3-39 3.9.1 Category A/C Valves.................................
3-40 3.10 Li quid Radwa ste Sy stem.....................................
3-40 3.10.1 Category A/C Valves.................................
3-41 3.11 Diesel Generator System...................................
3-41 3.11.1 Category B Valves..................................
3-42 3.12 Ventilation and Air Conditioning System.................
3-42
,i 3.12.1 Category A Valves.................................
3-43 3.12.2 Category A/C Valves..............................
3-47 3.13 Compressed Air Systems.....................................
3-47 3.13.1 C a teg o ry A/C Val v e s............................
3-47 4
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CONTENTS (continued)
Page APPENDIX A............................................................
I 1.
CODE REQUIREMENTS--VALVES........................................
1 2.
CODE REQUIREMENTS--PUMPS........................................
1 ATTACHMENT 1.........................................................
1 1.
MAIN AND AUXILIARY FEEDWATER SYSTEM..............................
1 i
1.1 Category B Valves...........................................
I 1.2 Category C Valves........................................,.
1-4 2.
TUR5INE STEAM SUPPLY SYSTEM..................................
2 4
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2.1 Ca t e g o ry B Va l v e s........................................
2 1
1 3.
REACTOR COOLANT SYSTEM...........................................
3 4
3.1 Category B Valves.........................................
3 4.
CHEMICAL AND VOLUME CONTROL SYSTEM..............................
3 4.1 C a t e g o ry A Va l v e s..........................................
3 4.2 Category B Valves..........................................
3 4.3 Category C Valves.........................................
4 5.
SAFETY INJECTION SYSTEM....................................
5 5.1 Category A/C Valves................
5 5.2 Category B Valves........................
5 6.
RESIDUAL HEAT REMOVAL SYSTEM...............................
6 6.1 C a t e g o ry A Va l v e s......................................
6 6.2 Category B Valves........................................
7 6.3 Category C Valves.........................................
7 7.
CONTAINMENT SPRAY SYSTEM............
7 7.1 Category B Valves 7
7.2 Category C Valves.....
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CONTENTS (continued)
Page 8.
COMPONENT COOLING WATER SYSTEM..................................
8 8.1 Category A Valves.........................................
8 9
8.2 Category B Valves.............
9.
VENTI LATION AND AIR CONDITIONING SYSTEM........................
9 9.1 C a t e g o ry A V a l v e s........................................
9 10.
LIQUID RADWASTE SYSTEM...............................
10 10 10.1 Category A Valves ATTACHMENT 2.
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1.
INTRODUCTION Contained erein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Pacific Gas and Electric Company (PG&E) for its Diablo Canyon Nuclear Power Plant, Unit 1.
The working session with PG&E and Diablo Canyon, Unit 1, representatives was conducted on February 7, 8, and 9, 1983. The utility's resubmittal dated May 10, 1983, was evaluated for compliance of proposed tests with the require-ments of the ASME Boiler and Pressure Vessel Code,Section XI, 1977 Edition-trough the Summer 1978 Addenda. In their resubmittal, PG&E has requested relief from the Section XI, ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.
The evaluations in this SER of the Diablo Canyon Nuclear Power Plant, Unit 1, pump and valve inservice testing program and the associated relief requests were prepared by the NRC staff with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idaho, Inc.)
A summary of pump and valve Section XI testing requirements is provided in Appendix A.
Category A, B, and C valves thatmeet the requirements of Subsection IWV of Section XI of the ASME Code, and are not exercised quarterly are addressed in.
l A listing of P& ids used for this review is contained in Attachment 2.
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12/05/84 1
DIABLO CANYON SSER 1 SEC 1
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2.
PUMP TESTING PROGRAM The Diablo Canyon Nuclear Power Plant, Unit 1, IST program submitted by Pacific Gas and Electric Company was examined to verify that Code Class 1, 2, and 3 pumps that perform a function important to safety were included in the program and that these pumps are subjected to the periodic tests required by Subsection IWP of Section XI of the ASME Code. Our review found that, except where speci-fic relief from testing has been requested, these pumps are included in the pro-gram and tested to the Code requirements summarized in Appendix A. Each Pacific Gas and Electric Company basis for requesting relief from the pump testing re-l quirements and the NRC staff evaluation of that request is summarized below.
2.1 Pump Testing Frecuency j
2.1.1 Relief Request f
The utility has requested specific relief from performing monthly inservice testing of all the listed pumps in the IST program and proposed performing the inservice testing at a quarterly interval.
2.1.1.1 Code Requirement.
Refer to Appendix A.
2.1.1.2 Utility's Basis for Requesting Relief Relief is requested to perform inservice tests on pumps "at least once per 92 days" instead of the "at least once per 31 days" frequency required by ASME i
Section XI 1977 Edition (Addenda through Summer 1978).
In accordance with 10 CFR 50.55a, Paragraph (g), Subparagraph-(4)(IV), the Inservice Tests of Pumps "may meet the requirements set forth in subsequent 2-1 I
i
editions and addenda that are incorporated by reference in Paragraph (b) of this section...".
Paragraph (b), Subparagraph (2), references ASME Section XI, 1980 Edition (Addenda through Winter 1980).
The newer requirements of Subsection IWP-3400 of ASME,Section XI, specify Inservice Pump Tests to be run every three months.
2.1.1. 3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the test frequency requirements of Section XI for all pumps in the IST program. 10 CFR 50.55a, Paragraph (g), Subparagraph (4)(IV), also states, "and subject to Commission approval...".
The NRC staff position is that the utility will perform the inservice pump testing at the frequency specified in the latest NRC approved edition of the ASME Code. The 1980 Edition, through the Winter 1980 Addenda, of Section XI of the ASME Code requires inservice testing of pumps to be performed every three months.
2.1.1. 4 Conclusion We conclude that the utility may test all pumps in the IST program every three months in accordance with the requirements of Subsection IWP of Section XI of the ASME Code.
- 2. 2 Pump Vibration Measurements 2.2.1 Relief Request The utility has requested specific relief from the testing requirement of measuring displacement vibration amplitude for all of the listed pumps in the IST program and proposed measuring vibration velocity for these pumps.
2.2.1.1 Code Requirement Refer to Appendix A.
11/02/84 2-2 Diablo Canyon 1 Pump and Valve SER
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2.2.1.2 Utility's Basis for Requesting Relief Velocity is a better indication of vibration severity because it accounts for both the displacement of the vibrat' ion and the rate or frequency of displacement.
Both of these parameters must be considered when determining the susceptibility of malfunction due to fatigue, the leading cause of mechanical failure.
For any unique frequency, vibration velocity can be related to displacement amplitude by:
V
= 52.30 (F/1000) x 10 3 peak where vibration velocity in inches per second, peak V
=
peak peak to peak displacement in mils 0
=
frequency, cycles per minute.
F
=
Using this relationship, conservative acceptable criteria have been derived which can be related directly to the code-specified limits on displacement.
Consider the case of a degraded antifriction, (ball) bearing. Displacement readings may not indicate the existence of an unacceptable condition; however, velocity, which accounts for displacement, and in this case the high frequency of ball rotation would indicate a problem.
J 2.2.1.3 Evaluation We agree with the utility's basis in that vibration velocity measurements are superior to displacement vibration amplitude measurements for monitoring pump degradation;.however, the proposed acceptance criteria for the vibration velocity measurements are not' adequate to ensure proper corrective actions are taken if pump degradation occurs.
11/02/84 2-3 Diablo Canyon 1 Pump and Valve SER
2.2.1.4 Conclusion We conclude that relief should be granted from the requirements of Section XI for measuring displacement vibration amplitude for all pumps in the IST program and the utility's alternate proposal of using vibration velocity measurements should be used. ' Alternate acceptance criteria for vibration velocity measure-ments should be developed by the NRC staff and used to replace the acceptance criteria proposed by the utility. This would result in necessary corrective actions being taken to ensure proper operability of the pumps in the IST program.
2.3 Pump Flow Measurements 2.3.1 Relief Request The utility has request specific relief from the test requirement of calibrating the flowmeters for the safety injection and containment spray pumps in accordance with the requirements of Section XI.
2.3.1.1 Code Requirement IWP-4140 states, " Instruments, together with their transmitters if used, shall be calibrated either prior to the establishment of reference quantities or on a regular basis as established by the Owner. New or repaired instruments shall be calibrated prior to test use. A system of calibration records shall be used to identify each instrument and its date of calibration, or alternatively each instrument may contain an attached tag or sticker that records the date of last calibration."
2.3.1.2 Utility's Basis for Requesting Relief Relief is requested from calibration of flowmeters FI-973 and FI-929. These instruments are variable-area head-type flowmeters whose response and accuracy are not expected to change. These flowmeters are used in the inservice test of the pumps, to provide verification of test / recirculation flow through a fixed resistance flow path.
11/02/84 2-4 Diablo Canyon 1 Pump and Valve SER
These flowmeters shall be observed to function properly during each pump test.
2.3.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the Section XI requirement of calibrating the flowmeters for the safety injection and containment spray pumps. These instruments cannot be calibrated due to their design. Since the response and accuracy of these instruments should not change over their lifetime, we feel that observation of proper operation of these instruments during the pump testing should give the utility sufficient assurance that pump flow rate is being measured in accordance with the requirements of Section XI.
2.3.1.4 Conclusion We conclude that proper flow rate for these pumps can be determined without calibrating the associated flowmeters. Based on the considerations discussed above, we conclude that the relief thus granted will not endanger life or property or the common defense and security of the public.
2.3.2 Relief Request The utility has requested specific relief from the test requirement of measuring flow for the centrifugal charging pumps, auxiliary feedwater pumps, diesel fuel oil transfer pumps, boric acid transfer pumps, and makeup water transfer pumps in accordance with the requirements of Section XI and proposed monitoring any changes in pump performance by observing changes in differential pressure while the pumps are being tested in a fixed resistance configuration.
2.3.2.1 Code Requirement Refer to Appendix A.
2.3.2.2 Utility's Basis for Requesting Relief Relief is requested from the measurement of flow rate on these pumps.
11/02/84 2-5 Diablo Canyon 1 Pump and Valve SER
Instrumentation for measurement of the test ficw rate was not provided in the system design.
These pumps are tested on fixed resistance flow paths. As such, the pump differential pressure is. determined and the flow rate, though not calculated, can be evaluated. Since the flow paths utilized for inservice testing are fixed resistance paths, pump differential pressure will give direct indication of pump, and therefore, flow rate degradation.
2.3.2.3 Evaluation i
We agree with the utility's basis that, given the present system configurations, pump flow rate cannot be measured in accordance with the requirements of Section XI for the listed pumps. The proposed alternate test method of monitor-ing pump differential pressure while these pumps are being tested in a fixed I
resistance configuration may not adequately monitor the hydraulic characteristics of these pumps and possible pump degradation; therefore, relief should not be granted and the utility should perform the necessary modifications to the appli-cable systems to allow measuring pump flow rate in accordance with the require-ments of Section XI.
2.3.2.4 Conclusion We conclude that the utility should perform the necessary modifications to the applicable systems to allow measuring pump flow rate in accordance with the requirements of Section XI.
2.3.3 Relief Request The utility has requested specific relief from comparing flow rate and differen-tial pressure for the component cooling water pumps with a fixed set of reference values in accordance with the requirements of Section XI and proposed comparing tnis test data to a pump test curve, which is actually a " family" of curves that includes a reference or manufacturer's curve with " alert" and " action" curves for both the high and low limits.
2-6
2.3.3.1 Code Requirement IWP-3110 states, " Reference values are defined as one or more fixed sets of values of the quantities shown in Table IWP-3100-1 as measured or observed when the equipment is known to be operating acceptably. All subsequent test results shall be compared to these reference values or with new reference values established in accordance with IWP-3111 and IWP-3112. Reference values shall be determined from the results of an inservice test which may be run during preoperational testing, or from the results of the first inservice test run during power operation. Reference values shall be at points of operation readily duplicated during subsequent inservice testing."
2.3.3.2 Utility's Basis for Requesting Relief The component cooling water pump inservice test is performed by operating a single pump and measuring flow, then comparing it to the required differential pressure indicated on a pump test curve.
This pump test curve is actually a " family" of curves that include a reference or manufacturer's curve with " alert" and " action" curves for both the high and low limits. The limit curves -are generated using the " Allowable Ranges of Test Quantities" Table IWP-3100-2.
A variable flow measurement is recuired because of the difficulty in establishing -
a single test flow rate on a system that has varying heat loads and therefore varying flow requirements.
2.3.3.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from comparing flow rate and differential pressure for the component cooling water pumps with a fixed 9et of reference values in accorcance with the requirements of Section XI.
The utility has demonstrated that flow rate and differential pressure measurements for these pumps cannot be duplicated during each inservice test, due to varying cooling requirements of the components supplied by this system. As an alternate test method, the utility has croposed 2-7 1
comparing the flow rate and differential pressure measurements taken for these pumps during each inservice test with a pump curve which establishes the relationship between flow and differential pressure in a band around the pump design point. We feel this proposed alternate testing will allow the utility to adequately determine the hydraulic characteristics of these pumps and detect any degradation of these pumps.
2.3.3.4 Conclusion We conclude that the utility's proposed alternate testing method of comparing the flow rate and differential pressure measurements taken for the component cooling water pumps during each inservice test with a curve of reference values rather than a fixed set of reference values should provide sufficient information to adequately monitor pump degradation and meet the intent of the Section XI requirements. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
2.4 Pump Inlet and Differential Pressure Measurements 2.4.1 Relief Request The utility has requested specific relief from the test requirement of measuring inlet pressure for the diesel fuel oil transfer pumps in accordance with the requirements of Section XI and proposed observing that discharge pressure of l
these pumps remains constant during the inservice test.
2.4.1.1 Code Requirement Refer to Appendix A.
2.4.1.2 Utility's Basis for Requesting Relief 4
1 i
Relief is. requested from the measurement of inlet pressure for the diesel fuel oil transfer pumps. Instrumentation for measurement of the pump inlet pressure i
j 11/02/84 2-8 Diablo Canyon 1 Pump and Valve _SER
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was not provided in the system design.
These are positive displacement pumps and measurement of a constant discharge pressure will indicate no problem in the suction line during the fixed flow pump test.
2.4.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the test requirement of measuring inlet pressure for the diesel fuel oil transfer pumps. The parameter that the utility has proposed measuring to determine the hydraulic condition of these pumps is discharge pressure. We feel that measurement of a constant discharge pressure for a positive displace-ment pump, will supply adequate information to determine hydraulic condition or pump degradation. For a positive displacement pump, the measurement of a constant discharge pressure in the suction line during a fixed flow test indicates an acceptable level of performance.
2.4.1.4 Conclusion We conclude that the requested relief by the utility from the test requirement of measuring inlet pressure for the diesel fuel oil transfer pumps in accordance with the requirements of Secticn XI should be granted. Based on the consideration discussed above, we conclude that the proposed testing will give reasonable assurance of the hydraulic conditions of the pumps and the relief thus granted will not endanger life or property or the common defense and security of the public.
2.4.2 Relief Request The utility has requested specific relief from the test requirement of measuring differential pressure for the reciprocating charging pump in accordance with the requirements of Section XI and proposed observing that flow rate for this pump is acceptable at test pressure.
2.4.2.1 Code Requirement Refer to Appendix A.
11/02/84 2-9 Diablo Canyon 1 Pump and Valve SER
2.4.2.2 - Utility's Basis for Requesting Relief Relief is requested from the measurement of pump differential pressure because pump discharge pressure is meaningless at low reactor coolant system pressures.
If the positive displacement pump flow rate is~ acceptable at test pressure the pump shall be acceptable.
2.4.2.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from measuring differential pressure of the reciprocating charging pump in accordance with the requirements of Section XI. The discharge pressure of this pump will vary according to reactor coolant system pressure since it is a positive displacement pump, therefore, measurement of differential pressure would not provide the utility with useable information to determine the hydraulic characteristics of this pump. The utility's proposed alternate testing method of insuring the pump flow rate is acceptable at test pressure should provide sufficient information to allow monitoring pump degradation.
2.4.2.4 Conclusion i
We conclude that the utility's proposed alternate testing method of insuring that pump flow rate for this pump is acceptable at test pressure should pro-vide sufficient information to adequately monitor pump degradation. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or 4
the common defense and security of the public.
I 2-10
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3.
VALVE TESTING' PROGRAM The Diablo Canyon Nuclear Power Plant, Unit 1, IST program submitted by Pacific.
Gas and Electric Company was examined to verify that Class 1, 2, and 3 valves i
that perform a function important to safety were included in the program and
.that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC staff positions and guidelines. Our review found that, except where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC staff positions and guidelines sum-marized in Appendix A and Section 3.1 of this' report. Each pacific Gas and Electric Company basis for requesting relief from the valve testing requirements and the NRC staff evaluation of that request is summarized below and grouped according to system and valve category.
3.1 General Considerations t
3.1.1 Exercising of Check Valves The NRC staff position was stated to the utility that check valves whose safety function is to open are expected to be full-stroke exercised. Since i
the disc position is not always observable, the NRC staff position is that l'
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 requirements. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown that the check valve's disc position at the 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.
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3.1.2 Valves Identified for Cold Shutdown Exercising The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them quarterly during plant operation. The utility has specifically identified the applicable valves and these valves are full-stroke exercised during cold shutdowns; therefore, the utility is meeting the require-ments of the ASME Code. Since the utility is meeting the requirements of the Code, it is not necessary to grant relief; however, during our review of the IST program, we have verified that it is not practical to exercise these valves during power operation and that we agree with the utility's cold shutdown justifications.
It should be noted that the NRC staff differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for valves identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and each refueling outage. However, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling outage.
In addition, for extended refueling outages, tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies.
3.1.3 Conditions for Valve Testing During Cold Shutdowns Cold shutdown testing of valves identified by the utility is acceptable when the following conditions are met:
1.
The utility is to commence testing as soon as the cold shutdown condition 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.
2.
Completion of all valve testing identified for a cold shutdown frequency is not a prerequisite to return to power.
3.
Any testing not ccmpleted during one cold shutdown should be performed during any subsegrent cold shutdowns that may occur before refueling to as closely as possible meet the Code-specified testing frequency.
12/04/84 3-2 Diablo Canyon 1 Pump and Valve SER
l
- l 4.-
For planned cold shutdowns, where ample time is available for testing all the valves' identified for the cold shutdown. test frequency in the IST program will be completed, 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.
l 3.1.4 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 staff has concluded that the applicable. leak' test procedures and requirements
}
for containment isolation valves are determined by 10 CFR 50, Appendix J.
i Relief from Paragraphs IWV-3421 through -3425 for containment isolation valves i
presents no safety problem since the intent of IWV-3421 through -3425 is met
~
j by Appendix J requirements, however, the utility is required to comply with l
the analysis of leakage rates and corrective action requirements, Paragraphs IWV-3426 and -3427 of the 1980 code respectively. Based on the considerations discussed above the NRC staff has concluded that this alternate testing will give reasonable assurance of valve leak-tight integrity intended by the Code and that this testing will not endanger life or property or the common defense and security of the public.
3.1.5 Application of Appendix J Testing to the IST Program The Appendix J review for this plant is completely separate from the IST j
program review. However, the determinations made by that review are directly applicable to the IST program. The utility has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
3.1.6 Valves Whose Function is Important to Safety l
This review was limited to valves whose function is important to safety, j
Valves whose function is important to safety are defined as those valves that
]
are needed to mitigate the consequences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves a
and could include some non-Code class valves.
It should be noted that the I
utility may have included valves whose function is not important to safety in 12/04/84 3-3 Diablo Canyon 1 Pump and Valve SER i.w
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l their IST program as a decision on their part to. expand the scope of their program.
3.1.7 Valves Which Perform a Pressure Boundary Isolation Function i
Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the ASME Code Class I boundary provide.the interface between these high and low pressure systems and protect the low pressure systems from pressures which exceed their design limit. In this role, the valves per-form a pressure isolation function. The NRC staff position is that the redun-2 dant isolation provided by these valves is important and therefore considers it necessary to ensure that the condition of each of these valves is adequate to j
maintain this redundant isolation function and protect the system integrity of the low pressure systems.
t The following is a list of valves that perform a pressure isolation function.
Safety Injection System Valve Category 8818A, RHR to cold leg-1 check A/C 8818B, RHR to cold leg-2 check' A/C 8818C, RHR to cold leg-3 check A/C 88180, RHR to cold leg-4 check A/C 8819A, SI to cold leg-1 check A/C 88198, SI to cold leg-2 check A/C 8819C, SI to cold leg-3 check A/C 8819D, SI to cold leg-4 check A/C 8948A, loop-1 cold leg injection check A/C 89488, loop-2 cold leg injection check A/C 8948C, loop-3 cold leg injection check A/C 89480, loop-4 cold leg injection check A/C 8956A, SI accumulator-1 discharge check A/C e
89568 SI accumulator-2 discharge check A/C 8956C, SI accumulator-3 discharge check A/C 89560, SI accumulator-4 discharge check A/C 8905A, SI to hot leg-1 check C
8905B, SI to hot leg-2 check C
8905C, SI to hot leg-3 check C
89050, SI to hot leg-4 check C
3-4 4
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l Safety Injection System Valve Category 8949A, SI to hot leg-1 check C
89498, SI to hot leg-2 check C
8949C,_SI to hot leg-3 check C
89490, SI to hot leg-4 check C
Residual Heat Removal System Valve Category 8701, RCS loop-4 to RHR isolation A
8702, RCS loop-4 to RHR isolation A-8740A, RHR to hot leg-1 check C
87408, RHR to hot leg-2 check C
The listed valves that are categorized A or A/C are being leak-rate tested to demonstrate their leak-tight integrity which is required to perform the pressure isolation function in accordance with Diablo Canyon Unit 1 technical specifi-cation requirements.
The listed valves that are categorized C are not being leak-rate tested to demonstrate their leak-tight integrity. These valves should be reclassified valve category A/C and tested in accordance with Diablo Canyon Unit 1 technical specification requirements and included in Table 3.4-1 of the technical specifications.
3.1. 8 Pressurizer Power Operated Relief Valves I
'The NRC staff 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 PORVs have shown a high probability of sticking open and are not needed for overpressure protec-I tion during power operation, the NRC staff has concluded that routine exercising i
l during power operation is "not practical" and, therefore, not required.
1 The PORV's function during reactor startup and shutdown is to protect the
]
i reactor vessel and coolant system from low temperature-overpressurization conditions and should be exercised prior to initiation of system conditions j
j.-
for which vessel protection is needed.
12/04/84 3-5 Diablo Canyon 1 Pump and_ Valve SER I
l L
The following schedule is' required:
1.
Full.-stroke exercising should be performed at each* cold shutdown or, as a minimum,.once each refueling cycle.
2.
Stroke timing should be performed at each cold shutdown or, as a minimum, once each refueling cycle.
3.
Fail safe actuation testing should be performed at each cold shutdown.
4.
The PORV block valves should be included in the IST program to provide protection against a small break LOCA should.a PORV fail open.
3.2 Auxiliary Feedwater System 3.2.1 Category C Valves 3.2.1.1 Relief Request The utility has requested specific relief from exercising valves FW-349 and FW-353, auxiliary feedwater pumps suction check valves from the raw water-storage reservoir, in accordance with the requirements of.Section XI and proposed disassembling these valves and inspecting the internals to demonstrate proper operability at a frequency of at least once per five years.
3.2.1.1.1 Code Requirement Refer to Appendix A.
- The staff position described in Section 3.1.3 regarding cold shutdown testing is not applicable to the PORVs; however, in the case of frequent cold shudowns, testing of the PORVs is not required more often than each three months.
12/04/84 3-6 Diablo Canyon 1 Pump and Valve SER
1 i
3.2.1.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised with flow because the water from the raw water storage reservoir would contaminate the steam generators, creating chemistry control problems which could affect the integrity of the steam a
generator tubes.
These valves will be disassembled and internally inspected (mechanical exercise) to verify operability. This inspection will be performed at a frequency of at least once per five years.
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3.2.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves FW-349 and FW-353. Exercising these valves with flow would contaminate the steam generators with water from the raw water storage reservoir, creating chemistry control problems which could affect the integrity of the steam generator tubes. As an alternate means of full-stroke exercising these valves, the utility has proposed disassembling them to verify proper operability at a five year interval. We feel that disassembly of these valves to verify proper operability is an acceptable alternate testing method, however, we cannot currently justify any inspection interval longer than each refueling outage.
3.2.1.1.4 Conclusion We conclude that disassembling these valves and inspecting the internals should demor. strate proper operability. However, we cannot currently justify any inspection interval longer than each refueling outage until the NRC staff has completed their review of the initial inspection report of the internal condition of these valves supplied by the utility in their IST program submittal.
3.3 Turbine Steam Supply System 3.3.1 Category C Valves 11/02/84 3-7 Diablo Canyon 1 Pump and Valve SER i
3.3.1.1 Relief Request The utility has requested specific relief from exercising valves MS-1068, MS-2066, MS-3062, and MS-4062, main steam line check valves, in accordance with the requirements of Section XI and proposed disassembling and/or internally inspecting these valves to demonstrate proper operability at a frequency of at least once per five years.
3.3.1.1.1 Code Requirement Refer to Appendix A.
3.3.1.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised closed because provisions are not provided in '
the plant design to verify that these valves close on reverse flow.
These valves will be disassembled and/or internally inspected to verify opera-bility. This inspection will be performed at a frequency of at least once per five years.
t 3.3.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves MS-1068, MS-2066, MS-3062, and MS-4062. The utility has demonstrated that, due to the current plant design, there is no means available to verify closure of these valves except by disassembly and inspection of the internals.
t As an alternative to disassembling these valves to demonstrate proper opera-bility, the utility has proposed modifying the drain lines on the bottom of each valve to allow a Fiberscope to be inserted into the valve to inspect the internal condition and verify the disc is in the closed position for each valve during refueling outages or other outages.
(Refer to Attachment B of the utility's IST program submittal for a detailed discussion of this proposed modification.) We feel this proposed alternate method of testing is acceptable
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11/02/84 3-8 Diablo Canyon 1 Pump and Valve SER s
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if it is; p,erformed at a refueling outage frequency and should demonstrate proper operability of these valves.
1 If the utility dces not make the proposed modifications to inspect these valves with a Fiberscope, they have proposed disassembling the valves to verify proper operability at a five year interval. We feel that disassembly of these valves to verify proper operability is an acceptable afternate testing method, however, we cannot currently justify any inspection interval longer than each refueling outage.
3.3.1.1.4 Conclusion We conclude th'at.the utility should provide the NRC staff with the information
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of which test method will be usedsto demonstrate proper operability of these valves, i.e., disassembly and" inspection of the internals or inspection of the internals with a Fiberscope.
3.4 Reactor Ccolant System 3.4.1 Category A/C Valves 3.4.1.1 Relief Request The utility has requested specific relief from exercising valves 8046 and 8047, primary water and nitrogen to the pressurizer relief tank inside containment
' isolation check valves, in accordance with the requirements of Section XI and proposed verifying closure of these valves, their safety position, at a two year interval when they are leak-rate tested.
3.4.1.1.1 Code Requirement Refer to Appendix A.
3.4.1.1.2 Utility's Basis for Requesting Relief These check valves can only be verified closed by leak-rate testing. They will be leak-rate tested at a two year interval.
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11/02/84 3-9 Diablo Canyon 1 Pump and Valve SER e
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t I t 3.4.1.1.3 Evaluation x
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m We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8046 and 8047.
The utility has demonstrated that, due to plant design, the only method available to verify valve closure, the safety position, is leak-rate testing. These i
valves are not equipped with valve position indication.and some of the required test connections are located inside containment.
3.4.1.1.4 Conclusion,"
s i
We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should 7
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demonstratepropepvalveoperability. Based on the considerations discussed 3
above, we conclude that the alternate testing proposed will give reason.rble assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and' security of,the public.
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3.5 Chemical and Volume Control System 3.5.1 Category A/C Valves 3.5.1.1 Relief Request
[
The utility has requested specific relief from exercising talses 8109, '8368A,
83688, 8368C, and 8368D, reactor coolant pump seal water return and injection inside containment isolation check valves, in accerf2 ace with the requirements of Section XI and proposed verifying closure et O ms v.ives, their safety position, at a two year interval when they af - ip ate tested.
3.5.1.1.1 Code Requirement Refer to Appendix is.
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11/02/84 3-10 Diablo Canyon 1 Pump and Valve SER
s e
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3.5.1.1.2 Utility's Basis for Requesting Relief These check valves can only be verified closed by leak-rate testing. They will be leak-rate tested at a two year interval.
3.5.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8109, 8368A, 83688, 8368C, and 8368D. The utility has demonstrated that, due to plant design, the only method available to' verify valve closure, the safety position, is leak-rate testing. These valves are not equipped with valve position indication and some of the required test connections are located inside contain-ment.
3.5.1.1.4 Conclusion We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we sonclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.5.2 Category C Valves 3.5.2.1 Relief Request The utility has requasted specific relief from exercising valves 8478A and 84788, centrifugal charging pumps discharge check valves, in accordance with the requireme'nts of Section XI and proposed partial-stroke exercising these
^
valves quarterly and full-stroke exercising them on the way to or during refueling outages.
2 11/02/84 3-11 Diablo Canyon 1 Pump and Valve SER
3.5.2.1.1 Code Requirement Refer to Appendix A.
3.5.2.1.2 Utility's Basis for Requesting Relief These valves cannot be full-stroke exercised during power operation because of insufficient available flow. These valves will be partial-stroke exercised during power operation.
These valves cannot be full-stroke exercised during cold shutdown.because this could result in a possible low temperature-overpressurization of the reactor coolant system.
i These valves will be full-stroke exercised on the way to or during refueling outages.
3.5.2.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8478A and 84788.
These valves cannot be full-stroke exercised during power operation because the normal operation of the charging system will not allow full flow to be achieved. Full-stroke exercising these valves during power operation could result in a loss of reactor coolant system level control and a possible plant trip. During cold shutdowns, these valves cannot be full-stroke exercised since this could result in a low temperature-overpressurization of the reactor coolant system due to lack of an adequate expansion volume.
3.5.2.1.4 Conclusion i
We conclude that the proposed alternate testing of partial-stroke exercising-these valves quarterly and full-stroke exercising them on the way to or during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and 3-12
that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6 Safety Injection System 3.6.1 Category A/C Valves 3.6.1.1 Relief Request The utility has requested specific relief from exercising valves 8819A, 88198, 8819C, and 88190, safety injection system to reactor-coolant system cold legs check valves, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3.6.1.1.1 Code Requirement Refer to Appendix A.
3.6.1.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because the safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure.
These valves cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by Technical Specification Surveillance Requirement 4.5.3.2 to protect against a low temperature-over-pressurization of the reactor coolant system. Also, during cold shutdown 1
there may not be sufficient volume in the reactor coolant system to accommodate the amount of water needed to full-stroke exercise these valves. These valves will be full-stroke exercised during refueling outages.
3.6.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be l
granted from the exercising requirements of Section XI for valves 8819A, l
11/02/84 3-13 Diablo Canyon 1 Pump and Valve SER
8819B, 8819C, and 88190. The only available flow path to exercise these valves is into the reactor coolant system. The utility has demonstrated that these valves cannot be exercised during power operation because the safety injection pumps do not develop sufficient head to overcome reactor cooliht system pressure. Exercising these valves during cold shutdowns could result in a low temperature-overpressurization of the reactor coolant system because a sufficient expansion volume may not exist to accommodate the flow required.
Also, during cold shutdowns the safety injection pumps are required to be inoperable b'y Technical Specifications to protect against a low temperature-overpressurization of the reactor coolant system.
3.6.1.1.4 Conclusion We conclude that full-stroke exercising these valves can only be accomplished during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume and this alternate testing should be sufficient to demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.1.2 Relief Request The utility has requested specific relief from exercising valve 8916, inside containment isolation check valve in the nitrogen supply line to the safety injection accumulators, in accordance with the requirements of Section XI and proposed verifying closure of this valve, the safety position, at a two year interval when it is leak-rate tested.
3.6.1.2.1 Code Requirement Refer to Appendix A.
11/02/84 3-14 Diablo Canyon 1 Pump and Valve SER
t 3.6.1.2.2 Utility's Basis for Requesting Relief This check valve can only be verified closed by leak-rate testing. The valve will be leak-rate tested at a two year interval.
3.6.1.2.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 8916. The utility has demonstrated that, due to plant design, the only method available to verify valve closure, the safety position, is leak-rate testing. This valve is not equipped with valve position indication and some of the test connections are located inside containment.
3.6.1.2.4 Conclusion We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.1.3 Relief Request The utility has requested specific relief from exercising valves 8948A, 89488, 8948C, and 89480, common check valves from the safety injection accumulators, safety injection system, and residual heat removal system to the reactor coolant system cold legs, in accordance with the requirements of Section XI and proposed partial-stroke exercising these valves during cold shutdowns and full-stroke exercising them during refueling outages.
3.6.1.3.1 Code Requirement Refer to A ppendix A.
11/02/84 3-15 Diablo Canyon 1 Pump and Valve SER s
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3.6.1.3.2 Utility's Basis for Requesting Relief These valves cannot be exercised'during power operation because the accumulators, 3
residual heat removal pumps, and safety injection pumps'do not develop sufficient head to overcome reactor coolant system pressure..These valves will be partial.-
stroke exercised during cold shutdowns utilizing residual heat removal flow.
These valves cannot be full-stroke exercised during cold shutdowns because this would involve personnel entry inside the secondary shield area to verify
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all valves fully stroked. Entry into this area could. result in excessive
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- radiation' exposure.
These valves will be full-stroke exercised during refueling outages.
<i 3.6.1.3.3 Evaluation 1
s i
We agree with the utility's basis and, therefore, believe that relief should be j
granted from the exercising requirements of Section XI for values 8948A, 8948B, 8948C, and 89480. The utility has demonstrated that these valves cannot be ex-ercised during power operation since the safety injection accumulators, safety injection pumps, or residual heat removal pumps do not develop sufficient head to overcome reactor coolant system pressure.
3.6.1.3.4 Conclusion i
i We conclude that full-stroke exercising these values'can only be accomplished i
during refueling outages whereas the valves can be partial-stroke excercised i
during cold shutdowns. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by Section XI of the Code.and that the relief thus granted will not endanger life or property or the common defense and security of the public.
1 i
i l
ll 3-16
P 3.6.1.4 Relief Request The utility has requested specific relief from exercising valves 8956A, 89568, 8956C, and 89560, safety injection accumulator discharge check valves, in accordance with the requirements of Section XI and proposed partial-stroke exercising these valves during refueling outages.
3.6.1.4.1 Code Requirement Refer to Appendix A.
3.6.1.4.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because the accumulator will not overcome reactor coolant system pressure.
These valves cannot be exercised during cold shutdowns because this could result in a low temperature-overpressurization of the reactor coolant system.
Full-stroke testing of these valves during refueling outages is not feasible because of the resulting water surge into the reactor vessel and potential for high airborne radiological control problems. These valves are not equipped with mechanical exercisers, position indicators or differential pressure instrumentation. They cannot be isolated or visually inspected. These valves will be partial-stroke exercised during refueling outages.
3.6.1.4.3 Evaluation The utility has demonstrated that the only available flow path for exercising these valves is into the reactor coolant system. During power operation, it is not possible to utilize this flow path because accumulator pressure cannot 1
overcome reactor coolant system pressure. During cold shutdowns, utilizing this flow path to exercise these valves could result in a low temperature-overpressurization of the reactor coolant system. Additionally, these valves cannot be full-stroke exercised utilizing accumulator flow during refueling outages, when the reactor vessel head is removed to provide an adequate expan-i sion volume, without creating a high airborne radiological control problem due 1
11/02/84 3-17 Diablo Canyon 1 Pump and Valve SER b
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to excessive flow rates. However, we feel that the utility c'annot be assured of proper operability of these valves without full-stroke exercising them, therefore, we recommend relief not be granted from the exercising requirements
-of Section XI for these valves. We feel that the utility should use an alternate testing method, such as partial valve disassembly to verify full-stroke capa-bility of these valves.
3.6.1.4.4 Conclusion We conclude that with the present system design, full-stroke exercising these valves is not feasible; however, we feel that relief should not be granted for never full-stroke exercising these valves. The proposed partial-stroke exer-cising does not meet the intent of the Code and may not provide reasonable assurance of proper valve operability. The utility should therefore use an alternate testing method by performing a partial valve disassembly in order to l
verify operational readiness.
3.6.2 Category B Valves 1
3.6.2.1 Relief Request The utility has requested specific relief from exercising valves 8803A and 8803B, boron injection tank inlet isolation valves, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves quarterly if the positive displacement charging pump is operable and during Modes 4, 5, or 6 (hot shutdowns, cold shutdowns, or refueling outages) if this pump is not operable.
3.6.2.1.1 Code Requirement Refer to Appendix A.
3.6.2.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation when the positive l
displacement charging pump is inoperable because, with the centrifugal charging pumps running to provide normal charging flow, opening either one of these 4
valves may dilute the baron injection tank concentration and/or subject the I
12/04/84 3-18 Diablo Canyon 1 Pump and Valve SER
)
boron injection tank to an unnecessary pressurization cycle. There is a specified number of design pressurization cycles for the boron injection tank, and a' low limit for operability for boron concentration.
6 These valves will be full-stroke exercised in all modes when the positive displacement pump is operable.
4 These valves will be full-stroke exercised in Modes 4, 5, or 6 when the positive displacement pump is not operable.
Evaluation If the positive displacement charging pump is operable, the utility will be full-stroke exercising these valves quarterly and no relief will be required.
However, if the positive displacement pump.is inoperable, the centrifugal J
charging pumps must be utilized to maintain reactor coolant system level control. The utility has demonstrated that opening either of these valves with a centrifugal charging pump running could result in diluting the baron injection tank concentration and/or subjecting the boron injection tank to an 4
unnecessary pressurization cycle, which are both undesirable conditions.
Therefore, we feel that relief should be granted from the exercising require-ments of Section XI for valves 8803A and 88038.
3.6.2.1.4 Conclusion We conclude that full-stroke exercising these valves quarterly, if the positive displacement charging pump is operable, or at a cold shutdown frequency, if this pump is inoperable, should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public, i
11/02/84 3-19 Diablo Canyon 1 Pump and Valve SER
i 3.6.2.2 Relief Request The utility has. requested specific relief from exercising-valves-8804A and 8804B, charging pumps and safety injection pumps suction valves from the residual heat removal system, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3.6.2.2.1 Code Requirement Refer to Appendix A.
3.6.2.2.2 Utility's Basis for Requesting Relief These valves cannot be exercised auring power operation because they are interlocked with valves 8982A and 89828 (containment sump isolation valves) that are required to be closed with power to the valve operators removed by j
Technical Specification Surveillance Requirement 4.5.2.
Valves 8982A or 89828 f
cannot be opened during power operation because this would result in one train of the residual heat removal system being not operable. Valve 8982A or 8982B cannot be opened during cold shutdown because they are interlocked with valves 8700A and 8700B (residual heat removal pump suction valves) which would have j
to be closed. With valve 8982A or 89828 opened in this configuration, it is quite likely that water from the piping between valve 8700A or 87008 and the sump valve connection will be discharged through valve 8982A or 89828 into the containment sump. This water will interfere with the reactor coolant system sump level / flow leakage detection system and void the suction piping, requiring refilling and venting the piping.
If a LOCA occurred under this condition, extensive time would be required to recover from this very abnormal lineup.
Also, during cold shutdown valves 8804A and 8804B cannot be exercised open because they are interlocked with valves 8701 and 8702 (reactor coolant system I
loop four to residual heat removal system isolation valves) in the closed position. 8701 and 8702 are required to be open, and closing one of these valves would result in both residual heat removal trains.being incapable of removing decay heat from the core. Valves 8804A and 88048 will be full-stroke exercised during refueling outages.
2 11/02/84 3-20 Diablo Canyon 1 Pump and Valve SER
3.6.2.2.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8804A and 88048.
The utility has demonstrated that, due to system interlocks, exercising these valves during power operation would require removing one train of the residual heat removal system from operation for an extensive time. To exercise these valves at power operation, the utility would have to shut one of the residual heat removal pump suction valves (8700A or 87008) and open the associated containment sump isolation valve (8982A or 89828) which could result in draining water from the residual heat removal system piping in to the containment sump.
If this condition occurred, the utility would require an extensive amount of time to refill and vent the associated piping. During cold shutdowns, these valves cannot be exercised because this would require closing valves 8701 and 8702, due to interlocks, which would result in both trains of the residual heat removal system being unavailable for removal of decay heat from the core.
3.6.2.2.4 Conclusion We conclude that full-stroke exercising these valves during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.2.3 Relief Request i
The utility has requested specific relief from exercising valves 8982A and 8982B, containment sump isolation valves to the residual heat removal pumps, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3.6.2.3.1 Code Requirement Refer to Appendix A.
11/02/84 3-21 Diablo Canyon 1 Pump and Valve SER
3.6.2.3.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because they are required to be closed with power to the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
If these valves were opened during power operation, this would result in one train of the residual heat removal system being not operable.
These valves cannot be exercised during cold shutdown because opening one of these valves could introduce air into the suction piping of the residual heat removal pumps, causing the residual heat removal pumps to be not operable for an extended period of time.
These valves will be full-stroke exercised during refueling outages.
3.6.2.3.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8982A and 89828.
Exercising these valves during power operation or cold shutdowns could result in rendering at least one train of the residual heat removal system inoperable for an extended period of time due to the possibility of draining the suction piping of the residual heat removal pumps to the containment sump and having to refill and vent this piping. During power operation, this condition could result in a possible plant shutdown and during cold shutdowns, the utility may not be able to adequately remove the decay heat from the core.
3.6.2.3.4 Conclusion We conclude that full-stroke exercising these valves during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
11/02/84 3-22 Diablo Canyon 1 Pump and Valve SER
3.6.3 ~ Category C Valves 3.6.3.1 Relief Request The utility has requested specific relief from exercising valves 8820, 8900A, 89008, 8900C, and 89000, check valves in the lines from the boron injection tank.to the reactor coolant system cold legs, in accordance with the require-ments of Section XI and proposed partial-stroke exercising valve 8820 during cold shutdowns and full-stroke exercising all of these valves during refueling 4
outages.
3.6.3.1.1 Code Requirement l
Refer to Appendix A.
3.6.3.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because this would require injecting highly concentrated boric acid solution from the boron injection tank into the reactor coolant system resulting in a possible plant l
shutdown. During power operation these valves cannot be partial-stroke exercised utilizing the bypass line because this could result in bypassing the baron injection tank, thereby not achieving design flow through 'the boron l
injection tank if an accident occurred.
Valve 8820 will be partial-stroke exercised during cold shutdown utilizing the
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bypass line (this method will not verify a partial-stroke exercise of the other valves).
These valves cannot be full-stroke exercised during cold shutdown because this would require injecting the baron injection tank into the' reactor coolant system which could significantly delay startup from the cold shutdown condition (the boron injection tank would have to be brought to the proper boron concen-tration and the reactor coolant system would have to be diluted sufficiently to allow startup). These valves will be full-stroke. exercised on the way to or during refueling outages.
11/02/84 3-23 Diablo Canyon 1 Pump and Valve SER 1
f 3.6.3.1.3 Evaluation We agree with the utility'.s basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8820, 8900A, 89008, 8900C, and 89000. 'These valves cannot be. full-stroke exercised during power operation'since this would require injecting highly concentrated boric acid solution from the boron injection tank into the reactor coolant system t
which could result in a plant shutdown. Also, partial-stroke exercising these valves during power operation via the bypass'line could result in not achieving design flow through the boron injection tank if an accident occurred. During l
cold shutdowns, these valves cannot be full-stroke exercised with flow from the boron injection tank since this could result in delaying startup from the
. cold shutdown condition due to the amount of time required to bring the boron i
injection tank back to the proper boron concentration and dilute the I
reactor coolant system sufficiently to allow startup. The check valves in the individual lines to the reactor coolant system cold legs (8900A, 89008, 8900C, I
and 89000) cannot be verified to partial stroke since these four valves are in parallel and individual flow instrumentation is not installed for these valves.
Installing temporary instrumentation to verify flow through each of these valves could result in delaying startup from the cold shutdown condition.
3.6.3.1.4 Conclusion j
We conclude that partial-stroke exercising valve 8820 during cold shutdowns i
and full-stroke exercising all of these valves during refueling outages should
{
demonstrate proper valve operability. Based on the considerations discussed
{
above, we conclude that the alternate testing proposed will give reasonable
)
assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security i
of the public.
3.6.3.2 Relief Request j
The utility has requested specific relief from exercising valves 8905A, 89058, l
8905C, 89050, 8922A, and 89228, safety injection systerii to reactor coolant j
system hot legs check valves (8905A, 8905B, 8905C, and 89050) and safety l
11/02/84 3-24 Diablo Canyon 1 Pump and. Valve SER I
injection pumps discharge check valves (8922A and 89228), in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3.6.3.2.1 Code Requirement Refer to Appendix A.
3.6.3.2.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because the safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure.
These valves cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by Technical Specification Surveillance Requirement 4.5.3.2 to protect against a low temperature-over-pressurization of the reactor coolant system. Also, during cold shutdown there may not be sufficient volume in the reactor coolant system to accommodate 1
the amount of water needed to full-stroke exercise these valves. These valves will be full-stroke exercised during refueling outages.
j 3.6.3.2.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8905A, 8905B, 8905C, 89050, 8922A, and 89228. The only available flow path to exercise these valves is into the reactor coolant system. The utility has demonstrated that these valves cannot be exercised during power operation because the safety injection pumps do not develo; sufficient head to overcome reactor coolant system pressure. Exercising these valves during cold shutdowns could result in a low temperature-overpres.lrization of the reactor coolant system because a sufficient expansion volume may not exist to accommodate the flow required.
4 11/02/84 3-25 Diablo Canyon 1 Pump and Valve SER
Also, during cold shutdowns the safety injection pumps are required to be inoperable by Technical Specifications to protect against a low temperature-overpressurization of the reactor coolant system.
3.6.3.2.4 Conclusion We conclude that full-stroke exercising these valves can only be accomplished during refueling outages when the reactor vessel head is removed-to provide a')
adequate expansion volume and should be sufficient to demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve opera-bility intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.3.3 Relief Request The utility has requested specific relief from exercising valve 8924, check valve in the supply line from the refueling water storage tank to the charging pumps, in accordance with the requirements of Section XI and proposed partial-stroke exercising this valve during cold shutdowns and full-stroke exercising it during refueling outages.
3.6.3.3.1 Code Requirement Refer to Appendix A.
3.6.3.3.2 Utility's Basis for Requesting Relief This valve cannot be exercised during power operation because this would require injecting borated water from the refueling water storage tank into the reactor coolant system which could result in a plant shutdown. This valve will be partial-stroke exercised during cold shutdown. This valve cannot be full-stroke exercised during cold shutdown because this would require utilizing the flow path through the boron injection tank. This flow path cannot be utilized during cold shutdown because this would require injecting the boron injection tank into the reactor coolant system which could significantly delay 4
11/02/84 3-26 Diablo Canyon 1 Pump and Valve SER
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startup from the cold shutdown condition (the baron injection tank would have to be brought to the proper baron concentration and the reactor coolant system would have to be diluted sufficiently to allow start up). This valve will be full-stroke exercised during refueling outages.
3.6.3.3.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 8924. The utility has demonstrated that this valve cannot be exercised during power operation since this would require injecting borated water from the refueling water storage tank into the reactor coolant system which could result in a plant shutdown. During cold shutdowns, this valve cannot be full-stroke exercised since this would require injecting the boron injection tank into the reactor coolant system which could result in delaying startup from the cold shutdown condition due to the amount of time required to bring the baron injection tank back to the proper boren concentration and dilute the reactor coolant system sufficiently to allow startup.
3.6.3.3.4 Conclusion We conclude that partial-stroke exercising this valve during cold shutdowns and full-stroke exercising it during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.6.3.4 Relief Request The utility has requested specific relief frcm exercising valves 8949A, 89498, 8949C, and 89490, safety injection'and residual heat removal system to reactor coolant system hot legs check valves (8949A and 89498) and safety injection system to reactor coolant system hot legs check valves (8949C and 89490), in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3-27
3.6.3.4.1 Code Requirement Refer to Appendix A.
3.6.3.4.2 Utility's Basis for Requesting Relief Valves 8949C and 89490 cannot be exercised during power operation because the safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure. Valves 8949A and 89498 cannot be exercised during power operation because the residual heat removal or safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure. These valves cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by Technical Specification Surveillance Requirement 4.5.3.2 to protect against a low temperature-overpressurization of the reactor coolant system. Valves 8949A and 89498 cannot be exercised during cold shutdown using the residual heat removal pumps because this would result in short circuiting the core and not removing decay heat properly. These valves will be full-stroke exercised during refueling outages.
3.6.3.4.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8949A, 8949B, 8949C, and 89490. The only available flow path to exercise these valves is into the reactor coolant system. The utility has demonstrated that these valves cannot be exercised during power operation because the safety injection pumps or residual heat removal pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. Utilizing the l
safety injection pumps to exercise these valves during cold shutdowns could result in a low temperature-overpressurization of the reactor coolant system because a sufficient expansion volume may not exist to accommodate the flow required. Also, during cold shutdowns valves 8949A and 8949B cannot be exer-cised with the residual heat removal pumps since this would result in short circuiting the core and not removing decay heat properly.
12/04/84 3-28 Diablo Canyon 1 Pump and Valve SER
3.6.3.4.4 Conclusion We conclude that full-stroke exercising these valves can only be accomplished during refueling outages when t'he' reactor vessel head is removed to provide an adequate expansion volume and this alternate testing should be sufficient to
. demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common' defense and security of the public.
3.6.3.5 Relief Request The utility has requested specific relief from exercising valve 8977, check valve from the refueling water storage tank to the suction of the safety injection pumps, in accordance with the requirements of Section XI and proposed partial-stroke exercising this valve quarterly and full-stroke exercising it during refueling outages.
3.6.3.5.1 Code Requirement Refer to Appendix A.
3.6.3.5.2 Utility's Basis for Requesting Relief This valve can only be partial-stroke exercised during power operation.
It cannot be full-stroke exercised because the safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure. This valve cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by Technical Specification Surveillance Requirement 4.5.3.2 to protect against a low temperature-overpressurization of the reactor coolant system. This valve will be full-stroke exercised during refueling outages.
11/02/84 3-29 Diablo Can3on 1 Pump and Valve SER
3.6.3.5.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be
. granted from the exercising-requirements of Section XI for valve 8977. The utility has demonstrated that this valve cannot be full-stroke exercised during power operation since the only available full flow path is into the reactor coolant system and the safety injection pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure during power operation. This valve cannot be exercised during cold shutdowns since the safety injection pumps are required to be inoperable to protect against a low temperature-overpressurization of the reactor coolant system.
4 3.6.3.5.4 Conclusion l
We conclude that partial-stroke exercising this valve quarterly and full-stroke exercising it during refueling outages should demonstrate proper valve operability.
l Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended I
by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
i 3.6.3.6 Relief Request The utility has requested specific relief from exercising valve 8981, check i
valve from the refueling water storage tank to the suction of the residual
]
heat removal pumps, in accordance with the requirements of Section XI and proposed full-stroke exercising this valve during refueling outages.
1 3.6.3.6.1 Code Requirement Refer to Appendix A.
I i
i 11/02/84 3-30 Diablo Canyon 1 Pump and Valve SER l
9 3.6.3.6.2 Utility's Basis for Requesting Relief This valve cannot be exercised during power operation because the residual heat removal pumps do not develop sufficient head to over come reactor coolant system pressure.
4 This valve cannot be exercised during cold shutdown because both residual heat removal pumps must be aligned to remove decay heat from the reactor coolant system so no path exists for full-stroke exercising this valve. This valve will be full-stroke exercised during refueling outages.
3.6.3.6.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve 8981. The utility has demonstrated that this valve cannot be exercised during power operation because the only available flow path is into the reactor coolant system and the residual heat removal pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure during power operation.
During cold shutdowns, the residual heat removal pumps are aligned to remove decay heat from the reactor coolant system, so no flow path is available for exercising this valve.
3.6.3.6.4 Conclusion We conclude that full-stroke exercising this valve during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.7 Residual Heat Removal System 3.7.1 Category B Valves 11/02/84 3-31 Diablo Canyon 1 Pump and Valve SER
3.7.1.1 Relief Request The utility has requested specific relief from measuring the stroke times of valves HCV-637 and HCV-638, residual heat removal heat exchangers outlet isolation valves, in accordance with the requirements of Section XI and proposed observing that these valves operate smoothly over their full range of travel when they are full-stroke exercised quarterly.
3.7.1.1.1 Code Requirement Refer to Appendix A.
3.7.1.1.2 Utility's Basis for Requesting Relief These valves have no limiting value of full stroke time because they are remotely controlled by manual adjustment of a potentiometer. The stroke times of these valves are dependent on how fast the operator adjusts the potentio-meters that control the valves' opening and closing. These valves have no remote position indication.
i These valves will be full-stroke exercised on a quarterly frequency without measurement of stroke time. This exercise will include observation of smooth operation of the valves over their full range of travel.
3.7.1.1.3 Evaluation We do not agree with the utility's basis and, therefore, feel that relief 4
should not be granted from measuring stroke times of valves HCV-637 and HCV-638 in accordance with the requirements of Section XI. We consider the stroke timing requirements of the code a valuable inservice testing tool to assist in identifying unacceptable value degradation or improper adjustments, packing overtightness, torque switch settings etc., prior to complete failure of a valve assembly to perform its required function under system challenging i
conditions.
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12/04/84 3-32 Diablo Canyon 1 Pump and Valve SER
3.7.1.1.4 Conclusion We conclude that the proposed alternate testing method of observing that these valves operate smoothly'over their full range of travel when they are full-stroke exercised quarterly without measurement of stroke time will not assist in identifying unacceptable valve degradation. Based on the considerations discussed above, we conclude that the alternate testing proposed will not give reasonable assurance of valve operability intended by the Code and that relief should not be granted from the measurement of stroke time for these valves.
3.7.2 Category C Valves 0
3.7.2.1 Relief Request The utility has requested specific relief from exercising valves 8740A and 87408, residual heat removal to reactor coolant system hot legs check valves, in accordance with the requirements of Section XI and proposed full-stroke exer-cising these valves during refueling outages.
3.7.2.1.1 Code Requirement Refer to Appendix A.
3.7.2.1.2 Utility's Basis for Requesting Relief
. These valves cannot be exercised during power operation because the residual heat removal pumps do not develop sufficient head to overcome reactor coolant I
system pressure.
l These valves cannot be exercised during cold shutdown because this would result in short circuiting the core, thereby not removing decay heat.
These valves will be full-stroke exercised during refueling outages.
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3.7.2.'1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 8740A and 87408.
The only available flow path for exercising these valves is into the reactor coolant system and during power operation, the residual heat removal pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. During cold shutdowns, exercising these valves could result in short circuiting the core and not adequately removing decay heat, since the residual heat removal system would be taking a suction from the reactor coolant system hot legs and discharging to the reactor coolant system hot legs.
3.7.2.1.4 Conclusion We conclude that full-stroke exercising these valves during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense l
and security of the public.
3.8 Containment Spray System 3.8.1 Category A/C Valves 3.8.1.1 Relief Request i
j The utility has requested specific relief from cxercising valves 9011A and 9011B, containment spray headers inside containment isolation check valves, in accor-dance with the requirements of Section XI and proposed disassembling these valves and inspecting the internals to demonstrato proper operability at a frequency of at least once per five years.
3.8.1.1.1 Code Requirement Refer to Appendix A.
12/04/84 3-34 Diablo Canyon 1 Pump and Valve SER
3.8.1.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation, at cold shutdown, or during refueling outages because flow through these valves would result in spraying down the containment. This would cause problems with wet lagging, corrosion of components inside containment, etc. The only practical. method of verifying operability of these check valves is by disassembly.
These valves will be disassembled and internally inspected (mechanical exercise) to verify operability. This inspection will be performed at a frequency of at least once per five years.
3.8.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves 9011A and 90118.
With the present system configuration, exercising these valves with flow would result in spraying down the containment, which would cause problems with wet lagging, corrosion of components inside containment, etc. As an alternate means of full-stroke exercising these valves, the utility has proposed disassem-bling them to verify operability at a five year interval. We feel that disassembly of these valves to verify proper operability is an acceptable alternate testing method, however, we cannot currently justify any inspection interval longer than each refueling outage.
3.8.1.1.4 Conclusion We conclude that disassembling these valves and inspecting the internals should demonstrate proper operabi'lity. However, we cannot currently justify any inspection interval longer than each refueling outage.
3.8.2 Category B Valves 11/02/84 3-35 Ofablo Canyon 1 Pump and Valve SER
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3.8.2.1' Relief Request l
- i The utility has requested specific relief from exercising valves 9003A and 9003B, isolation valves from the residual heat removal system to the containment spray headers, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
'U 3.8.2.1.1 Code Requirement f
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j Refer to Appendix A.
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3.8.2.1.2 Utility's Basis for Requesting Relief These valves cannot be exercised during power operation because they are
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interlocked with valves 8982A and 89828 (containment sump isolation valves) that are required to be closed with power to the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
Valves 8982A or 89828 cannot be opened during power operation because this-would result in one train of the residual heat removal system being not operable. < Valve 8982A or 89828 cannot be opened during cold shutdown because they are interlocked with valves 8700A and 8700B (residual heat removal pump suction valves) which would have e
to be closed. With valve 8982A or 89828 opened in this config't; ration, it is quitelikelythatwaterfromthepipingbe'tweenvalve8700Aod87008andthe sump valve connection will be discoarged through valve 8982A or 89828 into the containment sump. This water will interfere with the reactor coolant system sump level / flow leakage detection system and void the suction piping requiring refilling and venting the piping. If a LOCA occurred under this condition,
/.i extensive time would be required to recover from this very abnormal lineup.
Also, during cold shutdown valves 9003A and 90038 cannot be exerci' sed open i
because they are interlocked with valves 8701 and 8702 (reactor coolant system loop four to residual heat removal' system isolation valves) in the closed position. 8701 and 8702 are required to be open and closing one of these e
valves would result in both residual heat removal trains being incapable of f
removing decay heat from the core. Valves 9003A and 9003B will be full-stroke exercised during refueling outagds.
11/02/84 3-36 Diablo Canyon 1 Pump and Valve SER 4
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'I 3.8.2.1.3 Evaluation
' 'We agree with the utility's basis and, therefore, feel that relief should be
, granted from the exercising requirements of Section XI for valves 9003A and 9003B.
f Q The utility has demonstrated that, due to system interlocks, exercising these s
kivesduringpowercperationwouldrequireremovingonetrainoftheresidual heat removal system from operation for an extensive time. To exercise these
. valves at power operation, the utility would have to shut one of the residual heat removal pump suction valves (8700A or 87008) and open the associated
,,( conta nment sump isolation valve (8982A or 89828) which could result in draining i
'4. water from the residual heat removal system piping into cht. containment sump.
I If this condition occurred, the utility would require an extensive amount of time to refill and vent the associated piping. During cold shutdowns, these i
valves cannot be exercised because this would require closing valves 8701 h(
and 8702, due to interlocks, which would result in both trains of the residual heat removal system being unavailable for removal of decay heat from the core.
3.8.2.1.4 Conclusion We conclude that full-stroke exercising these valves during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.8.3 Category C Valves 3.8.3.1 Relief Request The utility has requested specific relief from exercising valves 9002A and 90028, j
i containment spray pumps discharge check valves, in accordance with the require-ments of Section XI and proposed full-stroke exercising these valves during 1
refueling outages.
11/02/84 3-37 Diablo Canyon 1 Pump and Valve SER
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3.8.3.1.1 Code Requirement
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1 Refer to Appendix A.
?
3.8.3.1.2 Utility's Basis for Requesting Relief i
'A These valves cannot be exercised during power operation because the system alignment for testing them would result in one train of the containment spray system being not operable. These valves cannot be exercised during cold shutdown because the system alignment for testing would result in one tYain of the residual heat removal system being not operable. During cold shutdown, both residual heat removal trains must be aligned to remove decay heat from I
These valves will be full-stroke exercised during refueling outages.
3.8.3.1.3 Evaluation l
We agree with the utility's basis and, therefore, feel that relief should be i
granted from the exercising requirements of Section XI for valves 9002A and 90028.
l These valves cannot be exercised with flow via the containment spray headers because this would result in spraying containment, which would cadse problems with wet lagging, corrosion of components inside containment, etc. Exercising these valves via the flow path through valves 9003A or 9003B would result in one train of the containment spray system being not operable. Also, this flow I
path cannot be utilized since valves 9003A and 9003B cannot be exercised except during refueling outages. Refer to Section 3.8.2 of this report for the technical justification for not exercising valves 9003A and 9003B during power j
operation or cold shutdowns.
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3.8.3.1.4 Conclusion Q
l We conclude that full-stroke exercising these valves during refueling outages should demonstrate proper vilve operability. Based on the considerations discusseo above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the 4
11/02/84' 3-38 Jiablo Canyon 1 Pump and Valve SER l
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relief thus granted will not endanger life or property or the common defense and security of the public.
- 3. 9 Component Coolina Water System 3.9.1 Category A/C Valves
- 3. 9.1.1 Relief Request The utility has requested specific relief from exercising valves CCW-585 and CCW-695, containment isolation check valves in the supply lines to the reactor coolant pumps thermal barriers and bearing oil coolers (CCW-585) and the excess letdown heat exchanger (CCW-695), in accordance with the requirements of Section XI and proposed verifying closure of these valves, their safety position, at a two year interval when they are leak-rate tested.
3.9.1.1.1 Code Requirement Refer to Appendix A.
3.9.1.1.2 Utility's Basis for Requesting Relief These check valves can only be verified closed by leak-rate testing. They j
will be leak-rate tested at a two year interval.
3.9.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the excercising requirements of Section XI for valves CCW-585 ano CCW-695. The utility has demonstrated that, due to plant design, the only method available to verify valve closure, the safety position, is leak-rate j
testing. These valves are not equtpped with valve position indication and some of the requ' fred test connections are located inside containment.
11/02/84 3-39 Diablo Canyon 1 Pump and Valve SER
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3.9.1.1.4 Conclusion We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.10 Liquid Radwaste System 3.10.1 Category A/C Valves 3.10.1.1 Relief Request The utility has requested specific relief from exercising valve LWS-60, inside containment isolation check valve in the nitrogen supply line to the reactor coolant drain line, in accordance with the requirements of Section XI and proposed verifying closure of this valve, the safety position, at a two-year interval when it is leak-rate tested.
3.10.1.1.1 Code Requiremert Refer to Appendix A.
3.10.1.1.2 Utility's Basis for Requesting Relief This check val **e can only be verified closed by leak-rate testing.
It will be leak-rate tested at a two year interval.
3.10.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve LWS-60. The l
utility has demonstrated that, due to plant design, the only method available 11/02/84 3-40 Diablo Canyon 1 Pump and Valve SER
to verify valve closure, the safety position, is leak-rate testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.
- 3.10.1.1.4 Conclusion We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two-year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.11 Diesel Generator System 3.11.1 Category B Valves 3.11.1.1 Relief Request The utility has indicated in their IST program that valves LCV-85, LCV-86, LCV-87, LCV-88, LCV-89, and LCV-90, isolation valves in the diesel fuel oil day tanks supply lines, will be full-stroke exercised at a cold shutdown d
frequency rather than at a quarterly frequency.
i 3.11.1.1.1 Code Requirement Refer to Appendix A.
3.11.1.1.2 Utility's Basis for Requesting Relief The utility has provided no technical justification for not full-stroke exercising these valves quarterly.
11/02/84 3-41 Diablo Canyon 1 Pump and Valve SER
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3.11.k.1.3 Evaluation I
We feel-that1these valves can be full-stroke exercised quarterly and, therefore, we recommend that relief not be granted to exercise these valves at a cold shutdown frequency.
3.11.1.1.4 Conclusion We conclude that the utility should full-stroke exercise these valves, quarterly, in accordance with the requirements of Section XI of the ASME Code.
3.12 Ventilation and Air Conditioning System 3.12.1 Category A Valves 3.12.1.1 Relief Request The utility has requested specific relief from exercising valves FCV-660, FCV-661, FCV-662, FCV-663, FCV-664, RCV-11, and RCV-12, containment ventilation isolation valves, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves during refueling outages.
3.12.1.1.1 Code Requirement Refer to Appendix A.
3.12.1.1.2 Utility's Basis for Requesting Relief These valves are required to be leak-rate tested every time they are exercised per Technical Specification 3.6.1.7 and 3.6.3.
Therefore, these valves will be full-stroke exercised every 18 months when they are required to be exercised per Technical Specification Surveillance Requirement 4.6.3.2.c.
Also, these valves are limited by Technical Specification 3.6.1.7 to be open less than or equal to 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per 365 days.
11/02/84 3-42 Diablo Canyon 1 Pump and Valve SER
3.12.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves FCV-660, FCV-661, FCV-662, FCV-663, FCV-664, RCV-11, and RCV-12. During power operation, these valves should remain closed to maintain containment integrity. During cold shutdowns, exercising these valves would result in requiring the utility to leak-rate test them, due to Technical Specification requirements, which could result in delaying the startup from the cold shutdown condition.
3.12.1.1.4 Conclusion We conclude that full-stroke exercising _these valves during refueling outages should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus' granted will not endanger life or property or the common defense and security of the public.
3.12.2 Category A/C Valves 3.12.2.1 Relief Request The utility has requested specific relief from exercising valves VAC-252 and VAC-253, inside containment isolation check valves in the return lines of the hydrogen monitors, in accordance with the requirements of Section XI and proposed full-stroke exercising these valves open during cold shutdowns and verifying valve closure at a two year interval when they are leak-rate tested.
3.12.2.1.1 Code Requirement Refer to Appendix A.
11/02/84 3-43 Diablo Canyon 1 Pump and Valve SER
3.12.'2.1.2 Utility's Basis for Requesting Relief The utility's Cold Shutdown Testing Statement No. 27 of the IST program submittal states, "These Containment Sample Isolation Valves cannot be exercised during power operation because Technical Specification Surveillance Requirement 4.6.1.la requires these valves to be closed when containment integrity is requireo, except under strict administrative control. These valves do not receive a containment isolation signal."
The utility's Request for Relief from Code Requirement No. 3 of the IST program submittal states, "These check valves can only be verified closed by leak-rate testing. They will be leak-rate tested at a two year interval."
3.12.2.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valves VAC-252 and VAC-253. These valves cannot be exercised open during power operation since the upstream containment isolation valves, FCV-237 and FCV-240, are requireo to be closed by Technical Specification Surveillance Requirement 4.6.1.la to maintain containment integrity since they do not receive.a containment isolation signal. Closure of these valves cannot be verified during power operation or cold shutdown since, due to plant design, the only method available-to verify valve closure is leak-rate testing. Leak-rate testing cannot be performed during power operation since some of the required test connections are located inside containment. Performing valve leak-rate testing during cold shutdowns could result in delaying the startup from the cold shutdown condition.
3.12.2.1.4 Conclusion i
1 We conclude that full-stroke exercising these valves open during cold shutdowns and verifying valve closure during the performance of leak-rate testing at two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and 12/04/84 3-44 Diablo Canyon 1 Pump and Valve SER
that the relief thus granted will not endanger life or property or the common defense and security of the public.
3.12.2.2 Relief Request Tha utility has requested specific relief from exercising valve VAC-21, inside containment isolation check valve in the containment air sample return line, in accordance with the requirements of Section XI and proposed verifying closure of this valve, the safety position, at a two year interval when it is leak-rate tested.
3.12.2.2.1 Code Requirement Refer to Appendix A.
3.12.2.2.2 Utility's Basis for Requesting Relief This check valve can only be verified closed by leak-rate testing.
It will be leak-rate tested at a two year interval.
3.12.2.2.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for valve VAC-21. The utility has demonstrated that, due to plant design, the only method available to verify valve closure, the safety position, is leak-rate testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.
3.12.2.2.4 Conclusion We conclude that the proposed altemate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing preposed will give reasonable assurance of valve operability intended by the Code and that the relief thus 11/02/84 3-45 Diablo Canyon 1 Pump and Valve SER
granted will not endanger life or property or the common defense and security of the public.
3:12.2.3 Relief Request The utility has requested specific relief from exercising valve VAC-116, inside containment isolation check valve in the containment air sample post-LOCA return line, in accordance with the requirements of Section XI and proposed verifying closure of this valve at a two year interval when it is leak-rate tested.
3.12.2.3.1 Code Requirement Refer to Appendix A.
3.12.2.3.2 Utility's Basis for Requesting Relief This check valve can only be verified closed by leak-rate testing.
It will be leak-rate tested at a two year interval.
3.12.2.3.3 Evaluation We agree with the utility's basis for verifying valve closure at a two year interval when this valve is leak-rate tested. The utility has demonstrated that, due to plant design, the only method available to verify valve closure is leak-rate testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.
However, we feel that this valve also performs a safety-function in the open position. The utility has not addressed exercising this valve to the full ope.n position in their IST program. Therefore, we feel that relief should be granted from the exercising requirements of Section XI for valve VAC-116 p
provided the valve is exercised to the full open position during the containment leak rate test.
11/02/84 3-46 Diablo Canyon 1 Pump and Valve SER
3.12.2.3.4 Conclusion We conclude that the utility should verify closure of this valve at a two year interval when it is leak-rate tested and also full-stroke exercise this valve to the full open position during the containment leak rate test.
3.13 Compressed Air Systems 3.13.1 Category A/C Valves 3.13.1.1 Relief Request The utility has requested specific relief from exercising valve AIR-I-587, inside containment isolation check valve in the instrument air supply line, in I
accordance with the requirements of Section XI and proposed verifying closure of this valve, the safety position, at a two-year interval when it is leak-rate tested.
3.13.1.1.1 Code Requirement Refer to Appendix A.
3.13.1.1.2 Utility's Basis for Requesting Relief This check valve can only be verified closed by leak-rate testing. It will be leak-rate tested at a two year interval.
3.13.1.1.3 Evaluation We agree with the utility's basis and, therefore, feel that relief should be
' granted from the exercising requirements of Section XI for valve AIR-I-587.
The utility has demonstrated that, due to plant design, the only method available to verify valve closure, the safety position, is leak-rate testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.
12/04/84 3-47 Diablo Canyon 1 Pump and Valve SER
3.13.1.1.4 Conclusion We conclude that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at a two year interval should demonstrate proper valve operability. Based on the considerations discussed above, we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or'the common defense and security of the public.
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APPENDIX A 1.
CODE REQUIREMENTS--VALVES Subsection IWV-3411 of the 1977 Edition of the Section XI ASME Code (which discusses full-stroke and partial-stroke requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3412(a), IWV-3415, and IWV-3416. IWV-3521 (which discusses full-stroke and partial-stroke requirements) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3522. In the above exceptions, the Co'de permits the valves be tested at cold shutdown where:
1.
It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
2.
It is not practical to observe the operation of the valves (with failsafe actuators) upon loss of actuator power.
Subsection IWV-3413 requires all Category A and B power-operated valves to be stroke-time tested to the nearest-second or 107. of the maximum allowable Owner-specified time.
2.
CODE REQUIREMENTS--PUMPS An inservice test shall be conducted on all pumps that perform a function important to safety, nominally once each month during normal plant operation.
Each inservice-test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
12/05/84 1
DIABLO CANYON 55ER 1 APP A
ATTACHMENT 1 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 valves are specifically identified by the Owner and are full-stroke exercised during cold shutdowns and refueling outages. The NRC staff has reviewed all valves in this attachment and agrees with the utility that testing these valves during power operation is not practical, due to the valve type and location or system design. We feel that these valves 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.
MAIN AND AUXILIARY FEEDWATER SYSTEM 1.1 Category 8 Valves FCV-438, FCV-439, FCV-440, and FCV-441, main feedwater isolation valves, cannot be exercised during power operation since closure of these valves would result in securing feedwater flow to the associated steam generator which could result in a reactor trip. Three loop operation has not been analyzed and is not allowed. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
1.2 Category C Valves FW-96, FW-98, FW-367, and FW-368, main feedwater check valves, cannot be exercised during power operation since closure of these valves would result in securing feedwater flow to the associated steam generator which could result in a reactor trip. Three loop operation has not been analyzed and is not allowed. These valves will be verified closed during cold shutdowns and refueling outages.
12/04/84 1
Diablo Canyon 1 Pump and Valve SER
FW-348, FW-350, and FW-352, auxiliary feedwater pumps suction check valves from the condensate storage tank, cannot be full-stroke exercised during power operation because the only available full flow path is into the steam generators
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which could result in thermal shock to the associated piping and fittings.
These valves will be partial-stroke exercised quarterly and full-stroke exercised at a cold shutdown frequency.
FW-361, FW-362, and FW-363, auxiliary feedwater pumps discharge check valves, cannot be full-stroke exercised during power operation because the only available full flow path is into the steam generators which could result in thermal shock to the associated piping and fittings. These valves will be partial-stroke exercised quarterly and full-stroke exercised at a cold shutdown frequency.
FW-369, FW-370, FW-371, FW-372, FW-373, FW-374, FW-375, FW-376, FW-377, FW-378, FW-379, and FW-380, check valves from the auxiliary feedwater pumps to the steam generators, cannot be full-stroke exercised during power operation because the only available full flow path is into the steam generators which could result in thermal shock to the associated piping and fittings. These valves will be partial-stroke exercised quarterly and full-stroke exercised at a cold shutdown frequency.
2.
TURBINE STEAM SUPPLY SYSTEM 2.1 Category B Valves FCV-41, FCV-42, FCV-43, and FCV-44, main steam isolation valves, cannot be full-stroke exercised during power operation since closure of these valves l
would result in securing steam flow from the associated steam generator which coula result in a reactor trip. Three loop operation has not been analyzed and is not allowed. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages.
PCV-19, PCV-20, PCV-21, and PCV-22, main steam atmospheric dump valves, cannot be exercised during power operation because this could result in an inadvertent safety injection actuation. These valves will be full-stroke xercised during cold shutdowns and refueling outages.
11/02/84 2
Diablo Canyon 1 Pump and Valve SER
4 3.
REACTOR COOLANT SYSTEM 3.1 Category B Valves PCV-455C, PCV-456, and PCV-474, pressurizer power operated relief valves, should not be exercised during power operation since the NRC staff position'is that these valves be exercised at a cold shutdown frequency. These valves will be full-stroke exercised during the approach.to cold shutdown.
8078A, 80788, 8078C, and 80780, reactor vessel head vents, should not be exercised during power operation since the NRC staff position is that these valves be exercised at a cold shutdown frequency. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
4.
CHEMICAL AND VOLUME CONTROL SYSTEM 4.1 Category A Valves t
8100 and 8112, reactor coolant pump seal water return containment isolation valves, cannot be exercised during power operation because this would result in challenging the relief valve in the reactor coolant pump seal water return-line. If the relief valve failed in the open position, this would result in unnecessary reactor coolant system leakage. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8152, letdown line isolation valve, cannot be exercised during power operation because failure of this valve in the closed position could result in a loss of reactor coolant system level control which could result in a-plant shutdown.
This valve will be full-stroke exercised during cold shutdowns and refueling outages.
4. 2.
Category B Valves LCV-1128'and LCV-112C, volume control tank outlet isolation valves, cannot be exercised during power operation because failure of either valve in the closed position would result in a loss of reactor coolant system level control or 3
injecting 2000 ppm boric acid solution from the refueling water storage tank into the reactor coolant system, resulting in a possible plant shutdown.
These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8105 and 8106, centrifugal charing pump recirculation line isolation valves, cannot be exercised during power operation because failure of either valve in the closed position could result in pump damage if a secondary system accident occurred. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8107 and 8108, charging header isolation valves, cannot be exercised during power operation because failure of either valve in the closed. position could result in loss of reactor coolant system level control, which could result in a plant shutdown. Also, failure of either of these valves in the closed position would place the plant in an LCO action statement due to a loss of the boration flow path from the boric acid tanks. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8145 and 8148, pressurizer auxiliary spray line control valve and bypass valve, cannot be exercised during power operation because failure of either valve in the open position could result in a loss of reactor coolant system pressure control which could result in a plant shutdown. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
4.3 Category C Valves 8377, pressurizer auxiliary spray line check valve, cannot be exercised during power operation because the upstream isolation and bypass valves (8145 and 8148) cannot be exercised during power operation. Refer to Section 4.2 of this attachment for the justification for not exercising valves 8145 and 8148 during power operation. This valve will be full-stroke exercised during cold shutdowns and refueling outages.
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Diablo Canyon 1 Pump and Valve SER
5.
SAFETY INJECTION SYSTEM 5.1 Category A/C Valves 8818A, 88188, 8818C, and 88180, residual heat removal to cold legs check valves, cannot be exercised during power operation because the residual heat removal pumps do_not develop sufficient head to overcome reactor coolant system pressure. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
5.2 Category B Valves 8802A and 8802B, safety injection pumps discharge isolation valves, cannot be exercised during power operation because they are required to be closed with power to the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
If these valves were opened during power operation, safety injection flow would go to the hot legs instead of the cold legs. The safety analysis was performed for flow going to the cold legs and not the hot legs.
These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8808A, 88088, 8808C, and 88080, safety injection accumulators discharge isolation valves, cannot be exercised during power operation because they are required to be open by Technical Specification Limiting Condition for Operation 3.5.1.
Also, the safety analysis does not cover one accumulator being isolated and a failure in another accumulator line. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8809A and 88098, residual heat removal to cold legs isolation valves, cannot be exercised during power operation because they are required to be open with power to the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
These valves will be full-stroke exercised during cold shutdowns and refueling outages.
)
8835, safety injection to cold legs isolation valve, cannot be exercised i
during power operation because it is required to be open with power to the 11/02/84 5
Diablo Canyon 1 Pump and Valve SER
valve operator removed by Technical Specification Surveillance Requirement 4.5.2.
Also, failure of this valve in the closed position would result in the entire safety injection system being not operable. This va' n will be full-stroke exercised during cold shutdowns and refueling outages.
8974A and 89748, safety injection pumps recirculation line isolation valves, cannot be exercised during power operation because they are required to be open with power to the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
Also, failure of either valve in the closed position could result in damage to the safety injection pumps, which would render the entire safety injection system not operable. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8976, safety injection pumps suction isolation valve from the refueling water storage tank, cannot be exercised during power operation because it is required to be open with power to the valve operator removed by Technical Specification Surveillance Requirement 4.5.2.
Also, failure of this valve in the closed position would result in the entire safety injection system being not operable.
This valve will be full-stroke exercised during cold shutdowns and refueling outages.
8980, residual heat removal pumps suction isolation valve from the refueling water storage tank, cannot be exercised during power operation because it is required to be open with power to the valve operator removed by Technical Specification Surveillance Requirement 4.5.2.
Also, failure of this valve in the closed position would result in the entire residual heat removal system being not operable. This valve will be full-stroke exercised during cold shutdowns and refueling outages.
6.
RESIDUAL HEAT REMOVAL SYSTEM 6.1 Category A Valves 8701 and 8702, isolation valves from the reactor coolant system loop four hot leg to the suction of the residual heat removal pumps, cannot be exercised during power operation because they are required to be closed with power to 11/02/84 6
Diablo Canyon 1 Pump and Valve SER
the valve operators removed by Technical Specification Surveillance Requirement 4.5.2.
Also, these valves are interlocked with reactor coolant system pressure and cannot be opened if the pressure is greater than 390 psi.
-These valves will be full-stroke exercised during cold shutdowns and refueling outages.
6.2 Category B Valves 8703, residual heat removal to the reactor coolant system hot legs isolation valve, cannot be exercised during power operation be cause it is required to be closed with power to the valve operator removed by Technical Specification Surveillance Requirement 4.5.2.
Also, failure of this valve in the open position would result in diversion of flow from the analyzed flow paths. This valve will be full-stroke exercised during cold shutdowns and refueling outages.
6.3 Category C Valves 8730A and 8730B, residual heat removal pumps discharge check valves, cannot be full-stroke exercised during power operation since the only available full flow path is into the reactor coolant system and the residual heat removal pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages.
7.
CONTAINMENT SPRAY SYSTEM 7.1 Category B Valves 8994A and 8994B, Na0H to containment spray educators isolation valves, cannot be exercised during power operation because exercising them could introduce NaOH into the refueling water storage tank and subsequently into the reactor coolant system causing NaOH activation problems and possible chemical damage to components in the reactor coolant system. To prevent getting NaOH into the refueling water storage tank, valve 8992 would have to be closed and the line flushed, which would result in the entire spray additive system being not 12/04/84 7
Diablo Canyon 1 Pump and Valve SER l
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operable. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
7.2 Category C Valves 8998A and 8998B, NaOH to containment spray educators check valves, cannot be exercised during power operation because the system alignment for testing these check valves would result in the entire spray additive system being not operable. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
8.
COMPONENT COOLING WATER SYSTEM 8.1 Category A Valves FCV-356, outside containment isolation valve in the supply line to the reactor coolant pumps thermal barriers and bearing oil coolers, cannot be exercised during power operation because exercising this valve could result in damage to the reactor coolant pumps and a possible plant trip. This valve will be full-stroke exercised during cold shutdowns and refueling outages.
FCV-750 and FCV-357, inside and outside containment isolation valves in the return line from the reactor coolant pumps thermal barriers, cannot be exercised during power operation because exercising these valves could result in damage to the reactor coolant pumps and a possible plant trip. These valves will be full-stroke exercised during cold shutdowns and refueling outages..
FCV-749 and FCV-363, inside and outside containment isolation valves in the return line from the reactor coolant pumps bearing oil coolers, cannot be exercised during power operation because exercising these valves could result in damage to the reactor coolant pumps and a possible plant trip. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
11/02/84 8
Diablo Canyon 1 Pump and Valve SER
7 8.2 Category B Valves
-FCV-355, component cooling water supply header "C" isolation valve, cannot be exercised during power operation because this is the header which supplies water to the reactor coolant pumps thermal barriers and bearing oil coolers.
Exercising this valve during power operation could result in damage to the reactor coolant pumps and a possible plant trip. This valve will be full-stroke exercised during cold shutdowns and refueling outages.
9.
VENTILATION AND AIR CONDITIONING SYSTEM 9.1 Category A Valves FCV-658, FCV-659, FCV-668, and FCV-669, inside and outside containment isolation valves in the lines to the containment external hydrogen recombiners, cannot be exercised during power operation because Technical Specification Surveillance Requirement 4.6.1.la requires these valves to be closed when containment integrity is required, except under strict administrative control. Also, these valves do not receive a containment isolation signal. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
FCV-235, FCV-236, FCV-237, FCV-238, FCV-239, and FCV-240, inside and outside containment isolation valves in the supply and return lines'of the hydrogen monitors, cannot be exercised during power operation because Technical Specifi-cation Surveillance Requirement 4.6.1.la requires these valves to be closed when containment integrity is required, except under strict administrative control. Also, these valves do not receive a containment isolation signal.
These valves will be full-stroke exercised during cold shutdowns and refueling outages.
4 FCV-6 98, FCV-699, and FCV-700, inside and outside containment isolation valves in the containment air sample post-LOCA supply and return lines, cannot be exercised during power operation because Technical Specification Surveillance Requiremer,t 4.6.1.la requires these valves to be closed when containment integrity is required, except under strict administrative control.
11/02/84 9
Diablo Canyon 1 Pump and Valve SER
Also, these valves do not receive a containment isolation signal. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
10.
LIQUID RADWASTE SYSTEM 10.1 Category A Valves FCV-696 and FCV-697, inside and outside containment isolation valves in the reactor cavity sump sampling supply line, cannot be exercised during power operation because Technical Specification Surveillance Requirement 4.6.1.la requires these valves to be closed when containment integrity is required, except under strict administrative control. Also, these valves do not receive a containment isolation signal. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
f 11/02/84 10 Diablo Canyon 1 Pump and Valve SER 4
ATTACHMENT 2 The P& ids listed below were used during the course of this review.
'1 System P&ID Revision Feedwater System 102003-4 9
Turbine Steam Supply System 102004-3 9
102004-5 10 102004-7 10 Auxiliary Steam System 102006-4 8
Reactor Coolant System 102007-4 9
102007-7 9
Chemical and Volume Control System 102008-3 9
102008-4 9
102008-4B 9
102008-5B 9
Safety Injection System 102009-3 7
102009-4 7
102009-5 5
Residual Heat Removal System 102010-3 6
Nuclear Steam Supply Sampling System 100211-2 8
Containment Spray System 102012-3 7
Component Cooling Water System 102014-5 11 102014-6 10 102014-7 10 102014-9 10 102014-10 10 Makeup Water System 102016-7 10 Salt Water Systems 102017-3 10 Fire Protection System 102018-7 6
Liquid Radwaste System 102019-3 7
Diesel Generator System 102021-2 11 102021-3 11 11/02/84 11 Diablo Canyon 1 Pump and Valve SER
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System P&ID Revision Ventilation and Air Conditoning System 102023-4A~
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102023-11 9
102023-13 9
i-i Compressed Air Systems 102025-4 8
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