ML20214Q773

Ser:Pump & Valve Inservice Testing Program,Crystal River Nuclear Power Station,Unit 3,for Remainder of First 10-Yr Interval

ML20214Q773
Person / Time
Site:	Crystal River
Issue date:	05/29/1987
From:	NRC
To:
Shared Package
ML20214Q770	List: ML20214Q766 ML20214Q773
References
NUDOCS 8706050174
Download: ML20214Q773 (48)

Text

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ENCLOSURE 1 SAFETY EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM CRYSTAL RIVER NUCLEAR POWER STATION, UNIT 3 FOR THE REMAINDER OF THE FIRST 10-YEAR INTERVAL l

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ACKNOWLEDGEMENT l

This safety evaluation report was prepared with substantial assistance from the Idaho National Engineering Laboratory (EG&G Idaho, Inc.) under contract to the U.S. Nuclear Regulatory Connission.

i 8706050174 870529 ~

fDR ADOCK 05000302 PDR

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l CONTENTS ,

1. INTRODUCTION ...................................................... 1

2. PUMP TESTING PROGRAM .............................................. 2 2.1 Generic Relief Requests ...................................... 2 2.2 Pump P re s s u re Me a su reme nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.3 Flow Pate Measurements ....................................... 5 2.4 V i b ra t i o n Me a s u reme n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3. VALVE TESTING PROGRAM ............................................. 8 3.1 General Considerations ....................................... 8 3.1.1 Full-Stroke Exercising of Check Valves ................ 8 3.1.2 Valves Identified for Cold Shutdown Exercising ........ 8 3.1.3 Conditions for Valve Testing During Cold Shutdowns ................... ......................... 9 3.1.4 Category A Valve Leak Test Re uirements for Containment Isolation Valves CIVs) ................... 9 3.1.5 Application of Appendix J Testing to the IST P r og ra m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.1.6 Safety-Related Valves ................................. 9 3.1.7 Active Valves ......................................... 10 3.1.8 Rapid-Acting Powe r Operated Valves . . . . . . . . . . . . . . . . . . . . 10 3.1.9 Valves Which Perform a Pressure Boundary ..............

Isolation Function .................................... 10 3.1.10 Pressurizer Power Operated Relief Valves ... . . .... .. . . . 11 3.2 Generic Relief Requests ...................................... 12 3.2.1 Category A and B Valves ............................... 12 3.3 Auxiliary Steam System ....................................... 16 3.3.1 Category B Valves ..................................... 16 3.4 Peactor Building Spray System ................................ 17 3.4.1 Category B Valves ..................................... 17 3.4.2 Ca te go ry C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 3.5 Core Flood System ............................................ 19 3.5.1 Category A/C Valves ................................... 19 3.6 Decay Heat Closed Cycle Cooling System ....................... 22 3.6.1 Category B Valves ..................................... 22  ;

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l 3.7 Decay Heat Removal System .................................... 23 3.7.1 Category B Valves ..................................... 23 3.8 Condensate and Demineralized Water Supply System ............. 26 3.8.1 Category A/C Valves ................................... 26 3.9 Fire Service System .......................................... 26 3.9.1 Category A Valves ..................................... 26 3.10 Makeup and Puri fica ti on System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27  ;

J 3.10.1 Ca te go ry A/ C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 l 3.10.2 Category B Valves ..................................... 28 3.10. 3 Catego ry C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 3.11 Spent Fuel Cool ing Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 3.11.1 Ca tego ry B Va l ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31  ;

l 3.12 Nuclear Services Closed Cycle Cooling System ................. 34 3.12.1 Category B Valves ..................................... 34 i

APPENDIX A--CODE REQUIREPENTS APPENDIX B--VALVES TESTED DURING COLD SHUTDOWNS APPENDIX C--SYSTEM P& ids LIST APPENDIX D--IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW l

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! SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PUMP AND VALVE INSERVICE TESTING PROGRAM l CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302 i

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1.0 INTRODUCTION

Contained herein is a safety evaluation of the pump and valve Inservice j Testing (IST) program submitted by. Florida Power Corporation (FPC) for its

! Crystal River, Unit 3, nuclear plant.

The licensee's submittal, dated June 1982, was received by the staff and '

! an evaluation of the program's compliance with the requirements of the

! ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, through the Sumer of 1975 Addenda, was performed. Those items not in compliance i were discussed during a working meeting with FPC representatives on March I and 2, 1983. The licensee resubmitted his program dated June 14, 1983 addressing changes resulting from the working session. The

, staff also held a second working meeting with FPC' representatives on June 7,1985 and the licensee provided an additional program resubmittal dated July 1, 1985. In the IST program submittal dated June 1982 and the June 14, 1983, and July 1,1985 resubmittals FPC has requested relief from certain ASME Code testing requirements for specific pumps and valves.

i These requests have been evaluated individually to deterinine whether they have significant risk implications and whether the tests, as required, are

indeed impractical. Required program changes, such as additional relief l j requests or the deletion of any components from the IST program, should be j i submitted to the NRC under separate cover in order to receive prompt attention; j but should not be implemented prior to review and approval by the NRC.

The IST program reviewed covers the first 10-year inspecticn interval from 4

March 13, 1977, to March 13, 1987, which is of course ended. Therefore, findings of relief granted or denied in this SER are for information only.

The second 10-year IST program, required to be submitted by March 13, 1988,

, must be based on a newer ASME Code version (1983 Edition through Sumer 1983 Addendum). The findings in this SER will be valid under the newer code version

, and should be incorporated in the second 10-year program.

'The evaluations in this Safety Evaluation Report (SER) of the Crystal River, i Unit 3, pump and valve inservice testing program and the associated relief i requests am those of the NRC staff. It should be noted that the staff will

not review requests for relief from Section XI requirements for nonsafety i related pumps and valves. These findings apply only to component testing (i.e., pumps and valves), and are not intended to provide the basis to change j the licensee's current technical specifications syJtem test requirements, such

as those for the Auxiliary Feedwater System.

i A summary of Section XI pump and valve testing requirements is provided in .

Appendix A. i f  ;

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Category A, B, and C valves that meet the requirements of the ASME Code,Section XI, but are not exercised quarterly are addressed in Appendix B.

A listing of P& ids used for this review is contained in Appendix C.

Inconsistencies and omissions in the licensee's IST program noted by the staff during the course of this review are listed in Appendix D. The staff's position is these items must be resolved in accordance with the staff's evaluations and conclusions.

2.0 pVMp TESTING PROGRAM The Crystal River Unit 3 IST program submitted by FPC is examined to verify that all safety-related pumps are included in the program and are subjected to the periodic tests required by ASME Code,Section XI. The staff's review finds that, except as noted below or where specific relief from testing has been requested, these pumps are tested to the Code requirements sumarized in Appendix A. Each FPC basis for requesting relief from the pump testing requirements and the staff's evaluation of that request is sumarized below.

2.1 Generic Relief Reouests 2.1.1 Relief Recuest l The licensee has requested relief from performing monthly inservice testing of all the listed pumps in the IST program and has proposed performing the inservice testing at a quarterly interval.

2.1.1.1 Code Requirement Refer to Appendix A.

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?.1.1.2 Licensee's Basis for Requesting Relief Subarticle IWP-3400 (Winter 1979 Addenda), Freouency of Inservice Tests, l requires an inservice test be performed every (3) months. An inservice test in accordance with subarticle IWP-3400 will be performed quarterly unless other- i wise specifically noted. The pump shall be exercised monthly to allow'an oil l film on bearings, prevention of shaft sag, bearing brinelling, liquid '

stagnation, lubrication stagnation, and prevention of seals or packing from corroding or stagnating at the rubbing interfaces.

2.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the test frequency requirements of Section XI for all pumps in the IST program. The licensee has provided sufficient technical justification for i an increase in the pump testing interval from monthly to quarterly. l 2.1.1.4 Conclusion The staff concludes that the proposed alternate of quarterly pump testing supplemented with monthly exercising will be sufficient to demonstrate proper operability of these pumps 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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l 2.2 Pump Pressure Measurements j 2.2.1 Relief Recuest The licensee has requested relief from the inlet and differential pressure )

measurements required by Section XI for the Emergency Diesel Generator Fuel Transfer pumps DFP-1A, -1B, -1C, and -1D. The utility has proposed to install the necessary instrumentation during Refuel VI (September, 1987). )

i 2.2.1.1 Code Requirement Refer to Appendix. A.

2.2.1.2 Licensee's Basis for Requestino Relief There are no pressure taps installed in the suction line/or discharge line of these pumps to measure the inlet or discharge pressures. Florida Power Corporation will install inlet and differential pressure instrumentation for the Emergency Diesel Generator Fuel Oil Transfer Pumps. The instrumentation will be installed during Refuel VI (March 1987).

2.2.1.3 Evaluation The staff acrees with the licensee's basis for relief and, therefore, interim relief should be granted from the requirements of measuring inlet pressure and differential pressure as per the Code until the licensee has installed the required instrumentation as he has proposed.

2.2.1.4 Conclusion The staff concludes that the licensee's proposal to add inlet and differential pressure instrumentation for these pumps during Refuel VI (March 1987) is reasonable and, therefore, interim relief is granted until that time to test ,

these pumps as proposed by the licensee. Requiring the licensee to make these modifications prior to the Refuel VI would impose unnecessary hardship on the '

licensee without a compensating increase in the level of safety. Taking into account the inservice tests that will be performed as well as the relatively short operational time until Refuel VI, it is concluded that this interim  :

relief will not endanger life or property or the common defense and security of '

the public.

2.2.2 . Relief Recuest The licensee has requested relief from the pump inlet pressure measuring requirements of Section XI for the Emergency Nuclear Service Seawater pumps, ,

RWP-2A and -28, and has proposed to calculate it from the tide level. l 2.2.2.1 Coda Requirement l Refer to Appendix A.

2.2.2.2 Licensee's Basis for Requesting Relief 1

The Emergency Nuclear Seawater Pumps are vertical, submerged pumps that take suction from a pit open to the Circulating Water Intake Structure through two j

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4 48 inch diameter lines. The pit water level is the same as the tide level, therefore, the pump inlet pressure is equal to atmospheric pressure plus a tide level pressure correction, i

The system is a fixed resistance type (if heat exchanger fouling is ignored).

l Table IWP-3100-1, Note 1 states (for systems of this type) measurement of both j flow and differential pressure is not required. Differential pressure can be

, calculated since the pumps have discharge pressure gauges and intake pressure is determined by tide level. Therefore, no relief is needed from the require-i ment to measure flow. However, a written clarification stating that inlet  ;

pressure is determined by tide level is appropriate. Florida Power Corporation perfoms testing of the Emergency Nuclear Seawater Pumps in accordance'with the Code, and no changes to the system or test procedures are required. i 1

2.2.2.3 Evaluation l 4

The staff does not agree with the licensee's basis and, therefore, permanent relief should not be granted from the suction pressure measurement requirements l of Section XI for the Emergency Nuclear Service Seawater pumps.

l 2.2.2.4 Conclusion I

The licensee must measure pump inlet pressure and differential pressure in accordance with the requirements of Section XI. Suitable instrumentation or other means should be provided by the licensee in order to do so. The licensee is required to make these modifications prior to the end of the next refueling outage. For the balance of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by licensee. Requiring the licensee to make these modifications prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in the level of safety. Taking into account the inservice tests that will be j performed as well as the relatively short operational time until the next refueling outace, it is concluovi that this interim relief will not endanger life or property or the common deknse and security of the public.

2.2.3 Relief Recuest The licensee has requested relief from the pump inlet pressure measuring  !

requirements of Section XI for the Decay Heat Service Sea water pumps, RWP-3A i

and -38, and has proposed to calculate pressure from the tide level. j t

2.2.3.1 Code Requirement Refer to Appendix A. '

2.2.3.2 Licensee's Basis for Requesting Relief There is no pressure tap installed in the suction line of these pumps to measure inlet pressure. The installation of a tap would require a modification to the system involving a violation of the pipe pressure boundary. The modification would entail tests in accordance with the Construction Code and

Section XI for a Class 3 System.

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j 2.2.3.3 Evaluation I

The staff does not agree with the licensee's basis and, therefore, permanent

i. relief should not be granted from the suction pre::sure measurement requirements

of Section XI for the Decay Heat Service Seawater pumps.

2.2.3.4 Conclusion The licensee must measure pump inlet pressure in accordance with the requirements of Section XI. Suitable instrumentation or other means should be

provided by the licensee in order to do so. The licensee is required to make these modifications prior to the end of the next refueling outage. For the i balance of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by the licensee. Requiring the licensee to make these modifications prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in the level of

-safety. Taking into account the inservice tests that will be performed as well i as the relatively short operational time until the next refueling outage, it is j concluded that this interim relief will not endanger life or property or the

[ common defense and security of the public.

4 2.3 Flow Rate Measurements i

! 2.3.1 Relief Request

! The licensee has requested relief from the flow measurement requirements of

! Section XI for the Emergency Nuclear Service Seawater pumps, RWP-2A and -2B, j and has not proposed an alternate test.

2.3.1.1 Code Requirement

! Refer to Appendix A. -

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2.3.1.2 Licensee's Basis for Requesting Relief i There is no flow element installed in the discharge line of these pumps to

measure the flow rate. The installation of an element would require a modf-

! fication of the pipe pressure boundary. This modification would entail exami-i nation and tests in accordance with the Construction Code and Section XI for a

) Class 3 System.

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The system may be variable resistance for the inservice test of these pumps at .

! at a given time (i.e., heat exchanger out for maintenance or cleaning). It-

will be attempted to fix the resistance of the system during the perfomance of

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an inservice test of the pump, though it may not be always possible. If the system resistance is varied during the test, it shall be noted on the procedure. Should a test quantity be out of normal range, it shall be i evaluated on the basis of the varied resistance in the system.

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l 2.3.1.3 Evaluation I

The staff does not agree with the licensee's basis for relief and, therefore, permanent relief should not be granted from the requirement of measuring flow as per the Code. The NRC position on measuring Section XI parameters requires j the necessary instrumentation be installed and states that the lack of i

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- 6-k instrumentation is not an adequate technical justification for granting relief.

The licensee has not provided adequate technical justification for granting relief and the licensee should provide the required instrumentation so flow can l be monitored per the Code.

2.3.1.4 Conclusion The licensee must measure pump flow rate in accordance with the requirements of i Section XI. Suitable instrumentation or other means should be provided by the i licensee in order to do so. The licensee is required to make these modifications prior to the end of the next refueling outage. For the balance l of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by the licensee. Requiring the licensee to make these modifications prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in the level of

safety. Taking into account the inservice tests that will be perfonned as well

as the relatively short operational time until the next refueling outage, it is i concluded that this interim relief will not endanger life or property or the

common defense and security of the public. l 2.3.2 Relief Request l 1

i The licensee has requested relief from the flow measurement requirements of l Section XI for the Decay Heat Service Seawater pumps, RWP-3A and -3B, and has I not proposed an alternate test.

l l 2.3.2.1 Code Requirement '

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Refer to Appendix A.

1 2.3.2.2 Licensee's Basis for Requestina Relief l

There is no flow element installed in the discharge line of these pumps to 4 measure the flow rate. The installation of an element would require modifica-tion of the pipe pressure boundary. This modification would entail examinations and tests in accordance with the Construction Code and Section XI l for a Class 3 System. This system is of fixed resistance. Flow measurement is i not necessary when the resistance may be fixed.

1 2.3.2.3 Evaluation i

4 The staff does not agree with the licensee's basis and, therefore, permanent

, relief should not be granted from he requirements of Section XI Table .

i IWP-3100-1, 1974 Edition, to measure both flow and differential pressure during i

! pump tests for variable resistance systems. The NRC position on measuring '

i Section XI parameters requires the necessary instrumentation be installed and I states that the lack of instrumentation is not an adequate technical justifi-

] cation for granting relief. The licensee has not provided adequate technical  !

! justification for granting relief and the licensee should provide the required '

instrumentation so flow can be monitored per the Code.

! 2.3.2.4 Conclusion 1

! The licensee must measure pump flow rate and differential pressure in j accordance with the requirements of Section XI. Suitable instrumentation or

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other means should be provided by the licensee in order to do so. The licensee is required to make these modifications prior to the end of the next refueling outage. For the balance of the period of the current fuel cycle, interim relief is granted to test the pumps as proposed by the licensee. Requiring the

! licensee to make these modifications prior to the next refueling outage would i

impose unnecessary hardship on the licensee without a compensating increase in the level of safety. Taking into account the inservice tests that will be perfomed as well as the relatively short operational time until the next i

i refueling outage, it is concluded that this interim relief will not endanger j life or property or the common defense and security of the public.

j 2.4 Vibration Feasurements

) 2.4.1 Relief Request 1

l The licensee has requested relief from the vibration instrumentation accuracy j requirements of Section XI, Table IWP-4110-1.

4 j 2.4.1.1 Code Requirement l Nominal Maximum Instrument Errors, Vibration Amplitude; 15% of full scale.

I i 2.4.1.2 Licensee's Basis for Requesting Relief

, The manufacturer of the vibration measuring equipment has stated to Florida i Power Corporation that the " instrument" error can be as low as *10% of full-scale reading, but not 5%. They indicated that this is due to the transducer

precision and accuracy, which must be included in the " instrument" error.

4 The calibration limits for the vibration amplitude measuring device will be set

at 10% of full-scale, the lowest error that the manufacturer will certify.

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l 2.4.1.3 Evaluation 4

The staff does not agree with the licensee's basis and, therefore, pemanent relief should not be granted from the vibration instrumentation accuracy

requirements of Section XI. The licensee's use of vibration instrumentation i that has an accuracy tolerance of 110% may not provide repeatable vibration measurements to utilize in assessing pump condition. It is the staff's 4

position that vibration instrumentation that is sufficiently accurate to meet

, the requirements of Section XI is available from various manufacturers and that i the licensee should obtain the necessary vibration instrumentation in order to conduct the pump vibration testing in accordance with Section XI.

j 2.4.1.4 Conclusion i

The staff concludes that the licensee will not be able to adequately monitor pump vibration utilizing present vibration instrumentation because the inforra-tion obtained would not be sufficiently accurate to monitor pump degradation.

The staff concludes that the licensee is required to obtain vibration instru-l mentation that is sufficiently accurate to meet the requirements of Section XI, i Table IWP-4]IO-1, for use in the pump monitoring program. The licensee is j required to obtain this instrumentation prior to the end of the next refueling outage. For the balance of the period of the current fuel cycle, interim

) relief is granted to test the pumps as proposed by the licensee. Requiring the

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! licensee to make these modifications prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in i the level of safety. Taking into account the inservice tests that will be i performed as well as the relatively short operational time until the next i refueling outage, it is concluded that this interim relief will. not endanger i

life or property or the comen defense and security of the public.

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3.0 VALVE TESTING PROGRAM

! The Crystal River, Unit 3, IST program submitted by Florida Power Corporation l l (FPC) was examined to verify that safety-related valves included in the program i

are subjected to the periodic tests required by the ASME Code,Section XI, and

, the NRC positions and guidelines. The staff's review finds that, except as i

noted in Appendix D or where specific relief from testing has been requested. l j these valves are tested to the Code requirements and the NRC positions and i i guidelines sumarized in Appendix A and Section 3.1 of- this report. Each FPC

{ basis for requesting relief from the valve testing requirements and the staff's j evaluation of that request is sunnarized below and grouped according to system

and valve category. <

4 3.1 General Considerations l 3.1.1 Full-Stroke Exercising of Check Valves The NRC's position was stated to the licensee that check valves whose safety i function is to open were expected to be full-stroke exercised. Since the disk '

l position is not always observable, the NRC staff position is that verification j of the maximum flow rate through the check valve identified in any of the  ;

plant's safety analyses would be an adequate demonstration of the full-stroke

requirement. Any flow rate less than this will be considered partial-stroke

exercising unless it can be shown that the check valve's disk position at the 4

lower flow rate would permit maximum required flow through the valve. It is the NRC staff's position that this reducted flow rate method of demonstrating i

full-stroke capability is the only test that requires measurement of the

differential pressure across the valve.

, 3.1.2 Valves Identified for Cold shutdown Exercising

The Code permits valves to be exerc'esed during cold shutdowns where it is not

, practical to exercise quarterly du'.ing plant operation, and these valves are j specifically identified by the lir.ensee and are full-stroke exercised during i cold shutdowns, therefore, the licensee is meeting the requirements of the ASME j Code. Since the licensee is meeting the requirements of the ASME Code, it is j not necessary to grant relief; Powever, during our review of the licensee's IST program, we have verified that it is not practical to exercise these valves during power operation and that we agree with the licensee's basis.

It should be noted that the NRC differtntiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for valves identified for testing at cold shutdowns, it is expected that the tests will be perforined both during cold shutdowns (See Section 3.1.3) and during each i refueling outage. However, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling j outage. In addition, for extended refueling outages, tests being performed are I

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i expected to be maintained as closely as practical to the Code specified frequencies.

3.1.3 Conditions for Valve Testing During Cold Shutdowns l Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:

1. The licensee 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 is not a prerequisite to return to power.

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Any testing not completed during one cold shutdown should be performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.  ;

4. For planned cold shutdowns, where ample time is available and testing all the valves identified for a cold shutdown test frequency in the IST program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

3.1.4 Category A Valve Leak Test Requirements for Containment Isolation Valves (CIVs) 1 All containment isolation valves that are Appendix J. Type C, leak tested should be included in the IST program as Category A or A/C valves. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are detennined b Relief from Para Addenda) graphs IWV-3420(a) through 3420(e) 1974 Edition through(y 10 CFR Sumer 1975 50, Appe for containment isolation valves presents no safety problem since the i intent of these paragraphs is met by Appendix J requirements, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action requirements of Paragraphs IWV-3420(f) and -3420(g). Based on the considerations discussed above, the NRC staff has concluded that the alternate testing proposed will give reasonable assurance of valve leak-tight integrity as required by the Code and that the relief thus granted will not endanger life or property or the comon defense and security of the public.

3.1.5 Applicatien of Appendix J Testing to the IST Program The Appendix J review for this plant is completely separate from the IST program review. However, the determinations made by that review are directly appitcable to the IST program. The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.

3.1.6 Safety-Pelated Valves This review was limited to safety-related valves. Safety-related valves 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 shut-down condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-Code class valves. It should be noted that the ifcensee may have included some non-safety-related

l valves in their IST program as a decision on their part to expand the scope of their program.

3.1.7 Active Valves i

The NRC staff position is that active valves are those for which changing I position may be reoufred to shut down a reactor to the cold shutdown condition or in mitigating the consequences of an accident. Included are valves which .1 respond automatically to an accident signal, such as safety injection; and J valves which may be optionally utilized but are subject to plant operator actions, such as service water supply to the steam generators, and valves utilized to establish long term recirculation following a LOCA.

3.1.8 Rapid-Acting Power Operated Valves The NRC staff has icentified rapid-acting power operated valves as those which stroke in 2 seconds or less. Relief from the trending requirements of Section XI (paragraph IWV-3410(c)(3) of the 1974 Edition through Sumer of 1975 Addenda) presents no safety concerns for these valves since variations in stroke times will be affected by slight variations in the response times of the personnel performing the tests. However, the staff does require that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

3.1.9 Valves Which Perform a Pressure Boundary Isolation Function Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure.

Pedundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems protect the low pressure systems from pressures which exceed their design limit. In this role, the valves perform a pressure isolation function. The NRC considers the redundant isolation provided by these valves to be important. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity.

A. The following list of valves are identified as pressure isolation valves PIVs by the licensee and are tested in accordance with Crystal River 3 Technical Specifications 4.4.6.2.2, 4.4.6.2.3, 3.4.6.2 and Table 3.4-2 which were incorporated into the technical specifications by order (Event V) dated April 20, 1981.

CFV-1 Core flood and decay heat in.fection check CFV-3 Core flood and decay heat injection check DHV-1 Decay heat discharge to cold leg check i DHV-2 Decay heat discharge to cold leg check i B. The following valves also perform a pressure isolation function, however, they are not categorized A or A/C and are not individually leak tested. In accordance with guidance from the Comittee to ReviewGenericRequirements(CRGR)onJuly 24, 1985, backfitting of non-Event V PIV leak testing at operating reactors may not be appropriate. Therefore, pending review and approval by CRGR of a PIY I testing plan for operating reactors, leak testing of these valves l l

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! which are not listed in Table 3.4-2 of the licensee's Technical l l Specifications, is not to be involuntarily imposed on the licensee. 1 The licensee should be advised of his option to only continue leak testing his current Technical Specification list of PIVs until further notice.

DHV-3 Decay heat suction from hot leg i

DHV-4 Decay heat suction from hot leg RCV-53 Auxiliary spray from decay heat i RCV-12 Auxiliary spray from decay heat check CFV-2 Core flood injection check CFV-4 Core flood injection check MUV-38 RCS letdown isolation MUV-39 RCS letdown isolation MUV-40 RCS letdown isolation MVV-41 RCS letdown isolation MUV-42 High pressure injection check MUV-43 High pressure injection check MUV-160 High pressure injection check

, MUV-161 High pressure injection check MUV-36 High pressure injection check MVV-37 High pressure injection check MUV-163 High pressure injection check MUV-164 High pressure injection check I

3.1.10 Pressurizer Power Operated Relief Valves

The NRC has adopted the position that the pressurizer power operated relief i 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 i probability of sticking open and are not needed for overpressure protection

! during power operation, the NRC has concluded that routine exercising during power operation is not practical and, therefore, not required by IWV-3410.

The PORVs' function during reactor startup and shutdown is to protect the i reactor vessel and coolant system from low-temperature overpressurization

! conditions and they should be exercised prior to initiatinn of system

conditions for which vessel protection is needed. ,

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The following test schedule is required:

1. Full-stroke exercising should be performed at each" cold shutdown or, .

] as a minimum, once each refueling cycle.

i 2. Stroke timing should be perfonned at each cold shutdown, or as a minimum, once each refueling cycle.

a. The staff position described in Section 3.1.3 regarding cold shutdown testing is not applicable to the PORVs; however, in case of frequent cold shutdowns, testing of the PORVs is not required more often

. than each three months. I i

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...--._ . .-.. - - _ .. .._ -.. - ,,.,-- ~., - . _ ,.-. _ ,,- _ ,- -. - _ ~ - _ . . . _ - . . . , - _ - , - . . - . . _ , . - - - _ . . . _ . . _ ,

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

3. Fail-safe actuation testing should be perfonned at each cold shutdown.

4. The PORV block valves should be included in the IST program and 4

tested quarterly to provide protection against a small break LOCA should a PORV fail open.

The licensee has included the PORV, RCV-10, and the PORY block valve, RCV-11,

, in the IST program and is testing them in accordance with these guidelines.

1 1 3.2 Generic Relief Requests

3.2.1 Category A and B Valves 3.2.1.1 Relief Request

! The licensee has requested relief from the corrective action statement of I IWV-3410(g) of ASME Code Section XI for IST program Category A and B valves

! tested during cold shutdown. The utility has proposed taking corrective action l

per their Technical Specifications.

I 3.2.1.1.1 Code Requirement

--IWV-3410(g) Corrective Action. If a valve fails to exhibit the required I change of valve stem or disk position by this testing, corrective action shall i be initiated imediately. If the condition is not, or can not be corrected j within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared inoperative. When corrective i action is required as a result of tests made during cold shutdown, the  ;

] condition shall be corrected before startup. A retest showing acceptable

operation shall be run following any required corrective action before the j, valve is returned to service.

j 3.2.1.1.2 Licensee's Basis for Requestino Relief Should a valve fail to exhibit the required change of valve stem position and i corrective action is initiated during cold shutdown, an assessment of system

) operability shall be made in relationship to the component's inoperability.

The action statement of the facility's Technical Specifications shall then be J followed. Therefore, relief is requested from the " Corrective Action" subparagraph of IWV-3410(g) concerning cold shutdown valves and unit startup.

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3.2.1.1.3 Evaluation l The staff agrees with the licensee's basis, and therefore, relief should be j granted from the Section XI corrective action requirements for Category A and B l valves. The licensee has stated that he would follow his Technical j i Specification requirements with respect to the valve found to be inoperable. '

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3.2.1.1.4 Conclusion The staff's position is that the licensee determines valve operability in accordance with the Code and that conditions for plant startup are detennined by plant Technical Specifications. Therefore, this relief is granted. The i

staff concludes that the alternate testing proposed will give reasonable assurance of valve operability required by the Code and that the relief thus granted of will not endanger life or property or the connon defense and security the public.

3.2.1.2 Relief Request The licensee has requested relief from the leak-rate testing requirements of Section XI for Category A valves used for containment isolation. The utility has proposed to use Appendix J leak-rate testing as an alternate test with their Technical Specifications as a means for establishing leakage limits.

3.2.1.2.1 Code Requirement

) IWV-3420-Valves must be leak tested at least each 2 years. Yalves with Teakage i

i greater than that specified by the Owner or those provided in the Code must be 4

replaced or repaired. For 6-inch and lar doubled (coinciding with a cold shutdown)ger valves, pending the test frequency corrective action, if the must be leak rate margin to failure is reduced by 50% or more from the previous test.

Also, 6-inch and larger valves must be repaired or replaced if the trend based on three or more be exceeded leakthan by more tests 10%indicates at the next that test.the maximum allowable leak rate will 3.2.1.2.2 Licensee's Basis for Requestino Relfef i

For those valves denoted as SLT-1, it is requested the Appendix J. Type C, test be substituted for the Section XI leak testing as provided by IWV-3420 of the i

Code. The combined leakage of all these valves and other penetrations subject to a Type B and C Appendix J test shall be less than 0.6La (percent /24 hours),

where La is the maximum allowable leakage at Pa, the calculated peak con-tainment Specification.

internal pressure as specified in the facility's Technical 3.2.1.2.3 Evaluation i

The staff agrees with the licensee's basis and, therefore, relief should be from some of the requirements of Section XI IWV-3420 of the ASME B&PV Code.

The licensee has demonstrated that substituting the Appendix J test program for the requirements of IWV-3420 is adequate to monitor valve degradation as per i

paragraphs (a) through (e). However, the licensee has not demonstrated that

the leak-rate limits and corrective action requirements of paragraphs (f) and i

(g) will be met with Appendix J testing. It is our position that these requirements should be met per the Code (Refer to Section 3.1.4 of this SER).

3.2.1.2.4 Conclusion i

t The testingstaff meetsconcludes the requirements thatofthe proposed Section XI IWV-3420 alternate (a) through test (e . of substituting)

However, IWV-3420 (f) and (g) are not met with the alternate test. Therefore, 1

b_ _ __ _ _ - - - - . - - . - - - - . . - _ - - - _ - _ . - _

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i the staff concludes that the leak-rate limits and corrective action require-

! ments must be met per the Code. The staff concludes that the relief thus

! granted will not endanger life or property or the common defense and security j of the public.

j 3.2.1.3 Relief Request I

The licensee has requested relief from the corrective action requirements of

, Section XI, Paragraphs IWY-34?0(g) (1) and (2) for Category A valves. The j utility proposes to use the leak-rate of 95% of 0.6La as a limit to replace or repair defective valves and then retest as judiciously as possible.

3.2.1.3.1 Code Requirement i --IWV-3420(g)(1)and(2). For 6-inch and larger valves, the test frequency

} must be doubled (coinciding with a cold shutdown) pending corrective action, if the leak-rate margin to failure is reduced by 50% or more from the pmvious test. Also, 6-inch and larger valves must be repaired or replaced if the trend j based on three or more leak tests indicates that the maximum allowable j leak-rate will be exceeded by more than 10% at the next test. i i

! 3.2.1.3.2 Licensee's Basis for Requesting Relief Relief is requested from subparagraph IVW-3420(g)(1)(2). The alternate pro-i posed method of specifying a maximum permissible leakage on each SLT-1 valve l shall be an administrative high leakage limit or " action" limit. This limit

{ shall be based upon 95% of 0.6La, where La is in standard cubic feet per minute

of leakage, and " nominal inches of valve diameter," excluding the Type B pene-I trations and the 48" reactor building purge valves. Where valves exceed their individual action limit, they should be replaced or repaired and retested as

, judiciously as possible.

!! The requirements of IWV-3420 are very similar to the existing requirements of 1 10 CFR 50, Appendix J. Florida Power Corporation has a testing program that j,, meets the Appendix J requirements and all of the intent of IWV-3420. From Appendix J, the total combined leakage of all type B and C valves must not {

exceed 0.6La at a test pressure of Pa, or 64.3 psia. The total allowable j leakage. 0.6La, has been found to equal 248,656 sec/ min, including the Type B j penetrations, and 221.942 sec/ min was attributable to Type C valves. The sum of

the relevant valve diameters is approximately 93 inches. These values yield a

. quotient of 2386 scc / min / inch. An alert value of 70% of this or 1670 sec/ min /

l inch and an action value of 95% of this or 2260 sec/ min / inch have been j established along with requirements for the evaluation and repair.

The requirements of 10 CFR 50, Appendix J, for local leak-rate testing will be met in lieu of the ASME Code. IWV-3420, requirements. As stated above in the I

basis for relief, the Appendix J program meets the intent of the ASME Code.

3.2.1.3.3 Evaluation

! The staff does not agne with the licensee's basis and, therefore, relief

should not be granted from the Section XI corrective action requirements for i Category A valves. Evaluation of the licensee's IST program indicates a sum of 1 i the relevant valve diameters greater than 170 inches which indicates the j licensee's proposed leakage rates am approximately twice what they should be.

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. . l In addition, the licensee has not provided sufficient technical justification I that demonstrates corrective action would be initiated or testing conducted when required but only that retests will be performed as judiciously as possible.

3.2.1.3.4 Conclusion The staff concludes that the licensee has not provided adequate technical justification for granting relief from the corrective action requirements of Section XI for Category A valves. Therefore, corrective action must be taken as per Section XI.

3.2.1.4 Relief Request l

The licensee has requested relief from the stroke timing requirements of Section XI for all power operated valves whose nonnal stroke times are two seconds or less and proposed to apply a maximum stroke time limit of two seconds as the limiting value of stroke time for fast acting valves. 1 l

3.2.1.4.1 Code Requirements 1 The stroke time of all power-operated valves shall be treasured to the nearest second or 10% of the maximum allowable stroke time, whichever is less, whenever ,

such a valve is full-stroke tested [IWV-3410(c)(2)]. If an increase in stroke time of 25% or more from the previous test for valves with stroke times of I greater than ten seconds or 50% or more for valves with stroke tas less than or equal to ten seconds is observed, test frequency shall be increased to once i each month until corrective action is taken, at which time the original test i frequency shall be resumed. In any case, any abnonnality or erratic action l

shall be reported [IWV-3410(c)(3)2

)

3.2.1.4.2 Licensee's Basis for Requestino Relief

" Fast acting" valves (those valves which stroke in less than two seconds) are not trended to accurately indicate en increase in stroke time of 50% from a previous test. Many of these valves "instantly" stroke and a 50% increase in stroke time is insignificant. " Fast acting" valves will have an action limit of greater than two seconds stroke time. The action required wil' " to investigate for any necessary corrective action, and to test mont, ., until the problem is resolved.

i 3.2.1.4.3 Evaluation i The staff acrees with the licensee's basis on the assumption that the licensee's " action limit" is the " limiting stroke time" as defined in IWV-3410(c)(1). Therefore, relief should be granted from the stroke timing requirements of Section XI for fast acting valves that stroke in less than 2 seconds.

{

f 3.2.1.4.4 Conclusion The staff concludes that the proposed alternate testing indicated above should I give reasonable assurance of valve operability as required by the Code and that relief thus granted will not endanger life or property or the common defense and security of the public. Also see Section 3.1.8 of this report.

3.3 Auxiliary Steam System 3.3.1 Category B Valves 3.3.1.1 Relief Request

! The licensee has requested relief from the exercising requirements of I l Section XI for valve ASV-23, auxiliary steam to emergency feedwater turbine manually operated valve, and has proposed to operationally check valve position before and after operations.

J 3.3.1.1.1 Code Requirement Refer to Appendix A.

3.3.1.1.2 Licensee's Basis for Requestino Relief This valve is closed during nomal plant operation. Auxiliary steam is not a safety and seismic class source of power for the emergency feedwater turbine.

, Operational checks with appropriate record entries shall record the position of this passive valve be' fore operations are perfomed and after operations are completed.-

3.3.1.1.'3 Evaluation l

The staff agrees with the ifcensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valve ASV-23. The licensee has demonstrated that this valve is passive and during plant operation l will be in its safety-related position, therefore, will not be required j to operate to mitigate the consequences of an accident or safely shut down the plant. The licensee's proposed alternate test of operational checks prior to i and after operation should be sufficient to demonstrate the valve perfoms its safety-related function.

3.3.1.1.4 Conclusion The staff concludes that the proposed alternate test of operational checks of ASV-23 prior to and after operation, should be sufficient to demonstrate the

valve performs its safety-related function.

I The staff concludes that the relief thus granted will not endanger life or j property or the common defense and security of the public.

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3.4 Reactor Buildino Spray System 3.4.1 Category B Valves 3.4.1.1 Relief Request '

The licensee has requested relief from the exercising requirements of Section XI for valves BSV-36 and 37, sodium hydroxide storage tank to HPI and LPI system isolation valves, and has proposed to stroke and stroke time at refueling outages.

3.4.1.1.1 Code Requirement Refer to Appendix A.

3.4.1.1.2 Licensee's Basis for Requesting Relief A full stroke of these valves would introduce sodium hydroxide into the LPI system. Should the valve fail in the open position, the sodium hydroxide would infiltrate the LPI and BWST. This could lead to sodium hydroxide in the HPI system and possibly the RC system. A chemical " clean-up" of the systems would be necessary. This would mean additional radiation waste and making piping more susceptible to caustic cracking. Should the sodium enter the RCS, it could lead to additional man-rem exposure b During cold shutdown, the decay heat (LPI) system y activation is in of theAsodium-24 use. stroke of the valve could introduce sodium hydroxide in the borated water system. This could increase unit down time to perform a system cleanup and have a chemically damaging effect on safety components.

3.4.1.1.3 Evaluation The staff agrees with the licensee's basis and finds that the quarterly exercising requirements of Section XI are not practical within the limitation of the design of this system. The staff agrees that quarterly exercising could result in damage to the system which would impair the system safety function.

Therefore, relief should be granted from the exercising requirements of Section XI for valves BSV-36 and 37. The licensee has demonstrated that these valves cannot be operated during power operation or at cold shutdown without contaminating the LPI systen with sodium hydroxide. The staff agrees that the proposed test of exercising at refueling outages is the best frequency for full-stroke exercising these valves.

3.4.1.1.4 Conclusion

The staff concludes that the proposed alternate test of full-stroke exercising and stroke timing valves BSV-36 and 37 at refueling outages should demonstrate proper valve operability and therefore, relief should be granted from the quarterly exercising requirements of Section XI.

3.4.2 Category C Valves, 3.4.2.1 Relief Request The licensee has requested relief from the full-stroke exercising requirement of Section XI for valves BSV-26 and 27, reactor building spray check valves, and has proposed to internally inspect one valve each refueling outage.

. 3.4.2.1.1 Code Requirement Refer to Appendix A.

3.4.2.1.2 Licensee's Basis for Recuesting Relief The full-stroke of these valves would require initiation of the RB spray system. This would entail spraying the reactor building with borated water.

3.4.2.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves BSV-26 and 27. The licensee has denonstrated that full-flow exercising these valves is not possible during power operation, cold shutdown or refueling cutages because it would require the reactor building to be sprayed with borated water.

The licensee has proposed to internally inspect one of these valves every refueling outage. We agree that relief should be granted for the proposed test interval.

3.4.2.1.4 Conclusion The NRC position is that a valve sampling disassembly / inspection utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability, therefore, the licensee is required to comply.

technique requires that each valve in the group must be of the The same sampling design (manufacturer, size, model number, and materials of construction) and must have the same service conditions.

Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

A different valve of each group is required to be disassembled, ins sected, and manually full-stroked at each refueling until the entire group has seen tested.

If it is found that the disassembled valve's full-stroke capability is in 3

l question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage. Therefore, relief is granted from the Code-required frequency of testing to perform these tests as described herein. Relief thus granted will not endanger life or property or I the coninon defense and security of the public.

Following successful disassembly, inspection, and manual full-stroking of all the check valves in the group, the licensee may submit a relief request to the NRC requesting lengthening of the intervals between these tests. This relief request should contain all pertinent historical maintenance data on each valve, including the inspection and maintenance data obtained at each disassembly /

inspection and manual full-stroke. Photographs should be provided of the valve "as found" internals, noting particularly any anomalies encountered.

3.4.2.2 Relief Request The licensee has requested relief from exercising valves BSV-150 and -151, sodium hydroxide storage tank outlet checks, in accordance with the requirements of Section XI and proposed to full-stroke exercise them at five year intervals.

e 3.4.2.2.1 Code Requirement Refer to Appendix A.

3.4.2.2.2 Licensee's Basis for Requesting Relief This is a storage tank for sodium hydroxide that will be used for post-LOCA pH control. The building spray system is lined up to the borated water storage tank which stores borated water for refueling and post-accident injection through the HPI, LPI, and BS systems. The Na0H is not chemically compatible with the borated water as the boron is an aqueous solution of beric acid.

Stroking these check valves could only be accomplished by injecting the NaOH into the borated water at the pump suction and recirculating this mixture to the BWST. Florida Power Corporation has a full-flow building spray test that full-stroke opens these valves. This test is performed at five year intervals.

3.4.2.2.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves BSV-150 and

-151. The staff agrees that valve testing is not practical at Code-required intervals with the present system configuration; however, relief should not be granted for the proposed test interval.

3.4.2.2.4 Conclusion The NRC position is that a sampling valve disassembly / inspection program utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability, therefore, the licensee is required to comply. (See Item 3.4.2.1 of this report for details). Relief from the Code-required frequency of testing is granted provided this testing is performed as described herein. Relief thus granted will not endanger life or property or the comon defense and security of the public.

3.5 Core Flcod System 3.5.1 Cateoory A/C Valves 3.5.1.1 Relief Request The licensee has requested relief from the Section XI exercising and leaktest reguirements for valves CFV-1 and CFV-3, isolation check valves from "A" and "B train Decay Heat and Core Flood Tanks to the Reactor Coolant System (RCS);

and CFV-2 and CFV-4, isolation check valves from "A" and "B" Core Flood Tanks to the RCS.

3.5.1.1.1 Code Requirement Refer to Appendix A.

3.5.1.1.2 Licensee's Basis for Requesting Relief These valves are in the flow path from the core flood tanks to the reactor coolantsystem(RCS). These valves provide passive isolation from the higher pressure RCS to the low pressure core flood tanks and the decay heat system and

between the core flood tanks and the decay heat system. In both trains, the two check valves are in series, and therefore both cannot be tested for leak tightness.

Additionally, due to the magnitude of the design flow for the core flood lines, ,

these valves cannot be demonstrated to fully open utilizing a flow test. One of the four check valves will be opened for internal inspection at each refueling.

After each valve has been opened once, an evaluation will ~ e o made and the frequency adjusted. If no problems have been evidenced the frequency will be extended to one valve every second refueling. The Alternate Examination program will begin in 1987 during Refuel VI.

3.5.1.1.3 Evaluation The staff agrees with the licensee's bases regarding the Section XI requirement to full stroke these valves quarterly to the open position. We also agree that a sampling disassembly / inspection at each refueling outage is an acceptable

~

method to meet this code requiremerit. "TRefer to 3.4.2.1 of this repert).

However, we do not agree with grouping these four valves into one group since CFV-1 and CFV-3 have different service conditions than CFV-2 and CFV-4. Addi-tionally, relief should not be granted at this time to extend the test fre- i quency to every other refueling. The licensee should follow the methodology l described in Section 3.4.2.1 of this report. ,

The staff also does not agree with the licensee's proposal to utilize its pro- i posed disassembly / inspections as verifications of the leaktight integrity of l these valves since it does not provide a quantified leak rate. Crystal River 3  !

Technical Specifications require that CFV-1 and CFV-3 be verified to have leakage less than specific values. In 3.1.9 of this report the staff has

. stated that CFV-2 and CFV-4 should also be subject to the same leak test requirements of Crystal River 3 Technical Specifications 4.4.6.2.2, 4.4.6.2.3, i

l 3.4.6.2 and Table 3.4-2. l

, 3.5.1.1.4 Conclusion The staff concludes that the licensee's proposal to utilize a sampling dis-assembly / inspection at each refueling is acceptable provided the valves are treated as two groups with CFV-1 and CFV-3 comprising one group and CFV-2 and CFV-4 comprising the other, and subject to the other provisions as described in 3.4.2.1 of this report. Relief from the Code-required frequency of full stroke

testing is granted on the assumption the licensee complies with those provisions. Relief thus granted will not endanger life or property or the comon defense and security of the public. Relief to extend the frequency of testing and to utilize the disassembly inspections as verifications of valve leak tight integrity is not granted.

3.5.1.2 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves CFV-18 and 19, makeup to core flood tank checks, and has  !

proposed to verify valve closure each refueling outage. l 3.5.1.2.1 Code Requirement Refer to Appendix A.

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' 3.5.1.2.2 Licensee's Basis for Reouesting Relief The core flood tanks have a static inventory of borated water. The major loss of inventory results from sampling for chemical assay. Makeup of borated water is not periodic and is not sufficient to full stroke open these valves. The normal position of these valves and the position required to fulfill their intended function is closed. Stroke testing would not provide assurance that these valves would perform their intended function. Therefore, stroke testing is unnecessary.

This valve is subject to 10 CFR 50, Appendix J. Type C leak rate testing at each refueling which will verify proper valve closure.

3.5.1.2.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves CFV-18 and

19. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety position) is leak testing. This i valve is not equipped with position indication and some of the required test connections are located inside containment.

3.5.1.2.4 Conclusion The staff concludes that the proposed alternate testing of verifying valve closure during the performance of Icak rate testing at refueling outages should demonstrate proper valve operability.

The staff concludes that the alternate testing proposed will give reasonable assurance of valve operability required by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

3.5.1.3 Relief Request The licensee has requested relief from exercising valves CFV-17 and -20, core flood tanks nitrogen supply checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety-related position) during each refueling outage.

3.5.1.3.1 Code Requirement Refer to Appendix A.

3.5.1.3.2 Licensee's Basis for Requesting Relief i

The core flood tanks have a static inventory of borated water with 600 psi pressure applied through a regulated nitrogen gas system. The norsal position l

of these valves and the position to fulfill their function is closed. Stroke testing would not provide assurance that these valves would perform their intended function. Therefore, stroke testing is unnecessary.

This valve is subject to 10 CFR 50, Appendix J, Type C, leak-rate testing at each refueling which will verify proper valve closure.

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3.5.1.3.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising reautrements of Section XI for valves CFV-17 and 20. The licensee has demonstrated that, due to plant design, the only ,

method available to verify valve closure (their safety-related position) is I 6

leak testing. These valves are located inside containment and are not equipped )

with position indication. ,

3.5.1.3.4 Conclusion i The staff concludes that the proposed alternate testing of verifying va'lve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. The staff concludes that the alternate testing proposed will give reasonable assurance of valve operability required by the Code and that the relief thus granted w-ill not endanger life or property or the common defense and security of the public.

3.6 Decay Heat Closed Cycle Cooling System 3.6.1 _ Category B Valves '

3.6.1.1 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves DCV-187 and 189, decay heat closed cycle cooling surge tank to waste gas disposal system isolation, and proposed to substitute operational checks before and after operations.

3.6.1.1.1 Code Requirement Refer to Appendix A.

3.6.1.1.2 Licensee's Basis for Requesting Relief These are passive valves not required to function during nomal or safety plant operations. Operational checks with appropriate record entries shall record the position of these passive valves before operations are performed and after operations are completed.

3.6.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves DCV-187 and 189. These valves are in their safety-related position and are not required to open or close to mitigate the consecuences of an accident or safely shut down the plant. Therefore, operability is inconsequential with regard to the safety function which they perfom.

3.6.1.1.4 Conclusion The staff concludes that valves DCV-187 and 189 are in their safety-related position, therefore, operability is inconsequential with regard to the safety function which they perform.

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. l The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the relief thus granted will not endanger life or property or the common defense and security of the public.

3.7 Decay Heat Removal System 3.7.1 Category B Valves 3.7.2.1 Relief Recuest The licensee has requested relief from the exercising requirements of .

Section XI for valves DHV-9 and 10, decay heat pump discharge valves to borated water storage tank, and has proposed to operationally test these valves before and after operations.

3.7.1.1.1 Code Requirement Refer to Appendix A.

3.7.1.1.2 Licensee's Basis for Reouesting Relief These are passive valves not required to change position to fulfill their function for nomal or safety reactor shutdown. Operational checks with ap-propriate record entries shall mcord the position of these passive valves before operations are performed and after operations are completed.

3.7.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves DHV-9 and 10.

The licensee has demonstrated that these valves am passive and during plant operation will be in their safety-related position, therefore, they will not be required to operate to mitigate the consequences of an accident or safely shut down the plant. The staff agrees that the licensee's proposed alternate test of operational checks prior to and after operation should be sufficient to demonstrate that these valves perform their safety-related functions.

3.7.1.1.4 Conclusion The staff concludes that the proposed alternate test of operational checks of valves DHV-9 and 10 prior to and after operations should be sufficient to demonstrate that these valves perfom their safety-related function. The staff .* 1 concludes that the relief thus granted will not endanger life or property or  ;

the common defense and security of the public. l 3.7.1.2 Relief Pequest The licensee has requested relief from the exercising requirements of Section XI for valves DHV-75 and 76, decay heat removal pumps suction from the makeup system filters, and has proposed to operationally test these valves before and after operation.

3.7.1.2.1 Code Requirement Refer to Appendix A.

3.7.1.2.2 Licensee's Basis for Requesting Relief These are passive valves not required to change position to fulfill their function for normal or safety reactor shutdown.

Operational checks with appropriate record entries shall record the position of these passive valves before operations are performed and after operations are complete:!.

3.7.1.2.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves DHV-75 and 76. The licensee has demonstrated that these valves are passive and during plant operation will be in their safety-related position, therefore, they will not be required to operate to mitigate the consequences of an accident or safely shut down the plant. The staff agrees that the licensee's proposed alternate test of operational testing prior to and after operation should be sufficient to demonstrate these valves perform their safety-related functions.

3.7.1.2.4 Conclusion The staff concludes that the proposed alternate test of operational checks of valves DHV-75 and 76 prior to and after operations should be sufficient to demonstrate that these valves perform their safety-related functions. The staff concludes that the relief thus granted will not endanger life or property or the comon defense and security of the public.

3.7.2.3 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves DHV-105 and 106, decay heat removal pumps discharge isolation valves to the makeup and purification prefilters, and has proposed to operationally test these valves before and after operations.

3.7.1.3.1 Code Requirement Refer to Appendix A.

3.7.1.3.2 Licensee's Basis for Requesting Relief These are passive valves not required to change position to fulfill their function for normal or safety reactor shutdown. Operational checks with appropriate record entries shall record the position of these passive valves before operations are performed and after operations are completed.

3.7.1.3.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves DHV-105 and 106. The licensee has demonstrated that these valves are passive and

during plant operation will be in their safety-related position, therefore,

4

. l they will not be required to operate to mitigate the consequences of an l accident or safely shut down the plant. The staff agrees that the licensee's  !

proposed alternate test of operational testing prior to and after operation  !

should be sufficient to demonstrate that these valves perform their safety-related functions.

, 3.7.1.3.4 Conclusion The staff concludes that the proposed alternate test of operational testing valves DHV-105 and 106 prior to and after operations should be sufficient to demonstrate these valves perform their safety-related functions. The staff ,

j concludes that the relief thus granted will not endanger life or property er the comon defense and security of the public.

3.7.1.4 Relief Recuest  !

' ]

The licensee has requested relief from the exercising and stroke time test requirements of Section XI for valves DHV-110 and Ill, decay heat removal pumps run out preventers, and has proposed to operationally test them during the decay heat removal system inservice operability checks.

3.7.1.4.1 Code Requirements Refer to Appendix A.

3.7.1.4.2 Licensee's Basis for Requesting Relief These valves are not required to move from a full closed to a full open posi- '

tion (or conversely) to fulfill their safety function. The valves are normally full open, sensing no flow, and will throttle to maintain flow during system operability checks or LPI operation. A full stroke and time test of these valves does not increase the facility safety. These valves will be tested at the same frequency as system inservice operability checks for the decay heat removal system. The valves shall be tested during these tests to assure that they maintain proper pump discharge operability flow.

3.7.1.4.3 Evaluation The staff does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising and stroke time test requirements of Section XI for valves DHV-110 and 111. The licensee has not demonstrated that the proposed alternate test of operational testing these valves during the decay heat removal system inservice operational test is adequate to prove valve reliability. Therefore, these valves should be tested per the Code.

3.7.1.4.4 Conclusion The staff concludes that the licensee has not provided an adequate test program I that demonstrates proper valve operability as required by Section XI. I Therefore, relief is not granted.

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3.8 Condensate and Demineralized Water Supply System 3.8.1 Category A/C V 11ves '

3.8.1.1 Relief Reques.

The licensee has reques':ed relief from the exercising requirements of Section XI for valve Dh f-162, demineralized flushing water to reactor coolant pump stand pipe check velve, and has proposed to substitute leak testing per Appendix J as a means of verifying valve full closure.

3.8.1.1.1 Code Requirement Refer to Appendix A.

3.8.1.1.2 Licensee's Basis for Requesting Relief During normal plant operation this check valve is part-opened to allow a small quantity of demineralized water to flow to the RC pumps' standpipes for flushing. This valve is not required to full open in any safety mode and must close in case of containment isolation. The only safety-related function of this valve is to close. This can only be verified during the 10 CFR 50 Appendix J. Type 'C' test which is performed during refueling outages.

3.8.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valve DWV-162. The licensee has demonstrated that closed is the safety-related position and that the only way to verify closure is with a leak test. The leak test will be done during Appendix J leak-rate testing at refueling. The staff agrees that this is the only practical way of verifying valve operability.

3.8.1.1.4 Conclusion The staff concludes that the licensee's proposed alternate test of verifying ,

valve DWV-162 closed with Appendix J 1eak-rate testing at refueling is the only l practical way of checking valve operability. The staff concludes that the  :

relief thus granted will not endanger life or property or the common defense l and security of the public.

i 3.9 Fire Service System 3.9.1 Category A Valves 3.9.1.1 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves FSV-261 and 262, reactor building fire service system isolations, and has proposed to leak-rate test these valves as a means of verifying valve closure.

3.9.1.1.1 Code Requirement Refer to Appendix A.

g - - . , - - - - - , , - - , -

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. l 3.9.1.1.2 Licensee's Pasis for Requesting Relief i These valves are not used in modes 1 through 4 and are classified as passive valves.

3.9.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves FSV-261 and 262. The licensee has demonstrated that these valves are passive and, therefore, exercising is not required. The proposed alternate test is.to Appendix J leak-rate test at refueling. The staff agrees that this is the best method of demonstrating that these valves perform their safety-related function.

3.9.1.1.4 Conclusion The staff concludes that the licensee's proposed alternate test of leak-rate testing valves FSV-261 and 262 at refueling will be sufficient to demonstrate that the valves perform their safety-related function. The staff concludes ,

that the relief thus granted will not endanger life or property or the connon '

defense and security of the public.

3.10 Makeup and Purification Systems 4

3.10.1 Category A/C Valves 3.10.1.1 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves MUV-36, 37, and 42, makeup system to reactor coolant system check valves.

3.10.1.1.1 Code Requirement Refer to Appendix A. '

3.10.1.1.2 Licensee's Basis for Requesting Relief These valves cannot be exercised during power operation and cannot be full-stroke exercised at cold shutdown due to the possibility of causing a low-  !

temperature overpressurization transient. These valves are partially-stroked exercised following modification to the system that requires the flow balancing procedure. The alternate examination will be required at the end of Refuel V, 4

scheduled to begin in March 1985.

3.10.1.1.3 Evaluation I

The staff does not agree with the licensee's basis and, therefore, relief should not be granted as requested from the exercising requirements of Section XI for valves MUV-36, -37, and -42. The licensee has provided conflicting infonnation in that Relief Request #V-190 does not agree with Table 2 and the exercising interval for these valves is unclear. Also, the licensee has not adequately described the alternate testing to be perfonned in lieu of that required by l

L. . - - , _ . _ ._ __ .. . ~ . . ._ - . - . _.

Section XI. Therefore, the licensee should implement u disassembly / inspection program for these valves.

3.10.1.1.4 Conclusion The NRC position is that a sampling valve disassembly / inspection program utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability, therefore, the licensee is required to comply. (See Item 3.4.2.1.4 of this report for details). Relief from the Code-required frequency of testing is granted provided this testing is per-

' formed as described herein. Relief thus granted will not endanger life or property or the common defense and security of the public.

3.10.2 Category B Valves 3.10.2.1 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valve MUV-5, makeup to core flood tank stop, and has proposed to substitute operational checks before and after operations.

3.10.2.1 Code Requirement Refer to Appendix A.

3.10.2.1.2 Licensee's Basis for Requesting Relief The valve is passive and is not recuired to change position for nomal or safety shutdown of the reactor.

3.10.2.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI. The licensee has demonstrated that valve MUV-5 is in its safety-related position and not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, operability is inconsequential with regard to the safety function which it performs.

3.10.2.1.4 Conclusion The staff concludes that valve MUV-5 is in its safety-related position, there-fore, operability is inconsequential with regard to the safety function which it performs. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the relief thus granted will not endanger life or property or the common defense and security of the public.

3.10.3 Category C Valves 3.10.3.1 Relief Request The licensee has requested relief from exercising valves MUV-60 and -72, makeup pumps borated water storage tank suction checks, in accordance with Section XI and proposed to partial-stroke exercise these valves during refueling outages.

3.10.3.1.1 Code Requirement Refer to Appendix A.

3.10.3.1.2 Licensee's Basis for Requesting Relief These operation.

power two valves are normally closed check valves that carrot be stroked during During refueling they can be partially-stroke exercised, however, they cannot be full-stroke exercised at cold shutdowns due to low-temperature overpressurization concerns. These valves will be partially-stroke exercised at each refueling.

3.10.3.1.3 Evaluation The staff does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising requirements of Section XI for valves MUV-60 and -72. The staff agrees that these valves cannot be exercised during power operation because that could upset the reactor coolant system boron concentration and result in a plant shutdown. The staff also agrees that a low-temperature overpressure condition could result if exercising were performed during cold shutdowns. However, it is the staff's position that these check valves perform a safety-related position in both the open and closed position and that their full-stroke capability must be demonstrated at least during refueling outages. Therefore, the licensee should implement a valve sampling / disassembly program for these valves in order to verify their full-stroke capability.

order that valve closure capability may be verified. Additionally, the licensee shoul 3.10.3.1.4 Conclusion The NRC position is that a sampling valve disassembly / inspection program utilizing a manual full-stroke of the disk is an acceptable method to verify a comply. valve's full-stroke capability, therefore, the licensee is required to check (See Item 3.4.2.1.4 of this report for details). Relief from the '.

Code-required frequency of testing is granted provided this testing is per-formed as described herein. Relief thus granted will not endanger life or property or the common defense and security of the public.

Regarding valve closure verification, the licensee must provide the necessary test connections in order to verify the closure capability of these valves. The licensee outage.

refueling is required to make these modifications prior to the end of the next Requiring the licensee to make these modifications prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in the level of safety. Taking into account the relatively short operational time until the next refueling outage, it is concluded that this interim relief will not endanger life or property or the common defense and security of the public.

3.10.3.2 Relief Request The licensee has requested relief from exercising valves MUV-43, -160 -161,

-163, and -164, makeup system to reactor coolant system checks, in accordance '

with the requirements of Section XI and proposed to partial-stroke exercise

these valves only after system modifications have been performed. ,

3.10.3.2.1 Code Requirement 4

Refer to Appendix A.

3.10.3.2.2 Licensee's Basis for Requesting Relief These valves cannot be exercised during power operation and cannot be full-stroke exercised at cold shutdown due to the pessibility of causing a low-temperature overpressurization transient. These valves are partially-stroke exercised following modification to the system that requires the flow balancing

, procedure. The alternate examination will be required at the end of Refuel V,

, scheduled to begin in March 1985.

3.10.3.2.3 Evaluation The staff does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising requirements of Section XI for valves MUV-43, 160, 161, 163, and 164. The licensee has provided conflicting infonnation in that Relief Request #V-190 does not agree with Table 2 and the exercising interval for these valves is unclear. Also, the licensee has not adequately described the alternate testing to be perfonned in lieu of that required by Section XI. Therefore, the licensee should implement a valve j sampling / disassembly inspection program.

4 3.10.3.2.4 Conclusion The NRC position is that a sampling valve disassembly / inspection program utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability, therefore, the licensee is required to i

, comply. (See Item 3.4.2.1.4 of this report for details). Relief from the l

Code-required frequency of testing is granted provided this testing is perfonned as described herein. Relief thus granted will not endanger life or property on the common defense and security of the public. l 3.10.3.3 Relief Request The licensee has requested relief from exercising valves MUV-1, -7, and -11, makeup pump discharge checks, in accordance with the requirements of Section XI and proposed to partial-stroke exercise them quarterly and full-stroke exercise them only after system modifications have been performed. -

3.10.3.3.1 Code Requirement Refer to Appendix A.

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.-. - _ . . _ _ _ _ _ . _ . . _ . . . _ . _ . ~ ._ - ,_. _ _. ,. .. _... _. _ _ , . _ _ _ . . . , _ . _ , , _

3.10.3.3.2 Licensee's Basis for Requestino Relief These valves are partially-stroked during each test of the makeup pumps and one of the pumps is always running. However, the flow rates are not sufficient to full-stroke open these valves in this recirculation mode. Full-stroke exercising of these valves at cold shutdown could subject the reactor coolant system to low-temperature overpressurization. These valves will be partially-stroke exercised quarterly. These valves are full-stroke exercised following modifications procedure be performed. to the system which requires that the flow balancing 3.10.3.3.3 Evaluation

. The staff does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising frequency requirements of Section XI for valves MUV-1, -7, and -11. The staff agrees that these valves cannot be full-stroke exercised during power operation because a loss of pressurizer level control could result in a reactor trip and that a low-temperature over-pressure condition could result from exercising during cold shutdown, however, the licensee has failed to identify a full-stroke exercise interval and has not adequately described the alternate testing to be performed in lieu of that required by Section XI. Therefore, the licensee should implement a valve sampling / disassembly inspection program.

3.10.3.3.4 _ Conclusion The NRC position is that a sampling valve disassembly / inspection program utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability, therefore, the licensee is required to comply.

(See Item 3.4.2.1.4 of this report for details). Relief from the Code-required frequency of testing is granted provided this testing is per-3 formed as described herein. Relief thus granted will not endanger life or property or the common defense and security of the public. ,

3.11 Spent Fuel Cooling System 3.11.1 Category B Valves I

3.11.1.1 Relief Request 4

The licensee has requested relief from the exercising requirements of Section XI for valve SFV-7, spent fuel pump suction cross-tie isolation valve, and has proposed to substitute operational checks before and after operations.

3.11.1.1.1 Code Requirement Refer to Appendix A.

3.11.1.1.2 Licensee's Basis for Requesting Relief This valve is open during normal operation of the spent fuel cooling system.

The valve adds to the flexibility of the system. 1 this valve does not add to the safety of the facility.TheOperational quarterly stroking checks with of appropriate record entries shall record the position of this passive valve before operations are performed and after operations are completed.

m . . . _ _ _ _ _ _ _ . ,

7  % - 9 +, .,,,ym.-,. - _,s ., , . _ . _ -9 p , __ - y.p, -wg4e g._ .- 9 p9., 9

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l 3.11.1.1.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valve SF-7. This valve is in its safety-related position and not required to open or close to mitigate the consequences of an accident or safely shut down the plant. There-fore, operability is inconsequential with regard to the safety function which it perfoms.

3.11.1.1.4 Conclusion The staff concludes that valve SFD-7 is in its safety-related position, therefore, operability is inconsequential with regard to the safety function which.it perfonns. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for pa'ssive valves and the relief thus granted will not endanger life or property or the common defense and security of the public.

3.11.1.2 Relief Reouest The licensee has requested relief from the exercising requirements of Section XI for valves SFV-13, suction from borated water storage tank, SFV-14, suction from cask storage area, SFV-21, borated water recirculation pump suction i

stop, SFV-35, fuel transfer canal fill valve, SFV-46, borated water return to BWST from transfer canals isolation, and SFV-88, fuel transfer canal isolation.

The utility has proposed to substitute operational testing before and after operations in lieu of exercising.

3.11.1.2.1 Code Requirement Refer to Appendix A. '

3.11.1.2.2 1.icensee's Basis for Requestino Relief l These are passive valves not required to operate during nonnal or safety function plant operation.

3.11.1.2.3 Evaluation The staff agrees with the Itcensee's basis and, therefore, relief should be granted from the requirements of Section XI for valves SFV-13,14, 21, 35, 46, and 88. These valves are in their safety-related position and not required to repen or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, operability is inconsequential with regard to the safety function which they perfom.

3.11.1.2.4 Conclusion The staff concludes that valves SFV-13,14, 21, 35, 46, and 88 are in their  ;

safety-related position, therefore, the operability is inconsequential with i regard to the safety function which they perform. The staff concludes that the  ;

quarterly stroke and stroke time measurements are meaningless for passive  !

valves and the relief thus granted will not endanger life or property or the common defense and security of the public.

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33 -

3.11.1.3 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valve SFV-50, spent fuel filter outlet, and has proposed to substitute operational checks before and after operations.

3.11.1.3.1 Code Requirement Refer to Appen' dix A.

3.11.1.3.2 Licensee's Basis for Requesting Relief This valve is normally left in the open position and not required to be manipu-lated to the during systemthe course of norral for operational modes. system operation. The valve adds flexibility 3.11.1.3.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valve SFV-50. This valve is in its safety-related position and not required to open or close to mitigate the consequences of an accident or safely shut down the plant. There-fore, operability is inconsequential with regard to the safety function which it performs.

3.11.1.3.4 Conclusion The staff concludes that valve SFV-50 is in its safety-related position, therefore, which operability is inconsequential with regard to the safety function it performs. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the relief thus ,

l granted will not endanger life or property or the common defense and security of the public.

3.11.1.4 Relief Request

],

The licensee has requested relief from the exercising requirements of Section XI for valves SFV-119 and 120, fuel transfer tube isolations, and has proposed to substitute operational checks before and after operations.

3.11.1.4.1 Code Requirement Refer to Appendix A. 1 3.11.1.4.2 Licensee's Basis for Requestina Relief These valves are closed during norwal plant operations and not required to 4

operate during any plant condition other than refueling. The flanges inside containment are Appendix J tested with 100 SCC / minute allowable leakage.

Operational checks with appropriate record entries shall record the position of i .

these passive valves before operations are performed and after operations are completed.

s9-ye,-y,-y- ,,m ---- r , - -w-,vy r s-w,---e-w,ww

3.11.1.4.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves SFV-119 and 120. These valves are in their safety-related position and not. required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, operability is inconsequential with regard to the safety function which they perfonn.

3.11.1.4.4 Conclusion The staff concludes that valves SFV-119 and 120 are in their safety-rel'ated position, therefore, operability is inconsequential with regard to the safety function which they perfonn. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the relief thus granted will not endanger life or property or the comon defense and security of the public.

3.12 Nuclear Services Closed Cycle Cooling System 3.12.1 gegoryBValves 3.12.1.1 Relief Recuest The licensea has requested relief from the exercising requirements of Section XI for valves SWV-279, 280, 284, and 285, nuclear services closed cycle cooling isolations from the makeup pump coolers, and has proposed to substitute operational checks before and after operations.

3.12.1.1.1 Code Requirement

• Refer to Appendix A. i 3.12.1.1.2 Licensee's Basis for Requesting Relief These are passive valves which are closed for normal and safety modes of operation. The valves add system flexibility.

3.12.1.1.3 Evaluation _

The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves SWV-279, 280, 284, and 285. These valves are in their safety-related position and not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, operability is inconsequential with regard to the safety function which they perfonn.

3.12.1.1.4 Conclusion The staff concludes that valves SWV-279, 280, 284, and 285 are in their safety- l related position, therefore, operability is inconsequential with regard to the  ;

safety furetion which they perform. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the I

,-, , . - - - y w - - ,

l relief thus granted will not endanger life or property or the common defense  !

and security of the public.

3.12.1.2 Relief Request The licensee has requested relief from the exercising requirements of Section XI for valves SWV-299, 300, 306, and 307, manual cross-ties between the industrial water and the nuclear service closed cycle cooling systems, and has proposed to substitute operational checks before and after operations.

3.12.1.2.1 Code Requirement Refer to Appendix A.

3.12.1.2.2 Licensee's Basis for Requestino Relief These are passive valves inner-connecting a non-safety, non-seismic system with

, the nuclear service closed cycle cooling system. These valves add flexibility to the system capability.

3.12.1.2.3 Evaluation The staff agrees with the licensee's basis and, therefore, relief should be

granted from the exercising requirements of Section XI for valves SWV-299, 300, 306, and 307. These valves are in their safety-related position and not required to open or close to mitigate the consequences of an accident before, operability is inconsequential with regard to the safety function which they l perform.

3.12.1.2.4 Conclusion The staff concludes that valves SWV 299, 300, 306, and 307 are in their safety-related position, therefore, operability is inconsequential with regard to the

+ safety function which they perform. The staff concludes that the quarterly stroke and stroke time measurements are meaningless for passive valves and the relief thus granted will not endanger life or property or the comon defense and security of the public.

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. n APPENDIX A

1. CODE REQUIREMENT--VALVES  ;

Subsection IWV-3410(a) of the 1974 Edition through Summer 1975 Addenda, of the Section XI ASME Code (which discussed full-stroke and partial-stroke re-quirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f).

IWV-3520(a) (which discusses full-stroke and partial-stroke requirements) re-quires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above exceptions, the Code per-mits the valves to 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-3410(c) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time. Additionally, all Category A valves are required to be individually leak rate tested and trended on a frequency not to exceed each two years in accordance with IWV-3420.

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-E-l l 2. CODE REnUIREMENT--PUMPS i

Section IWP-3400(a) of the 1974 edition of the ASME Code calls for an inservice test to be conducted on all pumps that perforra a Fafety-related func-tion r,cminally once each month during nornal plant operation. Each inservice '

test shall include the measurerrent, observation, ar.d recording cf all quan-tities in Table IWP-3100-1, except bearino temperature, which shall be measured during at least one inservice test each year. '

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APPENDIX B The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation. These valves are specifically iden-tified by the owner and are full-stroke exercised during cold shutdowns and refueling outages. The staff has reviewed all valves in this Appendix and agrees with the licensee that testing these valves during power operation is not practical due to the valve type, location, or system design. These valves either cannot or should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

System Valve Identification Function Decay Heat Removal DHV-3 Decay heat renoval isolation DHV-4 from the reactor coolant system DHV-1 Decay heat removal to reactor DHV-2 coolant system checks DHV-93 Decay heat removal to pressurizer spray Emergency Feedwater EFV-1 Emergency feedwater suction EFV-2 from the condenser EFV-5 Emergency feedwater pump EFV-6 discharge checks EFV-7 Emergency feedwater pump l

l EFV-8 discharge stop checks EFV-15 Emergency feedwater to the l EFV-16 steam generators checks 1

System Valve Identification Function EFV-17 Energency feedwater to the EFV-18 steam generators checks Feedwater FWV-29 Main feedwater systen block FWV-30 valves FWV-31 Low load feedwater block FWV-32 valves FWV-33 Startup feedwater block FWV-36 valves FWV-34 Emergency feedwater block FWV-35 valves FWV-41 Steam generator startup level FWV-42 control valve inlet checks FWV-43 Emergency feedwater line FWV-4a checks FWV-157 Back flow preventers from the FWV-158 main feedwater to the e

emergency feedwater piping Main and Reheat MSV-330 Steam Steam generator secondary 4

MSV-148 drains MSV-411 PSV-412 Main steam isolation valves FSV-413 PSV-414 ftSV-25 Main steam atmospheric dump MSV-76 valves Makeup and MUV-49 Purification Letdown cooler containment isolaticn i MUV-53 Makeup pumps minimum flow i

MUV-257 isolations i MUV-253 Reactor coolant pump seals l MUV-259 bleedoff containment MUV-260 isolations MUV-261 ,

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l System Valve Identification Function I MUV-18 Reactor coolant pump seal injection containment '

isolation MUV-64 Makeup tank isolation MUV-27 Normal makeup isolation block valve MUV-65 Makeup storage tank outlet  ;

check Reactor Coolant RCV-12 Pressurizer spray from decay ,

heat removal system check l l

RCV-53 Pressurizer spray from decay heat removal system isolation 1 Nuclear Services SWV-12 Cooling water supply to Closed Cycle Cooling reactor coolant evaporator i

package l

SWV-79 Cooling water supplies to RC l SWV-80 pump motor bearings, air SWV-81 cooler, and seal area coolers SWV-82 SWV-83 SWV-84 SWV-85 SWV-86 SWV-109 Cooling water to and from the SWV-110 CRDMs '

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AFFENDIX C The P& ids listed below were used during the course of this review.

P&ID System Number

, Revision RV Fuel Handling Area and Auxiliary FD-302-751 16 Building <

Auxiliary Stear FD-302-051 24 Reactor Building Spray FD-302-711 23 Reactor Building Pressure Sensing and FD-302-712 7 4

Testing Chemical Addition FD-302-671 16 Liquid Sampling FD-302-672 21 Condensate FD-302-101 25 Core Flooding FD-302-702 12 Chemical Cleaning Steam Generators FD-302-192 15 Chilled Water FD-302-756 18 Industrial Cooler Water FD-302-762 15 Decay Heat Closed Cycle Cooling FD-302-631 19 Emergency Diesel Generator F0 Transfer FD-302-281 11 Decay Heat Removal FD-302-641 27 i Diesel Jacket Coolant FD-302-283-1 2 Diesel Air Cooler Ccolant FD-302-284-1 1 Domestic Water FD-302-211 27 Condensate and Demineralized Water Supply FD-302-182 27 Emergency Feedwater FD-302-082 18 4

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...* )

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4 P&ID l System Number Revision '

i Emergency Diesel Generator Startine Air and FD-302-282 8 Exhaust Containment Monitering FD-302-693 15 Feedwater FD-302-0P1 25 Instrument and Station Service Air FD-302-271 24 RB Leak Rate Testing and Post Accident FD-302-727 16

H2 Purge Main and Reheat Stean FD-302-011 31 Makeup and Purification FD-302-661 32 Nitroter, Hydrogen, and Carbon Dioxide FD-302-673 28 j R(actor Coolant FD-302-651 23 i

f!uclear Services and DH Sea Water FD-302-611 23 .

i Spent Fuel Cooling FD-30?-621 16 Nucleer Services Closed Cycle Cooling FD-302-601 31

Liquid Waste Disposal FD-302-681 42 Gas Waste Disposal FD-302-691 41 l

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. ., o APPENDIX D ANOMALIES IDEUTIFIED IN THE REVIEW 1.

The licensee has included the diesel cer.erator air start valves in the program but has failed to describe the nethod utilized to measure the stroke tirre, therefore, these valves must be stroke timed in accor-dance with Section XI. ,

2. The licensee has not revised the IST program to reflect the inspec-

• tion performed to verify the integrity of the check valves in the diesel generator ccoling water system as he aoreed to do in his re-spcnse to IE Pulletin 83-03 dated May 31, 1983. The present IST program describes only functioncl verification during the perfnrru.ce of diesel generator testing. The affected valves are:

EMERGENCY DIESEL GENERATOR EGDG-1A DJV-1 Suction to standby ecolant pump DJV-17 Suction to standby coolant pump DJV-27 Outlet of jacket coolant radiator DJV-29 Outlet of jacket coolant radiator DJV-31 Outlet of temperature control valve to lube oil cooler inlet DJV-38 Outlet of the radiators to combustion ecclers EMERGENCY DIESEL EGDG-1B DJV-2 Suction to standby coolant pump 4

DJV-18 Suction to standby coclant pump l

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..o DJV-28 Outlet of jacket coolant radiator DJV-30 Outlet of jacket coolant radiator DJV-32 Outlet of temperature control valve to lube oil cooler inlet DJV-39 Outlet of the radiators to combustion coolers The staff does not agree with the licensee's position that diesel generator testing adequately verifies the full stroke capability cf these valves; therefore the licensee is required to perform sampling disassembly / inspections of these valves as described in 3.4.2.1.4 of this report. Relief from the Code-required frequency of testing is granted provided this testing is performed as described herein.

Relief thus granted will not endanger life or property or the common defense and security of the public.

3. The licensee has propored to verify closure of valves FWV-22 and -23, main feedwater pump discharge stop checks instead of valves FWV-45 and -46, steam generator feedwater header checks, during refueling outages but has failed to provide a relief request explaining the alternate test interval. The staff agrees that these two valves cannot be exercised during power operation, however, they are equipped with motor operators and can be verified shut during cold shutdowns. The licensee is recuired to comply with this position.

4. The licensee has not requested specific relief from the vibration amplitude and bearing temperature testing requirements of Section XI for the chemical addition pumps CAP-1A and cap-1B or provided a specific technical basis for not measuring these pumps parameters.

The staff concludes that these pumps should be tested quarterly to the requirements of Section XI.

5. Control valves that have no required safety function for which relief has been requested are not addressed in this SER. Relief is not re-quired as control valves are exempt per IWV-1200. The following lists these concerned valves:

CHV-48 DCV-189 CHV-49 DCV-191 CHV-50 CHV-51

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k* 6. Valve relief request for check valves in the Emergency Diesel Generator Fuel Oil Transfer System is not required as the valves are technical specification tested at least as frequently as Section;XI requires.

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