ML20214S520
| ML20214S520 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/31/1987 |
| From: | Ransom C, Rockhold H EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20214S510 | List: |
| References | |
| CON-FIN-A-6812 EGG-NTA-7508, NUDOCS 8706090300 | |
| Download: ML20214S520 (87) | |
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l l EGG-NTA-7508 March 1987 l r
INFORMAL REPORT u.
' idaho i National ~ TECHNICAL EVALUATION REPORT, PUttP AND VALVE Engineering INSERVICE TESTING PROGRAF 1, PILGRIM NUCLEAR Laboratory i POWER STATION Managed by the U.S.
C. B. Ransom Department H. C. Rockhold ofEnergy
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Prepared far the :
work performes unse, U.S. NUCLEAR REGULATORY COMMISSION umorJ!cfsl'*ll fos 6ISSOAE50Shk%3 P
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I DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their ernployees, makes any warranty, express or implied, or assumes any legal liabdity or responsibility for th9 accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infnnge onvately owned nghts. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not recessanly constitute or imply its endorsement, recommendation, or favonng by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessanly state or reflect those of the United States Government or any agency thereof.
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TECHNICAL EVALUATION REPORT '
PUMP AND VALVE INSERVICE TESTING PROGRAM PILGRIM NUCLEAR POWER STATION l
I' Docket No. 50-293 4
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! C. B. Ransom i H. C. Rockhold k
Published March 1987 1
Idaho National Engineering Laboratory 9 EG&G Idaho, Inc.
I Prepared for the U.S. Nuclear Regulatory Commission 4 Washington, D.C. 20555 1
Under 00E Contract No. DE-AC07-76ID01570 FIN No. A6812 i
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, ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation j of the Pilgrim Nuclear Power Station Inservice Testing Program for pumps and valves.
i FOREWORD i This report is supplied as part of the " Review of Pump and Valve I Inservice Testing Programs for Operating Plants" program being conducted
- for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor I l Regulation, Division of BWR Licensing, by EG&G Idaho, Inc., NRR and I&E Support. ,
! The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-10-11-2, FIN No. A6812.
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CONTENTS
- 1. INTRODUCTION ..................................................... 1
- 2. PUMP TESTING PROGRAM ............................................. 3 2.1 Pump Bearing Temperature Measurements ...................... 3 2.1.1 Relief Request ..................................... 3
. 2.2 Pump Vibration Measurements ................................ 6 ,
2.2.1 Relief Request ..................................... 6 2.3 Reactor Building Closed Cooling Water Pumps ................ 7 2.3.1 Relief Request ..................................... 7 2.4 Salt Service Water Pumps ................................... 9 2.4.1 Relief Request ..................................... 9 2.4.2 Relief Request ..................................... 9 2.4.3 Relief Request ..................................... 11 2.5 S tandby Liquid Control Pump s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 2.5.1 Relief Request ..................................... 12 2.6 Residual Heat Removal Pumps ................................ 13 2.6.1 Relief Request ..................................... 13 2.7 Diesel Oil Transfer Pumps .................................. 13 2.7.1 Relief Request ..................................... 13
- 3. VALVE TESTING PROGRAM ............................................ 16 3.1 General Relief Requests .................................... 16 3.1.1 Stroke Time Measurements for Rapid Acting Valves ............................................. 16 3.1.2 Fail-Safe Testing of Valves ........................ 17 3.1.3 Corrective Actions for Individual Valve Leakage Rates ...................................... 18 3.2 Reactor Building Closed Cooling Water System ............... 19
. 3.2.1 Category A Valves .................................. 19 3.2.2 Category A/C Valves ................................ 21 l 3.2.3 Category B Valves .................................. 22 1
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3.3 ' Compressed Air System ...................................... 25 3.3.1 Category A/C Valves ................................ 25 3.4 Containment Atmosphere Centrol System ...................... 26 3.4.1 Category A Valves .................................. 26 3.4.2 Category A/C Valves ................................ 27 .
3.4.3 Category C Valves .................................. 30 3;5 Core Spray System .......................................... 31 3.5.1 Category C Valves .................................. 31 3.6 High Pressure Coolant Injection System (HPCI) .............. 32 3.6.1 Category B Valves .................................. 32 3.6.2 Category C Valves .................................. 34 3.7 Reactor Core Isolation Cooling System (RCIC) ............... 40 3.7.1 Ca t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 3.7.2 Category C Valves .................................. 41 3.8 Standby Liquid Control System .............................. 45 3.8.1 Category A/C Valves ................................ 45 3.8.2 Category C Valves .................................. 45 3.9 CR0 Hydraulic System ....................................... 46 3.9.1 Category B Valves .................................. 46 3.9.2 Category C Valves .................................. 48 3.10 Nuclear Boiler System ....................................., 50
, 3.10.1 Category A/C Valves ................................ 50 3.10.2 Category B Valves .................................. 51 3.10.3 Category B/C Valves ................................ 53 3.10.4 C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 3.11 Recirculation Pump Seal Water System ....................... 56 3.11.1 Category A/C Valves ................................ 56 3.12 Salt Service Water System ......... ....................... 57 ,
3.12.1 Category B Valves .................................. 57 l .
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3.13 D i e se l OIi 1 Tra n s fe r Sy s tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 l 3.13.1 Category B Valves .................................. 58
- 3.13.2 Category C Valves .................................. 58 3.14 Containment Atmospheric Dilution System .................... 60 l ,
3.14.1 Category A Valves .................................. 60
. APPENDIX A--NRC STAFF POSITIONS AND GUIDELINES......................... 63 APPENDIX B--VALVES TESTED DURING COLD SHUTDOWNS . . . . . . . . . . . . . . . . . . . . . . . 71
- APPENDIX C--P&ID LIST ................................................. 75
.i APPENDIX D--IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW . . . . . . . . . . . . 79 i
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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM PILGRIM NUCLEAR POWER STATION
- 1. INTRODUCTION Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by Boston Edison Company for the Pilgrim Nuclear Power Station.
The licensee's IST program dated July 11, 1983 was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety related with the requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, 1980 edition through winter 1980 addenda. The working meeting with Boston Edison Company representatives was conducted on May 30, 31 and June 1, 1984. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER).
The NRC staff position is that required program changes, such as additional relief requests or the deletion of any components from the IST Program, should be submitted to the NRC under separate cover in order to receive prompt attention, but should not be implemented prior to review and approval by the NRC.
In their IST program, the Boston Edison Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine if the required testing is indeed impractical for the specified pumps or valves.
This review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/ Impact Statement titled " Identification of Valves for Inclusion in Inservice Testing Programs". The IST Program testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide
, the basis to change the licensee's current Technical Specifications for system test requirements. ,
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Section 2 of this report presents the Boston Edison Company bases for requesting relief from the Section XI requirements for the Pilgrim Nuclear Power Station pump testing program and the reviewer's evaluations and conclusions regarding these requests. Similar information is presented in Section 3 for the valve testing program.
The NRC staff's positions and guidelines concerning inservice testing requirements are provided in Appendix A. .
Category A, B, and C valves that meet the requirements of the ASME Code,Section XI, and are not exercised quarterly are addressed in Appendix B.
A listing of P& ids and Figures used for this review is contained in Appendix C.
Inconsistencies and omissions in the licensee's IST program noted during the course of this review are listed in Appendix D. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
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- 2. PUMP TESTING PROGRAM The Pilgrim Nuclear Power Station IST program submitted by Boston Edison Company was examined to verify that all pumps that are included in the IST program are subjected to the periodic tests required by the ASME Code,Section XI except for those pumps identified be'ow for which specific relief from testing has been requested and as summarized in Appendix 0. Each Boston Edison Company basis for requesting relief from the pump testing requirements and the EG&G reviewer's evaluation of that request are summarized below.
2.1 Pump Bearing Temperature Measurements 2.1.1 Relief Request The licensee has requested relief from the Section XI requirement of yearly measuring pump bearing temperatures for all of the pumps in the l Pilgrim IST program, and proposed to determine pump bearing condition by quarterly measuring pump vibration in velocity units.
2.1.1.1 Licensee's Basis for Requesting Relief. Pilgrim generating station proposes an alternate program which is based on vibration readings measured in velocity units rather than vibration amplitude in mils displacement. These readings go far beyond the capabilities of a bearing temperature monitoring program. A bearing will be seriously degraded prior
, to the detection of increased heat at the bearing housing. Quarterly
! vibration velocity readings will achieve a truch higher probability of i detecting developing problems than annual bearing temperature readings.
I Finally, IWP-3500 requires "three successive readings taken at
- l. ten minute intervals that do not vary more than three percent." Meeting this requirement for pumps having no recirculation test loop would be very difficult because the system water temperature, and consequently the ,
lubricant temperature, are expected to drift more than three percent during20 minutes. Also, the temperature of the lubricating fluid will vary with ambient conditions and make meaningful data trending impractical.
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i As described above, a program of bearing temperature trends and the
< evaluation of the results would in some cases be difficult to analyze.
O j Improper interpretation of results could result in unnecessary pump maintenance. In addition, it is impractical to measure bearing temperatures on many of the pumps in the program. Some specific examples l are as follows: *
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- 1. Salt service water pumps: There is no installed instrumentation ,
l to measure bearing temperature. Also, pump bearings are under l water and, therefore, inaccessible.
I 2. Standby liquid control pumps: There is no installed instrumentation to measure bearing temperature. Bearings are inaccessible for direct measurement due to the size of the j bearing housing and the location of the bearing within the j housing. Bearings are in an oil bath which is inaccessible.
l 3. HPCI pump: No installed instrumentation to measure bearing i temperature. Bearings are inaccessible for direct measurement due to the bearing housing and the location of the bearing within the housing. Measurement of lube oil temperature is not j practical because this lube oil supplies several bearings and ,
control valves and would not necessarily reflect the pump bearing l I
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j 4. Core spray pumps: There is no installed instrumentation to l measure bearing temperature. Bearings are inaccessible for l direct measurement due to the size of the bearing housing and the
! location of the bearing within the housing. Bearings are process liquid lubricated.
1 l S. Residual heat removal pumps: There is no installed i instrumentation to measure bearing temperature. Bearings are 1 .
! inaccessible for direct measurement due to the size of the bearing housing and the location of the bearing within the housing. Bearings are process liquid lubricated.
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- 6. Reactor building closed cooling water pumps: There is no installed temperature measuring equipment on the RBCCW pump bearings. The limited information provided by yearly temperature measurements would not provide additional information above that determined by quarterly pump vibration velocity measurements.
In conclusion, the foregoing reasons demonstrate that the proposed
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which meets the intent of the requirements of the ASME Code.
2.1.1.3 Evaluation. The NRC staff's position is that the lack of installed instrumentation is not an acceptable long term technical justification for not measuring the Code required parameters on safety related pumps. The reviewer agrees with the licensee that measuring pump vibration in velocity units instead of displacement units provides additional information which allows detection of pump bearing degradation, however, since the licensee's alert and required action criteria are greater than acceptable, relief should not be granted from the Section XI requirement of measuring pump vibration displacement (refer to Section 2.2.1). Therefore, for the RBCCW pumps where no technical basis was provided for not measuring pump bearing temperatures, relief should not be granted from the requirement to annually measure the bearing temperatures.
The licensee has demonstrated that due to the pumps being submerged in water that pump bearing temperatures cannot be measured for the salt service water pumps. The licensee has also demonstrated that due to the bearing housing design that the pump bearings are inaccessible for temperat're u measurements for the standby liquid control, HPCI, core spray, and residual heat removal pumps. The licensee also pointed out that the core spray and residual heat removal pumps are lubricated by the process liquid, which would cause the pump bearing temperature to follow the
- process liquid temperature instead of being representative of the bearing l
mechanical condition. The standby liquid control pump bearings are in an oil bath which is inaccessible for making temperature measurements. The HPCI pump bearing is lubricated by a lube oil system whose temperature is 5
not representative of bearing condition since it cools and lubricates other components. The reviewer agrees with the licensees basis for the salt service water, standby liquid control, HPCI, core spray, and residual heat removal pumps and, therefore, relief should be granted from the Code requirement of measuring pump bearing temperatures for those pumps.
2.1.1.4 Conclusion. The reviewer concludes that pump bearing temperatures should be measured for the RBCCW pumps as required by the ,
Code. The reviewer also concludes that the pump bearing temperatures need not be measured for the salt service water, standby liquid control, HPCI, core spray, and residual heat removal pumps because it is either not possible to make these measurements and/or the measurements would not produce any meaningful information about the bearing condition as described above. Testing the salt service water, standby liquid control, HPCI, core spray, and residual heat removal pumps by measuring or observing the other Code required parameters should give a reasonable assurance of the ability of these pumps to perform their safety related function and is, therefore, acceptable. The proposed alternate testing should provide an indication of pump operability and degradation as required by the Code and relief should be granted.
2.2 pump Vibration Measurements 2.2.1 Relief Request The licensee has requested relief from the requirement of Section XI, Paragraph IWP-3100, of measuring vibration amplitude on all pumps in the IST program and proposed to measure pump vibration in units of velocity.
2.2.1.1 Licensee's Basis for Reouesting Relief. Pilgrim 1 Generating Station proposes an alternate program which is believed to be more comprehensive than that required by Section XI. The proposed program is '
based on vibration readings measured in velocity units rather than vibration amplitude in mils displacement. This technique is an ,
industry-accepted method which is more sensitive to small changes that are indicative of developing mechanical problems and hence more meaningful.
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Velocity measurements detect not only high amplitude vibrations that indicate a major mechanical problem, but also the equally harmful low ;
amplitude high frequency vibration resulting'from misalignment, imbalance, or bearing wear that usually go undetected by simple displacement measurements.
r Pump vibration measurements will be taken in vibration velocity
) (in/sec). The alert range begins at .314 in/sec and the required action ;
range begins at .628 in/ cec for all pumps. These values are recommended by 4- IRD Mechanalysis Inc., and correspond to rough and very rough operating 9
conditions, respectively. Similar velocity ranges can be obtained by the i
Hydraulic Institute Standards,13th Edition, Figure 66.
l 2.2.1.2 Evaluation. The reviewer does not. agree with the licensee's
- basis and, therefore, relief should not be granted from the vibration j measurement requirements of Section XI for all pump in the IST program.
The NRC staff has determined that measurement of vibration velocity is an 1
acceptable alternate method to utilize to assess pump; condition, however, the licensee's proposed allowable ranges are not in. agreement with the limits established by the NRC staff (the " Required Action" limit cannot be a velocity measurement greater than .314 inches /second).
2.2.1.3 Conclusion. The reviewer concludes that the licensee should measure pump vibration in accordance with the reauirements of Section XI.
2.3 Reactor Building Closed Cooling Water Pumps 4
2.3.1 Relief Request The licensee has requested relief from the requirement of Section XI, Paragraph IWP-3100, of measuring pump flow rates for the reactor building
. closed cooling water (RBCCW) pumps and proposed to measure the pump shutoff head for each pump and the total system flow quarterly.
2.3.1.1 Licensee's Basis for Requesting Relief. Instrumentation is not installed to measure flow rate. Redesign of the system would be necessary to install flow instrumentation or to utilize portable flow 7
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instrumentation. There is no method available to control the flow rates of individual pumps. Pump shutoff head and total system flow will be measured quarterly. Shutoff head will provide a repeatable parameter for measuring pump performance. Pumps are not run at shutoff head for more than i
60 seconds by procedure.
Additionally, piping configuration does not permit installation of flow orifices on the pump discharge piping that would be consistent with ,
good instrument practices. Adequate distance downstream of elbows is not available on the individual pump discharge prior to where discharge piping joins a common header.
2.3.1.2 Evaluation. The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring RBCCW pump flow. The licensee has demonstrated that there is no installed instrumentation for measuring individual pump flow rates and that the piping configuration would not permit the installation of flow instrumentation. The licensee indicated that they have evaluated alternate.
test methods, such as ultrasonic flow measurement devices, but found that none of the evaluated alternate methods'of measuring flow could be employed for the RBCCW pumps. The licensee's proposal to measure pump total dynamic head is the only method currently available to determine the hydraulic performance of the RBCCW pumps. ,
2.3.1.3 Conclusion. The reviewer concludes that the licensee's proposal of measuring pump total dynamic head while running at the pump shutoff head should give an indication of the pumps' hydraulic condition which should provide a reasonable assurance of the pumps ability to perform its safety related function and is, therefore, acceptable. The proposed alternate testing should provide an indication of pump operability and degradation as required by the Code and relief should be granted.
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2.4 Salt Service Water Pumps l
2.4.1 Relief Request The licensee has requested relief.from the requirement of Section XI, Paragraph IWP-3100, of measuring pump inlet pressure for the salt service water pumps and proposed to calculate pump. inlet pressure from the measured tide level.
1 2.4.1.1 Licensee's Basis for Requesting Relief. No instrumentation is installed to measure pump inlet pressure. The tide level will be used to calculate pump inlet pressure, and to specify inlet pressure for test purposes.
2.4.1.2 Evaluation. The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring inlet pressure for the salt service water pumps. The licensee has demonstrated that the inlet pressure for these submerged pumps is due to the head of water above the pump inlets which can be calculated by measuring the tide level at the time of pump testing.
2.4.1.3 Conclusion. The reviewer concludes that the licensee's proposal of using the tide level to calculate pump inlet pressure provides the information required by the Code to determine proper pump operability.
- The proposed alternate testing should provide an indication of pump operability and degradation as required by the Code and relief should be granted.
2.4.2 Relief Request The licensee has requested relief from the requirement of Section XI, Paragraph IWP-3100, of measuring pump flow rate for the salt service water pumps and proposed to measure the pump shutoff head and total system flow
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2.4.2.1 Licensee's Basis for Requesting Relief. Instrumentation is not installed to measure individual pump flow rate. Redesign of the system would be necessary to install flow instrumentation. Piping configuration does not permit installation of flow orifices on the pump discharge piping
't prior to where the pump discharge joins a common header. Ultrasonic indicators cannot be utilized with the rubber lined p'iping used in the salt .
service water system, also the pump discharge piping is underground.
The salt service water system is tested monthly to demonstrate that sufficient cooling water flow can be delivered to the RBCCW heat exchangers to meet heat removal requirements.
There is no method available to control the flow rates of individual pumps. Pump shutoff head and total system flow will be measured quarterly. Shutoff head will provide a repeatable parameter for measuring pump performance. Pumps are not run at shutoff head for more than 60 seconds by procedure.
2.4.2.2 Evaluation. The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring flow for the salt service water pumps. The licensee has demonstrated that there is no installed instrumentation for measuring individual pump flow rates and that the piping configuration would not permit the installation of flow instrumentation. The licensee indicated that they have evaluated alternate test methods such as ultrasonic flew measurement devices, but found that none of the alternate methods of measuring flow could be employed for these pumps due to such factors as rubber lined pipe and underground pipe runs. The licensee's proposal to measure pump total dynamic head is the only method currently available to determine the hydraulic performance of the salt service water pumps.
2.4.2.3 Conclusion. The reviewer concludes that the licensee's proposal of measuring pump total dynamic head while running at the pump shutoff head should give an indication of the pump's hydraulic condition and give reasonable assurance of the pumps ability to perform its safety ,
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related function. The proposed alternate testing should provide an indication of pump operability and degradation as required by the Code and, i therefore, relief should be granted.
2.4.3 Relief Request
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The licensee has requested relief from the requirement of Section XI, Paragraph IWP-3100, of measuring pump vibration for the salt service water pumps and proposed to measure vibration at the upper motor bearing for these submerged pumps.
2.4.3.1 Licensee's Basis for Requesting Relief. The pump casing is physically located under water and is therefore, inaccessible. The pump motor vibration will be measured at the motor upper bearing per the Hydraulic Institute Standards.
2.4.3.2 Evaluation. The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring the pump vibration for the salt service water pumps. The licensee has demonstrated that these pumps are submerged and are inaccessible for direct measurement of pump vibration. The licensee also demonstrated how the radial vibration measurement at the motor's upper bearing would be more indicative of the pump and shaft bearing condition than a measurement at the lower motor bearing. Taking vibration measurements at this location is supported by a statement in the Hydraulic Institute Standards book (13th Edition, Figure 66).
2.4.3.3 Conclusion. The reviewer concludes that the licensee's proposal of measuring vibration at the upper bearing of the salt service water pump motors would provide the best possible indication of pump mechanical and pump bearing condition. The proposed alternate testing a
should provide an indication of pump operability and degradation as required by the Code and, therefore, relief should be granted.
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2.5 Standby Liouid Control Pumps' 2.5.1 Relief Request The licensee has requested relief from the requirement of Section XI, Paragraph IWP-3500(a), of running the standby liquid control pumps for five .
minutes during testing prior to measuring the Code specified parameters and proposed to run the pumps for three minutes during testing. ,
2.5.1.1 Licensee's Basis for Requesting Relief. The standby liqaid control pumps are tested by pumping demineralized water into a test tank.
The tank capacity does not allow operation of the pumps for longer than three minutes, therefore the pumps will be run for three minutes during testing.
2.5.1.2 Evaluation. The reviewer agrees with the licensee's basis and therefore, relief should be granted from the Section XI requirement of running the standby liquid control pumps for 5 minutes during the pump testing. The licensee has demonstrated that the only flow path available to test these pumps is into a test tank that has a capacity that will only allow operation of the pumps for three minutes. Operating the pumps for greater than three minutes using the test flow path could result in overfilling the test tank. ,
2.5.1.3 Conclusion. The reviewer concludes that the licensee's proposal of running the standby liquid contr<al pumps for three minutes should provide test conditions sufficiently stable to produce representative test data. The proposed alternate testing should provide an indication of pump operability and degradation as required by the Code and, therefore, relief should be granted.
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2.6 Residual Heat-Removal Pumps 2.6.1 Relief Request The licensee h'as requested relief from the requirement of Section XI, i Paragraph IWP-3100, of measuring differential pressure for the residual heat removal, HPCI, RCIC, core spray, and standby liquid control pumps and -
proposed to measure pump discharge pressures to determine pump performance.
2.6.1.1 Licensee's Basis for Requesting Relief. Discharge pressure will be used when determining acceptable performance instead of differential pressure. Inlet pressure will be controlled to ensure repeatability. Use of discharge pressure will simplify the pump acceptance
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2.6.1.2 Evaluation. The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the Section XI requirement of measuring pump differential pressure for the residual heat removal, HPCI, RCIC, core spray, and standby liquid control pumps. The
- licensee has not provided a justification of why the Code required measurements cannot be taken for these pumps, nor have they provided additional information to demonstrate the adequacy of their proposed alternate testing.
2.6.1.3 Conclusion. The reviewer concludes that the licensee should 2
measure or calculate pump differential pressure as required by the Code for the residual heat removal, HPCI, RCIC, core spray, and standby liquid control pumps.
2.7 Diesel Oil Transfer Pumps
= 2.7.1 Relief Request The licensee has requested relief from the requ'.rement of Section XI, Paragraph IWP-3100, of measuring inlet, pressure, differential pressure, flow rate, vibration, and bearing temperature for the diesel oil transfer 13 m -u-i---y -, _. - . - , ,_- , ,p- -.,--- , ,m y. ,7 7p ,-p.v. ,, p: ,q ,,9y
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pumps and proposed to verify proper pump operation by checking that the j transfer pump refills the day tank during the diesel operability tests.
2.7.1.1 Licensee's Basis for Requesting Relief. Discharge pressure or flow rate cannot be centrolled to the point of insuring repeatability of the reference test quantity. Pump startup is initiated automatically when ,
the oil level drops below the low level set point in the day tank during the diesel operability. tests. When the high level set point is reached the ,
pump shuts off.
Because the mass of the pump housing and impeller is small relative to the connecting pipes, it is the opinion of PNPS that vibration measurements would be highly susceptible to spurious vibrations and therefore meaningless for the prediction of pump degradation.
No instrumentation is installed to measure fluid temperature. During the diesel operability tests, the refilling of the day tank will be verified in conjunction with procedure 8.9.1. This operability test is performed on a monthly basis.
2.7.1.2 Evaluation. The reviewer does not agree with the licensee's basis and, therefore, permanent relief should not be granted from the requirements of Section XI, Table IWP-3100-1, to measure inlet pressure, bearing temperature, vibration, flow and dif ferential pressure during pump tests. The NRC staff has determined that the test quantities identified in Table IWP-3100-1 should be measured for these pumps in order to provide reasonable assurance of their continuing operational readiness.
2.7.1.3 Conclusion. The reviewer concludes that the licensee should measure all of the code required parameters for the diesel oil transfer pumps. 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 the licensee. Requiring the licensee to make these modifications prior to the next refueling outage would impose 14
unnecessary hardship on the licensee without 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 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.
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- 3. VALVE TESTING PROGRAM-The Pilgrim Nuclear Power Station IST orocram submitted by Boston Edison Company was examined to verify that all valves included in the program and are subjected to the periodic tests required by the ASME "
Code,Section XI, and the NRC positions and guidelines. The reviewer found that, except as noted in Appendix 0 or where specific relief from testing ,
has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines summarized in Appendix A of this report.
Each Boston Edison Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request are summarized below and grouped according to system and valve category.
3.1 General Relief Requests 3.1.1 Stroke Time Measurements for Rapid Acting Valves 3.1.1.1 Relief Request. The licensee has requested relief from the Section XI stroke time trending and corrective action requirements
[ Paragraph IWV-3417(a)] for solenoid actuated valves that have stroke time limits of 2 seconds or less, and proposed to perform corrective action on these valves only when the stroke time limits are exceeded.
3.1.1.1.1 Licensee's Basis for Requesting Relief--These valves are designed to be rapid acting and have stroke times that are extremely short. Since these valves stroke so fast it is difficult to time them accurately and any deviation in trended time could be due to reaction time of the individual performing the testing rather than to any change in the valve stroke time. Because of the rapid action of these valves the stroke times will not be trended or recorded but a two second acceptance limit will be used. '
3.1.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirements for solenoid valves whose stroke time limit is 2 seconds or less. The licensee has shown that it is not practical to obtain accurate-16
- measurements of the stroke times.for these rapid acting solenoid actuated valves. There are many factors, including the _ response time of the individual performing the testing, that could produce substantial variations in valve stroke times-from one test to the next. Therefore, the 50% increase criterion is not practical for valves with stroke time limits f of 2 seconds or less.
- 3.1.1.1.3 Conclusion--The reviewer concludes that it is not I practical to trend the stroke times of rapid acting power operated valves and that the licensee's proposal of assigning a limiting value of
! full-stroke time of 2. seconds to these valves and performing corrective action if the measured stroke time exceeds that limit is in conformance with the NRC staff's position on rapid acting valves (Refer to Appendix A, Item 8.). The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and relief should be granted.
3.1.2 Fail-Safe Testing of Valves 3.1.2.1 Relief Request. The licensee has requested relief.from the-requirements of Section XI, Paragraph IWV-3415, of performing a specific fail-safe test for all solenoid operated or controlled valves in the Pilgrim IST program and proposed that the norma _1 exercising of these valves tests their fail-safe function.
3.1.2.1.1 Licensee's Basis for Requesting Relief--De-energizing the solenoid valve has the same effect as loss of electrical power.
Therefore, stroking the valve from the control room to its fail-safe l position constitutes a fail-safe-test (FST). No additional testing is ,
j necessary, i
. 3.1.2.1.2 Evaluation--The reviewer agrees with the licensee that no specific fail-safe testing need be performed on solenoid operated or controlled valves since normal operation of these valves during testing de-energizes the solenoids, thereby, causing the valves to go to their fail-safe positions. The licensee has demonstrated that placing the valve l
I 17
control switch to the position that causes a solenoid operated valve or a solenoid controlled air operated valve to move to its fail-safe position )
constitutes a fail-safe test since it removes power from the solenoid in the same manner as would a ' ass of power from the power supply.
3.1.2.1.3 Conclusion--The reviewer concludes that the licensee's ~
proposal of verifying that fail-safe valves go to their fail-safe position when the solenoids are de-energized by placing the valve control switches ,
in the appropriate positions, meets the Code requirements for fail-safe-testing. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.1.3 Corrective Actions for Individual Valve Leakage Rates 3.1.3.1 Relief Request. The licensee has requested relief from the Section XI leakage rate trending and corrective action requirements, Paragraphs IWV-3426 and 3427, for all systems penetrating primary containment, and proposed to use the total leakage criteria per the plant Technical Specifications.
3.1.3.1.1 Licensee's Basis for Requesting Relief--The -Type C test leakages from all containment isolation valves are summed and added to the leakage from all Type B tests. This total leakage is compared to 0.6Lp where Lpis defined in Technical Specifications Section 4.7.A.b.
Along with the above maximum allowable leak rate, no isolation valve
] leakage can exceed 0.05L to where L to = 0.75Lp . The main steam isolation valve leakage cannot exceed 11.5 SCFH (0.192 SCFM).
Comparing the two leakage criteria, the 0.6Lp criteria is approximately seven times more restrictive than the 0.05L to maximum leakage criteria, when the 0.05L to leakage is summed for all isolation '
valves.
18
1 4
Given the conservatism of the 0.6L p criteria and the requirements of the 0.05L to criteria, no further ASME test requirements as described in l
IWV-3427 are necessary to ensure the leakage integrity of the containment )
isolation valves. l 3.1.3.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the requirements of IWV-3426 and 3427 of Section XI. The licensee has stated that both the total leakage rate and individual isolation valve leakage rates will be evaluated to insure that they are below the specified limits, however the proposed testing does not conform with Code requirements for corrective actions to be taken if the individual valve leakage rates become excessive (refer to Section 3.1.5).
3.1.3.1.3 Conclusion--The reviewer concludes that the licensee's proposed alternate testing does not meet the corrective action requirements of Section XI, IWV-3427 and the proposed alternate testing may not result in corrective action being taken when an individual valve leakage rate becomes excessive. The licensee should comply with the requirements of IWV-3427 to assure the leak tight integrity of each individual containment isolation valve.
3.2 Reactor Building Closed Cooling Water System 3.2.1 Category A Valves 3.2.1.1 Reifef Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 4002, isolation valve for the reactor building closed cooling water supply to the drywell, and proposed to exercise this valve and measure the stroke time during refueling outages.
c 3.2.1.1.1 Licensee's Basis for Requesting Relief--Valve 4002 isolates RBCCW cooling water supply to the drywell. Equipment cooled by this supply is all drywell area coolers and reactor recirculation pump seal coolers and reactor recirculation pump lube oil coolers.
19
.. . = - - _. _. - . - - -
y Based on the equipment serviced by this valve, stroke testing
-quarterly during normal operation could result in loss of cooling to the-recirc pump seals cooler and the recirc pump lube oil coolers with a consequent loss of forced circulation to the reactor and possible damage to major equipment, or loss of drywell cooling resulting in unnecessary high drywell temperature and pressure that would. lead to an unnecessary containment isolation and scram.
Based on equipment serviced by this-valve, stroke testing at cold ,
shutdown could result in securing operation of the reactor recirculation pumps due to loss of pump oil and seal cooling. This is detrimental
}- because even though the moderator temperature.is less than 212*F, the recirculation system is usually kept in operation during cold shutdown to
! provide mixing of the reactor coolant to prevent reactor vessel temperature
) stratification. The reactor vessel temperature profile takes on increasing temperature gradient between the bottom vessel head'and the shutdown core when mixing (forced circulation) is stopped. Additionally, the' water in the idle recirculation loops cools down. This stratification can have the following adverse effects: reactor vessel' temperatures become greater between vessel bottom to top resulting in unnecessary thermal cycling, startup of the shutdown recirculation pumps can cause-a cold water
, intrusion affecting reactor vessel metal temperatures. Deliberate stopping and starting of the recirculation pumps and/or recirc pump motor generators
! creates an unnecessary cycling wear on major equipment important to plant reliability. This valve will be exercised for operability and the stroke time will be measured during refueling outages.
L 3.2.1.1.2 Evaluation--The reviewer agrees with the licensees l basis for not exercising valve 4002 quarterly during power operations or l during cold. shutdowns when the reactor recirculation pumps remain in
, operation; and relief should be granted from the exercising requirements of Section XI for this valve. The licensee has demonstrated that exercising '
l this valve during power operation could result in loss of cooling water to
~
! major plant equipment whose failure could result in a plant power reduction.
q or actuation of a plant ESF. During cold shutdowns when the reactor recirculation pumps remain in operation, exercising this valve could result 20 i
in loss of cooling water to the recirculation pumps, which could result in damage to this equipment. However, during cold shutdowns when the recirculation pumps are secured, there is no justification for not exercising this valve and it, therefore, should be tested in accordance with the Code. This valve will also be exercised during refueling outages.
3.2.1.1.3 Conclusion--The reviewer concludes that exercising-this valve during cold shutdowns when the reactor recirculation pumps are
~
secured and during refueling outages should provide a reasonable assurance of valve operability. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.2.2 Category A/C Valves 3.2.2.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 30-CK-432, the outboard check valve in the RBCCW supply to the drywell, and i
proposed to verify reverse flow closure of this valve by performing the Appendix J, Type C leak rate test during refueling outages.
3.2.2.1.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be acccmplished by reverse flow testing, which is performed at refueling outages.
3.2.2.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valve 30-CK-432. The licensee has demonstrated that due to the plant design, the only method available to verify closure of this valve is to perform a leak rate test and this will be accomplished in conjunction with the Appendix J, Type C leak rate test during each refueling outage.
~
3.2.2.1.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when-21
. . . -. _= -_. . . .
performing the-Appendix J leak rate test during refueling outages is' acceptable. The proposed alternate testing should provide an' indication of*
valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.2.3 Category B Valves 3.2.3.1 Relief Request. The licensee has requested relief from the ,
exercising requirements of Section XI, Paragraphs IWV-3400 and.-3500, for l
4085A and B, the reactor building closed cooling water A=1oop-isolation l valves, and proposed to exercise these valves and measure their stroke times during refueling outages.
! 3.2.3.1.1 Licensee's Basis for Requesting Relief--Valves 4085 A I
and B are the A Loop RBCCW non-safety equipment isolation valves. Although the cooled equipment is classified as having a non-safety function, the equipment is not without importance. Equipment cooled by this branch
! includes the reactor recirculation pump motor generation set fluid coupling
, oil coolers and bearing coolers.
Based on the equipment serviced by these valves, stroke testing quarterly during normal operation could result in loss of cooling to the recire pump motor generation set fluid coupling oil coolers and bearir.g coolers with a consequent loss of forced circulation to the reactor and I
possible damage to major equipment.
4 Based on equipment serviced by these valves, stroke testing at cold shutdown could result in securing operation of the reactor recirculation pumps due to loss of MG set cooling. This is detrimental because even-though the moderator temperature is less than 212'F, the recirculation system is usually kept in operation during cold shutdown to provide mixing of the reactor coolant to prevent reactor vessel temperature -
stratification. The reactor vessel temperature profile takes on increasing
~
i temperature gradient between the bottom vessel head and the shutdown core when mixing (forced circulation) is stopped. Additionally, the water in the idle recirculation loops cools down. This stratification can have the 22 i
following adverse effects: reactor vessel temperatures become greater between vessel bottom to top resulting in unnecessary thermal cycling, startup of the shutdown recirculation pumps can cause a cold water intrusion affecting reactor vessel metal temperatures. Deliberate stopping and starting of the recirculation pumps and/or recirc pump motor generators creates an unnecessary cycling wear on major equipment important to plant reliability. These valves will be exercised for operability and the stroke times will be measured during refueling outages.
3.2.3.1.2 Evaluation--The reviewer agrees with the licensees basis for not exercising valves 4085A and B quarterly during power operations or during cold shutdowns when the reactor recirculation pumps remain in operation, and relief should be granted from the exercising requirements of Section XI for these valves. The licensee has demonstrated that exercising these valves during power operation could result in loss of cooling water to major plant equipment whose failure could result in a plant power reduction. During cold shutdowns when the reactor recirculation pumps remain in operation, exercising these valves could result in loss of cooling water to support equipment for the recirculation pumps, which could result in damage to this equipment. However, during cold shutdowns when the recirculation pumps are secured, there is no justification for not exercising these valves and they, therefore, should be tested in accordance with the code. These valves will also be exercised during refueling outages.
3.2.3.1.3 Conclusion--The reviewer concludes that exercising these valves during cold shutdowns when the reactor recirculation pumps are secured and during refueling outages should provide reasonable assurance of valve operability. The proposed alternate testing should provide an indication of valva 'g rability and degradation as required by the Code and, therefort, relief should be granted.
3.2.3.2 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 4009A and B, the reactor building closed cooling water B loop isolation valves, and proposed to exercise these valves and measure their stroke times during refueling outages.
23
3.2.3.2.1 Licensee's Basis for Requesting Relief--Valves 4009A and B are the B Loop RBCCW non-safety equipment isolation valves. Although classified as non-safety function, the equipment is not without major importance. Equipment cooled in this branch includes reactor water cleanup non-regenerative heat exchanger, 8 fuel pool cooling heat exchanger, reactor water cleanup system, recirculation pump coolers A and B, control
~
rod drive pump A and B thrust bearing coolers and, since valve 4002 is on a branch line downstream of 4009A, all drywell equipment described in ,
Section 3.3.1.1.2 for Valve 4002.
Based on the equipment serviced by these valves, stroke testing quarterly during normal operation could result in loss of cooling to the recirc pump seals cooler, recirc pump lube oil coolers and recirc pump motor and consequent loss of forced circulation to the reactor and possible damage to major equipment, and loss of drywell cooling resulting in unnecessary high drywell temperature and pressure that would lead to an unnecessary containment isolation and scram.
Based on equipment serviced by these valves, stroke testing at cold shutdown could result in securing operation of the reactor recirculation pumps due to loss of pump oil and seal cooling. This is detrimental because even though the moderator temperature is less than 212 F, the recirculation system is usually kept in operation during cold shutdown to provide mixing of the reactor coolant to prevent reactor vessel temperature stratification. The reactor vessel temperature profile takes on increasing temperature gradient between the bottom vessel head and the shutdown core when mixing (forced circulation) is stopped. Additionally, the water in the idle recirculation loops cools down. This stratification can have the following adverse effects: reactor vessel temperatures become greater between vessel bottom to top resulting in unnecessary thermal cycling, startup of the shutdown recirculation pumps can cause a cold water intrusion affecting reactor vessel metal temperatures. Deliberate stopping
- and starting of the recirculation pumps and/or recirc pump motor generators creates an unnecessary cycling wear on major equipment important to plant reliability. These valves will be exercised for operability and the stroke times will be measured during refueling outages.
24
3.2.3.2.2 -Evaluation--The reviewer agrees with the licensees basis for not exercising valves 4009A and B quarterly during power operations or during cold shutdowns when the reactor recirculation' pumps remain in operation, and relief should be granted from the exercising requirements of Section XI for these valves. The licensee has demonstrated that exercising these valves during power operations could result in~ loss of cooling water to major plant equipment whose failure could result in a plant power reduction or actuation of.a plant ESF. During cold shutdowns when the reactor recirculation pumps remain in operation, exercising these ,
valves could result in loss of cooling water to the recirculation pumps or to support equipment for the recirculation pumps, which could result in damage to this equipment. However, during cold shutdowns when the
! recirculation pumps are secured, there is no justification for not
, exercising these valves and they, therefore, should be tested in accordance with the Code. These valves will also be exercised during refueling outages.
3.2.3.2.3 Conclusion--The reviewer concludes that exercising these valves during cold shutdowns when the reactor recirculation pumps are secured and during refueling outages should provide a reasonable assurance of valve operability. The proposed alternate testing should provide an
]
j indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.3 Compressed Air System 3.3.1 Category A/C Valves 3.3.1.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for i
31-CK-167 and proposed to verify reverse flow closure of this valve by performing the Appendix J, Type C leak rate test during refueling outages.
3.3.1.1.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing, which is performed at refueling.
25
- - - ~ -
, ,,a _ , . . - - - - . _ .---n-,u. , . , - . .,.e,, , , we r - ,n
3.3.1.1.2 -Evaluation--The reviewer agrees with the licensee's-basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valve 31-CK-167. The licensee has demonstrated that due to the plant design, the only method available to verify closure of this valve is to perform a ' leak rate test.
3.3.1.1.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing ,
a leak. test, the licensee's proposal of exercising this valve closed.when performing the Appendix J 1eak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4 Containment Atmosphere Control System 3.4.1 Cg egory A Valves 3.4.1.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for CV-5046, isolation valve .in the air supply line to the drywell to torus vacuum breaker, and proposed to verify closure of this valve by performing the Appendix J, Type C leak rate test during refueling outages.
3.4.1.1.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing, which is performed at refueling. Also, there is no means to measure valve closure time for CV-5046.
3.4.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valve CV-5046. The licensee has
- demonstrated that due to the plant design, the only method available to
~
verify closure of this valve is to perform a leak rate test. Valve design and construction do not permit measurement of the valve stroke times.
i l
26
3.4.1.1.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a' leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J leak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4.2 Category A/C Valves 3.4.2.1 Relief Request. The licensee has requested relief from the leak rate test requirements of Section XI, Paragraph IWV-3420, for A0-5045A, B, C, D, E, F, G, H, J, and K, the pressure suppression chamber to drywell vacuum breaker valves, and proposed to demonstrate the leak tightness of these valves by performing a pressure decay test in accordance with Pilgrim Technical Specification 4.7.A.4.b.
3.4.2.1.1 Licensee's Basis for Requesting Relief--A specific maximum leakage per valve is not applicable to the vacuum breaker valve testing. A pressure decay test is performed on the pressure suppression chamber atmosphere in accordance with Technical Specification Section 4.7.A.4.b on a quarterly basis. This pressure decay test demonstrates the leak tightness of the vacuum breaker valves.
3.4.2.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the leak rate test requirements of Section XI for the pressure suppression chamber to drywell vacuum breaker valves. These valves cannot be individually leak rate tested due to the system design since they relieve the vacuum in the drywell downcomers from the suppression chamber and the pressure is common for all valves in both the drywell and the suppression chamber. The
- licensee will perform a pressure decay test quarterly to test the leak tightness of these valves.
3.4.2.1.3 Conclusion--The reviewer concludes that the licensee's proposal of demonstrating leak tightness of the drywell vacuum breaker 27
valves by performing the testing of Technical Specification 4.7.A.4.b -
should provide a reasonable assurance of the ability of these valves to perform their safety function in the closed position. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4.2.2 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for ,
9-CK-340 and-341, containment isolation valves on-the nitrogen makeup line to the drywell and torus, and proposed to verify reverse flow closure of these valves by performing the Appendix J, Type C leak rate test during refueling outages.
3.4.2.2.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing,.which is performed at refueling.
3.4.2.2.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valves 9-CK-340 and 341. The licensee has demonstrated that due to the plant design, the only method available to verify closure of these valves is to perform a leak rate test.
3.4.2.2.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J leak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of-valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4.2.3 Relief Reouest. The licensee has requested relief from the -
exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for
~
9-CK-353, the check valve that serves as the isolation valve for the TIP purge system, and proposed to verify reverse flow closure of this valve by performing the Appendix J, Type C leak rate test during refueling outages.
28
3.4.2.3.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing, which is performed at refueling.
3.4.2.3.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising
~
requirements of Section XI for check valve 9-CK-353. The licensee has demonstrated that due to the plant design, the only method available to verify closure of this valve is to perform a leak rate test.
3.4.2.3.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J leak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4.2.4 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 31-CK-434, check valve in the air supply line to the drywell to torus vacuum breaker, and proposed to verify reverse flow closure of this valve by performing the Appendix J, Type C leak rate test during refueling outages.
3.4.2.4.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing, which is performed at refueling.
3.4.2.4.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valve 31-CK-434. The licensee has
. demonstrated that due to the plant design, the only method available to verify closure of this valve is to perform a leak rate test.
3.4.2.4.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing 29
a-leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J leak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.4.3 Category C Valves 3.4.3.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 31-CK-430A and B, the check valves in the air supply lines to the accumulators for the torus to reactor building vacuum breaker block valves, and proposed to exercise these valves during refueling outages.
3.4.3.1.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by disassembling a portion of the air supply system. Therefore, exercise tests can only be performed during reactor refueling.
3.4.3.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valves 31-CK-430A and B. The licensee has shown that there are no test connections that permit verifying closure of these valves without disassembling a portion of the air supply system.
The air system can only be disassembled for valve testing during refueling outages.
3.4.3.1.3 Conclusion--The reviewer concludes that the licensee's proposal of verifying valve closure by disassembling a portion of the air supply system during refueling outages should provide reasonable assurance of valve operability. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code
- and, therefore, relief should be granted.
l
- 30 l
t
3.5 Core Spray System 3.5.1 Category C Valves 3.5.1.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for
~
1400-9A and 9B, the core spray injection check valves, and proposed to
' exercise these valves during refueling outages. l 4 3.5.1.1.1 Licensee's Basis for Requesting Relief--Testing these valves during normal operation would require injecting cold water into the reactor vessel using the core spray system. This would result in both a reactivity excursion and thermal shock to the reactor vessel and spray sparger. The thermal shock condition can also exist during cold shutdown when the vessel metal temperature is above 212'F.
3.5.1.1.2 Evaluation--The reviewer agrees with the licensee's basis for not exercising check valves 1400-9A and 9B quarterly during power operations and, therefore, relief should be granted from the quarterly exercising requirements of Section XI for these valves. The licensee has demonstrated that exercising these valves with flow would require injecting cold water into the reactor vessel which would cause a reactivity
+
excursion; it would also thermal shock the reactor vessel and the spray sparger, possibly damaging or reducing the expected service life of these components. The reviewer does not agree with the licensee's basis for not exercising these valves during cold shutdowns, therefore, the licensee should full-stroke exercise these valves during cold shutdowns when the reactor vessel temperature is below 212 F and during refueling outages.
3.5.1.1.3 Conclusion--The reviewer concludes that valves 1400-9A and 9B should not be exercised quarterly during power operations, however, the licensee should exercise these check valves during cold shutdowns when the reactor vessel temperature is below 212 F and during refueling outages. This alternate testing should provide reasonable assurance of valve operability and an indication of valve degradation as required by the Code and, therefore, relief should be granted from the quarterly exercising i requirements of the Code.
31
, - - , - v,, , , , - - - - --
, , . . . - .- - . , - , - - . . - - . . . . . , - . . - . - - - ----w n. w --.=< ,
3.6 High Pressure Coolant Injection System (HPCI) 3.6.1 Category B Valves 3.6.1.1 Relief Request. The licensee has requested relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413, for
~
2301-24, the HPCI turbine throttle valve, and proposed to verify proper operability of this valve by observing its response during the performance ,
of the HPCI system tests quarterly.
3.6.1.1.1 Licensee's Basis for Requesting Relief--The purpose of this valve is to regulate steam to the HPCI Turbine. Operability of this valve is adequately demonstrated by turbine operation. Valve position is steam line pressure dependent and therefore will not repeatedly throttle to i the same position. During turbine operation, this valve moves in response to control signals. Proper response of the valve will be verified by performing the HPCI system test.
3.6.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring the stroke times for throttle valve 2301-24. The licensee has demonstrated that this valve is a control valve that moves in response to control signals. The turbine throttle valve does not have control circuitry or mechanisms which permit stroking the valve to the fully open position, and fully opening the valve could result in a turbine overspeed. The valve operation will be observed during the HPCI system i tests.
i 3.6.1.1.3 Conclusion--The reviewer concludes that the licensee's proposal of verifying proper response of valve 2301-24 by performing the HPCI system test quarterly, should provide a reasonable assurance of valve.
operability. The proposed alternate testing should provide an indication
- of valve operability and degradation as required by the Code and, therefore, relief should be granted.
32
[
l l
., .-nc ---n--- -
-n -,n. .- ,_ - , . , --
j 3.6.1.2 Relief Request. The licensee has requested relief from the stroke time measurement' requirement of Section XI, Paragraph IWV-3413, for A0-9313, isolation valve in the nitrogen.. supply line to the HPCI turbine
, exhaust line, and proposed to exercise this valve during the HPCI operability tests every quarter but not measure the valve stroke times.
i 3.6.1.2.1 Licensee's Basis for Requesting Relief--Both A0-9312 and A0-9313 operate in tandem and provide isolation of the nitrogen supply j system. A0-9313 is in the IST program because the ISI boundary stops at this valve. There is no direct method for confirming that A0-9312 and
, A0-9313 close. If these valves do not close properly, primary containment f pre'ssure will slowly increase. An increase in containment. pressure will be
- detected by the primary containment monitoring system.
} These valves will be exercised during the HPCI operability tests every quarter. No increase in primary containment pressure following the HPCI operability tests implies that these valves have closed properly. Valve
{
stroke times will not be measured.
3.6.1.2.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the stroke time measurement requirement of Section XI, Paragraph IWV-3413, for valve t
A0-9313. The licensee has stated that there is no means to determine the time when this valve closes and, therefore, the valve stroke time cannot_be i measured. The valve will be exercised quarterly during the HPCI tests and valve closure will be determined by observing that containment pressure does not increase after the HPCI test.
l
. 3.6.1.2.3 Conclusion--The reviewer concludes that the licensee's proposal to exercise this valve quarterly during the HPCI operability tests should provide a reasonable assurance of valve operability as required by
. the Code and, therefore, relief should be granted.
I t ,
1 l '
i 33 ,
s
. - - _ _ _ _ _ , _ ~ . . . _ - - , .
, - , _ - _ - - , - _ , ,/,~ ,J - _--
3.6.2 Category C Valves 3.6.2.1 Relief Request. The licensee has requested relief from the I exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for testable check valve 2301-7, the HPCI injection header check valve, and proposed to manually full-stroke exercise this valve during refueling .
outages.
3.6.2.1.1 Licensee's Basis for Requesting Relief--Testing this valve during normal operation would require injecting cold water into the reactor vessel using the HPCI system. This would result in both a reactivity excursion and thermal shock to the feedwater nozzle and piping.
The thermal shock condition can also exist during cold shutdown when the vessel metal temperature is above 212 F.
The valve has been replaced with a valve that is manually stroke testable. The valve can be tested by manual stroke only if the pressure across the valve is equal as there is a maximum recommended torque from the manufacturer. Baseline tests after valve replacement were performed with zero pressure difference across the valve. The only time that such zero pressure differential can be obtained is when the plant is shutdown and the HPCI and feedwater lines are drained to relieve static head. This condition is achievable only during refueling outages.
The valve will be exercised for operability during reactor refueling by manual stroke test per IWV-3522. Valve closure is verified as part of the exercise test, the valve is manually opened then manually closed.
3.6.2.1.2 Evaluation--The reviewer agrees with the licensee's basis for not exercising this valve during power operation and, therefore, relief should be granted from the quarterly testing requirement of Section XI for valve 2301-7. Exercising this valve during normal operation
- cannot be performed utilizing the test operator since the differential
~
pressure across the valve would be too great for the operator to overcome.
The valve cannot be exercised with flow during power operations because this could result in thermal shock and a reactivity excursion. The 34
y_ ,
t !
licensee's basis for not exercising the valve using the test operator-during cold shutdowns is not considered to be an adequate technical justification and, therefore, relief should not be granted from the i
Section XI requirement of exercising this valve during cold shutdowns.
3.6.2.1.3 Conclusion--The reviewer concludes that check valve 2301-7 should be full-stroke exercised utilizing the valve test operator-during cold shutdowns. A new baseline test should be taken with the plant in a cold shutdown lineup and this test data should be used for Code testing purposes. Exercising this valve during cold shutdowns with the test operator.should provide a reasonable assurance of valve operability a 'and an indication of valve degradation as required by the Code.
3.6.2.2 Relief Request. The licensee has requested relief from the i exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 2301-45, the HPCI turbine exhaust line check valve, and proposed to '
I exercise this valve during refueling outages.
3.6.2.2.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by back pressure testing, which-is performed at refueling.
3.6.2.2.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valve 2301-45. -The only method to verify closure of this valve is by performing a valve leak test. This valve is exercised open quarterly during the HPCI tests but is verified in the closed position during refueling outages.
3.6.2.2.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing
) . a leak test, the licensee's proposal of' exercising this valve closed when I performing the Appendix J leak rate test during refueling-outages is j'- acceptable. The proposed alternate testing should provide an indica, tion of j valve operability and degradation as required by the Code and, therefore, relief should be granted.
l 35 1
-. . . ~ - , - - _ - , , - , , - - - , , _ ,
~
3.6.2.3 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 2301-39, a check valve in the HPCI pump suction line from the suppression pool, and proposed to exercise this valve during refueling outages.
3.6.2.3.1 Licensee's Basis for Requesting Relief--During the .
HPCI pump operability tests, water is taken from the condensate storage tank and not the suppression pool. Therefore, disk movement cannot be _,
confirmed by flow verification every quarter.
HPCI valve 2301-39 is a 16" swing check valve located in the suction line from the torus to the HPCI pump suction. ASME Section XI IWV-3520'is
" Tests for Check Valves." It allows a free flow test to be used to show the valve is functional. The valve will be fully open with sufficient flow to develop 1/2 psi of pressure drop through the valve. The Vendor believes that the 600 gpm test using the 4" minimum recirculation of the torus during the test will open the valve, and it is adequate to say the valve is functioning. 'Ji ussembly and/or measuring torque on the shaft is not necessary if a flow test is done.
It should be noted that 2301-39 is or.e of the 4 valves in the torus suction line. There are 2 motor-operated valves and another check valve.
2301-39 is located between the two motor (perated valves and is not a boundary valve that requires specific low leakage requirements. Therefore, the Section XI test to show the valve functions may be met with a flow test.
Additionally; the logic associated with the system is that HPCI suction is normal:y from the CST via 2301-6. Upon signals of either low
~
CST level or h'igh torus level, valves 2301-35 and 36 open. When 2301-35 and 36 are full open, then 2301-6 closes. Additionally, with this logic, the HPCI test valves 2301-10 and 2301-15 gef. a closure signal and the injection valves 2301-9 and 2301-8 receive opening signals. Since this
- logic is part of engineered safeguards, a deliberate circumvention is not prudent, therefore testing should be performed when a logic override is not required. Such a condition occurs at low reac;or pressures when the HPCI turbine driven pump can be readily and safely operated on the minimum flow line. This test condition is at initial cycle startup after a refueling.
36
- - - - - ~w
3.6.2.3.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising requirements of Section XI for valve 2301-39. The licensee has demonstrated that this valve cannot be exercised during power operation without overriding engineered safeguards logic circuits which is undesirable. The licensee did not provide an adequate justification for not exercising this valve using the 4 inch minimum recirculation flow path during cold shutdowns. The licensee also did not provide adequate information to show that their proposed testing during refueling outages' constitutes a full-stroke exercise of this value. The NRC staff's position is that a check valve is full-stroke exercised with flow when either the maximum flow rate identified in any of the plants safety analyses.is verified through the valve or when sufficient flow is established through the valve to fully open the valve disk and the differential pressure is measured across the valve (Refer to Appendix A, Item 1.). The licensee's proposed test will establish 600 gpm through the valve which is only approximately 14% of the 4250 gpm design flow rate of the HDCI pump. The reviewer also questions whether a 1/2 psi differential pressure across the valve would be sufficient to fully open a 16 inch swing check valve. More valve technical information is required and a measurement of differential pressure across the valve during every test would be necessary before the reviewer could recommend granting relief for a full-stroke exercise of this valve at a reduced valve flow rate.
3.6.2.3.3 Conclusion--The reviewer concludes that the licensee should perform a partial-stroke exercise of this valve during cold shutdowns by establishing flow through the valve and through the minimum recirculation line to the torus. The licensee should also full-stroke exercise this valve during refueling outages by some means such as a disassembly, inspection and manual stroke of the valve.
3.6.2.4 Relief Request. The licensee has requested relief from the Section XI, Paragraphs IWV-3400 and -3500, requirement of exercising and checking valve setpoints for VRV-9066, the vacuum relief valve between the HPCI turbine exhaust line and the suppression chamber, and proposed to reevaluate this valve and its function and to either perform system 37
$ modifications or provide analysis to support other testing by the completion-of refueling outage number-7-(RF0 #7).
3.6.2.4.1. Licensee's Basis for Requesting Relief--With respect to.setpoint testing, an attempt was made to setpoint test VRV-9066 during
]
i the 1984 outage.(RF0 #6). Field test teams determined that due to the welded-in configuration and vacuum relief function, the valve was not
- testable by available methods'and criteria. A request for Engineering services was made to evaluate modifying the piping configuration, to provide a flanged connection so that VRV-9066 could be bench tested, or, alternately, to replace VRV-9066 with a new, testable valve. Due to the lead time associated with the modification hardware, it was not practical
! to implement the modification during RF0 #6, and instead, it was' targeted for RF0 #7. -It should be noted, however, that during RFO.#6, VRV-9066 was 1 successfully pressure tested by a Class 2 system hydrostatic test to ensure i
the pressure retaining function of this relief valve. This test gave
! assurance that the relief valve did not compromise the pressure boundary of the HPCI' exhaust line.
1 In parallel with these activities, additional problems, documented in Licensee Reports LER 85-008 and 85-012 (concerning HPCI exhaust line water:
l hammer events) have caused us to reassess, from a broader perspective, the j vacuum relief capability of the HPCI exhaust line. It is our present i judgment that this review will likely make the 1 inch vacuum relief valve
! obsolete, and instead a substantial redesign and upgrading in vacuum relief capacity will be employed. Ultimately, corrective action for testing the vacuum relief function of HPCI shoula Le incorporated into the modification to the exhaust line. Implementation of any such modification will be i
j scheduled per BECO's Long Term Plan; a. feasible schedule for implementing i
such a. modification is RF0 #7. It is also our engineering judgment that the function and setpoint of the existing 1 inch valve is a relatively f minor contributor to the dynamics experienced in the HPCI exhaust line. '
l With respect to quarterly testing, the IST program's testing approach I to VRV-9066 for quarterly operability was to determine that the valve
! relieved vacuum in the exhaust line unless a problem became evident. In 38 l
[
other words, if HPCI successfully operated and met its system flow rate and discharge pressure requirements, the vacuum relief valve was considered successfully tested. With the problems in the exhaust line that became evident in 1985, this approach can no longer be considered valid. There is no installed indication on the vacuum relief valve itself and the use of an audible valve operation technique to verify operation is impractical because of background noise and the valve's physical position. Therefore, based on our recent experiences, it is now our position that stroke testing for VRV-9066 is not practical.
The integrity and operability of the HPCI exhaust line is not compromised. Use of the nitrogen purge system coupled with alarms on the HPCI exhaust rupture disks and exhaust line snubber inspection will continue to monitor the operability of the HPCI exhaust line.
3.6.2.4.2 Evaluation--The reviewer agrees with the licensee that the present system configuration does not allow setpoint testing of this vacuum relief valve. This valve does perform a safety related function of relieving vacuum in the HPCI turbine exhaust line to help reduce the possibility of damaging water hammer. Since no testing can presently be performed on this valve, temporary relief should be granted from the exercising and setpoint requirements of Section XI for VRV-9066. The licensee should perform the necessary valve or system modifications to allow testing of this valve, or of any replacement valve or valves performing this vacuum relief function, before startup from the next refueling outage (RF0 #7). After the startup from RF0 #7, this valve or replacement valves should be tested in accordance with the Code except where specific relief has been requested by the licensee and approved by the NRC.
3.6.2.4.3 Conclusion--The reviewer concludes that temporary relief should be granted from the Section XI testing requirements for VRV-9066 until the startup from RF0 #7 at which time the necessary valve or system modifications should be in place to allow Section XI testing of the valve or valves that perform the HPCI turbine exhaust vacuum relief 39
function. The temporary relief thus granted should not pose any safety problem since the plant is currently shutdown for RF0 #7 and the , identified modifications are in progress.
3.7 Reactor Core Isolation Cooling System (RCIC) 3.7.1 Category B Valves 3.7.1.1 Relief Request. The licensee has requested relief from the stroke time trending requirements of Section XI, Paragraph-IWV-3417(a), for HO-1 and 2, the RCIC turbine trip valve and governor valve, and proposed to verify closure of these valves within 5 seconds of turbine trip during the quarterly RCIC testing.
3.7.1.1.1 Licensee's Basis for Requesting Relief--Both. valves are normally open-fail closed, and are fast acting. The trip and throttle valve must be manually reset after trip. Both valves close as part of normal surveillance testing as part of the shutdown of the RCIC system but are rapid acting and operate simultaneously. This makes timing of each valve difficult and tedious. Since the valves act rapidly it is requested that a flat 5 second closure criteria be applied without trending of stroke time.
We propose to exercise these valves for operability every quarter, verify closure within 5 seconds of turbine trip. No stroke time trending will be performed, individual valve times will not be recorded.
3.7.1.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the Section XI requirement of trending stroke times for HO-1 and 2. As explained in Section 3.2.1 the reviewer does agree that stroke times need not be trended for rapid acting valves, however, the NRC staff has -
identified rapid acting valves as those with time limits of 2 seconds or
~
less.
40 i
3.7.1.'1.3 Conclusion--The reviewer concludes that' the licensee's.
proposed alternate testing is not' acceptable, however, if the licensee established a stroke time limit of 2 seconds for these valves instead of the proposed 5 seconds, then the testing would be considered adequate to give a reasonable assurance of valve operability and provide an indication of valve degradation as required-by the Code and relief.could be granted.
3.7.2 Category C Valves 3.7.2.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, . Paragraphs IW-3400 and -3500, for
! testable check valve 1301-50, the RCIC injection header check valve, and proposed to manually full-stroke exercise this valve.during refueling outages.
3.7.2.1.1 Licensee's Basis for Requesting Relief--Testing this valve during normal operation would require injecting cold water into the reactor vessel using the RCIC system. This would result in'both a reactivity excursion and thermal shock to the feedwater nozzle and piping.
- The thermal shock condition can also exist during cold shutdown when the vessel metal temperature is above 212*F.
i
- The valve has been replaced with a valve that is manually stroke
- testable. The valve can be tested by manual stroke only if the pressure across the valve is equal as there is a maximum recommended torque from the manufacturer. Baseline tests after valve replacement were performed with j zero pressure difference across the valve The only time that such zero pressure differential can be obtained is when the plant is shutdown and the 4
RCIC and feedwater lines are drained to relieve static head. This condition is achievable only during refueling outages. The valve will be exercised for operability during reactor refueling, by manual stroke test
- . per IW-3522. Valve closure is verified as part of the exercise test, the valve is manually opened then manually closed. I i
} 3.7.2.1.2 Evaluation--The reviewer agrees with the licensee's basis for not exercising this valve during power operation and, therefore, 41
relief should be granted from the quarterly testing requirement of Section XI for 1301-50. Exercising this valve during normal operation cannot be performed utilizing the test operator since the differential pressure across the valve would be too great for the operator to overcome.
The valve cannot be exercised with flow during power operations because this would result in thermal shock and a reactivity excursion. The licensee's basis for not exercising the valve using the test operator during cold shutdowns is not considered to be an adequate technical ,
justification and, therefore, relief should not be granted from the Section XI requirement of exercising this valve during cold shutdowns.
3.7.2.1.3 Conclusion--The reviewer concludes that chec'k valve 1301-50 should be full-stroke exercised utilizing the valve test operator during cold shutdowns. A new baseline test should be taken with the plant in a cold shutdown line up and this test data should be used for Code testing purposes. Exercising this value during cold shutdowns with the test operator should provide a reasonable assurance of valve operability and an indication of valve degradation as required by the Code.
3.7.2.2 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 1301-40, 41, 47, and 64, check valves in the RCIC lines to the suppression pool (vacuum pump discharge, turbine exhaust, minimum flow bypass, and turbine exhaust respectively), and proposed to exercise these valves during refueling outages.
3.7.2.2.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by back pressure testing, which is performed at refueling.
3.7.2.2.2 E_ valuation--The reviewer agrees with the licensee's basis and therefore, relief should be granted from the exercising '
requirements of Section XI for check valves 1301-40, 41, 47, and 64 The only method of verifying closure of these valves is by performing reverse flow leak tests on the valves. These valves are exercised open quarterly during RCIC tests but are verified closed during refueling outages.
l 42 1
3.7.2.2.3 Conclusion--The reviewer concludes that since the.only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J 1eak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.7.2.3 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 1301-27, a check valve in the RCIC pump suction line from the suppression pool, and proposed to exercise this valve during refueling outages.
3.7.2.3.1 Licensee's Basis for Requesting Relief--During the 4
RCIC pump operability tests, water is taken from the condensate storage tank and not the suppression pool. Therefore, disk movement cannot be confirmed by flow verification every quarter.
RCIC valve 1301-27 is a 6" swing check valve located in the suction line from the torus to the RCIC pump suction. ASME Section XI IWV-3520 is
" Tests for Check Valves." It allows a free flow test to be used to show the valve is functional. The valve will be fully open with sufficient flow to develop 1/2 psi of pressure drop through the valve. The Vendor believes that the test using the 2" minimum recirculation to the torus during the test will open the valve, and it is adequate to say the valve is functioning. Disassembly and/or measuring torque on the shaft is not necessary if a flow test is done.
It should be noted that 1301-27 is one of the 4 valves in the torus suction line. There are 2 motor-operated valves and another check valve.
1301-27 is located between the two motor operated valves and is not a boundary valve that requires specific low leakage requirements. Therefore, l the Section XI test to show the valve functions may be met with a flow test. I Additionally,thelogicassociatedwiththesystemisthatRCkC suction is normally from the CST via 1301-22. Upon signals of either low l
43 g- - g- --+u..
- 4. , - - . - . , . , , , . - - - . _ . - . ~ . , , , . , , , . , ., ----,-- e-y .--.n w v-.- -. _ _y
CST level or high torus level valves 1301-25 and 26 open. When 1301-25 and 26 are full open, then 1301-22 closes. Additionally, with this logic, the RCIC test valve 1301-53 gets a closure signal and the injection valves 1301-48 and 1301-49 receive opening signals. A deliberate circumvention of the control logic is not prudent therefore testing should be performed when a logic override is not required. Such a condition occurs at low reactor pressures when the RCIC turbine driven pump can be readily and safely operated on the minimum flow line. This test condition is at initial cycle. ,
startup after a refueling.
3.7.2.3.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising requirements of Section XI for valve 1301-27. The licensee has demonstrated that this valve cannot be exercised during power operation without overriding the RCIC control logic, which is undesirable. The licensee did not provide an adequate justification for not exercising this valve using the 2 inch minimum recirculation flow path during cold shutdowns. The licensee also did not provide adequate information to show that their proposed testing during refueling outages constitutes a full-stroke exercise of this valve. The NRC staff's position is that a check valve is full-stroke exercised with flow when either the maximum flow rate identified in any of the plants safety analyses is verified through the valve or when sufficient flow is established through the valve to fully open the valve disk and the differential pressure is measured across the valve. More technical information on the valve is required and a measurement of the differential pressure across the valve during each test would be necessary before the reviewer could recommend granting relief for a full-stroke exercise of this valve based on a reduced flow rate test.
3.7.2.3.3 Conclusion--The reviewer concludes that the licensee should perform a partial-stroke exercise of this valve during cold shutdowns by establishing flow through the valve and through the minimum '
recirculation line to the torus. The licensee should also full-stroke exercise this valve during refueling outages by some means such as a disassembly, inspection and manual stroke of the valve.
44
3.8 Standby Liquid Control System 3.8.1 Category A/C Valve 3.8.1.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 1101-16, a check valve in the standby liquid control header to the reactor pressure vessel, and proposed to exercise this valve during refueling .
outages.
'3.8.1.1.1 Licensee's Basis for Requesting Relief--Testing this valve would require either injection of demineralized water by the standby liquid control system or connection of a test pump to the test connection.
Either of these could render-the standby liquid control system inoperative. This system is required to be operative during normal operation and cold shutdown. This valve is exercised for operability at refueling outages.
3.8.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valve 1101-16. The licensee has demonstrated that it would require disabling the standby liquid control system in order to exercise this valve. The standby liquid control system is required to remain operable during power operations and cold shutdowns, therefore, valve testing can only be performed during refueling outages.
3.8.1.1.3 Conclusion--The reviewer concludes that the licensee's proposal to exercise this check valve during refueling outages when the standby liquid control system can be taken out of service is acceptable.
The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.8.2 Category C Valve 3.8.2.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 45
4 valve 1101-15, a check valve'in the standby liquid control header to the 4
reactor pressure vessel, and proposed to exercise this valve during 4
refueling outages.
i 3.8.2.1.1 Licensee's Basis for Requesting Relief--Testing this valve would require either injection of demineralized water by the standby liquid control system or connection of a test pump to the test connection.
Either.of these could render the standby liquid control ~ system .
inoperative; This system is required to be operative during. normal
- operation and cold shutdown. This valve is exercised for operability at
refueling outages.
I 3.8.2.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising 4 requirements of Section XI for check valve 1101-15. The. licensee has
! demonstrated that it would require disabling the standby liquid control
- system in order to exercise this valve. The standby liquid control system l 1s required to remain operable during power operations and cold shutdowns, therefore, valve testing can only be performed during refueling outages.
e i 3.8.2.1.3 Conclusion--The reviewer concludes that the licensee's l proposal to exercise this check valve during refueling outages should provide a reasonable assurance of valve operability and an indication of f ,
- - valve degradation as required by the Code and, therefore, relief should be
- granted.
! 3.9 CRD Hydraulic System i
3.9.1 Category B Valves l 3.9.1.1 Relief-Request. The licensee has requested relief from j the stroke time measurement requirements of Section XI, Paragraph IWV-3413, -
for the scram discharge volume isolation valves listed below, and proposed
- to measure the stroke time of these valves using electronic means,once per refueling cycle.
1 i
46 1
l
_ , _ , _ _ . , . , , . . . . . , . . . , - - . . . --m- . - . _ . , . _ _ _ _ _ , _ . . . . _ , . . , . . . _ , . . . . _ . . . _ _ . . . _ _ _ _ , _ , - . - - _ _ _ . _ , , . . . , , - _ , _ _ _ _ . . , ,
302-21A 302-22A 302-23A 203-24A 302-21B 302-22B 302-23B 302-24B 3.9.1.1.1 Licensee's Basis for Requesting Relief--Valves are l" solenoid operated valves designed to be rapid acting. They are difficult to time accurately, therefore any deviation in trended time may be due to
- reaction time, rather than valve time. The valves are timed using electronic means once per cycle. The valves are exercised for operability every quarter.
3.9.1.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the Section XI requirement of measuring valve stroke times quarterly. The licensee has demonstrated that these are rapid acting valves that have a maximum stroke time of 2 seconds. The reviewer agrees that relief should be granted from the stroke time trending and corrective action requirements of IWV-3417(a) of the Code (refer to Section 3.1.1 of this report) for rapid acting valves. The licensee proposed to measure stroke times for these valves on a refueling outage frequency, but has not provided the specific technical justifications for not measuring valve stroke times quarterly during power operations or during cold shutdowns.
3.9.1.1.3 Conclusion--The reviewer concludes that not trending the stroke times for these rapid acting valves presents no problem to safety per the discussion in Section 3.1.1. However, the licensee should measure the stroke times of these valves quarterly, when the valves are exercised in accordance with the Code.
3.9.1.2 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for CV-126 and 127 (typical of 145 each), the control rod drive scram inlet and
, exhaust valves, and proposed to test these valves by scram timing control rod drives in accordance with plant Technical Specifications.
3.9.1.2.1 Licensee's Basis for Requesting Relief--These valves operate in coincidence to rapidly insert control rods. Valves will be 47
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tested by SCRAM timing control rod drives in accordance with Technical Specification Section 4.3. This-requires testing of 50% of the drives
- every 16 weeks and 100% every 32 weeks. Additionally, 100% of the drives are tested each shutdown. Timing of the SCRAM function will be substituted for individual valve times.
3.9.1.2.2 Evaluation--The reviewer agrees with the licensee's i basis and, therefore, relief should be granted from the exercising- ,
requirements of Section XI for the CV-126 and 127 valves. Exercising "these valves would insert or scram the affected control rod which would result in i a reduction in reactor power. It.is not practical to scram eac
- the 145 l.
control rods quarterly to exercise these valves. The licensee has stated l that 50% of the control rod drives are tested every 16 weeks and 100% are tested every 32 weeks, also 100% of the drives are tested every shutdown.
These valves are constructed in such a manner that the stroke times cannot
! be readily measured, therefore, the licensee has proposed to measure the
- scram times for the control rods which is indicative of proper stroke times
! for the CV-126 and 127 valves. Valve degradation would show up in
- increased rod scram times.
3.9.1.2.4 Conclusion--The reviewer concludes that the licensee's
- proposal to exercise the CV-126 and 127 valves by performing the Technical i Specification control rod scram tests on 50% of the control rod drives every 16 weeks and 100% every 32 weeks should provide a reasonable assurance of valve operability. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
j 3.9.2 Category C Valves i
f 3.9.2.1 Relief Reouest. The licensee has requested relief from the
{ exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for
- j CRD hydraulic control unit valve number 138 (typical of 145 valves), the CRD cooling water check valves, and proposed to test these valves by
, performing the scram tests of the control rod drives in accordance with the i
plant Technical Specifications.
48 l
l
3.9.2.1.1 Licensee's Basis for Requesting Relief--Failure of these valves to seat in the reverse direction would result in the loss of scram insertion water flow. They are therefore indirectly tested with control rod scram testing per Technical Specification 4.3. Individual testing of these check valves during operation would necessitate isolation of control rod drive cooling water. This. action could result in overheating of the CRD seals and lead to scram timing problems and position control problems. These valves will be tested in conjunction with the control rod scram tests per Technical Specification Section 4.3.
I 3.9.2.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the 1
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Section XI exercising requirements for the HCU 138 valves. The licensee l has demonstrated that exercising.these valves would require isolation of j CRD cooling which would result in loss of cooling water to the CRD seals which could result in damage to the seals. The reviewer agrees that CRD seal cooling water flow should not be interrupted during power operations j or cold shutdowns when seal damage may occur. The licensee did not provide i any technical basis that supports their contention that the technical l specification testing exercises and verifies closure for the HCU 138 valves
] .
per the Code. The reviewer feels that the proposed alternate testing may not verify closure of the 138 valves, since the scram tests are performed ~
I with the cooling water header pressurized, the valves could be sticking open and yet the scram times could still meet the technical specification l limit because there may be insufficient differential pressure to divert a significant amount of insertion water away from the CRDs.
3.9.2.1.3 Conclusion--The reviewer concludes that the licensee j should verify closure of these valves on at least a refueling outage frequency. Relief should be granted from verifying valve closure during l i j power operations and cold shutdowns since it requires isolating CRD cooling l
!- water flow to do so. !
3.9.2.2 Relief Request. The licensee has requested relief from the l exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for the hydraulic control unit valves number 114 and 115, the check valves i
49
! l 1
. -. - - - .- -. - , . j
(typical of 145 each) in the line to the scram discharge volume and in -the line from the charging water header, and proposed to test 50% of these valves every 16 weeks and 100% of them every 32 weeks by performing the scram function testing.
3.9.2.2.1 Licensee's Basis for Requesting Relief--Testing of-the
~
valves' function is accomplished by meeting scram time testing requirements of Technical Specification 4.3. This requires testing of 50% of the ,
control rod drives every 16 weeks and 100% every 32 weeks. Performance of the scram function within Tech. Spec. required limits will assure that
< scram insert flow and scram exhaust flow is not diverted.
3.9.2.2.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for the HCU valves 114 and 115. These valves cannot be tested without inserting the associated control rod which would cause a reduction in reactor power. The licensee has demonstrated that the performance of the cor. trol rod scram testing per plant Technical Specifications would verify closure of valve 115 to prevent diversion of scram insert flow and verify opening of valve 114 to permit scram exhaust flow to the scram discharge header.
3.9.2.2.3 Conclusion--The reviewer concludes that the licensee's proposal of testing 50% of the 114 and 115 valves every 16 weeks and 100%
of them every 32 weeks during the performance of the control rod scram function testing should provide a reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.
3.10 Nuclear Boiler System 3.10.1 Category A/C Valves 3.10.1.1 Relief Request. The licensee has requested relief from the
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exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for valves 6-58A, 588, 62A, and 628, the main feedwater header check valves, and proposed to verify reverse flow closure of these valves by performing the Appendix J, Type C leak rate test during refueling outages.
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3.10.1.1.1 Licensee's Basis for Requesting Relief--Verification of valve closure can only be accomplished by leak testing, which is performed at refueling.
3.10.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for check valves 6-58A, 588, 62A, and 628. The licensee has demonstrated that due to the plant design, the only method available to verify closure of these valves is to perform a leak rate test.
3.10.1.1.3 Conclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J leak rate test during refueling outages is acceptable. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.10.2 Category B Valves 3.10.2.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 202-5A and 58, the reactor recirculation pump discharge valves, and proposed to full-stroke exercise these valves during refueling outages.
3.10.2.1.1 Licensee's Basis for Requesting Relief--Closure of these valves during normal operation will result in loss of forced circulation to the reactor, a condition prohibited by PNPS's License. '
Closure of these valves during cold shutdown necessitates securing
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operation of the reactor recirculation pumps. This is detrimental because j even though the moderator temperature is less than 212 F the recirculating system is usually kept in operation during cold shutdown to provide reactor coolant mixing to prevent reactor vessel temperature stratification. The reactor vessel temperature profile takes on an increasing tempera,ture gradient between the bottom vessel head and the shutdown core when mixing (forced circulation) is stopped. Additionally the water in the idle 1
51
l recirculation loop cools down. This stratification can have the following !
adverse effects: reactor vessel temperatures become greater between the vessel bottom and top resulting in unnecessary thermal cycling, startup of the shutdown recirculation pump can cause a cold water intrusion affecting reactor vessel metal temperatures. Deliberate stopping and starting of the recirculation pumps creates unnecessary cycling wear on major equipment .
important to plant reliability.
3.10.2.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted from the exercising requirements of Section XI for 202-5A and 58. The licensee has demonstrated that these valves cannot be exercised during power operation because this would result in a loss of forced circulation flow and would cause a reactor power reduction and violation of plant administrative requirements. The reviewer agrees that these valves should not be exercised quarterly during power operations, however, the licensee's justifications for not exercising the valves during cold shutdowns are not considered to be an adequate technical basis for not performing the Code required testing. During the time required to stroke one of these valves and to restart the recirculation pump there should be no problem from stratification in the reactor vessel and insufficient cooldown in the idle recirculation loop to cause any thermal shock concerns. Failure of one of these valves in the closed position during testing would cause some operational inconvenience, but would not be a safety problem or rescit in damage to any plant equipment because the other recirculation loop and the residual heat removal system would be available to cool the reactor and to prevent stratification.
3.10.2.1.3 Conclusion--The reviewer concludes that the licensee should not exercise these valves quarterly during power operations, but they should exercise them in accordance with the Code during cold shutdowns.
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3.10.3 Category B/C Valves 3.10.3.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for
- 203-3A, 3B, 3C, and 3D, the ADS valves, and proposed to exercise these valves at least once per operating cycle.
i 3.10.3.1.1 Licensee's Basis for Requesting Relief--Relief is i .
requested from the Section XI required testing frequency of once every three months. Exercising these valves during normal operation would cause primary system pressure spikes and reactor power fluctuations which could lead to a reactor scram. These valves are exercised once per operating i
cycle as specified in Technical Specification Section 4.5.E.
1 Relief is requested from the stroke timing requirements of Section XI. It is impractical to measure stroke times for relief and solenoid valves since the stroke times are on the order of 100 ms.
After the recent failures of two of the PNPS relief valves to open during bench testing at an independent laboratory (reported to NRC by LER) extensive failure analysis by metalographic examination was conducted by an independent consultant. Results of the exam revealed the following causes for failure:
Normal corrosion of the pilot valve's Stellite 6 seat to the Stellite 6B disk was the main reason for the sticking. The corrosion process is basic to the environment during operation.
It was discovered that the Stellite 6B disk had carbides at the surface. The normal corrosion went around the carbides and tended to " key" into the surface. This was proven by the examination of disk / seat surfaces. The disk had microscopic holes where the carbides were pulled out.
Operating the SRV at low operating pressure (150 psi) probably increases the potential for sticking. This is based on the theory that 53
there is little cushioning effect on the spring force due to reactor system pressure. This allows the disk to slam into the seat fracturing carbides at the surface. This gives corrosion more area (crevices) to adhere to, increasing sticking potential. The exact pressure where this would not occur is not known but 500 psi appears acceptable. The reason the valves are cycled is to insure they operate and are not stuck.
A material change to the pilot valve disk was made to help correct the ,
above items. Because of the above findings, PNPS intends to operate the relief valves at the higher reactor pressure between 350 and 500 psi. The analysis also indicates that mechanical interaction between the disk and the seat increases the potential for sticking. This fact allows the conclusion that mechanical interaction from stroking the pilot valve should be minimized. Based upon this information, no increase in frequency of testing beyond Technical Specification 4.5.E is advisable.
f Since the relief valves will be exercised at a higher pressure more indicative of expected actuation conditions, and since setpoints testing per Technical Specification 4.6.D is more frequent than that of IWV 3510, stroke testing once per operating cycle upon startup from a refuel outage is warranted.
3.10.3.1.2 Evaluation--The reviewer agrees with the licensee's
. basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves 203-3A, 38, 3C, and 30. The licensee has demonstrated that exercising these valves during power operation would cause RCS pressure disturbances and reactor power fluctuations which could lead to a reactor trip. They also stated that an extensive failure analysis performed after two ADS valves failed to open, indicated that
, mechanical interaction between the valve disk and seat increases the potential for sticking. The licensee proposed to exercise these valves once per operating cycle during the startup from refueling outages. The
- stroke times for these valves are extremely short (approximately 100 ms) making it impractical to measure using normal methods and meaningless to j
trend since measurement response times and inaccuracies would mask any l
changes in actual valve stroke times.
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l 3.10.3.1.3 Conclusion--The reviewer concludes that the licensee's proposed alternate testing should provide a reasonable assurance of valve operability for the ADS valves. More frequent testing either cannot be performed or is impractical, since it would not increase the reliability of these valves. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
O 3.10.4 Category C Valves 3.10.4.1 Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for the air supply line check valves for the ADS, inboard MSIV, and outboard MSIV air accumulators, and proposed to exercise these valves during refueling outages and verify valve closure by performing a valve leak test. The valves are:
83A 85A 31-CK-372A 83B 85B 31-CK-372B 83C 85C 31-CK-372C 83D 850 31-CK-3720 3.10.4.1.1 Licensee's Basis for Requesting Relief--Verification
- of valve closure can only be accomplished by disassembling a portion of the i air supply system. Therefore, exercise tests can only be performed during reactor refueling, 3.10.4.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for the above listed air accumulator supply check valves. The licensee has demonstrated that due to the system design the only method of verifying closure of these check valves is by performing
)
a leak test or backpressure test which requires disassembly of a portion of the air supply system. This testing can only be performed during refueling outages.
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l 3.10.4.1.3 Conclusion--The reviewer concludes that the licensee's. proposal tofexercise these valves during each refueling outage-should provide a reasonable assurance of valve operability and an indication of valve degradation as required by the Code and, therefore, relief should be granted.
3.11 Recirculation Pump Seal Water System 3.11.1 Category A/C Valves 3.11.1.1' Relief Request. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for F0-13A, 138, 17A, and 178, inboard and outboard check valves for the recirculation pump seal water lines, and proposed to verify reverse flow closure of these valves by performing the Appendix J, Type C leak rate test during refueling outages.
3.11.1.1.1 Licensee's Basis for Requesting Relief--Verification i of valve closure can only be accomplished by leak testing or backpressure testing, which is performed at refueling.
3.11.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, thereftre, relief should be granted from the exercising requirements of Section VI for check valves F0-13A, 138, 17A, and 178. The licensee his demonstrated that due to the plant design, the only method available to verify : sure of these valves is to perform a leak rate test.
3.11.1.1.3 Cenclusion--The reviewer concludes that since the only practical method of verifying closure of this check valve is by performing a leak test, the licensee's proposal of exercising this valve closed when performing the Appendix J 1eak rate test during refueling outages is acceptable. The proposed alternate testing should provide an
- indication of valve operability and degradation as required by the Code
- and, therefore, relief should be granted.
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3.12 Salt Service Water System 3.12.1 Category B Valves 3.12.1.1 Relief Request. The licensee has requested relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413, for valves 3915 and 3925, the service water to screen wash system isolation valves, and proposed to exercise the valves quarterly but not measure valve D
3.12.1.1.1 Licensee's Basis for Requesting Relief--When the screen wash pumps are turned off, these valves receive a signal to close.
There are no position indicator lights to show when the valves have closed after the pumps are tripped, therefore, the stroke times cannot be determined. Proper valve closure is verified by observation of actuator stem position change after the screen wash pumps have tripped.
3.12.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the stroke time measurement requirements of Section XI for valves 3915 and 3925. There are no remote position indicators for these valves and they are controlled by signals from the screen wash pumps and cannot be operated locally. Since there are no remote position indicators for these valves, their stroke times cannot be measured remotely, and since the valves cannot be controlled locally, the complete stroke times cannot be measured by observing the valve stems, therefore, it is not practical to measure the stroke times for these valves.
3.12.1.1.3 Conclusion--The reviewer concludes that the licensee's proposal to full-stroke exercise these valves quarterly and observe the valve actuator stem movement, should provide a reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.
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3.13 Diesel 011 Transfer System j 3.13.1 Category B Valves I
3.13.1.1 Relief Request. The licensee has requested relief from the stroke time measurement requirements of Section XI, Paragraph IWV-3413, for i
A0-4521 and 4522, the isolation valves on the line from the diesel oil !
i transfer pumps to the day tanks, and proposed to exercise the valves ,
i quarterly but not measure the valve stroke times.
i 3.13.1.1.1 Licensee's Basis for Requesting Relief--These valves j are not equipped with position indicators, therefore, stroke times cannot j be obtained. Valve opening is indirectly verified by proper system i operation.
i j 3.13.1.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the stroke time j measurement requirements of Section XI for valves A0-4521 and 4522. The f licensee has stated that these valves do not have any position indication i and the valve stems cannot be observed without disassembling the valves,
! which makes it so the valve stroke times cannot be measured. Valve
]. operation can be determined only by observing flow through the line into ,
the day tank.
! l 3.13.1.1.3 Conclusion--The reviewer concludes that it is j impractical to measure the stroke times for these valves and that the
! licensee's proposal to full-stroke exercise these valves quarterly and to
- verify valve operation by observing flow though these valves during system j operation should provide a reasonable assurance of valve operability as
! required by the Code and, therefore, relief should be granted, r i
j 3.13.2 Category C Valves j 3.13.2.1 Relief Request. The licensee has requested relief from the l Section XI, Paragraphs IWV-3400 and -3500, requirements to verify valve i
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. .-,,.,,---~___--..._.....-_m-_..,- m._,._ _ .,_.___ - _ . .-_ _ -- _.- __ ., ,_ _ ,, . _ . _ . . _ , , _ _ _ - - - - - -_
l l
closure for valves 38-CK-105A and 1058, the diesel oil transfer pump discharge check valves, and proposed to exercise these valves open but not verify valve closure.
3.13.2.1.1 Licensee's Basis for Requesting Relief--The function of the pump discharge check valves (1 in., No. 38-CK-105A,1058) is to prevent back flow through an idle diesel fuel oil transfer pump if the two I pumps are cross-connected. There is a provision to allow supply of fuel oil to either day tank A or 8 or fire pump day tank from either transfer pump (as an operator convenience), via a manual valve which is normally closed (Valve 1-1/2 in., 38-HO-109 on P&ID M223).
Since the discharge check valves are for operator convenience, the closure test requirement will be deleted from the test program. Support of this conclusion is that given the scenario that one of the fuel oil transfer pumps was used to fill both day tanks, the foot valve, which is tested for closure function, would ensure delivery of oil to the day tanks. Use of the cross-connect valve is procedurally controlled and valve alignment requires it to be normally closed.
3.13.2.1.2 Evaluation--The reviewer agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of verifying closure for check valves 38-CK-105A and 1058. The licensee has demonstrated that these valves are not required to close to prevent the diversion of diesel oil flow through an idle diesel oil transfer pump. Administrative procedures control the use of the cross connect between the two pumps and even when the cross connect is used, the pump foot valves, which are tested to verify closure, would prevent the diversion of flow away from the day tanks. These valves will be exercised open quarterly.
3.13.2.13 Conclusion--The reviewer concludes that the licensee's proposal of full-stroke exercising these valves open quarterly should provide a reasonable assurance of their ability to open to allow diesel fuel oil flow to the diesel day tanks which is the safety-related function ~
59
of these valves. The proposed alternate testing should provide an indication of valve operability and degradation as required by the Code and, therefore, relief should be granted.
3.14 Containment Atmospheric Dilution System 3.14.1 Category A Valves 3.14.1.1 Relief Request. The licensee.has requested relief from the exercising requirements of Section X1 for the combustible gas control containment isolatica valves listed below and proposed to exercise these valves once per operating cycle.
5081A 50818 5085A 50858 5082A 5082B 5086A 50868 5083A 50838 5087A 50878 5084A 50848 5088A 50888 3.14.1.1.1 Licensee's Basis for Requesting Relief--As part of the NRC review of the Pilgrim combustible gas control system to meet the requirements of NUREG 0737, Item II.E.4.1, an NRC concern was identified to Boston Edison by letter dated January 27, 1982 from Mr. Domenic B. Vassallo. The letter stated that the NRC staff was concerned about "the capability to isolate the containment at Pilgrim may be compromised given certain single failures within the CGCS". The system i consists of sixteen solenoid valves, two normally closed series valves in each of eight CGCS flow paths. Each set of series valves is powered from the same electrical supply. The NRC questioned if the design was adequate i to prevent a single failure from causing two in-scries valves to open.
BECO responded that:
The pnwer to both valves of a series pair of isolation valves is from the same power supply, and their respective cables are routed in the same raceway. We believe that this is acceptable, because:
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- 1. The only cables in the applicable raceways are to the isolation valves. Therefore, all cables to the isolation valves can be de-energized by moving all control switches to "close", and there wili be no other source of voltage within the raceway to cause the valves to open inadvertently.
- 2. The valves are normally closed and would be opened for a very limited time for testing. This period of energization makes extremely unlikely that both valves could be damaged due't'o over voltage on the solenoid coils.
The solenoid valves are ASME III Class 2 and were procured to the requirements of IEEE 323-1974, IEEE 382-1973, and IEEE 344-1975 for the expected conditions. The valves are rated at 120 VAC and are designed to operate between 80 and 110 percent of rated voltage. This range is compatible with expected bus voltages at PNPS. The valves will fail closed on loss of power.
In consideration of this single failure issue it is appropriate to limit the testing time of the valves to once per operating cycle. Additionally, per PNPS Tech. Spec. 4.7.A.7, the Post LOCA Containment Atmospheric Dilution System is designed to meet the requirements of Regulatory Guides 1.3,1.7 and 1.29, ASME Section III, Class 2 (except for stamping) and Seismic Class I as defined in PNPS FSAR Section 12.2.3.5 and 2.5.3. The system design contains sufficient redundancy to ensure its reliability.
Thus it is sufficient to test the operability of the whole system once per operating cycle.
The solenoid valves have keylocked control switches with indicator lights to continuously monitor valve position. The ,
< . position . indicators are driven by reed type limit switches mounted and sealed within the valve electrical housing. This makes the position switches inaccessible for observation so that i
the valve position indicator check of IWV3300 is performed once l per operating cycle in conjunction with the system operability test.
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3.14.1.1.2 Evaluation--The reviewer does not agree with the licensee's basis and, therefore, relief should not be granted.from the exercising requirements of Section XI for the listed valves. The licensee did not provide an adequate technical justification for not exercising these valves in accordance with the Code. The licensee's basis discussed a concern about single failures that could possibly compromise the containment isolation capability of the system and discussed the system redundancy. System redundancy is not a justification for not' performing ,
4 inservice testing in accordance with Section'XI requirements, in fact the testing is performed to help assure that the system's required redundant trains remain functionally available for use. The licensee pointed out that a single failure could not prevent both series isolation valves in any of the lines from closing on a containment isolation, therefore, the single failure concern is not a basis for not exercising these valves in accordance with the Code.
3.14.1.1.3 Conclusion--The reviewer concludes that the licensee should exercise these valves in accordance with the Section XI requirements.
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O APPENDIX A NRC STAFF POSITIONS AND GUIDELINES I
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1 63 j i
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APPENDIX A -
I NRC STAFF POSITIONS AND GUIDELINES
- 1. FULL-STROKE EXERCISING OF CHECK VALVES j The NRC staff's position is that check valves whose. safety function is .
to open are expected to be full-stroke exercised. Since the disk position I is not always observable, the NRC staff position is that verification of .
- the maximum flow rate through the check valve identified in any of the plant's safety analyses would be an adequate demonstration of the ;
full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve. It is the NRC staff position that this reduced flow i
rate method of demonstrating full-stroke capability is the only test that requires measurements of the differential pressure across the valve. ,
- 2. VALVES IDENTIFIED FOR COLD SHUTDOWN EXERCISING The Code permits valves to be exercised during cold shutdowns when exercising is not practical during plant operation and these valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns, therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it is not necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it is not practical to
] exercise these valves during power operations and that we agree with the i licensee's basis.
I It should be noted the NRC differentiates, for valve testing purposes, a
between the cold shutdown mode and the refueling mode. That is, for valves
, identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and each refueling outage.
However, when relief is granted to perform tests on a refueling outage f frequency, testing is expected only during each refueling outage. In addition, for extended outages, tests being performed are expected to be 1
maintained as closely as practical to the Code-specified frequencies.
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, .- _ . - _ , . . - , - _ _ -- , -- .. -, , . ,. -,_,, , _ . , , . _ . . . . _ , , _ _ , ,, .,.~. -,.., ,.,.., m.-.
- 3. CONDITIONS FOR VALVE TESTING DURING COLD SHUTOOWNS 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 no 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.
- 3. 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
- 4. For planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test frequency in the IST program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
- 4. CATEGORY A VALVE LEAK TEST REQUIREMENTS FOR CONTAINMENT ISOLATION VALVES All containment isolation valves (CIVs) that are Appendix J, Type C,.
leak tested should be included in the IST program as Category A or A/C valves. Tne NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, Appendix J. Relief from Paragraphs IWV-3421 through -3425 (1980 Edition through Winter 1980 Addenda) for containment isolation valves presents no safety problem since the intent of these paragraphs is met by Appendix J
- requirements, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action requirements of~ Paragraphs IWV-3426 and
-3427. Based on the considerations discussed above, the NRC staff has concluded that the alternate testing proposed will give reasonable assurance of valve leak-tight integrity as required by the Code.
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, 5. APPLICATION OF APPENDIX J TESTING TO THE IST PROGRAM i l The Appendix J review of this plant is completely separate from the !
IST program review. However, the determinations made by the Appendix J review are directly applicable to the IST program. - The NRC staff's position is that if any changes are made to the Appendix J program, the licensee should amend their IST program accordingly.
- 6. SAFETY RELATED VALVES The review was limited to valves whose functions is safety related.
Valves whose function is safety related are defined as those valves that are needed to mitigate the consequences of an accident and/or to shutdown .
the reactor to the cold shutdown condition and to maintain the reactor in a cold shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-Code class valves. It should be noted that the licensee may have included valves whose function is not safety related in their IST program as a decision on their part to expand the scope of their prog.am.
- 7. ACTIVE VALVES The NRC staff position is that active valves are those which may be required to change position to shutdown a reactor to the cold shutdown condition or to mitigate the consequences of an accident. - Included are valves which respond automatically to an accident signal, such as safety.
injection, and valves which may be optionally utilized but are subject to plant operator actions, such as service water supply to the steam generators and valves utilized to establish long term recirculation following a LOCA.
4
- 8. RAPID-ACTING POWER OPERATED VALVES The NRC staff has identified rapid-acting power operated valves as
, those which stroke in 2 seconds or less. Relief from the trending requirements of Section XI [ Paragraph IWV-3426 (1980 Edition through Winter 67
,, - ., -.-.r7---,-.. .w.< = w -----,--._<p , , y - a w -,m,e
l 1980 Addenda)]presentsnosafetyconcernsforthesevalvessince ;
j variations in stroke time will be affected by slight variations in the-
, response time of the personnel performing the tests. However, the staff does require that the licensee assign a maximum limiting stroke time of 2 seconds to those valves in order to obtain this Code relief.
- 9. VALVES WHICH PERFORM A PRESSURE BOUNDARY ISOLATION FUNCTION During'the working meeting with Boston Edison Company representatives
! on May 30, 31 and June 1, 1984, the NRC staff's position on pressure boundary isolation valves was explained and the following valves were identified as appearing to perform that function at Pilgrim Nuclear Power Station. Pilgrim did not receive an Event V letter and does not currently leak rate test any valves to verify their ability to perform a pressure isolation function. In accordance with guidance from the Committee to Review Generic Requirements (CRGR) on July 24, 1985, backfitting of non-Event V PIV leak testing at operating reactors may not be appropriate.
Valve Category Function 1001-50 A RHR suction isolation valve 1001-47 A RHR suction isolation valve 1001-68A C RHR discharge to the recirc. loop 1001-29A A RHR discharge to the recirc. loop 1001-688 C RHR discharge to the recirc. loop 1001-29B A RHR discharge to the recire loop 1001-60 A- RHR vessel head spray isolation valve 1001-63 A RHR vessel head spray : isolation valve 1001-23A A LPCI injection isolation valve
~
1001-26A A LPCI injection isolation valve 1001-238 A LPCI injection isolation valve -
1001-26B A LPCI injection isolation valve
- 68 n-,v,- -- - - - -
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~. . . . -- . . . . - - . _ _ _-_
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Valve Category Function l 1400-9A C Core spray injection header isolation valve 1400-25A A Core spray injection header isolation valve 1400-9B C Core spray injection header isolation valve 1400-25B A Core spray injection header isolation valve ,
, 2301-7 C HPCI injection isolation valve 2301-8 A HPCI injection isolation valve 1301-50 C RCIC injection isolation valve-1301-49 A RCIC injection isolation valve 1201-2 A Reactor water cleanup suction line isolation valve 1201-5 A Reactor water cleanup suction line isolation valve 1201-80 A Reactor water cleanup discharge line isolation valve l.
l 1201-81 C Reactor water cleanup discharge line check 1 valve
+
- 10. CHECK VALVE SAMPLING DISASSEMBLY / INSPECTION PROGRAM The NRC staff has concluded that a valve sampling disassembly and inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke' capability. This program involves grouping similar valves together and testing one valve 11n each group during each refueling outage. The sampling technique requires that each valve in the group be of the same design (manufacturer, size, model number and materials of construction) and have the_same service conditions. Additionally, at each disassembly it must be verified that the
- disassembled valve is capable of full-stroking and the its internals are structurally sound (no loose or corroded parts). ,
t 69
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, , ,4- -
--v r-- - ---. w<-v~
A different valve of each group is required to be ' disassembled, inspected and manually full-stroke exercised at each-refueling outage,-
until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected and manually full-stroke exercised during the same outage.
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9 APPENDIX B VALVES TESTED DURING COLD SHUTDOWNS s
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APPENDIX B l
i !
VALVES TESTED DURING COLD SHUTDOWNS Th'e following are Category A, B,.and C valves that meet the exercising l requirements of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation. These valves are specifically identified by the owner in accordance with Paragraphs IWV-3412 and -3522 and are full-stroke exercised during cold shutdowns and refueling outages. All valves in this Appendix have been reviewed and the reviewer-agrees with the licensee that testing these valves during power operations is not practical due to the valve type, location, or system design. These valves should not be full-stroke exercised during power operations. These valves are listed below and grouped according to the system in which they are located. ,
- 1. SALT SERVICE WATER SYSTEM .
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1.1 Category B Valves i MO-3801 and 3805, the turbine building cceling water heat exchanger ;
I outlet valves, cannot be full-stroke exercised during power operation because exercising these valves would disrupt cooling' water flow to power generation equipment such as the turbine lube oil coolers, the reactor feed-pump coolers, and generator hydrogen and stator coolers. Loss of cooling water flow could lead to equipment damage and a reactor trip. These valves
! will be partial-stroke exercised quarterly during power operations and i full-stroke exercised during cold shutdowns and refueling outages.
- 2. COMPRESSED AIR SYSTEM
= 2.1 Category A Valve 4
A0-4356, the isolation valve in the nitrogen / instrument air line to the drywell, cannot be exercised during power operations because failure of this valve closed during testing would cause a loss of nitrogen / instrument 73 i
air to the drywell which would cause the inboard MSIVs to close resulting in a reactor trip. These valves do not have a partial-strcke capability and will be full-stroke exercised during cold shutdowns and refueling outages.
- 3. RESIDUAL HEAT REMOVAL 3.1 Category A Valves ,
1001-47 and 50, the RHR shutdown cooling suction valves, cannot be exercised during power operation because these valves are interlocked to prevent opening when reactor pressure is greater than 100 psig. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
3.2 Category C Valves 1001-68A and 688, the low pressure coolant injection check valves, cannot be exercised during power operation because verification of the valves being open can only be accomplished by assuring cooling water flow into the reactor which can only be confirmed during shutdown cooling operations. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
- 4. NUCLEAR BOILER SYSTEM 4.1 Category B Valves 220-46 and 47, the reactor vessel head and main steamline "A" vent valves, cannot be exercised during power operation because exercising one
- of these valves would leave the other valve as the only barrier between the-reactor vessel and the drywell sump and any leakage through that valve would pressurize the drywell. Also, operating procedures prohibit l operation of these valves during power operation. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
74 l
6 D
e APPENDIX C P&ID AND FIGURE LIST t
O 75
APPENDIX C P&ID AND FIGURE LIST The following is a list of P&ID's used during the review of the Pilgrim Nuclear Power Station IST program.
System P&ID No. Revision Service Water System M-212 E4 Cooling Water System-Reactor Building M-215 E4 Compressed Air System M-220 Sh. 1 E5 Diesel Oil Storage and Transfer System M-223 El Containment Atmospheric Control System M-227 Sh. 1 E4 Containment Atmospheric Control System M-227 Sh. 2 E3 Radwaste Collection System M-232 E5 Analyzer Systems M-239 El Residual Heat Removal System M-241 E2 Core Spray System M-242 E2 High Pressure Coolant Injection System M-243 El High Pressure Cooiant Injection System M-244 El Reactor Core Isolation Cooling System M-245 E2 Reactor Water Clean-up System M-247 E3 Standby Liquid Control System M-249 E3 Control Rod Drive Hydraulic System M-250 E3 Recirculation Pump Instrumentation M-251 E1
. Nuclear Boiler M-252 E2 Post Accident Sampling System SK-1A A H and 0 Analyzer System SK-M-90A A 2 2 77
t w
APPENDIX D IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW 79
APPENDIX D IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW Inconsistencies and omissions-in the licensee's program noted during the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.
- 1. The licensee did not provide adequate technical justifications for not measuring the Code required parameters for the following safety related pumps and relief is not recommended from the Code requirements.
Parameters not Relief Request Pumps Measured Evaluation Reactor building closed Bearing temperature 2.1.1 cooling water pumps Residual heat removal pumps Differential pressure 2.6.1 High pressure coolant Differential pressure 2.6.1 injection pumps -
Reactor core isolation Differential pressure 2.6.1 cooling pumps Core spray pumps Differential pressure 2.6.1 Standby liquid control Differential pressure 2.6.1 pumps
- 2. The licensee's proposed allowable ranges for pump vibration in velocity units do not conform with the limits established by the NRC staff, therefore, the licensee should measure pump vibration in accordance with the Code requirements (see Section 2.2.1).
- 3. Lack of installed instrumentation is not a basis for permanent relief from measuring Code required parameters and the licensee should make
, the necessary system modifications prior to the end of the next refueling outage to allow measurement of Code parameters for the diesel oil transfer pumps. Interim relief should be granted for the balance of the current fuel cycle (see Section 2.7.1).
81
- 4. The reviewer agrees with-the licensee's basis for not exercising RBCCW.
' valves 4002, 4085A, 40858, 4009A, and-40098 during power operation or cold.si.utdowns when the recirculation pumps remain in operation, however, during cold shutdowns when the recirculation pumps are
- secured these valves should be exercised (see Sections 3.2.1.1, 3.2.3.1, and 3.2.3.2).
j y-
- 5. The licensee's bases for relief were judge ' to contain' inadequate ,
technical justifications to grant relief from the Section XI exercising requirements for the following valves:
Relief Relief Request System Valves Request Evaluation
< HPCI 2301-7 RV-15 3.6.~2.1 2301-39 RV-31 3.6.2.3 i RCIC 1301-50 RV-15 3.7.2.1
- 1301-27 RV-31 3.7.2.3
- Nuclear boiler 202-5A RV-23 3.10.2.1 202-5B- RV-23 3.10.2.1 Containment atmospheric 5081A and B RV-37 3.14.1.1 ,
dilution system 5082A and B RV-37 3.14.1.1 5083A and B RV 3.14.1.1 5084A and B RV-37 3.14.1.1 5085A and B RV-37 3.14.1.1 5086A and B RV-37 3.14.1.1 5087A and B RV-37 3.14.1.1
- 6. The licensee's proposed testing of valves 2301-39 and 1301-27 results in a small percentage of the design accident flow through these. valves and the licensee did not provide sufficient information to demonstrate.
i that the test flow will fully open the valve disks (see Sections 3.6.2.3 and 3.7.2.3).
- 7. The setpoint for the HPCI turbine exhaust line_ vacuum. relief valve VRV-9066 cannot be tested given the current system design. The ,
licensee will make valve or system modifications which will make testing possible prior to startup from RF0 #7 (see Section 3.6.2.4).
1 1
i-82
- 8. The licensee requested relief from the stroke time trending and corrective action requirements of IWV-3417(a) for the RCIC turbine trip and governor valves and assigned a stroke. time limit of 5 seconds to these valves. The NRC position on stroke times for rapid acting valves (see Section 3.1.1 and Appendix A Item 8.) is that rapid acting valves are those with stroke time limits of 2 seconds or less and that valves with limits greater than 2 seconds should comply with the Code requirements.
- 9. The licensee did not provide an adequate technical justification for not measuring the stroke times for the scram discharge volume isolation valves quarterly during power operations or during cold shutdowns. The isolation valves are listed below and are' discussed in Section 3.9.1.1.
302-21A 302-22A 302-23A 302-24A 302-21B 302-228 302-23B 302-248
- 10. The proposed alternate testing for the hydraulic control unit valves #138 (see Section 3.9.2.1) may not verify closure of these valves.
- 11. The licensee's IST program does not verify closure of the following safety related valves. These check valves do perform a safety function in the closed position. The licensee currently only verifies that one of two series check valves closes.
System Valve Residual heat removal system 1001-103 1001-104 Core spray system 1400-100
. 1400-102
~
- 12. The licensee has included the RCIC pump and many of the RCIC valves in revision IA of their IST program, however, operation of the following 83
1 RCIC valves appears to be necessary for the system to fulfill its function. These valves should be included in-the IST~ program and be tested in accordance with the Code unless the licensee requests-specific relief and the NRC approves the relief.
Valv~e Function P&ID Coordinates 3
1301-34 RCIC turbine steam supply drain M245- J-13 isolation valve ,
2" 223 Vacuum pump discharge line check M245 J-7 valve 1301-63 RCIC condensate pump discharge M246 K-6' check valve VRV-9067 RCIC turbine exhaust line vacuum M245 H-6 relief valve
- 13. No quantitative testing is currently performed on the excess flow check valves at Pilgrim; the operators make a judgement that there is a " marked decrease in flow." These valves should be included in the
! IST program and be quantitatively tested.
! 14. The NRC staff position is that the diesel generator air start solenoid valves perform a safety related function and should be included in the j IST program and be tested in accordance with the Code. The licensee has not conformed to this staff position.
! 15. The reviewer agrees with the licensee's basis for not exercising core l sprcy valves 1400-9A and 9B quarterly during power operations, j however, the relief request (RV-14) does not contain an adequate -
technical justification for not exercising these valves during cold shutdowns (see Section 3.5.1.1).
- 16. The licensee should conform with the corrective action requirements of IWV-3427 for all valves that are leak rate tested to verify their ,
j- containment isolation function (see Section 3.1.3.1 and Appendix A,
- Item 4.).
I I
84
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u.s. Nuctsam a erutafon, -::
i nepoar NwMean ,A , e, riac , v w.,r r, l une pones ass i f 3 Sol Ifa'"2d*'- 818LIOGRAPHIC DATA SHEET EGG-NTA-7508 54E tNSTauCTioNS ON TwE psygmsg 2 LEAVE SLANn 2 TITLE ANQ 568 TITLE TECHNICAL EVALUATION REPORT, PUMP AND VALVE INSERVICE TESTING PROGRAM, PILGRIM NUCLEAR POWER STATION , ,,,,, ,,,,,,,,,,,,,, )
M NTN ..A.
i i AuT o.is, March 1987
. oafs a. oar issuno C. B. Ransom. H. C. Rockhold asoNr4 vaAa l
March 1987
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& PaostCTITAss/wonn uNeT Muessen 7 Pts.7OAMING QRGA8ellATION NAME ANO MaluNG aconess tsaenwale Casw NRR and I&E
- *1= oa oaA=T NwMesa EG&G Idaho, Inc.
P. O. Box 1625 J Idaho Falls, ID 83415 A6812 its TYPE OP MEPORT TO. $PoNSQAING ORGAN 12AfloN NAMG ANQ MAILtNG acomtS5 dismesver te Caew PWR-A Engineering Branch Office of Nuclear Reactor Regulation
"'a ca* *a'a ' - --"
U.S. Nuclear Regulatory Commission '
Washington, 0C 20555 ,
12.EbPPLEU(NTany NOTES
- 13. AtSTR ACT r200 weres or sees This EGaG Idaho, Inc. report presents the results of our evaluation of the Pilgrim Nuclear Power Station Inservice Testing Program for pumps and valves that perform a safety related function.
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