ML20215J270

Pump & Valve Inservice Testing Program,Vogtle Electric Generating Plant,Unit 1, Final Technical Evaluation Rept

ML20215J270
Person / Time
Site:	Vogtle
Issue date:	02/28/1987
From:	Bonney R, Rockhold H EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20215J251	List: ML20215J249 ML20215J270
References
CON-FIN-A-6811 EGG-NTA-7468, NUDOCS 8705070324
Download: ML20215J270 (64)

Text

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EGG-NTA-7468 February 1987 INFORMAL REPORT 3

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/daho TECHNICAL EVALUATION REPORT PUMP AND YALVE National INSERVICE TESTING PROGRAM V0GTLE ELECTRIC GENERATING PLANT, UNIT 1 Engineering Laboratory Managed R. F. Bonney by the U.S.

H. C. Rockhold Department ofEnergy l

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Prepared for the 4

U.S. NllCLEAR REGULATORY COMMISSION DOE Contract No. DE-AC07 76tD01570 -

8705070324 870209^

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DISCLAIMER This book was prepared as an account of work sconsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of tosir empioyees, makes any warranty, express or imphed, or assumes any legal hability or responsibihty for the accuracy, comoteteness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infnnge pnvately owned nghts. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly 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 necessarily state or reflect those of the United States Government or any agency thereof.

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EGG-NTA-7468 4

TECHNICAL EVALUATION REPORT.

PUMP AND VALVE INSERVICE TESTING PROGRAM V0GTLE ELECTRIC GENERATING PLANT, UNIT 1 Docket No. 50-424 t

R. Bonney H. C. Rockhold Published February 1987 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415-Prepared for the U.S. Nuclear Regulatory Commission e

Washington, D.C.

20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6811

+

ABSTRACT ~

.This EG&G Idaho, Inc., report' presents the,results of our evaluation of the Vogtle Electric Generating Plant, Unit 1, Inservice Testing Program for safety-related pumps and valves.

FOREWORD This report is supplied as part of the " Review of Pump and Valve Inservice Testing Programs for Operating License Plants" Program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR. Licensing-A,~ by EG&G Idaho, Inc., NRR and I&E Support.

-I The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-40-41-2, FIN No. A681'1.

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l Docket No. 50-424 11

CONTENTS 1.

INTRODUCTION.....................................................

1 2.

PUMP TESTING' PROGRAM.............................................

-3 2.1 All Systems................................................

3 e

2.1.1 Relief Request.....................................

3 2.2 Chemical and Volume Control System.........................

4 2.2.1 Relief Request.....................................

4 2.2.2 Relief Request.....................................

6 4

3.

VALVE TESTING PROGRAM............................................

7 3.1 All Systems................................................

.7 3.1.1 Corrective Action..................................

7 3.1.2 Rapid Acting Valves................................

8 3.1.3 Valves Tested During Cold Shutdown.................

9 3.2 Reactor Coolant System.....................................

10 3.2.1 Category A/C Valves................................

10 3.3 Safety Injection System....................................

11 3.3.1 Category C Valves..................................

11 3.3.2 C a t e g o ry A/C Va l v e s................................

15 3.4 Containment Spray System...................................

18 3.4.1 C a te g o ry C Va l v e s..................................

18 3.4.2 Category A/C Valves................................

19 3.5 Chemical and Volume Control System.........................

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3.5.1 Category B Valves..................................

21 3.5.2 Category C Valves..................................

22 3.5.3 Category A/C Valves................................

24 3.6 Auxiliary Component Cooling Water System...................

24 3.6.1 Category C Valves..................................

24 3.7 Main Steam System..........................................

25 3.7.1 Category C Valves..................................

25 3.8 Aux i l i a ry Fe edwate r Sy stem.................................

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3.8.1.

Category C. Valves..................................

27:

1 3.9 Condensate and Feedwater System............................

28 3.9.1 Category C Valves..................................

28 3.10 Containment Air Purification and Cleanup System............

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3.10.1 Ca t e g o ry A/C Va 1 v e s -................................

29 3.11-Nitrogen to Accumulator System.............................

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-3.11.1. Category A/C Valves................................

30 3.12: Instrument Air System......................................

-30 3.12.1 Category A/C Valves................................

30 APPENDIX A--NRC STAFF POSITIONS AND GUIDELINES........................

33 APPENDIX B--VALVES TESTED DURING COLD SHUTDOWN........................

41 APPENDIX C--P&ID AND FIGURE LIST......................................

51 APPENDIX D--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW........

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TECHNICAL EVALUATION' REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM V0GTLE ELECTRIC GENERATING PLANT, UNIT 1 1.

INTRODUCTION Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by the Georgia Power Company for its Vogtle Electric Generating Plant, Unit 1.

By a letter dated July 30, 1986 Georgia Power Company submitted an IST program for Vogtle Electric Generating Plant, Unit 1.

The working session with Georgia Power Company and Southern-Company Services representatives was conducted on October 8 and 9, 1986.

The applicant's revised program, as attached to J. A. Bailey letter to NRC, dated October 31, 1986, which supercedes the previous submittal, was reviewed to verify compliance of proposed tests of Class 1, 2, and 3 safety related pumps and valves with the requirements of the ASME Boiler and Pressure Vessel. Code (the Code),

Section XI, 1983 Edition through Summer 1983 Addenda. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER).

It is an NRC staff position 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 submittal Georgia Power Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine whether they are indeed impractical.

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". These IST I

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I program testing requirements apply only.to component-testing (i.e., pumps and valves) and are not-intended to provide the basis to change the applicant's current Technical. Specifications for system test requirements.

Section 2 of this report presents the Georgia Power Company bases for requesting relief from the Section XI requirements for the Vogtle Electric Generating. Plant, Unit I pump testing program and EG&G'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 discussed in Appendix B.

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

l Inconsistencies and omissions in the applicant's program noted in the course of this review are listed in Appendix-0. The applicant should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

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i 2.

PUMP TESTING PROGRAM The Vogtle Electric Generating Plan't, Unit.1 IST program submitted by the Georgia Power Company was examined to verify that all pumps that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI, 1983 Edition through Summer of 1983 Addenda, except-for those pumps identified below for which specific relief from testing has been requested.

Each Georgia Power Company basis for requesting relief from the pump testing requirements and the EG&G reviewer's evaluation of that request is summarized below.

l 2.1 All Systems (except Nuclear Service Cooling Water System)

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i 2.1.1 Relief Request The applicant has requested relief from the Table IWP-3100-1 requirement of Section XI for measurement of pump bearing temperature yearly.

2.1.1.1 Applicant's Basis for Requesting Relief. The yearly temperature measurement will not provide significant information about pump conditions.

Industry experience has shown that bearing temperature changes caused by degrading bearings occur only after major degradation has occurred at the pump.

Prior to this major pump degradation, the vibration measurement would provide the necessary information to warn of an impending i

malfunction. Deletion of this measurement will not have a significant effect on pump evaluation since vibration amplitude'.is measured quarterly.

i 2.1.1.2 Evaluation. The reviewer agrees with the applicant that quarterly measurement of pump bearing vibration displacement will provide earlier indication of bearing problems that may result from pump bearing degradation than the annual measurement of bearing temperatures. The reviewer also agrees that changes in bearing or lubricant temperatures as a result of bearing problems usually occur only after significant degradation of the pump bearing has already occurred.

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monitoring would.have-detected the: degradation'long before the: increase-I

. temperatures were noticed thus deletion of the' annual bearing temperature measurement will.have no significant effect on pump performance evaluation.

2.1.1.3 Conclusion.

The reviewer concludes that the vibration

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j amplitude measurement will provide.the necessary information to warn of-an impending. pump talfunction hence the deletion of' yearly pump bearing.

i temperature measurement will-not-have aasignificant.effect on pump' performance evaluation. The reviewer. concludes.that the other required testing will give reasonable assurance'of~ pump. operability required by:the i

Code and, therefore, relief should be granted.

l 2.2 Chemical and Volume Control System l

2.2.1 Relief Request The applicant has requested relief from the IWP-3100' requirement of j

Section XI for the boric acid transfer pumps for measurement of-pump flow, i

rate.

The applicant has requested relief from'the=IWP-3100 requirement of"Section XI for the boric acid transfer pumps for varying system resistance to obtain the reference value of either measured differe'tial pressure'or.

n measured flow rate and proposed to utilize a closed-loop fixed-resistence recirculation flow path to determine pump degradation.

2.2.1.1 Applicant's Basis for Requesting Relief.

Relief.is requested.

from measuring pump flow rate as the plant does not have permanent-flow rate-measuring instruments.

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Relief is requested from varying the resistance of the. system as the test flow path, utilizing flow orifice FO-10117 to and from the boric acid storage tank, is a fixed resistance test flow path and not' a variable.

resistance test flow path.

During preoperational testing the flow rate from pumps 1-1208-P6-006 and 1-1208-P6-007 was measured to be 30.5 gpm and i

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31.5 gpm, respectively. This established the reference value flow rates for these pumps with their corresponding differential pressure measurements. During inservice testing pump degradation would be detected by changes in differential pressure and flow rate measurements would be unnecessary.

2.2.1.2 Evaluation. The reviewer does not agree with the applicant that not having permanent flow rate measurement instruments negates the requirement to measure pump flow rate.

The NRC staff position is that lack of instrumentation is not sufficient justification to not measure Code required parameters.

The reviewer agrees with the applicant that utilizing the fixed resistance test flow path to achieve conditions for measurement of Code required parameters will provide sufficient information to monitor for pump degradation.

With the addition of the installed flowrate instrumentation mentioned above, the measurement of both flowrate and differential pressure and the use of a band of acceptance criteria for variations in the two measured parameters should provide for detection of degradation of these pumps.

2.2.1.3 Conclusion. The reviewer concludes that not having permanent flow rate measuring instruments does not negate the requirement to measure pump flow rate, therefore, relief from measuring boric acid transfer pumps flow rate should not be granted.

The reviewer concludes that' utilization of a fixed resistance test flow path to achieve conditions for measurement of Code required parameters is adequate, therefore, relief from utilization of a variable resistance flow path should be granted.

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2;2.2 Relief-Request j

The applicant has requested relief from the IWP-4120 requirement of i-Section XI.for the boric acid transfer pumps suction pressure gauges to l

have a full scale range of three times the' reference value'or less.

2.2.2.1 ' Applicant's Basis for' Requesting Relief.

Suction pressure-

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gauges.PI-10115 and-PI-10116:on the boric acid transfer. pumps have a range.

4 of 0 psi to 15 psi. The suction pressure measurements taken during; preoperational testing =.were'between 2 and-3 psi. Therefore,.the maximum full scale range of the gauge would have to be from 0 to'6 or 9-psi to be within Code requirements. These instruments are within the accuracies of Table IWP-4110-1.

Considering'the low pressure involved, the difference between the Code ranges and the range on the installed instrume'nts would have no' significance on the adequacy of the measurements taken. The installed instruments will be used for taking suction pressure measurements 4

during pump tests.

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2.2.2.2 Evaluation. The reviewer agrees with the' applicant that the j

installed boric acid transfer pumps suction pressure gauges are sufficient to measure Code required pump suction pressure and that the variance on.the range-of the installed instruments would have no significant effect.on the adequacy of the measurement.

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2.2.2.3 Conclusion. The reviewer concludes that-utilization of the installed boric acid-transfer pumps suction pressure gauges is adequate to measure Code required-pump inlet pressure, therefore, relief should be granted.

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3.

VALVE TESTING PROGRAM The Vogtle Electric Generating Plant, Unit 1 IST program submitted by the Georgia Power Company was examined to verify that all valves that are

. included in the program are subjected to the periodic tests required by the

~ASME Code,Section XI, 1983 Edition through Summer 1983 Addenda, and-the NRC positions and guidelines. The reviewers 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..Each Georgia Power Company basis for-requesting relief from th'e valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to system _and valve category.

3.1 All Systems t

3.1.1 Corrective Action 3.1.1.1 Relief Request. The applicant has requested relief from I

testing all valves that require corrective action'as a result of cold' I

shutdown and refueling outage testing in accordance with the requirements of Section XI, Paragraphs IWV-3417(b) and IWV-3523 and proposed to utilize plant Technical Specifications to control whether plant startup is permissible or not.

t 3.1.1.1.1 Applicant's Basis for Requesting Relief--The plant Technical Specifications provide the requirements and plant conditions I

necessary for plant startup (i.e., made changes). As an alternative, the test requirement will be satisfied before the valve is required to be operable in accordance with the plant Technical Specifications.

i 3.1.1.1.2 Evaluation--The reviewer agrees with the applicant-that the plant Technical Specifications dictate the necessary requirements and plant conditions for plant startup (i.e., mode changes). The plant Technical Specifications place adequate controls on system and/or. valve 7

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operability by establishing and defining the ' Limiting Conditions-for:

Operation which restrict, allow, or require entry into the various modes of plant operation.

However, any valve that is inoperable prior to plant startup and cannot be tested prior to return to service and is subsequently required by Technical Specifications during operation shall be repaired

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prior to startup (see Section 3.1.3 of this report).

3.1.1.1.3 Conclusion--The reviewer concludes that the applicant's Technical Specifications dictate the necessary requirements and plant conditions for startup and operations.

The Section XI requirements determine component operability status and should not preclude plant startup when all applicable Technical Specifications requirements rre met.

The reviewer concludes that the testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.1.2 Rapid Acting Valves 3.1.2.1 Relief Request. The applicant has requested relief from the power operated valve stroke time trending requirements of Section XI, Paragraph IWV-3417(a), for all rapid-acting, power operated valves whose function is safety related and proposed to apply a maximum stroke time limit of 2 seconds to all rapid-acting, power operated valves; i.e., those valves with normal stroke times of less than 2 seconds. This includes l

reactor coolant system power operated relief valves 1201-PV-0455A and 0456A.

3.1.2.1.1 Applicant's Basis for Requesting Relief--These solenoid-operated valves have very short stroke times and are classified as

" rapid-acting" valves. Accurate measurement of stroke time-is not practical.

In addition, stroke times may vary significantly due to system pressure and/or temperature changes from one test to another. As an alternative, these valves will be required to be full-stroked and timed to the nearest second quarterly. Acceptance of the test will be based only on the stroke time limit (not to exceed 2 seconds) and not on the "50%"

criteria of IWV-34~7.

8

-3.1.2.1.2 Evaluation--The reviewer agrees with the applicant's proposal'to place a 2 second maximum limit on stroke time for rapid acting power operated valves..This' proposal is consistent with the NRC staff position on rapid acting valves discussed in Appendix A, Section 8 of this-report.

3.1.2.1.3 Conclusion--The reviewer concludes.that the 4

applicant's proposal to assign a maximum stroke time limit of 2 seconds on their rapid acting power operated valves is in accordance with the NRC' staff's' position on rapid acting valves and should be sufficient.to determine proper valve operabi.lity. The reviewer concludes that this j

alternate criteria proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.1.3. Valves Tested During Cold Shutdown i

3.1.3.1 Relief Request. The applicant has requested relief from the corrective a'ction requirement of IWV-3417(a) for category A and category B valves identified as being tested on a cold shutdown frequency (Appendix B of this report) and proposed to modify the required monthly testing frequency for degraded valves to a cold shutdown frequency.

3.1.3.1.1 Applicant's Basis for Requesting Relief--Valves'that

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are normally tested during cold shutdown cannot be tested once each month.

Stroking these valves during power operation may place the plant in an unsafe condition. As an alternative, the test frequency shall be increased l

to once each cold shutdown, not to exceed once each month.

i 3.1.3.1.2 Evaluation--The reviewer does not agree with the applicant's basis for requesting relief from the increased: test frequency 1

requirements of Section XI for those valves that are specifically identified for testing only during cold shutdowns. The Code requires an increased frequency of tests to assure continued operability of the f

degraded valves to demonstrate valve operability. Valves that are.

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specifically identified for testing only during cold shutdowns and refueling outages that are found to have exceeded the allowable change in stroke time and cannot be tested at the increased frequency should be

' repaired and demonstrated operable prior to being required for operation by the plant Technical Specifications.

3.1.3.1.3 Conclusion--The reviewer concludes that-the applicant's proposal to test degraded cold. shutdown exercised valves on a cold shutdown frequency will not be sufficient to demonstrate proper compliance with the corrective-action requirements of IWV-3417(a). The reviewer concludes that the alternate testing proposed will not give reasonable assurance of valve operability as required by the Code and, therefore, relief should not be granted.

3.2 Reactor Coolant System 3.2.1 Category A/C Valves i

3.2.1.1 Relief Request. The applicant has requested relief from exercising valve U6 112, reactor makeup water to. pressurizer relief tank check, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by full-stroke exercising this valve on a refueling outage frequency.

3.2.1.1.1 Applicant's Basis for Requesting Relief--This check valve cannot be exercised during power operation or cold shutdown as the only method available to verify reverse flow closure is valve leak testing during Appendix J, Type C. leak testing during refueling outages. As an alternative reverse flow closure will be verified during Appendix J, Type C, leak testing during refueling outages.

3.2.1.1.2 Evaluation--The reviewer agrees with the applicant that valve U6 112 cannot be full-or partial-stroke exercised during power operation or cold shutdown due to the fact that the only method available to verify reverse flow closure is valve leak testing during Appendix J, Type C, leak testing during-refueling outages.

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3.2'.1.1.3. Conclusion--The reviewer concludes that the applicant's proposal to verify closure capability of valve U6 -112 on a

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refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and,.therefore, relief should be granted.

3.3 Safety Injection-System 3.3.1 Category C Valves j

3.3.1.1 Relief Request. The applicant has requested relief from l.

exercising valves U4 026, 027, 028, 029, and U6 013, boron injection to

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cold leg checks, in accordance with the requirements of Section XI,

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Paragraph IWV-3522-and proposed to verify valve operability by full-stroke exercising these valves on a refueling outage frequency.

3.3.1.1.1 Applicant's Basis for Requestiing Reitef--These check valves cannot be exercised during power operation as the only method-available to verify full flow operability is by using charging pump flow through the boron injection tank into the cold legs. This, however, exposes the safety. injection nozzles to thermal. shock and unnecessarily-changes reactor coolant system boron concentration. These check valves cannot be exercised during cold shutdown as charging pump flow could result in a low temperature overpressurization of the reactor coolant system (RCS). As an alternative these check valves will be full-stroke exercised during refueling outages when the reactor vessel head is removed and full charging pump flow can be utilized.

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3.3.1.1.2 Evaluation--The reviewer agrees with the applicant that valves U4 026, 027, 028, 029, and V6 013 cannot be full-stroke exercised during power operation due to safety injection nozzle thermal l

shock considerations and unnecessary RCS boron concentration changes. The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to possible low temperature overpressurization of the RCS.

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3.3.1.1.3 Conclusion--The reviewer concludes that the.

applicant's proposal to full-stroke exercise valves U4 026, 027, 028, 029, and U6 013 on a refueling outage frequency should be sufficient to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.3.1.2 Relief Request. The-applicant has requested relief from exercising valve U6 090, safety injection system (SIS) pump suction from the refueling water storage-tank (RWST) check and valves U6 098 and 099, SIS pumps discharge checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by partial-stroke exercising these valves quarterly and full-stroke exercising these valves on a refueling outage frequency.

3. 3.1. 2.1 Applicant's Basis for Requesting Relief--These check valves cannot be exercised during power operation as the SIS pumps cannot overcome RCS operating pressure. These check valves cannot be exercised during cold shutdown as SIS pump flow could result in a low temperature overgressurization of the RCS. As an alternative these check valves will be partial-stroke exercised quarterly and full-stroke exercised during l

refueling outages when the reactor vessel head is removed and full SIS pump

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flow can be utilized.

I 3.3.1.2.2 Evaluation--The reviewer agrees with the applicant that valves U6 090, 098, and 099 cannot be full-stroke exercised during power operation due to the fact that the SIS pumps do not have the-capability to full flow into the RCS when the RCS is at normal operating pressure. The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to possible RCS low temperature overpressurization.

12

T 3.3.1.2.3 Conclusion--ThereviewerconclUdesthatthe-

. applicant's proposal to partial-stroke exercise. quarterly and full-stroke exercise valves U6 090, 098, and 099 on a refueling outage frequency should

'be sufficient to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will.give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.3.1.3 Relief Request. The applicant has~ requested relief from exercising valve U6163, residual heat removal (RHR) to SIS pump suction check, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify. valve operability by full-stroke exercising this valve on a refueling outage frequency.

3.3.1.3.1 Acolicant's' Basis for Reouesting Relief--This check valve cannot be exercised during power operation as the SIS pumps cannot i

overcome RCS operating pressure. This check valve cannot be~ exercised-during cold shutdown as SIS pump flow could result in a low l temperature overpressurization of the RCS. As an alternative this check valve will be full-stroke exercised during refueling outages when the reactor vessel head is removed and full SIS pump flow can be utilized, o

3.3.1.3.2 Evaluation--The reviewer agrees with the applicant that valve U6 163 cannot be full-stroke. exercised during power operation i

due to the fact that the SIS pumps do not have the capacity to full flow into the RCS when the RCS is at normal operating pressure. The reviewer i

agrees with the applicant that these. valves cannot be full-stroke exercised ~

during cold shutdown due to possible RCS low temperature overpressurization.

3.3.1.3.3 Conclusion--The reviewer concludes that the applicant's proposal to full-stroke exercise valve.U6 163 on a refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will-give reasonable assurance of valve operability as required by the Code l

and, therefore, relief should be granted.

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3.3.1.4 Relief Request. The applicant has requested relief from exercising valves U4 262 and 263, sludge mixing isolation to RWST checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 ar.d proposed to verify valve operability by' sample disassembly / inspection on' a refueling outage frequency.

3.3.1.4.1 Applicant's Basis for Requesting Relief--Reverse flow closure of these check valves-can,be-verified only by disassembly and-observation of the disk position. As an alternative one of these valves.

will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, i

the other valve will be disassembled.

3.3.1.4.2 Evaluation--The reviewer agrees with the applicant l

I that valves U4 262 and 263 can only be verified to close by valve l

disassembly.

The NRC staff has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of the disk is an -

acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

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

If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that

-group must also be disassembled, inspected, and manually full-stroked at the same outage.

14

n-3.3.1.4.3 Conclusion--The reviewer concludes that the applicant's proposal-to perform sample disassembly / inspection on a refueling outage frequency, when performed in accordance with the previous-discussion (Section 3.3.1.4.2), should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability required by the Code and, therefore, relief should be granted.

l 3.3.2 Category A/C Valves 3.3.2.1 Relief Request. The applicant has requested relief from exercising valves U4 120, 121, 122, 123, U6 124,-and 127, SIS hot leg checks and valves U4 143, 144, 145, and 146, SIS cold leg checks, in accordance with-the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by full-stroke exercising these valves on a refueling outage frequency.

3.3.2.1.1 Applicant's Basis for Requesting Relief--These check-

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valves cannot be exercised during power operation as the SIS pumps cannot overcome RCS operating pressure. These check valves cannot be exercised during cold shutdown as SIS pump flow could result in a low temperature overpressurization of the RCS. As an alternative 1 hese check valve will be t

full-stroke exercised during refueling outages when the reactor vessel head is removed and full SIS pump flow can be utilized. The total flow from one safety injection pump will be compared to the system flow balance requirements of the Technical Specifications to verify that these valves open to perform their function. The emergency core cooling system test line subsystem provides the capability for determination of the integrity 1

l of the high pressure boundaries.

The subsystem is used to verify that each of the series check valves can independently sustain operational differential pressure and is closed.

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l 3.3.2.1.2 Evaluation--The reviewer agrees with the applicant that valves U4 100, 121, 122, 123, 143, 144, 145, 146, U6 124, and 127 cannot be full-stroke exercised during power operation.due to the fact that the SIS pumps do not have the capacity to full flow into the RCS when the 15

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4 RCS is at normal operating pressure. The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to possible RCS low temperature overpressurization.

3.3.2.1.3 Conclusion--The reviewer concludes that the applicant's proposal to full-stroke exercise valves U4120,121,122,123, 143, 144, 145, 146, U6 124, and 127 on a refueling outage frequency should be sufficient to demonstrate proper valve. operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by. the Code and, therefore, relief should be granted.

3.3.2.2 Relief Recuest. The applicant has requested relief from exercising valves U6 079, 080, 081, and 082, accumulator outlet checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by sample disassembly / inspection on a refueling outage frequency.

3.3.2.2.1 Applicant's Basis for Requesting Relief--These check valves cannot be exercised during power operation as the 650 psig nitrogen charged accumulators cannot overcome normal RCS pressure in order to inject' their contents into the RCS.

These check valves cannot be exercised during cold shutdown as accumulator flow could result in a low temperature overpressurization of the RCS. As an alternative one of these valves will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the remaining valves will be disassembled.

3.3.2.2.2 Evaluation--The reviewer agrees with the applicant' that valves U6 079, 080, 081, and 082 cannot be full-stroke exercised during power operation due to insufficient accumulator discharge pressure.

The reviewer agrees with the applicant that these valves cannot be

~

full-stroke exercised during cold shutdown due to possible RCS low temperature overpressurization.

16 I

m-n

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-stroke capability of check valves. At each disassembly the applicant must verify that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

3.3.2.2.3 Conclusion--The reviewer concludes that the applicant's proposal to perform sample disassembly / inspection of valves U6 079, 080, 081, and 082 on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.3.2.3 Relief Request. The applicant has requested relief from exercising valves U6 083, 084, 085, and 086, accumulator and RHR checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by partial-stroke exercising these valves during cold shutdown and by sample disassembly / inspection on a refueling outage frequency.

3.3.2.3.1 Applicant's Basis for Requesting Relief--These check valves cannot be exercised during power operation as the 650 psig nitrogen charged accumulators cannot overcome normal RCS pressure in order to inject their contents into the RCS. These check valves cannot be exercised during cold shutdown as accumulator flow could result in a low temperature overpressurization of the RCS. As an alternative these valves will be partial-stroke exercised durir,g cold shutdown and one of these valves will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the remaining valves will be disassembled.

17

3.3.2.3.2 Evaluation--The reviewer agrees with the applicant that valves U6 083, 084, 085, and 086 cannot be full-stroke exercised during power operation due to insufficient accumulator discharge pressure.

The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to possible RCS low

~

temperature overpressurization.

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-stroke-capability of check valves. At each disassembly the applicant must verify that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

l 3.3.2.3.3 Conclusion--The reviewer concludes that the applicant's proposal to partial-stroke exercise during cold shutdown and to j

perform sample disassembly / inspection of valves U6 083, 084, 085, and 086 on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.4 Containment Spray System 3.4.1 Category C Valves 3.4.1.1 Relief Request.

The applicant has requested relief from exercising valves U6 001 and 008, RWST to containment spray pump checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by partial-stroke exercising these valves quarterly and by sample disassembly / inspection on a refueling outage frequency.

3.4.1.1.1 Applicant's Basis for Requesting Relief--These check valves cannot be exercised during power operation as the test flow path precludes full flow testing due to pipe sizing.

These check valve cannot 18

be exercised during cold shutdown as the required recirculation flow path would cause extensive damage to components inside containment. As an alternative these valves will be partial-stroke exercised quarterly and one of these valves will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the other valve will be disassembled.

3.4.1.1.2 Evaluation--The reviewer agrees with the applicant that valves U6 001 and 008 cannot be full-stroke exercised during power operation due to insufficiency of the test flow path capacity to allow full flow through the valves.

The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to the fact that the only full flow test path is into the containment spray header which will spray into containment thus damaging containment equipment.

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-st oke capability of check valves.

At each disassembly the applicant must verify that the disassembled valve is capable of full-stroking and that its internals are structurall,y sound (no loose or corroded parts).

3.4.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to partial-stroke exercise quarterly and to perform sample disassembly / inspection of valve U6 001 and 008 on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability 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 applicant has requested relief from exercising valves U6 015 and 016, containment spray checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to 19

verify valve operability by Appendix J, Type C, leak testing"and by sample disassembly / inspection on a refueling outage frequency.

3.4.2.1.1 ADplicant's Basis for Requesting Relief--These check valves cannot be exercised during power operation and cold shutdown as the only available flow test method would cause extensive damage to containment components. As an alternative these valves will be Appendix J, Type C, leak tested.and one of these valves will'be disassembled:and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the other valve will be disassembled.

3.4.2.1.2 Evaluation--The reviewer agrees with the applicant that valves U6 015 and 016 cannot be full-stroke exercised during power operation and cold shutdown due to containment equipment damage.

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-stroke capability of check valves. At each disassembly the applicant must verify that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

3.4.2.1.3 Conclusion--The reviewer concludes that the applicant's proposal to Appendix J, Type C, leak test and to perform sample disassembly / inspection of valves U6 015 and 016.on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code-and, therefore, relief should be granted.

e 20

. ~. - -

3.5 Chemical and Volume Control System-3.5.1 Category B Valves F

3.5.1.1 Relief Request. The applicant has requested relief from fail-safe testing valves HV 0190A and B, centrifugal charging pump to.

regenerative heat exchanger isolations, in accordance with the requirements of Section XI, Paragraph IWV-3415 and proposed to verify, valve operability by full-stroke exercising and stroke timing these valves quarterly.

3.5.1.1.1 Applicant's Basis for Reouesting Rel'ief--The safsty related position of these valves is open.

To fail-safe l test these. valves to the closed position does not stroke the valve in the direction required to perform a safety related function. Therefore, a fail-safe test.is not necessary. As an alternative these valves will be exercised and timed every quarter to ensure that they will perform their safety related function.

1 3.5.1.1.2 Evaluation--The reviewer agrees with the applicant-

}

that fail-safe testing valves HV 0190A and B serves no purpose as'these-3 valves fail closed when fail-safe tested and the safety related position l

for these valves is open. The reviewer agrees with.the applicant that i

performing a fail-safe test on these valves is not necessary.

SinceLthese l

valves do not have a required fail-safe position, this relief request is l

not necessary and should be deleted.

J 3.5.1.1.3 Conclusion--The reviewer concludes that'the

)

applicant's proposal to full-stoke exercise and stroke time valves HV 0190A-

]

and B quarterly should be sufficient to demonstrate proper valve operability.

The reviewer concludes that this relief request is unnecessary and should be deleted.

l 1

)

21 t

i 3.5.2 Category C Valves I.

3.5.2.1 Relief Request. The applicant has requested relief from exercising valves U6 142 and 149, charging pumps outlet checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by partial-stroke exercising these valves quarterly and by full-stroke exercising these valves on a refueling outage frequency.

j 3.5.2.1.1 Applicant's Basis-for Requesting Relief--These check valves cannot be exercised during power operation as the normal charging flow path is only capable of partial-stroking them. Alternate charging flow paths cannot be utilized due to safety injection nozzle thermal shock prohibitions. These check valves cannot be exercised during cold shutdown as charging pump flow could result in a low temperature overpressurization of the RCS. As an alternative these valves will be partial-stroke exercised quarterly and full-stroke exercised during refueling outages when the reactor vessel head is removed'and full charging pump flow can be utilized.

3.5.2.1.2 Evaluation--The reviewer agrees with the applicant that valves U6 142 and 149 cannot be full-stroke exercised during power operation due to chemical and volume control system (CVCS) alignment and thermal shock considerations. The reviewer agrees with the applicant that these valves cannot be full-stroke exercised during cold shutdown due to possible RCS low temperature overpressurization.

3.5.2.1.3 Conclusion--The reviewer concludes that-the applicant's proposal to partial-stroke exercise quarterly and full-stroke.

exercise valves U6 14E and 149 on a refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

22 n

'3'.5.2.2 ' Relief Request. The applicant has requested relief from-exercising valves U6189 and 436, charging pump suction from the RWST check and charging pump suction.from the RHR system check, in accordance with'the requirements of Section XI,. Paragraph IWV-3522 and proposed to verify valve operability by partial-stroke exercising.these valves during' cold shutdown and by full-stroke exercising these valves.on a refueling' outage frequency.

3.5.2.2.1 Applicant's Basis for Requesting' Relief--These check valves cannot be exercised during power operation or cold shutdown as both charging pumps would be required for proper flow, which would result in RCS j

- overpressurization.

Partial exercising by. operating one charging pump is.

undesirable due to resultant RCS boron concentration changes, which could cause a plant shutdown. As an alternative-these valves will be partial-stroke exercised during cold shutdown and full-stroke. exercised during refueling' outages when the reactor vessel head is removed and full-charging pump flow can be utilized.

3.5.2.2.2 Evaluation--The reviewer agrees with the applicant that valves U6 189 and 436 cannot'be full-stroke exercised during pcwer operation due 'to RCS overpressurization and undesirable RCS boron 1

concentration changes. The reviewer agrees with the applicant'that these i

I valves cannot be full-stroke exercised during cold shutdown due to RCS 1

overpressurization.

3 i

3.5.2.2.3 Conclusion--The reviewer concludes.that the applicant's proposal to-partial-stroke exercise during cold shutdown and full-stroke exercise valves U6189 and '43F ora, refueling outage frequency should be sufficient to demonstrate pm % r alve operability. The reviewer i

concludes that the alternate-testisg M p>

-d.will give reasonable-assurance of valve operability as requireo by the Code and, therefore',

j-~*

relief should be granted.

1 l

i 23 i

2

.a

3.5.31 Category A/C Valves 3.5.3.1 Relief Request. The applicant has requested relief from exercising valve U6 032, CVCS to regenerative heat exchanger check, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by verifying valve closure on a refueling outage frequency.

3.5.3.1.1 Applicant's Basis for Requesting Relief--This check valve cannot be exercised during power operation as the only method-available to verify reverse flow closure is valve leak testing during Appendix J, Type C, leak testing during refueling outages. As an alternative reverse flow closure will be verified during Appendix J, Type C, leak testing during refueling outages.

3.5.3.1.2 Evaluation--The reviewer agrees with the applicant that valve U6 032 cannot be verified to close during power operation or cold shutdown due to the fact that the only method.available to verify reverse flow closure is valve. leak testing during Appendix J Type C-leak testing during refueling outages.

3.5.3.1.3 Conclusion--The reviewer concludes that the applicant's proposal to verify closure of valve V6 032 on a refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.6 Auxiliary Component Cooling Water System 3.6.1 Category C Valves 3.6.1.1 Relief Request. The applicant has requested relief from exercising valves U4 084, 085, 086, and 087, auxiliary component cooling water to reactor coolant pump (RCP) thermal barrier checks, in accordance 24 l

with the-requirements of Section XI, Paragraph IWV-3522 and proposed to

' verify valve closure by full-stroke exercising these valves on 'a refueling r

['

outage frequency.

~3.6.1.1.1 Applicant's Basis for Requesting Relief--These check

. valves cannot be exercised during power operation as-interruption of RCP thermal barrier cooling water could damage the thermal barriers. These check valves-cannot be exercised during cold shutdown as installation and removal of test equipment'could delay plant'startup. As an alternative these valves will be' full-stroke exercised closed'during refueling outages.

3.6.1.1.2 Evaluation--The reviewer agrees with.the applicant that valves U4 084, 085, 086, and:087 cannot be full-or partial-stroke exercised closed during power operation due to required RCP thermal barrier cooling water flow. The reviewer agrees with the applicant that these

. valves cannot be full-or partial-stroke exercised closed during cold shutdown due to. plant startup considerations.

3.6.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to' full-stroke exercise closed valves U4 084, 085, i

086, and 087 on a refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate' testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.7 Main Steam System i

3.7.1 Category C Valves 3.7.1.1 Relief Request.

The applicant has requested relief from exercising valve U4 008, steam to auxiliary feedwater (AFW) pump check, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by. partial-stroke exercising this i

i l

25

aI Li-valve quarterly and full-stroke exercising this valve open during cold shutdown. Reverse flow closure will be verified on a refueling outage frequency by disassembly / inspection.

3.7.1.1.1 Applicant's Basis for Requesting Relief--This check valve cannot be exercised during power operation as the required steam flow would inject cold auxiliary feedwater into the steam generator (s) which would result in thermal shock to steam generator internals.

Reverse. flow-closure for this valve cannot be verified by flow or pressure. As an alternative <this valve will be partial-stroke exercised quarterly and full-stroke exercised open during cold shutdown.

Reverse flow closure will be demonstrated by disassembly / inspection and manually full-stroke exercising during refueling outages.

3.7.1.1.2 Evaluation--The reviewer agrees with the applicant that valve U4 008 cannot be full-stroke exercised during power operation due to the fact that the required steam flow would cause the steam driven auxiliary feedwater pump to inject cold auxiliary feedwater into the steam generator (s) which would result in thermal shock to steam generator internals. The reviewer agrees with the applicant that reverse flow closure can only be verified by disassembly / inspection.

3.7.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to partial-stroke exercise valve U4 008 quarterly, to full-stroke exercise this valve open during cold shutdown, and to disassemble this valve during refueling outages for reverse flow closure verification should be sufficient.to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

\\

~

l 26

3.8 Auxiliary Feedwater System 3.8.1 Category C Valves 3.8.1.1 Relief Request.

The applicant has requested relief from exercising valves V4117,118,119, and 120, feedwater bypass to steam generator checks,'in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by sample disassembly / inspection on a refueling outage frequency.

1 3.8.1.1.1 Applicant's Basis for Reouesting Relief--These check-valves cannot be exercised during power operation or cold shutdown as the only available method to verify reverse flow closure is by disassembly and observation of the disk position. As an alternative one of.these valves will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the remaining valves will be disassembled.

3.8.1.1.2 Evaluation--The reviewer agrees with the applicant that valves U4 117, 118, 119, and 120 can only be reverse flow closure verified by valve disassembly.

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-stroke capability of check valves. At each disassembly the applicant must verify that the disassembied valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

3.8.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to perform sample disassembly / inspection of valves U4 117, 118, 119, and 120 on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

27 w

3.9 Condensate and Feedwater System' 3.9.1 Category C Valves 3.9.1.1 Relief Request. The applicant has requested relief from

^

exercising valves V4 071, 073, 075, and 077, feedwater checks, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by sample disassembly / inspection on a.

refueling outage frequency.

4 3.9.1.1.1 Applicant's-Basis for Requesting Relief--These check valves cannot be exercised during power operation or cold shutdown as the only available method to verify reverse flow closure is by disassembly and observation of the disk position. As an alternative one of these valves will be disassembled and manually stroked during refueling outages on a staggered test basis.

If disassembly reveals that the valve is inoperable, the remaining valves will be disassembled.

3.9.1.1.2 Evaluation--The reviewer agrees with the applicant that valves V4 071, 073, 075, and 077 can only be. reverse flow closure verified by valve disassembly.

The NRC staff has concluded that valve disassembly / inspection using a manual full-stroke of the disk is an acceptable method to verify the full-stroke capability of check valves. At each disassembly the applica1t-must verify that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

3.9.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to perform sample disassembly / inspection of valves U4 071, 073, 075, and 077 on a refueling outage frequency, when performed in accordance with the previous discussion (Section 3.3.1.4.2) should be sufficient to demonstrate proper valve operability. The reviewer concludes 4

that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

28

.---r,

i

~

3.10 Containment Air Purification'and Cleanup System 3.10.1 Category A/C Valves 3.10.1.1 Relief Request. The applicant has requested relief from

~

4 exercising valves U4 001.and 002, hydrogen monitor checks, in accordance

~'

]~

with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve operability by exercising these valves closed on-a refueling outage frequency.

1 3.10.1.1.1 Applicant's Basis for Requesting Relief--These check-valves cannot be exercised.during power operation as the only method-available to verify reverse flow closure is valve leak testing during i

Appendix J, Type C, leak testing during refueling outages. As an alternative reverse flow closure will be verified during Appendix J, Type C, leak testing during refueling outages.

3.10.1.1.2 -Evaluation--The reviewer agrees with the applicant i

that valves U4 001 and 002 cannot be exercised closed during power l

operation or cold shutdown due to the fact that the only method available i

to verify reverse flow closure is valve leak testing during Appendix J l

Type C leak testing during refueling outages.

3.10.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to exercise valves U4 001 and 002 closed on a refueling outage frequency should be sufficient to demonstrate proper valve i

operability. The reviewer concludes that the alternate testing proposed' will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

I 1

4 29

3.11 Nitrogen to Accumulator System 3.11.1 Category A/C Valves 3.11.1.1 Relief Request. The applicant has requested relief from exercising valve U4 017, nitrogen supply check, in accordance with the requirements of Section XI, Paragraph IWV-3522 and proposed to verify valve -

~

operability by exercising.this-valve-closed on a= refueling outage frequency, 3.11.1.1.1 Applicant's Basis for Requesting Relief--This check valve cannot be. exercised during power operation as the only method available to verify reverse flow closure is valve leak testing during Appendix J, Type C, leak testing during refueling outages. As an alternative reverse flow closure will be verified during Appendix J, Type C, leak testing during. refueling outages.

3.11.1.1.2 Evaluation--The reviewer agrees with the-applicant that valve U4 017 cannot be' exercised closed:during~ power operation or cold' shutdown due to the fact that the only method available to verify reverse flow closure is valve leak testing during Appendix J Type C leak testing during refueling outages.

3.11.1.1.3 Conclusion--The reviewer concludes that the applicant's proposal to exercise valve U4 017 closed on a refueling outage frequency should be sufficient to demonstrate proper valve operability.

The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

3.12 Instrument Air System 3.12.1 Category A/C Valves 3.12.1.1 Relief Request. The applicant has requested relief from j

exercising valve U4 049, containment check, in accordance with the 1

30

-c,

- - +,

.~

requirements of Section XI, Paragraph IWV-3522 and proposed to verify operability by exercising this valve closed on a refueling outage frequency.

3.12.1.1.1 Applicant's Basis for Requesting Relief--This check valve cannot be exercised during power operation as the only method available to verify reverse flow closure is valve leak testing during Appendix J, Type C, leak testing during refueling outages. As an alternative reverse flow closure will be verified during Appendix J, Type C, leak testing during refueling outages.

3.12.1.1.2 Evaluation--The reviewer agrees with the applicant that valve V4 049 cannot be exercised closed during power operation or cold shutdown due to the fact that' the only method available to verify reverse flow closure is valve leak testing during Appendix J, Type C, leak testing during refueling outages.

3.12.1.1.3 Conclusion--The reviewer agrees that the applicant's proposal to exercise valve U4 049 closed on a refueling outage frequency should be sufficient to demonstrate proper valve operability. The reviewer concludes that the alternate testing proposed will give reasonable assurance of valve operability as required by the Code and, therefore, relief should be granted.

i s

31

y v

0 APPENDIX A NRC STAFF POSITIONS AND GUIDELINES 33 v

APPENDIX A NRC STAFF POSITIONS AND GUIDELINES 1.

Full-Stroke Exercising of Check Valves The NRC staff position is that check valves whose safety function is to open are expected to be full-stroke exercised.

Since the disk position is not always observable, the NRC staff position is that verification of the maximum flow rate through the check valve identified in any of the plant's safety analyses would be an adequate demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would permit maximum flow required through the valve.

It is the NRC staff's position that this reduced flow rate method of demonstrating full-stroke capability is the only test that requires measurement of the differential pressure across the valve.

2.

Valves Identified for Cold Shutdown Exercising The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operation, and these valves are specifically identified by the applicant and are full-stroke exercised during cold shutdowns; therefore, the applicant is meeting the requirements of the ASME Code, Paragraphs IWV-3412 and -3522.

Since the applicant is meeting the requirements of the ASME Code, it is not necessary to grant relief; however, during the review of the applicant's IST program, the reviewer verifies that it is not practical to exercise these valves during power operation and that the applicant's basis is valid.

It should be noted that the NRC differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for valves identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and each 35 l

j

. refualing outage. H:w:v2r, when relief is granted to perform tests on a i

. refueling outage frequency, testing is expected only dur'ing_each refueling-outage.

In addition, for extended outages', tests being performed are expected to be maintained as closely as practical to the Code-specified

-frequencies.

3.

Conditions for Valve Testing During Cold Shutdown Cold shutdown testing of' valves identified by the' applicant.is-acceptable when the following conditions are met:

a.

The applicant.is to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after i

shutdown, and continue until complete or the plant is ready to return to power.

j b..

Completion of all valve testing is not'a prerequisite to return to power.

c.

Any testing not completed during one cold shutdown should be

~

performed during any subsequent ~ cold shutdowns starting from-the I

last test performed at the previous cold shutdown.

i i

d.

For planned cold shutdowns, where ample time is available 'and.

l testing all'the valves identified for the cold shutdown test frequency in tne 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.

i 4.

Category A Valve-Leak-Test Requirements for Containment Isolation Valves (CIVs)

All containment isolation valves that are Appendix J, Type C, leak tested should be included in the IST program as Category A or A/C valves.

The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, j

i l

i 36 eye-y<me-1-,--y

, em r e-s

-y-

,*y---

w*-r-+----+---

~ - -

9-3---

-w--+w v--

--mn

-*+Trme--

e e ir e-e, a,-

e v m--

,-r--et---

, -, - -r

Appendix J.

Relief from Paragraphs IWV-3412 through -3425 (1983 Edition through Summer 1983 Addenda) for containment isolation valves presents no safety problem since the intent of these paragraphs is met by Appendix J requirements, however, the applicant must comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs IWV-3426 and

-3427 (1983 Edition through Summer 1983 Addenda).

Based on the considerations discussed above, the NRC staff has concluded that the alternate testing proposed will give reasonable assurance of valve leak-tight integrity as required by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

5.

Application of Appendix J Testing to the IST Program The Appendix J review for this plant is completely separate from the IST program review. However, the determinations made by that review are I

directly applicable to the IST program.

The applicant has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.

6.

Safew-Related Valves i

i This review was limited to valves whose function is safety-related.

Valves whose function is safety-related are defined as those valves that are needed to mitigate the consequences of an accident and/or to shut down the reactor to the cold shutdown conditions 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 applicant may have included valves whose function is not safety-related in their IST program as a

~

decision on their part to expand the scope of their program.

b i

37

7.

Active Valves The NRC staff position is that active valves are those for which changing position may be required to shut down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.

Included are valves which respond automatically to an accident signal and valves which may be optionally utilized but are subject to plant operator actions, such as valves utilized to establish long term recirculation following a*LOCA.~

8.

Rapid-Acting Power Operated Valves The NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less.

Relief from the trending requirements of Section XI (Paragraph IWV-3417(a), 1983 Edition through Summer 1983 Addenda) presents no safety concerns for these valves since variations in stroke times will be affected by slight variations in the response times of the personnel performing the tests. However, the staff does require that the applicant assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

9.

Pressurizer Power Operated Relief Valves The NRC has adopted the position that the pressurizer power operated relief valves (PORVs) should be included in the IST program as Category B valves and tested to the requirements of Section XI. However, since the PORVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that routine exercising during power operation is "not practical" and, therefore, not required by IWV-3410.

The PORV's function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low-temperature overpressurization conditions and should be exercised prior to initiation of system conditions for which vessel protection is needed.

38

F The following test sch::dule is r: quired:

a a.

Full-stroke exercising should be performed at each cold shutdown or, as a minimum, once each refueling cycle.

b.

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

d c.

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

d.

The PORV block valves should be included in the IST program and tested quarterly.to provide protection against a small break LOCA should a PORV fail open.

The applicant has included the PORVs (1201-PV-0455A and 0456A) in the IST program as Category B valves and the PORV block valves (HV 8000A and B) as Category B valves and is exercising them in accordance with the above guidelines.

10. Valves Which Perform a pressure Boundary Isolation Function The following valves meet the criteria for pressure boundary isolation valves and have been included in the IST program as Category A or A/C and are leak tested in accordance with the requirements of Section XI.

HV-8701A HV-8701B RHR Pump Suction Valves HV-8702A HV-87028 a.

The staff position described in Item A.3 regarding cold shutdown testing is not applicable to the PORVs; however, in case of frequent cold shutdowns, testing of the PORVs is not required more often than each three months.

~

39

h 1204 U4 120 SIS to hot leg _ second isolation valves U4'121 U4 122 i

U4 123 U6 079 Accumulator second isolation valves 1

U6 080 U6 081 U6.082 U6 083.

Injection line first isolation valves

.U6 084 U6 085-U6 086 1

U6 124 SIS to hottleg first isolation valves-U6 125.

U6 126.

V6 127 1

),

U6 128 RHR to hot leg second isolation valves U6 129 U4 143 SIS to cold leg second isolation valves U4 144 l

U4 145 i

U4 146 V6 147 RHR to cold leg second isolation valves-V6 148 U6 149 l

U6 150 4

l

)

i 40 1

9 d

APPENDIX B VALVES TESTED DURING COLD SHUTDOWNS e

i 41

APPENDIX B VALVES TESTED DURING COLD SHUTDOWNS The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation. These valves are specifically identified by the owner in accordance with Paragraph IWV-3412 and 3522 and are full-stroke exercised during cold shutdowns and refueling outages. All valves in this Appendix have been evaluated and the reviewer agrees with the applicant that testing these valves during power operation is not possible due to the valve type and location or system design. These valves should not be full-stroke exercised during power operation.

These valves are listed below and grouped according to the system in which they are located, l

1 1.

REACTOR COOLANT SYSTEM l

1.1 Category A Valves Residual heat removal pump suction isolation valves HV 8701A, B, 8702A, and B cannot be exercised during power operation due to a reactor coolant system pressure interlock (<750 psig) which prevents residual heat removal system overpressurization. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

1.2 Category B Valves Reactor head vent valves HV 0442A, B, 8095A, B, 8096A, and B cannot be exercised during power operation as the downstream vent valve will open due to the reactor coolant pressure surge when exercising the upstream vent valve. This uncontrolled flow path could cause a loss of reactor coolant l

and system pressure. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

43

Powar operated relief valves PV 0455A and 0456A cannot be exercised during. power operation due to.the resultant. undesirable reactor coolant-system pressure and pressurizer level transients and possit,le subsequent

~

reactor trip. These valves will be full-stroke exercised during cold shutdowns and refueling outages, and as' described in Section 9 of Appendix A.

2.

SAFETY INJECTION SYSTEM 2.1 Category B Valves-Hot _ leg loop isolation valves HV 8802A and B, RWST isolation valve HV 8806, RHR to cold leg isolation valves HV 8809A and 8, safety injection-pump miniflow valve HV 8813, SIS cold leg injection valve HV 8835, and crossover isolation valve HV 8840 cannot be exercised due to the technical specification requirement that power is removed from the valves' operators during plant power operation.

In addition, failure of these valves during testing would divert or render unavailable analyzed safety injection.

These-valves will be full-stroke exercised during cold shutdowns and refueling outages.

2.2 Category A/C Valves SIS to hot leg check valves U6125 and 126, RHR to hot leg check valves U6 128 and 129, and RHR to cold leg check valves U6 147, 148, 149, and 150 cannot be exercised during power operation as the RHR or SI pumps cannot overcome reactor coolant operating pressure. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

3.

CONTAINMENT SPRAY SYSTEM-3.1 Category B Valves Spray additive tank outlet isolation valves HV 8994A and B cannot be-exercised during power operation as the unavailability of the spray l

44 i

i.--

1 additiva tank would render the containment spray system unable to perform its safety function. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

l l

4.

CHEMICAL AND VOLUME CONTROL SYSTEM i

1 4.1 Category A Valves l

RCP seal water isolation valves HV 8100 and 8112 cannot be exercised

}

s during power operation due to possible RCP seal damage. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

Charging pump to reactor coolant system isolation valve HV 8105 and j

letdown isolation valves HV 8152 and 8160 cannot be exercised during power operation due to interruption of pressurizer level control and possible subsequent plant shutdown. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

4.2 Category B Valves Charging pumps to RCS isolation valve HV 8106 and letdown isolation valve HV 15214 cannot be exercised during power operation due to interruption of pressurizer level control and possible subsequent plant shutdown.

These valves will be full-stroke exercised during cold shutdowns and refueling outages.

VCT isolation valves LV 01128 and C, and RWST valves LV 01120 and E cannot be exercised during power operation because any alternate charging i

pump suction source would adversely affect RCS boron concentration which could result in plant shutdown. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

a 45

i 4.3 Category C Valves Boric acid to charging pump check valves U4 185 and 499 cannot be exercised during power operation as this would adversely affect RCS boron concentration which could result in plant shutdown. These valves will be full-stroke exercised during cold shutdowns and refueling outages, i

a 5.

AUXILIARY COMPONENT COOLING WATER SYSTEM 5.1 Category A Valves Auxiliary component cooling-water supply isolation valves HV 1978 and 1979 and auxiliary component cooling water return isolation valves HV 1974 and 1975 cannot be exercised during power operation because interruption of RCP thermal barrier cooling water could result in pump damage. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

5.2 Category B Valves t

Thermal barrier isolation valves HV 2041, 19051, 19053, 19055, and 19057 cannot be exercised during power operation because interruption of RCP thermal barrier cooling water could result in pump damage. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

6.

MAIN STEAM SYSTEM 6.1 Category 8 Valves-Main steam isolation valves HV 3006A, B, 3016A, 8, 3026A, B, 3036A, j

and B cannot be exercised during power operation as the resultant severe main steam pressure transient would cause a plant shutdown.

These valves J

will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages.

46 f

Main steaa power operated relief valves PV 3000, 3101, 3020, and 3030 cannot be exercised during power operation as an open failure would result in plant shutdown. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages.

6.2 Category C Valves Auxiliary feedwater pump check valves U4 006 and 404 cannot be

/

exercised during power operation due to the resultant feedwater nozzle thermal shock when operating the steam driven auxiliary feedwater pump.

This could cause steam generator feedwater nozzle cracking. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

7.

AUXILIARY FEEDWATER SYSTEM 7.1 Category B Valves Feedwater bypass isolation valves HV 15196, 15197, 15198, and 15199 cannot be exercised during power operation as the resultant interruption of feedwater flow could cause steam generator water level oscillation and subsequent reactor trip. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

7.2 Category C Valves Auxiliary feedwater pump outlet check valves U4 001, 002, and 014, auxiliary feedwater pump suction check valves U4 013, 033, 051, 052, 058, and 061, auxiliary feedwater pump isolation check valves U4 017, 020, 023, 026, 037, 040, 043, 046, and steam generator inlet check valves V4113, 114, 115, and 116 cannot be exercised during power operation due to the resultant feedwater nozzle thermal shock when operating the auxiliary feedwater pumps.

This could cause steam generator feedwater nozzle cracking.

These valves will be full-stroke exercised during cold shutdowns e

and refueling outages. Valves U4 051, 052, 058, and 061 will be partial-stroke exercised quarterly.

47 A

r l

l 8.

CONDENSATE AND FEEDWATER SYSTEM l

8.1 Category B Valves Steam generator feedwater isolation valves HV 5227, 5228, 5229, and 5230 cannot exercised during power operation as the resultant stoppage of feedwater flow would cause an undesirable steam generator water level transient and possible plant shutdown.~ These valves will be partial-stroke I

exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages.

9.

CONTAINMENT AIR PURIFICATION AND CLEANUP SYSTEM 9.1 Category A Valves Purge supply isolation valves HV 2626A and 2627A and purge exhaust isolation valves HV 2628A and 2629A cannot be exercised as they have not been demonstrated capable of closing during a LOCA or steam line break accident.thus technical specifications preclude opening of these valves during power operation. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

10.

FIRE PROTECTION WATER SYSTEM 10.1 Category A Valves Header isolation valve HV 27901 cannot be exercised during power operation as failure in the open position would unnecessarily compromise containment integrity.

This valve will be full-stroke exercised during cold shutdowns and refueling outages.

1 8

48

11.. INSTRUMENT AIR SYSTEM 11.1 Category A Valves Isolation valve HV 9378 cannot be exercised during power operation as failure in the closed position would case a loss of containment instrument air. The resultant loss of plant letdown capability could cause loss of pressurizer level control and subsequent plant shutdown. This valve will

)

be full-stroke exercised during cold shutdowns and refueling outages.

e j

49

o

)

APPENDIX C I

P&ID LIST 3

i

)

I d

I k

1 J

i e

D i

e n

I i

i 51 i

APPENDIX C The P& ids and drawings listed below were used using the course of this 4

review.

J System Drawing No.

Revision 4

Post Accident Sampling IX4DB110 4

Reactor Coolant IX4DB111 10 j.

l Reactor Coolant IX408112 13 Chemical and Volume Control IX408114 12 Chemical and Volume Control IX4DB116-1 6

{

Chemical and Volume Control 1X408116-2 6

Chemical and Volume Control 1X4DB118 9

4 1

Safety Injection 1X4DB119 10 Safety Injection 1X408120 8

]

Safety Injection IX4DB121 11

]

Residual Heat Removal IX408122 11 Waste Processing-Liquid 1X408127 9

Spent Fuel Cooling and Purification 1X4DB130 12 j

Containment Spray 1X408131 11 Nuclear Service Cooling Water IX408133-1 11 Nuclear Service Cooling Water IX408133-2 12 Nuclear Service Cooling Water IX408134 10 Nuclear Service Cooling Water IX4DB135-1 12 Nuclear Service Cooling Water 1X4DB135-2 11 I

Component Cooling Water 1X408136 10 l,

Auxiliary Component Cooling Water 1X4DB138-1 9

i j

Auxiliary Component Cooling Water IX408138-2 10 l

)

53 I

System Drawing No.

Revision Nuclear Sampling Liquid 1X408140:

92 Containment and Auxiliary Building Drains -

IX408143 13 Radioactive Main Steam IX4DB159-1 13 Main Steam IX4DB159-2 11' j

Main Steam IX4DB159-3 7

Auxiliary Feedwater IX4DB161-2 10 Auxiliary Feedwater Pump IX408161-3 9

Condensate and Feedwater 1X408168-3

- 12 Diesel Generator IX408170-1_

8 Diesel Generator IX4DB170-2 7

Fire Protection Water 1X40B174-4 9

Service Air 1X4DB186-1 10 Instrument Air IX4DB186-2.

10 Plant Demineralized Water AX408190-2 10 Purification and Clean-Up 1X4DB213-1 4

Purification and Clean-Up 1X4DB213-2.

3 i

1 Safety Related Chillers 1X4DB221 9

I i,

5

.m-

f 5

)

APPENDIX D IST PROGRAM AN0MALIES IDENTIFIED OURING THE REVIEW 1

1 i

i d

55

APPENDIX D IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Inconsistencies and omissions in the applicant's program noted during i

the course of this review are summarized below. The applicant should resolve these items in accordance with the evaluations, conclusions, and guidelines' presented in this report.

)

1.,

Pump relief request No. 2 requests relief from measuring boric acid transfer pumps flow due to # low instruments not being installed.

Not having instrumentation installed does not negate the requirement to measure flow (section 2.2.1 of this report).

2.

Valve relief request No. I requests relief from the corrective action requirement of measuring degraded and increasing valve stroke times monthly for valves identified as being tested on a cold shutdown frequency (Appendix B of this report). The applicant wishes to measure cold shutdown frequency tested degraded valves not being repaired as the monthly testing would not be applicable and the plant could go to power operation with the degraded valves.

Relief should not be granted as corrective action requires the degraded valves to be repaired (Section 3.1.3 of this report).

i

-57

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BIBLIOGRAPHIC DATA SHEET EGG-NTA-7468

$tt #45f avCTH3hS O4 t=t mEvinst 3 f af La A=O Suef atte J Llava eLama TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM V0GTLE ELECTRIC GENERATING PLANT, UNIT 1 4 Q Art stront COMPLETED uomrw vtan February 1987

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aoAfam m ar =wso R. F. Bonney H. C. Rockhold l

J February 1987 F s t**OmutmG OM4Am 2Af 60N Naut ANO waeksNG AOCatss ssacent,Ceses a PaoJECT,T ASK,WCmE UNsT Noweta NRR & I&E

acao"A" aw""a EG&G Idaho, Inc.

P. O. Box 1625 A6811 Idaho Falls, Idaho 83415 to $PON10meNG OmGANidareON Naut A40 MaaLahG AOomt13isac8veel,Comes e ta TYPE Op mtPQaf PWR-A Engineering Branch Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission m Plasco Covmo <>a ~~ ~-,

Washington, DC 20555 12 SUPPLEMENiame %QTES v3 AS$f m ACT dl# wers. or ses#

This EG&G Idaho, Inc. report presents the results of our evaluation of the Vogtle Electric Generating Plant, Unit 1 Inservice Testing Programs for pumps and valves that perform a safety related function.

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