ML20215M568

Rev 1 to Ser,Pump & Valve Inservice Testing Program,Big Rock Point Plant, Informal Rept

ML20215M568
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	10/31/1985
From:	Ransom C, Rockhold H EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20215M562	List: ML20215M560 ML20215M568
References
CON-FIN-A-6445 EGG-EA-5099, EGG-EA-5099-R01, EGG-EA-5099-R1, NUDOCS 8611030031
Download: ML20215M568 (47)

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cGG-EA-5099 Revision 1 SAFETY EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BIG ROCK POINT PLANT C. B. Ransom H. C. Rockhold Published October 1985 s

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570

. FIN No. A6445

O ABSTRACT This EG&G Idaho, Inc. report presents the results of our evaluation of the Big Rock' Point Plant Inservice Testing Program for safety related pumps ano valves.  !

FOREWORD This report is supplied as part of the " Review of Pump and Valve l

Inservice Testing Programs for Operating Plants" Program being conducted l for the U.S. Nuclear Regulatory Comission, Office of Nuclear Reactor Regulation, Division of Engir.eering, by EG&G Idaho, Inc., NRR and I&E Support Section.

The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-10-11-2, FIN No. A6445.

Docket No. 50-155 ii

CONTENTS

1. INTRCDUCTION .......................................'.............. 1 1

l. 2. PUMP TESTING PROGRAM ...........:..... ............. ........... 3

\

1 2.1 Diesel and Electric Fire Pumps ............................. 3

{

2.2.1 Relief Request ..................................... 3 2.2 Core Spray Pumps ........................................... 5 2.2.1 Relief Request ..................................... 5 2.2.2 Relief Request ..................................... 6 I 3. VALVE TESTING PROGRAM ............................................ 8 3.1 General Considerations ..................................... 8 3.1.1 Full-Stroke Exercising of Check Valves ............. 8 l

3. T.2 Valves Identified for Cold Shutdown Exercising .....

8 3.1.3 Conditions for Valve Testing During Cold Shutdowns .......................................... 9 3.1.4 Category A Valve Leak Test Requirements for l Containment Isolation Valves (CIVs) ................ 10 l 3.1.5 Application r,f Appendix J Testing to the IST Program ............................................ 10 3.1.6 Safety Related Valves .............................. 10 ..

3.1.7 Active Vaives ...................................... 11 '

3.1.8 Valves Which Perform a Pressure Boundary Isolation Function ........................................... 11 3.2 General Relief Requests .................................... 13 3.2.1 Containment Isolation Valves ....................... 13 1

3.3 Steam and Condensate System ................................ 14 3.3.1 Category A/C Valves ................................ 14 3.4 Nuclear Steam Supply System ................................ 15 3.4.1 Category A/C Valves ................................ 15 3.4.2 Category C Valves .................................. 17 3.5 Fire and Post Incident Cooling ............................. 18 3.5.1 Category B valves .................................. 18 3.5.2 Category C Valves .................................. 19

. iii

3.6 Re acto r Depres s urizatio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.6.1 Category B Valves .................................. 21 3.7 Make-up and Condensate Demineralization System ............. 22 3.7.1 Category A/C Valves ................................ 22 APPENDIX A ............................................................ 25

1. CODE REQUIREMENTS--VALVES ........................................ 27

2. CODE REQUIREMENTS--PUMPS ......................................... 27 j APPENDIX B--VALVES TESTED DURING COLD SHUTDOWNS ....................... 29 APPENDIX C--P&ID LIST ................................................. 33 APPENDIX D--IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW ............ 37 APPENDIX E--VALVES TESTED DURING COLD SHUTDOWN-DETAILS . .. . . . . . . . . . .. . . 41

1. REACTOR CLEANUP, SHUTDOWN, AND POISON SYSTEMS .................... 43 1.1 Category B Valves .......................................... 43 1.2 Category C Valves .......................................... 44

2. CONTROL R00 DRIVE SYSTEM ......................................... 44 2.1 Category B Valves .......................................... 44 2.2 Category C Valves .......................................... 44

3. NUCLEAR STEAM SUPPLY SYSTEM ...................................... 45 3.1 C at e g o ry A V a l ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 3.2 Category B Valves .......................................... 45 4 FIRE AND POST INCIDENT COOLING SYSTEM ............................ 45 4.1 Category B Valves .......................................... 45 4.2 Category C Valves .......................................... 46 iv

d SAFETY EVALUATION REPORT -

PUMP AND VALVE INSERVICE TESTING PROGRAM BIG ROCK POINT PLANT

1. INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program subnitted by the Consumers Power Company (CPC) for its Big Rock Point Plant.

The licensee's IST program, Revision 9 dated January 21, 1983 was reviewed to verify compliance of proposed tests of pumps and valves whose function is safe.ty r. elated with the requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, 1977 through summer 1978 addenda. Those items not in compliance were discussed in a conference call between Consumers Power Company, NRC, and EG&G Idaho, Inc., representatives on May 16, 1984. Consumers Power Company responded to some of the items that remained open after the conference call in a submittal dated October 4, 1984. In their IST program and the October 4, 1984 submittal, Consumers Power Company has requested relief from the Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.

Any IST program revisions subsequent to those noted above are not adoressed in this SER. Required program changes, such as additional relief requests or the deletion of any components from the IST Program, should be submitted to tne NRC under separate cover in order to receive promrt attention, but l should not be implemented prior to review and approval by the NRC.

The conclusions in this SER of the Big Rock Point Plant pump and valve inservice testing program and the associated relief requests are those of the NRC staff. These findings 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 system test requirements.

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.... . . - . -.. - .- -.~....... . . . ~ . - - - - - . . . . . . . . . . . - - -

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

Category A, B ano C valves that meet the requirements of the ASME '

Code,Section XI, and are not exercised quarterly are listed in Appendix B.

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

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

The details of valve cold shutdown testing justifications are included in Appendix E.

2 1

2. PUMP TESTING PROGRAM The Big Rock Point IST program submitted by Consumers Power Company was examined to verify that all pumps whose function is'safaty related are included in the program and are subjected to the periodic tests required by the ASME Code,Section XI. The staff's review found that these pumps are tested in accordance with Section XI except for those pumps identified below for which specific relief from testing has been requested and as noted in Appendix D. Each Consumers Power Company basis for requesting relief from the pump testing requirements and the staff's evaluation of that request is sumarized below.

2.1 Diesel and Electric Fire Pumps 2.1.1 Relief Request The licensee has requested relief from the Section XI requirement to measure diesel and electric fire pump parameters monthly and proposed to measure these parameters during cold shutdowns and refueling outages.

2.1.1.1 Code Requirement. Refer to Appendix A.

2.1.1.2 Licensee's Basis for Requesting Relief. The electric and diesel fire pumps cannot be tested during normal power operations. The valve lineup required to effectively test these pumps diverts ECCS flow that is required to mitigate the consequences of an accident by keeping the core covered.

2.1.1.3 Evaluation. The staff agrees with the licensee's basis and, therefore, relief should be granted from the monthly testing requirements of Section XI for the electric and diesel fire pumps. The licensee has demonstrated that changing the valve lineup to perform pump testing would divert ECCS flow from the core if it were required for mitigating the consequences of an accident, therefore, this pump testing is impractical during power operation.

3

2.1.1.4 Conclusion. The staff concludes that the licensee's proposal to measure pump parameters on the diesel and electric fire pumps during cold shutdowns and refueling outages should provide sufficient information to demonstrate the operability of the dieseLand electric f. ire pumps and to .

dstect any pump degradation. The staff concludes that the proposed alternate testing will give reasonabie assurance of pump operability -

required by the Code and that the relief thus granted will not endanger life or property or- the connon defense and security of the public.

2.1.2 Relief Request The licensee has requested relief from the Section XI requirement to measure pump bearing temperatures yearly for the diesel and electric fire pumps.

2.1.2.1 Code Requirement. Refer to Appencix A.

2.1.2.2 Licensee's Basis for Requesting Relief. The electric and diesel fire pumps have water lubricated bearings on long shafts making them inaccessible for bearing temperature measurement. Also, bearing '

temperature will vary with the temperature of the water being pumped and a useful reference value cannot be established.

2.1.2.3 Evaluation. The staff agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring pump bearing temperatures yearly on the electric and diesel fire pumps. The licensee has demonstrated that dud to inaccessibility of the pump bearings, the bearing temperatures cannot be measured. The licensee has also demonstrated that due to the variable temperature of the cooling water being pumped, a reference temperature for use in analyzing pump degradation cannot be established.

2.1.2.4 Conclusion. The staff concludes tnat the licensee's proposal to measure all pump parameters, except bearing temperature, should provide sufficient information to monitor pump degradation. The staff concludes 4

that the alternate testing proposed will give reasonable assurance of pump operability and that the relief thus granted will not endanger life or property or the common defense and security of the public.

2.2 Core Soray Pumos 2.2.1 Relief Reouest The licensee has requested relief from the Section XI requirement of measuring pump parameters monthly and has proposed to measure these parameters during refueling outages.

2.2.1.1 Code Requirement. Refer to Appendix A.

2.2.1.2 Licensee's Basis for Reouesting Relief. These pumps are part of the Emergency Core Cooling System., Testing during power operations would require a valve lineup which would preclude their performing their required function after a loss of coolant accident (LOCA). In the event of a LOCA, areas which must be entered to change this valve lineup would be untenable. In addition, testing during power operation would require personal entry into.the very high rauiation area directly beneath the reactor vessel.

During cold shutdown, the overall time required to perform testing is about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The additional radiation exposure received for each test woula be from 250 mR to 500 mR. This could possibly mean up to 6000 mR additional exposure if the reactor was in cold shutcown every month of the year, oue to other problems.

2.2.1.3 Evaluation. The staff agrees with the licensee's basis for not testing core spray pumps 2A and 2B during power operation and, therefore, relief should be granteo from the monthly testing requirements of Section XI. The licensee has demonstrated that the valve lineup required for pump testing isolates the core spray recirculation system and makes it unavailable to mitigate the consequences of an accident. Changing C

l I

the pump test valve lineup requires entry into the containment which would prevent cnanging to a correct safety system valve lineup following an accident. However, the staff does not agree with the licensee's basis for not testing core spray pumps 2A and 28 during cold shutcowns.

2.2.1.4 Conclusion. The staff concludes that the core spray pumps should not be exercised monthly during power operation since the exercising lineup could result in this system not being able to perform its safety function. However, the licensee should test the core spray pumps during cold shutdowns.

2.2.2 Relief Request The licensee has requested relief from the Section XI requirement to measure pump bearing temperature yearly for the core spray pumps.

2.2.2.1 Code Reouirement. Refer to Appendix A.

2.2.2.2 Licensee's Basis for Reouesting Relief. The core spray pumps have water lubricated bearings on long shafts making them inaccessible for bearing temperature measurements. Also, bearing temperature will vary with the *,emperature of the water being pumped and a useful reference value cannot be established.

2.2.2.3 Evaluation. The staff agrees with the licensee's basis and, therefore, relief should be granted from the Section XI requirement of measuring pump bearing temperatures yearly for the core spray pumps. The licensee has demonstrated that due to inaccessibility of the bearings, the bearing temperature cannot be measured. The licensee has also demonstrated that due to the variable temperature of the fluid being pumped, a reference temperature for use in analyzing pump degradation cannot be established.

2.2.2.4 Conclusion. The staff concludes that the licensee's proposal to measure all pump parameters, except bearing temperature, should provide sufficient information to monitor pump degradation. The staff concludes 6

f.

- that the alternate testing proposed will give reasonable assurance of pump operability and that the relief thus granted will not endanger life or

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3. VALVE TESTING PROGRAM The Big Rock Point IST program submitted by Consumers Power Company tras examined to verify that valves whose function is safety,related are included in the IST program and are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. The staff's review found that, except as noted in Appendix 0 l or where specific relief from testing has been requested, these valves are tested to the Lode requirements and the NRC positions and guidelines summarized in Appendix A and Section 3.1 of this report. Each Consumers Power Company basis for requesting relief from the valve testing requirements and the staff's evaluation of that request is sumarized below and grouped according to system and valve category.

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

3.1.2 Valves Identif'ed for Cold Shutdown Exercising j The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operation and the valves are specifically ioentified by the licensee and are full-stroke exercised 8

. '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 veriEjed that it is not practical to exercise these valves during power operation and that we agree with the licensee's basis. ,

It should be noted that the NRC differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for valves identified for testing curing cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and during each refueling outage. However, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling outage. In addition, for extended refueling outages, tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies.

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

1. The licensee is to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power.

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

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.

9

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

3.1.4 Category A Valve Leak Test Recuirements for Containment Isolation Valves (CIVs)

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

The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, Appendix J. Relief from Paragraphs IWV-3420 through -3425 (1977 Edition through Summer 1978 , 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 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.

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

3.1.6 Safety Related Valves 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 10

..___n__ -

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 IJcensee 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.

3.1.7 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.

3.1.8 Valves Which Perform a Pressure Boundary Isolation Function The following valves appear to perform a pressure boundary isolation function, however, they are not categorized A or A/C as appropriate and are not individually leak tested in accordance with NRC staff acceptance criteria for pressure boundary isolation valves. These valves should be categorized A or A/C, individually leak rate tested in accordance with the guidelines listed below, and included in the Big Rock Point Plant Technical Specifications.

Shutdown Cooling System M0-7056 Shutdown cooling system isolation valve M0-7057 Shutdown cooling system isolation valve M0-7058 Shutdown cooling system isolation valve M0-7059 Shutdown cooling system isolation valve.

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. .. . . . .. . . . . . . - . . . . - . . . . . ~ : : . -- - ..

Core Spray System M0-7071 Core spray isolation valve VPI-303 Core spray primary check valve M0-7061 Core spray isolation valve VPI-304 Redundant core spray check valve. l

l. To demonstrate ,the integrity of all pressure isolation valves, periodic leakage testing shall be accomplished on each of the listed valves prior to exceeding 600 psig reactor coolant system pressure every time the plant is placed in a cold shutdown condition for refueling, each time the plant is placed in a cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been acconclished in the preceding 9 months, and prior to returning the valve to service after maintenance, repair or replacement work is performed.

2. With a test differential pressure of not less than 150 psid, the valve leakage shall not exceed the amounts indicated in a through d below.

a. Leakage rates less than or equal to 1.0 gpm are considered acceptable

b. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are considered acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.

c. Leakage rates greater than 1.0 gpm.but less than or equal to 5.0 gpm are considered unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.

d. Leakage rates greater than 5.0 gpm are considered unacceptable.

12

3. If the leakage is not measured or they exceed the specified amounts, an orderly shutdown shall be initiated within I hour and the reactor shall be in the cold shutdown' condition within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

3.2 General Relief Requests 3.2.1 Containment Isolation Valves 3.2.1.1 Relief Recuest. The licensee has requested relief from the requirements of Subsections IWV-3426 and -3a27 of the Code for all containment isolation valves and proposed to calculate a combined leakage rate and take corrective actions if the combined leakage rate is 75% or greater of the Technical Specification and Appendix J allowable containment

leakage.

3.2.1.1.1 Code Requirement--IWV-3426

Leakage rate measurements shall be compared with previous measurements and with the permissible leakage rates specified by the plant Owner for a specific valve.

IWV-3427: Valves with leakage rates exceeding the values specified by the Owner shall be replaced or repaired. For valves 6 in. nominal pipe size and larger, if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage

rate and the maximum permissible rate by 50% or greater, the test frequency shall be doubled; the tests shall be scheduled to coincide with a cold shutdown until corrective action is taken, at which time the original test frequency shall be resumed. If tests show a leakage rate increasing with time, and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be replaced or repaired.

3.2.1.1.2 Licensee's Basis for Requesting Relief--The requirements of the Big Rock Point Plant Technical Specifications and 10CFR50 Appencix J are met by the methodology employed to analyze valve leakage rate and initiation of corrective action to correct excessive leakage rates. Indivioual valve leak rates are calculated and ccmbined 13

-- * - - - 9.sy,, . - - - , -w - y7 ,,~&-_--7-7--,-3 _---_.--.7.-_n __ _--y -~m- - _. , . - - - - -., -.--- .--.-*, . - m -.

T with all other component leak rates to give a fraction of the Technical Specifications and Appendix J allowable containment leakage. Corrective action, to repair or replace components with excessive leakage, is taken when 75% of the allowable leakage rate is reached. -

Code requirements are based on individual valve leak rates but the analysis and corrective actions are directed toward the same end result as those employed at Big Rock Point. This ensures the Technical Specifications and Appendix J requirements are not exceeded and ultimately ensures operational readiness of the components which are required to mitigate the consequences of an accident.

3.2.1.1.3 , Evaluation--The staff's position is that the requirements of IWV-3426 and -3427 must be met for containment isolation valves. Permissible leakage rates should be specified for each containment ,

isolation valve and the applicable corrective actions from IWV-3427 should be followed.

3.2.1.1.4 Conclusion--The staff concludes that the proposed alternate testing is not adequate, and that the licensee is require'd to analyze the leakage rate of individual containmert isolation valves and perform corrective action in accordance with the requirements of Sections IWV-3426 and -3427 of the Code.

i 3.3 Steam and Condensate System 3.3.1 Category A/C valves 3.3.1.1 Relief Recuest. The licensee has requested relief from the exercising requirements of Section XI for VRD-310, the CR0 pump outside containment suction check valves, and the CR0 pump suction poppet check valves and proposed to verify these valves open during power operation and verify them shut during refueling outages.

la

. 3.3.1.1.1 Code Requirement--Refer to Appendix A.

3.3.1.1.2 Licensee's Basis for Requesting Relief--These check valves can be verified open during power operation by observing normal CR0 pump operation. The safety function of these valves is to shut following a

- reactor trip.. A leak-rate test is required to verify valve closure. This leak-rate test will be accomplished during refueling outages.

3.3.1.1.3 Evaluation--The staff agrees with the licensee's basis and, therefore, relief should be granted from the quarterly exercising requirements of Section XI for valves VRD-310 and the CRD pump suction poppet check valves. The licensee has demonstrated that valve closure can only be verified during a leak-rate test because these valves are not equipped with local or remote position indicators.

3.3.1.1.4 Conclusion--The staff concludes that the proposed alternate testing of full-stroke exercising and performing leak-rate tests on these valves during each refueling outage should provide reasonable assurance of proper valve operability and that the relief thus grantea will j nct endanger life or property or the common defense and security of the public.

j 3.4 Nuclear Steam Supply System i

3.4.1 Category A/C Valves 3.4.1.1 Relief Recuest. The licensee has requested relief from the exercising requirements of Section XI for VFW-30", the feedwater check valve, and VFW-9, the feedwater stop check valve, and proposed to exercise these valves open quarterly and verify closure during the leak-rate test at refueling outages.

3.4.1.1.1 Code Recuirement--Refer to Appendix A.

15

3.4.1.1.2. Licensee's Basis for Requesting Relief--The check valve has no operator. The stop check valve cannot be closed against the pressure present in this line through which all feedwater to the reactor flows. Each reactor shutdown for ref0eling,--a local leak-rate test using .

air is performed on these valves. .

The added benefit resulting from the hand-operation of the feedwater stop check valve, VFW-9, each reactor shutdown, would be minimal. All that would be proven is that the check valve disk can be forced down upon its seat (it can't be hand-operated after an accident). This does not in any way prove the proper operation of the check valve. In addition, an sperator will spend about one-half hour in a high radiation area (approximately 350 mR/h). A quarterly valve testing would result in about 700 mR/yr additional exposure. This additional personnel exposure is not offset by the incremental benefit resulting from the exercising of the feedwater check valve.

3.4.1.1.3 Evaluation--The staff agrees with the licensee's basis for not exercising these valves during power operation and, therefore, relief should be granted from the quarterly exercising requirements of Section XI for valves VFW-304 and VFW-9. The licensee has demonstrated that exercising these valves during power operation would result in feedwater flow-rate transients which could possibly cause a reactor trip.

VFW-304 is not equipped with position indicators or a manual operator.

Therefore, valve closure can only be verified during a leak-rate test at refueling outages. VFW-9 is not equipped with position indicators but is equipped with a manual operator which can be used to move the valve disk shut, which is the safety related position. Valve closure can only be verified by performing a leak-rate test during refueling outages.

3.4.1.1.4 Conclusion--The staff concludes that these vaives should not be exercised quarterly during power operation, however, the 1icensee should manually exercise VFW-9 closed during cold shutdowns.

Verifying check valve VFW-304 closed by performing leak-rate testing during refueling outages snould provide a reasonable assurance of the valves 1 ability to perform its safety function, therefore, the relief thus granted I

16

'for VFW-304 will not endanger life or property or the common defense and security of the public.

3.4.2 Category C Valves -

3.4.2.1 Relief Reouest. The licensee has request,ed relief from the exercising requirements of Section XI for VP-301, the check valve in the line from the liquid poison supply to the recirculation pump suction, and VP-302, the check valve in the line from the liquid poison supply to the reactor vessel, and proposed to full-stroke exercise these valves during refueling outages.

3.4.2.1.1 Code Requirement--Refer to Appendix A.

3.4.2.1.2 Licensee's Basis for Reouesting Relief--These check valves have no operators and exercising by initiating flow in the system would require introducing liquid poison into the reactor. 'These valves will be full stroke exercised by manual operation after disassembly.

3.4.2.1.3 Evaluation--The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves VP-301 and VP-302. The licensee has demonstrated that injecting liquid poison into the reactor plant during power operation would cause severe power transients and could result in a reactor trip.

Injecting liquid poison into the reactor during cold shutdown would delay reactor start-up while the poison was filtered out of the reactor coolant system.

3.4.2.1.4 Conclusion--The staff concludes that the proposed alternate testing of valve disassembly and manual operation during refueling outages should provide a reasonable assurance of valve operability, and the relief thus granted will not endanger life or property or the common defense and security of the public.

17

.. ~. . . .

3.5 Fire and Post Incident Cooling System 3.5.1 Category 8 Valves 3.5.1.1 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI for MO-7064, and M0-7068, the enclosure spray isolation valves, and proposed to full stroke exercise these valves during refueling outages.

3.5.1.1.1 Code Requirement--Refer to Appendix A.

3.5.1.1.2 Licensee's Basis for Requesting Relief--These valves cannot be exercised during power operation without spraying water on c.nergized electrical equipment inside the containment. These valves cannot be exercised during cold shutdowns because the fire system header must be taken out of service and drained to allow exercising of the valves.

3.5.1.1.3 Evaluation--The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves M0-7064 and M0-7068. The licensee has demonstrated that exercising these valves during power operation would result in damage to equipment located inside the containment. Also, exercising these valves during cold shutdown would require taking the fire system out of service which would pose a hazard by not having the fire system available in the containment. The fire water header will be taken out of service and drained so the valves can be exercised on a refueling outage frequency.

3.5.1.1.4 Conclusion--The staff concludes that the proposed alternate testing of, full-stroke exercising these valvas during each refueling outage should provide a reasonable assurance of proper valve operability, and the relief thus granted will not endanger life or property or the common defense and security of the public.

18

3.5.2 Category C valves 3.5.2.1 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI for VPJ-303 and VPI-3,04, the core spray primary check valves, anc proposed to disassemble, inspect, and

. verify free disk movement during ref0eling outages.

3.5.2.1.1 Code Requirement--Refer to Appendix A.

3.5.2.1.2 Licensee's Basis for Requesting Relief--The core spray primary check valves have no operators. The valves cannot be opened against operating reactor pressure by initiating flow through these lines because core' spray system pressure is much less than operating reactor pressure. During shutdown, the initiation of flow through these lines would introduce nonreactor grade water into the core. The only means to ensure proper valve operation is to disassemble and inspect the valve during each reactor shutdown for refueling. There exists no method to ensure disk movement torque requirements are met. The valve will be inspected and verified that the disk is free to move.

3.5.2.1.3 Evaluation--The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for valves VPI-303 and VPI-304. The licensee has demonstrated that core spray pressure cannot overcome operating reactor system pressure, which prevents exercising these valves during power operation. In addition, exercising these valves with flow during cold shutdown requires injecting non-RCS grade water into the reactor coolant system resulting in severe water chemistry and cleanup problems which could delay plant start-ups.

3.5.2.1.4 Conclusion--The staff concludes that since these valves are not equipped with external operators or position indicators, that the most practical method to ensure proper valve operability is by disassembly, inspection, and manual verification of free disk movement

,19

during refueling outages, therefore, the relief thus granted will not .

endanger life or property or the common defense and security of the public.

3.5.2.2 Relief Request. The licensee. bas requested relief from the exercising requirements of Section XI for VPI-300, VPI-306, and VPI-307, the core spray check valves, and proposed to full-stroke exercise these valves during refueling outages. ,

/

3.5.2.2.1 Code Recuirement--Refer to Appendix A.

3.5.2.2.2 Licensee's Basis for Requesting Relief--These valves are part of the Emergency Core Cooling System. Testing during power operations would require a valve line-up which would preclude their p2rforming their required function after a loss of coolant accident l l

(LOCA). In the event of a LOCA, areas which must be entered to change this l valve lineup would be untenable. In addition, testing during power operation would require personnel entry into the very high radiation area l directly beneath the reactor vessel.

During cold shutdown, the overall time required to perform testing is about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The additional radiation exposure received for each test would be from 250 mR to 500 mR. This could possibly mean up to 6000 mR additional exposure in a year if the reactor was in cold shutdown every month of the year due to other problems.

3.5.2.2.3 Evaluation--The staff agrees with the licensee's basis fcr not testing the core spray check valves, VPI-300, VPI-306, and VPI-307 during power operation, and therefore, relief should be granted from the quarterly exercising requirements of Section'XI. The licensee has d:monstrated that the valve lineup required for effective pump testing and full-stroke exercising these valves woald isolate the core spray recirculation system thereby making it unavailable to mitigate the consequences of an accident. Changing the full stroke testing valve lineup requires entry into the containment which would prevent changing to a correct safety system valve lineup following an accident. However, the 20

staff does not agree with the licensee's basis for not exercising valves VPI-300, VPI-306, and VPI-307 during cold shutdowns.

. 3.5.2.2.4 Conclusion--The staff concludes that, given the present plant design, valves VPI-300, VPI-306 and VPI-307 should not be

- full-stroke exercised quarterly during power operation, however, the licensee is required to full-stroke exercise these valves during cold shutdowns.

3.6 Reactor Depressurization System 3.6.1 Category B Valves 3.6.1.1 Relief Request. The licensee has requested relief from full-stroke exercising SV-4984, SV-4985, SV-4986 and SV-4987, the reactor depressurization valves, in accordance with the requirements of Section XI and proposed to partial-stroke exercise these valves during cold shutdowns and refueling outages.

3.6.1.1.1 Code Recuirement--Refer to Appendix A.

3.6.1.1.2 Licensee's Basis for Requesting Relief--These valves cannot be full stroke exercised unless continuous primary system pressure is applied, releasing a large volume of primary steam into the containment and exposing personnel and equipment to adverse conditions. During testing, pressure in the spool piece between the isolation valve and the depressurization valve is relieved before the depressurization valve reaches the fully stroked position. Thus, only partial stroking of the valve is possible during testing and no valve stroke timing can be performed.

3.6.1.1.3 Evaluation--The staff agrees with the licensee's basis for not full-stroke exercising these valves quarterly during power operation or during cold shutoowns and, therefore, relief should be granted

_ from the quarterly exercising requirements of Section XI for 21

I valves SV-4984, SV-4985, SV-4986 and SV-4987. The licensee has j demonstrated that full or partial-stroke exercising these valves during p:wer operation would cause large-uncontrolled pressure transients that could result in a reactor trip. The licensee has also demonstrated that full-stroke exercising these valves during cold shutdown would result in an excessive amount of primary water, approximately 144 lb steam /s for each valve, being dumped into the containment requiring an extensive cleanup following each test. During the present testing, pressure in the spool piece between the isolation valve and the depressurization valve is relieved before the depressurization valve is full-stroke exercised open.

3.6.1.1.4 Conclusion--The staff concludes that, given the present system' design, the licensee's proposed alternate testing is the only practical method to test these valves while they are installed in the Reactor Depressurization System. However, never full-stroke exercising these valves is unacceptable and the licensee is required to full-stroke excerise these valves on a refueling outage frequency.

3.7 Make-uo and Condensate Demineralization System 3.7.1 Category A/C Valves 3.7.1.1 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI for the demineralization supply check valve downstream of CV-4105 and proposed to exercise this valve open quarterly and to verify valve closure by performing a leak-rate test during refueling outages.

3.7.1.1.1 Code Requirement--Refer'to Appendix A.

3. 7. l.. l .2 Licensee's Basis for Requesting Relief--This valve can be verified open by observing normal demineralized water flow during power operation. The safety function of this valve is to shut on reversal of flow. A leak-rate test is required to verify valve closure.

22

. 3.7.1.1.3 Evaluation--The staff agrees with the licensee's basis and, therefore, relief should be granted from the exercising requirements of Section XI for the demineralization supply check valve. The licensee

. has demonstrated that the only method to vendfy closure of this valve, which does not have position indication, is by performing a leak-rate test.

3.7.1.1.4 Conclusion--The staff concludes that the proposed alternate testing of verifying valve closure during the performance of leak-rate testing at refueling outages should provide reasonable assurance of valve operability, ano the relief thus granted will not endanger life or property or the common defense and security of the public.

e 23

- . . i l

~

l l

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APPENDIX A

1. CODE REQUIREMENTS--VALVES

2. CODE REQUIREMENTS--PUMPS s

25

APPENDIX A

1. CODE REQUIREMENT--VALVES ,

Subsection IWV-3410 of the 1977 Edition _through swuner, of 1978 addenda of the ASME Code,Section XI (which discusses full-stroke and

. partial-stroke exercising requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3412(a), IWV-3415, and IWV-3416. IWV-3520 (which discusses full-stroke and partial-stroke exercising requirements) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3522. In the above exceptions, the Code permits the valves to be tested at cold shutoown where:

1

1. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.

2. It is not practical to observe the operation of the valves (with failsafe actuators) upon loss of actuator power.

Subsection IWV-3413 requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time. Additionally, all Category A valves are required to be individually leak rate tested and trended on a frequency not to exceed each two years in accordance with IWV-3a20.

2. CODE REQUIREMENTS--PUMPS Section IWP-3400(a) of the 1977 edition'through summer of 1978 addenda of thi ASME Code calls for an inservice test to be conducted on all safety i

related pumps nominally once each month during normal plant operation.

Each inservice test shall include the measurement, observation, and l

recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

27

l l

. I l

APPENDIX B VALVES TESTED DURING COLD SHUTDOWNS l

f l

29

. APPENDIX B VALVES TESTED DURING COLD SHUTOOWNS ,

, The following are Category A, B, and C _ valves that mee,t the exercising requirements of the ASME Code,Section XI, and are not full-stroke

[.

exercised every three months during plant operation. These valves are specifically identified by the owner and are full-stroke exercised during cold shutdowns and refueling outages. The staff has reviewed all valves in this Appendix and agrees with the licensee that testing these valves during power aperation is not practical due to the valve type, location or system design. These valves should not be exercised during power operation.

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

System Vahe Identification Function Reactor Cleanup, Shutdown MO-7053 Emergency condenser and Poison Systems M0-7063 discharge isolation valves MO-7056 Shutdown cooling system t M0-7057 isolation valves M0-7058 M0-7059

( MO-7052 Emergency condenser MO-7062 inlet isolation valves CV-4020 Liquid poison discharge isolation VP-300 Liquid poison system supply check Control Rod Drive System CVNC-09 Scram inlet and outlet CVNC-10 valves VFP-304 Fire pump discharge VFP-309 check valves Nuclear Steam Supply M0-7050 Main steam isolation System valve CV-4050 Liquid poison supply to

. recirculation loop isolation 31 ,

System Valve Identification Function Fire and Post Incident MO-7022 Fire water to core spray Cooling System -

header isolation VPI-301 Core spray check valves VPI-302 .

l O

G 32

e@e g

0 0

8 e

4 APPENDIX C P&ID LIST 4

33

APPENDIX C D&ID LIST .

The P& ids listed below were used during_the course of ,this review.

. System P&ID Revision Steam and Condensate M-106 Z Reactor Cleanup-Shutdown-Poison M-107 V Radwaste M-108 V Make-up and Condensate Demineralizer. M-110 N Circulating, Cooling, and Service Water M-lli X Nuclear Steam Supply M-121 W Control Rod Drive M-122 P Fire and Post Incident Cooling M-123 AM Turbine Building and Service Building Ventilation M-124 J Reactor Building Vent, Heat and Cooling M-125 T Service and Instrument Air M-133 F Reactor Depressurization A-203 0 O

e 35

e4 e '

m e

APPENDIX D IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW 37

. APPENDIX D

~

IST PROGRAM ANOMALIES IDENTIFIED IN THE REVIEW

1. The Reactor System Depressurization Valves, SV-4984, .4985, -4986 and -4987, are never full-stroke exercised (see the relief request

. evaluation in Section 3.6.1.1).'

2. Relief should be granted from the Section XI requirements of testing the core spray pumps monthly during power operation. However, the licensee's relief request (see the relief request evaluation in Section 2.2.1) provided insufficient technical basis for not testing these pumps during cold shutdowns, therefore, relief should not be granted as requested and these pumps should be tested during cold _

shutdowns.

3. The staff agrees with the licensee that the following valves cannot or should not be exercised during power operation. However, the licensee's relief requests for these valves provided insufficient technical basis for not exercising the valves during cold shutdowns, q therefore relief should not be granted from cold shutdown testing and the valves should be exercised during cold shutdowns.

Valves Relief Request Evaluation VFW-9--Feedwater stop check valve 3.4.1.1 VPI-300--Core spray header check valve 3.5.2.2 l

VPI-306 and 307--Core spray pump 3.5.2.2 discharge check valves 4 The licensee dio not include the Diesel Fuel Oil Transfer System valves in their IST program. This system performs a safety function and the applicable valves should be included in the IST program and tested in accordance with Code requirements. The applicable Diesel Cooling Water System valves should also be included in the IST program and be tested in accordance with Section XI requirements.

39

. .. . : . ~ - . . ~ . . . ... - - . . . . . . . .

5. Permissible leakage rates should be specified for each -

containment isolation valve in accordance with IWV-3426 and the appropriate corrective actions outlined in IWV-3427 should be taken when the permissible leakage rate of a valve is approached (see IWV-3427.b) or exceeded.

6. The licensee did not identify valves that perform a pressure boundary isolation function in their IST program. The following valves appear to perform a pressure boundary isolation function and, therefore, should be categorized A or A/C as appropriate, be leak tested per the requirements listed in Section 3.1.8, and be included in the Big Rock Point Technical Specifications.

Shutdown Cooling System Core Spray System M0-7056 MO-7071 M0-7057 VPI-303  !

M0-7058 MO-7061 M0-7059 VPI-304 o

e 40

"9 9

9 8

O O

e 9

APPENDIX E VALVES TESTED DURING CDLD SHUTDDWN-DETAILS l

l 41

APPENDIX E VALVES TESTED DURING COLD SHUTDOWN-DETAILS, The following are Category A, B, and C_ valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke

- exercised every three months during plant operation. These valves are specifically identified by the owner and are full-stroke exercised during cold shutdowns and refueling outages. The staff has reviewed all valves in this Appendix and agrees with the licensee that testing these valves during power operation is not practical, due to the valve type, location or the system design. These valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

1. REACTOR CLEANUP, SHUTDOWN, AND POISON SYSTEMS 1.1 Cateoory B valves M0-7053 and M0-7063, the emergency condenser discharge isolation valves, cannot be exercised during power operation since opening these normally closed valves would admit operating temperature steam into the emergency condenser causing unnecessary thermal stresses and eventual damage to the tube bundles. These valves are full-stroke exercised during cold shutdowns and refueling outages.

M0-7056, M0-7057, M0-7058, and NO-7050, the shutdown cooling system isolation valves, cannot be exercised during power operation. The shutdown cooling system has a design pressure of 300 psig. Opening these normally shut valves during power operation would overpressurize and damage the shutdown cooling system. These valves are full-stroke exercised during cold shutdowns and refueling outages.

M0-7052 and M0-7062, the emergency condenser inlet isolation valves, l cannot be exercised during power operation since shutting these valves l during power operation would isolate flow to the emergency condenser and )

l 33

prevent safety system operation if the valves were to fail to reopen.

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

CV-4020, the liquid poison discharge isolation valve, cannot be exercised during power operation since failure of this valve to open, after exercising it to the closed position during testing, would render the liquid poison system inoperable. This valve will be full-stroke exercised during cold shutdowns and refueling outages.

1.2 Category C Valves VP-300, the liquid poison system supply check valve, cannot be exercised during power operation. This valve has no operator and a test pressure cannot be applied to verify valve closure without breaching the primary pressure boundary and releasing primary steam. Check valve VP-300 will be tested to verify closure (its safety position) during each cold shutdown and refueling outage when a test pressure can be applied downstream of the valve.

2. CONTROL R00 DRIVE SYSTEM 2.1 Category B Valves CVNC-09 and CVNC-10, the scram inlet and outlet valves, cannot be exercised during power operation since opening these normally closed valves would cause the associated control rod to scram. These valves will be -

full-stroke exercised within 0 to 7 days prior to the reactor critical approach following each cold shutdown and refueling outage.

2.2 Category C Valves VFP-304 and VFP-309, the fire pump discharge check valves, cannot be oxercised during oower operation since exercising these normally shut ,

valves requires fire pump operation. The fire pumps cannot be tested 44

during power operation because the full flow test lineup limits the amount of ECCS ficw available to the core to below the flow rate that is required for accident mitigation. These valves are full-stroke exercised during cold shutdowns and refueling outages. - ._

. 3. NUCLEARST5AMSUPPLYSYSTEM 3.1 Category A Valves M0-7050, the main steam isolation valve, cannot be exercised during power operation since shutting this valve would result in the interruption of'all main steam flow causing a turbine trip followed by a reactor trip.

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

3.2 Category B Valves CV-4050, the isolation valve for liquid poison supply to the recirculation line, cannot be exercised during power operation since this valve is interlocked to automatically open when either recirculation pump is operating. Securing the recirculation pump during power operation would place the plant in an unsafe condition and result in a reactor trip. This valve will be full-stroke exercised during cold shutdowns and refueling outages when the recirculation pumps are secured.

4. FIRE AND POST INCIDENT COOLING SYSTEM 4.1 Category B Valves M0-7072, the fire water to core spray header isolation valve, cannot be exercised during power operation since this would result in the introduction of low quality fire water into the core spray header. This would result in cleanliness and water chemistry problems that could be detrimental to the reactor and core components. This valve will be full-stroke exercised during cold shutdowns and refueling outages.

45

4.2 Catecory C Valves VPI-301 and VPI-302, the core spray primary and backup check valves, cannot be full-stroke exercised during powet_ operation.. Th.ese eneck valves have no operators for raanual actuation. Testing these valves requires that the core spray system be taken out of service thus making the system unavailable to perform its safety function. These valves will be full-stroke exercised during cold shutdowns and refueling outages using fire water system flow.

m 46

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"'"O seauOGRAPHIC DATA SHEET EGG-EA-7031

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SAFETY EVALUATION REPORT, PUMP AND VALVE INSERVICE TESTING PROGRAM, BIG ROCK POINT PLANT . .. = > c a ri.

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. . . . . $ctober - 1985 C. B. Ransom, H. C. Rockhold ,v.

O'tober c I 1985

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EG&G Idaho, Inc. l Idaho Fa11s, ID 83415 .

I A6445

.....,-,.c . . ,= .wa, Division of Licensing Office of Nuclear Reactor Regulation ,,,,,,,.,,,,,,,,,,,,,,  ;

U. S. Nuclear Regulatory Commission 1 Washington,.DC 20555 Technical Ev.luation a Report J This EG&G Idaho, Inc., report presents the results of our evaluation of the Big Rock Point Plant Inservice Testing Program for pumps and valves that are safety related.

...=.......... .....c.. .. ..,. g ,.

Unlimited

• . CW 'TV CL. 481 Car...

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. Unciassified

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Enclosure 2 LIST OF PARTICIPANTS FOR BRPP IST PROGRAM SEPTEMBER 3, 1986 CONFERENCE CALL NRC Thomas S. Rotella - BRPP Project Manager CPC Ralph Frisch - Senior Licensing Analyst (Headquarters)

Greg Withrow - Site - Engineering and Maintenance Superintendent Mike Acker - Site - Senior Engineer Jake Toskey -

Site - General Engineer Dan Moeganburg -

Site - Engineering Supervisor l

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