ML20237H597

Safety Evaluation Re Inservice Testing Program & Requests for Relief.Program Acceptable for Implementation

ML20237H597
Person / Time
Site:	Callaway
Issue date:	08/19/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20237H575	List: ML20237H572 ML20237H597
References
NUDOCS 8708250079
Download: ML20237H597 (8)

Text

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NUCLEAR REGULATORY COMMISSION 3

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.p WASHINGT ON, D. C. 20555 l

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF l

UNION ELECTRIC COMPANY CALLAWAY NUCLEAR PLANT, UNIT 1 l

DOCKET NO. 50-483 j

INTRODUCTION l

Technical Specification 4.0.5 of the Appendix A Technical Specifications to Facility Operating License No. NPF-30 for the Callaway Nuclear Plant, Unit 1, states that inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing (IST) of ASME Coue Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Code Boiler and Pressure Vessel Code and Applicable Addendo as required by 10 CFR Part 50, Section 50.55a(g),

except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55(g)(6)(i).

Certain requirements of the applicable

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Code edition and addenda of Section XI are impractical to perform because of l

certain plant system and component designs.

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Sect' ion 10 CFR 50.55(g)(6)(1) of the Commission's regulations authorizes the i

f Commission to grant relief from these requirements upon making the necessary findings. This safety evaluation contains NRC staff's findings with respect to granting er not granting reliefs submitted as part of the licensee's IST program.

By letter dated January 31, 1984, Union Electric Company (UE) submitted its first 10-year IST program and additional information related to requests for relief from certain code requirements determined to be impractical to perform on the Callaway Nuclear Plant, Unit 1.

Subsequent revisions were provided by letters dated May 29, 1984, February 11, June 28, and August 9, 1985, March 4, 1986, and January 14 and April 14, 1987.

The program is based on the requirements of the 1980 Edition through the Winter of 1981 Addenda of Section XI of the ASME Code and remains in effect until December 19, 1994, unless the program is modified or changed prior to the 10-year interval end date.

An emergency relief request associated with the inservice testing program submitted by UE on May 28, 1987, was granted by the NRC staff on June 3,1987.

l The request was with regard to four check valves that might not have been l

stroked to their open position during the plant's last cold shutdown. The licensee's relief request was to postpone the testing of these valves to the next cold shutdown or refueling outage, whichever comes first, in order not to shut down the plant for the sole purpose of doing the valve testing.

EVALUATION The IST program and the requests for relief from the requirements of Section XI that have been determined by UE to be impractical to perform have been reviewed by the staff's contractor, EG&G, Idaho, Inc. (EG&G).

In addition to the review of 8708250079 870019-DR ADOCK 0500 3

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i I the IST program and relief requests, EG&G and staff members met with UE repre-sentatives on September 10 and 11, 1986, at the SNUPPS office in Gaithersburg, l

Maryland, to discuss questions resulting from the review. The Technical Evalu-l ation Report (TER), which is attached, is EG&G's evaluation of the licensee's l

inservice testing program and relief requests. The staff has reviewed the l

TER and, with the exceptions noted below, concurs with the evaluations and l

conclusions contained in the TER. A summary of the relief request deter-minations is presented in Table 1.

The granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternate proposed testing.

In requests P03 and P09 evaluated in TER sections 3.4.1 and 3.6.1, UE requested relief from the Code flow measurement requirements in Section XI, paragraph IWP-3100, for the centrifugal charging and boric acid pumps. The licensee performs the quarterly testing of these pumps using the mini-flow recirculation loops which do not contain flow measuring devices. The licensee has not provided sufficient infomation to demonstrate that installation of the flow measurement devices is impractical.

In order for the licensee to assemble the information necessary to support their request for relief, interim relief on requests P03 and P09 is granted until June 1,1988. This relief 1s based upon the testing of these pumps which, except for flow measurement, is in accor. dance with the code, the fact that the flow devices are not presently installed, and a reasonable length of time to assemble the necessary data.

In the TER, EG&G recommended that the licensee install the flow measuring devices at the next refueling outage. The licensee should justify the present or proposed alternative testing in terms of all the potential pump failure rechanisms for these pumps and the means by which the IST program will detect degradation. The licensee should include in their discussion, as necessary, the pump vibration monitoring techniques to be used, failure rates for similar pumps in use at nuclear power plants, and scheduled main-tenance performed on these pumps.

CONCLUSION i

Based on the review of the licensee's IST program and relief requests, the staff concludes that the IST program will provide reasonable assurance of the operational readiness of the pumps and valves covered by the IST program to perform their safety-related functions. The staff has determined that, j

pursuant to 10 CFR 50.55a(g)(6)(1), granting relief where the Code requirements j

are impractical is authorized by law and will not endanger life or property, or the common defense and security. The staff has also concluded that l

granting relief is otherwise in the public interest considering the burden that could result if the requirements were imposed on the facility. During 1

the review of the licensee's inservice testing program, the staff has not i

identified any significant misinterpretation or omissions of Code requirements.

l Thus, the IST program is accepuble for implementation.

AUG 191987 i

Date:

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Attachments:

l 1.

Table 1 - Summary of Relief Requests l

2.

Technical Evaluation Report (TER) EGG-NTA-7493, Rev. 1 j

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Y TABLE 1

SUMMARY

OF RELIEF REQUESTS Licensee's TER~

Section XI Requirement / Alternate Relief' Action Relief Section Subject Method of by USNRC Recuest No.

Testing j

i PO4 3.1.1 IWP-3100/ Pump Bearing None Granted 1

-Temperature Measurement P07 3.1.2 IWP-4110/ Instrument Multiple over-Granted Accuracy Requir'a nt lapping range vibration meters P08 3.1.3 IWP-4510/ Direction Take measurements Granted vibration displace-as closely as ment measurement practical to the requirements required planes P01 3.2.1 IWP-4110/ Instrument Use of permanently Granted Accuracy Requirements installed instru-ments

,w P05 3.3.1 IWP-4120/ Inlet Pressure Use of permanently Granted Gauge Range installec instruments l

P03 3.4.1 IWP-3100/ Pump Flow None Interim Measurement granted until June 1, 1988 I

l P06 3.4.2 IWP-4120/ Inlet Pressure Use of pennanently Granted

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Gauge Range installed instru-l ments l

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P02 3.5.1 IWP-3100/ Measurement None Granted of pump parameters l

P09 3.6.1 IWP-3100/ Pump Flow None Interim Measurement granted until June 1, 1988 i

P10 3.6.2 IWP-3100/ Lubricant None Granted Level or Pressure V02 4.'1.1 IWV-3417(b)/ Required None Granted for l

Corrective Actions For valves in Valves Tested During tech speced i

Cold Shutdowns and flow paths; Refueling Outages otherwise denied V03 4.1.2.

IWV-3300/ Position Verify leak Granted Indication Verifi-integrity for j

cation for Her-valve closure and metically Enclosed verify flow or Solenoid Valves pressure for valve operation V04 4.1.3 IWV-3421 thru IWY-3425/ Appendix J. Type C Granted Leak Rate Testing of leak rate testing Containment Isolation Valves V05 4.1.4 IWV-3421 thru IWV-3427/ Test valves in Granted Leak Rate Testing of accordance with Pressure Isolation requirements of Valves the t'ch specs.

4.4d_'. 2 BB 7, 4.1.5 IWV-3520/ Verification Leak rate testing Granted BG 1, of Reverse Flow Closure during refueling i

BL 1, and for Check Valves outages KA 2 Inside Containment l

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AE 1 4.2.1 IWV-3520/ Exercising Disassembly, Granted

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requirements for Cat.

inspection and C valves AE-V120, V121 manual exercising V122, & V123 on a sampling basis at refueling outages AL 2 4.3.1 IWV-3520/ Exercising Disassembly Granted requirements for Cat inspection and 5

C valves AL-Y006, V009, manual exercising l

V012 & V015 on a sampling basis at refueling outages BB 1 4.4.1.1 IWV-3520/ Exercising Disassembly, Granted requirements for Cat.

inspection and AC valves (RCS) BB-manual exercising 8948 A,B,C & D on a sampling basis 1

at refueling outages BB 2 4.4.1.2 IWV-3520/ Exercising Full stroke exer-Granted l

requirements for Cat.

cised during re-AC valves (RCS) BB-fueling outages 8949 A & D valves

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I BB 4 4.4.2.1 IWV-3520/ Exercising Full stroke exer-Granted j

requirements for Cat.

cised during re-

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C valves (RCS) BB-fueling outages l

V001, V022, V040

& V059 BG 4 4.5.1.1 IWV-3520/ Exercising Valves to be Granted j

requirements for Cat.

partial stroked Cvalves(CYCS)BG-exercise quarterly j

8481 A & B and full-stroke at refueling outages BG 5 4.5.1.2 IWY-3520/ Exercising Full stroke exer-Granted j

requirements for Cat.

cised during re-l C valves (RWST) BG-fueling outages

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8546 A & B l

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i EJ 2 4.6.1.1 IWV-3520/ Exercising Full-stroked Granted requirements for Cat.

exercising at Cvalves(RHR)EJ-refueling outages 8969B EJ 9 4.6.1.2 IWV-3520/ Exercising Full stroked Granted requirements for Cat.

exercising at Cvalve(RHR)EJ-8969A refueling outages EJ 8 4.6.1.3 IWV-3520/ Exercising Partial-stroked Granted requirements for Cat.

exercising quar-C valves (RHR) EJ-terly and full-8958 A & B stroked exercising at refueling outages EM 2 4.7.1 IWY-3520/ Exercising Full-stroked Granted requirements for Cat.

exercising at l

AC valves EM-V001, refueling outages V002, V003 & V004 EM 1 4.7.2.1 IWV-3520/ Exercising Full-stroked Granted requirements for. Cat.

exercising at i

C valves EM-8922 A refueling outages

&B 1

l EM 3 4.7.2.2 IWY-3520/ Exercising Full-stroked Granted requirements for Cat.

exercising at C valves EM-8815, refueling outages V240 & V241 EM 5 4.7.2.3 IWV-3520/ Exercising Partial-stroked Granted requirements for Cat.

exercising quar-C valves EM-8926 A & B terly and full-stroked exercising at refueling outages l

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-S-EN 1 4.8.1.1 IWV-3520/ Exercising.

Disassembly Granted requirements for Cat, inspection and C valves EN-V002 manual exercising V008 on a sampling basis at refueling outages

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EN 2 4.8.1.2 IWV-3520/ Exercising Disassembly, Granted requirements for Cat.

. inspection and C valves EM-V003, manual exercising V004, V009 & YO10-on_a sampling. basis at refueling outages o

EN 3 4.8.1.3 IWV-3520/ Exercising Disassembly ~,

Granted -

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requirements for Cat.

inspection and C valves EN-V013 manual. exercising and V017 on a' sampling basis.

at refueling outages EP 2 4.9.1.1 IWV-3520/ Exercising Disassembly Granted requirements for Cat.

inspection and AC valves EP-8956 A, manual exercising B, C, & D on a sampling basis at refueling outages EP 3 4.9.1.2 IWV-3520/ Exercising Full-stroked Granted requirements for Cat.

exercising at AC valves EP-V010, refueling outages V020, V030 & V040 FC 1 4.10.1 IWV-3520/ Exercising Disassembly, Granted requirements for Cat.

inspection and C valves FC-V001, V002, manual exercising V024, & V025 on a sampling basis-at refueling outages i

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1 XJ 1 4.11.1 IWV-3413/ Stroke time The diesel Granted measurement require-generator mants for XJ-PV-001A, starting times 001B, 101A and 101B and the starting air tank pressures.

i will be used to verify operation of individual l

valves and to monitor valve degradation I

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EGG-NTA-7493 Revision 1 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM CALLAWAY NUCLEAR PLANT, UNIT 1 Docket No. 50-483 C. 8. Ransom H. C. Rocknoic Published July 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 I

Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Under DOE Contract No. DE-AC07-76IO01570 FIN No. A6812

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1 ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation of the Callaway Nuclear Plant, Unit 1, Inservice Testing Program for pumps and valves whose function is safety related.

FOREWORD l

This report is supplied as part of the " Review of Pump and Valve Inservice Testing Programs for Operating Reactors (III)" being conducted for the U.S. Nuclear Regulatory Commission. Office of Nuclear Reactor f

Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., NRR and I&E Support.

The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-10-11-2, FIN No. A6812.

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Docket No. 50-483 i

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CONTENTS ABSTRACT................................................................

ii FOREW0RD................................................................

ii 1.

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

1 2.

SC0PE...............................................................

3 3.

PUMP TESTING PR0 GRAM................................................

9 3.1 All Pumps in IST Program......................................

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3.1.1 Pump Bearing Temperature Measurements..................

9 3.1.2 Accuracy of Vibration Analyzers........................

10 3.1.3 Lirection of Vibration Measurements....................

11 3.2 Residual Heat Removal Pumps...................................

12 3.2.1 Instrument Accuracy Requirements.......................

12 i

l 3.3 Auxiliary Feedwater Pumps.....................................

13 3.3.1 Inlet Pressure Gauge Range.............................

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3.4 Centrifugal Charging Pumps....................................

14 3.4.1 Pump Flow Measurement..................................

14 3.4.2 Inlet Pressure Gauge Range.............................

15 3.5 Diesel Generator Fuel Oil Transfer Pumps......................

17 3.5.1 Measurement of Pump Parameters.........................

17 3.6 Boric Acid Transfer Pumps.....................................

18 3.6.1 Pump Flow Measurement..................................

18 3.6.2 Lubricant Level or Pressure............................

19 4.

VALVE TESTING PR0 GRAM...............................................

21 4.1 General Valve Relief Requests.................................

21 4.1.1 Requirea Corrective Action for Valves Tested During Cold Shutdowns..................................

22 4.1.2 Position Indicator Verification for Hermetically Enclosed Solenoid Valves...............................

22 4.1.3 Leak Rate Testing of Containment Isolation Valves......

23 4.1.4 Leak Rate Testing of Pressure Isolation Valves.........

25 4.1.5 Verification of Reverse Flow Closure for Check Valves Inside Containment..............................

25 4.2 Feedwater System..............................................

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i 4.2.1 Category C Valves......................................

27 4.3 Auxiliary Feedwater System....................................

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

28 4.4 Reactor Coolant System...................

29 4.4.1 Category AC Valves.....................................

29 4.4.2 Category C Va1ves......................................

32 4.5 Chemical and Volume Control System............................

33 4.5.1 Category C Valves......................................

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4.6 Residual Heat Removal System..................................

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l 4.6.1 Category C Valves......................................

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4.7 High Pressure Coolant Injection System........................

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l 4.7.1 Category AC Va1ves.....................................

41 4.7.2 Category C Valves......................................

42 4.8 Containment Spray System......................................

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4.8.1 Category C Va1ves......................................

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4. 9 Accumulator Safety Injection System...................

50 4.9.1 Category AC Valves.....................................

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4.10 Auxiliary Feedwater Pump Turbine.............................

53 4.10.1 Category C Valves.....................................

53 4.11 Emergency Diesel Generator Air Start System..................

55 4.11.1 Category B Valves.........................

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APPENDIX A-- VALVES TESTED DURING COLD SHUTDOWNS 57 i

APPENDIX B--P&lD AND FIGURE LIST......................................

71 APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW........

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e TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM CALLAWAY NUCLEAR PLANT, UNIT 1 1.

INTRODUCTION f

Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by the Union Electric Company for l

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its Callaway Nuclear Plant, Unit 1.

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The working session with Union Electric Company and Callaway Nuclear Plant representatives was conducted on September 10 and 11, 1986. The licensee's IST program, Revision 7 dated January 15, 1987, as amended by Revision 8 dated April 14, 1987, was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety related with the i

requirements of the ASME Boiler and Pressure Vessel Code (the Code),

Section XI, 1980 Edition through Winter 1981 Addenda.

Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER),

The NRC staff position is that required program changes, such as additional relief requests or the deletion of any components from the IST Program, should be submitted to the NRC under separate cover in order to receive prompt attention, but should not be implemented prior to review and approval by the NRC.

In their IST program, Union Electric Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine if the required testing is indeed impractical for the specified pumps or valves.

This review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/ Impact Statement titled, " Identification of Valves for Inclusion in Inservice l

Testing Programs." The IST Program testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requirements.

1 1

i Section 3 of this report presents the Union Electric Company bases for requesting relief from the Section XI requirements for the Callaway Nuclear Plant pump testing program and the EG&G reviewer's evaluations and conclusions regarding these requests.

Similar information is presented in Section 4 for the valve testing program.

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

A listing of P& ids and Figures used for this review is contained in Appendix B.

Inconsistencies and omissions in the licensee's IST program noted during the course of this review are listed in Appendix C.

The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

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a 2.

SCOPE I

i The EGSG Idaho review of the Callaway Nuclear Plant, Unit 1, inservice testing (IST) program for pumps and valves was begun in May of 1986.

The program initially examined was Revision 6, dated March 4, 1986, which

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identified the licensee's proposed testing of safety related pumps and valves in the following plant systems:

1 Main Steam System Feedwater System 1

Auxiliary Feedwater System j

Condensate Storage and Transfer System Reactor Coolant System

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Chemical & Volume Control System Reactor Make-up Water System Steam Generator Blowdown System Borated Refueling Water Storage System Fuel Pool Cooling and Clean-up System Essential Service Water System l

Component Cooliiig Water System Residual Heat Removal System j

High Pressure Coolant Injection System 1

Containment Spray System Accumulator Safety Injection System Auxiliary Feedwater Pumo Turbine J

Containment Hyorogen Control System j

Containment Purge System j

Liquid Radwaste System Decontamination System Emergency Fuel Oil System Compressed Air System Breathing Air System Fire Protection System Standby Diesel Generator System Reactor Building and Hot Machine Shop Floor and Ecuipment Drain System Nuclear Sampling System Service Gas System To review the licensee's proposed testing of certain pumps and valves in these systems, they were first located and highlighted on the appropriate system P& ids (refer to the listing of P& ids in Appendix B of this report).

After identifying the components and determining their function in the system, the proposed testing was evaluated to determine if it was in compliance with the ASME Code requirements, based on the component type and function.

For pumps, it was verified that each of the seven in urnice test quantities of Table IWP-3100-1 are measured or 3

observed as appropriate.

For those test quantities that are not being measured or observed quarterly in accordance with the Code, it was verified that a request for relief from the Code requirements had been submitted.

If the testing was not being performed in accordance with the Code and a relief request had not been submitted, then a question was written for inclusion in the Request for Additional Information (RAI) document that served as the agenda for the working meeting between the licensee, the NRC, and the EG&G reviewers.

The relief requests were individually evaluated to determine if the licensee clearly demonstrated that compliance with the Code required testing was impractical for the identified system components, and to determine if their proposed alternate testing provided a reasonable indication of component condition and degradation considering the burden to the licensee if the Code requirement were imposed. Where the licensee's technical basis or alternate testing was insufficient or unclear, a question was generated or a comment made.

The system P&ID was also examined te determine whether the instrumentation l

necessary to make the identified measurements was available.

If, based on the unavailability of adequate instrumentation or the reviewers experience and system knowledge, it was determined that it may not be possible or practical to make the measurements as described by the licensee in his IST 1

program, a question or comment was generated.

The review of the proposed testing of valves verified that all appropriate ASME Code testing for each individual valve was being performed as required or a question was generated to be included in the RAI. The proposed testing was evaluated to determined if all valves that were judged to be active category A, B, and/or C,(other than safety and l

relief valves)-were exercised quarterly in accordance with IWV-3410 or

-352,0, as appropriate.

If any active safety related valve was not full-stroke exercised quarterly as required, then the licensee's justification for the deviation, either in the form of a cold shutdown justification or a rr: lief request, was examined to determine its accuracy and adequacy.

The proposed alternate testing was also evaluated to determine if all testing was being performed that could reasonably be performed on each particular valve to bring its testing as closely in compliance with the Code requirements as practical.

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If a valve was thought or shown on the P&ID to have remote position indication, the reviewer confirmed that the valve remote position indication was verified in accordance with IWV-3300. The reviewer.

l verified that the licensee had assigned limiting values of full-stroke l

d times for all power operated valves in the IST program as required by IWV-3413. The assigned limits were examined to determine if they were j

reasonable for the size and type of valve and the type of valve operator.

l It was also verified that the valve. full-stroke times are being measured

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overy time that the valves are full-stroke exercised for the IST program, i

If a valve was thought or shown on the p&ID to have a fail-safe actuator, j

the reviewer confirmed that the valve's fail-safe actuator was tested in accordance with IWV-3415.

It was confirmed that all category A and A/C valves were leak rate tested to either the 10 CFR 50, Appendix J, and Section XI IWV-3426 and i

-3427 requirements, for those valves that perform a containment isolation f

function, or to the Section XI, IWV-3421 through -3427, requirements for those valves that perform a pressure boundary isolation function.

It was l

also verified that valves that perform both a containment isolation and a pressure isolation function are leak rate tested to both the Appendix J and the Section XI requirements.

Furthermore, if any valve appeared to r

i perform a containment isolation and/or a pressure isolation function but was not categorized A or A/C and being leak rate tested, a question was asked to verify that those valves had not been categorized improperly in the IST program.

Each check valve was evaluated to determine if the licensee's proposed testing would verify the valve's ability to perform its safety related function or functions.

Extensive system knowledge and experience with other similar facilities were used to determine whether the proposed tests l

would full-stroke the check valve disks open or verify their reverse flow j

closure capability.

If there was any doubt about the adecuacy of i.h j

identified testing, questions were included in the RAI to address these concerns.

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A further evaluation was performed on all valves in the program to f

determine that the identified testing could practically and safely be conducted as described.

If the ability to perform the testing was in j

. doubt, a question was formulated to alert the licenne to the suspected problem.

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Safety related safety and relief valves, excluding those that perform only a thermal relief function, were confirmed to be included in the IST program and being tested in accordance with IWV-?610.

Safety related explosively actuated valves were verified to be ine.luded in the IST program and being tested in accordance with IWV-M10.

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After all of the valves in the licensee's.IST program had been identified on the P&lDs and evaluated as described above, the P& ids were examined closely by at least two trained and experienced reviewers to determine if any pumps or valves that may perform a safety related function were not included'in the licensee's program. Questions were I

asked about any valves that were identified by this process. Also, the list of systems included in'the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/ Impact Statement

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titled, " Identification of Valves for Inclusion in Inservice Testing Programs".

Systems that appear in the Draft Regulatory Guide list but not i

in the licensee's program were evaluated and, if appropriate, questions were added to the RAI concerning safety related pumps and valves in those l

systems.

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l Additionally, if the reviewers suspected a specific or a general l

aspect of the licensee's IST program based on their past experiences, ques.tions were written for inclusion in the RAI to clarify those areas of doubt.

Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this TER.

l At the completion of the rev.iew, the RAI was transmitted to the NRC.

These questions were later used as the agenda for the working meeting with the licensee on September 10 and 11, 1986.

At the meeting each question and comment generated during the review was discussed in detail.

The licensee provided a written response to the RAI in their correspondence 6

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3 dated September 3, 1986, identified by the licensee as UOTE 86-391.

During the course of the meeting all of the questions and comments of the RAI were discussed and left in one of the _following conditions:

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i The licensee agreed to make the necessary IST program corrections a.

or changes that sat'.4fied the concerns of the NRC and their reviewers.

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b.

The licensee provided additional information or clarification about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change is required.

j c.

The item remained open for the licensee to further investigate and propose a solution to the NRC.

d.

The item remained open for further investigation by the NRC.

The item remained open for further investigation and discussion e.

by both the NRC and the licensee.

l Revision 7 of the licensee's IST program dated January 14, 1987 was received by the reviewers and was compared to Revision 6 to identify any changes.

The program chanas were then compared to the proposed changes from the working meeting to identify any deviations from the changes proposed in the meeting. These deviations were evaluated to determine whether they were acceptable and if not, they were added to the list of items that remained open from the meeting.

Several conference calls were I

held between the licensee, the NRC, and the reviewers to clarify the NRC posi.tions on the open items and discuss the licensee's proposed

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resolutions.

Revision 8 of the licensee's IST program dated April 14, 1987 was received by the reviewers and was compared to Revision 7 to identify any i

changes.

The program changes were then compared to the proposed changes from the conference calls to identify any deviations.

A conference call 7

was held between the licensee, the NRC, and the reviewers to discuss these deviations and the items that were still not satisfactorily resolved in Revision 8 of the Callaway Nuclear Plant IST program.

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l This TER was then prepared and is based on information obtained from the submittals, meetings, and conference calls identified in the above described review process.

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A 3.

PUMP TESTING PROGRAM 1

The Callaway Nuclear Plant IST program submitted by Union Electric 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, except for those pumps identified belcw for which specific relief from testing has been requested and as summarized in Appendix C.

Each Union Electric Company basis for requesting relief from the pump testing requirements and the reviewer's evaluation of that request are summarized below.

3.1 All pumos in IST Program 3.1.1 pump Bearing Temperature Measurements Y

3.1.1.1 Relief Recuest. The licensee has requested relief from the bearing temperature measurement requirements of Section XI, Paragraph IWP-3100, for all pumps listed in their IST program and proposed to measure the required pump hydraulic parameters and vibrath>n to determine pump operability and mechanical degradation.

3.1.1.1.1 Licensee's Basis for Recuesting Relief--Measuring pump l

i hydraulic parameters and vibration will ensure operability and the trending of mechanical degradation is assured.

Bearing degradation will be observed by changes in vibration.

Increases in bearing temperature do not occur until just prior to total bearing failure.

To detect bearing degradations using bearing temperature would require continuous monitoring. The chance of observing bearing degradation with a yearly test is very low.

3.1.1.1.2 Evaluation--The licensee has indicated that a yearly measurement of pump bearing temperature for these pumps is not a meaningful test for detecting pump bearing degradation. There are several factors such as the temperature of the working fluid, the ambient temperature, and the

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lubricant temperature that would affect the measured bearing temperature and mask any bearing condition change short of a catastrophic bearing failure.

The Code required quarterly pump vibration measurement gives a much more accurate indication of pump bearing condition than the temperature 9

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measurement, and the vibration measurement is not substantially affected by any system parameter or other factor dhat could mask problems or result in erroneous indications of bearing degradation.

A yearly bearing temperature measurement is impractical for these pumps because they do not have temperature sensors installed in the bearings. The burden on the licensee if the Code requirements were imposed would not be justified by the limited information that would be provided about pump mechanical condition.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed and considering the quarterly pump vibration measurements that will be taken to determine pump mechanical condition and to detect pump bearing degradation, relief may be granted from the Section XI requirement of annually measuring bearing temperature for these pumps.

l 3.1.2 Accuracy of Vibration Analyzers l

l 3.1.2.1 Relief Recuest.

The licensee has requested relief from the instrument accuracy requirements of Section XI, Paragraph IWP-4110, for all pumps in the IST program and proposed to use vibration meters with multiple overlapping ranges and to use the range that is most accurate for the pump i

being measured.

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3.1.2.1.1 Licensee's Basis for Reouesting Relief--Vibration analyzers generally have multiple overlapping scales rather than a single l

full-scale range.

Also, for vibrations in the lowest range of Table IWP-3100-2, when V is greater than 0 and less than 0.5 mils, if a r

gauge of 3 V were used we would not be able to reach the required action r

rang.e of greater than 1.5 mils.

It is not feasible, for example, to require a meter with a range of 0-0.6 mils for a reference vibration of 0.2 mils when the alert range is 1.0-1.5 mils.

Vibration meters with multiple overlapping scales will be used to take the test measurements, the actual a

scale used will be determined by the amplitude of vibration for each test.

3.1.2.1.2 Evaluation--Due to the wide variation of pump vibration measurements encountered on safety related pumps in the IST program it would be impractical to use a single range vibration instrument that would meet 10 4

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both the instrument accuracy and range requirements of Section XI, Paragraphs IWP-4110 and 4120.

A single vibration instrument is normally i

used to make the vibration measurements on many different pumps in the IST program, and since the pumps vary greatly in size and application, their.

vibration amplitudes would have a wide divergence. The licensee has indicated that some pumps have reference vibration measurements that are suffic-iently small that the allowable instrument range of three times the reference value, does not reach the Code specified alert and required action

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i limits.

Since the use of a single range vibration instrument would not permit compliance with the requirements of both Paragraphs IWP-4110 and 4120 over the entire anticipated vibration measurement range in the case of these pumps, use of a single range vibration instrument is considered to be impractical. The use of a multiple scale instrument allows the selection of a scale that meets the IWP-4120 range requirements for each pump vibration measurement taken and permits usage of the same instrument on a variety of 1

different pumps.

The appropriate scale should be selected that results in the vibration measurement being as close as possible to the center of the instrument scale.

I Based on the determination that the use of a single range vibration i

instrument is impractical, and considering that the licencee's proposal to use a multiple scale vibration instrument to measure pump vibrations should not diminish the licensee's ability to determine pump mechanical condition and detect degradation, relief may be granted from the Code requirements as requested.

3.1.3 Direction of Vibration Measurements 3.1.3.1 Relief Reauest.

The licensee has requested relief from the direction of vibration displacement measurement requirements of Section XI,

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Paragraph IWP-4510, for all pumps in the IST program and proposed to measure the pump vibration as closely as possible to the Code required directions with allowances for obstructions around the bearing housings.

3.1.3.1.1 Licensee's Basis for Recuestina Relief--Some bearing housings have obstructions such as oil fill caps, sight glasses, bolts, l

rigid supports, etc., which prevent obtaining valid vibration data in the I

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perfectly horizontal or vertical direction.

Therefore, the direction of displacement shall be measured in a plane approximately perpendicular to the rotating shaft, and in approximately the horizontal or vertical d'irection;

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I that has the largest deflection for the particular pump installation.

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3.1.3.1.2 Evaluation--In some pump installations obstructions may I

l prevent the licensee from taking the pump vibration measurements in the l

exact directions prescribed by the Code.

In order to meet this Code requirement, modifications would be required to relocate the affec%;

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hangers and supports to positions that may not be optimum for them to, or l

even permit them to, perform their design functions.

Taking these measurements as closely as practical to the required planes should provide l

meaningful data to determine pump condition and if the measurements are consistently made at the same locations and in the same planes, they should I

provide an adequate indication of pump mechanical degradation.

Based on the impracticality of meeting this Code requirement, the burden on the licensee if this requirement were imposed, and the licensee's proposed alternate testing of measuring pump vibrations as closely as practical to the required planes, relief may be granted from the Code requirements as requested.

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3.2 Residual Heat Removal pumes 1

3.2.1 Instrument Accuracy Requirements 3.2.1.1 Relief Recuest. The licensee has requested relief from the instrument accuracy requirements of Section XI, Paragraph IWP-4110, for the residual heat removal pump discharge pressure gauges, and proposed to use the permanently installed system gauges.

3.2.1.1.1 Licensee's Basis for Recuestina Relief--Reference values for discharge pressures for these pumps are between 200 psig and 300 psig.

This would require a discharge pressure gauge of 0-600 psig maximum.

The accuracy required for this gauge would be 2% of 600 psig which is 112 psig.

The permanent discharge pressure gauges we have installed 12

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i are 0-700 psig 5 psig.

Although the permanent instruments are above the i

maximum range limits they are within the accuracy requirements and are therefore suitable for the test.

We propose to use the permanently installed discharge pressure gauges.

3.2.1.1.2 Evaluation--The installed residual heat removal pump discharge pressure gauges do not meet the range requirements of Section X1, Paragraph IWP-4120, however, their accuracy is better than is required by Paragraph IWP-4110.

The installed instruments with ranges of 0 to 700 psig I

woulc read 28.6% of full-scale for the most restrictive reference pressure 1

of 200 psig instead of the required 33.3% of full-scale.

Therefore, meeting the Code requirement is impractical with the installed instruments.

l However, since the installed instruments are more accurate than the Code requirements, they should provide adequate information to allow the determination of pump hydraulic condition.

Because the installed discharge pressure instruments will not diminish the licensee's ability to monitor pump condition and detect hydraulic degradation, requiring plant modifications to meet this Code requirement would impose an undue burden on the licensee.

Based on the impracticality of meeting the Code requirements, and the fact that the instruments that the licensee has proposed to use are more accurate tnan the Code requires, relief may be granted from the Code requirements as requested.

3.3 Auxiliary Feedwater Pumos l

l 3.3.1 Inlet Pressure Gauge Rance

. 3.3.1.1 Relief Reouest.

The licensee has requested relief from the instrument range requirements of Section XI, Paragraph IWP-4120, for the auxiliary feedwater pump inlet pressure gauges, and proposed to use the permanently installed gauges to make the required test measurements.

3.3.1.1.1 Licensee's Basis for Reouesting Relief--Raference values for suction pressure for these pumps are about 15 psig.

This would require suction pressures gauges of 0-45 psig maximum.

The accuracy 13 w

required for these gauges would be 2% of 45 psig which is 0.9 psig.

The permanent suction pressure gauges we have installed are 0-60 psig t0.5 psig.

Although the permanent instruments are above the maximum range limits, they are within the accuracy requirements and are therefore suitable for the test.

3.3.1.1.2 Evaluation--The installed auxiliary feedwater pump inlet pressure instruments do not meet the range requirements of Section XI, Paragraph IWP-4120, however, their accuracy is better than is required by

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paragraph IWP-4110.

The installed instruments with ranges of 0 to 60 psig would read 25% of full-scale for the most restrictive reference pressure of 15 psig instead of the required 33.3% of full-scale. Therefore, meeting the Code requirement is impractical with the installed instruments.

However, the 25% reading should be sufficient to avoid the bottom of the scale instrument inaccuracies, and since the installed instruments are more accurate than the Code requirements, they should provide adequate l

information to allow the determination of pump hydraulic condition.

Because the installed discharge pressure instruments will not diminish the licensee's ability to monitor pump condition and detect hydraulic j

degradation, requiring plant modifications to meet this Code requirement l

would impose an undue ourden on the licensee.

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i Based on the impracticality of meeting the Code requirements, and the fact that the instruments that the licensee has proposed to use are more 1

accurate than the Code requires, relief may be granted from the Code requirements as requested.

3.4 Centrifugal Charcina Pumos 3.4.1 pumo Flow Measurement i

3.4.1.1 Relief Reouest. The licensee has requested relief from the flow measurement requirements of Section XI, Paragraph IWp-3100, for the centrifugal charging pumps, and proposed to test these pumps in a fixed I

resistance minimum flow path and measure pump differential pressure to determine pump hydraulic condition.

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3.4.1.1.1 Licensee's Basis for Requesting Relief--Technical Specification 4.5.2.f.1 states, "Each ECCS Subsystem shall be demonstrated

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OPERABLE by verifying that each centrifugal charging pump develops a discharge pressure greater than or equal to 2390 psig on recirculation flow l

when tested pursuant to Specification 4.0.5".

Testing of'these pumps is j

performed on the fixed resistance mini-flow path (-2500 psid, 60 gpm).

At this flow rate, the pump curve for these pumps is relatively flat

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(-25 psid/60 gpm).

Flow rate changes of plus or minus 50% would result in less than 1% change in pump differential pressure. Adequate flow is l

verified for protection of the pumps by monitoring discharge pipe temperature changes. Measurement and trending of pump differential pressure j

provides sufficient information to adequately monitor pump hydraulic i

.1 degradation.

Pump discharge pressure and differential pressure will be I

measured in lieu of pump flow rate.

1 3.4.1.1.2 Evaluation--The' licensee has not provided adequate information to justify relief from measuring centrifugal charging pump flow rates as required by the Code in order to determine pump hydraulic condition i

j and detect pump degradation.

They have failed to show that it is impractical to install adequate flow instruments to permit them to meet this Code requirement.

Also, they have not satisfactorily demonstrated that measuring the pump differential pressure while running the pumps on the minimum flow paths will provide sufficient information to determine the proper operability and detect degradation of the centrifugal charging pumps.

Since the licensee has not clearly shown the impracticality of making l

the Code required flow rate measurements or demonstrated the adequacy of their proposed testing, relief should not be granted frcm the pump flow rate measurement requirements of Section XI for the centrifugal charging pumps.

The licensee should make the necessary system modifications to allow them to measure this parameter as required.

3.4.2 Inlet Pressure Gauce Rance 3.4.2.1 Relief Recuest.

The 1icensee has reauested relief from the instrument range requirements of Section XI, Paragraph IWP-4120, for the 15

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centrifugal charging pump inlet pressure gauges and proposed to use the permanently installed pump inlet pressure instruments.

l 3.4.2.1.1 Licensee's Basis for Reauestina Relief--Reference values for suction pressures for these pumps are between 30 psig and 40 psig.

This would require suction pressure gauges of 0-90 psig maximum.

The accuracy required for this gauge would be 2% of 90 psig which is il.8 psig. The permanent suction pressure gauges we have installed are 0-150 psig 1.0 psig.

Although the permanent instruments are above the maximum range limits, they are within the accuracy requirements and are therefore suitable for the test.

3.4.2.1.2 Evaluation--The installed centrifugal charging pumps I

l inlet pressure instruments do not meet the range t.quirements of Section XI, Paragraph IWP-4120, however, their accuracy is better than is required by Paragraph IWP-4110. The installed instruments with ranges of 0 to 150 psig would read 20% of full-scale for the most restrictive reference prossure of 30 psig instead of the required 33.3% of full-scale. Therefore, meeting the Code requirement is impractical with the installed instruments.

However, 1

the 20% reading should be sufficient to avoid the bottom of the scale instrument inaccuracies, and since the installed instruments are more accurate than the Code requirement, they should provide adequate information to allow the determination of pump hydraulic condition.

Because the installed inlet pressure instruments will not diminish the licensee's ability to monitor pump condition and detect hydraulic degradation, requiring plant modifications to meet this Code requirement would impose an undue burden on the licensee.

. Based on the impracticality of meeting the Code instrument range requirement, and the fact that the instruments that the licensee has proposed to use are more accurate than the Code specifies, relief may be granted from the C.de requirements as requested.

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l 3.5 Diesel Generator Fuel Oil Transfer Pumos 3.5.1 Measurement of pump parameters 3.5.1.1 Relief Reouest. The licensee has requested relief from the pump vibration and bearing temperature measurement and the observation of the bearing lubricant pressure or level requirements of Section XI, l

1 Paragraph IWP-3100, for the diesel fuel oil transfer pumps and proposed to measure pump flow rate and differential pressure quarterly.

l 3.5.1.1.1 Licensee's Basis for Requestina Relief--The diesel generator fuel oil transfer pumps are submersible sump pumps.

Vibration and

' earing temperature cannot be measured on these submersible pumps.

o Lubrication levels need not be verified since these pumps are lubricated by i

the liquid they are submerged in.

Pump differential pressure and flow I

measurements will be made quarterly.

l 3.5.1.1.2 Evaluation--The diesel fuel oil transfer pumps are i

submerged in the diesel fuel oil storage tanks and are cooled and lubricated j

by the working fluid, therefore, it is not necessary to observe the lubricant pressure or level.

Since the pump bearings are in the stream of the working fluid, measurement of the bearing temperatures is no' required I

by IWP-4310.

Both the pump and motor are submerged in the diesel 3il and are not accessible for vibration measurements. The pump outlet pipi n is the only component available for vibration measurements, however, taking vibration measurements on the outlet piping would not provide information l

that is indicative of pump mechanical condition and would, therefore, be meaningless.

These pumps sit in the bottom of the storage tanks and would have an inlet pressure due to the head of fuel oil in the tank.

The inlet pressure when the pump is operating cannot be determined because there are no installed inlet pressure instruments.

However, sufficient blockage in the pump suction woula be indicated by a reduction in the pump flow rate.

l Due to the location and design of the ciesel fuel oil transfer pumps, j

I it is impractical to measure pump vibration or the inlet pressure of a pump 1

l while it is in operation.

A complete redasign of the diesel fuel oil l

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transfer system would be required to meet the Code requirements.

Based on the impracticality of these measurements, the burden on the licensee if j

these Code requirements were imposed, and the measurement of the pump I

differential pressure and flow rate that will be performed by the licensee, relief may-be granted from the Section XI requirements as requested.

l 3.6 Boric Acid Transfer Pumps 3.6.1 Pump Flow Measurement l

3.6.1.1 Relief Reouest.

The licensee has requested relief from the l

flow measurement requirements of Section XI, Paragraph IWP-3100, for the 1

boric acid transfer pumps, and proposed to test these pumps in a fixed resistance minimum flow path and measure pump differential pressure to determine pump hydraulic condition.

3.6.1.1.1 Licensee's Basis for Reouestina Relief--Testing of l

these pumps is performed on the fixed resistance mini-flow path.

Since l

there is no flow instrumentation in the recirculation test loop, flow cannot be measured. Measurement and trending of pump differential pressure l

l provides sufficient information to adequately monitor pump hydraulic I

degradation.

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3.6.1.1.2 Evaluation--The licensee has not provided adequate l

information to justify relief from measuring boric acid transfer pump flow l

l rates as required Dy the Code in order to determine pump hydraulic condition and detect pump degradation.

They have failed to show that it is 1

j impractical to install adequate flow instruments to permit them to meet this Code. requirement.

Also, they have not satisfactorily demonstrated that measuring the pump differential pressure while running the pumps on the minimum flow paths will provide sufficient information to determine the proper operability and detect degradation of the boric acid transfer pumps.

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Since the licensee has not clearly shown the impracticality of making l

the Code required flow rate measurements or demonstrated the adequacy of their proposed testing, relief should not be granted frem the pump flow rate l

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measurement requirements of Section XI for the boric acid transfer pumps.

The licensee should make the necessary system modifications to allow them to measure this parameter as required.

3.6.2 Lubricant Level or pressure 3.6.2.1 Relief Reouest.

The licensee has requested relief-from the l

Section XI, Paragraph IWP-3100, requirement to observe pump lubricant level or pressure for the boric acid transfer pumps.

i 3.6.2.1.1 Licensee's Basis for Reouesting Relief--These pumps are canned pumps.

The pumps and motors are lubricated by the fluid being iJmped.

3.6.2.1.2 Evaluation--Section XI, Paragraph IWP-4310, implies that pumps with bearings in the working fluid flow path are acceptable designs in applications covered by the scope of Section XI, even though lubricant temperature cannot be measured.

Because the boric acid transfer pumps are cooled and lubricated by the working fluid, it is also not possible to observe the lubricant level or pressure.

A sufficient supply of the system working fluid must be available for these pumps to meet their safety related function.

Therefore, when called upon to perform their safety function, adequate lubricant is designed to be available to these pumps. For this pump design, where the pump bearings are cooled and lubricated by the working fluid, observation of the lubricant level or pressure is not an appropriate requirement, because it does not provide any information to evaluate pump condition.

Based on the facts that these parameters cannot be observed and that, by the nature of the pump and systam design, adequate bearing lubrication will be available when other IST parameters are measured and when the pumps are operated to perform their safety function, we conclude that the Code requirement does not apply to these pumps.

Therefore, relief need not be requested from the Section XI requirement to observe pump lubricant level or pressure for the boric acid transfer pumps.

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4.

VALVE TESTING PROGRAM The Callaway Nuclear Plant IST program submitted by Union Electric Company was examined to verify that all valves included in the program are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines.

The reviewer found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the Code requirements and established NRC positions.

Each Union Electric Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request are summarized below and grouped-according to system and valve category.

1 4.1 General Valve Relief Reouests 4.1.1 Required Corrective Actions for Valves Tested During Cold Shutdowns and Refueling Outages 4.1.1.1 Relief Reauest. The licensee has requested relief from the corrective action requirements of Section XI, Paragraph IWV-3417(b), for all l

valves that are identified to be tested on a cold shutdown or refueling outage frequency and proposed to follow the plant Technical Specification requirements to determine if a problem valve must be repaired prior to start-up or, if the limiting conditions for operations are met with the l

valve out of service, to delay valve repair until after start-up.

4.1.1.1.1 Licensee's Basis for Reouesting Relief--The Plant Technical Specifications provide the requirements and plant conditions necessary for plant start-up.

The test requirement will be satisfied before the valve is required for plant operability as defined in the Plant Technical Specifications.

4.1.1.1.2 Evaluation--The plant Technical Specifications i

establish system operability requirements but do not necessarily provide all of the requirements and plant conditions for plant startup.

However, the plant should be permitted to start up if allowed by Technical Specifications, even if one or more valves are out of service in a flow path that is specifically addressed by the plant Technical Specifications.

Since 21 l

plant Technical Specifications do not provide the minimum operability regurements fcr plant start-up, general relief cannot be granted for valves in flow paths not covered by the plant Technical Specifications.

If relief is desired from IWV-3417(b) for any of these valves, the licensee should submit relief requests for specific valves.

In these relief requests, the licensee should provide the basis to justify the relief request in terms of the safety function of the specific valves.

The licensee should also identify in the relief requests, a plan for repairing and retesting these valves in order to return them to service.

Sased on the impracticality of requiring the licensee to delay plant start-up in order to repair a valve in a flow path addressed in the plant Technical Specifications which is not required, by the plant Technical l

Specifications, to be operable for plant start-up and operation, relief may be granted from the Section XI requirements of IWV-3417(b).

However, the requesteo relief is not granted for valves in flow paths which are not I

specifically addressed in the plant Technical Specifications.

Specific relief must be requested for those valves as described above.

If the l

testing of any valve is deferred in order to allow plant start-up, a retest of that valve showing acceptable operation shall be made before the valve is returned to service.

This testing should be performed prior to entering any l

operating mode where the valve is required to be in service, even if the plant must be shutdown in order to perform the testing.

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4.1.2 Position Indicator Verification for Hermetically Enclosed Solenoid Valves l

4.1.2.1 Relief Reauest.

The licensee has requested relief from the valve remote position indicatic verification requirements of Section XI, Paragraph IWV-3300, for hermetically enclosed solenoid valves and proposed to verify their closed position by performing leak rate testing during each refueling outage and to verify that the valve disk moves away from the closed seat by observing a pressure reduction when each valve is opened after the leak rate test or by observing flow through the valve.

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4.1.2.1.1 Licensee's Basis for Reouesting Relief--Solenoid valves in use at Callaway are a hermetically enclosed, seal welded design.

Visual verification of valve position is not possible without removing valves from service and disassembling them in the maintenance shop.

The leak rate test performed each refueling outage will verify that the l

remote position indicators accurately reflect the closed position of the valves.

Following each leak rate test the air pressure will be relieved by opening these valves, thus verifying that the disk moves away from the seat.

4.1.2.1.2 Evaluation--These solenoid valves are a hermetically enclosed seal welded design, which makes it so the disk position cannot be l

1 observed unless the valves are disassembled.

It is impractical to require the licensee to remove these valves from the piping and disassemble them l

every two years in order to verify the valve remote position indication.

l The only practical method available to verify the remote position indication l

is by demonstrating the leak tight integrity of the valves when they are i

closed and observing flow through the valves when they are open.

The proposed leak rate test will provide a positive indication of valve closure.

Observing flow through the valve or a decrease in air pressure following the leak rate test will verify that the valve is at least l

partially open but does not veri J that the valve disk is fully open.

The most common f ailure mode for solenoid valves is failure to promptly operate, which would be detected by the licensee's proposed testing.

Based on the impracticality of valve disassembly, the burden on the i

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licensee if these Code requirements were imposed, and the licensee's i

proposed alternate testing of verifying valve leak tight integrity for valve closure and flow or pressure testing to verify the valves in the open position, relief may be granted from the Section XI requirements as requested.

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4.1.3 Leak Rate Testing of Containment Isolation Valves 1

I 4.1.3.1 Relief Reouest.

The licensee has requested relief from the

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leak rate test requirements of Section XI, Paragraph IWV-3421 through j

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1 IWV-3425,.for all valves that are individually' leak tested to verify their containment isolation function, and proposed to leak test these valves to the requirements of 10 CFR 50, Appendix J'and Section XI, Paragraphs IWV-3426 and 3427.

4.1.3.1.1 Licensee's Basis'for Recuesting Relief--10'CFR 50, 1

Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reaccors, provides leakage' test requirements for containment isolation.

j valves.

Technical Specifications provide action statements'to be adhered to in the event of test failure.

I Valve leak rate testing for containment isolation valves will be' I

performed to the leak test requirements of 10 CFR 50, Appendix J,- and q

Technica1' Specifications. This includes requirements for test frequency, I

1 differential test pressure, seat leakage. measurement, and test medium.

The analysis of leakage retes and corrective action requirements of IWV-3426 and 3427 will be followed for these valves.

4.1.3.1.2 Evaluation--The leak test procedures and requirements i

for containment isolation valves identified by 10 CFR 50, Appendix J.

essentially meet the Section XI Code requirements since it incorporates all of the major elements of Paragraphs IWV-3421 through 3425.

Appendix J, q

Type C leak rate testing adequately determines the leak-tight integrity of these valves.

The 10 CFR 50, Appendix J, leak rate testing.does not trend or establish corrective actions based on individual valve leakage rates, therefore, the Analysis of Leakage Rates and Corrective Action requirements of Section XI, Paragraphs IWV-3426 and 3427 must be followed and the licensee has committed to meet these requirements.

Relit # may be granted from the requirements of Paragraphs IWV-3421 through IWV-3425 of the Code for containment isolation valves that are tested alternatively to the Appendix J, Type C leak rate requirements based on'the equivalency of the proposed alternative testing to the Code requirements.

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4.1.4 Leak Rate Testing of Pressure Isolation Valves 1

4.1.4.1 Relief Recuest. The licensee has requested relief from the leak rate testing requirements of Section XI, Paragraphs IWV-3421

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through 3427, for the reactor coolant system pressure boundary isolation valves and proposed to test these valves in accordance with the requirements of the Callaway Technical Specifications.

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4.1.4.1.1 Licensee's Basis for Recuesting Relief--Reactor coolant system pressure isolation valves are sufficiently leak tested per Callaway Plant Technicai Specification 4.4.6.2.2.

l 4.1.4.1.2 Evaluation--The Callaway Plant Technical Specifications identify in Table 3.4-1 valves that are leak rate tested as pressure isolation valves and establishes the maximum permissible leakage rate of 1 gpm (3.4.6.2.f), the test pressure requirements, the test frequency requirements (4.4.6.2.2), and the required action if the leak rate limit is I

exceeded.

The Technical Specification testing of the reactor coolant system I

pressure isolation valves essentially meets the Section XI Code requirements since it incorporates all of the major elements of Paragraphs IWV-3421 i

through 3427. The Technical Specification leak rate testing adequately determines the leak-tight integrity of these valves.

1 Relief may be granted from the requirements of Paragraphs IWV-3421 1

l through 3427 of the Code for the reactor coolant system pressure isolation 1

valves that are leak rate tested alternatively to the Technical Specification requirements based on the equivalency of the proposed l

alternative testing to the Code requirements.

l 4.1.5 Verification of Reverse Flow Closure for Check Valves Inside Containment 4.1.5.1 Relief Recuest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for the following Category AC valves that are located inside containment, and proposed to l

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verify reverse flow closure of these valves by performing a leak test during each refueling outage.

I System Valve System Valve Recctor Coolant BB-V118 Chemical and Volume Control BG-8381 1

R?icter Coolant BB-V148 Reactor Makeup Water BL-8046 Reactor Coolant BB-V178 Compressed Air KA-V204 Reactor Coolant BB-V208 l

I 4.1.5.1.1 Licensee's Basis for Recuesting Relief--The only method I

l available to verify reverse flow closure is by valve leak testing.

These valves will be verified closed during Appendix J, Type C leak rate testing at refueling.

4.1.5.1.2 Evaluation--These are simple check valves which are located inside primary containment and are not equipped with position 1

indication.

The only method available to verify closure of these valves is to perform a leak test. The test connections to leak test these valves are inside containment and, therefore, it would require a containment entry in order to verify valve closure.

Routine containment entry cannot be made quarterly during power operations because of high raoiation levels and j

potentially harsh environment inside containment.

Performing this testing during cold shutdowns would subject the plant perscrm?1 to ine eased l

radiation dosages and other potential hazards, and could result in delaying returning the plant to power.

These valves receive an Appendix J, Type C, l

leak rate test during refueling outages and it would be impractical to require the licensee to make a containment entry quarterly during power operations or during cold shutdowns in order to verify closure of these valves.

Based on the impracticality of complying with the Code requirements, the burden on the licensee if he Code requirements were imposed, and the licensee's proposed alternate testing of verifying valve closure by the performance of leak rate testing during reactor refueling outages, relief may be granted from the exercising interval requirements of Section XI for these valves, w

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4.2 Feedwater System 4.2.1 Category C Valves 4.2.1.1 Relief Request. The licensee has requested relief from the l

exercising requirements of Section XI, Paragraph IWV-3520, for AE-V120, V121, V122, and V123, the main feedwater header check valves, and proposed to test these valves using a sample disassembly and inspection of these l

valves during refueling outages.

I 4.2.1.1.1 Licensee's Basis for Requesting Relief--Exercising l

these valves during power operation would require isolation of feedwater to the steam generator which would result in a severe transient in the steam generator, possibly causing a unit trip.

Valve disassembly requires draining the steam generator below the feed header which can only be performed during longer term shutdowns.

i l

l A different valve from this group will be disassembled, inspected, and manually full-stroked at each refueling, until the entire group has been j

tested.

If the full-stroke capability of the disassembled valve is in j

question, the remainder of the valves in that group will also be

)

disassembled, inspected, and manually full-stroked at the same odtage.

l l

l 4.2.1.1.2 Evaluation--It would be necessary to isolate feedwater l

to a steam generator in order to exercise these valves closed, and isolating l

feedwater flow during power operations would result in loss of steam l

generator level contiol which could cauce a plant trip.

Since this testing 1

would cause a plant transient which could lead to a plant trip, it is not onsidered to be practical during power operations.

The only methods l

i available to verify valve closure during cold shutdowns and refueling j

outages are leak testing and disassembly and inspection of the valves.

The system design makes it so the steam generators would have to be isolated and

]

pressurized in order to leak test these valves which would be impractical j

during cold shutdowns or refueling outages.

To disassemble these valves, the licensee must first drain the steam generators below the feed nozzle and subsequently drain the main feedwater header which is an evolution that is impractical during cold shutdowns since it could delay plant start-up.

I I

27 j

Disassembly, inspection, and manually exercising the valve disk during reactor refueling outages would provide an indication of valve mechanical condition and its ability to close to perform its safety.related function.

1 Compliance with the Code required testing method is impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve

]

disassembly.

Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the i

Code required testing frequency, and the licensee's proposed alternate testing of verifying valve closure by disassembly, inspection, and manually l

exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

{

I 4.3 Auxiliary Feedwater System l

4.3.1 Cateoory C Valves

)

4.3.1.1 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for AL-V006, V009, V012, and V015, the check valves in the essential service water supply i

l i

lines to the suctions of the auxiliary feedwater pumps, and proposed to l

disassemble, inspect, and manually exercise these check valves during each refueling outage.

4.3.1.1.1 Licensee's Basis for Reouestino Relief--Full stroking these valves would result in feeding dirty water into the steam generators l

or to the condensate storage tank as these are the only flow paths available.

A different valve from this group will be disassembled, inspected, and manually full-stroked at each refueling, until the entire group has been tested.

If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in this group will also be disassembled, inspected, and manually full-stroked at the same outage.

28

4.3.1.1.2 Evaluation--The only flow paths to exercise these check valves open with flow would be through the auxiliary feedwater pumps into the steam generators (full-stroke exercise) or into the condensate storage tank (partial-stroke).

Since the essential service water is low quality water, using either of these paths would result in water chemistry problems which would necessitate draining and flushing the systems that were degraded by the low quality water and this would require a plant shutdown because the auxiliary feedwater system cannot be out of service during power operations.

Draining and flushing the auxiliary feedwater system, the steam generators, and the condensate storage tank is a major evolution that would l

be impractical during cold shutdowns since it could delay plant start-up.

The licensee will disassemble, inspect, and manually full-stroke the valve disk for these check valves during refueling outages on a sampling basis.

Compliance with the Code required testing method is impractical due to system design. Compliance with the Code required testing frequency would be l

burdensome since this would require quarterly shutdown for draining and flushing the auxiliary feedwater system and the steam generators or for valve disassembly.

Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve closure by disassembly, inspection, and manually exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

4.4 Reactor Coolant System 4.4 1 Category AC Valves

- 4. 4.1.1 Relief Recuest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for BB-8948A, B, C, and D, the check valves in the flow path to the RCS cold legs from the safety injection pumps, safety injection accumulators, and the residual heat removal pumps, and preposed to disassemble, inspect, and manually full-stroke exercise the valves on a sampling basis during refueling outages.

I 29

a 4.4.1.1.1 Licensee's Basis for Recuesting Relief--These valves i

cannot be full or part-stroke exercised during power operation since safety injection pump discharge pressure (approximately 1520 psig) cannot overcome reactor coolant system pressure.

These valves cannot be full-stroke exercised during cold shutdowns since the residual heat removal pumps cannot l

1 provide accident required flow rates through the valves.

Accident required j

flow rates would recuire injection from the accumulators which cannot be done due to cold overpressurization concerns.

)

1 i

A different valve from this group will be disassembled, inspected, and manually full-stroked at each refueling, until the entire group has been

]

tested.

If the full-stroke capability of the disassembled valve is in

]

question, the remainder of the valves in this group will also be l

disassembled, inspected, and manually full-stroked at the same outage.

4.4.1.1.2 Evaluation--These valves cannot be full-or partial-stroke exercised during power operations because the only flow path j

through these valves is into the reactor coolant system and the accumulator, l

safety injection pumps, and residual heat removal pumps cannot establish flow into the RCS when it is at operating pressures.

Residual heat removal recirculation flow can be established into the RCS during cold shutdowns, but this flow by itself would result in only a partial-stroke exercise of these valves.

Administrative controls prevent accumulator or safety injection pump flow into the RCS during cold shutdowns because it could result in a low-temperature overpressurization of the RCS.

Establishing design accident flow through these valves into the RCS during refueling outages when the vessel head is removed to provide an adequate expansion volume is not practical since this could cause hydraulic damage to reactor and core components.

Disassembly, inspection, and manually exercising the valve disks during reactor refueling outages would provide an indication of valve mechanical condition and their ability to perform their safety related functions.

Compliance with the Code required valve exercising at power is impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly.

Based on the impracticality of complying with the 30

i Code required testing method, the burden to the licensee of complying with I

the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve closure by disassembly, inspection, and manually j

exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

i l

4.4.1.2 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for BB-8949A and D, the check valves in the safety injection pump discharge path to the I

reactor coolant system hot legs, and proposed to full-stroke exercise these valves during each refueling outage.

4.4.1.2.1 Licensee's Basis for Reouestino Relief--Valves BB-8949A and D cannot be full or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system.

Safety j

injection pump discharge pressure (-1520 psig) cannot overcome reactor coolant system pressure.

During cold shutdown these valves cannot be full or partial-stroke exercised since this could result in a low-temperature overpressurization of the reactor coolant system. These check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

4.4.1.2.2 Evaluation--The only path available to establish flow through these valves to full or partial-stroke exercise them is pumping with the safety injection pumps into the reactor coolant system. The safety injection pumps do not produce sufficient head to overcome reactor coolant system pressure during power operations.

Therefore, these valves cannot be full or partial-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, were'made which would permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved.

furthermore, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

These valves cannot be exercised by pumping into the RCS with the safety injection pumps during cold shutdowns because there is not an adequate expansion volume to receive the water and pumping into the RCS 31

Could cause or contribute to a low-temperature overpressurization of the

RCS, Additionally there are administrative controls to prevent pumping into the RCS with the safety injection pumps.during cold shutdowns.

Therefore, it is impractical to full or partial-stroke exercise valves l

BB-8949A and 0 during cold shutdowns.

The licensee will stroke these check I

valves using safety injection pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to full-stroke exercise them.

Based on the impracticality of exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.4.2 Catecory C Valves 4.4.2.1 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for BB-V001, V022, V040, and V059, the check valves in the injection lines from the centrifugal charging pumps to the reactor coolant system cold legs, and proposed to full-stroke exercise these valves during refueling outages.

j 1

4.4.2.1.1 Licensee's Basis for Recuestino Relief--Operating these valves would require using a centrifugal charging pump to provide flow which would result in injecting borated water into the reactor coolant system thereby causing a power decrease and thermal shock to the reactor coolant piping.

During cold shutdowns exercising this valve could result in a low temperature overpressurization of the reactor coolant system. These check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

4.4.2.1.2 Evaluation--The only path to exercise these valves with flow is through the centrifugal charging pumps and into the reactor coolant system cold legs which would result in injecting relatively cold water that may have a high concentration of boric acid.

Injecting this water into the i

RCS during power operations could thermal shock the system piping and 32 l

4 nozzles which could result in their premature failure induced by metal or weld fatigue due to thermal cycling.

It could also cause reactivity and pressurizer level transients which could lead to a plant trip.

Therefore, these valves cannot be full or partial-stroke exercised quarterly during 1

I power operations unless extensive system modifications, such as installing full flow test locps, are made to permit this testing.

It would be burder.some for the licensee to make such modifications because of the cost involved. Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

I l

During cold shutdowns there is inadequate expansion volume to establish centrifugal charging pump flow into the RCS through these valves without j

possibly resulting in a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full or partial-stroke exercise valves

)

BB-V001, V022, V040, and V059 during cold shutdowns. The only time that there would be a sufficient expansion volume to establish design accident flow through these valves is during refueling outages when the reactor j

vessel head is removed, l

Based on the impracticality of exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke I

exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.5 Chemical and Volume Contro'l System l

4.5.1 Catecory C Valves 4.5.1.1 Relief Recuest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for BG-8481A and B, the centrifugal cnarging pump discharge check valves, and proposed to partial-stroke exercise these valves quarterly and full-stroke exercise them during each refueling outage.

33

x q

1 4.5.1.1.1. Licensee's Basis for Recuesting Relief--These vaives' i

cannot be full-stroke exercised ~during power operation. The'only full flow path is through the boron injection tank into.the reactor coolant system.

This would cause aa increase in reactor coolant system boron inventory and i

possibly cause plant shutdown. These valves cannot be exercised during cold

'l shutdown since this could result in a cold overpressurization of the reactor coolant system.

These check valves will' be exercised (full-stroke) to the l

l l

l position required to fulfill their function at refueling.

I

4. 5.1. L 2 Evaluation--The only full flow path through these:

valves is into the RCS and establishing design accident flow through these-i valves quarterly during power operations would inject relatively cold water-

]

that may have a high' concentration of boric acid into the RCS.

Dumping this j

water into the RCS during power operations could thermal shock the system piping and nozzles which could result in premature component failure induced by metal or weld fatigue due to thermal cycling.

Injecting into the RCS-could also cause reactivity and pressurizer level transients which could lead to a plant trip.

Therefore, these valves cannot'be full-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are made to permit this testing.

It would be burdensome for the licensee to make such-modifications because of the cost involved.

Additionally, reduced system l

reliability could result from failures that could divert the injection flow a

away from the RCS.

]

During cold shutdowns there is inadequate expansion volume to establish full centrifugal charging pump flow into the RCS through these valves without possibly resulting'in a low-temperature overpressurization of'the i

RCS., Because of this concern and administrative controls to prevent its l

l occurrence, it is impractical to full-stroke exercise valves BB-8481A and B during cold shutdowns.

The only time that there would be a sufficient' l

i expansion volume to establish design accident flow through these valves is during refueling outages when the reactor vessel head is removed.

l Based on the impracticality of full-stroke exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code i

34

I requirements were imposed, and the licensee's proposed alternate testing of partial-stroke exercising quarterly and full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.5.1.2 Re'ief Recuest. The licensee has requested relief from the exercising requirements of Section XI, paragraph IWV-3520, for BG-85a6A and B, the check valves in the lines from the refueling water storage tank to the sucticn of the centrifugal charging pumps, and proposed to full-stroke exercise these valves during refueling outages.

4.5.1.2.1 Licensee's Basis for Recuestino Relief--These valves cannot be full or partiai-stroke exercised during power operation as this would increase the reactor coolant system boron inventory and possibly cause plant shutdown. These valves cannot be exercised during cold shutdown since this could result in a cold overpressurizacion of the reactor coolant system.

To perform testing on these valves requires injection of 2000 ppm borated water for several minutes for each valve. This would rasult in injection of large quantities of borated water, which would have to be removed prior to start-up and would result in larger quantities of radwaste.

Also, the test would only be a partial exercise test since full flow cannot be obtainea due to cold overpressurization concerns with lack of room for expansion to handle additional injected water.

The small amount of additional assurance supplied by a partial-stroke on a cold shutdown frequency does not justify the additional radwaste, system manipulations and manpower required to perform the tests.

These check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

4.5.1.2.2 Evaluation--The only flow path that results in full

~

flow through these valves is into the RCS and establishing design accident j

j flow through these valves quarterly during power operations would inject I

relatively cold water with a high concentration of boric acid into the RCS.

Pumping this water into the RCS during power operations could thermal shock the system piping and nozzles which could result in premature component j

failure induced by metal or weld fatigue due to thermal cycling.

In]ecting j

i 35 I

i i

i 1

4

's into the RCS could also cause reactivity'and pressurizer level transients which could lead to a plant tr.ip. Therefore, these valves cannot be full-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are'made to i

permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involvea.

Additionally, reduced system i

reliability could result from failures that could' divert the injection flow away from the RCS.

'l i

During cold-shutdowns there is inadequate expansion volume to establish full centrifugal charging pump injection flow-into the RCS through these' valves without possibly resulting in a low-temperature overpressurization of the RCS, Because of this concern'and administrative controls to. prevent.its occurrence, it is-impractical to full-stroke exercise v'alves BB-8546A.and B during cold shutdowns. The only time that there would be 'a sufficient expansion volume to establish design accident flow'through these valves is during refueling outages when the reactor vessel head is removed.

Partial-stroke exercising these valves during power operations would add water with high concentrations of boric acid to the reactor coolant system causing reactor power fluctuations which could result in.a plant trip.

Establishing flow through these valves and.into the normal charging and pump seal flow paths during cold shutdowns would result in a partial-stroke of the valves but could inject excessive amounts of boric acid into the RCS which could delay plant start-up and result in additional radioactive waste to be processed.

Based on the impracticality of full or partial-stroke exercising valves BB-8546A and B ouarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the. licensee's proposed alternate testing of full-stroke' exercising these valves during reactor refueling outages, relief may be granted from the Section XI-

)

requirements as requested.

.I 36-

)

4.6 Residual Heat Removal System 4.6.1 Catecory C Valves 4.6.1.1 Relief Recue,st. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EJ-89693, the check valve in the line from the discharge of the residual heat removal pump to the safety injection pump suction, and proposed to full-stroke exercise this valve during refueling outages.

4.6.1.1.1 Licensee's Basis for Reouestino Relief--This valve cannot be full stroke exercised during power operation since the only full flow path discharges into the reactor coolant system.

Safety injection pump discharge pressure (approximately 1520 psig) cannot overcome reactor coolant system pressure.

This valve cannot be full stroke exercised during cold shutdown since this could result in a cold overpressurization of the reactor coolant system.

This check valve will be exercised (full-stroke) to the position required to fulfill its function at refueling.

4.6.1.1.2 Evaluation--The only path available to establish flow through this valve to full or partial-stroke exercise it is pumping with the safety injection pumps into the reactor coolant system.

The safety injection pumps do not produce sufficient head to overcome reactor coolant system pressure during power operations.

Therefore, this valve cannot be full or partial-stroke exercised quarterly during power operations unless extensive system modifications, such as installing a full flow test loop, is made to permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved.

Additionally, reduced system reliability could result from failures that could divert the inje'ction flow away from the RCS.

l This valve cannot be exercised by pumping into the RCS with the safety l

l injection pumos during cold shutdowns because there is not an adequate expansion volume and pumping into the RCS could cause or contribute to a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full l

or partial-stroke exercise valve EJ-8969B during cold shutdowns.

The 37 l

licensee will exercise this check valve.using safety injection pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to full-stroke exercise it.

1 Based on the impracticality of exercising valve EJ-8969B quarterly or during cold shutdowns, the burden on the licensee if these Code requirements.

j were imposed, and the licensee's proposed alternate' testing of full-stroke exercising this valve during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

1 I

4.6.1.2 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EJ-8969A, the check valve in the line from the discharge of the residual heat removal-pump to the centrifugal charging pump suction, and proposed to full-stroke exercise this valve during refueling outages.

4.6.1.2.1 Licensee's Basis for Reouesting Relief--This valve cannot be full-stroke exercised during power operation since the centrifugal charging pumps do not full-flow into the RCS during normal operation (average flow -120 gpm, full flow -500 gpm.)

Partial-stroke exercising would require starting up the RHR pump, aligning it to the RWST, opening EJ-HV-8804A, and as a result you would borate the RCS with 2000 ppm water, which is not conducive to plant operation.

This valve cannot be full-stroke exercised during cold shutdown since this could result in a cold over pressurization of the reactor coolant system.

This check valve will be full-stroke exercised to the position required to fulfill its function at refueling.

l 4.6.1.2.2 Evaluation--The only path available to establish' flow l

through this valve to full or partihi-stroke exercise check valve EJ-8969A l

is pumping with the centrifugal charging pumps into the reactor coolant j

system.

Establishing full centrifugal charging pump injection flow into the reactor coolant system during power operations would be adding relatively cold water with high concentrations of boric acid _to the RCS.

Injecting into the RCS during power operations could cause thermal shock to. system piping and_ injection nozzles resulting in their premature failure, and could cause reactivity and pressurizer level fluctuations which could result in a 38

plant trip. Therefore, this valve cannot be full-stroke exercised quarterly during power operations unless extensive. system modifications, such as installing a full flow test loop, is made to permit' this testing.

It would be burdensome for the licensee to make such modifications because'of the l

cost involved. Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

This valve cannot be exercised by pumping into the RCS through the injection flow path with the centrifugal charging pumps during cold shutdown vecause there is not an adequate expansion volume and pumping into the RCS could cause or contribute to a low-temperature overpressurization of j

the RCS.

Because of this concern and administrative controls to prevent its

{

l occurrence, it is impractical to full or partial-stroke exercise valve EJ-8969A during cold shutdowns. The licensee will exercise this check valve using centrifugal charging pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to full-stroke exercise it.

Based on the impracticality of exercising valve EJ-8969A quarterly or during cold shutdowns, the burden on the licensee if these Code requirements i

were imposed, and the licensee's proposed alternate testing of full-stroke exercising this valve during reactor refueling outap a, relief may be granted from the Section XI requirements as requested.

)

4.6.1.3 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EJ-8958A and B, the check valves in the lines from the refueling. water storage tank to the suction of the residual heat removal pumps, and proposed to q

partial-stroke exercise these valves cuarterly and to full-stroke exercise j

them"during refueling outages.

4.6.1.3.1 Licensee's Basis for Reouestino Relief--These valves cannot be full-stroke exercised during power operations since the full flow.

~

I path discharges into the reactor coolant system.

Residual heat removal pump discharge pressure (approximately 250 psig) cannot overcome reactor coolant system pressure during full power operations.

Valves EJ-8958A and B cannot be full-stroke exercised during cold shutdown due to insufficient expansion 39

a volume for injection during cold shutdown. These check valves will be partial-stroke exercised every three months and will be exercised (full-stroke) to the position required to fulfill their function at refueling.

i 4.6.1.3.2 Evaluation--The only path available to establish flow through these valves to full-stroke exercise them is pumping with-the residual heat removal pumps into theLreactor. coolant system.

The residual heat removal pumps do not produce sufficient head to overcome reactor-coolant system pressure during power operations. Therefore, these valves cannot be ful.1-stroke exercised quarterly during power operations unless l

extensive system modifications, such as installing a full flow test loop, is made'to permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved. Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS. The residual heat removal pumps can be operated in a recirculation flow path back to the refueling water storage tank quarterly during power operations, however, these valves are only partial-stroke exercised at that time because design acc dent flow rates J

cannot be established through this flow path.

These valves cannot be exercised during cold shutdowns because there is insufficient expansion volume in the reactor coolant system to accommodate LPSI flow rates through these valves into the RCS..Because of this and the concern that injection flow could contribute to a low-5 mperature overpressurization of the RCS, it is impractical to full or partial-stroke exercise valves EJ-8958A and B during cold shutdowns. The licensee will 4

partial-stroke exercise these check valves in a recirculation flow path l

quarterly and will full-stroke exercise them using low pressure safety injection pump (residual heat removal) flow during refueling outages when an l

adequate expansion volume exists to accommodate the required flow.

t.

I Based on the impracticality of full-stroke exercising valves EJ-8958A and B quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of partial-stroke exercise these check valves in a recirculation j

flow path quarterly and full-stroke exercising them during reactor refueling 40

i i

4 outages, relief may be. granted from the Section XI requirements as requested.

4.7' High Pressure Coolant injection System 1

l 4.7.1 Category AC Valves l

4.7.1.1 Relief Recuest. The licensee has requested relief from the l

exercising requirements of Section XI, Paragraph IWV-3520, for EM-V001, l

V002, V003, and V004, the high pressure coolant injection'to RCS hot leg check valves, and proposed to full-stroke exercise these valves during refueling outages when an adequate expansion volume is available.

3 i

i l

4.7.1.1.1 Licensee's-Basis for Reouesting Relief--These valves cannot be full or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system.

Safety injection j

l pump discharge pressure (approximately 1520 psig) cannot overcome reactor l

coolant system pressure. During cold shutdown these valves cannot be full or partial-stroke exercised since this could result in a low temperature-overpressurization of the reactor coolant system.

These check valves will l

be exercised (full-stroke) to the position required to fulfill their j

L function at refueling, j

4.7.1.1.2 Evaluation--The only path available to establish flow through these valves to full or partial _ stroke exercise them is pumping with l

the safety injection pumps into the reactor coolant system.

The safety i

l injection pumps.do not produce sufficient head to overcome reactor coolant system pressure during power operations. Therefore, these valves cannot be full or partial-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are made which permit this testing.- It would be burdensome for the licensee to make such modifications because of the cost involved.

Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

These valves cannot be exercised by pumping into the RCS with the safety injection pumps during cold shutdowns because there is not an 41

(

l I

adequate expansion volume and pumping into the RCS could cause or contribute to a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical' to I

full or ps.rtial-stroke exercise valves EM-V001, V002, V003, and V004 during cold shutdowns.

The licensee will full-stroke these check valves using safety injection pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to exercise them.

Based on the impracticality of exercising valves EM-V001, V002, V003, and V004 quarterly or during' cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

)

I 1

1 4.7.2 Category C Valves 4.7.2.1 Relief Recuest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EM-8922A and B, the safety injection pumps discharge check valves, and proposed to full-stroke exercise these valves during refueling outages.

4.7.2.1.1 Licensee's Basis for Recuesting Relief--These valves cannot be full or partial-stroke exercised during power operation since' the only flow path discharges into the reactor coolant system.

Safety injection pump discharge pressure (approximately 1520 psig) cannot overcome reactor coolant system pressure.

During cold shutdown these valves cannot bc full or partial-stroke exercised since this could result.in a low-temperature overpressurization of the reactor coolant system.

These' check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

E aiuation--The only path available to establish flow 4.7.2.1.2 l

through these valves to full or partial-stroke exercise them is pumping with the safety injection pumps into the reactor coolant system. The safety injection. pumps do not produce sufficient head to overcome reactor coolant system pressure during power operations.

Therefore, these valves cannot be 42 1

_ _ _. _ ___1__j

(

y l

' full or partial-stroke. exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are made which permit thisLtesting.

It would be burdensome for the licensee to make such modifications because of.the cost involved.

Additionally, reduced i

u system reliability could result from failures that could divert the j

injection flow away from.the RCS.

These valves cannot be exercised by pumping into the RCS with the

.l safety injection pumps during cold shutdowns because there is not an adequate expansion volume and pumping into tne RCS could'cause or contribute I

to a low-temperature everpressurization of the RCS.

Because of.this concern l

and administrative controls to prevent its occurrence, it is impractical to full or partial-stroke exercise valves EM-8922A and B during cold I

shutriowns. The licensee will full-stroke these check valves using safety l

injection pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to exercise them.

Based on the impracticality of exercising valves EM-8922A and B quarteriy or during cold shutdowns, the burden on the licensee if these Code i

requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.7.2.2 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EM-8815, V240, and V241, the check valves in the centrifugal charging pump injection flow path, and proposed to full-stroke exercise these valves during refueling outages.

4.7.2.2.1 Licensee's Basis for Reouesting Relief--Using a centrifugal charging pump to provide flow would result in injecting borated water into the reactor coolant system through the. cold leg injection lines.

This would result in a decrease in reactor power and thermal shock to the reactor coolant piping.

During cold shutdowns exercising these valves could result in a low-temperature overpressurization of the reactor coolant system. These check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

43 I

4.7.2.2.2 Evaluation--The only path available to establish flow through these valves to full or partial-stroke exercise them is pumping with the centrifugal charging pumps into the reactor coolant system cold l

legs, which would result in injecting relatively cold water that may have a high concentration of boric acid.

Injecting this water into the RCS during power operations coulu thermal shock the system piping and nozzles which could result in their premature failure induced by metal or weld fatigue due to thermal cycling.

It could also cause reactivity and pressurizer level transients wHch could lead to a plant trip. Therefore, these valves cannot be full or partial-stroke exercised quarterly during l

power operations unless extensive system modifications, such as installing full flow test loops, are made to permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved.

Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

During cold shutdowns there is inadeqcate expansion volume to

--+ablish centrifugal charging pump flow into the RCS through valves LJ 8815, V240, and V241 without possibly resulting in a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full or partial-stroke exercise these valves during cold shutdowns.

The only time that there would be a sufficient expansion volume to establish design l

I accident flow througn these valves is during refueling outages when the reactor vessel head is removed.

Based on the impracticality of exercising valves EM-8815, V240, and V241 quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.7.2.3 Relief Reauest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EM-8926A and B, the check valves in the safety injection pump suction from the refueling water storage tank, and proposed to partial-stroke exercise f

44 l

- ------ - a

these valves quarterly during power operations and to full-stroke exercise them at refueling outages.

i 4.7.2.3.1 Licensee's Basis for Reouesting Relief--These valves cannot be full-stroke exercised during power operation since the only full flow path discharges into the reactor coolant system.

Safety injection pump discharge pressure (-1520 psig) cannot overcome reactor coolant j

system pressure.

During cold shutdown these valves cannot be full-stroke l

exercised since this could result in a low-temperature overpressurization l

of the reactor coolant system.

These check valves will be partial-stroke exercised every 3 months and full-stroke exercised to the position required to fulfill their function at refueling.

1 4.7.2.3.2 Evaluation--The only path available to establish full l

flow through valves EM-8926A and B to full-stroke exercise them is pumping l

i l

with the safety injection pumps into the reactor coolant system. The l

l l

safety injection pumps do not produce sufficient head to overcome reactor coolant system pressure during power operations. These valves are I

exercised during the quarterly safety injection pump tests, however, the recirculation flow path used for this test does not allow passage of design l

accident flow which makes this a partial-stroke exercise of these check l

valves.

Therefore, these valves cannot be full-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are made which permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved. Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

EM-8926A and B cannot be exercised by pumping into the RCS with the safety injection pumps during cold shutdowns because there is not an adequate expansion volume and pumping into the RCS could cause or contribute to a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full or partia'-stroke exercise valves EM-8922A and B during cold shutdowns. The licensee will partial-stroke exercise these check valves quarterly during power operations and full-stroke them using safety 45

.q:

injection pump flow into the R'CS during refueling outages when an adequate expansion volume exists to accommodate the flow required to exercise them.

Based on'the impracticality of exercising valves EM-8926A and 8 quarterly or during cold shutdowns, the burden on the licensee if these' Code requirements were imposed, and the licensee's proposed alternate testing of partial-stroke exercising these valves quarterly during power operations and full-stroke exercising them during reactor refueling outages, relief may be j

l granted from the Section XI requirements as requested.

4.8 Containment Spray System i

l 4.8.1 Category C Valves 4.8.1.1 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EN-V002 and

{

V008, the check valves in the suctior of the containment spray pumps from j

the containment sump, and proposed to disassemble, inspect, and manually exercise these valves during refueling outages on_a sampling basis.

l 4.8.1.1.1 Licensee's Basis for' Requesting Relief--These valves i

cannot be full-stroke exercised since the only flow path is.from the l

containment sump.

Flow from the containment sump would require filling the sump with water and providing it with a constant supply of clean water.

This would be very difficult to perform.' Also, full' flow would require spraying containment which would result in damage to lagging, non EQ electrical equipment, etc.

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

If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in that group will also be disassembled, inspected, and manually full-stroked at the same outage.

4.8.1.1.2 Evaluation--Valves EN-V002 and V008 cannot be full-stroke exercised during power operations because the only full flow path through these valves is from the containment sump to the containment spray rings which would result in spraying water inside containment.

46

l Establishing flow through the containment spray nozzles would result in wetting down most of the equipment and structures inside containment which j

could cause damage to equipment and insulation and require extensive repairs and cleanup.

Flow can be established through these valves utilic'.ng the l

recirculation flow path back to the refueling water storage tank, however, this is not a full-flow path and using it would only result in a partial-stroke exercise of these check valves.

To full or partial-stroke exercise these valves with flow would also require providing a source of water to fill the containment sump, and pumping from the sump could 1

introduce impurities into the containment spray system and into the l

l refueling water storage tank which could require draining and refilling to restore them to acceptable water chemistry standards.

A partial-stroke exercise of valves EN-V002 and V008 would require filling the containment sump with water and establishing flow from the sump into the refueling water storage tank.

It is impractical for the licensee to enter the primary containment quarterly during power operation to fill the containment sump to perform this testing.

Performing a partial-stroke l

exercise of these valves during cold shutdowns would result in poor quality water being placed into the containment spray system and into the refueling water storage tank which could necessitate flushing these systems to return them to the required water chemistry standards. 'It is impractical for the licensee to perform this partial-stroke exercise during cold shutdowns because of the involvement of this testing which could delay returning the plant to power.

Disassembly, inspection, and manually exercising the valve disks during reactor refueling outages would provide an indication of valve mechanical condition and their ability to perform their safety related functions.

Compliance with the Code required valve exercising at power is 1

impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly.

Based on the impracticality of complying with the l

Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve operability by disassembly, inspection, and l

l 47 1

manually exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

4.8.1.2 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EN-V003, V004, V009, and V010, the containment spray pump suction from the refueling water storage tank and discharge check valves, and proposed to partial-stroke exercise these valves quarterly during power operations and to disassemble, inspect, and manually exercise the valve disks on a sampling basis during refueling ou'. ages.

4.8.1.2.1 Licensee's Basis for Reauesting Relief--These valves cannot be full-stroke exercised since the only full-flow flow path is to the spray headers which would result in spraying containment resulting in damage to lagging, non EQ electrical equipment, etc. These check valves will be exercised (partial-stroke) every 3 months.

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

If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in that group will also be disassembled, inspected, and manually full-stroked at the same outage.

4.8.1.2.2 Evaluation--Valves EN-V003, V004, V009, and V010 cannot be full-stroke exercised during power operations because the only full flow path through these valves is from the refueling water storage tank to the containment spray rings which would result in spraying water inside containment.

Establishing flow through the containment spray nozzles would result in wetting down most of the equipment and. structures inside containment which could cause damage to equipment and insulation and require extensive repairs and cleanup.

Flow can be established through these valves utilizing the recirculation flow path back to the refueling water storage tank, however, this is not a full-flow path and using it would only result in a partial-stroke exercise of these check valves.

A partial-stroke exercise of valves EN-V003, V004, V009, and V010 utilizing the recirculation flow path back to the refueling water storage i

48

tank will be performed quarterly during power operation;.

It is impractical to establish spray flow through these valves to full-stroke exercise them during any mode of plant operation since this would result in damage to equipment and insulation inside' containment.

Disassembly, inspection, and i

manually exercising the valve disks on a sampling basis during reactor refueling outages would provide an indication of valve mechanical condition and their ability to perform their safety related functions.

l Compliance with the Code required valve exercising at power is

)

impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly.

Based on the impracticality of complying with the l

Code required test *.ng method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate l

testing of verifying valve operability by disassembly, inspection, and manually exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

1 4.8.1.3 Relief Recuest.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for EN-V013 and V017, the containment spray header check valves, and proposed to disassemble, inspect, and manually exercise the valve disks on a sampling basis during refueling outages.

l 4.8.1.3.1 Licensee's Basis for Recuesting Relief--To full or partial-stroke these valves, flow from the containment spray pump would have to be initiated.

This would result in spraying water through the spray nozzles into containment resulting in damage to lagging, non EQ electrical equipment, etc..

These check valves will be disassembled at refueling and inspected to ensure freedom of movement.

A different valve from this group will be disassembled, inspected, and manually full-stroked at each refueling, until the entire group has been tested.

If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in this group will also be disassembled, inspected, and manually full-stroked at the same outage.

49

j

)

4.8.1;3.2 Evaluation--Valves EN-V013 and V017 cannot be full or partial-stroke exercised with flow during power operations or any plant operating mode, because the only flow path through these valves results:in.

i flow.to the containment spray rings which would result in spraying water i

inside containment.

Establishing flow through' the containment spray nozzles would result in wetting down most of the equipment and structures inside containment which could cause. damage to equipment and insulation and require' extensive repairs and cleanup.

l 1

Disassembly, inspection, and manually exercising the valve disks on a j

sampling basis during reactor refueling outages would. provide an indication I

of valve mechanical condition and their ability to perform their safety related functions.

]

I l

Compliance with the Code required valve exercising at power is-

.i impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown j

and valve disassembly.

Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the' licensee's proposed alternate testing of verifying valve operability by disassembly, inspection, and manually exercising the valve disks during reactor refueling' outages, relief may be granted from the Code requirements as requested.

4.9 Accumulator Safety Injection System

_l 4.9.1 Cateoory AC Valves.

j

~

4.9.1.1 Relief Reouest.

The licensee has requested relief from the exercising requirements of Section:XI, Paragraph.IWV-3520, for EP-8956A, B, C, and D, the safety injection accumulator outlet check valves, and proposed to disassemble, inspect, and manually exercise the valve disks on a sampling basis during refueling outages.

4.9.1.1.1 Licensee's Basis for Reauesting Relief--These valves cannot be full or part-stroke exercised during power operation since cold leg accumulator pressure (approximately 540 psig) cannot overcome reactor 50

i I

i coolant system. pressure.

During cold shutdowns, exercising these valves j

could result in a low-temperature overpressurization of the reactor coolant system. These check valves will be disassembled at refueling and inspected l'

to ensure freedom of movement.

A different valve from this group will be i

disassembled, inspected, and manually full-stroked at each refueling, until the entire group has been tested.

If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in this group j

will also be disassembled, inspected, and manually full-stroked at the same j

-i outage.

t 4.9.1.1.2 Evaluation--Valves EP-8956A, B, C, and D cannot'be full-or partial-stroke exercised during. power operations because the only -

flow path through these valves is into the reactor coolant system and the f

accumulator cannot establish flow into the RCS when at operating pressures.

'j Therefore, these valves cannot be full or partial-stroke exercised quarterly 1

l during power operations unless extensiv'e system modifications, such as installing full flow test loops, are made to permit this testing.

It would j

be burdensome for the licensee to make such modifications because of the j

cost involved.

Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

These check valves cannot be exercised by discharging the accumulators into the RCS during cold shutdowns because there is not an adequate expansion volume and injecting into the RCS could cause or contribute to a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full or partial-stroke exercise valves EP-8956A, B, C, and D during cold shutdowns.

Establishing design accident flow through these valves into the RCS during refueling outages when the vessel head is removed to provide an adequate expansion volume is not practical since this could cause hydraulic damage to reactor and core components.

These valves will be disassembled, inspected, and the valve disks will be manually exercised on a sampling basis during refueling outages.

Compliance with the Code required valve exercising at power is impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown 51

a and valve disassembly.

Based on the impracticality of complying'with the i

f Code required testing method, the burden to the licensee of complying with the Code required testing' frequency, and the licensee's proposed alternate testing of verifying valve operability by disassembly, inspection, and -

manually exercising the valve disks during reactor refueling outages, relief' may be granted from the Code requirements as requested.

l 4.9.1.2 Relief Request. The licensee has requested relief from the-exercising requirements of Section XI, Paragraph IWV-3520, for EP-V010, V020, V030, and V040, the check valves in the safety injection pump discharge lines to the reactor coolant system cold legs, and proposed to full-stroke exercise these valves'during refueling outages.

4 ;

4.9.1.2.1 Licensee's Basis for Requesting Relief--These valves cannet be full or partial-stroke exercised during power operation since the only flow path discharges into the reactor coolant system.

Safety injection pump discharge pressure (-1520 psig) cannot overcome reactor coolant system pressure.

During cold shutdown these valves cannot be full or partial-stroke exercised since this could result in a low-temperature

]

overpressurization of the reactor coolant system.

These check valves will be exercised (full-stroke) to the position required to fulfill their function at refueling.

4.9.1.2.2 Evaluation--The only path available to establish flow through valves EP-V010, V020, V030, and V040 to full or partial-stroke exercise them is pumping with the safety injection pumps into the reactor coolant system.

The safety injection pumps do not produce sufficient head I

to overcome reactor coolant system pressure during power operations.

Therefore, these valves cannot be full or partial-stroke exercised quarterly during power operations unless extensive system modifications, such as I

installing full flow test loops, are made which permit this testing.

It would be burdensome for the lic.ensee to make such modifications because of the cost involved.

Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

i i

52

7" 4

These valves cannot be exercised by pumping into the RCS with the safety injection pumps during cold shutdowns because there is not an adequate expansion volume and pumping into the RCS could cause or contribute to a low-temperature overpressurization of the RCS.

Because of this concern and administrative controls to prevent its occurrence, it is impractical to full or partial-stroke exercise valves EP-V010, V020, V030, and V040 during cold shutdowns. The licensee will full-stroke these check valves using safety injection pump flow during refueling outages when an adequate expansion volume exists to accommodate the flow required to exercise them.

Based on the impracticality of exercising valves EP-V010, V020, V030, i

and V040 quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4.10 Auxiliary Feedwater pumo Turbine 1

4.10.1 Cateaory C Valves l

l 4.10.1.1 Relief Request.

The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for FC-V001, V002, V024, and V025, the check valves in the main steam supply to the auxiliary feedwater turbine, and proposed to partial-stroke exercise these I

valves open quarterly during power operations, full-stroke them open during cold shutdowns, and to verify the reverse flow closure of these check valves by disassembling, inspecting, and manually exercising the valve disks during refueling outages on a sampling basis.

4.10.1.1.1 Licensee's Basis for Reouestina Relief--These valves cannot ce full-stroke opened during power operation since this would require full flow of cold water from the turbine driven auxiliary feedwater pump to 1

l the steam generators. This is undesirable since this would unnecessarily thermal shock the steam generator feedwater nozzles.

53 E

l I

These valves cannot be full or partial-stroke tested closed since there are no lines coming off between the two valves on a line to allow for j

pressurization and depressurization.

1 These check valves will be partial-stroke tested open quarterly and f

full-stroke exercised open at cold shutdown frecuency.

These valves will be tested for closure capability by disassembling,. inspecting, and manually

)

full-stroking a different valve of this group at each refueling outage until f

the entire group has been tested.

If the full-stroke capability of the f

disassembled valve is in question, the remainder of the valves in this group i

i will also be disassembled, inspected, and manually full-stroked at the same j

outage.

I 4.10.1.1.2 Evaluation--To draw enough steam through valves f

FC-V001. V002, V024, and VC25 to verify a full-stroke exercise with flow would require establishing essentially full turbine driven auxiliary i

feedwater pump flow.

The recirculation flow path used during the quarterly l

I l

turbine driven auxiliary feedwater pump tests is not a full-flow path, therefore, insufficient steam flow passes through the steam check valves to assure that they full-stroke open. The only flow path that allows full auxiliary feedwater flow is when the pump is lined-up to discharge into the l

l steam generators.

Auxiliary feedwater flow should not be directed into the i

i steam generators for testing during power operations because this would

{

inject relatively cold water into the feedwater piping and nozzles which could thermal shock these components and result in their premature failure.

I These valves will be partial-stroke exercised quarterly during the pump test l

l when recirculation flow is established and full-stroke exercised by feeding the steam generators while going into cold shutdowns when the temperature j

differentials are reduced.

The reverse flow closure of these valves cannot be determined during power operations or during cold shutdowns because there are no test

(

connections that allow these valves to t;e indi Oually verified. closed.

l Therefore, these valves cannot be exercised cicsed quarterly during power operations unless extensive system modifications, such as installing test taps, are made to permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved.

54

1 c.

s.

l Additionally, reduced system reliability could result from failures associated with the additional system penetrations.

These valves will be verif{edtoclosebyvalvedisassembly, inspection,andmanualstroking j

during refueling outages on a sampling basis.

Compliance with the Code required valve exercising at power is impractical due to system design.

Compliance with the Code required testing

(

frequency would be burdensome since this would require quarterly shutdown and valve disassembly.

Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with j

the Code required testing frecuency, and the licensee's proposed alternate testing of verifying valve closure capability by disassembly, inspection, j

and manually exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

4.11 Emergency Diesel Generator Air Start System i

4.11.1 Category B Valves i

4.11.1.1 Relief Recuest.

The licensee has requested relief from the l

stroke time measurement requirements of Section XI, Paragraph IWV-3413, for KJ-PV-001A, 001B, 101A, and 101B, the emergency diesel generator air start solenoid operated valves, and proposed to measure the diesel generator starting times and the starting air tank pressures to verify operation of individual valves and to monitor valve degradation.

4.11.1.1.1 Licensee's Basis for Reauesting Relief--These are totally enclosed solenoid valves. The valves are controlled by the start /stop switch for the diesel.

Therefore, stroke time for the valves themselves cannot be measured.

Valve stroke time affects diesel start time.

Diesel start time will be used to monitor valve performance.

A maximum stroke time of 12 seconds will be used since this is the limit for diesel start time.

Since both valves actuate when the diesel is started, changes in starting air tank pressures will be monitored to ensure approximately equal pressure decreases to verify both valves actuated properly.

55

o 4.11.1.1.2 Evaluation--These valves are totally enclosed solenoid operated valves which have no externally visible-indication of valve position.

It is not possible to measure the stroke times of these solenoid operated valves because there is no way to determine when a valve receives a signal to open or when it reaches the open position.

These solenoid valves are rapid acting valves which normally stroke almost instantly and when they do not operate promptly, they most commonly fail to' operate at all.

It can A

i be indirectly. verified that each valve has opened by monitoring the air pressure in the associated air start tank. Measuring the diesel start times-

.gives an indication of possible valve degradation since any significant change in valve stroke time would result in longer diesel generator start times. The full-stroke. times cannot be measured for these~ valves.unless system modifications, such as replacing the diesel air start solenoid valves

]

I with valves that have valve disk position indication, are made to permit this testing.

It would be burdensome for the licensee to make such modifications because of the cost involved and considering the most common failure mode and the limited amount of additional information that would be provided above that generated by the proposed alternate testing.

Compliance with the Code required testing method is impractical due to the system design.

Based on the impracticality cf complying with the Code required testing method and on the licensee's proposed alternate testing'of measuring the diesel generator starting times and observing the starting air tank pressures to verify operation of the individual solenoid operated air start valves and to monitor their degradation, relief may be granted from the Code requirements as requested.

9 56

4 l

. N 4

APPENDIX A i

VALVES TESTED DURING COLD SHUTDOWNS i

l k

l l

l I

57

APPENDIX A 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 Paragraphs IWV-3412 and -3522 and are full-stroke exercised during cold shutdowns and refueling outages.

All valves in this Appendix have been reviewed and the reviewer agrees with the licensee that testing these valves during power operations is not practical due to the valve type, location, or system design. These valves should not be full-stroke exercised during power operations. These

{

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

1.

MAIN STEAM SYSTEM l

1 l

1.1 Category B Valves AB-PV-1, 2, 3, and 4, the steam generator power operated relief valves, cannot be exercised during power operations because opening these valves would cause an increase in main steam header flow which would result in a steam pressure and reactor power transient and could lead to a plant trip.

These valves will be full-stroke exercised, fail-safe tested, and g

have their stroke times measured during cold snutdowns and refueling l

)

outages.

AB-HV-11,14,17, and 20, the main steam isolation valves, cannot be

~

full-stroke exercised during power operations because fully closing one of these valves isolates the steam supply from one of the four steam generators to the main turbine resulting in a severe steam pressure and l

power transient which could cause a plant trip.

These valves will be partial-stroke exercised quarterly during power operations and will be j

full-stroke exercised and have their stroke times measured during cold i

shutdowns and refueling outages.

59 l

a 2.

MAIN FEEDWATER SYSTEM l

l l

2.1 Category B Valves l

AE-FV-39, 40, 41, and 42, the isolation valves on the main feedwater headers, cannot be full-stroke exercised during power operations because closing these valves would isolate feedwater flow to a steam generator l

which would cause the loss of steam generator water level control and could f

result in a plant trip.

These valves will be partial-stroke exercised quarterly during power operations and full-stroke exercised, fail-safe tested, and have their stroke times measured during cold shutdowns and l

refueling outages.

2.2 Category C Valves AE-V-124, 125, 126, and 127, the auxiliary feedwater header check valves, cannot be exercised during power operations because to exercise l

these valves with flow would require establishing auxiliary feedwater flow into the steam generators and this relatively cold water could thermal shock the feedwater piping and nozzles which could cause premature failure of those components.

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

3.

AUXILIARY FEEDWATER SYSTEM 3.1 Cateoory C Valves The following auxiliary feedwater check valves cannot be exercised I

during power operations because to exercise these valves open would require establishing auxiliary feedwater flow into the steam generators and this relatively cold water could thermal shock the feedwater piping and nozzles which could result in premature failure of those components.

Valves AL-V-001, -002, and -003 will be partial-stroke exercised quarterly during power operations and all of the following valves will be full-stroke exercised during cold shutdowns and refueling outages.

l 60 l

I e

1

' Valve Function AL-V-001 Auxiliary feedwater pump suction from the CST AL-V-002 Auxiliary feedwater pump suction ~from the CST AL-V-003-Auxiliary feedwater pump suction from the CST AL-V-030 Motor driven pump "B" discharge check valve AL-V-033 Motor driven pump supply to SG-"A"'

AL-V-036 Motor driven pump supply to SG "0" AL-V-042 Motor driven pump "A" discharge check valve AL-V-045 Motor driven pump supply to SG "C" AL-V-048 Motor driven pump supply to SG."B" l

AL-V-054 Turbine driven pump discharge check valve AL-V-057 Turbine driven pump supply to SG "A" AL-V-062 Turbine driven pump supply to SG "D" AL-V-067 Turbine driven pumo supply to SG "B" AL-V-072 Turbine driven pump supply to SG "C" 4.

REACTOR COOLANT SYSTEP 4.1 Category A Valves BB-HV-8351A, B, C, and D, the reactor coolant pump seal water supply isolation valves, cannot be exercised during power operations because failure of one of these valves in the closed position during testing would stop flow to the pump seals which could damage the reactor coolant-pump seals and result in a plant shutdown.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

l BB-PV-8702A and B, the residual heat removal (RHR) recirculation suction isolation valves, cannot be exercised during power operations because these valves are interlocked with reactor coolant system pressure in such a manner that the valves cannot be opened when the pressure is above 383 psig in order to prevent overpressurization of the low pressure-RHR system piping by the higher pressure reactor coolant system.

Overpressurization of the RHR could result in an inter-system LOCA outside-of containment.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

61

a e

4.2 Category A/C Valves BB-8949B and C, the residual heat removal recirculation path isolation valves to the reactor coolant system hot legs, cannot be exercised during power operations because the only flow path to exercise these valves ~with flow is into the reactor coolant system and neither.the RHR pumps nor the safety injection pumps produce sufficient discharge pressure to overcome the normal reactor coolant system operating pressure. The discharge pressure of the RHR pumps is -210 psig and the discharge pressure of the SI pumps is -1520 psig.

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

4.3 ' Category B Valvec BB-HV-8001A, 8001B, 8002A, and 8002B, the reactor coolant system high point vent valves, cannot be exercised during power operations because, no matter what sequence is used when testing these valves, exercising them t

would result in venting out son:e RCS water which could contaminate

. equipment inside containment and could result in equipment damage unless a vent rig is used to control the effluent.

During power operations a vent rig cannot be installed to allow testing because this would require entering containment and working in a radiation area;.

These valves will be' 1

exercised and have the'ir stroke times measured during cold shutdowns and re9eling outages.

i BB-HV-13, 14, 15, and.16, the isolation valves in the reactor coolant pump thermal barrier cooling water return lines, cannot be exercised during j

power operations because failure of a valve in the closed position during i

testing would isolate cooling flow to.one of the reactor coolant pumps i

thermal barrier which could damage the" reactor coolant pump and result in a p

plant shutdown.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

BB-PCV-455A and 456B, the pressurizer power operated relief valves, will be exercised during cold shutdowns.

This exercising frequency is consistent with the NRC guidelines for pressurizer power operated relief valves.

62

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l 5.

CHEMICAL AND VOLUME CONTROL SYSTEM 5.1 Category A Valves

]

BG-HV-8100 and 8112, the isolation valves on the reactor coolant pump q

seal water return lines, cannot be exercised during power operations because closure of either valve would stop seal water flow across the reactor coolant pump seals which could damage the seals and result in-leakage from the reactor coolant system. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

L i

BG-HV-8152 and 8160, the containment isolation valves in the normal l

letdown lines, cannct be exercised during power operations because failure.

l of either valve in the closed position during testing would isolate the j

normal letdown flow which would cause a-loss of pressurizer level control l

and could result in a plant trip.

These valves will be exercised and have l

their stroke times measured during cold shutdowns and refueling outages.

l i

5.2 Category B Valves BG-HV-8105 and 8106, the isolation valves in the normal charging lines y

to the reactor coolant system, cannot be exercised during power operations because closing either valve would isolate normal charging flow to the' reactor coolant system which would cause a loss of pressurizer level l

control and could result in a plant trip.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling l

outages.

~ BG-LCV-112B and 1120, the isolation valves in the line from the volume control tank to the charging pump suctions, cannot be' exercised during power operations because closing either valve would isolate the normal suction source for the charging pumps which could stop reactor coolant. pump seal flow, thereby damaging the seals, and cause a loss of pressurizer level control. Using an alternate suction source for the charging pumps could result in injecting water with a higher concentration, af boric acid 63

e into the seals and the reactor coolant system which would cause a reactor power transient and could result in a plant shutdown.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

5.3 Cateaory C Valves BG-V-147, 165, and 174, the check valves in the emergency boration flow path, cannot be exercised during power operations because the only flow path available to exercise these valves establishes flow from the boric acid storage tanks to the charging pumo suction and then into the reactor coolant system which would cause a substantial boration of the reactor coolant system. This boration would cause unwanted negative reactivity addition and result in reactor power fluctuations. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

6.

STEAM GENERATOR BLOWDOWN SYSTEM 6.1 Catecory B Valves BM-HV-1, 2, 3, and 4, the isolation valves in the steam generator blowdown lines, cannot be exercised during power operations because failure of a valve in the closed position during testing would isolate normal I

blowdown flow which would disrupt steam generator chemistry control and could result in exceeding chemistry limits which would require a plant shutdown and could cause steam generator damage.

These valves are inside containment and are not accessible during power operations, therefore, they will be exercised, fail-safe tested, and have their stroke times measured i

during cold shutdowns and refueling outages.

l l

7.

REFUELING WATER STORAGE TANK SYSTEM l

7.1 Catecory B Valves BN-LCV-1120 and 112E, the isolation valves in the line from the refueling water storage tank to the charging pump suctions, cannot be 64 I

d I

exercised during power operations because failure of either valve in the open position would provide a path for refueling water storage tank water I

l with its higher concentrations of boric acid to the charging pump suctions which would increase the boric acid concentrations being injected into the reactor coolant system and result in a reactor power transient and possibly in a plant shutdown. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

BN-HV-8813, the isolation valve in the minimum flow line for both safety injection pumps, cannot be exercised during power operations since failure in the closed position during testing would isolate the minimum flow path for both safety injection pumps which could damage both pumps and i

render an entire safety system inoperable if they were started when reactor coolant system pressure was above the 1520 psig safety injection pump discharge pressure capability.

This valve will be exercised and have its i

stroke times measured during cold shutdowns and refueling outages.

8.

RESIDUAL HEAT REMOVAL SYSTEM l

l I

8.1 Category A Valves l

EJ-HV-8701A and B, the isolation valves in the residual heat removal l

pump suction in the normal recirculation path, cannot be exercised during power operations because these valves are interlocked with reactor coolant system pressure so that they cannot be opened when pressure is above 383 psig in order to prevent overpressurization of the low pressure RHR system piping by the higher pressure reactor coolant system.

l Overpressurization of the RHR piping could result in an inter-system LOCA outside of containment.

These valves will be exercised and have their stnoke times measured during cold shutdowns and refueling outages.

I a

l 8.2 Category A/C Valves EJ-8841A and B, the check valves in the residual heat removal injection lines to the reactor coolant system hot legs, cannot be exercised durinc power operations because the only flow path available to exercise i

65 L - -- ---

these valves with flow is into the reactor coolant system and neither the residual heat removal (discharge pressure of ~210 psig) nor the safety f

injection pumps-(discharge pressure of -1520 psig) produce sufficient head to overcome the normal operating reactor coolant system pressure.

I These valves will be full-stroke exercised during cold shutdowns and l

refueling outages.

j 8.3 Cateoory B Valves-

)

EJ-HV-8804A and B, the isolatici valves in the residual heat removal pump discharge line to the charging pump suctions, cannot be exercised during power operations because they are interlocked with valves BN-HV-8813'

.I and EM-HV-8814A and B so that these valves are closed when EJ-HV-8804A and i

B are openeo and closing BN-HV-8813 and EM-HV-8814A and B isolates the minimum flow recirculation lines for the safety injection pumps which could damage them and render an entire safety system inoperable (see the discussion for BN-HV-8813 in Appendix A Section 7.1 above).

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

I EJ-HV-8809A, 8809B, and 8840, the isolation valves for low pressure safety injection to the reactor coolant system cold legs and residual heat J

removal flow to the RCS hot legs, cannot be exercised during. power

']

operations because EJ-HV-8809A and B are required to remain open and EJ-HV-8840 is required to remain closed, with power removed from the valve operators, by the plant Technical Specifications. Moving these valves out j

of the above required positions could result in the blockage or diversion of low pressure safety injection flow to the RCS cold legs if the system was called upon to perform its emergency core cooling function by an ECC actuation. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages, l

EJ-HV-8811A and 8811B, the isolation valves in the residual heat removal pumps suction from the containment sump, cannot be exercised during power operations because opening these valves could allow water to leak into the containment sump from the pump suction line and air to get into l

66

j l

the-suction piping which could air bind and possibly damage the residual 3

heat removal pumps.

Current procedures isolate and drain the suction header prior to strcking these valves and then fill and. vent the header prior to placing the system back in service.

It is. impractical to perform j

this testing during power operations.

These valves will be exercised and j

have their. stroke times measured during cold shutdowns. and refueling outages.

i EJ-HV-8716A and B. the isolation valves in the cross-connect line between the two low pressure safety injection headers, cannot be exercised during power operations because closing either valve would isolate each low l

pressure safety injection header from two of the RCS loops. With these i

cross-connect valves closed, if a single active failure of one of the low pressure safety injection trains occurred, the remaining train could only j

deliver cooling water to two of the four reacter coolant loops. The FSAR accident analyses take credit for low head safety injection flow into-three reactor coolant system cold legs, therefore, in order to meet these requirements, valves EJ-HV-8716A and B cannot be closed curing power operations when credit is taken for the operability of the low pressure-safety injection function of the residual heat removal system. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

8.4 Category C Valves EJ-8730NandB,thecheckvalvesintheresidualheatremovalheat I

exchanger outlet lines, cannot be full-stroke exercised during power operations because the only full flow path available to exercise these j

valves with flow is into the reactor coolant system and the residual heat removal pumps (discharge pressure of -210 psig) do not produce sufficient head to overcome the normal operating reactor coolant system pressure.

These valves will be partial-stroke exercised quarterly during power operations and full-stroke exercised during cold shutdowns and refueling i

outages.

67 i

9.

HIGH PRESSURE COOLANT INJECTION 9.1 Cateaory B Valves EM-HV-8802A and B, the isolation valves in the safety injection headers to the RCS hot legs, cannot be exercised during power operatinns because these valves are required to remain closed with power removed from their actuators by the plant Technical Specifications in order to prevent diversion of safety injection flow from the reactor coolant system cold legs.

Safety injection flow is required to be into the RCS cold legs to help mitigate a LOCA as analyzed in the plant FSAR.

These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

10.

CONTAINMENT SPRAY SYSTEM 10.1 Cateaory B Valves EN-HV-1 and 7, the isolation valves in the containment spray pumps suction from the containment sump, cannot be exercised during power I

operations because opening these valves could allow water to leak into the containment sump from the pump suction line and air to get into the suction I

piping which could air bind and possibly damage the containment spray I

pumps.

Current procedures isolate and drain the suction header prior to stroking these valves and then fill and vent the header prior to placing the system back in service.

It is impractical to perform this testing l

during power operations. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

11.

ACCUMULATOR SAFETY INJECTION SYSTEM 11.1 Cotecory A/C Valves l

EP-8818A, B C, and D, the low pressure safety injection check valve to the reactor coolant system cold legs, cannot be exercised during power operations because the only flow path to exercise these valves with flow is l

l 68

i into the. reactor coolant system and the residual heat. removal pumps do not-produce sufficient discharge pressure (-210 psig) to overcome normal operatino. reactor coolant system pressure.

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

i 11.2 Catecory B Valves EP-HV-8950A, B, C, D, E, and F, the safety injection accumulator tanks vent valves, cannot be exercised during power operation because opening any l

of these valves would vent an accumulator vapor space to the atmosphere which could reduce accumulator pressure and render the accumulator inoperable.

If one of these valves failed open during testing it would depressurize the associated accumulator which would require a plant s

shutdown if the accumulator _was not returned to operation within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, These valves will be exercised and have their stroke times measured during a

cold shutdowns and refueling outages.

12.

COMPRESSED AIR SYSTEM 12.1 Catecory A Valve KA-FV-29, the containment isolation valve for the instrument air supply to the containment, cannot be exercised during. power operations because closing this valve will interrupt the instrument air supply to components inside containment including the normal letdown valves and the pressurizer spray valves which would cause pressurizer level and RCS pressure fluctuations and could result in a plant trip.

This valve will be exercised and have its stroke times measured during cold shutdowns and refueling outages.

13.

EMERGENCY DIESEL GENERATOR AIR START SYSTEM 1

13.1 Cateoory C Valve KJ-V-711A, 7118, 712A, and 712B, the check valves that prevent back-flow from the emergency diesel generator air start tanks, cannot be 69

i f

exercised during power operations because to verify closure of these valves would require bleeding the air from one of the air start tanks and

)

isolating the other, which would disable one of the diesels and require that the remaining diesel be tested every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> which would cause l

addition wear and possible damage to that diesel generator.

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

i

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I l

I l

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1 1

APPENDIX B i

P&ID AND FIGURE LIST l

1 l

1 a

l i

i i

)

O 71 l_ _____- ______. - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -

e' APPENDIX B i

P&ID ANO FIGURE LIST The P& ids and Figures listed below were used during the course of this

)

review.

System P&ID or Figure Revision Main Steam System M-02AB01 11 l

M-02AB02 12 l

l teedwater System M-02AE01 15 l

M-02AE02 13 Auxiliary Feedwater System M-02AL01 15 l

I Condensate Storage and Transfer M-02AP01 13 j

System j

l Reactor Coolant System M-02BB01 15 i

M-02BB02 18 M-02BB03 12 i

M-02BB04 6

Chemical & Volume Control System M-02BG01 12 1

M-02BG02

'14 i

M-02BG03 17

)

M-02BG04 11 I

M-02BG05 14 Reactor Make-up Water System M-02BL01 9

Steam Generator Blowdown System M-02BM01 13 i

Borated Refueling Water Storage M-02BN01 12 l

l System Fuel Pool Cooling and Clean-up M-02EC01 10 System M-02EC02 10 Essential Service Water System M-02EF01 10 M-02EF01 10 t

M-02EF02 11 73 l

System P&ID or Figure Revision Component Cooling Water System M-02EG01 11 M-02EG02 14 M-02EG03 15 l

Residual Heat Removal System M-02EJ01 17 High Pressure Coolant Injection M-02EM01 8

System M-02EM02 11 Containment Spray System M-02EN01 6

Accumulator Safety Injection System M-02EP01 13 Auxiliary Turbines-Auxiliary M-02FC02 13 Feedwater Pump Turbine Containment Hydrogen Control System M-02GS01 8

Containment Purge System M-02GT01 l'7 l

Liquid Radwaste System M-02HB01 16 1

Decontamination System M-02H001 5

Emergency Fuel Oil System -

M-02JE01 5

Compressed Air System M-02KA01 14 M-02KA02 11 M-02KA05 5

Breathing Air System M-12KB01 0

Fire Protection System M-02KC02 12 Standby Diesel Generator System M-02KJ01 5

M-02KJ02 10 M-02KJ03 5

M-02KJ04 5

M-02KJ05 9

M-02KJ06 4

Reactor Building and Hot Machine Shop M-02LF03 6

Floor and Equipment Drain System M-02LF09 12 Nuclear Sampling System M-02SJ01 12 M-02SJ04 4

Service Gas System M-02KH02 6

74

9

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e 9

l APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW 4

75

e-i APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Inconsistencies and omissions in the licensee's program noted during the course of this review are summarized below.

The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

The licensee's proposal to test the centrifugal charging pumps when 4.

running them.in a fixed resistance test loop and meesuring pump differential pressure but not measuring pump flowrate, is not acceptable.

Lack of installed instrumentation is not an adequate justification for not testing in accordance with the Code. The licensee should measure pump flowrate as well as differential pressure in order to be able to detect hydraulic degradation of these pumps as required by the Code (refer to Section 3.4.1 of this report).

2.

The licensee's proposal to test the boric acid transfer pumps when running them in a fixed resistance test loop and measuring pump differential pressure but not measuring pump flowrate, is not j

acceptable.

Lack of installed instrumentation is not an adequate justification for not testing in accordance with the Code. The 1-icensee should measure pump flowrate as well as differential pressure in order to be able to detect hydraulic degradation of these pumps as required by the Code (refer to Section 3.6.1 of this report).

3.

Since the plant Technical Specifications do not provide the minimum operability requirements for plant start-up, general relief from the

- requirement to repair, prior to start-up of the plant, any valves that are declared inoperable due to Section XI testing performed during cold shutdowns, should not be~ granted for valves in flow paths not covered by the plant Technical Specifications.

If relief is desired from IWV-3417(b) for any of these valves, the licensee should submit relief requests for specific valves (refer to Section 4.1.1 of this report).

'77 t

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31,764 aNo Austifti TECHNICAL EVALUATION REPORT, PUMP AND VALVE INSERVICE J

TESTING PROGRAM, CALLAWAY NUCLEAR PLANT, UNIT 1 8 Dat 8 Al' Cat COMPLiflo j

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July 1987 i

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I P. O. Box 1625 Idaho Falls, ID, 83415

'A6812 l

1 its TVP40FmEPORT 10 SPOmSomiNG onGamigaf aQn nasist aseo mangimG aoomiss giarews.ge Casms Mechanical Engineering Branch i

Office of Nuclear Reactor Regulation I

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U.S. Nuclear Regulatory Commission i

Washington, DC, 20555 l

is sve*Lawt=Taarsofts o a. 1.ac, a This EG&G Idaho, Inc. report presents the results of our evaluation of the Callaway Nuclear Plant, Unit 1, Inservice Testing Program for pumps and valves that perform a safety-related function.

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