ML20247N542

Technical Evaluation Rept on Pump & Valve Inservice Testing Program:Peach Bottom Atomic Power Station,Units 2 & 3

ML20247N542
Person / Time
Site:	Peach Bottom
Issue date:	05/11/1998
From:	Hartley R, Ransom C IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC (Affiliation Not Assigned)
Shared Package
ML20247N523	List: ML20247N518 ML20247N535 ML20247N542
References
CON-FIN-J-2422 INEEL-EXT-97-01, INEEL-EXT-97-1, TAC-M98850, TAC-M98851, NUDOCS 9805270178
Download: ML20247N542 (40)

Text

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• INEEUEXT-97-01406 ATTACHMENT 2 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 Docket Nos. 50-277 and 50-278 R. S. Hanley C. B. Ransom Published February 1998 Idaho National Engineering and Environmental Laboratory Nuclear Operations Suppon Programs Depanment Lockheed Manin Idaho Technologies Company Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-94IDI3223 FIN No. J2422, Task Order 3, TAC Nos. 98850 and 98851 9805270178 980511 PDR i

P ADOCK 05000277 pm

I ABSTRACT This 1.ackheed Manin Idaho Technologies Company (LMITCO) repon presents the results of our evaluation of the Peach Bottom Atomic Power Station, Units 2 and 3. Inservice Testing Program for pumps and valves whose function is safety-related.

l l PREFACE 1

l This report is supplied as pan of the " Review of the Peach Bottom, Units 2 and 3, Inservice Testing Third Ten Year Program" being conducted for the U.S. Nuclear Regulatory Cammie= ion, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by LMITCO, Nuclear ~

Operations Suppon Programs.

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l CONTENTS ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -. . . . . . . . . . .

FREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .l 1

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

2. SCOPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 . . . . . . .

3. PUMP TESTING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 . . . . . . . :

3.1 Selected Pumps in the lST Program . . . ..

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3.1.1 Flow Measurements Using Ultrasonic Flowmet :rs . . . . . . . . . . . . . . . . . . . . . 5 3.2 Emergency Service Water System . . . . . . . . . . . . . .

......................7 3.2.1 Test Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i

4. VALVE TESTING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9. . . . . . . . .

4.1 All Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4.1.1 Containment Isolation Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . .9. . . . . . .

4.1.2 Containment Isolation Check Valves . . . . . . . . . . . . . . . . . . 10 4.1.3 Excess Flow Check Valves . . . . . . . . . . . . . . . . . . . . . . . .... . . . . . . . . . 11 4.1.4 Active Manual Isolation Valves . . . . . . . . . . . . . . . . . . . . . . ........ . . . . . . . . 13 4.1.5 Passive Manual Isolation Valves . . . . . . . . . . . . . . . . . . .

4.1.6 Rapid. Acting Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

. . . . . . . . . . . . 15 4.2 Contro1 Rod Drive Hydraulic System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.2.1 Category B Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.2.2 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . .............

............. 17 4.3 Residua 1 Heat Removal system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4.3.1 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4.4 Emergency Service Water System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 l

4.4.1 Category B Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . .

19 4.4.2 Category C Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............

............. 23 APPENDIX A IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW . . . . . . A.

APPENDIX B IST PROGRAM ISSUES IDENTIFIED DURING THE SYSTEMS REVIEW . . .

APPENDIX C DEFERRED TEST JUSTIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1 111

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! TECHNICAL EVALUATION REPORT

! PUMP AND VALVE INSERVICE TESTING PROGRAM PEACH BO'ITOM ATOMIC POWER STATION, UNITS 2 AND 3

1. INTRODUCTION Contained herein is a technical evaluation of the pump and valve inseite testing (IST) prog l submined by the Philadelphia Electric C=p=ay (PECO) for its Peach Bottom Atomic Power St l Units 2 and 3.

' By a letter dated May g,1997, PECO submitted Revision 7 (approved May 2,1997) of their IST program for the Peach Bonom Atomic Power Station, Units 2 and 3. 'Ihe program for the Third Ten Year Interv.1 begins for both units on November 5,1997 and continues to November 4, 2007. The pr reviewed to verify compliance of proposed tests of pumps and valves whose function is safety-r the requirementsof the American Society of Mechanical Engineers (ASME) Operations and Maintena (OM) Code (the Code),1990 Edition.

This technical evaluation report (TER) does not address any IST program revisions suh==w to those noted above. Program changes involving additional or revised relief requests should be submined to the

' U.S. Nuclear Regulatory Commission (NRC) under separate cover in order to receive prompt a but should not be implemented prior to review and approval by the NRC.

. In its IST program, PECO requests relief from the Code testing requirements for specific pum valves. These requests were evaluated individually to determine if the criteria in 10 CFR 50.55a for granting relief or authorizing alternatives are met for the specific pumps and valves. This review was performed utilizing the acceptance criteria and guidance of the following

Standard Review Plan, Section 3.9.6

' Draft Regulatory Guide and Value/ Impact Statement titled " Identification of Valves for Inclusion in Inservice Testing Programs" Generic letter No. 89 04, " Guidance on Developing Acceptable Inservice Testing Programs" NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants" NUREG/CR-6396, " Examples, Clarifications, and Guidance on Preparing Requests for Relief from Pump and Valve Inservice Testing Requirements" Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756, " Inservice Testing of Pumps and Valvea," and Answers to Panel Questions on Inservice Testing Issues 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 tes requirements.

' Section 2 of this report presents the scope of the Peach Bottom Atomic Power Station, Units 2 and 3, review.

Section 3 of this report presents the PECO bases for requesting relief from the OM Code requirements for the Peach Bonom, Units 2 and 3, pump testing program and Lockheed Martin Idaho Technologies Company's (LMITCO's) evaluations and conclusions regarding these requests. Section 4 presents similar information for the valve testing program.

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Appendix A contains a listing ofinconsistencies and omissions in the licensee's program noted du this review. The licensee should resolve these items in accordance with the evaluations, conclusions, guidelines presented in this report.

Appendix B contains a listing ofissues identified during a review of the the Residual Heat Removal l

' (RHR)/ Low Pressure Coolant Iqjection (LPCI) and Emergency Service Water (ESW) systems. 'Ihe licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

Appendix C provides a brief description of the licensee's y ":~=4ons for deferring tests to cold shutdowns or refueling outages.

This TER, including all relief requests and component identification numbers, is applicable to Units 2 -

and 3. The Unit 3 designator has been placed in parentheses, where possible, to minimize repetition, i.e.,

MO-2(3)-02-53A. A zero used as a designator indicates that the component is common to both Units 2 ard 3. '

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2. SCOPE The LMITCO staff reviewed the Peach Bottom Atomic Power Station, Units 2 and 3, inservice testing (IST) program pump and valve relief requests, cold shutdownjustifications, refueling outagejustifistions, and technicalpositions. The staff specifically reviewed the Residual Heat Removal (RHR)/ Low Pressure Coolant Injection (LPCI) and Emergency Service Water (ESW) systems and the Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS) for the RHR/LPCI system. The staffidentified each component in the RHR/LPCI and ESW systems listed in the IST program on the plant's P&ID(s) and evaluated the test (s) designated in the IST program to assess compliance with the applicable American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code test requirements.

Following this review, the staff assessed the designated systems for completeness (to determine if additional components should have been included in the IST program). This review yielded a list of issues that shoukt be addressed by the licensee as summarized in Appendices A and B. ]

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3. PUMP TESTING PROGRAM The Peach Bottom Atomic Power Station, Units 2 and 3, IST program pump relief requests submitted by PECO were examined to determine whether relief should be granted or alternatives authorized according to the requirements of 10 CFR 50.55a and NRC positions and guidance. Each PECO basis for requeming relief from the pump testirng requh.m and proposed alternative testing and the reviewer's evaluation of that request is summarized below.

3.1 Relected Pumne in the IST h gurs i

3.1.1 mw Menema...e..a Unine tRrraennie Flowmaean 3.1.1.1 Relief Ra=ae'. Generic pump relief request, GPRR-1, requests relief from the pump .

Instrumentation accuracy requirements specified in ASME OM-1990, Section ISTB, Table 4.6.1-1, and proposes to measure flow using ultrasonic flow instrumentation calibrated to an accuracy within 15 % of reading for the following pumps:

l Pump Description Identification Diesel Fuel Oil Transfer Pumps OAP060 OBP060 l OCP060 ODP060 l Emergency Service Water Booster Pumps OAP163 OBP163 Emergency Cooling Water Pump 00P186 3.1.1.1.1 Iicemee's Racia for Reauestino Relief-PECO proposes to measure flow using  !

ultrasonic flow instrumentation that is calibrated to an accuracy within +5% of- reading instead of the  !

l Code required accuracies as specified in the OM. For instruments to be in compliance whh OM-1990, l Para.1 STB 4.6.1(a) and Table 4.6.1-1, analog instmments must be accurate to within.12 % of full scale and digital instrumentation must be accurate to within1% of the calibrated range.

While 1 STB requirements for digital instruments may be more restrictive than the proposed accuracy of the ultrasonic flowmeters, the ultrasonic flowmeters yield an accuracy which is comparable if more accurate than an analog instrument calibrated to 12 % of full scale given a full scale range of up to 3 times the reference value. PECO considers that the ultrasonic flow instruments provide the necessary accuracy for pump performance trending purposes and to detect pump degradation. The above referenced pumps

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are not equipped with permanentplant instrumentationto measure flow rate. It would be a hardship withois a commensurateincrease in the level of quality and safety to require a system modification to install flow instrumentation that meets the accuracy requirements specified in the Code.

l l In summary, the proposed alternate method of measuring flow is sufficient because 1) an ultreonic l flowmeter calibrated to 15 % of- resding provides a level of accuracy comparable if not bener than analog instruments calibrated to Code requirements, and 2) it would be a significant hardship to modify the current l

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I design for the installation of permanent plant instrmnenratian to measure flow at the Code require accuracy.

h cosed Ahernate Teatino: Use ultrasonic flow instrm'=~ ion calibrated to an accuracy of within

+5 % . f - reading for measuring IST flow data.

3.1.1.1.2 Evaluation 'Ihe listed pumps do not have installed flow rate instruments, therefore, it is impractical to measure the pump flow rates using installed instruments. However, the flow rate can be measured using portable ultrasonic flow instruments. Use of these instruments should provide sumciently accurate and repeatable data to utilize in monitoring pump degradation. The burden on the licensee would not be justified by the limited information that would be provided se.iulug pump l mechanical condition if the Code requirements were l===A i

Since flow rate and dp (discharge pressure for positive displacemm . .nps)are used to evaluatepu hydraulic performance, accurate flow rate measurements are essential for IST. Excessive flow instrument l inaccuracy can result in measurements with a high level of uncertainty that can give either false indication of pump degradation or mask actual degradation. In cases where there is an excessive amount of l

measurement uncertainty, licensees frequently relax the acceptance criteria to reduce the number of false positive test results. Relaxing test acceptance criteria can further reduce the ability of the testing to detect l pump degradation, therefore, the appropriate corrective actions may not be taken prior to pump failure.

l The Code required instrument accuracy for flow instruments is 12 percent of the full-scale range. The l 15 percent accuracy of the proposed instruments does not meet the Code requirement, however, it is at least as accurate as a reading obtained from analog instruments that meet the Code requirements (i.e to 16 percent of the reference value, see Section 5.5.1 of NUREG-1482). Section 5.5.2 of NUREG-1482 states that the requirements of OM-6 should be applied to digital instruments. OM-6 requires digital instruments to be accurate to A2 percent of the reading over the calibraed range and for reference values not to exceed 70 percent of the calibrated range. The proposed alternative does not meet the guidance of the NUREG-1482 discussion.

The proposal to utilize ultrasonic instruments accurate to 15 percent of the indicated reading may provide measurements that are sufficiently repeatable to monitor pump condition and detect hydraulic degradation. However, insumcientinformation is provided in this reliefrequest for a detennination of the long term acceptability of this proposal, therefore, interim relief should be granted for one year or until the next refueling outage, whichever is longer. Long term relief could be granted in this type of situation if additional information is provided in the request. Tbc in-situ accuracy and repeatability of these instruments in each system application should be speci6ed. Procedures and controls should be established that permit measurements sumciently repeatable to allow detection of pump degradation. The request should also indicate if the flow measurements are sumciersly repeatable to use the Code allowable ranges

. or if expanded ranges are specified by the licensee.

'Ihe Code does not define or provide criteria for the repeatability ofIsr."=:m However, in situations where portable instrumentation is used, repeatability can be an important factor. If there is significant data scatter of the test measurements so the allowable ranges of the Code cannot be applied, it is questionable that the measurements are sufficiently repeatable to detect pump degradation.

Based on the determination that it is impracticalto meet the Code accuracy requirements for the pump flow rate instruments, the burden on the licensee if the Code requirements were immediately imposed, and since the proposed alternate testing should provide sumcient information to adequately monitor the hydraulic condition of these pumps during the interim period, interim relief should be granted in 6

accordance with 10 CFR 50.55a(f)(6)(1)from the Code instrn==='a'ionasw.cy requirements fo of one year or until the next refueling outage, whichever is longer. At the end of this period, the licen should test these pumps according to the Code requLs. or provide additional information the adequacy of their alternate testing methods.

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3.2 F=9rcv Service Water Evata=

3.2.1 Test Freauenev 3.2.1.1 Relief Request. Technical Position, TP-1, requests relief from the pumpstest faiw y requirements specified in Section ISTB, Para. 5.1, and proposes to test the following pumps ac the Code test method requirements (with the exception of NRC approved deviations)at least on when the river temperature is less than or equal to 53*F. -

Pump Description Identification ESW Booster Pumps OAP163 OBP163 3.2.1.1.1 Licenmee's nacie for Reauentino Relief--Pump testing under design conditions requ closing motor operated valve MO-330-498 which functions as the ESW return to Conowingo Pond isola valve. Closing this valve during power operation, with a subsequent failure to reopen, would render the ESW system inoperable. Testing shall be deferred to at least once each year when river temperature than or equal to 53*F. At this temperature, adequate heat removal is provided to the safety related equipment dependent upon ESW without reliance on the support of the ESW booster pumps when ES is aligned to the emergency heat sink. The deferral of testing this pump is acceptable per the discussio provided in NUREG 1482, Section 3.1.1.

The above pumps are included in the IST Program as Augmented components. As such, they do n perform a design basis safety related function. They are required to operate when aligned to the e heat sink during a

• Loss of Conowingo Pond" special event. The emergency heat sink has insufficient capacity to support continued operation for 30 days without makeup during post-accident conditions. In addition,neither the emergency heat sink nor any ofits associated components are credited in any de basis accident. Also, providing a reliable backup source of cooling water in the event both ESW p fail to achieve adequate discharge pressure would require failure of both ESW pumps, each of which hav 100% capacity to supply the heat load demands during post-accident conditions.

Pronomed AlternateTeetine Pumps and associated valves shall be tested at least once annually w ,

the river temperature is less than or equal to 53'F.

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3.2.1.1.2 Evalunt an--The referenced NUREG-1482, Section 3.1.1, addresses allowable extensions of testing intervals to cold shutdowns or refueling outages for valves. That section of the NUREG does not address the extension of pump testing frequencies nor does it address the annual test i frequency suggested for these pumps. Therefore, deferral of pump testing is not acceptable on that bas According to the Peach Bottom, Units 2 and 3, Technical Specifications, Limiting Conditions for Oper (LCO), 3.7.3, the emergency heat sink, which relies on the emergencyservice water booster pumps, m be Operable in Modes 1,2, and 3. Therefore,it appears that the emergency service water booster puml perform an active safety function and should be included in the IST program and be tested according to j

the Code test method and frequency requirements. The following evaluation treats TP-1 as a reliefreques i 7

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The licensee proposes to test these pumps once each year when the river temperature is below 537.

In that temperature condition, valve MO-0-33-0498, the emergency cooling water system discharge discharge pond (the alternate flow path) can be closed and ESW discharge routed to the ESW booster pumps and to the emergency cooling towers. Since the operability of both booster pumps cannot be relied upon because of the lack of required separation, failure of MO-0 33-0498 in the closed positim ditring testing could make the ESW system inoperable if the river temperature is above 537. This is because the ESW system cannot generate sufficient flow to the heat exchangers to provide the required cooling the river temperature is above 537 and flow is forced through the emergency cooling towers with the booster pumps not operating. Under these conditions, failure of this valve in the closed position d testing would render the system incapable of performing its safety function.

Since failure of MO 0-33 0498 in the closed position during testing could cause loss of ESW system function under the above Wntified conditions, this valve abould not be closed during those plant conditions. Ahhough the Code does not discuss once a year as an approved testing frequency, this test interval is more frequent than once each refueling outage and could be more frequent than the cold shutdown frequency. In addition, since this testing depends on certain climatic conditions, i.e., the river temperature being below 537, the once each year frequency could be scheduled during the cold months of the winter when the necesary conditions would be present. Requiring the licensee to test these pumps more frequently during extended periods when the river temperature remains below 537 would likely cause scheduling problems and would be an unreasonable burden to the licensee.

Based on the determination that it is impractical to shut valve MO-033-0498 and operate the ESW booster pumps quarterly during power operations when river temperature is above 537, the burden on the licensee of making system modifications to permit this testing, and considering that testing these pumps once a year when river temperature is below 537 should provide reasonable indication that the pumps are capable of performing their safety function, relief should be granted in accordance with 10 CFR j

50.55a(f)(6)(i) from the Code requirements as requested. However, TP-1 bases its justification on being in compliance with NUREG-1482, Section 3.1.1, which does not address pump testing or authorize or address the once a year test frequency. Further, TPs should not be used to obtain relief from the Code testing method or frequency requirements, therefore, TP-1 should be modified in the licensee's IST program to reflect the relief request evaluation.

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4. VALVE TESTING PROGRAM

'Ihe Peach Bottom Atomic Power Station, Units 2 and 3, IST program valve alief mquests submitted by PECO were examined to determine whether relief should be granted or alternatives authorized according to the requirements of 10 CFR 50.55a and NRC positions and gnid-e. Each PECO basis for requesting relief from the valve testing requirements and proposed alternative testing and the reviewer's j evaluation of that request is summarized below and grouped sca,id'ng to system and valve category.

l 4.1 All Systems 4.1.1 Cnntninment fanlatinn Valven 4.1.1.1 meliefRanneet General Valve ReliefRequest GVRR 3 requests to use ASME OM Code-1990 in lieu of the ASME Section XI, Division 1,1988 Addenda through 1989 Edition, which invokes the use of ASME/ANSIOMa-1988 Addenda to ASME/ANSIOM-1987 Parts 6 and 10 and ASME/ ANSI OM-i l

Part 1.

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4.1.1.1.1 Iicenmee's n ele for nennectine Relief--GVRR-3 is included in Appendix C as a means of documenting the alternate test plan to invoke the use of the 1990 ASME OM Code. It does not represent a deviation from the requirements of ASME OM-1990, Paragraph ISTC 4.3.2..

Pronoted Alternate Tectino: 10 CFR 50.55a(3) states that proposed alternatives to the requirements of paragraphs (c), (d), (c), (f), and (g) of 10CFR50.55a may be used if the applicant demonstrates that proposed alternatives would provide an acceptable level of quality and safety.10 CFR 50.55a(fX4Xii) requires that inservice tests must comply with the requirements in the latest edition and addenda of the l Code incorporated by reference in paragraph (b) of 10 CFR 50.55(a) Paragraph (b) currently references the use of the ASME Boiler and Pressure Vessel Code,Section XI, Division 1,1988 Addenda through the 1989 Edition. As an additional condition specified in 50.55a(b)(2 Xvii).When using SubsectionIWV of the 1988 Addenda through the 1989 Edition, leakage rates for Category A containment isolation valves that do not provide a reactor coolant system pressure isolation function must be analyzed in accordance with paragraph 4.2.2.3(e) of part 10, and corrective actions must be made in accordance with paragraph 4.2.2.3(f) of part 10 of ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987.

l PECO Energy Company proposes to use ASME OM Code-1990 in lieu of the ASME Section XI, i

' Division 1,1988 Addenda :hrough 1989 Edition, which invokes the use of ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987 Parts 6 and 10 and ASME/ ANSI OM-1987 Part 1.

ASME OM Code-1990 provides an acceptable level of quality and safety in that the requirements of OM-1990 are the same u in the ASME/ ANSI OMa-1988 Addenda. Additionally,use of ASME OM 1990 eliminates the additional conditions specified in 50.55a(bX2 Xvii) for leakage rate analysis and corrective action requirements for Category A containment isolation valves that do not provide a reactor coolant system pressure isolation function. Laakage of containment isolation valves is controlled by the PBAPS Primary Containment Laak Rate Test (PCLRT) Program. This program ensures that if a valve is identi6ed with excessive leakage, corrective actions are taken to ensure the leakage is maintained below the containment integrity limits specified by 10CFR50, Appendix J and the Tedate=1 Specifications.

The PBAPS PCLRT I'rogram include. owner specified accayaare criteria for individual valves and groups of valves. Corrective maintenance is initiated when the measured leakage rate exceeds the owner specified limit. As always, the operability of a valve or valve combination which exceeds the owner specified limit is evaluated in accordance with PECO Nuclear procedures.

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4.1.1.1.2 Evaluation -De licenseeproposes to use ASME OM Code-1990in lieu of the ASME Section XI, Division 1,1988 Addenda through 1989 Edition. OM Code-1990 invokes ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987 Parts 6 and 10 and ASME/ ANSI OM-1987 Part 1. The

' rewrite of the OM Code-1990 from the standards referenced in the 1989 Edition of Section XI did not l include any significant technical changes. nerefore, the testing provides an acceptable level of quality and safety and the alternate is authorized in accordance with 10 CFR 50.55a(a)(3)(i).

4.1.2 cantninment 1 nlatlan rwk valves 4.1.2.1 Relief Reaneet GVRR-4 requests relief from the test frequency requirements of Para. ISTC i 4.5 for the following Category A/C containment isolation check valves. The licensee proposes to verify i the closure capability of these valves during leak rate testing as part of their primary containment leak rate !

testing program. De licensee's test frequency for closure verifications not stated in the request, but would l be determined according to 10 CFR 50, Appendix J, Option B - Performance-Based Regia-.-..

CHK 2(3)06-028A, B CHK-2(3F07C-4(5)0144 CHK-2(3)-06-096A, B CHK-2(3F07C-4(5)0145 CHK-2(3F07C 4(5)0142 CHK-2(3F13C-50 CHK-2(3)-07C 4(5)0143 CHK-2(3F23C45 4.1.2.1.1 Licensee's Basic for Reauentine Relief.-These check valves perform a safety function in the closed direction as containment isolation valves. The only means available to exercise these check valves in the closed direction is by leak testing. PBAPS currently performs leak rate testing at the frequency allowed by Option B of 10 CFR 50 Appendix J. Reverse exercising these check valves by performing seat leakage testing at the frequency allowed by the Primary Containment Leak Rate Test (PCLRT) Program provides adequate assurance the valve is closing properly. In the absence of good performance history, Option B limits the test frequency to 30 months. Based on the current 2 year operating cycle, this would require testing at a 2 year frequency (valves are tested during refueling) which is the same frequency which would be invoked for these valves via a Refueling Outage Test Justification since reverse exercise testing requires the installation of test equipment. Performing seat leakage testing to satisfy reverse exercising requirements at a frequency greater than that required by the PBAPS (PCLR'!)

Program is burdensome without a commensurate increase in quality and safety.

Pronosed Alternate Tettine: Dese check valves will be exercised in the closed direction during the performance of leak rate testing in accordance with the frequency specifad by the PBAPS PCLRT Program.

4.1.2.1.2 Evaluatinn--Dese containment isolation check valves perform their safety function in the closed direction. Dey are Category A/C valves that are Type C leak-rate tested at a frequency determined according to Appendix J, to 10 CFR 50. These valves cannot be verifad in the closed position quarterly because they do not have remote position indication and are located inside reactor containment or in other inaccessible locations. These check valves lack design provisions for system testing to verify closure capability in any plant condition. Verification of valve closure involves installation of test instrumentation and performance of a seat leakage or reverse pressurization test.

The OM Code, Para. ISTC 4.5.2, requires quarterly exercising of check valves with certain exception and allows testing of check valves as infrequently as once each refueling outage based on impracticability.

De licensee requests to assess the reverse flow closure capability of these valves at the frequency allowed by Option B of 10 CFR 50, Appendix J, as an ahernative to exercising them according to the Code test frequency requirements.

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NUREG-1482, Section 4.1.4. Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by leak Testing, discusses the test frequency issue for these valves in detail. To summarize: leak rate testing verifies valve closure and provides more information about the closed position l than a simple backflow test. However, performing leak rate testing quarterly or during each cold shutdown i

may not be practical because the installation and removal of test equipment would remove needed systems from operation or delay plant stanup. OM Code, Section ISTC, recognizes the practicalities of performin testing during power operations and cold shutdown outages and Para. ISTC 4.5.2, allows testing to be performed during refueling outages for certain valves. The need to set up test M =^ is adequate i

justificationto defer backflow testing of a check valve until a refueling outage. If no other practical menna is available, it is aepe=ble to verify that check valves are capable of closing by performing leak-rate testhg, such as local leak rate testing in accordance with Appendix J to 10 CFR Part 50, at each reactor refueling outage. However, to justify an interval extension beyond the maximum allowed by Para. ISTC ,

4.5.2, either the basis for the impracticality of performing testing during each refueling outage must be ..

described or the proposed alternate testing should be shown to provide an equivalent level of quality and safety.

The ASME Code Committee recognizes the benefits of performance-based testing of check valves. A rer change included in the 1996 Addenda to the ASME OM Code-1995 incorporates Appendix D, Ches Valve Condition Monitoring Program, which allows changes to the test program based on corrvonent perfonnance. The current rulemaking for 10 CFR 50 will include the 1996 Addenda to the OM Code and govern its use. However, the ASME Code Committee has not approved the use of Option B of Appendix J as an alternative to quarterly exercising of check valves.

l To obtain relief from the Code requirements, the licensee must support one of the following i requirements: 1) the proposed alternative provides an acceptable level of quality and safety; 2) compliance with the specified requirements would result in a hardship or unusual difficul:y without a compensating increase in the level of quality and safety; and 3) the Code requirements are impractical.

l The ahernate testing according to Option B of Appendix J, while adequate for the required periodic assessment of containment isolation capability, has not been shown by the licensee to provide an adequate level of quality and safety when compared to the exercise frequency requirements of the OM Code. The licensee has not demonstrated that it is impractical to use a Code allowed method such as pressurization testing to verify that these valves close during each refueling outage. The licensee has not shown that the Code frequency requirements create an unusual or undue hardship. Therefore, relief should not be granted as requested.The licensee should verify the closure capability of these valves according to the OM Code test frequency requirements.

4.1.3 heese Flow f%ek Valven 4.1.3.1 Relief Reaueet GVRR-2 requests relief from the test frequency requirements of Para. ISTC 4.5 for all excess flow check valves in the IST program. The licensee proposes to functionally test these valves during refueling outages or during certain system outages.

4.1.3.1.1 Y le*a***'s n els for Reauestine Relief--Excess flow check valves (EFCV) are installed on instrument lines penetrating containment to minimi_* leakage in the event of an instrumentline failure outside the containment in accordance with Regulatory Guide 1.11, The EPCV is a spring loaded ball check valve. Since the system is normally in a static condition, the valve ball is feld opeu by the spring. Any sudden inercase in flow through the valve (i.e. line break) will result in a differential pressure across the valve which will overcome the spring and close the valve. Functional testing of valve closure 11

l l

! 1s accomplished by venting the instrument side of the valve while the process side is under pressure and veifying the absence ofleakage through the vent.

The testing described above would require the removal of the associatedinstrument or instruments from ,

service on a quanerly basis. Removal of any of these instruments from service outside of a scheduled l

l

' refueling outage or a controlled system outage may cause a spurious signal which could result in a plant I trip, an inadvenent initiation of a safety system, loss of decay beat removal and/or the defeating of safety i interlocks.

Testing of EFCVs can be performed during a refueling outage or a scheduled system outage when l appropriate plant administrativeprocedures and controls are utilized to ensure plant safety. System outags are performed in order to enhance system performance and maximize system availability. They are scheduled on a less than quarterly frequency (typically once an operating cycle). Scheduling system outages quanerly solely for the purpose of EFCV testing would result in reduced system availability and increased risk to the plant and personnel.

Personnel safety would decrease if EFCV testing would be performed on a quarterly basis during plara operation without an appropriate system outage. During power operation, the process side of the EFCVs is normally high pressure (>500 psig) and/or high temperature (>200*F) and exposed to highly contaminated reactor coolant. Testing EFCVs during system outage windows or refueling outages with the I appropriate administrative procedures and controls applied will ensure personnel safety. 1 In summary, considering the extremely low failure rate, personnel and plant safety concems, and the high monetary costs of quanerly testing, EFCV testing at a frequency greater than once per operating cycle  !

is impracticableand would result in unnecessary hardship without a compensating increase in the level of valve reliability and plant safety.

Pronoted AttemnteTectine- Functional testing will be performed once per operating cycle during a refueling outage or system outages when appropriate plant administrative controls are in place. j 4.1.3.1.2 Evaluntlan-These Category A/C check valves are eacess flow check valves on l instrument sensing lines that penetrate the primary containment. They are normally held open by spring pressure to transmit pressure signals to instruments. Their function is to close against excessive flow, such as that resulting from a line break, to limit leakage of reactor coolant and perform a containment isolation function. It is impractical to exercise these valves quanerly during power operation because that would require the venting of various instrument sensing lines. Many of these lines provide signals to reactor l instrumentation needed for reactor protection and control signals. I.oss of this reactor instrumentation l during power operation could result in a reactor trip. It is impractical to exercise these valves during cold shutdowns because removal of the associated instruments from service could disrupt or prevent operation of systems required for decay beat removal.

The OM Code requires that check valves be exercised nominally every three months (ISTC 4.5.1) with cenain exceptions. Paragraph!STC 4.5.2 allows deferral of testing from quanerly to each cold shutdown or each refueling outage. Issues related to excess flow check valves and this request are discussed in  ;

NUREG-1482, Section 4.144, NUREG/CR4396, Sectica 2.2.1(4), and in the Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756, Section 3.8. Many requests of this  ;

narme have bc:a to test these valves during refueling outages and are based on the impracticality of testTis '

qaanerly during power operation or during cold shutdowns.

12 l

l The licensee proposes to functionally test these valves once per operating cycle either during refueling outage or during certain system outages. The licensee states that these valves can be tested at power when their associated system is out of service for a scheduled snairwenance outage. De freq

! of testing for these valves would be similar to the refueling cycle length of twenty four months cur at Peach Bottom. His ahernate testing would be consistent with Technical Specification (TS) Surveillance Requirement 3.6.1.3.11 which requires that the operability of the EFCVs be verified at least once pe months. Both the TS and the IST program allow one-time 25 percent extensions of testing intervals.

However, if a particular testing interval had the pan-~ t Int o exceed the extended frequency, the licensee would be required to request an extension to the TS and IST frequencies and provide adequate basis for the extension. The licensee indicates that personnel and plant safety can be ensured while testing EFCV either during a refueling outage or during a scheduled system outage when appropriateplant maninistratiw procedures and controls are utilized. 1 De licensee provided additionaljustification relevant to this request in their submittals dated, August 9 September 5, and September 25,1995, and stated that current methods employed for testing these valves would increase the length of their refueling outage by approximately 1.5 - 2 days. His is because the

' instrument lines at Peach Bonom do not have test taps upstream of the EPCVs which would allow the attachment of an alternate pressure source to conduct closure testing throughout the entire refueling outag Without this configuration, the EFCVs can only be tested during refueling outages when the reactor vessel I is adequately pressurized. Dis occurs immediately after shutdown when the reactor is being depressunzed and during the reactor vessel hydrostatic test. De licensee stated that testing conducted during the hydrostatic test is on the critical path to the refueling outage schedule. Therefore, testing all EFCVs duri the refueling outage at Peach Bonom directly effects the length of the refueling outage.

The NRC responded to the licensee's request with a Safety Evaluation anached to a letter from NRC to the licensee, ReliefRequest GVRR-2, Revision 3 Peach Bottom Atomic Power Station, Units 2 and 3, l dated July 1,1996. In that letter the NRC advised the licensee to clearly identify the EFCVs that would be tested in systems out of service during power operation when the licensee's IST program was updated to the third ten-year interval. He NRC needs an adequate level of information (including the specific l

components to be considered) to fully assess a relief request and grant relief or authorize an alternative according to the requirements of 10 CFR 50.55a. Instead of specifically identifying additional valves that could be tested during system outages when the reactor is at power, the licensee has identified all EFCVs to be tested either during power operation or during system out of service outages. The proposed interval I between tests on these valves cannot be ascertained and assessed, i

l Based on the determination that the licensee has not provided sufficient information to grant relief or j authorize an alternative, relief should be denied.

4.1.4 Active Mannat tentatinn Valvet 4.1.4.1 Relief Reaucer GVRR-1 requests relief from the exercising frequency requirements of Para.

ISTC 4.2.1, for all active Category B manual isolation valves, and proposes to establish a full-stroke exercise frequency of once every 2 years for those active manual valves provided with remote position indication, and once ever 5 years for those active manual valves not provided with position indication.

4.1.4.1.1 1 te*maa's naeit for Reanectine Relief--These manual valves perform an active safety function as defined in the Scope ofISTC Para.1.1, and therefore require full-stroke exercising per the requirements of ISTC 4.2.1. However, due to the sl7nplicity of manual valve design, tim !.mited number of failure modes, and historical data from the second 10 year interval, full stroke exercising on a quarterly frequency is considered burdensome without a commensurate increase in the level of quality and safety.

13

l Additionally, the valves are located in a non harsh service envirnament making them less prone to degradation.

l Pranae.d Ahema'* T*=tia=: As an alternative to the testing resp.L of the Code, PBAPS proposes to establish a fWl-stroke exercise frequency of once every 2 years for those active manual valves provided with remote position indication, and once every 5 years for those active manual valves not provided with poskion indication. De proposed ahernate test frequency will provide adequate assurance l of valve operability without compromising plant adety.

4.1.4.1.2 Evaluntlan De Code of record does not differentiate between manual valves an other Category A and B valves with regard the exercising frequency. The Code requires that these valves be exercised quarterly if practical, or during cold shutdowns or refueling outages, when justified by the l licensee. No provisions are made in the Code for exercising active Category A and B valves at frequencies longer than once each refueling outage. Extending this frequency to once every 5 years for'some of these valves may not be justified by valve type, installation, and history. De licensee made general statements about historical data from the second 10 year interval and mentioned that these valves are located in a non-harsh service environment. However, the licensee did not provide specific information, such as a listing of the affected valves, the systems in which they are located, whether they have temote poskion indication or not, accessibilityof the valves, high radiation or other personnel harards near the valves, valve failure l history and the failure rate for similar valves at other facilities.

l l

As stated in the request, manual valves are of a simple design. Testing these valves is also generally l simple. De testing simply consists of the valve being manually cycled either open or closed and then being i

returned to its originalposition. These valves are generally relatively small in size and can be cycled in a short time once the necessary approvals are obtained and conditions are established.

To obtain relief from the Code requL ..sas, the licensee must support one of the following requirements: 1) the proposed ahernative provides an acceptable level of quality and safety; 2) compliance with the specified requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety; and 3) the Code requirements are impractical. Similarly, the 4 licensee mustjustify deferring exercising of these valves in accordance with OM Code Para. ISTC 4.2.2, l

' and document this in a cold shutdown justification (CSJ) or refueling outage justification (ROJ) as applicable.

The licensee has not provided sufficient information to support granting relief to test these Category l B, manual valves at 2 or 5 year intervals as requested. Therefore, relief should not be granted. The licensee i

should continue to test these valves at the frequency specified in the Code.

4.1.5 Pattive Mann=11mniatlan Valven 4.1.5.1 Relief Request. GVRR-5 requests relief from 6e remote position indication verification requirements of Para.1STC Table 3.6 1 for administrativelycontrolled Category B passive manual isolation valves and proposes not to perform remote position indication WN'M for these valves. -

l 4.1.5.1.1 i t~a 's maele for Renneetine Reliet Dese category B passive manual valves are installed in a safety related flow path and perform a passive safety function in the open position. However, they are administrative 1ycontrolled in their safety related position by maintaining them in the locked open position and are prevened from closure during all plant operating conditions when the associated system is required to be operable. The valves are considered maintenance valves and are placed in the closed position to either facilitate seat leakage testing of upwdiri containment isolation valves or to perform 14

system maintenance wkhout draining down reactor vessel water level. When opened, s -

system alignment procedures ensure the valves are properly positioned with locks reapplied.

Pronnand Alternate Testine: Remote poshion indicarian verification will not be performed o category B passive manual valves identified above.

4.1.5.1.2 Evaluatin>SubsectionlSTC 4.1 states that " Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve positionM.is. . accurately

." i The purpose of the Code requirement is to ensure that if a valve has remote position indicatio indicationwill accurately reflect the valve's position. The fact that a valve is passive an I

i controlled in its safety position during all plant operating conditions when the associated sys to be operable, does not ensure that the remote position indication of that valve will never be obser believed to accurately reflect the valve's position. Since, the position indication may at come time to determine valve position, never verifying ks accuracy may resuk in k providing an erroneous indic Even though this may not occur during plant power operation, when mitigating the conseq an accident, and bringing the plant to the safe shutdown condition; k may occur during post accide recovery operations while maintaining the plant in the safe shutdown condition. Therefore, relief abould not be granted as requested from the valve position indication verification rig,s. of the Code.

4.1.6 Ranid-Actino Valves 4.1.6.1 Relief Reanect. GVRR 6 requests relief from the valve stroke timing requirements of Para.

ISTC 4.2.8(d), for all Category A and B rapid acting valves in the IST program and propose maximum stroke time of 5 seconds or for valves that stroke in 5 seconds or close the reference stroke time to these valves. '

4.1.6.1.1 1 leentee's Basie far Reaucerine Relief-For rapid actuating power operated valves, I PBAPS proposes to utiliu a maximum limiting stroke time of 5 seconds in lieu of the 2 second criteria; specified in ISTC 4.2.8(e). These valves generally are small air and solenoid operated valves whic because of their size and actuator types, stroke very quickly. Operating history on this type of v indicates that they generally either operate immediately or fall to operate. The intent of the referenced testing requirement is to trend valve stroke time as a means of detecting valve degradation. Due to huma response time variations, comparkon of stroke times to a reference stroke time or utilizing the maximum limiting stroke time of 2 seconds could lead to declaring a valve inoperable when it is function Assigning a maximum limiting stroke time of 5 seconds to power operated valves which stroke in <5 seconds or utilizing the accepraae* criteria specified in ISTC 4.2.g(d) for those rapid acting valves which normally stroke close to 5 seconds provides adequate assurance that valve degradation will be detscsed prior to hs inability to accomplish its design safety fhmetion.

PronnaM Altemate Testine A maximum limiting stroke time of 5 see will be specified for each actuating power operated valve. If the valve strokes in 5 sec or less, k will be considered aca prahle no corrective action will be required. lf the valve exceeds 5 seconds, .w.d4 corrective action will be taken. For those power operated valve which stroke at or close to the 5 second limit, PBAPS ma the Etcey= e criteria specified in Para. ISTC 4.2.g(d), which allows not more than 3,505 change in stroke time when compared to a reference value. '

4.1.6.1.2 Evainatin%'Ihe OM Code exempts power operated valves . hat stroke in less than 2 seconds from the stroke time ace prane* criteria requirements of Para. ISTC 4.2.8(d), provided the licensee assigns a maximumlimiting stroke time of 2 seconds to these valves. These valves are generally referred 15

to as rapid acting. NRC Oeneric letter 8904. Position 6, and NUREG-1482, 4.2.2, Stroke Time Measurements for Rapid-Acting Valves, both discuss issues and staff positions related to rapid-acting vdm. ,

De licensee proposes to assign a maximum limiting stroke time of 5 seconds to power-operated valves l that stroke in 5 see or less. The valves will be considered acceptable if their stroke times are less than 5 seconds and corrective actions will be taken if the stroke time exceeds 5 seconds. For valves with stroke times at or close to 5 seconds, the licensee may apply the eccy =+ criteria of the Para. ISTC 4.2.8(d),

which is based on a comparison of the stroke time with a reference value.

l Much of the recent thinking on the topic of rapid-acting valves has been that L.yws.J timing techniques may allow better analysis and trending of stroke times. NUREG-1482, Section 4.2.2, Stroke Time Measurements for Rapid-Acting Valves, discusses this topic in depth. De following discussion is excerpted from that section. ~

r

• New technologies and new applications of existing technologies enable licensees to time the strokes of rapid-acting valves with accuracy measured in milliseconds, though the Code does not require such l accuracy. Using new technology, the licensee could establish an appropriate limh based on a multiple of l

l a reference value to ensure corrective actions are taken if degrading conditions are evidenced." j i

j "The traditional method of stroke timing power-operated valves wu to use stopwatches to measure the stroke time from initiation of the signal at the handswitch to the change in position-indicatinglights (switch to light). The traditional method includes signal processing time from the switch to the valve actuator.

Monitoring stroke times for valves that stroke in milliseconds using the diagnostic equipment that measures only actual valve travel is acceptable for indicating degrading trends; however, the method does not ,

indicate increases that could occur in the signal to the valve, which may be important in meeting safety  !

analysis limits for certain valves. Typically, the valves that would benefit from this monitoring are rapid-l acting valves. De traditional method would have a set limit of 2 seconds which masks any signal l

processing time unless a gross change occurs. If measuring the stroke times locally needs to be supplemented by a periodic test to include the signal processing times, a periodic 2-second limit test could be performed to augment the IST. The code does not specify a particular method, so there would be no l conflict in using more than one method."

t i The NRC recommends that, "Although the licensee is not required to do so by the Code, if a licensee uses new technology for stroke-time measurements of rapid acting valves, the staff recommends that the licensee determine if continued reliance on the 2-second acceptance criterion of Position 6 of GL 89 04 or Para. 4.2.1.8(e)of OM-10 is approprise when actual stroke times are measured to within milliseconds."

The requirements of Para. 4.2.1.8(e) of OM-10 are equivalent to those of Para. ISTC 4.2.8(d). De proposal to adopt a 5 second acceptance criteria has not been shown to be justified for the specific valves covered by this proposal.

To obtain relief from the Code requirements, the licensee must support one of the following requirements: 1) the proposed alternative provides an acceptable level of quality arid safety; 2) compliance with the specified requirements would resuk in a hardship or unusual difficulty without a compensating increase in the level of quality and safety; and 3) the Code requirements are impractical.

The licensee has not shown that the proposed ahernative provides an acceptable level of quality and safety, compliance with the specified requirements would asult in a hardship or unusual difficulty without a compensating increase in the level of quality and safety; or the Code requirements are impractical to 16

support granting relief or authorizing an alternative as required by 10 CFR 50.55a. Derefore, relief a not be grarued or the alternative authorized as requested.

4.2 control Rad Drive Hvdraulie t;==

4.2.1 cateenev B Valves 4.2.1.1 Relief Rean**'.

03A-VRR-1 requests relief from exercising and stroke timing valves CV-2(3) 03-13126AA through HC and CV-2(3)-03-13127AA through HC, contro' rod scram inlet and outlet, in accordance with the requisias;. of Para. ISTC 4.2.1 and proposed to verify proper va operation during the performance ofindividual control rod scram insertion testing in accordan Technical Specirentiana.

l 4.2.1.1.1 Ileennee's Anele for Rennectine Retter-These valves are located on the hydraulic control units for the control rod drives, whose function is to rapidly insert the control rods on a signa the reactor protection system for reactor scram initiation. The proper functioning of these valves as a un is most practically verified by performing an actual scram test' and measuring control rod insertion tim i Pronosed Alternn'* Testine: The control rod scram insertion time testing required by Technical Specification 3.1.4 will be performed in lieu of the OM Code required testing.

l 4.2.1.1.2 Evaluatinn-The NRC staff position on exercising these valves and measuring their full-stroke times is contained in Generic Letter 89 04, Attachment 1. Item 7. The Generic Letter states: ".

for those control rod drive system valves where testing could result in the rapid insertion of one or more control rods, the rod scram test frequency identified in the facility TS may be used as the valve tes i

frequency to =Inimin rapid reactivity transients and wear of the control rod drive mechanisms.' The Generic Letter further states: 'The scram inlet and outlet valves are power operated valves that full-stroke in milliseconds and are not equipped with indication for both positions, therefore, measuring their full stroke time as required by the Code may be impractical Verifying that the associated control rod meets the scram insertion time limits dermed in the plant TS can be an acceptable alternate method of degradation of these valves. Also, trending the stroke times of these valves may be impractical and unnecessary since they are indirectly stroke timed and no meaningful correlation between the scram time and valve stroke time may be obtained, and furthermore, conservative limits are placed on the control rod scram insertion times. If the above test is used to verify the operability of scram inlet and outlet valves, it should be specifically documented in the IST program."

The licensee's proposed testing is in accordance with Generic letter 89 04, Atenehment 1. Item 7 therefore, reliefis granted.

l 4.2.2 entannrv c Valves 4.2.2.1 Relief Reaueet. 03A-VRR-1 requests relief from exercising valves CHK-2(3) 03-13114AA through HC, control rod scram discharge header checks, in accordance with the requirements of Para.

ISTC 4.5 and proposed to full-stroke them during control rod scram testing.

4.2.2.1.1 i tran=a.'s Anele for Reonettine Relief-These valves are located on the hydraulic control units for the control rod drives, whose function is to rapidly insert the comrol rods on a signal from the reactor protection system for reactor scram initiation. The proper functioning of these valves as a unit i

is most practically verified by performing an actual scram test and measuring control rod insertion times.

17

_ - _ - - --- - - - - - -~

Pronosed Alternate Testing: The control rod scram insertion time testing required by Te Specification 3.1.4 will be performed in lieu of the OM Code required testing.

4.2.2.1.2 Evaluntlan-De NRC staff position on exercising control rod drive system valves is contained in Generic 1.etter 89 04, Attachnent 1. Item 7. The Generic lener states: "... for thos rod drive system valves where testing could result in the rapid insertion of one or more contr rod scram test frequency identified in the facility TS may be used as the valve testing fre minimie rapid reactivity transler.ts and wear of the control rod drive merhanieme. This alternat frequency should be clearly stated and documented in the IST program."

The licensee's proposed testing is in accordance with Generic Letter 89-04, Artnehmen therefore, reliefis granted.

4.3 Residunt Heat Remnvn1 Svetem 4.3.1 Categorv C Valves 4.3.1.1 Relief Rennest 10VRR-1 requests relief from the exercising method and frequency requirements of Para.1STC 4.5 for CHK-2(3)-10-183A,-183B,-184A, and -1848, residual beat re (RHR)/ low pressure coolant injection (LPCI) stay fill supply check valves and proposes to test th pairs to verify closure capability during refueling outages.

4.3.1.1.1 Ucemee's Basis for Reauestine Relief-The above stay-fill check valves are installed in pairs (series arrangements) with no provisions for individual valve testing (i.e. CHK-10-183 a CHK-10-184 are in series). The valves funt tion, in series as a pair, to prevent loss of RHR the stay-fill system in the event of a stay-fill system failure and to maintain the discharge piping system in a filled condition to prevent water hammer upon system initiation as required by Techn Specification 3.5.1. Although, only one valve is required by design to provide isolation c these valves as a pair is preferable to valve disassembly and inspection. Therefore, both valves i shall be included in the IST Program as directed in NUREG-1482 Section 4.1.1. The onl closure of these valves is by performing a leak or pressurization test. Both methods require the in of test equipment. Testing these valves during power operation would render the stay fill s inoperable, requiring entry into the associated limiting condition for operation (LCO). Testing t during cold shutdown could delay plant restart due to the necessity of utilizing temporary tes Proposed AfternateTesting: Valves will be tested as a pair in the reverse direction during outages. Both valves in the pair will be considered inoperable if testing indicates the valves do not close on reverse flow.

4.3.1.1.2 Evntuntion--These stay fill valves are simple check valves without remote or other extemalindication of disk position. These valves are installed as pairs in a series arrangement with n connections between the valve pairs to permit leak testing of each valve. They perform a safety in the closed position to prevent diversion of injection flow away from the reactor vessel. Onl in each of these stay-fill series check valve pairs is required to perform the closed safety fun preventing diversion ofirdection flow away from the reacter coolant system (RCS). De license relief from both the test method and frequency requirements of the Code and proposes to test each check valve combination as a pair each refueling outage and to declare both valves inoperab testing indicates that the pair does not close on reverse flow. This tening does not provide indication condition of each va've, however, it does provide positive indication that at least one valve in th capable of performing the closed safety function.

18

The OM Code, Para. ISTC 4.5.2, requires quarterly exercising of check valves with certain evaph and allows testing of check valves as infrequentlyas once each refueling outage based on knpracticability.

The subject valves can be exercised closed during quarterly RHR pump testing, however, the system design l

makes it impractical to verify closure by leak testing or observing a differentia! ressure P across each valve.

i Test taps wodd have to be installed to permit individual leak testing to verify their reverse flow closure l individually at any frequency. Requiring the licennae to make these system modifk:ations would be l burdensome and could reduce system reliability.

NUREG-1482, Section 4.1.1, addresses closure verification for series check valves without l

i intermediate test taps, including those in stay-fill (or keep-fill) systems. The NUREG states in part, " Keep.

fill valves are a special case in that thej are redundant valves in redundant systems in which only one valve of a series is actually weemaary to perform a system's intended function. Licensees have proposed to exclude the upstream valve f:om the IST program. However, recognizing that neither valve-can be .

individually demonstrated to shut, the NRC previously determined for the alternative test method diarnaasd l

in this section that both valves must be included in the IST program and operationally tested as a pair to prevent reverse flow. The NRC specified that, upon observing leakage, the licensee diansmemble, inspect, l and repair or replace both valvec as =e*===ry before the return to service."

The licensee's proposed testing and frequency gives reasonable assurance of the operational readiness of each check valve pair, is in accordance with the NUREG guidance, and provides an acceptable alternative to the Code test method and frequency requirements. If testing indica " that the closure l capability of the pair of valves is questionable, both valves will be declared inoperaR. and repaired or replaced before being returned to service Based on the determination that it is impractical to individuallyverify the reverse flow closure of these valves, the burden on the licensee of making system modifications to permit this testing, and considering that leak testing these stay-fill series check valves as a pair should provide reasonable indication that the i

' pair is capable of perfonning its safety function in the closed position, relief abould be granted in accordance with 10 CFR 50.55a(fX6Xi) from the Code requirements as requested.

4,4 Fmereenev Service Water Evntem 4.4.1 f'ateeorv B Valves 4.4.1.1 Ralismagung. 33-VRR-1 requests relief from the exercising frequency requ' n ,.wu of Para.

ISTC 4.2.1 for the einergency service water (ESW) isolation return valve to normal heat sink, MO-0 33-

• 0498, and propeses to full stroke exercise and stroke time k annually when river temperature it less than or equal to $3'F.

4.4.1.1.1 I Icemee's kaalt for Remientine Relief-The function of this valve is to isolate the ESW System discharge to create a closed loop system for emergency heat sink operatien. MO 0 33 0498 is the only power operated valve in the ESW system single discharge line to the Conowingo Pond. When the valve is in the fMI open position, the ESW system is aligned in its normal configuration and is i

OPERABLE. When MO 0 33 0498 is closed, an ESW pump and a booster pump are started providing the required flows to all safety.related equipment served by ESW. However, the ESW booster pumps do not meet separatien criteria requirements and cannot be relied upon to support the ESW pumps in maintaining system design fbw rates to safety related equipment served by the ESW system in the event of a design basis axident. Failure of MO 033 0498 in the closed position could result in flow rates to components served by ESW to fall below theit design values. Exercising this valve to the closed position during power operation, with a subsequent failure to reopen, would render the ESW system inoperable. Testing shall be 19

s deferred to at least once each year when river temperature is less than or equal to 53'F (PECO Calculation PM-0989). At this temperature, adequate heat removal is provided to the safety related equipment dependent upon ESW without reliance on the support of the ESW booster pumps when ESW is aligned to the emergency heat sink. *Ihe deferral of testing this valve is acceptable per the discussion provided in NUREG-1482, Section 3.1.1.

l l Pmnoted Altemate Teerlan: MO 0-33 0493 aball be fbli stroke exercised tested and stroke timed annum 11y when river temperature is less than or equal to 53 degrees F.

4.4.1.1.2 Evaluation-NUREG 1482, Section 3.1.1 states: " Exercising valves at each cold shutdown outage is not a deviation from the Code and does not require a relief request. Testing at each refueling outage is a deviation from requ's In Subsection IWV of Section XI, but is an allowable deferral of the testing required by OM 10. The Code specifies testing at cold shutdowns ifit is impractied to test quarterly during operation. OM-10 specifies full-stroke exercising at each refueling outage if testirg is impracticalboth quarterly while in operation and during cold shutdown outages. The Code (IWV-3412, IWV-3522, and OM-10, paragraph 6.2) requires the valves for which testing is deferred be identified and the basis for determining impracticality be documented in the inservice testing (IST) program. The licensee may implement the portions of OM-10 which allow deferral of the testing in accordance with 10 CFR 50.55a(f)(4)(iv)... '!herefore, although reliefis not required, this section must be referenced in the IST program...."

As can ba seen from this discussion, this section of the NUREG deals with exercising at cold shutdowns or refueling outages when testing is impractical quarterly during power operations.The NUREG section referenced in the licensee's relief reques' basis does not authorize testing at alternate frequencies other than cold shutdowns or refueling outages. The licensee's proposal to exercise this valve at a frequency of once each year when the river temperature is below 53'F may be justified, however, the NUREG-1482 discussion does not justify deferring valve testing to once each year as stated by the licensee.

Valve MO-0-33-0498 is on the emergency cooling water system discharge to the discharge pond. The valve is normally open to allow flow to the pond. When the valve is closed the ESW discharge is routed to the ESW booster pumps and to the emergency cooling towers. Since the operability 'of both booster pumps cannot be relied upon because of the lack of required separation, failure of MO-0-33 0498 in the closed position during testing could make the ESW system inoperable if the ri er temperature is above 53'F. This is because the ESW system cannot generate sufficient flow to the heat exchangers to provide the required cooling when the river temperature is above 53'F and flow is forced through the emergency cooling towers with the booster pumps not operating. Under these conditions, failure of this valve in the closed position during testing would render the system incapable of performing its safety function.

The NRC issued guidance in leners to licensees in 1976 which included examples of valves to be specifically excluded from exercising (cycling) tests during plant operations. One of the examples included .

in the correspondences: " valves whose failure in a norwonservativeposition during the cycling test would cause a loss of system function. Valves in this category would typically include all non-redundant valves in lines such as a single discharge line from the refueling water storage tank or accumulatordischarge lines in pressurized-waterreactors (PWRs) and the high-pressure coolant in$ection (HPCI) turbine steam supply and the HPCI pump discharge in boiling-water reactors (BWRs). Other valves may fall into this category under certain system configurations or plant operating modes. For example, when one train of a redundart system such as an emergency core cooling system (ECCS) is inoperable, non-redundant valves in the t remaining train should not be cycled since their failure would cause a loss of total system function."

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o Since failure of MO 0 33 0498 in the closed position durirs testing could cause loss of ESW system function under the above identified conditions, this valve should not be exercised closed during those plant conditions. Although the Code does not discuss once a year as an .yywved testing frequency, this test interval is more frequent than once each refueling outage and could be more frequent than the cold shutdown frequency. In addition, since this testing dep ade on certain climatic conditions, i.e., the river temperanre being below 537, the once each year frequency could be scheduled during the cold months of the winter when the -==y conditions would be present. Requiag the licensee to test this valve more frequently during extended periods when the river temperature remains below 537 would result in scheduling problems and would be an unreasonable burden to the lleen=*.

Based on the determination that it is impractical to exercise valve MO4 33 0498 closed rio.mly during power operations when river temperature is above 537, the burden on the licensee of makirg system modifications to permit this testing, and considering that exercising this valve once a year when -

river temperature is below $37 should provide reasonable indication that the valve is capable of performing its safety fbaction in the closed position, relief should be granted in accordance with 10 CFR 50.55a(f)(6)(i)from the Code requirements as rq=='ed. However, request 33-VRR-1 bases its justificatie on being in compliarce with NUREG-1482, Section 3.1.1, which does not authorize or address the once a year test frequency. The licensee should delete the reference to NUREU- 1482, Section 3.1.1, in this relief request to correct this discrepancy.

4.4.1.2 Relief Rennect 33-VRR-2 requests relief from the stroke timing ace pe==* requirements of Para. ISTC 4.2.8 for ESW cooling water flow isolation to the diesel generator air cooler jacket water cooler and lube oil cooler valves, AO-0 33-0241 A, 0241B,-0241C,-0241D, and propc,ses not to compare measured stroke times to the initial reference values and apply the stroke time acceptance criteria specifed in Para. ISTC 4.2.8, but instead to establish limiting values of stroke time in accordance with Para. ISTC 4.2.4 and to perform corrective actions according to Para. ISTC 4.2.9(a). -

4.4.1.2.1 Licenta,'s natic for Reauentine Relief--The Amction of these air operated valves is to isolate the ESW cooling water flow to the diesel generator air cooler, Jacket water cooler, and lube oil cooler and must open to allow flow. These air operated valves are provided with == hanical stops to allow

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adjustment of stroke length. The valve stroke lengths are adjusted, or flow balance verified, at a frequency j of at least once every 6 weeks as river temperature changes to ensure the proper amount of cooling flow is provided to each diesel generator. Frequent flow balancing is performed as a result of commitments made in response to GL 89-13. This activity results in frequent failuras to meet the ace p'==> criteria specified in ISTC 4.2.8 and thus requires subsequent corrective action per the requirements of ISTC 4.2.9(b). Due to the level of test activity associated with these valves, degradation would be detected I without applying the stroke time acceptance criteria specified in ISTC 4.2.8. In addidon, although not considered skid mounted, the valves are also verifad to be functioning properly by virtue of satisfactory diesel generator testing.

l Pronoted Alternate Testine: Limiting values of stroke time shall be established in accordance with ISTC 4.2.4 and corrective actions shall be performed in accordance with ISTC 4.2.9(a). The stroke time '

aca peaaae criteria specified in ISTC 4.2.8 shall not be applied.

l 4.4.1.2.2 Exahiatino These 6 inch, Category B, air operated globe valves open to direct ESW cooling flow to the diesel generator air cooler, Jacket water cooler, and tube oil cooler. The licensee regululy adjusts the stroke length of these valves to compensate for chan,3es in river temperature (coolant tempert ture).This also changes the valve stroke times, which can result in failure to meet the asy=Es '

,;riteria specified in Para. ISTC 4.2.8 and necessitate corrective actions according to Para. ISTC 4.2.9(b).  ;

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OM Code, Para. ISTC 4.2.8, provides stroke time acceptance criteria for comparison with reference values of stroke times for power operated valves. Para. ISTC 4.2.9 states requirements for corrective actions. Additionalreference values may be established according to the requirements of Para. ISTC 3.5.

De licensee proposes not to compare measured stroke times to the initial reference values and apply the stroke time acceptance criteria specified in Para. ISTC 4.2.8, but instead to establish limiting values of stroke time in accordance with Para. ISTC 4.2.4 and to perform corrective actions according to Para. ISTC 4.2.9(a). The licensee indicates that due to the level of test activity associated with these valves, degradation would be detected without applying the stroke time acceptance criteria specified in .* ara. ISTC 4.2.8 and that the valves are also verified to be functioning properly by virtue of satisfactory diesel generator testing.

Changes 5 the measured stroke time from the reference value(s) can indicate valve degradation. He combination of reference values and stroke time acceptance criteria of Parc. ISTC 4.2.8 helps to ensure -

that appropriate corrective actions are taken when the performance of a power-operated valve degrades significantly. De limiting value of stroke time of Para. ISTC 4.2.4(a) is an absolute criteria. De Code, Para. ISTC 3.5, allows for the establishment of multiple reference values. Multiple reference values might be suitable, for example, if test conditions could impact the reference stroke time. This could be the result of changing pressure or flow in a system, or as in this case, a change in the valve's stroke length.

Shortening a valve's stroke length should shonen the valve's stroke time, thus making the acceptance criteria based on a longer stroke time non-conservative. Degraded operation that may be detected via comparison of the measured stroke time to the initial reference value might not be detected.

The licensee's proposal may identify degradation or failure of these valves by visual observation when adjusting the mechanical stops or by seeing excessive temperature on cooled components and thus provides a reasonable interim alternative to the Code for the shon term. However, it hss not been shown by the information furnished to provide an acceptable level of quality and safety when considered as a long term alternative to the Code requirements. Immediate compliance with the Code acceptance criteria requirements for these valves is impractical since it may result in unneeded maintenance or repair. However, the licensee has not shown that compliance with the requirements is impractical in the long term. De licensee should consider the provision of the Code Para. ISTC 3.5 to establish multiple reference values so that there is objective criteria to assist in identifying degradation and help to assess the operational readiness of these valves. Alternately, the licensee might provide details related to the adjustment of stroke length that demonstrate the adequacy of their process to suppon the granting of relief or authorization of an altematiw according to 10 CFR 50.55a.

To obtain relief from the Code requirements, the licensee must suppon one of the following requirements: 1) the proposed alternative provides an acceptablelevel of quality and safety; 2) compliance with the specified requiremen:s would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety; and 3) the Code requirements are impractical, ne licensee has not shown that their proposed alternative provides an acceptable level of quality and safety, compliance with the specified requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety; or the Code requirements are impractical to suppon granting relief or authorizing an alternative as required by 10 CFR 50.55a for the long term.

Immediate compliance with the Code acceptance criteria requirements for these valves is impractical since it may result in unneeded maintenance or repair. Additionally, the constant attention given these valves should allow detection of degradation during the interim period. Derefore, interim relief should be granted in accordance with 10 CFR 50.55a(f)(6)(1) for a period of one year or until the next refueling outage, whicheveris longer. At the end of that period, the licensee should test these valves in accordance with the Code requirements or justify an altemate method.

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o 4.4.2 Categorv C Valves 4.4.2.1 Relief Request. TP-1 was submitted as a Technical Position to support deferring the testing of pumps and valves stated to be " Augmented components" until once each year. However, since the LCO in Section B 3.7.3 of the PBAPS Technical Specificationsstates that the " emergency heat sink is required to provide the minimum heat removal capability for the ESW and HPSW Systems to safely shutdown both units," k appears that credit must be taken for the operational readiness of some of the components listed in TP-1. In addition, since the proposed once annually test frequency is not an approved test frequency in either the Code or NUREG-1482, reliefis necessary from the Code test freqwsy requirements for these components. Derefore, the decision was made to evaluate TP-1 as a relief request. His section deals specifically with the ESW booster pump discharge check valves, CHK 048-504A and -504B. Relief is being evaluated from the exercising frequency requirements of Para. ISTC 4.5.1 for these valves. De licensee proposes to full stroke exercise them annually when river temperature is less than or equal to 537.

4.4.2.1.1 I icensee's n==le for Reauettine Relief--Pump testing under design conditions requires closing motor operated valve MO-0-330498 which functions as the ESW return to Conowingo Pond isolation valve. Closing this valve during power operation, with a subsequent failure to reopen, would render the ESW system inoperable. Testing shall be deferred to at least once each year when riser temperature is less than or equal to 53'F. At this temperature, adequate heat removal is provided to the safety related equipment dependent upon ESW without reliance on the support of the ESW booster pumps when ESW is aligned to the emergency heat sink. De deferral of testing this pump is acceptable per the discussion provided in NUREG-1482, Section 3.1.1.

The above pumps are included in the IST Program as Augmented cei=r=nts. As such, they do not perform a design basis safety related function. They are required to operate when aligned to the emergency beat sink during a " Loss of Conowingo Pond" special event. The emergency heat sink has insufficient capacity to support continued operation for 30 days without makeup during post-accident conditions. In addition, neither the emergency heat sink nor any of its associated components are credited in any design basis accident. Also, providing a reliable backup source of cooling water in the event both ESW pumps fail to achieve adequate discharge pressure would require failure of both ESW pumps, each of which have 100% capacity to supply the heat load demands during post accident conditions.

Pronosed Alternate Testine Pumps and associated valves shall be tested at least once annually when river temperature is less than or equal to 537.

4.4.2.1.2 EvaluatiowValve MOM-0498 is on the emergency cooling water system discharge to the discharge pond. De valve is normally open to allow flow to the pond. When the valve is closed the ESW discharge is routed to the ESW booster pumps and to the emergency cooling towers. MM33 0498 must be closed to provide a suction supply to the ESW booster pumps to allow them to be operated to provide flow to exercise the ESW booster pump discharge check valves, CHK4 48-504A and -504B, to their open position. As discussed in TP-1, failure of MO 0 33 0498 in the closed position during this testig could make the ESW system inoperable, ne NRC issued guidance in leners to licensees in 1976 which included examples of valves to be specifically excluded from exercising (cycling) tests during plant operations. One of the examples included in these correspondence is: " valves whose failure in a norsonservative position during the cycling test would cause a loss of system function." Section 4.4.1.1 of this report demonstrates that closing valve MO 0 334498 during power operations when river temperature is above 537 can result in loss of function of the ESW system and that this should not be performed for routine testing. j l

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O Since failure of MO433-0498 in the closed position during testing could cause loss of ESW system function under the above identified conditions, this valve should not be closed during those plant condition to allow testing of valves CHK 048-504A and -504B. Although the Code does not discuss once a year as an approved testing frequency, this test intervalis more frequent than asce each refueling outage and could be more frequent than the cold shutdown frequency. In addition, since this testing depends on certain climatic conditions, i.e., the river temperature being below 537, the once each year frequency could be scheduled during the cold months of the winter when the necessary conditions would be present. Requirirs the licensee to test these valves more frequently during extended periods when the river temperature remains below 537 would result in scheduling problems and would be an unreasonable burden to the licensee.

Based on the determination that it is impractical to exercise valves CHK 0 48-504A and -504B open quarterly during power operations or during each cold shutdown when river Wsture is above 537, .

the burden on the licensee of making system modifications to permit this testing, and considering that' exercising them once a year when river temperature is below $37 should provide reasonable indication that they are capable of performing their safety function in the open and closed positions, relief should be granted in accordance with 10 CFR 50.55a(f)(6)(1)from the Code requirements for these valves. However, in subsequent program submittals, a relief request should be submitted for these valves. In addition, NUREG-1482, Section 3.1.1, does not authorize or address deferring valve testing to the once a year test frequency, therefore, this NUREG section should not be used as a basis for relief for these valves.

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APPENDIX A IST PROGRAM ANOMAUES IDENTIMED DURING THE REVIEW I

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l APPENDIX A IST PROGRAM ANOMALIES IDENTHED DURING THE REVIEW l

Inconsistencies and omissions in the licensee's program noted during the course of this review are summarized below. The licensee abould resolve these items in accordance with the evaluations, conclusions, and guidelines p. sa.d in this report.

1.

The licensee submitted GPRR-1 (see section 3.1.1.1 of this repon) for the listed diesel fbel oil transfer, i

emergency service water booster, and the emergency cooling water pumps. The licensee proposes to use ultrasonic instruments with an accumey of plus or minus 5 % of reading in lieu of the code accuracy requirements. Use of these instruments abould provide sufficiently accurate and repeatable data to

' utilize in monitoring pump degradation. The burden on the licensee would not be justifed by the limited information that would be provided concerning pump mechanical caaMan if the~ Code requirements were imposed. However, the licensee has not provided information on the pumps, pump l test circuits, test flow rates, or the test mstrument installation process to allow a thorough evaluation of the request Interim relief should be granted from the Code instrumentation accuracy requirements for a period of one year or until the next refueling outage, whichever is longer.

2. TP 1 (see section 3.2.1.1 of this repon) requests relief from the pump test frequency requirements i

specified for the ESW Booster Pumps and proposes to test them once each year when the river temperature is less than or equal to 53*F. Relief should be granted from the Code requirements as requested. However, TP-1 bases its justification on guidance in NUREG 1482, Section 3.1.1, which does not address pump testing or authoriu or address the once a year test frequency. Funher, TPs i

should not be used to obtain relief from the Code testing method or frequency requirements. TP-1 should be modified in the licensee's IST program to reflect the relief request evaluation.

3. The licensee submitted GVRR-1 (see section 4.1.4.1 of this repon) for deferring the exercising frequency of certain Category S active manual isolation valves without remote position indication. The licensee proposes to exercise these valves once every five years, which may not be justified by valve type, installation, and history. & licensee made general statements about historical data, however, did not provide specific information, such as a listing of the affected valves, the sysems in which they are located, whether they have remote position indication or not, accessibility o. the valves, high radiation or other personnel hazards near the valves, valve failure history and the failure rate for similar valves at other facilities. As stated in the request, manual valves are of a simple design. Testh1g these valves is also generally simple. & licensee has adequately demonstrated the impracticality of exercising these valves quanerly and during cold shutdowns. GVRR 1 is acceptable as a refueling outage justification, however relief to test at the extended frequency abould not be granted as r-W. Until additional information is provided and longer test intervals are justified and approved, l these valves should be exercised once each refueling outage as permitted by the Code.

4. GVRR 4 (see section 4.1.2.1 of this report) requests relief from the test frequency %d.-.a. for cenain Category A/C containment isolation check valves and proposes to verify the closure capability of these valves during leak rate testing as part of their primary containment leak rate testing program.

M tests frequency would be determined according to 10 CFR 50, Ap =adh J. Option B -

Performance-Based RegtJ. . b ASME Code Committee recognizes the benefhs of performance-based testing of check valves. A recent change included in the 1996 Addenda to the ASME OM Code-1995 incorporates Appendix H, C. heck Valve Condition Monitoring Program, which allows changes to the test program based on component performance. The current rulemaking for 10 CFR 50 will include the 1996 Addenda to the OM Code and govern its use. However, the ASME Code A-3

Comminee has not approved the use of Option B of Appendix J as an ahernative to quarterly exercisirg of check valves. De licensee has not demonstrated tha,t it is impractical to use a Code allowed method such as pressurization testing to verify that these valves close during each refueling outage. The licensee has not shown that the Code frequency requirements create an unmat or undue hardship.

Therefore, relief should not be granted as requested. De licensee should verify the closure capability of these valves according to the OM Code test frequency requ's.-- at least each refueling outage.

5. GVRR-5 (see section 4.1.5.1 of this report) requests relief from the remote position indication verification requirements for administratively controlled Category B passive manumi isolation valves and proposes not to perform remote position indication verification for these valves. De fact that a valve is passive and administratively controlled in its safety position during all plant operating conditions when the associated system is required to be operable, does not ensure that the remote i

position indication of that valve will never be observed and believed to accurately reflect the valve's -

position. The licensee has not shown that the Code requirements create an unusual or undue hardship -

or burden. Since, the position indication may at some time be used to determine valve position, never verifying its accuracy may result in it providing an erroneous indication. Relief should not be granted as requested from the valve position indication verification requirements of the Code. l

6. GVRR-6 (see section 4.1.6.1 of this report) requests relief from the valve stroke timing requinments for all Category A and B rapid-acting valves in the IST program and proposed to apply a maximum stroke time of 5 seconds or for valves that stroke in 5 seconds or close to 5 seconds 4.50% of the reference stroke time to these valves. Much of the recent thiatring on the topic of rapid-acting valves has been that improved timing techniques may allow bener analysis and trending of stroke times. The proposal to adopt a 5 second acceptance criteria has not been shown to be justified for the specific valves covered by this proposal and no unique burden is indicated. Relief should not be granted or the alternative authorized as requested.

7. 33-VRR 1 (see section 4.4.1.1 of this report) requests relief from the exercising frequency requirements for the motor operated emergency service water (ESW) isolation return valve to normal heat sink, MO 0-33 0498, and proposes to full stroke exercise and stroke time it annually when river temperature is less than or equal to 53'F. De NUREG section referenced in the licensee's relief request basis does not authorize testing at alternate frequencies other than cold shutdowns or refueling outages. Relief should be granted from the Code exercising frequency requirements as requested.

However, since this request bases lu justification on being in compliance with NUREG-1482, Section 3.1.1, which does not authorize or address the once a year seu frequency, this relief request should i be modified to correct this discrepancy (see also anornaly 2).

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8. 33-VRR-2 (see section 4.4.1.2 of this report) requests relief from the stroke timing eccp=+ l requirements for ESW cooling water flow isolation to the diesel generator air cooler jacket water  ;

cooler and lube oil cooler valves and proposes not to compare measured stroke times to the initial reference values but to use only the limiting values of stroke time. De licensee regularly adjusts the stroke length of these, which changes the valve stroke times and can resuk in failure to meet the '

accg== criteria and result in unneeded corrective actions. Immediate compliance with the Code acceptance criteria requirements for tese valves is impractical since it may resuk in unneeded maintemnce or repair. Additionally, the constant attention given these valves should allow detection of degradation during the interim period. Derefore, interim relief should be granted in accordance with 10 CFR 50.55a(fX6Xi) for a period of one year or until the next refueling outage, whichever is longer. At the end of that period, the licensee should test these valves in accordance with the Code requirements or justify an alternate method.

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9. He licensee submitted refueling outagejustification01-ROJ-1 for the main steam Category B/C ADS valves. The proposed test frequency is appropriate, however, the stroke time method deviates from the Code requirements. Derefore, the test method portion of this ROJ should be submitted as a relief request. The guidance of NUREG-1482, Section 4.3.4, provides a vehicle for approval of this request.

10. Te.chnical Positions TP-1 and TP-3 state that "De deferral of testing this pump / valve is acceptab the discussion in NUREG-1482, Section 3.1.1. Section 3.1.1 of NUREG 1482 approves deferring valve and pump testing to once each cold shutdown or once each refueling outage for certain situatiors where quarterly testing is impractical or poses an undue hardship. However, k does not address the yearly testing interval proposed by the licensee. De yearly interval may be found to be acceptable, however, the justification abould be cw.sied and auMM to support this interval, even for extended periods when the river temperamre is below 53'F.

11. In addition to the components evaluated in Sections 3.2.1 and 4.4.2.1 of this report TP-1 also includes the Emergency Cooling Water (ECW) Pump, 00P186, ECW pump discharge check valve, CHK-048 506, and ECW pump discharge isolation valve, MO 048-0841. These components appear l

to be augmented wmponents as stated by the licensee in TP-1, therefore, h is appropriate to use TP-1 3

to document an extended test frequency for these components.

l TP-1 also includes motor operated valve MO 048 OR41. The reasons given for extending the test intervals for the other augmented components in the TP (preceding) do not appear to apply to this l

valve. His is a motor operated valve, it does not appear that ESW flow to the emergency cooling l l

' tower is necessary to exercise it. Exercising this valve does not appear to rely on the position of valve MO-0 33-0498. The reviewers could not determine the basis for deferring valve testing until once l

l I annually. However, since this appears to be an augmented component, no changes to the test program  !

are required. De licensee may provide additional information regarding this valve in future updates to the IST program.

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APPENDIX B IST PROGRAM ISSUES IDENura:.D DURING THE SYSTEMS REVIEW l

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( i APPENDIX B IST PROGRAM ISSUES IDENTIFIED DURING THE SYSTEMS REVIEW The INEEL staff reviewed the Residual Heat Removal (RHR)/1.ow Pressure Coolant Iqjection (LPCI) and Emergency Service Water (ESW) systems. 7te staff reviewed the Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS) for the IWR/LPCI system. The staff identified each component in these systems listed in the IST program on the plarn P&ID and evaluated the test (s) designated in the IST program to assess compliance with the applicable American Society of Mechantent r=9-:rs (ASME)

Operations and Maintenance (OM) Code test requirements. Related extended test interval MX-:-s, technical positions and relief requests were also assessed. Following this review, the staff assessed the system for completeness (to determine if additional components should have been included in the IST program). This review yielded the following list ofissues that should be addressed by the licensee.

1. RHR injection header keep-fill line check valves CHK-2-10183A & B are listed as non< ode Class valves in the Peach Bottom IST Program submittal on page 49 of 236 of the Valve Test Table.

However, the P& ids (6280.M-361 Sheets 1,2,3, & 4) show a class break upstream of these series valves. The licensee should review the as built P& ids for this system and make corrections to the P&lDs or valve test tables as needed.

2. On page 46 of 236 of the Valve Test Table, The "RR/CSJ/ROJ" Column for valves CHK-2-10-183A

& B and CHK-2-10 184A & B provides an incomplete reference to the applicable relief request. It lists "10 VRR " but, should be 10 VRR-1. This errata should be corrected in a future update of the test program as appropriate.

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3. Valves MO-2-10 017 and MO 21(M)18 are identified as 24" valves, the P&ID shows them as 20" valves. This errata should be corrected in a future update of the test program as appropriate.

l 4. The RHR system contains several relief valves that appear to perform a safety fhnetion to protect safety relatedcomponents.The Code requires testing of relief valves that protect systems or portions of systems that perform a required function in shuning down the reactor to the safe shutdown condition, in maintaining thc safe shutdown condition, or in mitigating the consequences of an accident.

The following relief valves are not included in the licensee's IST program and appear to perform a safety function.

Valve Number Systeen P&ID Number Coot 1tinates RV 40 RHR 6280-M 361 (Sheet 1) B-3 RV-35A RHR 6280-M-361 (Sheet 1) 0-7 RV-35B RHR 6280-M-361 (Sheet 2) G4 RV-72A RHR 6280-M 361 (Sheet 1) B4 RV-72B RHR 6280-M-361 (Sheet 2) C4 ,

RV-72C RHR 6280 M-361 (Sheet 1) C4 RV-72D RNR 6280-M 361 (Sheet 2) A4 B-3

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ne licensee should review these valves to determine if they should be included in the IST program and tested to the Code an for relief valves. .

5. On pages 102 and 103 of 236 of the Valve Test Table, De "RR/CSJ/ROJ" Column for valves AO 0-33 0241 A, B, C, and D provides an incomplete reference to the applicable relief request. It lists "33 VRR ", but should be 33 VRR-2. This errata should be corrected in a fbture update of the test program as .yyivydsE.

6. On pages 102 and 103 of 236 of the Valve Test Table, The "REQfrEST" Column for valves AO 0 33-0241 A, B, C, and D provides an incomplete designation for the quarterly fail safe test. Since there is no extended test frequencyjustification for performing the fall safe test, we believe that the test is being performed quarterly in the open dt.ction. The licensee indicates that these components will receive . .

FS-(0) (no frequency designation). Similar components are designated to receive an FS-Q(0), or fail safe test in the open direction quarterly. This errata should be corrected in a future update of the test program as appropriate.

7. On page 103 of 236 of the Valve Test Table, The " VALVE NO" Column for valves CHK-2-33-513 and -514 provides an inaccurate reference to the PID "315(SHT5)" and coordinates , G-2 and H-2.

These valves can be found on PID 6820-M-315 (Sheet 4) at coordinates E-8 and F-8, respectively.nis errata should be corrected in a future update of the test program as appropriate.

8. Various other errata (such as improper references) similar to that addressed in issue 7 (preceding) were found on both the P& ids and valve test tables during the review. De reviewers failed to locate valve i MO-2-33 2972 on PID 6820-M-315, Sheets 1 through 4. The licensee should review the valve test

) tables and P& ids for the ESW and emergency cooling water systems and correct deficiencies as appropriate.

9. On page 235 of 236 in the Valve Test Table, valve MO-3-48-3803, "HPSW Return to ECT Iso Valve," is identified as a normally open 24" motor-operated butterfly valve. The P&ID, 6820 M-330 (coordinate G-7), indicates that this is a 12" motor-operated gate valve. The valve table indicates that i this valve has open and closed safety functions. In the valve table, the closed function is indicated to be passive under the " ACTIVE-PASSIVE" column heading. If this valve is normally open and performs an active safety function in the closed position, the valve performs an active safety function and should be stroke timed in both directions as yd to only the open position as indicated in the valve table. The licensee should review the valve tables, P&ID, safety function (s), and testing for this valve and correct the deficiencies as appropriate.

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8 e APPENDIX C DEFERRED TEST JUSTIFICATIONS i

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APPENDIX C l

DEFERRED TEST JUSTIFICA'nONS  ;

De INEEL staff reviewed the licensee's IST program to assess compliance with the applicable AmericanSocietyofMechanica! Engineers (ASME)OperationsandMaintenance(OM)Coderen. . ,

for deferred testjustifications. De following section summarizes the licensee'sj== W=k--- for extending  !

the test intervals to cold shutdowns or refueling outages and is organized by plant system. Inconsistencies or ommissions related to deferred test y.,me.g. are addressed in AM= A and B.

4 MAIN STEAM i

Justification for an extended test interval is provided in CI A-VCS-1, for the Category A main steam line header drain inside/outside primary contaimnent isolation valves (CIVs), MO 2(3F01 A-074 and -077.

During operation,these valves are normally closed, which is their required safety position for containment isolation (i.e. all valves receive a containmentisolation signal). Valves MO 2(3F01A-074 are located in the drywell and valves MO 2(3F01A-077are located in the outboard main steam isolation valve (MSIV) room.

The drywell and outboard MSIV rooms are both high radiation areas during operation and access to these ,

areas is limited to emergencies only. In addition,the drywellis inerted with nitrogen and the outboard MSIV room is a high temperature area, which results in a limited occupation time for plant personnel. Failure in

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the open position during testing would compromise primary containment isolation. De control circuitry of '

these valves only permits full stroke operation. Dese valves will be exercised and stroked timed each cold shutdown.

Justification for an extended test interval is provided in OlA-VCS-2, for the Category A MSIVs, AO-2(3>01 A 080A,-080B,-080C,-080D and AO-2(3>01 A 086A,-086B,-086C, and -086D.

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Exercising these valves during normal operation isolates one line of steam flow to the turbine. Isolation of a main steam header would cause a severe pressure transient in the associated main steam line possibly resulting in a plant trip. Additiont fly, closure of an MSIV, at power, could potentially result in challenging the set point of the MSRV/automaticdepressurization system (ADS) valves causing inadvertent liAing. To i minimize the potential for a plant trip and safety reliefvalve discharge, reduction in power would be required prior to valve closure. Reducing power level to perform testing is not practical due to the impact on plant operations and power production.The valves are provided with partial stroke capabilityto the closed position and will be partial stroke exercised quarterly. Dese valves will be exercised and stroked timed each cold shutdown.

Justification for an extended test interval is provided in Ol ROJ-1, for the Category B/C ADS valves, RV-2-02-070A, -070B, -070C, -070G, -070K, RV-3-02-071 A, -071 B, -071 C, -071 G, and -071 K.

If any of these valves fall to re-close aAer testing, the plant would be placed in a loss-of coolant-accident (LOCA) condition. In addition, a study (Boiling Water BWR Owner's Group Evaluation of NUREG-0737, Item II.K.3.16, Reduction of Challenges and Failures of ReliefValves) recommends that the number of ADS openings be reduced as much as possible. Based on this study and the potential for causing a I.OCA condition, exercise testing of the ADS valves sill be performed during restart aRer refueling. Also, a direct method to stroke time the ADS valves is not available since the control room indication only reflects ADS reliefvalve pilot valve position, and not the actual valve disc position. An attemate indirect method to stroke time the ADS valves is available, which includes timing the pilot valve and observing plant parameter C-3

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l changes. Partial stroke exercising cannot be performed for the same reasons mentioned above. Exercise during restart after refueling. Stroke time test during restart after refueling by timing the interval kt-. ]

pilot valve initiation and observable plant parameter changes. .

Justification for an extended test interval is provided in 01 ROJ-2, for the Category C main steam safety /reliefvalve tailpipe vacuum breaker valves, RV-2-02-3096A, thru -8096H, -8096J, -3096K, -8096L, RV.3 02 9096A thru-9096H,-90960,-9096K,and-9096L.

Dese vacuum breaker /checkvalves are located inside the primary containment.During power operation and at cold shutdown, the containment atmosphere is normally inert with nitrogen gas limiting access to emergencies only. In addition, high radiation levels during power operation prohibit containment entry.

Partialstroke exercising cannot be performed for the same reasons mentioned above. Forward and reverse exercising will be verified during all refueling outages and during cold shutdowns when the primary containment is de-inert.

REACTOR RECIRCULAT10N Justification for an extended test intervalis provided in 02-VCS-1, for the Category B reactor recirculation pump discharge isolation valves, MO 2(3F02-53A and -53B.

Closure of either of the recirculationpump discharge valves would reduce flow possibly resulting in reactor water temperature transients and reactivity transients. Dese transients would reduce control of power distribution and fuel usage.His could lead to decreased fuel reliabilityand increase the possibility of a fuel element failure. To minimize these potential effects would require a reduction in power, prior to valve closure testing, which is not practical due to the impact on plant operations and power production.

Additionally,if these valves failed in the closed position during testing,the plant would be forced to operate at a reduced power level until the plant could be shutdown to facilitate valve repair. Dese valves will not be partial stroke exercised for the same reasons stated above. Exercise and stroke time during cold shutdown.

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HYDRAULIC CONTROL UNIT (HCU)

Justification for an extended test interval is provided in 03A VCS-1, for the Category A/C scram accumulator charging and drive water line check valves, CHK-2(3)-03A-13115AA through -13115HC.

Dese valves are located htwm the HCU accumulators and the charging water header. Deir function is to maintain control rod drive (CRD) accumulator pressure in the event ofloss of CRD pump. Verification of reverse flow closure requires isolating the CRD pump from the charging water header, depresarizing the header, and monitoringthe individualaccumulsor pressure and alarm to verify that the valves have closed on reverse flow. nis test cannot be performed during power operation because isolating the CRD pump and depressurizingthe header would require a Technical Specification Action to manually scram 20 minutes after two accum ulatorlow pressure alarm s actuate. His would be in direct conflict with the objective of Technical

, Specification 3.1, which is to assure the ability of the controt rod system to control reactivity. Partial stroke testing is not performed because k requires the same conditions as full stroke testing. Reverse flow closure capability will be verified by depressurizingthe header and monitorirs the individual accumulator pressure alarms. His demonstrates that the valves have closed on reverse flow. His activity shall be performed during cold shutdowns.

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FEEDWATER Justification for an extended test interval is provided in 06 VCS 1, for the Category A feedwater long path recirculation isolation valves, MO 2(3) 06 038A and -038B.

These valves perform a safety function in the closed direction for containment isolation. De valyn are placed in the open position during start-up and shutdown, and cannot be opened when reactor pressure is greater than 600 psig. His interlock prevents inadvertent over pressurization of the condensate system.

Because reactor coolant system (RCS) pressure during power operation is greater than 600 psig, these valves cannot be exercised without defeating associated interlocks,which would resuh in over pressurization of the condensate system. De control circuitry of these valves only permits full stroke operation. Exercise and stroke time during cold shutdown.

CONTAINMENTATNOSPHEPJC' CONTROL Justification for an extended test interval is provided in 07B-VCS-1, for the following Category A primary CIVs, AO-2-07B-2505, -2506, -2507, -2511, -2512 -2519, -2520, -2521 A, -2521B, AO 3-07B 3505,

-3506, -3507, -3511 -3512, -3519 -3520, -3521 A, and -3521B.

During operation these valves are administrativelyclosed which is their required safety position for primary containment isolation. Failure of these valves in the open position during testing would result in a ,

compromise of primary containment isolation capability.The valves are operatedjust prior to start-up and l shutdown for inerting de-inerting purposes only; at which time they will be exercised and stroke timed, and fall-safe tested. De control circuitry of these valves only permits full stroke operation. Exercise, stroke l

time and fall. safe test during cold shutdowns when containment inening/de inerting is performed.

RESIDUAL HEAT REMOVAL (RHR)

Justification for an extended test interval is provided in 10 VCS-01, for the Category A/C RHR irdection testable check valves, AO-2(3)-10 046A and -046B.

These testable check valves are closed during power operation and function as both primary CIVs and RCS PIVs. At power, these valves protect the low pressure RHR system piping from the high pressure RCS.

De valves are located inside primary containment, which is not accessible during operation, since containment is inerted with nitrogen and is a high radiation area. In addition, because these valves are required to be operable for primary containment isolation per Technical Specirmations (T.S. 3.6.1.3), and are inaccessible during operation, failure to reclose during testing would compromise primsty mneminment isolation capability. Failure to reclose would also create the p**M for over i arization of the RHR system piping due to the loss of one of the two required boundary barrier isolation valves between the RCS and systems oflower pressure design. Dese adverse conditions would require a plant shutdown to repair the valves. Partial stroke exercising cannot be performed for the same reason stated above. Exercise in the forward and reverse direction during cold shutdown.

Justification for an extended test interval is provided in 10 VCS 02, for the Category A RHR shutdown cooling return CIV/PIVs, MO-2(3) 10017 and 418.

These valves are interlocked to prevent operation when RCS pressure is greater than 75 psig. His in:erlock is provided to prevent inadvertent over pressurization of the RHR system piping from the high pressure RCS. Because RCS pressure is greater than 75 psig during power operation, these valves cannot be exercised without defeating the associated interlock, which could result in over pressurization of the RHR C-5

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l pumps low-pressure suction piping. Partial stroke exercising cannot be performed for the same reason stated above. Exercise and stroke time during cold shutdowns.

J##+9 for an extended test interval is provided in 10 VCS 03, for the Category A RHR hiection isolation valves (PN/CIV) MO 2(3F10025A and 025B l Motor operated gate valves MO 2(3F10025A,B are normally closed during power operation and ihnetion as both outboard primary CWs and RCS PIVs. A PN is defined as one of two normally closed valves in series that isolate the RCS from an attached low pressure system and are designmed as such in accordance with Generic Letter (GL) 87 06 and GL 89 04, Anehment 1, Position 4. For the RHR/ low pressure ,

coolant injection (LPCI)irdectionline, check valve CHK-2(3F10046A, B and motor operated gate valve MO-2(3F10025A,B are the two normally closed PNs that prutect the low pressure RHR piping from the  ;

RCS. In order to test MO-2(3)-10 025A, B quarterly, the valve must be opened during power operation ..;

resuking in only a single high to low presure Mmda'y barrier during the test. Additionally, because the valve is required to be operable for primary containment isolation per Technical Specifications (T.S.

3.6.1.3), failure to reclose subsequent to opening may require a plant shutdown to mpair the valve. Partial stroke exercising cannot be perfonned for the same reason stated above. Exercise and stroke time during  ;

cold shutdown.  !

REACTOR WATER CLEAN-UP (RWCU)

Justification for an extended test interval is provided in 12-VCS-01, for the Category A RWCU CIVs, MO-2(3F12-015 -018, and -068.

l These valves are normally open during power operation providing a path for RWCU supply and return flow. Stroking these valves at power requirs removing the RWCU system from service. Failure of these valves in the closed position would result in an unplanned RWCU system outage and degradation in RCS chemistry. If the valves could not be repaired, the result would be an eventual plant shutdown due to unacceptable RCS chemistry. In addition, MO 2(3F12-0151s located in the drywell, which is not accessibb  ;

during power full operation, since it is inerted with nitrogen and is a high radiation area. MO 2(3F12 068 is located in the outboard MSIV room, which is a high temperature, high radiation area during full power operation. A reductionin power level and possibly a plant shutdown would be required to facilitate valve repair for restoration of the RWCU system to an operable status. Failure of any of the above valves in the open or partially open position would resuh in an inoperable primary CIV. In this event, PBAPS Technical Specifications require isolation of the affected penetration. Again, this would resuk in a loss of RWCU system function. This position is consistent with the guidance provided in NUREG 1482, Section 3.1.1, concerning the exercising of valves whose failure would cause a loss of system function. Quarterly partial stroke will not be performed. Failure of the valves in a partially closed position could result in the same condition as discussed above. Exercise and stroke time during cold shutdown.

REACTOR CORE ISOLATION COOLING (RCIC)

Justification for an e*MM test interval is provided in 13-VCS 01, Category A RCIC r, seam supply isolation, inboard primary CIVs, MO 2(3F13015.

'Ibese valves are normally open during power operation providing an open flow path for the supply steam i

to the RCIC turbine. In addition, these valves are located inside primary containment which is not accessible during power operation, since it is inerted with nitrogen and, is a high radiation area. Should the valve fail to reopen, subsequent to closure, the RCIC system would be rendered inoperable. This condition would r?. quire plant shutdown and entry into primary containment to facilitate valve repair for C-6

restoration of the RCIC system to an operable status. Quanerly partial stroke will not be performed.

Failure of the valves in a panially closed position could result in the same condition as discussed above.

Exercise and stroke time during cold shutdown.

Justification for an extended test intervalis provided in 13-VCS 02, for the Category A/C RCIC Iqjection testable check valves, AO 2(3F13 022.

Dese testable check valves are closed during power operation and function as the only RCS P!V for the RCIC system. At power, these valves protect the low pressure RCIC system suction piping from the high pressure RCS. Failure to reclose would create the pa*='i=1 for overpressurization of the RCIC system suction piping due to the loss of boundary barrier isolation between the RCS and the RCIC sysem. These adverse conditions would require a plant shutdown to repair the valves. Panial stroke exercising cannot i be performed for the same reason stated above. Exercise in the forward and reverse direction during cold shutdown.

l Justification for an extended test intervalis provided in 13C-ROJ-1, for the Category C RCIC imw=Aric i

condenser vacuum pump discharge check valve to the torus, CHK-2(3F13C-38. '

These check valves are not coulpped with local or remote position indication. De only way to verify -

closure of these valves is by performing a leak test. or by using a pressurizationtest method. Both methods require removing RCIC from service to install test equipment. The RCIC system is a high pressure coolirig '

system, which provides an additional margin of safety to the reactor during accidents and transients, which do not fully depressurize the reactor. In order to support maximum availabilityof this reactor cooling safety system, testing will be deferred to refueling outages when the system is not required for reactor coolant injection. The NRC has approved extension of the test interval to refueling outages for check valves verified closed by leak testing in Section 4.1.4 of NUREG 1482. CHK 2(3F13C-38 does not have a forward exercise test requirement (no ssfety function in the forward direction) but is implicitly tested quanerly as pan of the skid during RCIC operability testing. Testing in the reverse direction will not be i

performed quarterly. Valves will be exercised in the reverse direction during refueling outages. '

CORE SPRAY '

l Justification for an extended test interval is provided in 14-VCS 01, for the Category A/C core spray injection check valves, AO-2(3F14-013A and -013B.

These testable check valves are closed during power operation and function as both primary CIVs and RCS PIVs. At power, these valves protect the low pressure CS system piping from the high pressure RCS. The j valves are located inside primary containment, which is not acceuible during operation, since containment i is inened with nitrogen and is a high radiation area. In addition, because these valves are required to be

( operable for primary containment isolation per Technical Specifications (T.S. 3.6.1.3), and are inaccessibh during operation, failure to reclose during testing would wioyieroise primary containment isolation ,

capability. Failure to reclose would also create the pad ='ial for overpresnui nionof the CS system piping i due to the loss of one of the two required boundary barrier isolation valves between the RCS and a system oflower pressure design. These adverse conditions would require a plant shutdown to repair the valves. ,

Panial stroke exercising cannot be perfonned for the same reason stated above. Full stroke exercising in the forward and reverse direction will be performed during cold shutdown by utilizing the air operator.

Justification for an extended test irnerval is provided in 14-VCS-02, for the Category A core spray injection isolation PIV/CIVs, MO-2(3F14-012A and 012B C-7 l

l Motor operated gate valves MO-2(3F14412A,B are normally closed during power operation and functim as both outboard primary CIVs and RCS P1Vs. A P!V is defined as one of two normally closed valves in i series that isolate the RCS from an anached low pressure system and are designated,as such in accordance with Generic I.stter 3746 and GL 3944, Attachment 1 Position 4. For the Core Spray /LPCI ' .'7'-w line, check valves CHK-2(3F14413A,B and motor operated gate valves MO2(3F14-12A,B are the two normally closed PIVs that protect the low pressure core spray piping from the RCS. In order to test MO.2(3F14-012A,B quarterly, the valve must be opened during power operation resulting in only a single high to low pressure boundary barrier during the test Additionally, because the valve is required to be operable for primary comin=nt isolation per Technical Specifications (T.S. 3.6.1.3), failure to reclose subsequent to opening may require a plant shutdown to repair the valve. Partial stroke exercising will not l be performed for the same reason mentioned above.

HIGH PRESSURE COOLANT INJECTION (HPCI) . .. .

Justification for an extended test interval is provided in 23-VCS41, for the Category A HPCI steam supply I isolation inboard primary CIVs, MO-2(3F23415.  !

These valves are normally open during power operation providing an open flow path for the supply steam l to the HPCI turbine. In addition, these valves are located inside primary containment which is not accessible during operation, since it is inerted with nitrogen and is a high radiation area. Should the valve fail to reopen, subsequent to closure, the HPCI system would be rendered inoperable. This condition would require plant shutdown and entry into primary containment to facilitate valve repair for restoration of the

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HPCI system to an operable status. Quarterly partial stroke will not be performed. Failure of the valves in a partially closed position could result in the same condition as discussed above. Exercise and stroke time during cold shutdown when the containment is de-inerted.

Justificationfor an extended test intervalis provided in 23 VCS42, for the Category A/C HPCI injection check valves, AO-2(3F23413.

These testable check valves are closed during power operation and function as the only RCS PIV for'the ,

HPCI system. At power, these valves protect the low pressure HPCI system suction piping from the high '

pressure RCS. Failure to reclose would create the potential for overpressurization of the HPCI system suction piping due to the loss of boundary barrier isolation between the RCS and the HPCI system. These adverse conditions would require a plant shutdown to repair the valves. Partial stroke exercising cannot be performed for the same reason stated above. Exercise in the forward and reverse direction during cold shutdown.

Justification for an extended test interval is provided in 23 ROJ41, for the Category C HPCI turbine exhaust drain to suppression pool check valves, CHK-2(3)23C 56.

These check valves are not equipped with local or remote position indication.The on'ly way to verify closure of these valves is by performing a leak test, or by using a pressurization test method. To perform either of these tests,'l) the system must be blocked,which renders the HPCI system inoperable,and 2) test equipmera must be installed.For these reasons,quarterlytesting during power operation is not practicable, and testing during cold shutdown could delay plant startup due to the necessity of utilizing temporary test equipment.

The HPCI system is designed to pump water into the reactor while it is fully pressurized and provides emergencycore cooling in the ever.t of a small break LOCA, which does not cause a rapid depressurizatior of the reactor. In order to support maximum availability of this emergency core cooling system (ECCS),

testing will be deferred until refueling when the system is not required for HPCI capability and no impact exists on plant startup activities. The NRC has approved extension of the test interval to refueling outages C-3 I

for check valves verified closed by leak testing in Section 4.1.4 of NUREG 1482. Forward exercising is performed quarterly during the HPCI operabilitytest; quarterly exercise testing in the reverse direction will not be performed. Valves will be tested in the severse direction during refueling outages.

EMERGENCY SERVICE WATER (ESW)

Justification for an extended test interval is provided in 33 VCS-01, for the Category C ESW diversion prevention check valves, CHK 2(3)33-514.

Check valves CHK-2(3)33-514cannot be exercised in the reverse direction during normal plant operation because the present piping configuration does not allow for isolating service water upstream of these check valves. In order to perform a valid reverse closure test during power operation,the service water system must be shutdown rendering several plant systems inoperable or incapable of performing their process functions.

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Those plant systemsinclude:

Fuel Pool Service Water Booster Pumps RBCCW Heat Exchangers j Condensate Pump Room Coolers Demin Hold Pumps Drywelland ControlRoom Chillers Main Generator Hydrogen Coolers Main Turbine Lube Oil Coolers Vacuum Pump Heat Exchanger Reactor Feed Pump Lube Oil Coolers Loss of service water to the above systems can result in equipment damage. In addition, loss ofservice water to critical turbine generator support equipment will result in a turbine trip and subsequent reactor shutdown.

Reverse flow closure will be verified during cold shutdown when service water operation can be interrupted REACTOR BUILDING CLOSED COOLING WATER Justification for an extended test interval is provided in 35.VCS-01, Category A inboard and outboard primary CIVs, MO-2 35-2373,-2374, MO 3 35-3373, and -3374.

Exercise testing these valves during power operation would cause a loss of cooling water flow to the  ;

recirculationpump seal and motor oil coolers. The failure of any one of these valves to reopen, subsequent to closure would result in a complete loss of cooling to the associated recirculation pump, potentially resulting in damage to the pump shaA seals and motor. A damaged recirculation pump shaA seal or motor, necessitating pump shutdown, would require a reduction in reactor power in accordance with Technical Specification 3.4.1. Quarterly partial stroke exercising will not be performed for the same reasons stated I

' above. Exercise and stroke time during cold shutdown when the associated recirculation pump can be removed from service.

STANDBY GAS 1REATMENT(SBGT)

Justification for an extended test interval is provided in 40B-VCS-01, for the reactor building ventilation supply and exhaust isolation valves, ACL2-40B 20452,-20453,-20457,-20458, 20461, 20462,-20463,

-20464, AO-3-40B-30452, -30453, .30457, -30458, -30461, .30462, -30463, and -30464.

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Exercise wsting these valves, with the exception of the refuel floor vent supply and exhaust dampers, durin power operation would require removal of+he associated supply fan frorn service. This would cause a high temperature condition in the steam tunnel room, which is cooled by the reactor building ventilation system.

After a supply fan is taken out ofservice, approximately 20 to 30 minutes would be required to reduce the l

temperature to an acceptable level in the steam tunnel rooms subsequent to returning the fan to service. lf temperatures get high enough, the reactor would eventually scram. In addition, loss of sesedwy containment integrity would be a violation of Technical Specification 3.609A.4.1. Exercise testing l AO 2(3)0452,AO 2(3)0453, AO-2(3)0461,and AO 2(3)0462, refuel floorvent supplyand exhaust dampers, at power would require the refuel floor ventilation isolation dampers to be closed. If these dampers could not be reopened, and at least one exhaust fan isimed, Technical Specification 3.3.6.2 would require the start-up of SBGT within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If SBGT were started, the reactor building supply fans would have to be i

secured. Again, as stated above,this would result in elevated main steam tunnel temperatures and eventual l

' reactor scram. The control circuitry of these valves only permits fbli stroke operation. Exercise, stroke time, and fail-safe test during cold shutdown.

CHILLED WATER Justification for an extended test interval is provided in 44A VCS-01, for the Category A drywell chilled water supply and return header CIVs, MO 2-44A-2200A, -2200B, -2201 A, -2201B, MO-3 44A 3200A,

-3200B, -3201 A, and -3201B l

Exercising these valves during power operation could result in a trip of the drywell chillers due to a low flow condition. These chillers supply chilled water to the reactor recirculation motor air coolers and the drywell fan coolers, and if tripped require 30 minutes for restart. Interrupting chilled water flow to the recirc. motor coolers, due to a chiller trip, creates the possibility of overheating and damage to the motors which would result in taking the recire. pump out of service. Removing a recire. pump from service would require a reduction in power. Interrupting chill water flow to the drywell fan coolers, due to a chiller trip, could result in an increase in drywell temperatures, which would cause an increase in drywell pressure.

I Normal operating drywell pressure is .50 to .75 psig with a reactor protection system (RPS) trip set point j of 2.20 PSIG. Therefore, an increase in drywell temperature could result in a reactor scram. De control circuitry of~these valves only permits full stroke operation. Exercise and stroke time during cold shutdown.

REACTOR VESSEL LEVEL INSTRUMENT REFERENCE LEG BACKFILL SYSTEM Justification for an extended test interval is provided in 02G-ROJ-1, for the CRD supply to the reactor pressure vessel instrument condensing chambers isolation check valves, CHK-2 02G-23450A, -23450B, l

-23451 A, -23451B, -23462A, -23462B, -23463A, -23463B, CHK-3 02G-33450A, 33450B, -33451 A,

-33451B, -33462A, -33462B, -33463A, and -33463B.

Exercise testing of these check valves requires system valve isolation and the use of a testing to introduce flow toward the check valve in the reverse direction.nis increases the possibility of air infiltration to the system which could resuk in ECCS or RPS safety system actuation due to spurious level indications.

During refueling, air infiltration is reduced because the system is backfilled through system head chambers and the CRD system. Backfill of the system could not be performed during normal power operation because of the requirements for availability of the CRD and RPV level system at this time. Additionally, the valve mavement required to perform this test increases the risk of a pressure spike on the reference leg which could result in the initiation of a plant transient. In addition to the plant safety concerns, personnel safety concerns must be considered since the process side of these valves is normally high energy (> $00 psig) during normal power operation. Personnel safety risks are considerably minimized when testing is performed during refueling outages. The NRC has approved extension of the test interval to refueling C - 10

c outags for check valves verified closed by leak testing in Section 4.1.4 of NUREG 1482. Partial stroke exercising cannot be performed for the same reasons awarianart above. Valves will be caercised in the reverse direction during refueling outages. .

STANDBY L1 QUID CONTROL (SLC)

Justification for an extended test interval is provided in 11-ROJ-1, for the Category A/C (416) and C (-

017) SLC bj~daa check valves, CHK-2(3) 11416 and 417.

l Verifying forward flow operabilityrequires firing a squib valve and bj~da- water into the RCS using the I SLC pumps.1stjection of borated water during operation will result in a reduction in power. Additionally,

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introduction of relatively colder water into the RCS will cause a thermal cycle (shock) which can result in i the premature failure of system components (piping). Since the firing of squib valves requires valve- - -

disassemblyto replace valve internals, firing should be minimimi. Therefore, forward flow testing of the check valves will be performed during SLC injection testing as required by Tehnint Specifications (T.S.  ;

3.1.7). Also, firing squib valves should be minimized as mentioned above, and replacing squib valve l l internals at cold shutdown could delay plant start-up. Partial stroke exercise testing cannot be performed for the same reasons stated above. Forward flow operability will be verified at refbeling during SIE injection testing.

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