ML19336A599

Ser,Inservice Testing Program,Salem Nuclear Generating Station Unit 2, Interim Rept

ML19336A599
Person / Time
Site:	Salem
Issue date:	10/31/1980
From:	Cook T, Hanek J EG&G IDAHO, INC., EG&G, INC.
To:	Cappucci J Office of Nuclear Reactor Regulation
References
CON-FIN-A-6265 EGG-EA-5257, NUDOCS 8010300218
Download: ML19336A599 (48)

Text

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FORM EGSG 398 e is m INTERIM REPORT Accession No.

Report No. EGG-EA-5257 Contract Program or Project

Title:

Systems Engineering Support Subject of this Document.

Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Salem Nuclear Generating Station Unit 2 (Docket No. 50-311) for the Period from Issuance of the Operating License until the start of Commercial Operation Type of Document:

Safety Evaluation Report Author (s):

T. L. Cook J. F. Hanek Date of Document:

. October 1980

- Responsible NRC Individual and NRC Office or Division:

A. J. Cappucci, NRC-MEB This document was prepared primarily for preliminary or internal use. it has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

EG&G loaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclea. Hegulatory Commission Wastii.'gton, D.C.

. Under DOE Contract No. DE-AC07-761D01570 NRC FIN No. A6265 INTERIM REPORT

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I CONTENTS i

- I. I n t r o d u c t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. Pump Testing Program ............................................ 3 III. Valve Testing Program ........................................... 4 IV. Attachment I .................................................... 35 V. Attachment II ................................................... 37 VI. Att6chment III .................................................. 46 VII.-Attachment IV ................................................... 47 e

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-I . ' Introduction i . ~

Contained herein is a saf'ety evaluation of the pump.and valve inservice testing (IST) program. submitted by.the Public Service Electric. and Gas. Company,(PSEE) on January 4,1979 for its Salem, Unit 2 nuclear plant. - The program applies *to Salem, Unit 2 for. the period from issuance of the operating license until the start of comercial operation. The working session with PSEE and Salem,

i. ' Unit 2 representatives was conducted on January 30 and 31, 1980. The licensee resubmittal was issued on April 23, 1980 and was reviewed by

!- EGE Idaho Inc., to verify compliance of proposed tests of safety related class 1, 2, and 3 pumps and valves with requirements of the-ASME Boiler and Pressure Vessel _ Code,Section XI,1974 Edition, i through the Sumer of 1975 Addenda. PSEE has also requestet relief from the ASME Code from testing specified valves because of practical reasons. These requests have been evaluated individually to determine whether they have significant risk implications and whether the tests,

, as reqaired, are indeed impractical.

1 The evaluation of the pump testing program is contained in Section -II; the evalution of the valve testing progran and associated relief L requests is contained in Section III. All ' evaluations for Sections II

and III are the recommendations of EGE Idaho, Inc.

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Category A, A/C, and A/E valves that are currently being leak tested per Technical Specifications (Appendix J) or are currently exempted from leak rate-testing by Technical Specifications are contained in 4

Attachment f.

I Valves that should be reviewed by the NRC to determine if they should be: categorized'A~are contained in Attachment I.-

Category A, B,.and C valves that meet the requirements of the ASME

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Code Sec' tion XI and are not exercised every 3 months are contained in

. Attachment II.

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A listing of P&ID's used for this review are contained in Attachment III. -

~ Valves that are never full stroke' exercised or that have a testing interval greater than each refueling outage and relief requests with insufficient technical basis where relief is not recomended are sumarized in Attachment IV.

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'II. Pump Testing Program The.IST program submitted by PSE&G Company was examined to verify that Class 1, 2, and 3 safety related pumps were included in the program and -that those pumps are subjected to the periodic. tests as required by the ASME Code,Section XI. Our review found that all Class 1, 2,-

and 3' safety related pumps were included in the IST program and the pump tests and frequency of testing comply with the code.

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l III. Valve Testing Program Evaluation The IST program submitted by PSE&G Company was examined to verify that Class 1, 2, and 3 safety related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that all Class 1, 2, and 3 safety related valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guidelines listed in General Section A.

Also, included in the General Section A is the NRC position and valve listing for the leak testing of valves that perform a pressure isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each PSE&G request for relief from testing valves, the code requirement for testing, PSE&G basis for requesting relief, and the EG&G evaluation of that request is sunnarized (B through K) below and grouped according to each -

specific systen.

. I A. General Considerations

1. Testing of Valves Which Perform a Pressure Isolation Function There are several safety systems connected to the reactor coolant pressure boundary that have design pressure below the rated Reactor Coolant System (RCS) pressure. Also included are .those systems which are rated at full reactor pressure on the discharge side of pumps but have pump suction below RCS pressure. In order to protect these systems from RCS pressure, two or more isolation valves are placed in series to form the interface between the high pressure RCS and the low pressure systems. The leak tight .

integrity of these valves must be ensured by periodic leak testing to prevent exceeding the design pressures of the low .

pressure sytcms causing a LOCA.

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It-is our position that these valvas be classified as

- - . Category A or A/C as described in Section XI Subsection IWV of ASME Boiler and pressure vessel code and leak tested in accordance with IWV-3420 of the above mentioned code at.

least once per refueling. The allowable leakage limit for

each . valve should not exceed 1.0 Gallons Per Minute (GPM).1 These valves are:

1 21-24SJ17 Safety injection to reactor coolant system 21-24SJ43 Residual heat removal to reactor coolant system ,

, 21-24SJ55 Safety injection accumulators to reactor coolant system 21-24SJ56 Safety injection accumulators to reactor

. coolant systen 21-24SJ139 Safety injection to reactor coolant system 21-24SJ144 Safety injection to reactor coolant system

. 2SJ150 Safety injection to reactor coolant system 21-24SJ156 Safety injection to reactor coolant system 2 RH1 Residual heat removal from reactor coolant system 2 RH2 Residual heat removal from reactor coolant system 23-24RH27 Residual heat removal to reactor coolant 1

system

1. This staff position is currently under review by the NRC with the licensee.

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1. See NUREG-0677, "The Probability of Intersystem LOCA: Impact Due to Leak Testing and Operational Changes" and the " Proposed Appenjix A to SRP Section 3.9.6, " Leak Testing of Pressure Isolation Valves."

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2. ASME Code Section XI Requirements Subsection IWV-3410(a) of the Section XI Code (which .

discusses full stroke and partial stroke) requires the Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-1), (e), and (f). IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3520(b). IWV-3700 requires no regular testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time for each power operated valve shall be identified by the owner 'and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where: -

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

b. It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

3. Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only limited operation is possible (and it has been denonstrated by the licensee and agreed to by the ,

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NRC) the check valves shall be partial stroked. Since disk position'is not always observable, the NRC staff stated that verification of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement. Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or greater than the

- design flow rate through the valve. The licensee agreed to conduct flow test to satisfy the above position.

4. Stroke Testing of Motor Operated Valves The licensee has requested relief from the part-stroke requirement of Section XI for all power operated valves.

The licensee has stated that none of the Category A or B power operated valves identified can be part-stroked because

. of the design logic of the operating circuits. These circuits are such that when an open or close signal is received the valve must complete a full stroke before the relay is released to allow '.he valve to stroke in the other direction. We find that the hbove relief request from part-stroking is warranted and should Le granted because the required function of the valves involves only full open or full closed positions.

5. Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category A and B valves and once every nine months for Category C valves. It is NRC's position that the Code is inconsistent and the C2tegory C valves should be S '

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tested on the same schedule as Category A and B valves. The l licensee has agreed to modify his procedures on cold -

l shutdowns to read, "In the case of frequent cold shutdowns, valve testing will 'not be performed more of ten than once ,'

every three (3) months for, Category A, B and C valves."

6. Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to be tested at cold shutdown, and the Code conditions under which this is permitted is noted in Appendix A. These valves.are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to' exercise these valves during power operation and that we. agree with the licensee's basis.

It should be noted that the NRC differentiates for valve testing purposes between the cold shutdown mode and the refueling mode. That is, for testing purposes the refueling mode is not considered as a cold shutdown.

7. Changes to the Technical Specification In a November 1976 letter to the licensee, the NRC provided an attachment entitled, "NRC Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." -The attachment stated that when one train of a redundant system such as the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the 8

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! remaining train should not be cycled if their failure'in a

non-safe position would.cause a loss of total system function. For example, during pwer operation in some plants, there are stated minimum requirements for systems

j. which allow certain limiting conditions for operation to l l exist at any one time and if the system is not restored to .,

meet the requirements within the time period specified in a

- plant's Technical Specifications (T.S.), the reactor is I

required to be put in some'other mode. Furthermore, prior ,

! to initiating' repairs all valves and interlocks in the l

!, - system that provide a duplicate function are required to be tested to demonstrate operability innediately and ,.

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periodically.thereafter during power operation. For such

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plants this situation could be contrary to the NRC guideline t

as stated in the document mentioned above. It should be noted that reduction in redundancy is-not a basis for a T.S.

change nor is it by itself a basis for relief from

. - exercising in accordance with Section XI.

Tie licensee has agreed to review the plant's T.S. and to l

l consider the need to propose T.S. changes which would have

) the effect.of precluding such testing.

After making this review, if the licensee determines that the T.S. should be changed because the guidelines are applicable, the licensee will submit to the NRC, in

. conjunction with the proposed T.S. change, the inoperable

- condition for each system that is effected which l demonstrates that-the valve's failure would cause a loss of system function or if the licensee determines that the T.S.

should not be changed because the guidelines are not

- applicable or cannot be followed, the licensee will submit-

- the reasons that led to their determination for each.

~ potentially affected. section of the T.S.

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8. Safety Related Valves This review was limited to safety-related valves.

Safety-related valves are defined as those valves that are needed to mitigate the consequences of an accident and/or to shutdown the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2 and 3 valves and could include some non-code Class valves.

It should be noted tnat the licensee may have included nt'-safety related valves in their Inservice Test Program as a decision on the licensee's part to expand the scope of their progran.

9. Valve Testing at Cold Shutdown Inservice valve testing at cold shutdown is acceptable when -

the following conditions are met: It is understood that the licensee is to commence testing as soon as the cold shutdown '

condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown and continue u..cil complete or plant is ready to return to power. Complet:.on of all valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing frequency.

For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

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10. Category A Valve Leak Check Requirements tor Containment Isolation Valves (CIV)

All CIVs shall be classified as Category A valves. The Category A valve leak rate test requirements of IWV-3420(a-e) have been superseded by Appendix J requirer.ents for CIVs. The NRC has concluded that the applicable 1e.ak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J. Relief from paragraph IWV-3420 (a-e) for CIVs presents no safety problems since the intent of IWV-3420 (a-e) is met by Appendix J requirements.

The licensee shall comply with Sections f and g of IWV-3420 until relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C Appendix J leak test is performed.

Based on the considerations discussed above the NRC concludes that the alternate testing proposed above will give the reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property of the common defense and security of the public.

11. Application of Appendix J Testing to the IST Program The Appendix J review for this plant is a completely separate review from the IST program review. However, the ,

determinations made by that review are directly applicable to the IST program. Our review has determined that the current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis Appendix J. The licensee has agreed that, should the

. Appendix J program be amended, they will amend their IST program accordingly.

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12. Pressurizer Power Operated Relief Valves The NRC has adopted the position that the pressurizer power ,

operated relief valves should be included in the IST program as Category B valves and tested to the requirements of Section XI. However, since the PORVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that. routine exercising during power operation is "not practical" and therefore not required by IWV-3410(b)(1).

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

The following test schedule is recommended: -

1. Full stroke exercising should be performed during cooldown prior to achieving the water solid condition in the pressurizer and during cold shutdown prior to heatup.

2. Stroke timing should be perf ormed at each cold shutdown or as a minimum once each refueling cycle.

3. Fail safe actuation testing is permitted by the code to be performed at each cold shutdown if the valves cannot be tested during power operation. This testing should be performed at each cold shutdown.

4. The PORV block valves should be included in the IST ,

program to provide protection against a snall break LOCA should a PORV fail open. -

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It should be noted that the licensee has included the PORVs and associated block valves in the IST program; however, relief was not requested from the exercising requirements of Section XI because this NRC position was not adopted entil after the working meeting and the licensee's resubmittal.

B. - Auxiliary Feed

1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Category C valves 21-23AF53, demineralized water check valves, in accordance with the requirements of Section XI and proposed to manually full stroke exercise during refueling.

Code Requirement

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Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief .

The line in which this valve is installed is maintained empty and vented to the atmosphere. We do not fill this line except in need as it is routed through a vital relay room and a leak would cause extensive damage and trip the reactor. These valves will be manually stroke exercised per Section XI during 4

refueling.

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Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the Category C valves 21-23AF53 from the exercising requirements of Section XI. The licensee has demonstrated that the only method available to exercise these valves is by disassembly and manual full stroke exercising. This portica of the system is normally kept drained and vented to prevent the possibility of leakage into the vital relay room which could result in equipment damage and a reactor trip. We conclude that disasser'.ly and manual full stroke exercising during refueling outages should demonstrate proper valve operability.

b. Relief Request The licensee has requested specific relief from -

exercising Category C valve 23AF4, #23 auxiliary feed pump suction check, in accordance with the requirements '

of Section XI and proposed to partial stroke during power operation and manually full stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This valve cannot be full stroke exercised during Power Operation without thermal shocking the feed nozzles. -

The normal feed path to the SGs is the only available full flow path. The valve cannot be tested in Cold 14

d Shutdown or Refueling because the steam must be available to drive the turbine to operate the #23 Auxiliary Feed Pump to exercise 23AF4. This valve is partial 'troked through the recirculation path during power operation. This valve will be manually full stroke exercised per Section XI during refueling.

Evaluation We' agree with the licensee's basis and therefore feel relief should be granted for Category C valve 23AF4 from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow path is into the steam generatars which would result in thermal shocking of the fet i nozzles. Only partial stroke exercising is possible during power operation due to the limited size of the pump

, recirculation line. Exercising during cold shutdown or refueling with auxiliary feed system flow is not possible because steam is not available to operate the turbine driven pump. We conclude that disassembly and manual full stroke exercising during refueling outages should denonstrate proper valve operability.

c. Relief Request The licensee has requested specific relief from exercising Category C valve 23AF8, #23 auxiliary feed pump discharge check, in accordance with the requirements of Section XI and proposed to manually full stroke exercise during refueling.

Code Requirement

. Refer to valve testing paragraph A. 2.

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Licensee's Basis for Requesting Relief This-valve cannot be tested during power operation ,

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without thermal shocking the feed nozzles on the SGs.

It cannot be flow tested during cold shutdown or refueling because there is no steam available to drive the #23 Auxiliary Feed Pump Turbine. This valve will be manually full stroke exercised per Section XI during refueling.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C valve 23AF8 from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow path is into the steam generators which would result in thermal shocking of the feed nozzles. -

Exercising during cold shutdown or refueling with auxiliary feed system flow is not possible because steam is not available to operate the turbine driven pump. We conclude that disassembly and manual full stroke exercising during refueling outages should demonstrate proper valve operability.

C. Chemical and Volume Control

1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Category C valve 2CV196, chemical addition ,

tank outlet check, in accordance with the requirements of Section XI. -

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Code Requirement Refer to talve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This valve is passive, normally closed and not required to change position to perform it's safety function.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C valve 2CV196 from the exercising requirements of Section XI. This valve is in it's safety related position and not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

. Therefore, the operability of this valve is inconsequential with regard to the safety function _ it performs. We conclude that quarterly stroke exercising is meaningless for passive valves.

D. Containment Spray

1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Category C valves21-22CS4 and 21-22CS48, containment spray discharge header check valves, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling outages.

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Code Requirement Refer to valve testing paragraph A. 2.

i . Licensee's Rasis'for Requesting Relief a

~'t  : valves cannot~ be exercised during power operation or cold shutdown without spraying down the containment, causing equipment and lagging damage requiring extensive cleanup and rr. pair. The full flow test connection is connected to the refueling. cavity and can only be used during refueling, Evaluation -

We agree'with the licensee's basis and therefore feel j relief should be granted for Category C valves21-22CS4 and 21-22CS48 from the exercising requirements of i Section XI. The licensee has denonstrated that exercising chese check valves during power operation or. -

cold shutdown is not possible without spraying borated wate: into the reactor cc.:teiraent building resulting in' lagging and equipment damage. The licensee has proposed to full stroke valves21-22CS4 and 21-22CS48 during refueling outages when a test spool piece can be installed and the borated water discharged to the reactor refueling cavity. We conclude the licensee's proposed alternate testing frequency should be sufficient to ensure proper valve operation,

b. Relief Request t

The licensee has requested specific relief from exercising Category C valve 21-22CS21, spray additive tank checks, in accordance with the requirements of .

5ection XI and proposed to partial stroke exercise-

. quarterly.

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Code Requirement 4 -

Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief The-safety-related position is open to allow the caustic solution in the spray additive tank to be educted i.'to +he C.S. system and sprayed into the containment. Only partial stroke is possible due to the limited size of the recirculation line.

Evaluation We agree with the licensee's basis and therefore feel

-temporary relief should be granted for Category C valves21-22CS21 from the full stroke exercising

. requirements of Section XI. We conclude that with the present piping configurations, only partial stroke exercising of these valves is possible. However, we recommend that the licensee further investigate a method to full stroke exercise these valves, i.e.,

manual exercising during refueling outages.

E. Main Steam

1. Category B Valves

a. Relief Request The licensee has requested specific relief from exercising Category B valve 2MS52, auxiliary feed pump turbine steam supply valve, in accordance with the

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requirements of Section XI.

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. Code Requirement Refer to_ valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This is a passive valve. It is always in the position required to allow the pump to operate during an incident.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category B valve 2MS52 from the exercising requirements of Section XI. This valve is in it's safety related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant. -

Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke time measurenents are meaningless for passive valves.

b. Relief Request The licensee has requested specific relief from stroke timing Category B valve 2MS53, auxiliary feed pump turbine governor valve, in accordance with the raquirements of Section XI.

Code Requirement Refer to valve testing paragraph A. 2.

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Licensee's Basis for Requesting Relief Stroke time does not provide any meaningful data for valve degradation. Proper valve operation is verified through normal system operation during the auxiliary feed pump test.

Evaluation We agree with the licensee's basis and'+.lierefore feel relief should be granted for Category B valve 2MS53 from the stroke timing requirements of Section XI. The licensee has denonstrated that stroke timing a modulating valve will not provide any meaningful data for valve degradation. We conclude that verifying proper system operation is the most practical method of ensuring proper modulating valve operability.

c. Relief Request The licensee has requested specific relief from exercising and stroke timing Category B valves21-24MS168, MSIV three-way pilot valves, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief ,

This is a passive valve always maintained in its ,

safety-related position (i.e., open to the MS169s and MS171s).

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Evaluation We agree with the licensee's basis and therefore feel .

relief should be granted for Category B, valves21-24MS168 from the requirements of Section XI.

These valves _are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the pl ant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the_ quarterly stroke and stroke time measurements are meaningless for passive valves, i F. Nitrogen i

1. Category A/C Valves

a. Relief Request The licensee has requested specific relief from exercising Category A/C valve 2NT26, pressurizer relief tank nitrogen-supply check, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This valve has no position indication and is located inside the containment. This valve can only be verified shut during refueling.

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Eysluation We agree with the licensee's basis and therefore feel relief should be granted for Cateoary A/C valve 2NT26 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position) is during leak testing. This valve is not equipped with valve position indication and some of the required test connections are loca+sd inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

G. Residual Heat Removal System

1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Cgbegory C valves 23-24RH27. hot leg injection checkh, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This is a passive valve. During an incident LPSI is

, through another path.

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Evaluation We agree with the licensee's basis and therefore feel ,

relief should be granted for Category C, valves 23-24RH27 from the exercising requirements of Section XI. These valves are in their safety related positions and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety

function which they perform. - We conclude that the quarterly stroke and ' stroke time measurements are meaningless for passive valves.

NOTE: .The categorization of these valves is currently under review by the NRC with the licensee.

H. Safety Injection -

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1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Category C valves 21-24SJ17, and 2SJ150, safety injection to the reactor coolant system, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

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Licensee's Basis for Requesting' Relief For power operation, testing would require pumping 2,000 ppm borated water into the RCS. This would render the reactor subcritical and would also violate Technical Specification LC0 3.5.4.1.

, For cold shutdown, testing would ultimately require significant RCS dilution and boric acid recovery operation. It would also present a possible low-temperature RCS oyr j,dssurization and would violate Technical Specification 3.5.4.1. and certata operating procedures. These valves will be exercised during refueling per Section XI.

Evaluation

. We agree with the licensee's basis and therefore feel relief should be granted for Category C valves 21-24SJ17 and 2SJ150, from t:1e exercising requirements of Section XI. The licensee has demonstrated that exercising these valves during power operation would require injecting 2000 ppm borated water into the reactor system and would result in reactor shutdown. These valves cannot be exercised during cold shutdown without the possibility of creating a low tenperature-overpressurization condition in the reactor coolant system. In addition, injecting 2000 ppm boron into the reactor system could delay reactor startup due to the extensive cleanup required to return reactor system chemistry to operating specifications. We conclude that exercising tiiese valves during refueling outages when an expansion volume is available and chemistry requirements do not

. restrict reactor operation should demonstrate proper valve operability.

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NOTE: The categorization of these valves is currently

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under review by the NRC with the licensee.

b. Relief Request The licensee has requested specific relief from exercising Category C valve 2SJ31, safety injection suction check, in accordance with the requirements of Section XI and proposed to partial stroke during power operation and full stroke exercise during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Only partial stroke is possible due to design of the -

recirculation line. Flow to loop cannot be done at

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power operation because the RCS pressure is greater than safety _ injection pump shutoff head. During cold shutdown, the possibility of a low temperature

' overpressurization of the RCS exists. This valve will be full stroke exercised during refueling.

1 Evaluation We agree with the licensee's basis and feel. relief should be granted for Category C valve 2SJ31 from the i exercising requirements of Section XI. The licensee has denonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety injection ,

pumps cannot overcome RCS pressure. Only partial stroke exercising is possible during power operation -

due to the limited size of the pump recirculation line.  ;

26.

1 This valve cannot be full stroke exercised during cold shutdown without the possibility of creating a low temperature-overpressurization condition in the RCS.

We conclude that full stroke exercising this valve

! during refueling outages when an expansion volume is available should denonstrate proper valve operability.

f

c. Relief Request The licensee has requested specific relief from exercising Category C valves 21-22SJ34, safety injection pump discharge checks, 21-24SJ139, 21-24SJ156, safety injection hot leg injection checks, and 21-24SJ144, safety injection cold leg injection checks, in accordance with the requirements of Section XI and proposed to full stroke the.e valves during refueling.

Code Requirement Refer to valve testing paragraph A.-l2.

Licensee's Basis for Requesting Relief During power operation, testing is not possible since RCS pressure is greater than safety injection pump shutoff head. During cold shutdown, the possibility of a low tenperature-overpressurization of the RCS exists. These valves will be full stroke exercised during refueling outages.

27

Evaluation We agree with the licensee's basis and therefore feel ,

relief should be granted for Category C valves 21-22SJ34, 21-24SJ139, 21-24SJ156, and 21-24SJ144 from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety injection pumps cannot overcome RCS pressure. These valves cannot be full stroke exercised during cold shutdown without the possibility of creating a low temperature-overpressurization condition in the RCS. We conclude that full stroke exercising these valves during refueling outages when an expansion volume is available should demonstrate proper valve operability.

NOTE: The categorization of valves 21-24SJ139, 21-24SJ144, and 21-24SJ156 is currently under review by the NRC with the licensee.

d. Relief Request The licensee has requested specific relief from exercising Category C valves 21-24SJ55, safety accumulator discharge checks, in accordance with the requirements of Section XI and proposed to partial stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

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Licensee's Basis for Requesting Relief During power operation the RCS pressure is greater than accumulator pressure. During cold shutdown, testing of this valve by accumulator discharge could result in low temperature-overpressurization of the RCS. These valves will be part stroke tested during refueling per 1 Section XI. .

Evaluation We agree with the licensee's basis and feel temporary relief should be granted for Category C valves 21-24SJ55 from the exercising requirements of Section XI. The licensee has denonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety accumulator pressure cannot overcome RCS pressure.

These valves cannot be full stroke exercised during j cold shutdown without the possibility of creating a low tempcrature-overpressurization condition in the RCS.

We conclude that with the present piping configuration, only partial stroke exercising of these valves is possible. However, we recommend that the licensee further investigate a method to full stroke exercise these valves.

NOTE: The categorization of these valves is currently under review by the NRC with the licensee.

29

e. Relief Request The licensee has requested specific relief from ,

exercising Category C valve 2SJ70, RWST to LPSI pump suction check, in accordance with the requirements of Section XI and proposed to partial stroke exercise during power operation and full stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Only part stroke exercising is possible during power operation due to the limited size of the recirculation line and because LPSI pump discharge cannot overcome RCS pressure. This valve will be full stroke exercised -

during refueling when the LPSI pump discharge can be lined up to fill the reactor cavity.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C valve 2SJ70 from the exercising requirements of Section XI. The licensee has denonstrated that the only full flow path available is into the reactor coolant system and is not possible during power operation because LPSI (RHR) pump discharge pressure cannot overcome reactor coolant system pressure. This valve cannot be full stroke exercised during power operation due to the limited size of the recirculation line. This valve cannot be .

30 i

full-stroke exercised.during cold shutdown without the 1

- possibility of creating a low temperature-overpressurization in the RCS. We conclude that full 1 stroke exercising during-refueling when the vessel head I is removed and the refueling cavity is being filled

, (this provides an adequate expansion volume) should demonstrate proper valve operability.

I. Spent Fuel C:oling I ,

1. Category A/E Valves

! a.' Relief Request

.The licensee has requested specific relief from exercising Category A/E valves.2SF22 and 2SF36, spent I fuel cooling isolation-valves, in accordance with the

. requirements of Section XI.

Code Requirement ,

Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief r ,sive valves not required to change position to ,

fulfill their function.- Valves are kept locked shut per Technical Specification 3.6.3.1, Table 3.6-1. ,

Evaluation i

We agree with the licensee's basis and '_therefore feel f, relief should be granted for Category A/E valves 2SF22 and 2SF36 from the requirements of Section XI.

31 ais . -, - , , - -- ,.n s , +.---~,-.,~-w , ., ,, 4 I,. m m ,

These valves are in their safety related position and are not required to open or close to mitigate the -

consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

J. Station Air (Compressed Air)

1. Category A/E Valves

a. Relief Request The licensee has requested specific relief from exercising Category A/E valve 2SA118, station air containment isolation valve, in accordance with the .

requirements of Section XI.

Code Requirement Refer to valve tes' ting paragrcph A. 2.

Licensee's Basis for Requesting Relief Passive valve not required to change position to fulfill it's function. Velve is locked shut per Technical Specification 3.6.3.1, Table 3.6-1.

Evaluation We agree with the licensee's basis and therefore feel

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relief-should be. granted for Category A/E valve 2S4318 i

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fran the exercising . requirements of -Section XI. This I valve is in it's safety related position and is not .

required to open or close to mitigate tae consequences-1 of in' accident-or safely shut down the plant.

Therefore, the operability of this valve is

inconsequential with regard to the safety function which it performs. 'We conclude that-the quarterly i

stroke and stroice time measurements are meaningless for passive valves.

K. Waste Disposal - Liquid

-1. Category A/E Valves i

. a. Relief Request

The licensee has requested specific relief from

. exercising Category A/E valves 2WL190 and 2WL191, reactor cavity to spent fuel cooling pump containment isolation,. in accordance with the requirements of Section XI.

.t Code Requirement 4

Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Passive valves not required to change position to

, ' fulfill their function. Valves are kept locked shut per Technical Specification 3.6.3.2.d, Table 3.6-1.

. i 33

~ , . _ __. , __ - . . . . .

. Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/E valves 2WL190 and 2WL191 from the requirements of Section XI. These valves are in their safety related position and are not

required to oren or close to mitigate the consequences of an accident or safely shut down the plant.

Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

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- IV. Attachment I A. The following Category A, A/C and A/E valves are currently being

~

leak tested per Technical Specification 4.6.1.2.d (Appendix J) instead of Section XI.

2CV 3, 4, 5, and 7, reactor coolant. letdown isola +. ions 2CV68 and 69, regen heat exchanger isolations 2CV74, regen heat exchanger isolation 2CV116 and 284, RCP seal water isolations 2CV296, seal water line overpressure protection isolation 2CC113 and 215, excess letdown isolations 2CC117,118,131,136,187 and 190, CC to RCP isolations 2CC186 and 208, overpressure protection isolations 21 and 22CA330, control air isolations 2DR29, demin water isolation 2FP147, fire protection isolation 21-24GB4, S/G drain and blowdown isolations 2NT25 and 26, N to the PRT isolations

~

2 2N132,-N 2 to S.I. accumulators isolation 2PR17 and 18, PRT and gas analyzer isolations 2SJ53, 60, and 123, S.I. test line 2SS27, 33, 49 and 64, primary sampling isolations 2SS103,104,107, and 110, primary sampling isolations21-24SS94, S/G drain and blowdowo 1solations 2VCl-6, containment ventilation isolations 2tC7, 8, 11, and 12, containment sample isolations 2WL96 and 97, RCDT sample isolations 2WL98, 99, and 108, PRT to waste gas isolations 2WL12 and 13, RCDT pump isolations 2WL16 and 17, containment sump pump isolations 2WR80 and 81, PRT supply and RCP head tank isolations m

35

B. The following Category A, A/C, and A/E valves are currently

, exempted from leak rate testing by Technical Specification Table 3.6-1. .

)

21-24CV98, RCP seal water throttle valves21-24SS93, S/G sample isolations 2SF22 and 36, spent fuel cooling isolations 2SA118, station air isolation 2WL190 and 191, reactor cavity to SPC pump isolations C. The following valves should be reviewed by the NRC Appendix J review committee to' determine if they should be categorized A, A/C or A/E and tested in accordance with the requirements of Section X'.

l 2VC9, 10, 13 and 14, containment semple isolations. (These valves are currently exempted from leak testing by Technical Specification.) ~

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1 V. -Attachment II The following are Category A, B, and C valves that meet the requirements'of the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG&G.has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible due to the valve type and' location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

A. Auxiliary Feed

1. Category C/E valves 21 through 24AF23, auxiliary feedwater header checks, cannot be exercised during power operation.

Exercising these valves with cold auxiliary feedwater would thermal shock the feed nozzles resulting in nozzle damage.

These valves are full stroke exercised during cold shutdown.

2. Category C valves 21-22AF4 and 21-22AF8, auxiliary feed pump suction.and discharge checks, cannot be full stroke exercised during power operation. The only available full flow path is into the steam generators. Exercising these

. valves with cold auxiliary feedwater would thermally shock the feed nozzles resulting in feed nozzle damage. 21-22AF4 are partial stroke exercised during power operation .through the recirculation test line. All valves are full stroke exercised during cold shutdown.

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B. Steam Generator Feed and Condensate

1. Category C/E, valves 21 through 24BF22, feedwater header checks cannot be exercised during power operation.

Exercising these valves would require 3 loop reactor operation which is not permitted and a reactor trip is required. These valvet will be full stroke exercised during cold shutdowns.

C. Chemical and Volume Control

1. Category A valve 2CV7, reactor coolant letdown containment isolation, cannot be exercised during power operation.

Exercising this valve would isolate normal letdown flow through the -egenerative heat exchanger causing the injection ci cold water into the RCS resulting in thermal cycling of injection nozzles and possible cracking damage.

This valve is fuli stroke exercised during cold shutdown. .

2. Category A valves 2CV68 and 69, regenerative heat exchanger containment isolations, cannot be exercised during power operation. If these valves f ailed shut during testing, loss of pressurizer level control would result requiring a reactor trip. These valves are full stroke exercised during cold shutdown,

3. Category A valves 2CV116 and 284, reactor coolant pump steal water containment isolations, cannot be exercised during power operation. Shutting these valves would cause an RCP trip which would then cause a reactor trip. These valves will be exercised during cold shutdown.

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4. Category A/C val- 'CV74, regenerative heat exchanger containment. isolauion, cannot be exercised during power

-operation. Shutting this valve during power operation would cause a loss of pressurizer level control and a reactor trip would result. This valve is full stroke exercised during cold shutdown.

5. Category A/C valve 2CV296, RCP seal return line overpressure protection containment isolation, cannot be isolated during power operation without tripping an RCP which will cause-a reactor trip. This valve cannot be shut without shutting 2CV284. This valve is full stroke exercised during cold shutdown.

6. Category B valves 2CV41 and 42, VCT outlet isolations, cannot be exercised during power operation. Closing these valves during' power operation requires lining up the alternate source of water from the refueling water storage tank to the suction of the charging pumps. This is 2,000 ppm borated water which would render the reactor subtritical. These valves are exercised during cold shutdown.

7. Category C valve 2CV42, VCT oatlat suction check, cannot be exercised during power operation. Exercising (closing) would result in a loss of nonnal makeup to the RCS, pressurizer level control, and RCP seal flow. This would require a reactor trip. Use of the only alternate suction for the charging pumps, the RWST, which is water borated to approximately 2000 ppm, would result in a reactor shutdown.

This valve is full stroke exercised during cold shutdown.

B a

)

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8. Category C valves 21 through 24CV99, RCP seal water. check

~

valves, and category A/E valves 21-24CV98, RCP seal water throttle valves, cannot be exercised during power operation ,

without securing seal water to an RCP resulting in a loss of an RCP and requiring a reactor trip. These valves are full stroke exercised during cold shutdown.

9. Category C valve 2CV176, rapid boration check, cannot be exercised during power operation. Testing during power operation would require injecting highly borated wcter into the RCS resulting in a reactor shutdown. This valve is full stroke exercised during cold shutdown.

D. Component Cooling

1. Category A valves 2CC117, 118, 131, 136, 187, and 190, CC to RCP supply and return containment isolations, cannot be exercised during power operation because if the valves -

f ailed shut a loss of RCP cooling would occur requiring the RCP be secured and thus requiring a reactor trip. These valves are ejercised during cold shutdown when RCPs are secured.

2. Category A/C valves 2CC186 and 208, overpressure protection for containment isolation piping, cannot be exercised during power operation without isolating CC to RCPs requiring RCPs to be secured which would result in a reactor trip. These valves are full stroke exercised during cold shutdown when RCPs are secured.

4 40

E. ' Containment Spray

1. Category B valves 21 and 22CS36, LPSI to. containment spray,

.cannot be. exercised during power operation. These valves are interlocked shut with 21 and 22SI44, containment sump

. suction isolations. These valves are full stroke exercised during cold shutdown.

F. Main Steam

1. Category B valves, 21 through 24MS167, main steam isolation

- valves, and 21 through 24MS169 and 21 through 24MS171, backup valves for shutting main steam isolations, cannot be exercised during power operation. Shutting one main steam valve will cause a steam flow / feed flow mismatch in the corresponding SG because the steam flow would go to zero.

This would cause a reactor trip. Testing the shutting backup valves would result in the associated main steam isolation valve closure.- These valves are full stroke exercised during the startup following cold shutdown.

G. Residual Heat Removal

1. Category B valves 2RH1 and 2, RHR injection hot leg isolations, cannot be exercised during power operation.

These valves are pressure interlocked shut and cannot be opened when RCS pressure is greater than 590 psig. These valves are full stroke exercised during startup following a cold shutdown.

NOTE: The categorization of these valves is currently under review by the NRC with the licensee.

~41 y_. ,

2.- Category B valve 2RH26, RHR to hot leg isolation,cannot be

. exercised during power operation because valve is shut with -

power removed (per Technical Specification 4.5.2) to prevent overpressurization of the RHR sytem (low pressure.SI system). Also if the valve failed open, flow would be diverted from the injection flow path. This valve will be full stroke exercised during cold shutdown.

3. Category C valves 21 and 22RH8, RHR '(LPSI) pump discharge checks, cannot be full stroke exercised during operation.

To full stroke exercise these valves at power operation requires opening valve 2RH21. Should this valve fail while open or should an incident occur while testing, too much water would be diverted from the LPSI to provide sufficient cooling. These valves will be part stroke exercised during power operation and full stroke exercised at cold shutdown and refueling.

H. Safety Injection

1. Category B valves 2SJ1 and 2, RWST to charging pump suction isolations, cannot be exercised during power operatior.

without injecting 2000 ppm boron into the RCS resulting in a reactor shutdown. These valves will be exercised during cold shutdown.

2. Ca+egory B valves 2SJ4 and 5, BIT inlet isolations, cannot rcised during power operation. Opening these valves during power operation would dilute the BIT below 20,100 ppm boron, the concentration required by Techncial Specification 3.5.4.1 to ensure safe plant shutdown of the reactor during an incident. These valves will be exercised during cold shutdown.

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3. Category B valve 2SJ30, RWST to SI pump suctic.. isolation, cannot be exercised during power operation. Stroking this valve requires isolating the suctions of both safety injection pumps from the RWST. Failure of this valve would disable both ECCS' trains. This valve is full stroke exercised during cold shutdown.

4. Category B valves 21 and 22SJ44, SI pump suction containment isolations, cannot be exercised during power operation because if a valve f ailed, containment integrity would tre breached to initiate a repair to the valve and the reactor would have to be shut down. These valves will be exercised durin, cold' shutdown.

5. Category B valves 21 and 22SJ45, LPSI pump discharge to the SI and HPSI pumps, cannot be exercised during power operation because the~21 and 22SJ44 must be opened to

. exercise these valves due to interlocks between them. See relief request for 21 and 22SJ44. These valves will be exercised during cold shutdown.

6. Category B valve 2SJ69, LPSI pumps suction isolation, cannot be exercised during power operation. This is a passive valve always maintained in the open position -(Technical Specification 4.5.2 requires this valve to be open with the power removed during power operation). Failure of this valve in the closed position during testing would render the RHR (LPSI) system inoperable. This valve will be exercised during the startup following cold shutdown.

7. Category B valve 2SJ135, SI pump discharge to RCS cold legs, cannot be exercised during power operation because if it f ails shut during testing cold leg injection would be isol ated. This valve will be full stroke exercised during

. cold shutdown. i i

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8. Category B valves 21 through 24SJ54, accumulator outlet isolations, cannot be exercised when the accumulators are at

• normal pressure and the RCS is <1000 psig to prevent a "

possible low tenperature-overpressurization of the RCS.

These valves will be stroke timed and exercised while:

4

a. The accumulators are at normal pressure and RCS

>1000 psig.

b. The accumulators are depressurized and the RCS is

<1000 psig.

9. Category C valve 2SJ3, prevent backflow from the VCT to the RWST check, cannot be exercised during power operation. In order to test this valve 2SJ1 or 2SJ2 must be opened. 2SJ1 and 2 cannot be exercised during power operation without injecting 2000 ppm boron into the RCS resulting in a reactor shutdown. This valve will be full stroke exercised during .

cold shutdown.

10. Category C valves 21-24SJ56, safety accumulator, RHR/LPSI header checks, cannot be exercised during power operation because these systems cannot overcome RCS operating pressure. These valves will be full stroke exercised during cold shutdown when the RHR system is in service.

NOTE: The categorization of these valves is currently under review by the NRC with the licensee.

11. Category C valves 21 through 24S]43, RHR/LPSI header checks, cannot be exercised during power operation because the RHR/LPSI pumps cannot overcome RCS pressure. These valves are full stroke exercised during cold shutdown when the RHR system is placed in service.

44

1 l

1 NOTE'. The categorization of these valves is currently under

• - review by the NRC with the licensee.

I. Service Water

1. Category C valves 21 and 22SW51, backflow preventors from

. the containment f an coil units to the nuclear service water header, cannot be exercised during power operation. Testing these valves requires isolating service water to 2 fan coil units. -This places the plant in a limiting condition for operation (Technical Specification 3.6.2.3). These valves will be full' stroke exercised during cold shutdown.

'2. Category C valves 21 and 22SW79, service water overload discharge checks, cannot be exercised during power operation because both nuclear headers are required (Technical Specification 3.7.4.1). If these valves failed shut while

, exercising, a plant shutdown would be required. These valves are full stroke exr.rcised during cold shutdown.

J._ Ventilation Containment

1. Category A valves 2VC1 through 6, containment ventilation isolations, need not be exercised during power operation.

These valves are passive during power operation. They cannat be opened per connitment to NRC in LER 50-272/79-55/01T. These valves will be exercised during cold shutdown.

O 45'

VI. Attachment-III The P& ids listed below were used during the course of this review.

Systen P&ID Rev.

Auxiliary Feedwater 205336 4 Steam Generator Feed and Condensate 205302 9 Chemical and Volume Control, Boric Acid 205329 6 Recovery Chemical and Volume Control Operation 205328 6 Chilled Water- 205216 12 Component Cooling 205331 7 Containment Spray 205335 6 Reactor Containment and Penetration 205347 4 Area Control Air Demineralized Water Restricted Areas 205246 6 Fire Protection 205222 9 Steam Gerierator Drains and Blowdown 205325 7 Main Reheat and Turbine Bypass Steam 205303 8 Reactor Coolant 205301 6 Dasidual Heat Removal 205332 3 Safety Injection 205334' 7 .

', ampling 205344 7 Service Water Nuclear Area 205342 8 -

Spent Fuel Cooling 205333 5 Compressed Air _

205317 6 Reactor Containment Ventilation 205338 8 Waste Disposal Liquid 205339 6 Chemical and Volume Control, Primary - 205330 6 Water Recovery d

t l

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VII.' Attachment'IV A. Valves that are never full stroke exercised or that have a testing frequency greater than each refueling outage:

1.21-22CS21, Spray addit've tank ~ checks

• 21-24SJ55, Safety accumulator discharge checks

• NOTE: The categorization of these valves is currently under review hy the'NRC with the licensee.

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. . - - . . . . . . - . . . - . - . -