ML19345G223

Inservice Testing Program,Salem Nuclear Generating Station, Unit 1, Safety Evaluation for 790501-801201

ML19345G223
Person / Time
Site:	Salem
Issue date:	02/28/1981
From:	Fehringer J, Rockhold H EG&G IDAHO, INC., EG&G, INC.
To:	Nerses V Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 EGG-EA-5265, NUDOCS 8103170136
Download: ML19345G223 (60)

Text

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=~ Assistance lepor*'-

INr. RIM REPORT Accession No.

Report No. EGG-EA-5265 Revision 1 Contract Program or Project

Title:

Systems Engineering Support Subject of this Document:

Safety Evaluation of the Inservice Testing . .vgram for Pumps and Valves at the Salem Nuclear Generating Station Unit 1 (Docket No. 50-272) for the Period 5-1-79 through 12-1-80 Type of Document:

Safety Evaluation Report

<s Author (s):

J. M. Fehringer E

[ TfV' H. C. Rockhold 2_g NL.j/j.,J f.

. Date of Du ..-ment: l, SMll J 3 Jgg i February 1981 ** '

Responsible NRC Individual and NRC Office or Division:

G u s N ' e- .

Victor Nerses, NRC-DE E This document was prepared primarily for preliminary or internal use. it has not received full review and apnroval. Since there may be substantive changes, this document should not be considered final.

4 EG&G Idaho tr.c Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission

, Washington, D.C.

Under DOE Contract No. DE-AC07-76 f D01570 NRC Flh No. A6258 INTERIM REPORT VRC Researci anc "ec1nical

81f M W 1,e Assistance Repor':

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CONTENTS I. Introduction .................................................... 1 II. Pump Testing Program ............................................ 3 III. Valve ?esting Program ........................................... 4 IV. Attachment I .................................................... 35 V. A t t a tnm e n t I I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 VI. Atta:hment III .................................................. 47 VII. AttacNnent IV ................................................... 43 e

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l. Introduction k8$fSI80C0 3090Tt a

, Contained herein is a safety evaluation of +he pump and valve inservice testing (IST) program submitted by the Public Service Electric and Gas Company (PSE&G) on February 9,1979 for its Salem, Unit I nuclear plant. The program applies to Salem, Unit 1 for the period. The working session with PSE&G and Salem, Unit 2 representatives was conducted on January 30 and 31, 1980. The licensee resubmittal was istued on March 10, 1980 and was reviewed by EG&G Idaho Inc., to verify compliance of proposed tests of safety i related class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Pressure Yessel Code,Section XI, 1974 Edition, through the Summer of 1975 Addenda. PSE&G has also requested relief from the ASME Code from testing specified valves because of practical I

reasons. These requests h' ave been evaluated individually to determine whether they have significant risk implications and whether the tests, 3

as required, are indeed impractical.

The evaluation of the pump testing program is contained in Section II; the evalution of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.

' Category A, A/C, and A/E valves that are currently oeing leak tested per. Technical Specifications.(Appendix J) or are currently exempted j from-leak rate testing by Technical Specifications are contained in l Attachment I.

f Valves that should be reviewed by the NRC to determine if they should be categorized A are contained in Attcchment I.

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.' Category.A,.B,'and C valves that meet the requirements of the ASME Code-Section-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 recommended are sumarized in Attachment IV.

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II. Pump Testing program

. The IST program submitted by PSE&G Company was exar,.;ned to varify that Class 1, 2, cnd 3 safety related pumps were included in the program and that tho',e pumps are subjected to the periodic tests as r2 quired by the ASMd Code,Section XI. Our review found that all Class 1, 2, and 3 safety related pumps were included in the IST program and ' a pump tests and frequency of testing comply with the code.

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III. V21ve Testing Program Evaluation The IST program submitted by PSE&G Company for Salen Unit I was examined to verify that Class 1, 2, and 3 safety related valves were inclu.ied 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 rela ed 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 l

NRC position and valve listing for the leak testing of valves that

! perform 'a pressure iwlation 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 fcr testing, PSE&G basis for requesting relief, and the EG&G evaluation of that request is summarized (B through K) below and grouped according

to each specific system. .

A. General Considera' ions

1. Testing of Valves Which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boundry have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class.1 boundary forming the interface between these high and low pressure systems prevent the low pressure systems from~ pressures which exceed their design

limiL. In this role,- the valves perform a pressure  !

isolation function.

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The NRC considers the redundant isolation provided by these valves to be important. The NRC considers it necessary to ensure that the condition of each of these valves is adequate to maintain this redundant isolation and system

. integrity. For these reasons, EG&G believes that some method, such as pressure monitoring, leak testing, radiography and ultrasonic testing, should be used to ensure the condition of each valve is satisf actory in maintaining this pressure isolation function.

If leak testing is selected as the appropriate method for achieving this obiective, and EG&G Inc. believes that the following valves should be categorized as A or AC and leak tested according the IWV 3420 of Section XT of the applicable edition of the ASME Code. These valves are:

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11-14SJ139 11-14SJ156 11 + 12S140 11-14SJ144 11-14SJ55 13 + 14RH2s

, 11-14SJ56 11-14SJ43 1RH1 + 2 1RH26 The NRC and EG&G Inc. have discussed this . matter with the licensee and ident fied the valves listed above. The licensee agreed to consider testing and categorizing each of these valves with the appropriate designation depending on the' testng method selected. Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC for evaluation the details of the testing method which clearly demonstrate the condition of each valve.

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2. ASME Code Section XI Requirements i r

Subsection IW-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 IW-3410(b-1), (e), and  !

(f). IW-3520(a) requires that Code Category C valves be j

exercised once every 3 months, with the exceptions as i defined in IW-3520(b). IW-3700 requires no regular testing fo* Code Category E valves. @cratkcal 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 IW-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 operation.

b.- It is not practical to observe the operation of the

valves '(with f ail-safe actuators) upon loss of actuator' power.

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3. Stroke. Testing of Check Valves The NRC stated its po'sition 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 demonstrated 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

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• of the full stroke requiremerit. Any flow rate less than desige will be con idered part stroke exercising unless it

-can ta ihown that the check valve's disk position at the i- lower F.ow rate would be equivalent to or greater than the f

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

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4. Stroke' Testing of Motor Lperated Valves  ;

i The licensee has requested relief from the part-stroke

.i requirement of Section XI for all power operated valves. .

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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 tre operating circuits. These r~* circuits are such that when an open or close signal is received the valve must complete a full stroke before the 1 relay is released te: allow the valve to stroke in the other direction. We find that the.a'ccve relief request from i

i. part-stroking is warranted and should be granted because tne ,

b 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 ,

l testing need not be performed more often than once every three months for Category A and B valves and once every nine.

- mcnths- for Category C -valves. It is NRC's position that the.

- . Code _is inconsistent and the Category C valves should-be-

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tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold 4

! 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 valvas." ,

6. Licensee Request for Relief to Test Valves at Cold Shutdown

. The Code permits valves to be tested at cold shutdswn, and the Code conditions under which this is permittel is noted i 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 requirenents 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 i Exercising ~(Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that_when ene train of s redundant system such as;the Emergency Core Cooling System.

.(ECCS) is inoperable, nonredundant valves in the ,

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remaining train should not be cycled if their failure in a I non-safe position would cause a loss of total system function. For example, during power operation in some plants, there are stated minimum requirements for systems

. which allow certain limiting conditions for operation to

. 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 required to be put in some other mode. Furthermore, prior to initiating repairs ell valves and interlocks in the system that provide a dupli ate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation. For such plants this situation could be contrary to the NRC guideline 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.

'. The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would hara the effect of precluding such testing.

After making this review, if the licensee detennines 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 demonstrates that the val've's f ailure 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

!. tha reasons that led to their determination for each potentially affected section of the T.S.

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8. Safety Related Valves i

pIhis review was limited to safety-rela'ted valses. ,

Safety-relaced valves are defined as those y .lves 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 that the licensee may have included no:bsafety related valves in their Inservice Test Progran as 1

a decision on the licensee's'part to expand the scope of their program.

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

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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 /> af ter shutdown and continue until complete or plant is ready to return to power. Completion of all valve testing is not a i 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-ti.eL 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 for Containment Isolation Valves (CIV)

All CIVs shall be classified as Category A valves. The C'a tegory A valve leak rate test requirements of -

IWV-3420(a-e) have been superseded by Appendix J requirements for CIVs. The NRC has concluded that the applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J.- Relief from

' paragraph IWV-3420 (a-e) for CIVs presents .w 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 110-3420 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 tell'ef thus granted will not endanger iife or property of the comon defense and security of the public.

I 11. Application of Appendix J Testing to the IST Program ,

Th( 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 detarmined 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 l: .'

Appendix J program be amended, they will amend their IST-

-program accordingly..

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B. Auxiliary Feed

1. Category C Valves

a. Relief Request .

The licensee has requested specific re'ief from exercising Category C valves 11-13AF53, demineralized water check valves, in accordance with the requirements of Section XI and prepnsed to manually full stroke exercise during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief .

The line in which this valv; 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 full stroke exercised per Section XI during refueling.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the Category C valves 11-13AF53 from the exercising requirements of 12

Section XI. The licensee has demonstrated that the only method available to exercise these valves is by disassembly and manual full stroke exenising. This portion of the system 1 normally kept ufained 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 disassembly anc manual full stroke exercising _ during refueling outages should demonstrate prope* valve operability.

b. Relief Request The licensee has. requested specific relief from exercising Category C valve 13AF4, #13 auxiliary feed pump suction check, in accordance wi'..h the requirements I

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

i Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief

! This valve cannot be full stroke' exercised during Power f Operation without thermal shocking the feed nozzles, t

The normal i::d path to the SGs is the only available ..

. full' flow path. The~ valve cannot be tested in Cold

Shutdown or Refueling.because the steam must be available' to drive the turbine to operate the #13 Ausiliary Feed Pump to exercise 13AF4. This valve is

. partial stroked through the recirculation path-during .

--power operation. This valve wi" be manually full r

- stroke exercised per Section XI during refueling.

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

' relief should be granted for Category C valve 13AF4 from the exercising requirements of Section XI. The -

licensee has demonstrated that the only available full flow paih is into the steam generators which would result in thermal shocking of the feed nozzles. Only partial stroke exercising is possible during power operation due to the 11,7.ited 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 dr' en pump. We conclude that disassembly and man al full stroke exercising du ing refueling outages should demonstratu proper valve operability.

c. Relief Request The licensee has requested specific relief from exercising Category C valve 13AF8, !13 auxiliary feed pump discharge check, in accordance with the requirements of Sectic" vi and proposed to manually full stroke exercise curing refueling.

Code Requirement Refer to valve testing paragraph A. 2.

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e Licensee's Basis for Requesting Relief i

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This valve cannot be tetted during power operatier without thermal shocking tF* feed nozzles on the SGs.

. It cannot be flow tested during cold shutdown or refueling because there is no steam available to drive i the #13 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 13Att from the exercising requirements of Section XI. The licensee has demonstrated that the only available full 1

flew path is into the steam generators which would result _in thermal shocking of the feed nozzles.

. . Exercising during cold shutdown or refueling with auxiliary feel system. flow is. not possible because steam is not 'c.'ailable to operate the turbine c-1ven

{' pump. We concidde that disassembly and manual full.

stroke exercising during refueling outages should demonstrate proper valve operability, i C. Chemical and Volume Control l.- Category C Valves

, a .- Relief Request

.The licensee has requested specific relief _from

exercising Category C valve ICV 196, chemical addition

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

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

Licensee's Basis for Requesting Relief -

This valve is ' passive, ncrmally closed and not required to change position to perform it's safety function. '

Evaluation

[ We agree with the licr7see's basis and therefore feel elief should be granted for Categury C valve 16V196

t;;n 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. Tir. conclude that quarterly stroke exercising  ;

is meaningless for passive valves.

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D .- Containment Spray

1. Category C Valves

a. Relief Request Tne licensee has requested specific relief from exercising Category C valves11-22CS4 and 11-12CS48,

. containment spray discharge header check valves,,in f .

accordance with the requirements of Section XI and

~ proposed to exercise these ' valves during refueling

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

- Licensee's Basis for Requesting Relief These valves cannot be exercised during power operation or cold shutdown without spraying down the containment,

. causing equipment and lagging damage requiring extensive cleanup and repair. The full flow test connection .is connected to the refueling cavity and can

.only be used during refueling.

4 Evaluation We agree with the licensee's basis and therefore feel relief -should be granted for Category C valves11-12CS4 and 11-12CS48 from the exercising requirements of i: . Section XI. The licensee has demonstrated that i exercising these check valves during power operation or cold shutdov:n is not-possible without spraying borated 4

water. into the reactor containment building resulting in-lagging and equipment damage. .The licensee has l ~

' proposed ~ to full stroke valves11-12CS4 ard 11-12CS48

' 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 .

- propo' sed alternate testing . frequency _should be e sufficient to ensure' proper valve operation.

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-The licensee-has requested: specific-relief from I exercisir.g Category C valve 11-12CS21, spray additive  ;

• tank. checks, in accordance with the requirements of i s Section XI and proposed to partial stroke exercise quarterly.  !

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k Code Requirement Refer to valve testing paragraph A. 2. .

Licensee's Basis for Requesting Relief ,

i i The safety-related position is open to tilow the caustic solution in the s7 ray additive tank to be educted into the C.S. system and sprayed into the containment. ' Only partial stroke is possible due to the limited size of the recirculation-line.

Evalu'ation We agree with the licensee's basis and therefore feel tenporary relief should be granted for Category C valves11-12CS21 from the full stroke exercising requirementso lf Section XI. We' conclude that with the present piping configurations, only partial stroke .

exercising of these' valves is.possible. However, we reconnend that theElicensee further investigate a

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-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 IMSS2,- auxiliary feed pwnp

't'urbine steam supply valve,Jin accordance with the .

f requirements of Section XI.

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c Code Requirement Refer to valve testing paragraph A. 2.

- Licensee's Basis for Requesting Relief i

j This is a passive valve. It is always in the position

. required to allow tne pump to operate during an incident.

. Evaluation We agree with the licensee's bas:s and therefore fcel

relief should be granted for Category B valve IM552 from the exercising requirements of Section XI. This a valve .is in it's safety reiated position and is not

_g ' required'to open or close to mitigate the consequences of an accident-or. safely shut'down the plant, t

- Therefore, the operability of this velve is i'

inconsequential with regard to the safety f unction which it performs. We conclude that the quarterly stroke- and stroke time measurements are meaningless for

. passive. valves, i

b.- Relief Request The licensee'has requested specific relief from stroke timing Category B valve IMS53,: auxiliary feed pump turbine governor valvc, in accordance with the requirements of Section XI. -

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. Code Requirement-i _

lRefer to valve; testing paragraph A. 2.

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Licensee's Basis for Requesting Relief 4

Stroke time does not provide any meaningful data for ,

valve degradation. Proper valve operation is verified thrcugh normal system operation during the auxiliary -

f eed pump test.

Evaluation k- We agree with the licensee's basis and therefore feel relief should be granted for Category B valve IMS53 from the stroke timing requirements of Section XI. The licensee has denonstrated that stroke timing a

j. 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 operacility. ,

- c. kelief Request .

The licensee has requested specific relief from exercising and stroke timing Category B.

. valves11-14MS168, MSIV three-way pilot valves, in l

accordance with the requirements of Section XI.

r Code Requirement Refer to valve testing paragraph A. 2.

F Licensee's Basis for Requesting Relief i'

- 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,

- valves11-14MS168 from the requirements of Section XI.

These valves are in their safety related position and are rat required to open or close to mitigate the consequences of an accident or saf ely 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.

F. Nitrogen

1. Category A/C Valves

- a. Relief Request The licensee has requested specific relief from exercising Category A/C valve INT 26, 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 contairrnent. This valse can only be verified shut during refueling.

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J Evaluation We agree with the licensee'- basis and therefore feel relief should be granted for Category A/C valve INT 26 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 pcsition) is during leak testing. This '

valve is not equipped with valve position indication and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure 4

during the performance of leak rate testing at I refueling outages should demonstrate proper valve operability.

LG. Residual Heat Removal System I  ?.

1 Category C Valves *

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

. exercising Category C valves 13-14RH27, hot leg

~ injection checks, in.accordance with the requirements of Section XI.

.' Code Requirement i

Refer to valve testing paragraph A. *.

-Licensee's Basjs for Requesting Reliefe ,

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~ This is- a passive valve. . During an incident LPSI is 1through another. path. ,

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Evalcation We . gree with the licensee's basis and therefore feel relief should be granted for Category C, valves 13-14RH27 from the exercising requirements of Section XI. These valves are in their safety related positions and are not required to cpen 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 measurenents are meaningless for passive valves.

b. Relief Request The licensee has requested specific relief from excrriciag Category C valves 11 and 12 RH8, RHR (LPSI) pump discharge cuecks, in accordance with the requirenents of Section XI and proposed to partial stroke exercise these valves during power operation and cold shutdown and full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief t_ These valves cannot be full stroke exercised during power operation because the RHR (LHSI) pumps cannot e

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overcome RCS operating pressure and the pump test l' recirc lines limit exercising to partial stroking.

During cold shutdown RCS pressure is greater than -

} design accident pressure; thus, only partial stroke  !

exercising is possible. These valves will be full stroke exercised during refueling outages.

i: Evaluation

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

! that relief should be granted for Category C valves 11

, and 12 RH8 fron the requirements of Section XI. The

, I!censee has demonstrated that, due to plant design and ,

RCS pressures, these valves.can only be partial stroke

$ exercised during power operation and cold shutdowns.

We conclude' that partial stroke exercising these valves during power operation and cold shutdowns, and full -

stroke exercising these valves during refueling outages

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when the RCS is at abnospheric pressure (design

accident pressure) should demonstrate proper valve operabil ity, t

H. - Safety Injection

1. Category C Valves 4

a. Relief Request The licensee-has requested specific' relief from exercising Category C valves ll-14SJ17, and ISJ150, safety injection't'o the reactor coolant system, in n

l 24 J

f a

3_

accordancc with the requirements of Section XI and I proposed to exercise these valves during refueling.

• i r

Code Requirenent Refer _ to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief

. For power operation, testing would require pumping I

. 2,000 ppn 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

/

i RCS dilution and boric acid recovery operation. It i would.also present.-a possfule low-temperature RCS

, overpressurization and would violate Technical Specification 3.5.4.1. -and certain operating procedures. -These valves will be exercised during

' refueling per Section XI.

Evaluation' ,

i

! We agree with the licensee's b' asis ard therefore feel relief should be granted for Category C i valves 11-14SJ17 and ISJ150, from the exercising requireneats of_ Section XI. The licensee-has demonst'ated that~ exercising these valves during power

- oper:.. ton would require injecting 2000 ppm borated l = water into tha reactor system and would result in l reactor. sh'utdown. These valves cannot be exercised -

i.

I .

i

'v i

i

+

25 ,

_g.-g p, y W w g m p --ee gy -  % --yg --

m y.p, -

during cold shutdtwn without the possibility of creating a low temperature-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 sp ecifications'. We conclude that exercising these valves during refueling outages when an expansion volume .is available and chemistry requirements do not restrict reactor operation should demonstrate proper valve-operability.

b. Relief Request The licensee has requested specific relief from exercising Category C valve ISJ31, 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 Requirenent t

, Refer.to valve testing paragraph A. 2.

Licensee's Basis for Requesting Rea ief -

Only partial strokesis possible due'to design of the

-recirculation line. Flow to' loop cannot be done at 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 2during refueling.

2ii

1: .

3 J

Evaluation We' agree with the licensee's basis and feel relief should be granted for Category C valve ISJ31 from the exercising requirements of Section XI. The licensee i has demonstrated that the only available full flow path

is into the reactor coolant system and is not possible 4

4 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.

This valve cannot tHL full stroke exercisad during cold shutdown without the possibility of creating a low I

temperature-overpressurization condition in the RCS.

We conclude that full stroke exercising this valve during' refueling outages when an expansion volume is

. 'available shocid demonstrate proper valve operability.

i' c. ReliefERequest

The licensee hac requested specific relief from exeicisir,g Category C valves 11-12SJ34, safety injection pump discharge ~ checks, 11-14SJ139, 11-14SJ156, safety injection hot leg injection checks, and 14SJ144, safety injection cold leg injection checks, in accordance with the requirements of .

Section XI-'and proposed ta full stroke these valves

-during refueling. '

~

Code Requir'ement~

Referito valve testing ~ paragraph A. 2.

27 '

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 snutdown, the possibility of a low temperature-overpressurization of the RCS exists. The;e valves will be full stroke exercised during refueling outagas.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C valves 11-12SJ34,11-14SJ139,11-14SJ156, and 11-14SJ141 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 shutdom) 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.

6 28

d. Relief Request The licensee has requested specific relief from exercising Category C valves 11-14SJ55, safety accumulator discharge checks, in accordance with the requirements of Section XI and proposed to pa- tial stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

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 Section XI.

Evaluation We agree with the licensee's basis and feel temporary relief should be granted for Category C valves ll-14SJ55 from the exercising requiremencs 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.

29

A i

i 4

These valves cannot be full stroke exercised during cold shutdown without the possibility of craating a low

-temperature-averpresvarization condition in the RCS. -

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

4 e.. Relief Roquest

f. The licensee has requested-specific relief from exercising Category C valve 1SJ70, RWST to LPSI r snp

sucticn check, in accordance with the requirements of Section XI and proposed to partial stroke exercise during power cperatien and full stroke during refueling.

Code Requirenent Refer to valve. testing paragraph A. 2.

Licensee's Basis for Requesting Relief

)

Only part stroke exercising is possible during power 7

- 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.

i l' .

30:

Evaluation We agree with the '<1censee's basis and therefore feel relief should be granted for Category C valve ISJ70 from the exercising requirements of Section XI. The licensee has demonstrated 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 l-

!' size of the ' recirculation line. This valve cannot be ,

! full stroke exercised-during cold shutdown without the possibility of creating a low .cmperature-

. overpressurization in~the RCS. We conclude that full stroke' exercising during refueling when the vessel head is removed and the refueling cavity is being filled i

(this provides an adequate expansion volume) shotild demonstrate proper valve op rability,

f. Relief Regi:est i.

The licensee' h'as reg :sted specific relief from exercising Category C valves 11-14SJ56,. safety .e

!. accumulator RHR/LPSI header checks, and 11-14SJ43, ,

, RHR/LHSI checks, in:accordance-with the requirements of

-Section.XI and proposed to-full stroke exercise these

~

[

valves-during refueling outages.

L j Code' Requirement

. Refer-, to valve testing paragraph A.2.

I 4

31-b

l Licensee's Basis for Requesting Relief

~

i- These valves cannot be exercised during power operation or cold shutdown becaute the RHR/LHSI pumps cannot .

overcome RCS operating pressure or cold shutdown pressure. .These valves are full stroke exercised

< during refueling outages- . .

. -t

. Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C -

valves 11-14SJ56 and 11-14SJ43 from the requirements of Section XI. The licensee has denonstrated that these j valves cannot be exercised during power operation or

~

cold shutdown because the RHR/LPSI pumps cannot

~

overcome RCS operating pressure or cold shutdown pressure. We conclude that full stroke exercising ,

thesezvalves dur.ing refueling outages when the RCS is at abnospheric pressure (de;; jn accident pressure)

=should demonstrate.prope- vive operability.

I, j: .I. Spent F0el Cooling

+

k-

!' 1. Category A/E Valves i

a.- Relief Request '

The licensee has; requested specific relief from t exercising Category A/E valves ISF22 and ISF36,' spent

[ fuel cooling Lisolation' valves, . in accordance with the requirements of.Section XI.- ,

T e

i

, 32

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

. . . . - --. .- . . . . . ~ - . . .=

1 l

Code Requirement Ref.. 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 3.6.3.1, Table 3.6-1.

Evaluation We agree with the licensee's basis a'id therefore feel relief should be granted for Category A/E valves ISF22 and 1SF36 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 plant.

Therefore, the operability of these valves is-inconsequential with regard to the safety function wh ich . 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;11.censee has requested specific relief from

, exercising Category A/E valve 1SA118, st'ation' air, 33

containment isolation valve, in accordance with tha requirements of Section XI. -

Code Requirement .

Refer to valve testing paragraph A. 2.

Licensee's' Basis for Requesting Relief Passive valve not required to change position to fulfill it's function. Valve 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 -

relief-should be granted for Category A/E valve 15A118 from the exercising requirements of Section XI. This .

valve .isL in 'it's safety'related position' and 'is not required to open or;close to mitigate.the consequences Lof 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 measurements are meaningless for passive valves.

m S

e

- 34 l. ..

4 K. Wasta Disposal - Liquid

1. Category A/E Valves

a. Relief Request

The licensee has requested specific relief from exercising Category A/E valves 1WL190 and 1WL191, reactor cavity to spent fuel cooling pump containment isolation, in accordance with the requirements of Section XI.

2 Code Requirement j Refer to 931ve testing paragraph A. 2.

Licensee's Basis for Requesting- elief Passive valves not required to change position to fulfill their function. Valves are kept locked shut r .per Technical Specification 3.6.3.2.d, Table 3.6-1.

Evaluation i

We agree-with the licensee's basis and therefore feel l rt llef should be granted for Category A/E valves 1WL190 and 1WL191 from the requiremc- ts of Section XI. These ,

l-valves are.in their safety.related position and.are not l -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 l . Inconsequential with regard to the safety function

! which they perform. We conclude that the quarterly

- stroke and stroke time measurenents. are meaningless for passive 1 valves.

^ 35

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

IV. Attachment I A. The following Category A, A/C and A/E valves are currently being leak tested per Technical Specific ation 4.6.1.2.d (Appendix J) '

instead of Section XI.

ICV 3, 4, 5, and 7, reactor coolant letdown isolations ICV 68 and 69, regen heat exchanger isolations ICV 74, regen heat exchanger-isolation ICV 116 and 284, RCP seal water isolations ICV 296, seal water line overpressure protection isolation ICC113 and 215, excess letdown isolations 1CC117,118.131,136,187 and 190, CC to RCP isolations ICC186 'and ?]8, overpressure protection isolations 11 and 12CA330, control air isolations

~

1DR29, -demin water isolation .

1FP147, fire protection isolation 11-14GB4, S/G drain and blowdown isolations -

INT 25 and 26, N to the PRT isolations 2

-1NT32, N to S.I. . accumulators isolation ~

2 1PR17 and 18, PRT 'and gas analyzer isolations 1SJ53, 60, and'123, S.I. test line ISS27, 33, ~ 49 and - 64, primary sampling isolations 1SS103,104,107, and 110, primary sampling isolations11-14SS94, S/G drain'and blowdown isolations-IVC 1-6, containment ventilation isolations IVC 7, 8, 11,'and 12, containment sample isolations 1WL96 and 97, RCDT sample isolations

-1WL98, 99, and 108, PRT to waste gas isolations 1 1WL12 and 13, RCDT pump isolations 1WL16 and 17, containment sump pump isolations 1WR80 'and 81, PRT supply 'and RCP head tank -isolations -

-36

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

, exempted from leak rate testing by Technical Specification Table 3.5-1.

11-14CV98, RCP seal water throttle valves11-14SS93, S/G sample isolations ISF22 and 36, tpent fuc1 cooling isolations 1SA118, station air isolation 1WL190 and 191, reactor cavity to SPC pump isolations C. The following valves should be reviewed by the NRC Appendix J red iaw conmittee to determine if they should be categorized A, A/C or A/E and tested in accordance with the requirements of Section XI.

IVC 9,10,13 and 14, containment sample isciations. (These valves are currently exempted from leak testing by Technical Specification.)

9 37

f V. Attachment II The following are Category A, B, and C valves that meet the requi ements 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. EGMi 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 tne 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 11 through 14AF23, auxiliary feedwater heace* checks, cannot be exercised during power operation.

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

.These valves are full stroke exercised during cold shutdown.

2. - Category C valves 11-12AF4 and 11-12AF8, ' 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 valv'es with cold (auxi.llary feedwater would thermally shock l the . feed nozzles resulting in feed - nozzle damage. 12AF4 -

are partial ' stroke _ exercised dur.ing power operation through

-the recirculation' test line. All valves'are full stroke-

-exercised _during cold shutdown.

L e

138 -

L

B. Steam Generator Feed and Conjensate

1. Category C/E valves 11 through 14BF22, 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 valves will be full stroke exercised during cold shutdowns.

C. Chemical and ' Volume Control

1. Category A valve ICV 7, reactor coolant letdown containment isolation, cannot be exercised during power operation.

Exercising this valve would isolate normal letdown flow through the regenerative heat exchanger causing the

. injection of cold wate.- into 'the RCS resulting in thennal cycling-of injection nozzles and possible cracking damage.

'This valve is full stroke-exercised during cold shutdown.

~

2. Category A valves ICV 68 and 69, regenerative heat exchanger containment isolations, cannot-be exercised during power

cperation. fIf these valves. failed 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 ~1CV116 and 284, reactor. coolant pump seal l 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.

@~ ;

'39 -

- . - . . - ___ - .. ~ . -- __

4. Category A/C valve 1CV74, regenerative heat exchanger containuent isolation, cannet be exercised during power cperation. Shutting this valve during power operation would -

.cause a loss of pressurizer level control and a reactor trip '

j. would result. This valve is full stroke exercised during cold shutdown.

5. Category A/C valve.lCV296, 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 ICV 40 and 41, VCT ' outlet isolations, cannot be exercised during power operation. Closing these valves duringlpower operation requires lining up the- .

i alternate source of water from the refueling water. storage I

tank to the suction of the charging pumps.- This is '

2,000 ppn borated water which would render the reactor _;

subcritical. These valves are exercised during cold.

shutdown.

_ 7. - Category C valve ICV 42, VCT outlet suction check, cannot' be exercised during power. operation. Exercising (closing) would. result in a loss of normal 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.

L

.This valve is full stroke exercised during cold shutdown.

4 I

1 e

I 40 F _

8. Category C valves 11 through 14CV39, RCP seal water check valves, and category A/E valves 11-14CV98, RCP seal water throttle valves, c'nnot be exercised during power operation without securing seal water to an RCP result'eg in a loss of G

an RCP and requiring a reactor trip. These valves are full stroke exercised during cold shutdown.

9. Category C valve ICV 176, rapid boration check, cannot be exercised during power operation. Testing during power operation would requi.'s injecting highly borated water into the RCS resulting in a reactor shutdown. This valve is full stroke exercised during cold shutdown.

D. Component Cooling

1. Category A valves ICC117, 118, 131, 136, 187, and 190, CC to RCP supply and return containnent isolations, cannot be exercised during power operation because if the va!<es

. failed shut a loss of RCP cooling would occur requiring the RCP be secured and thus requiring a reactor trip. T1.ese valves are exercised during cold shutdown when RCPs are secured.

2. Category A/C valves ICC186 and 208, overpressure protection f or containment isolation piping, cannot be exercised during power operatien 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 RCP: are secured.

G 41 m

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

4-E. Containment Spray i

l. Category B valves 11 and 12CS36, LPSI to containment s.: ray, -

cannot be exercised during power operation. ' ese valves

' are interlocked shut with 11 and 12SI44, containnent sump suction isolations. These valves are full stroke exercised during cold shutdown.

.l F. Main Stern

1. Category B. valves, 11 throug- 14MS167,r 41n steam isolation valves,' and 11 througn 14MS169_and 11 t hrough 14MS171,

l. backup valves for . shutting main steam isolations, cannot be i

i exercised during power operation. Shutting one main steam valve will cause a steam flow / feed flow mismatch in the corresponding SG because tho steam flow would go to zero.

This would cause a reactor trip.- Testing the shutting .

. backup valves would result in the associated main steam

1",olation valve closure. :These valves are full stroke exercised during the startup following cold shutdown.

,. G. Residual Heat-Removal-

ategory B valves 1RH1 and.2, RHR injection not leg

.- l .

t isolations,' cannot be exercised during power operation.

These valves are F essure interlocked shut and cannot be ,

j opened when RCS pressure iT greater than 530 psig. These valves are full stroke exercised during startup following a

cold shutdown.

t <

O s

f 1 /

t 7

'42 m.

E

T J

2. Category B valve IRH26, RIR 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. "

H. Safety Injection

1. Category B valves ISJ1.and 2, RWST to charging pump suction isolations, cannot be exercised during power operation without : injecting 2000 ppm boron into the RCS resulting in a reactor snatdown. These valves will be exercised during J-cold shutdown.

2. Category B valves-1SJ4 and 5, E!T inlet isolations, cannot be' exercised. during poker operation. Opening these valvcs-

,:.- during power' operation would dilute the BIT below 20,100 ppm I

- 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

~

shutdowh.

'3. Category B valve 1SJ30, RWST' to .SI pump suction isolation,

~~

cannot be exercised during power' operation. Stroking.this

avalve requires isolating the suctions of both safety

inj ection~ pumps from the RWST. Failure of this valve would l . disable both ECCS trains. Th's valve is full stroke

- exercised during cold. shutdown.

4

+

b ~

4 43 22

4. Category B valves 11 and 12SJ44, SI pump suction contaimnent isolations, cannot be exercised during power operation because .if a valve failed, containment integrity would be breached to initiate a repair to the valve and the reactor ,

would have to be shut down. These valves will be exercised during cold shutdown.

5. Category B valves 11 and 12SJ45, LPSI pump discharge to the SI and HPSI pumps, cannot be exercised during power operation because the 11 and-12SJ44 must be opened to exercise-these valves due to interlocks between them. See relief request for 11 and 12SJ44. These valves will be exercised during cold shutdown.

i

6. Category B valve ISJ69, LPSI pumps suction isolation, cannot be exercised during power operation. This is a passive-

~

7 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 ISJ135, SI pump discharge to RCS cold legs, cannot be exercised during power operation because if it fails shut during testing cold-leg injection would be isol ated. This valve will be full stroke exercised dt, ring cold shutdown.

G 44

l

8. Category B valves 11 through 14SJ54, accumulator outlet

isolations, cannot be exercised when the accumulators are at a

nonnal pressure and the RCS is 1000 psig to prevent a possible low temperature-overpressurization of the RCS.

, These valves will be stroke timed and exercised while:

a. The accumulators are at normal pressure and RCS 1000 psig. ,

L

b. The accumulators are depressurized and the RCS is 1000 psig.

4

. 9. Category C valve ISJ3, prevent backflow from the VCT to the I RWST check, cannot be exercised during power operation. In order to test this valve ISJ1 or ISJ2 must be opened. ISJ1 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.

i I.. Service Water

1. Category C valves 11 and 12SW51, 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 f an coil -

units. This places the plant in a limiting condition for operation (Technical Specification 3.6.2.3). These valves '

i will be full stroke exercised daring cold shutdown.

2. Category C valves 11 and 125W79, 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 exercised during cold shutdown.

J. Ventilation Containment

1. Category A valves IVCl through 6, contalanent ventilation isolations, need not be exercised during power operation.

These valves are passive during power operation. They cannot be opened per connitment to rRC in LER 50-272/79-55/0lT. These valves will be exercised during cold shutdown.

'e a

46

VI. Attachment !!!

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

System P&lD Rev.__

Auxiliary Feedwater 205236 4 Steam Generator Feed and Condensate 205202 10 Chemical and Volume Control, Boric Acid 205229 7 Recov^ry Chemical and Volume Control Operation 205228 8 Chilled Water 205216 12 Component Cooling 205231 10 Contehunent Spray 205235 6 Reactor Containment and Penetration 205247 12 Area Control Air Deminer.lized Water Restricted Areas 205246 6 Fire Protection 205222 9 Steam Generator Drains and Blowdown 205225 7 Main Reheat and Turbine Bypass Steam 205203 12 Reactor Coolant 205201 9

- Residual Heat Removal 205232 6 Safety In section 205234 10

, Sanpling 205244 5 Service Water Nuclear Area 205242 11 Spent Fuel Cooling 205233 6 Compressed Air 205217 9 Reactor Containment Ventilation 205238 8 Waste Disposal Liquid 205239 8 Chemical and Volume Control, Primary 205230 7 Water Recovery i

1 s

9 47

man VII. Attachment IV A. The following valves are never full stroke exercised cr have a testing frequency greater than each refueling outage:

1.11-12CS21, Spray additive tank checks 11-14SJ55, S3 cty accumulator discharge checks 9

4 9

48