ML20087B559

Technical Evaluation Rept Pump & Valve Inservice Testing Program,Ja Fitzpatrick Nuclear Power Plant

ML20087B559
Person / Time
Site:	FitzPatrick
Issue date:	12/31/1991
From:	Hartley R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20087B492	List: ML20087B559
References
CON-FIN-A-6812 EGG-NTA-9782, TAC-M74766, NUDOCS 9201130167
Download: ML20087B559 (61)

Text

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

'. '. ENCt.05URE 2 EGG NTA 9782 I

TECHNICAL EVALUATION REPORT l PUMP AND VALVE INSERVICE TESTING PROGRAM JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 1

i R. S. Hartley i I

Pr" ished December 1991 Idaho National Engineering Laboratory-EG&G Idaho,- Inc. [

Idaho Falls, Idaho. 83415  !

Prepared for the -

U.S. Nuclear Regulatory Cosnission. -

Washington D.C. 20555-  :

Under DOE Contract No.-DE-AC07-761001570 FIN No. A6812 TAC No. 74766-9201130167.920108 PDR ADOCK 05000333. .

P -PDR. m

i

. e i 1

1

. i i

ABSTRACT  !

This report presents the results of our evaluation of relief requests for the James A. FitzPatrick Nuclear Power Plant inservice testing program for i safety related pumps and valves.

[

PREFACE This report is supplied as part of the " Review of Pump and Yalve Inservice Testing Programs for Operating Reactors (Ill)" program conducted for -

the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, ,

Mechanical Engineering Branch, by EG&G Idaho, Inc., Regulatory and Technical  :

Assistance Unit. .

t 4

,t I

i T

FIN No. A6812 B&Rs'20 19 05 02 0 -

- Docktt No. 50 333-TAC No. 74766 11 t

- ,,c .-, - . - - - ,,, ,.,,---na, - - - - . - -- e--., -..-n- n +

,,,.:.y,,---,.,..ns . . , . . . . n , ...-, - ,,-n-.,v. , , --,n-.

CONTENTS 11 -

A B S T RA C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

PREFACE ................................................................ 11

1. INTRODUCTION ..................................................... I

2. PlH P T E S T I N G P ROG RAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1 Gene ral Pump Rel ief Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1.1 Inlet Pressure Measurement ........................... 3 2.1.2 Vibration Measurecent Location ....................... 4 2.1.3 Bearing Temperature Hessurement ...................... 6 2.1.4 Vibration Measurement ................................ 7 2.1.5 Instrument Ranges .................................... 8 2.1.6 Liquid in Gage Lines ................................. 9 2.2 Standby Liquid Control System .............................. 10 2.2.1 Relief Request ....................................... 10 2.2.2 Relief Request ....................................... 11 2.2.3 Relisf Request ....................................... 12 2.2.4 P.e' af Request ....................................... 12 2.3 High Feessure Cool ant Injection tystem . . . . . . . . . . . . . . . . . . . . . 13 2.3.1 Reliaf Request ....................................... 13 2.4 Core Spray System .......................................... 14 2.4.1 Relief Request .......,............................... 14 2.5 Eme rgency Se rvice Wate r Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 2.5.1 Relief Request ....................................... 15

3. VALVE TESTING PROGRAM ............................................ 17 3.1 General Valve Relief Requests .'............................. 17 3.1.1 Excess Flow Check Valves ............................. 17 3.1.2 Cold Shutdown Valve Te sting . . . . . . . . . s . . . . . . . . . . . . . . . . 18 3.1.3 Valve Leak Rate Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.2 Reactor Water Recircul ation Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . 20 3.2.1 Category A/C Valves ................................., 20 tii

g .

b 3.3 Reactor Core Isol ation Cooling System . . . . . . . . . . . . . . . . . . . . . . 21 3.3.1 Category A/C Valves .................................. 21 3.4 Reactor Building Cooling Water Systes ....................... 22 3.4.1 Category A Valves ..................................... 22 3.4.2 Category A/C Valves ................................... 22 3 . 4 . 3 C a t e g o ry C V al v e s . . . . . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . 23 3.5 feedwater System ............................................ 25 25  !

3.5.1 Category A/C Valves ...................................

3.6 Breathing, Instrument, and Service Air System ............... 26 ,

3. 6.1 C a t eg o ry A/C V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 i

3.7 Service Water Systew ........................................ 27 6 3.7.1 Category B Valves ..................................... 27 3.8 High Pressure Coolant Injection System ...................... 27 3.8.1 Category A/C Valves ................................... 27

3. 8. 2 C at ego ry C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 3.9 Peergency Service Water System .............................. 29 ,

3.9.1 Category A/C Valves ................................... 29

3. 9. 2 Ca tego ry B V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 3.10 Automatic Depressurization System / Main Steam ...... ........ 31 3.10.1 C at ego ry B Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 3.10.2 Category B/C Valves .................................. 32 3.10. 3 C at ego ry C V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . - . . . . . . . . . 33 3.11 Re s idual Heat Removal Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 3.11.1 C a t ego ry C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 3.11.2 Category A/C Valves ........................,......... 34 3.12 Containment Atmosphere Dilution System ...................... ,

39 3.12.1 Category A/C Valves .................................. 39 3.13 . Core Spray Systca ........................................... 41 3.13.1 Category C Valves .................................... 41 tv

3.14 RHR Service Water System .................................... 42 3 .14 .1 C a t e g o ry B V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 -

3.15 Traversing In Core Probe (TIP) System ....................... 44 3.15.1 C a t eg o ry A V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 APPENDIX A IST PROGRAM AH0KAllES ........... ........................... A1 a

y

JECHNICAL EVALUATION REPORT PUMP AND YAlyE INSERVICE TESTING PRMPRI JAMES A. FITZPATRICK NUCLEAR POWER PLANI ,

1. INTRODUCTION This is a technical evaluation of certain relief requests from the pump and valve inservice testing (IST) program for James A. FitzPatrick Nuclear Power P3 ant submitted by New York Power Authority (the Authority).

The licensee submitted these relief requests in revision 4 of the IST program transmitted to NRC by a lester dated September 27, 1991. This program covers the second ten-year IST interval, which runs from July 1985 to July 1995. The relief requests pertain to requirements of the American Society of Mechanical Engineers (ASHE) Boiler and Pressure Vessel Code (the Code),

Section XI, 1980 Edition through Winter 1981 Addenda and 10 CFR 50.55a.

The Authority requested relief from the ASME Code testing requircrents for specific pumps and valves. These requests are reviewed using the acceptance criteria of the Standard Review Plan, Secticn 3.9.6, NRC Generic 1.etter No. 89 04 (GL 89 04), ' Guidance on Developing Acceptable Inservice Testing Programs " and 10 CPR 50.55a.

These TER relief request evaluations are applicable only to the components or groups of components identified by the submitted requests. These evaluations may not be extended to apply to similar components that are not identified by the request at this or another com) arable facility without separate review and approval by NRC. Further, tie evaluations and recommendations are limited to the requirement (s) and/or function (s) explicitly discussed in the applicable TER section. For exampla, the results of an evaluation of a request involving testing of the containment isolation function of a valve cannot be extended to allow the test to satisfy a requirement to verify the valve's pressure isolation function, unless that extension is expiteitly stated.

Section 2 of this report presents the Authority's bases for requesting relief from the requirements for pumps followed by an evaluation and conclusion. Section 3 presents similar information for valves.

Appendix A lists program inconsistencies and omissions, and identifies needed program changes. '

1

-w G... ___.2ma+_ A 1 --e++w a' ar --m*- wM- -- -r_.m.Ay_ a4.A_A4m,.x 4 A. A L._.M uh4y4 J,2__4m.uA. 4.adi-.3,a,-mm 4a._ .a ,4,__,,4 4 - 0 A 4 0

e 1

l 9

P s

D b

o 4

A e

2

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

. 2. PUMP TESTING PROGRAM ,

The following pump relief requests were evaluated against the

• requirements of the ASME Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A sunnary and the licensee's basis for each relief request is presented. The evaluation and recommendation follow. The requests are grouped according to topic or system.

2.1 General Pumo Relief Reagn11 2.1.1 Inlet Pressure Measurement 2.1.1.1 Relief Reauest. Note P2 requests relief from directly measuring inlet and differential pressure per the requirements of Section XI, Paragraph IWP 3100 and Table IWP 3100-1, for the residual heat removal service water (RHRSW) and emergency service water (ESW) pumps, RHRSW 10P 1A, 18. -10

10. ESW 46P-2A and 28. The licensee proposes to measure the elevation difference between the forebay water level and discharge pressure gauge and to ensure each pump has adequate suction pressure available. The licensee also  ;

proposes to use the measurement to calculate differential pressure.

2.1.1.1.1 Licensee's Basis for Reauestina Relief. These pumps are of _ a vertical submerged open line shaf t design. There is no installed instrument for direct measurement of the inlet pressure. Instead, the stuimum -

pumping level is monitored to insure adequate net positive suction head (NPSH) is available for pump operation. Since the forebay water level is not expected to change significantly during the testing of these pumps, only one measurement is required.

Alternate Testina. During each test, the difference in elevation tietween the i forebay water level and the pump discharge pressure gauge will be determined by measurement to the nearest foot, which corresponds to approximately 0.5 psi. This value will be verified to be less than or equal to the value corresponding to the minimum water level required for pump operation and will also be used to calculate pump differential pressure.

2.1.1.1.2 Evaluation. These submerged, vertical line shaft pumps provide emergency cooling water to various heat exchangers and back u) injection points. Instruments are not installed on the pus.ps or in tie inlet bay to directly measure suction or differential pressure. Therefore, direct measurement is impractical. Significant system design changes and modification or replacement of eculpment are needed for direct measurement.

These changes would be costly anc burdensome to the licensee.

Inlet pressure for these pumps is due to the height of water above the suction point and can be calculated accurately. This is a relatively simple calculation. It is not impractical or burdensome. The licensee counttted to ensure that adequate NPSH is available by measuring the height of water above the suction point. Adequate NPSH is important for pump operation, but not a factor in detecting changes in pump condition. Differential pressure, however, is an important factor for evaluating pump condition. An accurate 3

. i i

calculation will allow an adequate assessm9nt of pump conc..,:on as required by the Code.

~

Since calculating pressure is not impractical or burdensome, relief should be granted from directly measuring inlet or differential pressure provided these parameters are calculated and the calculation meets the accuracy requirements of Table IWP 4110-1 for direct measurements (12%).

2.1.2 Vibratten Measurement location 2.1.2.1 Relief Reauest. The licensee requests relief in Note P9 from the location of vibration measurement requirements of Section XI, Paragraph IWP-4510, for the RHRSW purps, 10P-1A, -1B, -1C. lD, and ESW pumps, 46P 2A and 2B, The licensee proposes to measure vibration on the lower motor bearing housing in a plane perpendicular to the shaft in the ' vertical

• and

' horizontal" directions and record the larger of the two measurements.

2.1.2.1.1 Licensee's Basis for Reauestina Relief. These pumps are of a vertical submerged open lint shaf t design with the pump bearings submerged and inaccessible balow the floor. The bearing housing near the upper coupling, which is accessible, is in a confined area in close proximity to the rotating shaft and is considered to be a safety hazard for personnel taking vibration measurements. Adjacent to this area is the lower motor boaring whose housing is freely accessible for locating a vibration probe.

This location will provide a satisfactory means, to the extent practical, for monitoring motor and pump shaft vibration in a consistent manner for data evaluation as required by the Code.

Alternate Testina. The required vibration measurements for these pumps will be taken at the lower motor bearing housing in a plane perpendicular to the shaft. (See Relief Request Note P15) 2.1.2.1.2 Evaluation. These submerged, vertical line shaf t pumps provide emergency cooling water to various heat exchangers and back-up injection points. The lower pump coupling bearings re located below the pump support structure floor level. They are inaccessible during testing.

Therefore, direct measurement of vibration at the Code specified location is currently impractical. To require immediate compliance with the Code would be costly and burdensome. An Electric Power Research Institute (EPRI) report.

EPRI NP-5704H, "On Line Vibration Monitoring for Submerged Vertical Shaft Pumps,' was issued in March 1988. It disedsses problems associated with assessing pump condition based on vibration measurements taken solely at remote locations. The report also suggests methods for monitoring vibration on submerged pumps. .

Pump-related vibration levels measured at the upper motor thrust bearing housing can be significantly attenuated by intermediate materials. Pump vibration can also be masked by motor vibrations. These effects make it difficult to evaluate pump mechanical condition based on readings taken at the upper motor thrust bearing housing. Yet, this is generally considered the best available location for remotely measuring vibration to assess the mechanical condition of submerged pumps. The ASME/American National Standards 4

. i Institute (ANSI) Standard, " Operation and Maintenance of Nuclear Power Plants, ASME/ ANSI OH-1988a " Part 6, allows measurement of vibration on the upper motor 'c: earing housing of vertical line shaft pomps. Part 6 also specifies the

• number and location of measurements, acceptance criteria for vibration displacement and velocity, instrument accuracies, and other program as:ects.

The NRC approves the use of Part 6 vibration testing requirements in tieir entirety.

The upper motor thrust bearing housing is accessible in this case. But, the licensee states that its location in a small space and proximity to the rotating shaft ) resents a personnel safety hazard during pump o)eration.

There are many lazards associated with plant opeiation. These iazards or hardshi)s must be weighed against the value of testing. The licensee has not shown t1at the hardship of the test outweighs the test's value. Neither has the licensee indicated the difficulty of reducing hazards to acceptable levels. The licensee should evaluate ways to improve test personnel safety so that data can be gathered from this location, if needed.

The licensee proposes to measure vibration at the lower motor bearing housing. The housing is readily accessible and provides repeatable measurements for trending. However, the proposed measurement location is remote from the sumps. The measured vibration levels attributable to the pump might be lower t1an the actual pump levels, as discussed above and in the EPRI re) ort. The Code specifies alert and required action levels applicable to vi) ration measurements taken at the pumps. These acceptance criteria might not be appropriate for measurements taken as )roposed. To justify using the proposed measurement locations, even in the $1 ort-term, the licensee must show that the measurement location and acceptance criteria will adequately assess pum) condition. This implies that the correlation of measured vibration data wit 1 actual pump conditions is known and that the acce)tance criteria will require corrective action prior to pump failure, if tie relationship between these-is unknown, then the proposed location and acceptance criteria might not be justified (or suitable) for this application.

The proposed method is not shown to be adequate for assessing pump operational readiness. Therefore, for the short-term interim period of six months after issuance of this TER, the licensee must do one i' the following:

(1) justify the proposed measurement location, method, and acceptance criteria, (2) measure vibration on the upper motor thrust bearing housing per all the applicable requirements of Part-6 for vibration measurement, or (3) justify some other alternative to the Code that adequately assesses operational readiness of these pumps (during this interim period).

In the long-term, that is within one year of issuance of this TER, the licensee should investigate alternate methods, such as attaching accelerometer or displacement probes to the pumps (as described in the EPRI report), that allow an adequate assessment of pump operational readiness. Alternately, if the licensee can show that measuring vibration at the proposed location and applying Code specified vibration acceptance criteria is equivalent to or provides a reasonable long term alternative to the Code, this inforsation should be provided to justify granting relief.

5

Based on the determination that compliance with the Code test method is impracticable and burdensome, and considering the proposal, interim relief should be granted with the above stated short and long term provisions. The '

licensee should address and provide a s:hedule for resolving these issues within six months and one year, respectively, after issuance of this TER.

2.1.3 Bearino Temoerature Measurement 2.1.3.1 Relief Reouett. The licensee requests relief in Note P14 from measuring bearing temperatures per Paragraph IWP 4310, for all pumps in the IST program. The licensee proposes to measure vibration per IWP 4500 and per their Relief Request Note P15.

2.1.3.1.1 Licenige's Basis or Reauestino Relief. The data associated with bearing temperatures taken at one-year intervals provides little statistical basis for determining the incremental degradation of a bearing or any meaningful trending information or correlation. In many cases pump bearings are water-cooled and thus, bearing temperature is a function of the temperature of the cooling medium, which can vary considerably. Vibration measurements are a sigalficantly more reliab'.e indication of pump bearing degradation than are temperature measurements. All pumps in the program are subjected to vibration measuremen ) in accordance with IWP 4500. Although excessive bering temperature is an indication of kn imminent or existing bearing failure, it is highly unlikely that such a condition would go unnoticed during routine surveillance testing since it would manifest itself in other obvious indications such as audible noise, unusual vibration, increased motor current, etc. Any potential gain from taking bearing temperature measurements, which in most cases would be done locally usirg portable instrumentation, cannot offset the cost in distraction of operators from other primary duties, excessive operating periods for standby pumps, and unnecessary personnel radiation exposure.

Alternate Testina. Vibration monitoring will be perfonned in accordance with IWP 4500 and Relief Request No. Note P15. Such vibration monitorbg will provide adequate monitoring of and evaluation of the material condition of the pump bearings.

2.1.3.1.2 Evaluation. The licensee requests relief from the Code requirements for annual bearing temperature measurement for all pumps in their IST program. It is recognized that annual measurement of pump bearing temperature does not aid in the detection of bearing degradation since it shows bearing degradation only in severe cases. The licensee is measuring pump vibration quarterly, which is more likely to show bearing degradation.

Annual measurement of pump bearing temperature presents a hardship to the licensee without a compensating increase in the level of quality and safety.

The licensee's proposal provides a reasonable alternative to the Code requirements.

Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements and since the hardship of compliance would not be offset by a compensating increase in safety, relief should be granted as requested.

6

2.1.4 Vibration Measurement 2.1.4.1 Relief Reauest. The licensee requests relief in Note P15 from measuring pump bearing vibration per IWP 4500 for all pumps in the IST program. The licensee proposes to measure vibration in either displacement or velocity units and comply with the acceptance criteria of OMb 1989, Part 6, Tables 3 and 3a. Test data will be evaluated per IWP 3100, 2.1.4.1.1 Licensee's Basis or Re m stina Relief. Measuring vibration in velocity units rather than displacement is an industry accepted practice considered to be more sensitive to small changes that are indicative of developing mechanical problems. Velocity measurements detect both high-am>11tude vibration, characteristic of major mechtnical problems, and low-vi) ration, caused by misalignment, imbalance, or minor bearing wear. 1 *. i s impractical to search for the direction with the largest deflection and procedurally return to that precise location Sn successive tests. in addition, the direction of maximum deflection may vary with the condition and age of the pump thus eliminating consi:tency between test data. Adapting this requirement to test procedures could cause confusion as to the proper locations for measuring pump vibration. Also, comparing subsequent test data to reference test data taken at different locations does not provide a good measure of pump degradation.

ASME/ ANSI OMa-1987, Operation and Maintenance Of Nuclear Power Plants, Part 6, Section 4.6.4 has adopted the concept of measuring vibration at two mutually perpendicular locations for inner pump bearings and comparing subsequent test data to the reference value at that specific location.

Measuring vibration in velocity units is permitted by the most recent version of OHb 1989 - Standard for Inservice Testing At Nuclear Power Plants, Part 6.

Alternate Testino. Pump vibration measurements may be taken in either displacement or velocity units. Acceptance criteria for velocity measurements will conform to those set forth in OMb 1989, Part 6, Tables 3 and 3a. For centrifugal and rotary (non reciprocating) positive disp 1 m ment pumps vibration readings will be taken in a plane perpendicula, o the operating shaf L in two (2) mutually perpendicular directions. Test Jata shall be evaluated per IWP 3100 with successive vibration readings compared to reference values previously taken at that specific location.

2.1.4.1.2 Evaluation. There are distinct advantages of using a program l employing measurement of vibration velocity for evaluating the mechanical c.ondition of certain pumps. For pumps with 4 high rotating shaft speed, vibration velocity can better assess condition than displacement. This is widely acknowledged in the industry. A comprehensive pump testing program, such as that in OM 6, using vibration velocity readings taken over a wide frequency range can provide a great deal of information about pump mechanical condition that could not be obtained by using vibration displacement readings.

7

The licensee proposes to measure either vibration velocity or displacement'and to use the aseptance criteria of OMb-1989, Part 6. The licensee also specified the location of measurements. The locations are different from those specified in OH 6. For example, the licensee proposes to -

measure vibration in 2 mutually serpendicular directions rather than in three directions (one the a.dal on eac1 accessible thrust bearing). This approach is not shown to be justtfied. The vibration testing program in OH 6 specifies instrument renuirements ar.J many other attributes that are not addressed in the licensee's proposal. Additional inforaation is needed to fully evaluate and approve the proposed propam with its differences from the program in OH-6. If specific requirements of OH-6 are deemed impracticable, the licensee should develop and propose alternates tnat give an adequate assessment of pump condition.

A pump vibration measurement prcgram perfomed in accordance with the applicable ASME/ ANSI OMb-1989, Part 6, vibration testing requirements is acceptable to NRC. It gives an adequate level of quality and safety and provides a reasotable alternative to the Code.

Relief should be granted to use the vibration program as stated in OH-6 provided all stipulations relative to vibration measurement are followed.

2.1.5 Instrument Ranaes 2.1.5.1 Relief Reauest. The licensee requests relief in Hote Pl7 from the instrument range requirrnents of IWP-4120 for various pumps in the IST program. The licensee proposes to use digital instruments whose range exceeds the Code, but whose accuracy is independent ci the instrument range.

2.1.5.1.1 Licensee's Basis or Reauestina Relief. In several instances instruments used to measure pump parameters use digital readouts.

Although these instruments are highly accurate and suitable for use, they are virtually unlimited in range and thus do not meet the Code requirement.

ASME/ ANSI -1987, Part 6, Paragraph 4.6.1.2 allows the use of digital instrument. J limiting provisions.

Alternate Test ;. Digital instruments may be used during pump testing provided that the reference value shall not exceed 70% of the calibrated range of the instrument. Digital instruments shall have an accuracy of 12% (15% for vibration) over the calibrated range of the instrument.

2.1.5.1.2 Evaluation. The licensee proposes to utilize digital instruments with an accuracy of 12% (15% for vibration) of the indicated reading. This accuracr is independent of the instrument full-scale range and might exceed three times the reference value. Adoittonally, the digital instrument will be used only if the reference value, for the measured parameter, does not exceed 70% of the calibrated range of the instrument.

The proposal allows an adequate assessment of component operational readiness and provides a reasonable alternative to the Code requirements, it would be a hardship to require the licensee to purchase digital instruments 8

i i

meeting the full-scale range requirements. This hardship would not be offset by a commensurate increase in safety.

Based on the determination that the proposal provides a reasonable -

alternative to the Code requirements and compliance with the Code wot.ld be a hardship without a compensating increase in the level of safety, relief should be granted as requested.

2.1.6 Liouid in Gaae lines 2.1.6.1 Relief Reqmi. The if censee requesti relief in Hote P16 from the requirements of IWP-4210 to determine the presence or absence of liquid in suction pressure gage lines for various pumps in the IST program. The licensee proposes to ensure the presence or absence of liqu'd in a gage line, as required by IWP-4120, if it could produce a difference of more than 0.25%

in the calculated valua of the pump differential pressure.

2.1.6.1.1 Licensee's Basis or Reauestina Relief. When this requirement is applied to the measurement of pump suction pressure where measured pressures are at relative low levels, the 0.25% limit is overly restrictive and oftentimes results in complicated venting procedures and unnecessary health physics risks associated with handling and disposal of radioactive contaminated water with no commensurate gain or improvement of test reliability.

Norm:dly, the only quantitative t.se of suction pressure measurements, where significant accuracy is required, is in determining pump differential pressure or head. In most cases the pump discharge pressure exceeds the suction pressure by at least a factor of 5. This being the case, a 0.25%

error introduced into the suction pressure measurement results in an error of 0.05% in the differential pressure calculation. This is insignificant in light of the potential 6% error allowance applied to botn the suction and discharge pressure instruments (Ref lWP-4110).

Alternate Testina: If the presence or absence of liquid in a gage line, used for sensing pump suction pressure, could produce a difference of more than 0.25% in the calculated value of the pump differential pressure, mear.s shall be provided to ensure or determine the presence or absence of liquid as required for the static correction used.

2.1.6.1.2 Enlation. For pumps with a large discharge pressure to suction pressure ratio (high head pump') small error in inlet pressure has little effect on the measured value of di;ferential pressure. Venting might be needed to comply with ttc subject Code requirement (to evaluate the line contents). This procedure is time consuming and constitutes a hardship on the licensee. The hardship of meeting this requirement would not be offset by a compensating increase in safety for pumps with a high pressure ratio, as discussed above. The licensee proposes to perform ths procedure of IWP-4120 (which might require some system modifications) only if the presence or absence of liquid in the gage line could cause a difference of >0.15% in the value of differential pressure. This proposal allows an adequate assessment 9

. =

of pump operational readiness and provides a reasonable alternative to the Code.

Based on the determination that the licensee's proposal provides a -

reasonable alternative to the Code and that the hardship of complying with the Cc,de would not be offset by a compensating increase in the level of safety, relief should be granted as requested.

2.2 Standby Liouid Control System 2.2.1 Relief Reauest. The licensee requests relief in Note P7 from the pump run time and direct measurement of flow rate requirements of Section XI, Paragraph IWP-3500 and Table IWP-3100-2, for the standby liquid control (SLC) pumps, SLC llP-2A and -28. The licensee proposes to measure the rate of water level change in the test tank during a two minute test.

NOTE The licensee's proposed acceptance criteria for flow rate are evaluated in Section 2.2.2 of this report.

2.2.1.1 Licensee's Basis for Recuestina Relief. The SLC system is not equipped with a flow meter. The flow rate of the positive displacement SLC pumps is expected to be relatively insensitive to small variations in discharge head. Therefore, it can be measured by monitoring the change of leal in the test tank while water is being pumpcJ into the test tank. The tes, tank has a capacity of 210 gallons which is insufficient for 5 minutes of pumping at rated conditions (250 gpm).

Due to the limitation of pumping time and human factors involved in measuring water level, the accuracy of flow rate measurement cannot be verified to be within 2% required by Code. Historically, the measured flow rates are within 0.93 to 1.09 of reference flow rate, Qr (54.5 gpm).

Alternate Testina. Measure the water level change in the test tank when pumping water into the test tank at rated condition for two minutes. Then convert the level change to flow rate. Evaluate the test result with the following allowable ranges:

a. Acceptable Range -

0.90 to 1.10 Qr.

b. Alert Range - Low - 0.'88 to 0.90 Qr.

- High - 1.10 to 1.12 Qr.

c. Required Action Range - tow - <0.88 Qr. .

- High - >1.12 Qr.

2.2.1.2 Evaluation. These positive displacement pumps inject a borated solution into the reactor coolant system (RCS) for emergency shutdown. Direct measurement of pump flow rate is impractical. The test flow path does not have installed instrumentation. Installation of permanent instruments to meet the Code would require system modtfication. This might be costly and 10

burdensome. Eowever, lack of installed instruments is not a sufficient justification for not meeting the Code. The licensee proposes to calculate flow rate based on a timed change in the test tank level. The accuracy of this technique is not described, but might exceed that required by the Code -

(2%).

The quality of the propored method cannot be fully evaluated with the information provided. The licensee should determine the accuracy obtained from the proposed technique. If changes are made to the test methodology that allow complying with the Code accuracy, then relief should be granted to calculate flow rate. However, if the flow rate calculation is not within the Code accuracy the licensee must show that the accuracy achieved is adequate to assess pump operational readiness and that it provides a reasonable alternative to the Code. If this cannot be done, the licensee should either comply with the Code by installing an instrument to measure flow rate directly or develop and justify another method of evaluat;ng the hydraulic performance of these pumps.

The test flow path is into a tank with a capacity of 210 gallons. These pumps provide approximately 54 gpm each during operation. The configuration makes running these pumps for five minutes impractical since it would over-fill the test tank with borated water. System redesign would be needed to allov tne five minute run. This would be costly and curdensome. The proposal to run these pumps for two minutes allows adequate assessment of their condition and is a reasonable alternative to the Code run time requirement.

Based on the determination that compliance with the Code requirements for pump run time and direct measurement of flow rate is impracticable and burdensome and considering the proposal, relief should be granted provided the flow rate calculation meets the accuracy requirements of Table IWP-4110-1 for direct measurement (i2%). If the licensee cannot meet the Table accuracy, the licensee should comply with the Code or propose and justify, in a relief request, a method for assessing pump operational readiness that provides a reasonable alternative to the Code.

2.2.2 Relief Reauest. The licensee requests relief in Note P7 from the allowable ranges of flow rate per the requirements of Section XI, Table IWP-4110-1, for the SLC pumps, St.C llP-2A and -2B, and proposes to expand these ranges.

2.2.2.1 Licensee's Basis for Reuuestino Relief. See section 2.2.1.1 of this report for the licensee's basis for requesting relief and proposed alternative testing for Note P7.

2.2.2.2 Evaluation. These pumps inject a borated solution into the reactor coolant system for emergency shutdown. The licensee indicates that test results are within 0.93 to 1.09 of the reference flow rate. This wide range of test results indicates a possible problem with the test method or pump condition. Significant pump degradation might exist that is not acted on using the proposed acceptance criteria. The licensee must be able to show that, using the expanded ranges, the pump will remain capable of fulfilling its function.

11

The lic'ensee proposes to expand the flow rate acceptance ranges, as described. However, the relationship between the calculated and actual flow rate through these pumps is not stated. Inconsistencies in the method of -

calculating flow rate can mask changes in pump condition. There is no information provided that shows the proposed ranges will require corrective action when necessary. Acceptance criteria ranges should not be expanded to accomodate data scatter, if that is the case. Since there is no basis provided for these expanded ranges, relief should be denied to use them.

Therefore, relief should not be granted from complying with the Code specified acceptance ranges for pump flow rate.

2.2.3 Relief Reauest. The licensee requests relief in Note P12 from the inlet pressure instrument full-scale range requirements of Section XI, Paragraph IWP-4120, for the SLC pumps, 11P-2A and -2B. The licen re proposes to use existing instruments for measuring inlet pressure.

2.2.3.1 Licensee's Basis for Reauestina Relief. The pump inlet pressure indicators are designed to provide adequate inlet pressure indication when pumping from the SLC storage tank. These instruments have a range of 0-30 psig and are calibrated to 12% accuracy. Thus there is a e tential variation of 10.6 psi due to instrument accuracy. Since the SI: oumps are of the reciprocating positive displacement type, the pump flow rate is not sentitive to differential pressure. In addition, the typical pump inlet pressure (approx. I psi) is less than 0.1% of dP (1279 psi). A variation of 10.6 psi in the inlet pressure will not significantly affect pump parameters.

Alternate Testina. Use existing vendor supplied inlet pressure indicators for the SLC pump flow test. (See Relief Request Note P16) 2.2.3.2 Evaluation. These are positive displacement pumps. Their pressure is dependant on the system pressure into which they are pumping. The discharge pressure is not affected significantly by either inlet pressure (providing adequate NPSH exists) or flow rate. The inlet pressure instrument ranges exceed three times the test reference value. Inlet pressure is about 1 psi. The proposed inlet pressure gage reading inaccuracy might be as great as 10.6 psig. However, the rated discharge pressure of these pumps is 1279 psig. The inlet pressure is so small compared to the discharge pressure that the slight inaccuracy in inlet pressure is meaningless. This will have no appreciable impact on the ability to evaluate the condition of these pumps.

Therefore, the proposal is essentially equivalent to the Code requirement and provides sufficiently accurate data for assessing pump degradation. The proposal provides an acceptable level of quality and safety.

Based on the determination that the licensee's proposal provides an acceptable level of quality and safety, relief should be granted as requested.

2.2.4 Relief Reauest. The licensee requests relief in Note P13 from the vibration instrument frequency response range requirements of Section XI, Paragraph IWP-4520(b), for the SLC pumps, llP-2A and -2B. The licensee 12

i proposes to use existing instruments and to evaluate the results to dettet changes.

2.2.4.1 Licensee's Basis for Reauestina Relief. The speed of the pump .

shaft crank is 520 RPM. For this running speed, the vibration instrument response range required by Code would be 4.3 Hz to 8.7 Hz with accuracy to s5%

full scale meter amplitude. The instruments currently in use for monitoring vibration have a calibrated range of 6 to 500 Hz with accuracy 15% full-scale.

While these instruments are capable of detecting vibration below 6 Hz, they are not calibrated to the Code required 15% accuracy in this range. These instruments provide usable measurements that enable monitoring of changes in pump condition and allow for corrective action to be taken in the event of significant pump degradation - thus meeting the intent of the Code.

Alternate Testino. The vibration measurements will be taken using existing instrumentation and the data evaluated per IWP-3200.

2.2.4.2 Evaluation. These positive displacement pumps operate at low speed. The proposed vibration instrument does not meet the Code accurkey at this low RPM. In Revision 1 of the IST program, submitted by the licensee via letter to NRC dated March 30, 1990, the licensee comitted to obtain new instruments meeting the Code accuracy requirement. Instruments of sufficient accuracy are comercially available. Requiring imediate procurement would be a hardship on the licensee.

The licensee will evaluate the information from tests with current instrumentation to detect changes in pump condition. This gives sone assurance that pump degradation will be detected. However, the vibration measurement is less accurate than required. The Code acceptance ranges are based on Code accuracies. Conservative vibration acceptance criteria should be assigned before the next test. This criteria should be based on the best-estimate of accuracy. Continued operation should not be allowed for pumps with significant degradation that might be masked by the instrument inaccuracy. With these provisions the proposal should give adequate assurance of operational readiness during an interim period of one year. But, this may not be an appropriate long term solution. The licensee should procure instruments that comply with the Code frequency response requirements within one year.

Based on the determination that the proposal, with the specified provisions, provides a reasonable alternative to the Code for an interim period and that the hardship associated wifh imediate compliance would not be offset by a compensating increase in the level of safety, interim relief should be granted from the Code for one year after issuance of this TER.

2.3 Hiah Pressure Coolant in.iection S'vstem 2.3.1 Relief Reauest. The licensee requests relief in Note P10 from measuring inlet and differential pressure per the requirements of Section XI, Paragraph IWP-3100 and Table IWP-3100-1, for the high pressure coolant injection (HPCI) main and booster pumps, 23P-1M and -1B. The licensee proposes to measure and monitor pump inlet and differential pressure for this 13

pump combinat. ion a i an integral unit. Corrective action will be taken on both pumps for test parameter values outside the acceptable range.

2.3.1.1 Licensee's Basis for Reouestino Relief. There are no provisions for ineasuring the pressure in the connecting piping between the HPCI booster pump and main pumps. Since these pumps are driven by a common driver and are connected in tandem, they are tested together simultaneously under the same test conditions (i.e., same flow rate and turbine speed, etc.).

Therefore, measuring the inlet pressure of the booster pump and calalating the differential pressure of both pumps will effectively verify operability and monitor performance of the pair.

Alternate Testino. During IST of these pumps, the suction pressure of the booster pump will be measured and the differential pressure of the pair will be determined from measurements of the suction and discharge pressures of the booster and main pumps, respectively. The results of testing in this manner will be evaluated in accordance with IWP-3200 as if the pair were a single multi-stage pump.

2.3.1.2 Evaluation. These pumps are driven by the same turbine. They are i b rconnected and act as a unit to provide high pressure makeup capab. ty for the RCS. There is no provision for measuring pressure at the discharge of the booster pump, which is the suction point for the main pump.

Also, the flow rate is the same through both these series pumps. It is not practical to test these pumps for hydraulic degradation independently. The licensee proposes to measure and evaluate the differential pressure across both pumps and apply the Code acceptance criteria. Further, the licensee has committed to take corrective action on both pumps if test values are outside the acceptable range. The proposal provides an adequate alternate to the Code. Degradation in hydraulic performance of either or both pumps would be seen as a change in the differential pressure across the combination.

Therefore, the proposal is essentially equivalent to the Code and provides a reasonable alternative.

Based on the determination that the licensee's proposal is essentially equivalent to the Code, relief should be granted as requested.

2.4 Core bray System 2.4.1 Relief Reauest. The licensee requests relief in Note P11 from the inlet pressure instrument full-scale range and accuracy requirements of Section XI, Paragraph IWP-4120, for the core spray (CS) pumps, 14P-1A and -1B, and proposes to use the installed inlet pressure indicators.

2.4.1.1 Licensee's Basis for Reauestina Relief. *The installed CS pump inlet pressure indicators are designed to ;eovide adequate inlet pressure indication during all expected operating conditions. The full-scale range, 60 psig, is sufficient for a post accident condition when the torus is at the maximum pressure. This, however, exceeds the range limit for inlet pressure under the test condition (approx. 5 psig). Suction pressure measurement serve two functions. First, they provide assurance that the prescribed NPSH requirements are met. Secondly, they are used for determining pump 14

differential pressure. The installed gages are calibrated to within 12%

accuracy (FS), thus the maximum variation in measured suction pressure due to inaccuracy wculd be 11.2 psi. This is considered to be suitable for -

determining that adequate NPSH is available for pump operation.

Pump discharge pressure during testing is typically 300 psig, which results in a calculated differential pressure of approximately 295 psid.

Given the accuracy of the discharge pressure measurement of 2.5 psi, the resultant maximum variation in calculated differential pressure will be 3.7 psi. or 1.25%. This is consistent with the requirements of Table IWP-4110-1 that only requires that instrument accuracy be better than 2% of full-scale.

Alternate Testina. Use existing vendor supplied inlet pressure indicators (as described above) for testing of the CS pumps. (See Relief Request Note P16) 2.4.1.2 Eyaluation -The licensee proposes to use inlet pressure instruments for the CS pumps with a full-scale range of 0-69 psig and an accuracy as stated. The ranges of these instruments exceeds three times the test reference value for dynamic pump inlet pressure when pressure is low.

This prevents over-ranging and damage to the instrument when the pressure is much higher, such as when subjected to post-accident torus pressure conditions. The licensee has not provided a value for reference inlet pressure. However, it must be less than 20 psig or relief would not be needed. Conservatively assuming a CS pump discharge pressure of 300 psig, the differential pressure is between 300 and 280 psig (0 - 20 psig inlet pressure). This results in an inlet pressure inaccuracy of 1.2 psig, which represents an error in differential pressure measurement of only about i0.4%

(1.2 psig/290 psig - 0.00414). The proposed method should not have a significant negative impact on the ability to evaluate the condition of these pumps. Therefore, the proposal is essentially equivalent to the Code requirement and provides sufficiently accurate data for assessing pump degradation. This proposal provides an acceptable level of quality.

Based on the determination that the licensee's proposal provides an acceptable level of quality and safety, relief should be granted as requested.

2.5 Emeraency Service Water System 2.5.1 Relief Recuest. The licensee requests relief in Note PIB from the flow rate instrument accuracy requirements of Section XI, Paragraph IWP-4110-1, for the emergency service water (ESW) pumps, 46P-2A and -2B, and proposes to use existing installed instruments to measure flow rate.

l 2.5.1.1 Licensee's Basis for Reauestina Relief _. The ESW System was i originally designed and installed without flow measuring instruments. Te meet Regulatory Guide 1.97 requirennents, flow instrumentation was installed on the two oranch lines off of each pump (the emergency diesel generators and the reactor building). This was the only way the flow instruments could be installed due to system configuration. Th4 arrangement requires the use of electronic summation for determining toS1 flow of the two branch lines.

Despite the fact that the anubars purchased were calibrated to 11%, the 15

i sumation of these signals brings the loop accuracy to approximatsly 13% of full-scale. The installed instruments provide a repeatable and trendable result on which to base operational readiness. .

Alternate Test.ing. Use the existing installed flow instrumentation far testing of the ESW pumps.

2.5.1.2 Evaluation -The Code requires flow rate instruments with an i accuracy of 12% of full-scale. The licensee proposes to use the installed i instruments for measuring flow rate during ESW pump testing. The accuracy of  !

these instruments is approximately 13% of full-scale. The licensee states that these instruments provide repeatable and trendable results for assessing operational readiness. The proposed instrument accuracy does not deviate significantly from the Code and snould allow an adequate assessment of pump condition and provide a reasonable alternative to the Code for an interim period.

To require imediate compliance with the Code accuracy requirements would require changes to procedures or the purchase of different instruments and would be a hardship that would not be offset by a compensating increase in the level of quality and safety. The proposal gives adequate infomation to evaluate the condition of these pumps for an interim period of or.e year.

However, not enouDh information is provided to determine that this proposal is an acceptable long-term alternative to the Code accuracy requirements.

This proposal was reviewed in light of the flow diagram for the

" Emergency Service Water System 46 & 15, No. 11825-FM-46B, Rev. 14, dated 6/10/91." The print shows only one instrument in each main flow path and one in the each line to the diesel jacket coolers. It is not evident that a test method, such as testing through only one flow path, cannat be used to obtain data as accurate as required. Additienti information is needed to fully assess the proposal and to recomend granting long-term relief. During the interim period the licensee should evaluate changes to the test procedures or other methods of complying with the Code accuracy requirements. If compliance is impracticable, the licensee should submit additional information that supports this determination.

Based on the determination that imediate compliance with the Code would be a hardship not offset by a compensating increase in the level of safety and considering the licensee's proposal, interim relief should be granted for one year or until the next refueling outage, dichever is longer.

16

3. VALVE TESTING PROGRAM The following valve relief requests were evaluated against the .

requirements of the ASME Code,Section XI,10 CFR 50.55a, and applicable NRC positions and guidelines. A sumary and the licensee's basis for each relief request is presented. The evaluation and recomendation follow. The requests are grouped according to system and Code Category. Two cold shutdown justifications were also evaluated as relief requests because the proposed test frequency did not comply with the Code requirement.

3.1 General Valve Relief Reauests 3.1.1 Excess Flow Check Valves 3.1.1.1 Relief Reauest. The licensee requests relief in Note Y28 from the test frequency requirements of Section XI, Paragraph IWV-3521, for the excess flow check valves (listed in Note V28) and proposes to exercise these valves once each operating cycle.

3.1.1.1.1 Licensee's Basis for R_g.cuestina Relief. Testing these valves requires isolation of their associated safety-related instrument, which could place the plant in an unsafe condition. In addition, the induced hydraulic transients resulting from establishing flow and subsequent valve closure would most likely result in an engineered safety feature actuation.

During such testing, the radiation dose to the test personnel would be high due to the location of these valves and effluence of reactor water during the test. These valves have proven to be highly reliable and testing at the Code-required frequency would not significar.tly increase the reliability of these valves.

Alternate Testina. Exercise these valves for operability once each operating cycle.

3.1.1.1.2 Evaluation. These are Category A/C check valves on instrument sensing lines, which penetrate the primary containment. They are not equipped with local or remote valve position indication. Installation of position indication or other instruments to show valve position woulu require system redesign and modification. This modification would be costly and burdensome to the licensee. The::e valves close to restrict flow in case of excessive line leakage for containment isolation. Performance of valve closure verification quarterly or during cdid shutdowr.s is impractical. The i verification test procedure would isolate various instruments and could result in loss of control signals to vital instrumentation and subsequent unnecessary initiation of automatic safety systems. 1he proposal to exercise and leak rate test these valves per Code each operating cycle provides a reasonable alternative to the Code requirements.

Based on the detennination that compliance with the Code test frequency is impractical and burdensome, and that the proposed frequency provides a i

reasonable alternative, relief from the Code test frequency requirements should be granted as requested.

l l

17

3.1.2 Cold Shutdown Yalve Testina 3.1.2.1 Relief Reouest. The licensee requests relief in Note V51 from '

the test frequency requirements of Section XI, Paragraphs IWV-3411 and 3521, for various valves in the IST program, that are identified to be tested during cold shutdowns, and proposes to exercise them at the frequency described below.

3.1.2.1.1 Licensee's Basis for Reauestino Relief. In many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage or the lack of plant conditions needed foi testing specific valves, it has been the policy of the NRC that if testing commences in a reasonable time and reasonable efforts are made to test all valves, then outage extension or significant changes in plant conditions are not required when the only reason is to provide the opportunity for completion of valve testing.

ASME/ ANSI OMa-1987, Operation and Maintenance Of Nuclear Power Plants, Part 10 (Paragraphs 4.2.1.2 and 4.3.2.2) recognizes this issue and allows deferred testing as set forth belov.

Alterne .Testina. For those valves designated to be exercised or tested durint Id shutdown, exercising shall commence as soon as practical after the plant reaches a stable cold shutdown condition as defined by the applicable Technical Specification but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutoown. The 48-hour requirement need not apply if all valves are tested during an outage. Valve testing need not be performed more often than once every three (3) months ex.:ept as provided for in IWV-3417(a). Completion of all valve testing during a cold shutdown outage is not required if plant conditions preclude tests of specific valves or if the length of the shutdown period is insufficient to complete all testing. Testing not completed prior to startup will be rescheduled for the next cold shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves.

3.1.2.1.2 Evaluation. Due to the hardship that delaying plant startup places on a licensee, the NRC staff does not require licensees to complete all testing identified for the cold shutdown frequency prior to startup from each cold shutdown. Requiring completion cf all cold shutdown testing prior to startup could delay the return to power, which would be costly. The staff has previously approved. alternatives to the Code requirement to test all cold shutdown valves during each cold shutdown but not more frequently than once every three months. The licensee's proposed testing is similar to the staff apnoved alternatives, however, this approval is limited to valves that can be tested during any cold shotdown. Therefore, the licensee's proposal provides a reasonable alternative to the Code test frequency requirements for valves that can be tested during any cold shutdown.

For any other valve, or class of valves, that cannot be tested during each cold shutdowe of sufficient duration to complete all testing (such as, valves that cannot be tested when reactor recirculation pumps are operating or when the containment atmosphere is inert), a relief request must be submitted 18

ar.d approved by NRC prior to implementation since the test interval for these valves could exceed that allowed by Section XI.

Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements for valves that can be tested during any cold shutdown, and considering the hardship that would be placed on the licensee without a compensating increase in safety if the Code test frequency requirements were imposed, relief should be granted as requested for those valves that can be tested during any cold shutdown.

3.1.3 Valve Leak Rate Testina 3.1.3.1 Re_1_tef Ramtut . The licensee requests relief in Note V46 from the test method requirements of Section XI, Paragraph IWV-3427(t,), for various Category A valves (identified in Note V46) and proposes to test them per GL 89-04, Position 10, without complying with IWV-3427(b).

3.1.3.1.1 Licensee's Basis for Reouestina Relief. Based on input from many utilities and NRC staff review of testing data at some plants, the NRC determined that the usefulness of IWV-3427(b) does not justify the burden of complying with the requirements of IWV-3427(b).

Alternate Testina. In accordance with GL 89-04, Position 10, these valves are provided with leak rate limits specified in accordance with IWV-3426 and will be repaired or replaced whenever seat leakages exceed established limits.

3.1.3.1.2 Evaluation. These valves close to perform a containment isolation and/or high-pressure boundary isolation function. The licensee proposes to leak rate test them per GL 89-04 Position 10, without IWV-3427(b). Leakage rates will be evaluated against established limits. The licensee implies that GL 89-04, Position.10, guidelines will be met. Testing per the Code or Appendix J and Paragraphs IWV-3426 and -3427(e), as specified in GL 89-04, Position 10, gives adequate assurance of operational readiness of these valves for performing the containment isolation function.

The requirements of IWV-3427(b) are applicable to Category A valves that perform a leakage restriction function, other than or in addition to, containment isolation. Valves in this group include pressure isolation valves, even if they also perform a containment isolation function. The proposal to not endorse IWV-3427(b) does not provide a reasonable alternative to the Code for these valves. .

Relief is granted to test the CIV function of CIVs per GL 89-04, Position 10. This relief is limited to assessing the containment isolation capability of these valves. Relief from IWV-3427(b) applies only to testing of the containment isolation function. For Category A valves that perform any other leakage restriction function, in addition to or other than containment isolation, the requirements of IWV-3427(b) should be met.

19

3.2 Reactor Water Recirculation System 3.2.1 Catecory A/C Valves 3.2.1.1 Relief Reouest. The licensee requests relief in Note VI from the test frequency requirements of Section XI, Paragraph IWV-3521, for the seal water supply check valves to the reactor water recirculation {RWR) pumps, 02-2RWR-13A and -138. The licensee proposes to verify closure of these valves during Appendix J 1eak rate testing each refueling outage.

3.2.1.1.1 Licensee's Basis for Reouestina Relief. To test during nonnal operations or cold shutdown requires securing the RWR pumps and entering containment to check the valves closed via a back-leakage test.

Testing during operation is therefore impossible and, during cold shutdown, performing back-leakage tests would place an undue burden on the plant staff.

Alternate Testina. During each refuel outage, these normally open valves will be verified to close during leak testing performed per 10 CFR 50, Appendix J.

3.2.1.1.2 Evaluation. These are normally open check valves in the seal water supply lines to the RWR pumps. They are not equipped with external position indication or operators. The valves are located inside the primary containment. The containment is inerted with nitrogen gas during power operations and during certain cold shutdowns. Entry for testing is impractical during power operation, it is also impractical during cold shutdowns when the drywell is inerted because of the personnel safety hazard posed by the oxygen deficient atmosphere. Requiring de-inerting containment every cold shutdown would be costly and burdensome to the licensee. The process of de-inerting and re-inerting could also delay plant start-up.

Verifying the valves closed is impractical durirs power operation or during cold shutdowns when containment is inerted or when the RWR pumps are operating.

A practical means available for closure verification is leak testing.

This requires establishing a reverse differential pressure across the valves.

The RWR pumps must be stopped to establish test conditions. System reconfiguration, hooking up, and disconnecting of leak testing equipment during cold shutdowns would likely delay the return to power. System reo m 9n and modification would be necessary to allow testing these valves closed quarterly or during each cold shutdown. This modification would be costly and burdensome. The licensee prcposes to verify closure capability during local leak rate testing per the 10 CFR 50, Appendix J 1eak rate test requirements.

Performing this each refueling outage is a reasonable alternative to the Code test frequency requirements.

Based on the determination that compliance with the Code test frequency requirements is impracticable and burdensome, and considering the proposed alternative testing, relief should be granted as requested.

20

3.3 Reactor Core Isolation Coolina Svita 3.3.1 Cateaorv A/C Valves .

3.3.1.1 Relief Reaues1 The licensee requests relief in Note V6 from test frequency requirements of Section XI, Paragraph IW 3521 for check valves in the reactor core isolation cooling (RCIC) turbine steam exhaust line to the suppression chamber, 13RCIC-04 and -05. The licensee proposes to ver:fy closure of these valves during Appendix J 1eak rate testing each ref">1ing outage.

3.3.1.1.1 Licensee's Basis for Reauestina Relief. These valves are exercised (open) during the RCIC operability surveillance tests performed periodically during plant operation. There are no position 1-dicators on these valves or other means to verify closure following the Fu,1C tests, thus, the only method of verifying closure is by means of a back-leakage test.

Testing during operation is therefore impossible and, during cold shutdown, performing back-leakage tests would place an undue burden on the plant staff.

Alternate Testina. At each refueling outage, these valves will be verified to close during leak testing performed per 10 CFR 50, Appendix J.

3.3.1.1.2 Evaluation. These are simple check valves in the exhaust line from the RCIC turbine to the suppression chamber. They are not equipped with external position indication or operators. These valves are exercised open during RCIC system su,veillance testing. A practical means available for closure verification is leak testing. This testing requires establishing a reverse differential pressure across the valves. System piping diagrams show adequate isolation valves and test taps for reverse flow testing these valves. The licensee has not shown that this testing is a hardship or excessive burden to perform quarterly or during cold shutdowns.

The NRC is authorized by law to grant relief from the Code requiret.cnts when the licensee demonstrates either that their proposed alternatives would provide an acceptable level of quality and safety 10 CFR 50.55a(a)(3)(i), that compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety (a)(3)(ii), or that the Code requirements are impractical (g)(6)(1).

l The licensee proposes to verify valve closure during the Appendix J 1eak rate test during refueling outages. But, t,he licensee has not shown that exercising these valves closed quarterly is impractical or burdensome.

Therefore, the test provisions should be used to exercise these valves closed per the Code test frequency requirements.

Since system design allows reverse flow testing and this test is not impractical or burdensome, relief should not be granted from the test frequency requirements as requested. These valves should be exercised closed per the Code test frequency requirements. If the licensee determines that relief is needed, the licensee should prepare and submit a more detailed relief request per 10 CFR 50.55a for evaluation.

l 21 t

3.4 Reactor Buildina Coolina Water System 3.4.1 Cateaory A Valvgi 3,4.1.1 Relief Reouest. The licensee requests relief in Note V31 from closure testing per the test frequency requirements of Section XI, Paragraph IWV-3411, for valves in the reactor building cooling (RBC) system,15RBC 22A,

~22B, -26A, -268, and -33. The licensee proposes to verify closure during the Appendix J 1eak rate test once each operating cycle.

3.4.1.1.1 Licensee's Basis for Recue-tina Relief. During plant operation, these valves remain open to provide recirculation of cooling water to the drywell coolers and drywell equipment drain sump cooler. Cicsing these valves during operation could cause a spike in drywell pressure due to the loss of cooling water flow which may result in a reactor scram and plant shutdown. These are manually-operated valves and their operation is highly reliable. Therefore, an exercise frequency of once each operating cycle is sufficient to ensure continued operability.

Alternate Testina. Each valve will be exercised closed once each operating cycle in conjunction with leak testing performed per 10 CFR 50, Appendix J.

3.4.1.1.2 Evaluation. These are containment isolation valves in the RBC cooling supply lines to containment. They are manually operated valves equipped with operators and can be closed and reopened locally. The valves are located outside of containment. The licensee proposes to exercise and verify closure during Appendix J 1eak rate testing once each operating cycle.

The information provided does not justify deferring testing, as proposed. Tae short time it takes to close and reopen these valves thould not cause a significant change in drywell pressure and lead to a plant trip.

Compliance is not shown to result in hardship without an increase in quality or safety. Nor'is compliance shown to be impractical or an excessive burden.

Also, the proposed alternative, te extend the test interval for these manually operated valves, is not equivalsat to the Code requirements. Therefore, relief should not be granted as requested.

l 3.4.2 Cateaory A/C Valves l

3.4.2.1 Relief Reauest. The licensee requests relief in Note V33 from l

closure testing per the test frequency reqtiirements of Section XI, Paragraph IWV-3521, for containment isolation check valves in the RBC system supply lines to the drywell coolers,15RBC-21A, -218, -24A, and -24B. The licensee proposes to verify vahe closure during Appendix J 1eak. rate testing each refueling outage.

l 3.4.2.1.1 Licensee's Basis for Reouestino Relief. These are l

simple check valves with no means of determining disc position without perfonning a back-leakage test. Performing such a test would require securing cooling water flow to the drywell coolers for an extended period of time.

l During plant operation this could cause a spike in drywell pressure with a l 22 i

potential for a reactor scum and plant shutdown. During cold shutdown, the system lineup' changes and effort involved with testing would constitute an unreasonable burden on the plant staff.

Alternate Testina. During each refuel outage these valves will be verified to close during leak rate testing performed per 10 CFR 50, Appendix J.

3.4.2.1.2 Evaluation. The safety function of these valves is to close to prevent flow from the ESW system into the RBC system and to provide containment isolation. The system prints show the valves are equipped with local test connections and isolation valves (located outside of the drywell) to allow reverse flow closure testing. Verifying closure of these valves with the test taps can be done with a portable pressure source. Closure verification does not require any flow from the ESW system. The basis for relief does not justify testing these valves closed at an interval greater than specified in the Code. Reverse low testing these valves during power operation is impractical, however, the licensee has not shown that testing each cold shutdown is an unreasonable burden or hardship.

The licensee proposes to verify closure of these valves each refueling outage during Appendix J 1eak rate testing. This test must be done to satisfy the Appendix J 1eak rate testing program requirements. 1he licensee has not shown that the proposed test frequency is an acceptable alternate to the Code frequency for exercising these valves closed. Therefore, these valves should be exercised closed per the Code. Relief should not be granted to defer testing the closure capability of these valves until Apperdix J testing is done at refueling outages.

Since the licensee has not shown that testing these valves closed per the Code test frequency requirements is impractical, burdensome, or a hardship without a compensating increase in the level of quality or safety, er that the propcsal provides a reasonable alternative tc the Code, relief should be danied.

3.4.3 Cateaory C Valves 3.4.3.1 9elief Reauest. The licensee requests relief in Hote V7 from closure testing per the test method t.nd fr(quency requirements of Section XI, Paragraph IWV-3520, for RBC check valves,15RBC-35A thru -350, -38A, -38B, and -61. The licensee proposes to verify valve closure capability by sample disassembly and inspection of at least two , valves each operating cycle.

3.4.3.1.1 Licensee's Basis for Reouestina Ralief. Initiation of the ESW system at full flow to demonstrate operability of the valves would introduce untreated lake water into the treated RBC water which is maintained at a high level of purity. A loss of chemistry would require extensive

" bleed-and-feed" operations to restore the RBC system water purity, and could result in unacceptable metallurgical effects.

Alternate Testina. Each operating cycle (normally a refueling outage) a rotating sample of at least 2 of the valves will be disassembled and inspected such that each valve is inspected at a frequency of at least every 6 years.

23 l

1

If a disassembled valve is found inoperable, the remaining valves will be disassembled hnd inspected prior to plant startup.

3.4.3.1.2 Evaluation. These valves close to prevent flow from -

the ESW system into the RBC system. The RBC system is maintained with high quality water and is treated to present corrosion of system components. The EW system contains untreated lake water. Introduction of this low quality water w uld cause increased corrosion of components in the RBC systen u d would require extensive system flushing and draining. It is impractical to exercise these valves closed quarterly or during each cold shutdown. These valves are not equipped with local test connections and isolation valves to allow reverse flow closure costing. System redesign and modifications is needed to allow testing quarterly or during each cold shutdown. These modifications would be costly and burdensome to the licensee.

The licensee proposes to disassemble and inspect two of these valves each operating cycle. Disassembly, inspection and manual full-stroke of the valve disk can adequately ascertain a check valve's internal condition.

However, this technique should be used only when full forward or reverse flow testing is impractical. The NRC considers check valve disassembly anJ inspection to be a maintenance procedure not a test equivalant to exercising produced by fluid flow as required by Section XI. This procedure has some risks, which may make its routine use as a substitute for te ning undtsirable when some testing method is possible. The procedure is a valuable maintenance tool that can provide much information about valve internal condition aad, as such, should be performed under the maintenance program at a frequer..:y comensurate with the valve type and service.

It is clearly difficult to test these valves closed quarterly or at cold shutdowns. But, the licensee has not shown that testing is impractical during refueling outages. During the outage, adequate time should be availabla for RBC system reconfiguration and draining and flushing if necessary. The licensee should actively pursue use of alternate testing metnds, such as non-intrusive diagnostic techniques to demonstrate whether the valves swing fully closed when flow has ceased.

The licensee's proposed disassembly and inspection program is not thoroughly stated and it is not ir.di L;d th:t a unual stroke of the valve disk is included as part of the program. A determination that the proposal provides a reasonable alternative to the Code requirements cannot be made.

However, a check valve inspection program p,orformed per GL 89-04, Position 2, can adequately determine valve c.ondition and provides a reasonable alternative to the Code. In this case, it would be a reasonable alternative during an interim period of one year or until the next refueling outage, whichever is longer. During this interim period the licensee st ild. consider non-intrusive methods of testing closure capability during refueling outages.

Based on the determination that compliance with the Code is impracticable and burdensome, and considering the licensee's proposal, interim relief should be granted for one year or until the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 8g-04, Position 2. During this interim period the 24

licensee should investigate other methods, including non-intrusive, of testing these valves.

3.5 Feedwater System -

3.5.1 LLtfoory A/C Valves 3.5.1.1 Belief Recuelt. The licensee requests relief in Note V12 from the frequency requirements of Section XI, Paragraph IWV-3521, for feedwater system check valves, 34FWS-28A and -28B. The licensee proposes to verify closure during the Appendix J leak rate test each refueling outage.

0.5.1.1.1 Licensee's Basis for Reouestina Relief. There are no pcsition indicators on these valves or other means to verify closure, thus, the only practical method of verifying closure is by means of back-leakage tests. Exercising these valves to the closed position requires securing all feedwater flow to the reactor vessel and performing such a test. This is obviously not possible during normal plant operation. Back-leakage testing during cold shutdown requires extensive system realignment and would be an unreasonabic burden on the plant staff.

Alternate Testina. During each reactor refuel outage these valves will be verified to close per 10 CFR 50, Appendix J, leak testing.

3.5.1.1.2 Evaluation. These eighteen inch diameter valves are in the flow path for feedwater flow to the reactor. They are always open during power operation 3nd cannot be closed without stopping flow through the associated feedwater train. Testing these valves closed quarterly is impractical. It would require a reactor shutdown and result in high radiation doses to personnel. System redesign and modifications are needed to allow quarterly valve testing. This would be costly and burdensome to the licensee.

However, the feedwater system is configured with appropriate isolation valves and test taps (located inside the drywell). This contiguration should allow reverse flow closure testing during cold shutdowns when fecdcter flow is stopped and the drywell is de-inerted. The licensee has not shown that it is impractical or burdensome to test in that condition. Testing is impractical during cold shutdowns when the drywell is inerted becau:e of the personnel safety hazard-posed by the oxygen deficient atmosphere. It would be costly and burdensome to require de-inerting containment every cold shutdown because of the delay it could cause in plant start-up due to the time and expense associated with de-inerting and re-inerting containment.

The licensee proposes to test closure during Appendix J local leak rate testing each refueling outage. However, testing is not shown to be impracticable during cold shutdowns when containment is de-inerted. Since it is not impracticable or excessively burdensome to test during cold shutdowns when containment is de-inerted, these valves should be tested during that condition.

Based on the determination that quarterly testing during power operation or during cold shutdowns when containment is inerted is impracticable and 25

burdensome, and considering the proposal, relief should be granted from the Code test frequency requirements provided these valves are closure tested during each cold shutdown when the containment is de-inerted and each refueling outage. ,

3.6 Breathina. Instrument. and Service Air System 3.6.1 Cateaory A/C Valves 3.6.1.1 Relief Reauest. The licensee reouests relief in Note V14 from the test frequency requirements of Section XI, Paragraph IWV-3521, for instrument air system check valves 391AS-22 and -29. The licensee proposes to verify closure during the Appendix J leak rate test each refueling outage.

3.6.1.1.1 Licensee's Basis for Recuestina. Relief. Since these valves have no position indicators or other means of determining valve position, a back-leakage test must be performed to verify closure. These valves are located inside the drywell which is generally inaccessible during operation. During cold shutdown, performing back-leakage tests of these valves would be an unreasonable burden on the plant staff.

Alternate Testina. During each reactor refuel outage these valves will be verified to close per leak rate testing in accordance tith 10 CFR 50, Appendix J.

3.6.1.1.2 Eyaluation. These are simple check valves in the instrument air supply lines to containment. They close for contairrnent isolation. These valves are not equipped with external position indication or operators. A practical means available for verifying closure capability is leak rate testing. These valves are equipped with isolation valves and test taps to allow this. Some of these test taps are located inside the dryt. ell.

It is impractical to test these valves quarterly during power operation due to high radiation levels. It is impractical during cold shutdowns when the drywell is inerted because of the personnel safety huard posed by the oxygen deficient atmosphere. Requiring de-inerting containment every cold shutdown would be costly and burdensome to the licensee. The process of de inerting and rc-inerting could also delay plant start-up.

The licensee proposes to test closure during Appendix J leak rate testing each refueling outage. However, testing these-valves is not shown to be impracticable during cold shutdowns when containment is de-inerted. Since it is not impracticable or excessively burdensome to test during cold shutdowns when the containment is de-inerted, these valves should be tested l during that condition.

1 Dased on the determination that quarterly testing *during power operation or during cold shutdowns (when the containment is inerted) is impracticable and burdensome, and considering the licensee's proposal, relief should be granted from the Code test frequency requirements provided these valves are closure tested during each cold shutdown when the containment is de-inerted and each refueling outage.

26 l

l 1

l

3.7 Service Water Syster 3.7.1 Cateaory B Valves 3.7.1.1 Relief Reauest. The licensee requests relief in Note VS2 from the frequency requirements of Section XI, Paragraph IWV-3411, for ESW to control room chiller valves, 46(70)SWS 13 -14, 70WAC-12A, and 128. The licensee proposes to exercise these valves closed once every two years.

3.7.1.1.1 Licensre's Basis for Recuestina Relief. These are normally open manual valves. Since manually-operated valves are inherently reliable, exercising on a 2 year frequency is adequate to assess operational readiness.

Alternate Testina. These valves will be exercised closed once every two years.

3.7.1.1.2 Evaluation. These manual valves are in the supply lines to the control room chiller condenser. They are manually closed during an accident if E3W flow is not needed to the condenser. The licensee proposes to exercise them closed once every two years. The licensee has not shown that the proposal is an acceptable alternative to the Code frequency for exercising these valves closed. Therefore, these valves should be exercised closed per the Code. Relief should not be granted to increase the test interval for these valves to once every two years.

Since the licensee has not shown that testing these valves closed per the Code test frequency requirements is impractical, burdensome, or a hardship without a compensating increase in the level of quality or safety, or a reasonable alternative to the Code, relief should be denied.

3.8 Hiah Pressure Coolant _In_iection System 3.8.1 Cateaory A/C Valves 3.8.1.1 Relief Recuest. The licensee requests relief in Note V34 from the test frequency requirements of Section XI, Paragraph IWV-352), for HPCI turbine exhaust line to suppression pool check valves, 23HPI-12 and -65. The licensee proposts to verify valve closure during the Appendix J 1eak rate testing each refueling outage.

3.8.1.1.1 Licensee's Basis for' Reauestina Relief. The valves are full-flow (open) tested during quarterly HPCI pump operability surveillance tests. Since these are check valves with no external means for determining disc position, there is no practical means to verify prompt closure without performing a back-leakage test. During cold shutdown, the system lineup changes and effort involved with testing would constitute an unreasonable burden on the plant staff. -

altsrnate Testina. During each refuel outage these valves will be verified to close during leak rate testing performed per 10 CFR 50, Appendix J.

27

l 3.8.1.1.2 Evaluation. The safety functions of these valves are to open to exhaust the HPCI turbine and close to provide containment isolation. They are not equipped with position indicators or external operators. However, system prints show the pipe system is equipped with local test connections and isolation valves to allow reverse flow closure testing.

The licensee's basis for relief does not . justify deferring testing these valves closed. Reverse flow testing these valves during power operation is impractical, but the licensee has not shown that testing each cold shutdown is an unreasonable burden or hardship.

The licensee proposes to verify closure of these valves each refueling outage during Appendix J 1eak rate testing. This test must be done to satisfy the Appendix J leak rate testing program requirements. The licensee has not shown that the proposal is an acceptable alternative to the Code frequency for exercising these valves closed. Therefore, these valves should be exercised closed per the Code frequency. Relief should not be granted to defer testing the closure capability of these valves until Appendix J testing is done at refueling outages.

Since the licensee has not shown that testing these valves closed per the Code test frequency requirements is impractical, burdensome, or a hardship without a compensating increase in the level of quality or safety, or a reasonable alternative to the Code, relief should be denied.

3.8.2 C.ateaory C Valves 3.8.2.1 Relief Reauest. The licensee requests relief in Note V17 from

the test method and frequency requirements of Section XI, Paragraph IW-3520, for HPCI turbine exhaust line vacuum breaker check valves, 23HPI-402 and -403.

The licensee proposes to verify closure by disassembly and inspection of one valve each operating cycle.

3.8.2.1.1 Licensee's Buis for Reauestina Relief. There is no positive means to demonstrate operability of these valves during quarterly HPCI operability surveillance tests. Furthermore, the valves are mounted in series and cannot be individually verified to close.

Alternate Testina. Each operating cycle (normally a refuel outage), on a rotating schedule, one of these valves will be disassembled, inspected, and verified to be operable. If a valve is found to be inoperable, the other valve will t,e disassembled and inspected prior to plant startup.

3.8.2.1.2 Evaluation. These check valves are located in series without intermediate test taps. They are simple check valves not equipped with position indication or external operators. Their function is to close to prevent steam from entering the suppression chamber vapor space and to open to break the vacuum created by condensing steam in the turbine exhaust line.

According to system prints, the line containing these valves has isolation valves and test taps accessible outside of the suppression chamber. This provision should allow testing with air or nitrogen, both open (which tests both valves open) and closed (which confirms only the closure ekpability of one valve of the pair).

28

i It is impractical to individually verify closure of these valves at any frequency. These valves have no provision for external verification of position (i.e., position indicators, pipe taps). Requiring installation of

~

instrumentation to verify valve position would involve system redesign and modifications. These modifications would be costly and burdensome to the licensee. However, the closure capability of this series valve pair might be verified by leak testing. Testing the pair closed would give reasonable assurance of operational readiness and supply a reasonable alternative to the Code test method provided that both valves are declared inoperable and repaired or replaced if e:cessive leakage is noted. This closure test, and the open test should be performed quarterly or during cold shutdowns as practicable.

Since it is practical to test these valves, as described above, disassembly and inspection should not be performed as an alternative to the Code test frequency requirements. However, the disassembly and inspection procedure should still be done during refueling outages as proposed.

Based on the deteunination that compliance with the Code test method is impractical and burdensome, and considering the licensee's proposal, relief should be granted provided the pair is verified closed quarterly or at cold shutdowns, as practicable. If excessive leakage is noted through the pair, both valves must be repaired or replaced prior to their return to service.

This testing should be done in addition to the sample disassembly and inspection, as proposed, at refueling outages.

3.9 Emeroency Service Water System 3.9.1 Cateoory VC Valves 3.9.1 Jelief Reauest. The licensee requests relief in Note V45 from the freque .y requirements of Section XI, Paragraph IWV-3521, for ESW to drywall cooler check valves, 46ESW-15A, -15B, -16A, and -16B. The licensee proposes to verify closure during the Appendix J seat leak rate testing at each refueling outage.

3.9.1.1.1 Licensee's Basis for Reauestina Relief. These are simple check valves with no means of determining disc position without performing a back-leakage test. Performing such a test, would require securing cooling water flow to the drywell . coolers for an extended period of time. During plant operation this could cause a spike in drywell pressure with a potential for a reactor scram and plant shutdown.

Initiation of the ESW system to " exercise" these 9alves would introduce untreated lake water into the treated RBC water system where the water is maintained at a high level of purity. A loss of chemistry would require extensive " bleed-and-feed" operations to restore the RBC system water purity, and could result in unacceptable metallurgical effects. During cold shutdown, the system lineup changes and effort involved with tes'.ing would constitute an unreasonable burden on the plant staff.

29

Alternate Testina. During each refuel autage these valves will be verified to be closed during leak rate testing per.^ormed per 10 CFR 50, Appendix J.

3.9.1.1.2 Evaluation. The safety function of these valves is to .

close to prevent flow from the ESW system into the RBC system and to provide containment isolation. The system prints show the valves are equipped with local test connections and isolation valves to allow reverse flow closure testing. Verifying closure of these valves with the test taps does not involve the ESW system. The licensee's basis for relief does not justify deferring testing from the frequency required by the Code. Reverse flow testing these valves during power operation is impractical as it would interfere with system cperation and could cause a plant shutdown. However, the licensee has not shown that testing each cold shutdown is an unreasonkble burden or hardship.

The licensee proposes to verify closure each refueling outage during Appendix J 1eak rate testing. This test must be done to satisfy the Appendix J program requirements. The licensee has not shown that this is an acceptable alternative to the Code frequency for exercising these valves closed.

Therefore, the valves should be exercised closed per the Code frequency.

Relief should not be granted to defer testing closure capability until Appendix J testing is done at refueling outages.

Since the licensee has not shown that testing these valves closed per the Code test frequency requirements is impractical, burdensome, or a hardship wi+hout a compensating increase in the level of quality or safety, or that the proposal provides a reasonatie alternative to the Code, relief should be denied.

3.9.2 Cateaory B Valves.

3.9.2.1 Relief Reauest. The licensee requests relief in Note V49 from the exercising frequency requirements of Section XI, Paragraph IWV-3411, for the manually-operated emergency service water valves to the control and relay room air handlers, 46(70)ESW-101 through 104. The licensee proposes to exercise these valves when the respective chilled water systems are drained.

3.9.2.1.1 Licensee's Basis for Reauestina Relief--These valves provide isclation between the raw ESW system and the glycol / water mixture in the chilled water system. Opening these valves will cause contamination of the glycol / water solution. .

Alternate testina: These valves will be exercised during periods when the respective chilled water system is drained.

3.9.2.1.2 Evaluation--Opening these normally-closed manuni isolation valves would cause contamination of the control room area chilled water system with raw water from the ESW system. Contamination by this raw water could lead to increased corrosion and reduced cooling capacity. To exercise these valves open requires ramoving the control room chilled water systems from service to drain and flush the contaminated piping. This is impracticable to perform quarterly during power operation.

30

It is impractical to exercise these ESW isolation valves during cold shutdowns because the control room chilled water systems are required to be operable. Also, due to the material costs and time requirements for this testing, it would be burdensome to require the licensee to drain and flush of the affected system during each cold shutdown.

The licensee proposes to exercise these valves when the respective chilled water systems are drained. However, the licensee has not specified a frequency for performing this test. Exercising these valves as close to the Code specified frequency as practicable, at least once every refueling outage, allows an adequate assessment of operational readiness and provides a reasonable alternative to the Code. The licensee's basis for relief does not provide sufficient justification for testing these valves less often than every refueling outage.

Based on the determination that compliance with the Code exercising frequency requirements is impractical, and considering the burden on the licensee if the Code requirements were imposed, relief should be granted provided these valves are exercised no less than once each refueling outage.

3.10 Automatic Deoressurization System / Main Steam 3.10.1 Cateaory B Valves 3.10.1.4 Relief Recuest. The licensee requests relief (in Cold Shutdown Justification No. 12) from the test frequency requirements of Section XI, Paragraph IWV-3415, for the main steam isolation valves (MSIVs),

29A0V-80A thru -80D and -86A thru -860. The licensee proposes to verify valve fail-safe during uld shutdowns with containment de-inerted.

3.10.1.1.1 Licensee's Basis for Reouestina Relief. These valves close to provide containment isolation. Performance of the fail close test for the MSIVs requires entry into the drywell and steam tunnel. This cannot be done during normal operation and, in the case of the valves in containment, when shutdown with the containment inerted.

3.10.1.1.2 Evaluation. Testing these valves requires entry into the containment drywell and the steam tunnel. This is impractical quarterly during plant operation or during cold shutdowns when the drywell is inerted.

A significant personnel safety hazard is posed by the oxygen deficient atmosphere in the drywell. There is also a safety concern regarding high energy lines in the steam tunnel during power operation. Requiring de-inerting containment every cold shutdown would be costly and burdensome to the licensee. The process of de-inerting and re-inerting could also delay plant start-up.

The licensee proposes to test these valves during <:old shutdowns when the containment drywell is de-inerted. The proposed test frequency should allow an adequate assessment of operational readiness and provides a reasonable alternative to the Code.

31

Based on the determination that testing quarterly during power operation or during cold shutdowns when the containment is inerted is impracticable and burdensome, and considering the proposal, relief should be granted as requested. .

3.10.2 Cateaory B/C Valves 3.10.2.1 Relief Reauest. The licensee requests relief in Note V27 from the method and frequency requirements of Section XI, Paragraphs IWV-3411

-3413, and -3520, for the automatic depressurization system (ADS) valves, 02RV-71A thru -71H, -71J, -71K, and -71L. The licensee proposes to test these valves as described below.

3.10.2.1.1 Licensee's Basis for Reauestina Relief. These valves are fast-acting valves and do not have position indication. Therefore, stroke time cannot be effectively measured.

When testing these valves, a reactor pressure of at least 50 psi is needed for valve opening by the pilot assembly and a minimum reactor pressure of 940 psig is specified to minimize damagt to the pilot valve and disc surfaces. Testing at each start-up from a cold shutdown condition would produce additional stress cycles which may leao to a low cycle fatigue failure.

Al. ternate Testina. Following each refuel outage or once each operating cycle with reactor pressure at least 940 psig, these valves will be exercised in accordance with the operational test requirements set forth in James A.

FitzPatrick Technical Specifications. Safety / relief valve (SRV) tailpipe temperature and acoustic monitors will be used to verify valve opening.

Additionally, in accordance wt th Technical Specification requirements, the pilot assembly for each SRV will be bench tested at least once e v two operating cycles. The bench testing includes "as found" setpoir. , leakage and pilot disc sticking tests.

In addition to the pilot assembly bench testing, refurbishment is performed, if necessary, in accordance with the valve manufacturer's procedure including inspection of the pilot valve stem labyrinth seal area. This program of testing, inspections, and maintenance is performed in accordance with the related BWR owners group (BWROG) recommendations to monitor and resolve setpoint drift problems.

3.10.2.1.2 Evaluation. Operat' ion of these valves during power operation causes reactor pressure and power transients that could result in a reactor trip. These valves should not be exercised quarterly during power operation as failure to close may result in a rapid depressurization and cooldown af the reactor vessel (loss-of-coolant accident) and a reactor trip.

NUREG-0626 " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near Term Operating License Applications" recommends reduction of challenges to relief valves to lessen the risk of Small Break LOCA (see also NUREG-0737,Section II.K.3.16). Therefore, a redaced frequency of testing is appropriate.

32 I

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

These valves must be exercised while the reactor is at power because reactor steam' warms the valve seating surfaces and aids in preventing seat damage and leakage. The valves should not be exercised when the reactor is at low temperature and pressure during cold shutdowns. In that condition, .

reactor steam is not available to warm them even though the valve operators are capable of cycling the valve without steam pressure. The licensee's proposal to full-stroke exercise these valves after refueling outages on the return to pcwer operation with steam pressure of 940 psig gives adequate assurance of operational readiness and provides an acceptable level of safety.

These valves are not equipped with external or remote position indication based on valve obturator or actuator position. Verification of valve position changes is based on system response (i.e., thermocouple indication or acoustic monitors). This response is not very accurate and lags actual valve position. Installation of instrumentation to directly indicate valve position would require system redesign and modification. This modification would be costly and burdensome to the licensee. The licensee proposes to verify the operational readiness of these valves following each refueling outage or once each operating cycle when the reactor pressure is 940 psig, per plant Technical Specifications. Valve opening will be verified using temperature and acoustic monitors. The pilot assembly for each SRV will be bench tested at least once per two operating cycles. This proposal provides a reasonable alternative to the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and co'sidering the licensee's proposal, relief should be granted as requested.

3.10.3 Cateoory C Valves 3.10.3,1 C 3f Reauest. The licensee requests relief (in Cold Shutdown Justification No. 8) from the frequency requirements of Section XI.

Paragraph IWV-3521, for the ADS relief line vacuum breaker valves, 02RV-1 thru

-11 and 02VB-1 thru -11. The licensee proposes to exercise them during cold shutdowns when the containment drywell is de-inerted.

3.10.3.1.1 Licensee's Basis for Reouestino Relief. These valves cicse to prevent steam release into the drywell and open to relieve the vacuum in the main steam relief valves (SRVs) discharge piping to prevent suppression pool water from being drawn into these lines following SRV actuation.

Exercising these valves requires entry into the drywell. This cannot be done during normal operation or when shutdown if' the containment is maintained inerted.

3.10.3.1.2 Evaluation. These vacuum breaker valves are in the containment drywell. _ sesting requites drywell entry and is impractical

quarterly or during cold shutdowns when the drywell is inerted. A significant personnel safety hazard is posed by the oxygen deficient atmosphere in the drywell. Requiring de-inerting containment every cold shutdown would be costly _and burdensome to-the licensee. The process of de-inerting and re-inerting could also delay plant start-up.

33

The licensee proposes to test these valves during cold shutdowns when the containment drywell is de-inerted. This test frequency :hould allow an adequate assessment of operational readiness and provides a reasW1e alternative to the Code.

Based on the determination that testing these valves quarterly during power operation or during cold shutdowns when the containment is inerted is impracticable and burdensome, and considering the proposal, relief should be granted as requested from the Code test frequency requirements.

3.11 Residual Heat Removal System 3.11.1 Cateoory A/C Valves 3.11.1.1 Pelief Reauest. The licensee requests relief in Hote V24 from the test method requirements of Section XI, Paragraph IWV-3420, for the residual heat removal (RHR) and core spray CIV and PlVs,10MOV-17, 25A,

-258 -32, -33, 14M0V-12A and -12B. The licensee proposes to test these valves per the Appendix J, Type C, requirement:.

Note:

-Note V24 is indicated approved in the IST program per GL 89-04.

This relief request was presented as V24 in Revision 1 of the program. A significant change was made to the alternate test as proposed in the earlier submittal. Thcrefore, the request is evaluated as follows.

3.11.1.1.1 Licensee's Basis for Reauestina Relief. Presently, each of the above listed motor operated valves must pass an Appendix J.

Type C, local leak rate test (LLRT) each refuel outage. The performance of an additional full pressure differential test would unnecessarily double the radiation exposure of test personnel. The LLRT test has been demonstrated, at this site, to be more conservative, in fact, in 1978, via Amendment 40 to the facility's Technical Specifications, the LPCI and core spray containment boundaries were shifted to outboard MOVs. This was due to the continued inability to successfully pass LLRT tests on inboard check valves which resultad in substantial man-rem exposures during subsequent repair efforts, in lieu of the low pressure LLRT air test, the amendment required a water leak test at operating pressure to be performed on the check valve. To date, no difficulty has been experienced in performi,ng this test, thus demonstrating, the significant conservatism in performing an LLRT test.

In addition, the system configuration provides additional protection for l pressure interface concerns. Each injection check valve has a least one

! motor-operated valve (10M0V-25A, B or 14MOV-12A, B) in the closed position during all conditions at operating pressure. Whichever motor-operated injection valve is closed, the logic requires reactor vessel pressure to drop below the rating of the low pressure injection discharge piping before giving a permissive signal to open.

34 l

l

e. .

Also the shutdown cooling suction isolation valves (10HOW17 and 10MOV-18) and'the head spray isolation valves (10MOV-32 and 10H0V-33) are redundant motor operated gate valves that are all closed when operating at normal pressure.

Alternate Tuling. Test the above listed containment isoittion valves via the Appendix J. Type C, requirements, 3.11.1.1.2 EDluation. The licensee proposes to leak rate test identified valves per the Appendix J test requirements. The procedures and requirements specified in 10 CFP 50, Appendix J, for Type C tests of containment isolation valves, are essentially equivalent to Code Paragraphs IWV-3421 through -3425 for assessing the containment isolation capability.

The test adequately determines the ability to isolate the containment under peak accident conditions. Air or nitrogen is used as the test media. This is more conservative than water at the same pressure. Appendir J does not require measurement of individual valve leak-rates or assignment of individual limits. Appendix J does not require trending or establishing corrective action requirements based on individual valve leak-rates, as does the Code in Paragraphs IWV-3426 and -3427(a), Analysis of leak rates and Corrective Actions. The intent of these two requirements is different.

Leak testing these valves to the requirements of both Appendix J, Type C, and Code Paragraphs IWV-3421 through -3425, is impractical. Efforts would-be duplicated with marginal additional benefit to safety. This would be costly and burdensome. The licensee's IST program indicates that the GL 89-04 requirements will be met. Testing per Appendix J and Paragraphs IWV-3426 and -3427(a), as specified in GL 89-04, Position 10, gives adequate assurance of operational readiness for performing the containment isolation function.

The licensee must meet the requirements of Paragraphs IWV-3426 and -3427(a) for assessing the CIV function of the identified valves per Position 10.

The requirements of IWV-3427(b) are applicable to every Category A valve that performs a leakage restriction function, other than or in addition to, containment isolation. Valves in this group include pressure isolation valves, even if they also perform a containment isolation function.

Based on the conclusion that testing to both requirements is impractical and burdensome and that Appendix J Type C, testing essentially meets the requirements of Paragraphs IWV-3421 through -3425, relief should be granted with the following provisions. The licensee should test these valves to the requirements of Appendix J, Type C, and Paragraphs IWV-3426 and -3427(a) per GL 89-04, Position 10. This relief is limited to assessing the containment isolation capability of these valves. Relief from IWV-3427(b) applies only to testing of the containment isolation function. For Category A valves that perform any other leakage restriction function, in addition to or other than containment isolation, such as pressure boundary isolation, the requirements of IWV-3427(b) should be met, as applicable.

The licensee also indicates in the request that the LLRT results are conservative compared to the water leak rate test. The test results can be conservative in some cases, however, the conservatism depends on several 35

factors, including acceptance criteria and the direction of pressure differential. if the licensee develops a test methodology, using low pressure P r or gas, hv an demonstrate that it is conservative for the affected components, tn a iould be proposed for consideration. There is not encugh information provided to evaluate and recommend approval of that aspect of the licensce's proposal.

3.11.2 Cateoory C Valves 3.11. 2 . .' Relief Reales1 The licensee requests relief in Note V30 from the test method and frequency requirements of Section XI Paragraph IWV 3520, for the RHR system keep fill check valves, 10RHR 262 and 277 The itcensee proposes to verify valve closure by sample disassembly and inspection once each operating cycle.

3.11.2.1.1 Licensee's 06 sis for Reguestina Relief. There are no positicn indicators on these valves or other means to verify clor,ure, thus, tne only practical means is by means of back leakage tests. These valves are ccnfigured in series eith non safety related check valves RHR 261 and 276 and cannot be verified to c1cse by means of a reverse flow test.

Alternate Testino. In accordance with GL 89 04, position 2, at least once each operating cycle (normally a refuel outage) one valve will be disassembled. inspected, and verified to be operable. If a valve is found to be inoperable, the other valve will be disassembled and inspected prior to startup.

3.11.2.1.2 EvaluatioD. These check valves are located in series with other non safet.v rer ' Ped check valves. The piping system between these valves does not contain tne needed test taps for verifying closure individually. These are simple check vahes not equipped with position indication or external operhtors. Theit safety function is to close to prevent loss of RHR system fluid. Individually verifying these valves closed is impractical at any frequency. These valvas have no provision for external verification of valve position (i.e., pocitich indicators, pipe taps).

Requiring installation of instrumenteticn to verify valve position would invoire system redesign and modifications. These modifications would be costly and burdensome to the licensee.

Hnwover, the reverse closure capability of each series valve pair might be verified by leak testing +he pair. Testing the pair closed would give reasonable assurance of operational readiness during the period between refueling outages. The test would also provide a reasonable alternative to the Code test method requirements provided both valves in each pair are declare.1 inoperable and repaired or replaced if excessive leakage is noted through the pair. A test of this type is preferred over the proposed valve disassnbly and inspection. Inis closure test should be performed quarterly or daring cold shutdowns as practicable. As such, d'.sassembly and inspection shnuld not be performed as an alternative to the Code test frequency requirement. However, the procedure could still be done for preventative maintenance purposes at a frequency determined by the licensee.

36 l

I' Based t.. the determination that comt ice with the Code test method requirements is impractical and burdensome, and considering the alternative testing discussed above, relief should be granted provided the pair of series ,

check valves is verified closed quarterly or at cold Putdowns, as

)racticable, if excessive leakage is noted inrough the pair, both valves must  !

?e repaired or replaced prior to their return to service. This testing should be dc.ne rather than the sample disassembly and inspection, as proposed, quarterly or during cold shutdowns, as practicable.

3.11.2.2 ReliefReagnt. The licensee requests relief in Note V32 from

, the test method and frequency requirements of Section XI, Paragraph IWV 3520, '

for check valves in the RHR system minimum flow lines,10RHR.64A thru 640.

The licensee proposes to verify full flow open and reverse flow closure capability by sample dist.ssembly and inspection once per operating cycle.

3.11.2.2.1 Lip Attfit.Jasis for Rttqq nting Relief. These valves are demonstrated to be operable in the closed direction by successful completion of the quarterly RHR operability surveillance test. There is no means to demonstrate, by flow measurement or valve indication, that a valve has fully opened.

Alternate Testing. The valves will be exercised during quarterly RHR pump operability testing withwt determhation of full flow. In accordance with GL 89 04, Position 2, at least once each operating cycle (normally a refuel outage) at least I valve will be disassembled, inspected, and verified operable. If any valve is found to be inoperable, the remaining valves will be inspected prior to startup. The inspection schedule will be such that all valves in the group are inspected at least once every 6 years.

3.11.2.2.2 LyJLlatiqD. These check valves must open to allow a minimum flow rate through the RHR pumps during dead head operatior.. They close to prevant diversion of flow through an idle loop. These valves are not equipped with position indication or external operators.

Verifying these valves closed is difficult at any frequency. They have no provision for external verification of valve position (i.e., position indicators, pipe taps). Requiring installation of instrumentatien to verify the closed valve position would involve system redesign and modifications.

These modifications would be costly and burdensome to the licensee. However, testing is preferred over valvs disassembly and inspection, particularly for closure capaDility. ,

The licensee stated that these valves are demonstrated operable by the l quart:i y RHR operability surveillance test, but that full stroke opening l capabihty cannot be verified by flow measurement or valve indication.

Employing a test to verify these valves open fully or sufficiently to pass the

, required minimum flow during quarterly RHR pump testing might be practical.

I Alternate techniques should be considered.

l Flow rate is measured in the main 100,. during the test, it might be practical to record main line flow, isolate the minimum flow return line by shutting the manual isolation, and re measure the main line flow. The 37 L

l l

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

difference in measured flow rate might be attributable to the minimum flow path and indicate a full stroke of the valve disk. If a test such as this, or pr.other suitable non intrusive test method, can verify the full stroke open capability of these valves the test should be used. The licensee should evaluate non intrusive methods of testing the open capability of these valves per GL 89 04, Position 1.

The licensee proposes to perform sample disassembly and inspection of these valves each operating cycle. Disassembly, inspection and manual  !

full stroke of the valve disk can adequately ascertain internal condition. '

However, this technique should be used only when full forward and/or reverse flow testing is impractical. The NRC considers check valve disassembly and inspection to be a maintenance procedure with risks. This may make its routine use as a substitute for testing undesirable. The procedure is a valual'e maintenance tool that can provide much information about valve intern. condition. As such, the procedure should be serformed un;er the maintenance program at a frequency commensurate with tie valve type and service.

Testing these valves closed is clearly dif ficult. But, the licensee should actively pursue use of alternate testing methods to exercise these valves to both positions, such as using non intrusive diagnostic techniques.

The licensee's proposed disassembly and inspection program is not thoroughly stated and it is not indicated that a manual stroke of the valve disk is included as part of the program. A determination that the proposal provides a reasonable alternat ve to the Code requirements cannot be made.

However, a check valve inspection program performed per GL 89 04, Position 2, can adequately determine valve condition and provides a reasonable alternative to the Code, in this case during an interim period of one year or until the nextrefuelingoutage,whIcheverislonger. During this interim period the licensee should consider non intrusive methods of testing these valves' open and closure capability during refueling outages.

Based on the determination that compliance with the Code is impracticable and burdensome, and considering the Itcensee's proposal, interim relief should be granted for one year or until the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 89 04, Position 2, as well as the quarterly exercising during pump tcsting. By the end of this period, the licensee should implement testing per GL 89 04, Position 1, and/or Pqsition 3, as applicable.

3.11.2.3 Relief Raa m 1, The licensee requests relief in Note V56 from the test frequency requirements of Section XI. Paragraph IWV-3521, for check valves in the torus lines,10RHR 95A thru 958. The licensee proposes to verify their closure by hydrostatic testing each refueling outage.

3.11.2.3.1 Licensee's _ Basis for Reouestina Relief. . These are simple check valves with no means of determining disk position without perforrhg a backleakage test. Performing such a test, would require setting up a hydrostatic pump in a high radiation area. During cold shutdown, the 38

lineup changes and effort involved with testing would constitute an unreasonable burden on the plant staff.

Alternate Testing: During each refuel outage these valves will be verified to '

close during a hydrostatic leak rate test.

3.11.2.3.2 Evaluatigfl. These valves shut to prevent reverse flow out of the torus. They are simple check valves without remote position indicators or operators, it is impractical to verify them closed during power operation or during cold shutdowns. Testing these valves closed during power operation requires setting up for a test in a high radiation area. System reconfiguration and hooking up and disconnecting leak testing equipment d uing cold shutdowns would likely delay the return to power. System redesign and modification would be necessary to allow testing these valves closed per the Code frequency. This modification would be costly and burdensome to the licensee.

The only practicable means available for determining these valves' capability to close is by leak rate testing. The licensee proposes to verify these valves' closure capability during hydrostatic leak rate testing at least once every refueling outage. This allows an ad;quate assessment of operational readiness and provides a reasonable alternative to the Code requirements.

Based on the determination that compliance with the Code test frequency is impracticable and burdensome, and considering the proposed testing frequency, relief should be granted as requested.

3.12 Containment Atmojphere Dilution System 3.12.1 Cateaory A/C Valves 3.12.1.1 Relief Reauest. The licensee requests relief in Note V36 from the test frequency requirements of Section XI, Paragraph IW 3521, for the containment atmosphere dilution (CAD) system containment isolation check valves, 27 CAD-67. -68. -69, and 70. The licensee proposes to verify closure during the Appendix J 1eak rate test each refueling outage.

3.12.1.1.1 Ucensee's Basis for Relief. Since these are simple check valves with no means of determining disk position, there is no practical means of verifying closure without performing a backleakage test. The system lineup changes and effort involved with such testing would constitute an unreasonable burden on the plant staff.

Alternate Testing: During each refuel outage these valyes will be verified to close during leak rate testing performed per 10 CFR 50, Appendix J.

3.12.1.1.2 Evaluation. 1hese check valves open to supply nitrogen tn the supprestion chamber and drywell and close for containment isolation. They are simple check valvos not equipped with position indicators or external operators. These valves are in separate trains of the CAD system (valves 27 CAD 67 and -68 in one train, and -69 and -70 in the other). The 39

system prints show the system is equipped with local test connections and isolation val.ves to allow reverse flow closure testing. Only one train needs to be secured to test each pair. 1he licensee's basis for relief does not justify testing at an interval greater than speelfied in the Code. ,

The licensee proposes to verify closure each refueling outage during Appendix J 1eak rate testing. This test must be done to satisfy the Appendix J program requirements. The licensee has not shown that the proposal is an acceptable alternative to the Code frequency for exercising these valves closed. Therefore, these valves should be exercised closed per the Code frequency.

Since the itcensee has not shown that testing thesv valves closed per the Code test frequency requirements is impractical, burdensome, or a hardship without a compensating increase in the level of quality or safety, or that the proposal provides a reasonable alternative to the Code, relief should be denied.

3.12.1.2 Relief Reagul. The itcensee requests relief in Note V48 from the test method requirements of Section X1, Paragraphs IWV 3424 and -3426, for the CAD system drywell vacuum breaker check valves, 27VB 1 through -5. The licensee 1roposes to leak rate test them as a grnup each refueling outage per plant Tecinical Specifications.

3.12.1.2.1 Licensee'r A sis for R911ef. The configuration of the vacuum breaker lines precludes measuring individual valve leak rates, in accordance with JAF Technical Specifications Section 4.7.A.S.d these valves are leak tested as a group each cycle (normally refueling outage) in conjunction with an integrated drywell/ suppression chamber bypass leakage test.

Alternate Testina: These valves will be tested together in accordance with JAF Technical Specifications Section 4.7.A.5.d (also see V46),

3.12.1.2.2 Ivaluation -These check valves open to relieve vacuum from the torus to the drywell if differential pressure between them exceeds 3.5 psid. They also close to prevent bypass flow from the drywell to the suppression chamber without quenching by the suppression pool.

Due to system piping configuration, it is not practical-to measure individual leakage rates for these valves. compliance with the individual valve leak rate testing requirements of the Code could be achieved only after significant system modification. This modification would be costly and burdensome. The licensee's proposed alternative, to leak rate test these valves as a group, is sufficient to assess the capability of these valves to perform their safety function in the closed position. If excessive leakage is detected, the degraded valve (s) should be repaired or replaced per the Code.

The proposed alternative would, therefore, provide reasonable assurance of operational readiness and a reasonable alternative to the Code.

40

l'. '

Based on the determination that compliance with the Code leak rate test method requirement is impractical and burdensome and considering the licensee's proposed alternative, relief should be granted as requested.

3.13 [gre Sorav system 3.13.1 CJtieoory C Valves 3.13.1.1 Relief Regni. The licensee requests relief in Note V55 from the test method and frequency requirements of Section XI. Paragraph IWV 3520, for core spray check valves, 14 CSP 62A, 628 -76A, and -76B. The licensee proposes to perform sample disassembly and inspection of these valves per GL 89 04, Position 2.

3.13.1.1.1 Licensee's Basis for Relief. There are no position indicators on these valves to verify closure, thus, the only practical method of verifying closure is by means of back leakage tests. These valves cannot be verified to close by means of a reverse flow test.

Al ternate _ Tu11qq. In accordance with GL 39 04, Position 2, at least once each opert'ing cycle (normally a refueling outage) one valve will be disassembled, inspected, and verified to be operable. If a valve is found to be inoperable, the other valves will be disassembled and inspected )rior to startup. The inspection schedule will be such that all valves in tie group are inspected at least once every six years.

3.13.1.1.2 Evaluation. These valves perform similar functions in the core spray system. Valves 14 CSP 62A and 62B ensure minimum flow conditions are met for the core spray holding pump. Valves 14 CSP 76A and -

76B are in the keep fill lines from the condensate transfer system. Both sets of valves must close to prevent diversion of flow. However, testing their closure capability requires establishing a reverse differential pressure across them.

From the review of system prints, it appears impractical to individually test these valves closed quarterly or during each cold shutdown. This test might not be practicable at any frequency. System redesign and modification is needed to make testing quarterly or during each cold shutdown reasonable.

This would be costly and burdensome to the licensee. It might be difficult to test and verify the reverse flow closure capability of these valves even at refueling outages. However, testing of the 14 CSP 76A and -76B valve series, as a pair, might be feasible during the qudrterly core spray pump test given the isolation valves and potential test locations in the system.

The licensee proposes to perform sample disassembJy and inspection of these valves each operating cycle per GL 89 04, Position 2. This is done to verify closure capability. Disassembly, inspection and manual full-stroke of the valve disk can adequately ascertain valve internal condition. However, this technique should be used only when full forward or reverse flow testing is impractical. The NRC considers disassembly and inspection a maintenance procedure not a test equivalent to exercising produced by fluid flow as required by Section XI. The procedure has riscs, which might make its routine 41 I

l

use as a substitute for testing undesirable when some testing method is possible. This is particularly true for verifying closure casability. The procedure is a valuable maintenance tool that can provide muc1 information about valve internal condition. As such, the procedure should be performed .

under the maintenance program at a frequency commensurate with the valve type and service.

It is difficult to test these valves closed quarterly or at cold shutdowns. The licensee should actively pursue use of alternate testing methods, such as non intrusive diagnostic techniques to demonstrate whether the valves swing fully closed when flow has ceased or reversed. When valve operational readiness cannot practically be determined by testing inspection may be used as an alternative. But, the licensee should perform post maintenance valve testing (e.g., forward flow and reverse flow closure capability, as practicable) before returning the valve to service.

The licensee's proposed disassembly and inspection program is not thoroughly stated and it is not indicated that a manual stroke of the valve disk is included as part of the program. A determination that the proposal provides a reasonable alternative to the Code requirements cannot be made.

However, a check valve inspection program performed per GL 89 04, Position 2, can adequately determine valve condition and provides a reasonable alternative to the Code, in this case, during an interim period of one year or until the next refueling outage, whichever is longer. During this interim period the itcensee should consider non intrusive methods of testing closure capability et least during refueling outages.

Based on the determination that compliance with the Code is impracticable and burdensome, and considering the licensee's proposal, interim relief should be granted for one year or until the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 89-04, Position 2, each refueling outage and evaluates alternate test methods as discussed above. During the interim period the licensee should evaluate other test methods, including non intrusive.

Additionally, the licensee should evaluate the feasibility of testing valves 14 CSP 76A and 76B, for closure capability of the pair, during quarterly core i spray pump testing.

3.14 BHR Service Water System 3.14.1 Cateaory B Valves ,

3.14.1.1 Relief Reauest. The licensee requests relief in Note V53 from the test method requirements of Section XI, Paragraphs IWV 3413(b) and

-3417(a), for RHR lube oil cooler valves, 1050V 101A thru 1010. The licensee l proposes to verify evidence of valve movement within five seconds of actuation during quarterly pump testing and to check flow rate through the coolers each operating cycle.

3.14.1.1.1 Licensee's Basis for Relief. These are rapid acting solenoid valves with no position indication. Therefore the only practical method of verifying valve operation is by monitoring cooling water discharged 42

-- -. , -- - - c -

from the cooler drain lines. This satisfies the requirements for exercising per IWV-3412[b), however, by utilizing this method, a true value for valve stroke time cannot be accurately determined. in addition, due to the lack of precision related to stroke time measurements derived from this method, a wide range on measurements (greater than 50%) is expected. Adhering to the requirements of IWV-3417(a) would result in frequent and unnecessary testing at a monthly frequency Measuring the time interval from pump start to the time water is emitted from the drain lines will provide a measure of valve stroke time as well as the degree of valve opening. Should either of these degrade, the measured time interval will lengthen providing indication that a problem exists.

Typical transit time measurements are in the range of 1 3 seconds indicating a flow rate greatly in excess of that required for cooling. The minimum cooling water flow equates to approximately 11 seconds for the most limiting case.

Based on this, establishing a limit of five seconds for initiating monthly testing is reasonable and conservative.

The drain lines from the coolers are open ended and have no convenient means cr ..,=.turing flow through the coolers. Thus, ascertaining that a valve has " full struxed" is not possible by this simple timing technique. Flow rate, however, can be determined by collecting discharged water over an elapted period of time. Such testing, done at a frequency of once each operating cycle in conjunction with the " stroke" timing described above provides adequate assurance that cooling water flow to the lube oil coolers is adequate.

Alternate Testing. These valves will be exercised in conjunction with the testing of the respective RHR service water pumps and a measure of " stroke time' using the time interval from pump start to the emission of water from the cooler drain line will be recorded. Should this time interval exceed five seconds, the testing frequency will be increased to once each month until corrective action is taken. Once each operating cycle a flow rate check will be performed to verify flow through each cooler is satisfactory.

3.14.1.1.2 Evaluation. These solenoid valves are enclosed and are not equipped with remote position indicatier.. The valves have no manuni control switches but instead are controlled by system der.and for cooling water. This makes obtaining accurate stroke times for these valves very difficult. System modifications might be necessary to directly measure the stroke times of these valves and would be expensive and burdensome to the licensee, but it may be prudent at some later date to install provisions to allow accurate stroke time testing of these valves. However, some method of stroke timing or otherwise adequately evaluating these valves' condition is r.ecessary for determining their operational readiness. ,

The licensee proposes to determine timely valve actuation by verifying system flow begins within five seconds of the signal to these valves to open.

if this stroke time criteria is exceeded the licensee will increkse the test frequency to monthly. Also, once per operating cycle the flow rate through these valves will be evaluated. The licensee's proposal allows an adequate assessment of the condition of these valves and provides an reasonable 43

alternative to the Code test requirements for a short term interim period of one year or until the next refueling outage, whichever is longer. During this period, the licensee should consider alternate methods for accurately stroke time testing these valves. Methods employing magnetics, acoustics, .

ultrasonics, or other technologies should be investigated for their suitability. Also, the results of testing these valves, as proposed above, should be considered during this period to determine if the method adequately assesses component condition for the long term.

Based on the determination that complying with the Code requirements is impractical and burdensome and considering the licensee's proposal, interim relief should be granted for one year or until the next refueling outage, whichever is longer. During this period, the licensee should evaluate the effectiveness of their proposed method, as well as other alternate methods of accurately measuring the stroke times or otherwise monitoring the condition of these valves.

3.15 Traversina In Core Probe (TIP) Syst eJD 3.15.1 Oteacry A Valves 3.15.1.1 Relief Reauelt. The licensee requests relief in Note V50 from the test method requirements of Section XI, Paragraph IWV 3413(b), for TIP CIV, 07S0V 104A thru 104C. The licensee proposes exercise these valves via .

the TIP computer and to verify completion of valve cycling within 12 seconds.

3.15.1.1.1 Licensee's Basis for Relief. The computer control system for TIP system includes a provision for measuring valve cycle time (opened and closed) and not closure time alone. The sequence opens the

. subject valve (stroke <2 secor.ds), maintains it energized for 10 seconds (including the opening stroke), and deenergizes the valve solenoid allowing the valve to stroke closed (<2 seconds). The total elapsed valve cycle time is specified to be s 12 seconds.

Alternate Testina. The overall cycle time (opened and closed) for these valves will be measured and evaluated per IWV 3413 and IWV 3417, 3.15.1.1.2 Evaluation. These are CIVs in the TIP system. They close to isolate containment. Their o>eration is controlled by the TIP system computer, which also measures the stroce time of the overall cycle. The system opens each valve, then 10 seconds later it closes the valve. The overall cycle time is verified to be s 12 seconds. Since the closure of the valve is initiated 10 seconds af ter the open signal and the acceptance criteria is s 12 seconds, the proposed acceptance criteria is essentially the

- same as that applied to rapid-acting valves per GL 89 0. 4 , Position 6, (52 seconds) and is applied to operation in the safety function direction.

1 The test results will be evaluated per IWy-3413 and -3417.

Additionally, these valves are verified leak tight during Appendix J testing each refueling outage. It is impractical to independently stroke time these i

valves to each position. This would require system redesign and modification, which would be a hardship to the licensee that would not be offset by a 44

- - . ,-a __-,._,..,c-,, g - . - ---w---- , , . . , ._- ,

compensating increase in the level of quality or safety. The proposed testing allows an adequate assessment of operational readiness and provides a reasonable alternative to the Code requirements.

~

Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements and considering the hardship -

that would be placed nn the licensee without a compensating increase in safety, relief should t>e granted as requested.

4 N,

4 4

e 4 0

o APPENDIX A IST PROGRAM AN0KAllES A-1

9 0 e 8 e

O 6

e A-2 s

APPE MIX A ISi PROGRAM ANOMAlllS Su mcrized below are inconsistencies and oat W ons in the IST pr0gren .

noted during this review. The licensee should resolve these ittas is ,

indicated.

1. Note P2 (See Sectton 2.1.1 of this report) requests relief from measuring inlet and differential pressure per the Code for the RHRSW and ESW pumps. The licensee proposes to measure the elevation difference between the forobay water level und discharge pressure gauge and to ensure adequate suction pressure is available. Differential pressure will be calculated. Direct measurement of inlet or differential pressure is impractical. Calculating pressure is not impractical or burdensome. Relief should be granted from directly wasuring inlet or differential pressure provided these par 6 meters are alculated and the calculations meet the accuracy requirements of Table M 4110 1 for direct measurements (12%).

2. Note P7 (See Section 2.2.1 of this report) requests relief from the pump run time and direct measurement of flow rate requirements for the SLC pumps. The licensee proposes to measure the rate of water level change in the test tank during a two minute test, but the accuracy of test results is not shown. The quality of the proposed method cannot be fully evaluated with the information provided. If changes are made to the test method to meet the Code accuracy, then relief should be granted to calculate flow rate.

Relief should be granted to run those pumps for two minutes as requested. Relief should 3130 be granted to calculate flow rate provided the calculation meets the accuracy requirements of Table  !

IWP-4110 1 for direct measurement (12%). If the Table accuracy cannot be met, the licensee should enmply with the Code or pro)ose and justify, in a relief request per 10 CIR 50.55a, an alternate met 1od for assessing pump operational readiness.

3. Note P7 (See Section 2.2.2 of this report) requests relief from the Code allcwable ranges of flow rate for the SLC pumps and proposes to expand these ranges. There is no information )rovided that shows the proposed ranges will require corrective action w1en necessary. There is no basis provided for these expanded ranges. Relief should not be granted from complying with the specified acceptance ranges for pump flow rate. The licensee should comply with the Code range requirements.

4. Note P9 (See Section 2.1.2.1 of this report) requJsts relief from the Code location for measuring RHRSW and ESW pump vi) ration. The licensee proposes to measure vibration on the lower motor bearing housing. The proposed method is not shown to be adequate for assessing pump operational readiness. Foi the short term interim period of six months after issuance of this TER, the licensee must do one of the following:

(1) justity the proposed measurement location, method, and acceptance A3

motsare vibration on the upper motor thrust bearing criteria, housing per(2)lla the applicable requirements of Part 6 for vibration measurerent, or (3) justify some other alternative to the Code that adequately assesses operational readiness of these pumpt (during this .

) interim period).

In the long term, that is within ene year of issuance cf this TER, the licensee should investigate alternate methods, such as attaching accelerometer or displacement probes to the pumps (as described in the referenced EPRI report), to adequately assess pump operational readiness. Before the end of the interim period the licensee should provide the NRC the results of this evaluation with an implementation schedule. Alternately, if the licensee can show that measuring vibration at the proposed location and applying Code specified vibration acceptance criteria is equivalent to or provides a reasonable long-term alternative to the Code, this information should be provided to justify granting relief.

5. Note P13 (See Section 2.2.4 of this report) requests relief from the vibration instrument frequency response range requirements for the St.C pumps and proposes to use existing instruments. The proposal gives some assurance that pum) degradation will be detected. However, for lower frequencies the vi) ration measurement is less accurate than required.

The Code acceptance ranges are based on Code accuracies. Also, sufficiently accurate instruments are comercially available.

Conservative vibration acce)tance criteria should be assigned beforr the next test. This criteria siould be based on the best estimate of accuracy. With the above provision, the proposal should give adequate assurance of o)drational readiness during an interim period of one year.

The licensee siould procure instrun,ents that comply with the Code frequency response requirements within one year after issuance of this TER.

6. Note P15 (See Section 2.1.4.1 of this report) requests relief from the method of measuring pump bearing vibration for all pumps in the IST program. The licensee proposes to measure vibration in either displacement or velocity units, comply with the acceptance criteria of OMbil989, Part 6, Tables 3 and 3a, and evaluate test data per IWP 3100.

The vibration testing program in OH 6 specifies instrument requirements and many other attributes that are not addressed in the licensee's proposal. Additional information is needed to fully evaluate and approve the pro)osed program with its differences from the program in OH 6. Relief $1ould be granted to use the vibration program as stated in OH 6 provided all vibration measurement requirements are followed.

7. Nota PIB (See Section 2.5.1 of this report) reque'sts relief from the flow rate instrument accuracy requirements for the ESW pumps and proposes to use existing installed instruments to measure flow rate.

The proposed instrument accuracy does not deviate significantly from the Code and should allow an adequate assessment of pump condition and provide a reasonable alternative to the Code for an interim period of A-4

one year or untti the next refueling outage, whichever is longer.

However, not enough infomation is provided to determine that this proposal is an acceptable long ters alternative to the Code accuracy requirements. During the interim period the licensee should evaluate .  :

changes to the test procedures or other methods of complying with the Code accuracy requirements. If compliance is impracticable, the licensee should submit additional information that supports this detemination. . Interim relief should be granted for one year or until the next refueling outage, whichever is longer.

8. NoteV6(SeeSection3.3.1.1ofthisreport)requestsreiteffromthe l test frequency requirements for check valves in the RCIC turbine steam exhust line to the sup;ression charher. The licensee )roposes to ,

verify closure during tie Appendix J 1eak rate test enci refueling outage. System piping diagrams show adequate isolation valves and test "

taps for reverse flow testing these valves more frequently tha'i proposed. The licensee has not shown that exercising these u ves t closed quarterly is ig ractical or burdensome. Relief should not be '

gi anted. The test provisions should be used to exercise these valves closed per IW 3521.

9. Note V7 (See Section 3.4.3.1 of this report) requests relief from testing per the method and frequency requirements for RBC check valves.

The licensee proposes to verify closure capability by sample disassembly and inspection of at least two valves each o>erating cycle.

Disassembly, inspection and manual full stro(e of the valve disk can adequately ascertain a check valve's internal condition. However, this technique shod 1d be used only when full forward or reverse flow testing is impractical. .

The NRC considers disassembly and inspection a maintenance procedure not a test equivalent to exercising produced by fluid flow as required by .

Section XI. This procedure has some risks, which may make routine use as a substitute for testing undesirable when some testing method is possible. Disassembly an! inspection is a valuable maintenance tool

.that can provide much infomation about valve internal condition. As such, the-inspection should be arformed under the maintenance program at a frequency commensurate witt the valve type and service.

It is clearly difficult to test these valves closed quarterly or at cold shutdowns. But, the licensee has not shown that this is impractical during refueling outages. During the outage, adequate time should be available for RBC system reconfiguration and draining and flushing if necessary. The licensee should actively pursue use of alternate testing methods, such as non intrusive diagnnstic-techniques to demonstrate whether they swing fully closed when flow has cea' sed.

The licentee's proposed disassembly and inspection program is not l thorough.) stated and does not include a manual stroke of the valve disk. A determination that the proposal provides a reasonable l

alternative to the Code requirements cannot be made. However, a check I A5 l -

L - - - - - . , . - , - - - -- - - - - . - - - ---.-.- -,-

valve inspection program performed per GL 89 04, Position 2, can adequately determine valve condition and provides a reasonable alternative. In this case, the procedure would be a reasonable alternative durirg an interim period. -

Interim relief should be granted for one year or untti the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 89 04, Position 2. During this interim period the Itcensee should investigate other test methods, including non intrusive.

10. Note V12 (See Section 3.5.1.1 of this report) requests relief from the test frequency requirements for feedwater system check valves. The licensee proposes to verify closure during the Appendix J 1eak rate test each refueling outage. The feedwater system is configured with isolation valves and test taps provisions should allow reverse flow(located closure inside testingthe drywell).

during cold These shutdowns when feedwater flow is stopped and the drywell is de-inerted.

The licensee has not shown that testing these valves is impractical or burdensome in that cold shutdown condition. Relief should be granted from the Code test frequency requirements )rovided these valves are closure tested during each cold shutdown w1en the containment is de inerted and each refueling outage,

11. Note V14 (See Section 3.6.1.1 of this report) requests relief from the test frequency requirements for instrument air system check valves. The licensee proposes to verify closure during the Appendix J 1eak rate test each refueling cutage. lesting these valves is not shown to be impracticable during cold shutdowns when containment is de-inerted.

These valves should be tested during that cold shutdown condition.

Relief should be granted from the Code test frequency requirements provided these valves are closure tested during each cold shutdown when the containment is de-inerted and each refueling outage.

The licensee also requests relief from the frequency requirements in Cold Shutdown Justification No. 11 for these instrument air valves. The licensee proposes te exercise them during cold shutdowns when the containment is de inerted. This is the appropriate test frequency for these valves, as stated above. Ralief should be granted to .est at that frequency. This cold shutdown justification should be deleted fror the program. Note V14 should also be revised and resubmitted. These valves should be tested as described above.'

12. Note V17 (See Section 3.8.2.1 of this report) requests relief from the test method and frequency requirements for HPCI turbine exhaust line vacuum breaker check valves. The licensee )roposes to verify closure by disassembly and inspection of one valve eac1 operating cycle. However, according to system prints, the line containing these valves has isolation valves and test taps accessible outside of the suppression chamber. This should allow testing with air or nitrogen, to both the A-6

open (which tests both valves) and closed (which confirms only the closure capability of one valve of tne pair) positions.

Relief should be granted provided the pair is verified closed quarterly ,

or at cold shutdowns, as practical. if excessive leakage is noted through the pair, both valves must be declared inoperable, inspected and repaired or replaced prior to their return to service.

13. Note V24 (See Section 3.11.1.1 of this report) requests relief from the test method requirements for several RHR and core spray CIV and P!Vs.

The licensee pro)oses to test them per the Ap)endix J Type C, .

requirements. T1e request is considered by tie licensee to be approved per GL 89 04, however, a significant change was made to the alternate test that was proposed in the earlier (approved) submittal. Therefore, the request is evaluated.

The licensee's IST program indicates that the GL 89 04 requirements will be met. Testing per Appendix J and Paragraphs IWV 3426 and 3427(a), as specified in GL 89 04, Position 10, gives adequate assurance of operatibnal readiness for performing the containment isolation function.

The licensee must meet the requirements of Paragraphs IWV 3426 and -

3427(a) for assessing the CIV function of the identified valves per Position 10. The requirements of IWV-3427(b) are applicable to every Category A valve that performs a leakage restriction function, other than or in addition to, containment isolation. Valves in this group include pressure isolation valves, even if they also perform a containment isolation function.

Relief should be granted provided the licensee tests these valves to the requirements of Appendix J, Type C, and Paragraphs IWV-3426 and -3427(a) per GL 8f 04, Position 10. This relief is limited to assessing the containmect isolation capability of these valves. Relief from IWV-3427(b) rpplies only to testing of the containment isolation function, for Category A valves that perform any other leakage rostriction function, in addition to or other than containment isolation, the requirements of IWV 3427(b) should be met.

The licensee also indicates in the request that the LLRT results are ccnservative compared to the water leak rate test. If the licensee develops a test methodology, using low pressure air or gas, and can demonstrate that it is conservative for the affected com)onents, this method should be proposad for consideration. However, tiere is not I

cnough information provided to evaluate and recommend approval of that aspect of the licensee's proposal.

14. Note V30 (See Section 3.11.2.1 of this report) re* quests relief from the test method and frequency requirements for the RHR system keep fill l check valves. The licensee proposes to verify closure by disassembly I

and inspection each o)erating cycle. The closure capability of each series valve pair mig 1t be verified by leak testing the pair. This l should be performed quarterly or during cold shutdowns as practicable.

A-7

Disassemb;y and inspection per GL 89 04, Position 2, could be done for preventative maintenance purposes, but will not be required for inservice testing if the inkage testing is performed. Relief should be granted provided the pair of series check valves is verified closed .

quarterly or at cold shutdowns, as practicable, if excessive leakage is noted through the pair, both valves in the affected series must be repaired or replaced prior to their return to service. If the licensee determines that the leakage testing cannot be performed at the Code required frequency, a relief request should be submitted.

15. Note V31 (See Section 3.4.1.1 of this report) requests relief from the test frequency requirements for valves in the RBC system. The licensee proposes to verify closure with the Appendix J 1eak rate test each refueling outage.

with operators, and These can be valves closed are andoutside reopened of containment,ltof locally. Re shouldare equipped not be granted from the test frequency requirements as requested. These valves should be exercised per the Code.

16. Note V32 (See Section 3.11.2.2 of this report) requests relief from the test method and frequency requirements for check valves in the RHR system minimum flow lines. The licensee proposes to verify full flow open and reverse flow closure by sample disassembly and inspection once per operating cycle. Testing is preferred over valve disassembly and inspection, particularly for closure capability. It might be practical to test te verify these valves open fully or sufficiently to pass the required minimum flow during quarterly RHR pump testing. If a test, such as the one described in this report, or another suitable non intrusive test method, can verify valve full stroke open capability of these valves the test should be used in lieu of disassembly. The licensee should evaluate non intrusive methods of testing the open capability per GL 89 04, Position 1.

The NRC considers check valve disassembly and inspection to be a maintenance procedure with risks. This may make its routine use as a substitute for testing undesirable. Testing these valves closed is clearly difficult. But, the licensee should actively pursue use of alternate testing methods, such as using non intrusive diagnostic techniques, to exercise the valves to both positions.

Interim relief should be granted for one year or until the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 89 04, Position 2, as well as the proposed exercising. By the end of th u period, the licensee should implement the testing per the Code or GL 89 04.

17. Notes V33, V34, and V45 (See Sections 3.4.2.1, 3.8.1.1, and 3.9.1.1 of this report) request relief from the test frequency requirements for various check valves. The licensee proposes to verify closure during Appendix J 1eak rate testing each refueling outage. The system prints show local test connections and isolation valves to allow reverse flow l

A8

cicsure testing these valves. Deferring testing is not justified.

Relief 'should not be granted to defer testing the closure capability of these valves until Appendix J testing is done at refueling outages.

These valves should be tested per !WV 3521 to verify their closure -

)

capability, j During the evaluation, another potential concern was noted. For l instance, Note V45 requests relief from exercising certain ESW system ,

cher'( valves closed per the Code test frequency requirements. The  ;

proposed alternate test addresses only closure. However, the affected valves tnay also need relief from testing open per the Code test frequency requirements. Relief is not granted from the full stroke open exercise frequency requirement. The licensee should evaluate this issue and address it appropriately for affected components.

18. Note V36 (See Section 3.12.1.1 of this report) requests relief from the test frequency requirements for the CAD system containment isolation check valves. The licensee proposes to verify closure during the Appendix J test each refueling outage. The system prints show local test connections and isolation valves to allow reverse flow closure testing. Only one train needs to be secured to test each pair. The licensee's basis for relief does not justify deferring testing. Relief should be denied. These valves should be exercised closed per the Code.

19. Note V49 (See Section 3.9.2.1 of this report) requests relief from the exercising frcquency requirements for manually operated ESW volves, 46(70)ESW 101 through 104. The licensee proposes to exercise them when the respective chilled water systems are drained, but there is no frequency specified. Relief should be granted provided these valves sre exercised as close to the Code frequency 9s prat.ticable and no less than once each refueling outage.

20. Note V52 (See Section 3.7.1.1 of this report) requests relief from the frequency requirements for ESW to control room chiller valves. The licensee aroposes to exercise them closed once every two years. The licensee las not shown that the proposal is an acceptable alternative to the Code frequency. Relief should not be granted to increase the test interval for these valves to once every two years.

21. Note V65 (See Section 3.13.1.1 of this report) requests relief from the test method and frequency requirements for core spray check valves. The licensee proposes to perform sample disassembly and inspection of these valves per GL 89 04, Position 2 to verify their closure capability.

Testing the closure capability of the 14 CSP 76A and 76B valve series, as a pair, might be feasible given the isolations.and potential test locations in the system. This might be done during the quarterly core spray pump test.

Interim relief should be granted for one year or until the next refueling outage, whichever is longer, provided the licensee performs check valve disassembly and inspection per GL 89 04, Position 2 and A9

f.

evaluates alternate test methods as discussed. During the interim period'the licensee should evaluate other test methods, including non intrusive. Additionally, the licensee should evaluate the fessibility of testing the series of valves 14 CSP 76A and 760 cic2ed -

during quarterly core spray pump testing.

22. Note V53 (See Section 3.14.1.1 of this report) requests relief from the test method requirements for RHR lube oil cooler valves and proposes to verify evidence of valve movement within five seconds of actuation, quarterly, and to check flow rate through the coolers once each operating cycle. The proposal allows an adequate assessment of the condition of these valves and erovides an reasonable n1ternative to the Code test requirements for a short term tuterim period.

During this period, the licensee should consider alternate methods for testing these valves. Methods employing magnetics, acoustics, ultrasonics, or other technologies should be investigated. Also, the results of testing these valves, as proposed, should be evaluated during thii period to determine if the method adequately assesses component condition for the long term. Interim relief should be granted for one year or until the next refueling, whichever is longer. During this period, the licensee should evaluate the effectiveness of their proposed method, as well as other alternate methods of accurately measuring the stroke times or otherwise monitoring the condition of these valves.

23. Co'.d Shutdown Justifications No. 8 and 12 (See Sections 3.10.1.1 and 3.10.3.1 of this report) request relief from the Code test frequency requirements for the ADS relief line vacuum breaker valves and the MSIVs, respectively. The licensee proposes to exercise them during cold shutdowns when the containment drywell is de inerted. These requests are presented as cold shutdown justifications. However, testing at a reduced frequency, less than each cold shutdown, is not according to the Code. The requests were evaluated in the TER like relief requests.

Relief should be granted to test at the proposed frequency. These should be revised and submitted with the next program revision as relief requests, if the drywell will be de inerted each cold shutdown, then relief is not needed. In this case, a statement to the effect that the drywell will be de inerted each cold shutdown should be included in the IST program.

24. The Authority transmitted their 'fing1 Response to NRC Generic Letter 8904RegardingGuidanceonDevelopingAcceptableInserviceTesting Programs by a letter to NRC dated March 30. 1990. In Attachment 1, page 3 of 4 to the letter the Authority states that exception is taken to GL 89 04, Position 8. If the position is deemed unreasonable for certain cases, these cases should be described in detail so that they can be evaluated. And, a relief request with this information should be submitted to NRC for review within one year of receipt of this TER.

25. Notes Vl9 and V46 (See Section 3.1.3.1 of this report) seem to conflict with each other. Note Vl9 also conflicts with GL 89 04, Position 10, A 10 i

N..

k,. I

. g* j I

' Containment Isolation Valve Testing.' Position 10 states that 'the Itcensee must comply with the Analysis of Leakage Rates'and Corrective i e Action requirements of Paragraphs IWV 3426 and .3427Ca).' Paragraph 4- IWV 3426 requires that leakage rates for specific vahves be compared to

• previous measurements and with permissible rates. Note Vl9 contains a  ;

I list of containment isolation valves and proposes to test and evaluate  ;

valves in groups. This implies that individual valve leakage rates are t not determ ned. The note also states that valves may be tested in the

' wrong direction." Note V46 is indicated to be pre approved and states i that the valves.will be tested per GL 89 04, Position 10. The licensee should delete or revise and resubmit Note Vl9. For additional ,

information on this topic, see Section 3.11.1.1 of this report, which t presents the evaluation of Note V24 on leak testing CIVs and PlYs.

r

[

t i

[

h A ll

._ ...._m.,_...____..--.___--____...__.__.____.-_.._.___.-._.