ML20126C201

Responds to NRC Se/Ter Dtd 920917,providing Results of NRC Review of Listed Util Submittals Re Relief Requests for IST Program for Pumps & Valves.Revised Relief Requests & Cold Shutdown Test Justifications Encl

ML20126C201
Person / Time
Site:	Farley
Issue date:	12/17/1992
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212220416
Download: ML20126C201 (30)

Text

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9 Southern Wclear Operating Company A . Post OMce Box 1295 g .Y Dirmingham, Alabama 35201 Telephone 205 868 5086

__a,, sem1nc<o ~ mace <ogc<eties c omgeev Vse President the Southem electoc system ,

December 17, 1992 Docket Nos. 50-348 50-364 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Joseph M. Farley Nuclear Plant - Units -l & 2 Inservice Testing (IST) Program for ASME Code Class 1. 2 and 3 Pumps and Valves 2

l Gentlemen:

t This letter is in response to the NRC Safety Evaluation / Technical Evaluation Report (SE/TER) dated September 17, 1992. The SE/TER provided

the results of the Nuclear Regulatory Commission (NRC) staff's review of the information provided by Southern Nuclear.0perating Company (SNC) letters dated July 26,1991, July 29,1991, December 3,-1991, December 30, 1991 (2 letters), and April 10, 1992 (2 letters), concerning the relief requests for Joseph M. Farley Nuclear Plant Units 1 and 2, Inservice

Testing (IST) Program for Pumps and Valves. .These submittals included j responses to the IST program action ite:ns that were identified in the NRC's i

Safety Evaluation (SE). issued by letter dated May 23,.1991, and to the

NRC's request for additional information contained in a letter dated February 14, 1992.

.The September 17, 1992, SE/TER denied three relief _ requests and stated that compliance with applicable ASME XI requirements and Generic Letter 89-04

guidelines would be required in three months.. Two of the reliefs were withdrawn and replaced with cold shutdown test: justifications in compliance j with ASME XI requirements. The remaining. relief _ request, Q1(2)N2S-RV-1, has been revised and is being resubmitted because the-pressure decay type test-proposed may be- considered an alternative test requiring relief.

F Performance of the pressure decay type test during cold shutdown complies j with the applicable ASME Section XI requirements and)!RC Generic Letter 89-04 guidelines..

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U. S. Nuclear Regulatory Commission Page 2 The NRC SE/TER also provisionally granted certain reliefs. A summary of these items was documented in Section 5 of the SE/TER, The SNC response to each of the action items listed in Section 5 of the SE/TER, including those denied and provisionally granted, is summarized in Enclosure 1. Revised relief requests and cold shutdown test justifications for Unit I and Unit 2 are included in Enclosures 2 and 3 respectively.

SNC respectfully requests that the relief requests be reviewed and granted by June 15, 1993.

If there are any questions or if additional information is needed, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY r

DEM/AJP:cht-ISTEFB.NRC Enclosures cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell 4

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!s j Enclosure 1 Southern Nuclear Operatina Company ResDonse tQ

NRC September 17. 1992 SE/TER Action Items Reference SE/TER Section 5.

. Section Response

5.1 See revised relief request PR-10.

5.2 See cold shutdown testing justification Q1(2)B13-CS-2. The FSAR has been revised to indicate the modification made

(PCNB88-2-5245) rerouting the discharge of the vent system to the pressurizer relief tank.

5.3 See revised relief requests Q2E13-RV-1 (Version 1), Q2E13-RV-1 (Version 2) and Q2E13-RV-4 (Version 1).

l 5.4 See revised relief request Q1(2)E21-RV-1, 1

5.5 See revised relief request Q1(2)E21-RV-4.

5.6 See revised relief request Q1(2)N23-RV-1.

5.7 See cold shutdown testing justification Q1(2)P19-CS-2.

5.8 See revised relief request Q1(2)P19-RV-3. These valves have been withdrawn from the IST Program; therefore the relief request is being withdrawn. The valves are not in ASME Class 1, 2 or 3 piping, and instrument air systems do not fall within

the requirements of Regulatory Guide 1.26 for the classification of safety related components. These valves will be added to the FNP preventative maintenance program for the 1 performance of appropriate testing, t

5.9 Code Case N-472 will be used.in its entirety-for pump vibration testing, thus relief is not required.

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ENCLOSURE 2

-g I Summary of Changes to the J. M. Farley Nuclear Power Plant Unit No. 1 Second Ten Year Inservice Testing Program l

for ASME Code Class 1, 2, and 3 Pumps and Valves Description / Reason for Chanae

! 1. Relief Request PR-10: This relief request has been revised to add i individual service water pump testing at each refueling outage and i at any cold shutdown of sufficient duration to support the testing.

Additional actions have been specified to address corrective actions

in the event three pumps are not available to support three dual pump testing.

l 2. Relief Request QlB13-RV-1: This relief request has been withdrawn

[ and replaced with cold shutdown justification QlB13-CS-2.

3. Relief Request QlE21-RV-1

This relief request has been revised to add partial exercising with flow while changing. modes from power j operation to cold shutdown or during cold shutdown.

4. Relief Request Q1E21-RV-4: Relief Request.has been revised to

, perform full stroke exercising with flow for each check valve during

! each refueling outage.

5. Relief Request QlE21-RV-15: This approved relief request has been i revised to add additional justification discussed in the SE/TER that j supports why quarterly testing is not possible.

!- 6. Relief Request Q1N23-RV-1: This relief request has been revised to

[ add pressure decay type testing during cold shutdown andLat each j -refueling outage.

$ 7. Relief Request-QlP19-RV-2: This relief request has been withdrawn and replaced with cold shutdown-justification Q1P19-CS-2. -

8. Relief Request QlP19-RV-3: .This relief request.has been withdrawn.

. The subject valves are not required to be included in the IST

Program.

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e FNP 1-M-042 PUMP REUEF REQUEST PR-10 System: Service Water Pump: P001 A-A, P0018-A, P001C-AB, P001D-B, P001E B Class: 3 Function: Provide cooling water to safety-related equipment.

Test Requirement: IWP-3400(a) requires that a quarterly inservice test be run on each pump. l Basis for Relief: The Service Water System is designed so that during normal operation there are two pumps in each of the two trains operating, with a standby pump available to swing to either traln. Each pump has pressure gages, however flow instrumentation is installed only to measure the flow from each of the two trains.

Since flow instrumentation was not provided during construction for each pump, the only viable means of indMdually testing these pumps is by removal of one pump from service and measuring flow through the train with only one pump aligned. However, a flow of 32,186 gpm, which requires four pumps (or both trains operable) is required for normal operation per the FSAR. A condition where only one pump is aligned at a time to a train would result in degraded cooling water flow to essential or safety related equipment and is therefore an unacceptable method of operation. Furthermore, removal of one pump from the service water train could lead to an isolation of the turbine building service water supply lines causing a plant trip.

Since hydraulic performance of a degrading pump may be masked by the other pump when service water pumps are tested in pairs, FNP has developed analytical methods which can be used to determine Individual pump flow rate.

These analytical methods involve solving three equations involving dual pump flows for three Individual pump flow rates. These analytical methods have proven reliable in determl4ag individual pump degradation when the other pump in combination is campensating for the degraded pump.

Alternate Testing: Quarterly combined flow, differential pressure and vibration will be measured and compared to trierence values.

Whenever combined flow measurements are not in the acceptable range, individual pump evaluations, which consist of performing three dual pump combination tests at a reference differential pressure and solving analytical equations for individual flows, will be performed. if three pumps are not immediately available to support this testing, tests will be performed as soon as three pumps are available. For the case in which three pumps are not immediately available to support testing and flow is in the ALERT Range, dual Page 1 of 2

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FNP 1 M442 1

l 5 PUMP REUEF REQUEST PR 10 (cont) 1 i pump testing of the two pumps in the ALERT Range will be performed at double

the regulred frequency untR three pumps are available. Corrective action will be i taken on the Individual pumps as a result of the evc!uation in accordance with

IWP 3230.

i Individual service water pumps testing will be performed at each refueling 1

outage and any cold shutdown of sufficient duration to support such testing.

! Individual pump testing will consist of monitoring pump flow, differentia!

pressure, and vibration and comparison of test data to reference values for each parameter, 1

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FNP 1 MC42 COLD SHUTDOWN TEST JUSTIFICATION 01813 CS 2 System: Reactor Coolant Valve: HV 1, HV 2, HV4, HV 4 Category: B Class: 2 Function: Valves open to vont the reactor vessel.

ASME Section XI Quarterly Test Requirements: Exercise, tim 9 and fall. (lWV 3411,3413 and 3415)

Cold Shutdown Test Justification: The head vent valves can not be exercised during normal operation with adequate assurance that an uncontrolled release of teactor coolant and a rapid RCS de.

pressurization would not occur. To exercise the valves open in any order could result in a potential pressure shock to the closed valve and a potential '8URP' reaction. The consequences of this reaction are too severe to warrant testing during normal operation.

Quarterly Part Stroke Testing: None, these are rapid acting valves and their operating logic does not allow for partial exercising.

Cold Shutdown Testing: Exercise, time and fall test.

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' FNP 1 M442 1 REUEF REQUEST Q1813 RV 1 (Withdrawn see 01813-CS-2) l 4

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FNP 1 M442 I REUEF REQUEST l

i OtE21 RV 1 System: SI/CVCS 4

Valve: OV026 Category: C ,

a l Class: 2 l 4 Function: RWST to charging pump suction line check valve.

ASME Section XI Test Requirements: Ver4y forward flow operability quarterly or at cold shutdown. (lWV-3521)

Basis for Rollef: ". he only possible method of full flow testing this valve is by aligning the RWST to j the charging pu.p suction and injecting full design flow into the RCS. Full flow 4

testing during normal operation is impossible because the charging pumps cannot develop full rated flow against RCS pressure, j Partial flow testing utilizing the charging pump cannot be performed during normal operation because water from the RWST is highly borated and injection into the j RCS could adversely affect reactivity.

Alternate Testing:

Valve will be partial exercised with flow while changing modes from power

operation to cold shutdown or during each cold shutdown.

Additionally, vase will be full exercised with flow during each refueling outage.

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I FNP 1 M 042 REUEF REQUEST

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01E21 RV-4 System: Sl/CVCS l Valve: Group 1 OVOC2A, QV062B, QV062C Group 2 - OV00GA, QV000B, OV0000 i Group 3 - QV078A, OV0788, OV078C Group 4 OV079A, OV0798, QV0700 Category: C Class: 1

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Function: Safety injectlon to the RCS check valves.

ASME Section XI Test Requirements: Verify full forward flow operability quarterly or at cold chutdown. (IWV 3521)

Basis for Rollef: It is impractical to full or part stroke any of these check valves with flow during normal operation because all of the associated flow paths bypass the regenerative heat exchanger and establishing flow through these valves would result in relatively cold water being injected into the RCS. The thermal stresses produced by injecting cold water could greatly reduce the service life of the injection noz2les.

l These valves cannot be full-stroke exercised during cold shutdowns because the RCS may not contain sufficient expansion volume to accommooste the flow required and a low temperature overpressure condition criuld occur, it is also impractical to perform a pa.i-stroke exercise of ths se valves during cold shutdowns. Part stroke testing would require lowering the ?.ressurizer level to accommodate the insurge volume and would result in an incri.: sect risk of a low temperature overpressure condition and possibly delay plant stari op. In addition, initiating flow through Group 3 and Group 4 valves would sw disturb RCS pressure isolation valves leading to further technical specification rfW.Jlred testing, ALARA concerns, and possible delay of plant start up.

Alternate Testing: All valves will be full stroke exercised with flow during each refueling outage. Either permanently installed or removable instrumentation will be ut!!! zed to confirm check valve exercising. Confirmation of full stroke exercising wl!I be either by flow 4

measurement or by the use of non-intrusive check vah e testing technology at the discretion of FNP.

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REUEF REQUEST OtE21-RV 15 I

System: SI/CVCS

! Valve: QV115A, B, C Category: C Class: 2

Function

Prevent loss of RCS Inventory upon break in the seal injection line, i

ASME Section XI i Quarterly Test l Requirements: Verify reverse flow closure quarterly or at cold shutdown. (lWV 3521)

Basis for Rollef: Reverse flow closure testing this valve will require Isolation of seal injection flow to

the reactor coolant pumps therefore testing during normal operation (quarteriy) is impractical.

Test performance will require personnel entry into the containment to position associated system valves and to set up testing equipment. Personnel entry into the

containment and performance of this test has the potential to

increase personnel radiation exposure, increase the potential for RCP seal and bearing damage due to interruption of seat injection flow, and prolong the shutdown due to the stringent requirements on personnel entry into containment and the time required to perform the test.

l Therefore the only practical method available to verify reverse flow closure is by pressure decay or leak testing at each refueling outage.

Alternate Testing

Reverse flow closure will be confirmed by a pressure decay type test or leak test procedure (similar to Appendix J, Type C test) at each refueling Miage. This type test will confirm that the check valve is capable of reverso flow t,.asure.

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FNP 1 M-042 i

I REUEF REQUEST l

I 01N23 RV 1 System: AuxHlary Feedwater j Valve: OV006, OV007A, OV0078 i

Category: C i

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Class: 3 i

Function: Condensate storage tank to auxillary feedwater pump suction line check valves.

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! ASME Section XI Test Requirements: Verify reverse flow closure quarterly. (lWV 3521)

, Basis for Relief: There are no system design provlsions for verification of reverse flow closure. The

ordy possible test method would involve isolating the condensate storage tank and 4

performing a pressure decay type test which confirms that the check valve is j closed. Performing this type test is impractical during normal operation since it j would render the auxillary feedwater system inoperable for an extended period of

time.

j Alternate Testing: Reverse flow closure will be confirmed by performing a pressure decay type test

at cold shutdown and at each refueling outage. This pressure decay type test will j confirm that the check valve is capable of reverse flow closure. If multiple

shutdowns occur, testing frequency is not to exceed quarterly.

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3 FNP 1 M442 COLD SHUTDOWN TEST JUSTIFICATION Q1P19-CS 2 System: Instrument Air Valve: OV004 Category: AC Class: 2 Function: Backup nitrogen supply to pressurizer PORVs.

ASME Section XI Cuarterly Test Requirements: Verify forward-flow operability (IWV-3521).

Cold Shutdown Test Justification: The only practical way to forward flow exercise this valve would be to isolate the normal instrument air supply to the PORVs and utilize the backup nitrogen supply and exercise a PORV. Isolating the instrument air supply outside the containment (01P19HV3611) results in isolation of the normal alt supply to all components located inside the contalnment that rely on normal Instrument air for their supply thus rendering them inoperable. Isolating the normal Instrument air supply to the PORVs only (01P19NV139) requires a contalnment entry which is not practical during normal ope *ction.

Quarterly Part Stroke Testing: None, these are rapid acting valves and control logic does not allow for partial exercising.

Cold Shutdown

. Testing: Valve will be forward-flow exercised by exercising a PORV at cold shutdown. If multiple shutdowns occur, testing frequency is not to exceed quarterly.

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FNP 1-M442 REUEF REQUEST 01P19 RV 2 (Withdrawn soo 01P19-CS 2)

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, ENCLOSURE 3 Summary of Changes to the J. M. Farley Nuclear Power Plant i' Unit No. 2 Second Ten Year Inservice Testing Program for ASME Code Class 1, 2, and 3 Pumps and Valves Description / Reason for Chance

1. Relief Request PR-10: This relief request has been revised to add

, individual service water pump testing at each refueling outage and at any cold shutdown of sufficient duration to support the testing.

Additional actions have been specified to address corrective actions in the event three pumps are not available to support three dual pump testing.

2. Relief Request Q2813-RV-1: This relief request has been withdrawn and replaced with cold shutdown justification Q2013-CS-2.

3. Relief Request Q2E21-RV-1: This relief request has been revised to add partial exercising with flow while changing modes from power 4

operation to cold shutdown or during cold shutdown.

4. Relief Request Q2E13-RV-1 (Version 1): This relief request has been revised to add partial exercising with air u ring cold shutdowns with additional justification for not partial stroke testing the valves during cold shutdown.

Relief Request Q2E13-RV-1 (Version 2): This relief request has

, been revised to add partial exercising valves QV002A(B) with air during cold shutdowns.

5. Relief Request Q2E21-RV-4: Relief Request has been revised to perform full stroke exercising with -ilow for each check valve during each refueling outage.

, G. Relief Request Q2E13-RV-4 (Version 1): This approved relief request has been revised to explain that the subject check valve is 4

partially exercised with flow quarterly during normal containment l spray pump testing.

7. Relief Request Q2E21-RV-15: This approved relief request has been revised to add additional justification discussed in the SE/TER that supports why quarterly testing is not possible.

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8. Relief Request Q2N23-RV-1: This relief request has been revised to add pressure decay type testing during cold shutdown and at each refueling outage.

9. Relief Request Q2P19-RV-2: This relief request has been withdrawn j and replaced with cold shutdown justification Q2P19-CS-2.

10. Relief Request Q2P19-RV-3: This relief request has been withdrawn.

The subject valves are not required to be included in the IST Program.

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FNP 2 M-067

PUMP RELIEF REQUEST 1 PR 10 a

1 System: Service Water Pump: P001 A-A, P0018 A, P001C-AB, P001D B, P001E B Class: 3 3

j Function: Provide cooling water to safety-related equipment.

Test Requirement: IWP-3400(a) requires that a quartoriy inservice test be run on each pump. l

! Basis for Rollef: The Service Water System is designed so that during normal operation there are two cumps in each of the two trains operating, with a standby pump available to swing to either traln. Each pump has pressure gages, however flow 2

Instrumentation is installed only to measure the flow from each of the two trains.

Since flow instrumentation was not provided during construction for each pump, the only viablo means of individually testing those pumps is by removal of ono l pump from service and measuring flow through the train with only one pump 1

aligned. However, a flow of ?.2.186 gpm, which requires four pumps (or both trains operable) is required for normal operation per the FSAR. A condition

, where only one pump is aligned at a time to a train would result in degradod

, coo!!ng water flow to essential or safety related equipment and is therefore an i unacceptable method of operation. Furthormore, removal of one pump from the service water train could lead to an Isolation of the turbine building service water supply lines causing a plant trip, i

Since hydraulic performance of a degrading pump may be masked by the other pump when service water pumps are tested in pairs, FNP has develop 0d analytical methods which can be used to determino individual pump flow rate.

These analytical methods involve solving three equations involving dual pump flows for three individual pump flow ratos. These analytical methods have .

I provea reliable in determining individual pump degradation when the other pump in combination is compensating for the degraded pump.

l Alternate Testing: Quarterly combined flow, differentla! pressure and vibration will be measured and compared to reference values.

Whenever combined flow measurements are not in the acceptable range, individual pump evaluations, which consist of performing three dual pump combination tests at a reference differential pressure and solving analytical equations for individual flows, will be performec. it three pumps are not immediately available to support this testing, tests will be performed as soon as three pur a are available. For the case in which three pumps are not immediatu available to support testing and flow is in the ALERT Range, dual Page 1 of 2 l

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, FNP 2 M467 PUMP REUEF REQUEST PR 10 (cont) a 1 pump testing of the two pumps in the ALERT Range will be performed at double j the required frequency until three pumps are available. Corrective action wl!! be taken on the Individual pumps as a result of the evaluation in accordance with i fWP 3230.

IndMdual service water pumps testing will be performed at each refueling outage and any cold shutdown of sufficient duration to support such testing, i individual pump testing wl!I consist of monitoring pump flow, differential pressure, and vibratlon and comparison of test data to reference values for each parameter.

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FNP 2 M467 COLD SHUTDOWN TEST JUSTlFICATION 02B13-CS 2 System: Reactor Coolant Valve: HV-1. HV 2, HV-3, HV 4 Category: B Class: 2 Function: Valves open to vent the reactor vessel.

ASME Section XI Quarterly Test Requirements: Exercise, time and fall. (IWV 3411,3413 and 3415)

Cold Shutdown Test Justification: The head vent valves can not be exercised during normal operation with adequate assurance that an uncontrolled release of reactor coolant and a rapid RCS de-pressurization would not occur. To exercise the valves open in any order could result in a potential pressure shock to the closed valve and a potential

• BURP' reaction. The consequences of this reaction are too severe to warrant testing during normal operation.

Quarterly Part Stroke Testing: None, these are rapid acting valves and their operating logic does not allow for partial exercising.

Cold Shutdown Testing: Exercise, time and fall test.

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1 FNP 2 M-067 2

, REUEF REQUEST

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} O2B13 RV 1

! (Whhdrawn see 02B13-CS-2) ,

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FNP 2 M-067 REUEF REQUEST 02E21-RV 1 System: SI/CVCS Valve: QV026 Category: C Class: 2 Function: RWST to charging pump suction line check valve.

ASME Section XI Test Requirements: Verify forward flow operability quarterly or at cold shutdown. (lWV 352i)

Basis for Rollef: The only possible method of full flow testing this valve is by align!ng the RWST to the charging pump suction and injecting full design flow into the RCS, Full flow testing during normal operation is impossible because the charging pumps cannot develop full rated flow against RCS pressure.

Partial flow testing utilizing the charging pump cannot be performed during normal operation because water from the RWST is highly borated and injection into tha RCS could adversely affect reactivity, Alternate Testing: Valve will be partial exercised with flow while changing modes from power operation to cold shutdown or during each cold shutdown.

Additionally, valve will be fu'! exercised with flow during each refueling outage.

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RELIEF REQUEST 02E13-RV.1 (Version 1) l 1

System: Containment Spray

, Valvo: OV002A, QV0028 Category: C Class: 2

Functiori

Containment spray system inside contalnment isolation check valvos (OV002A, 8).

I ASME Section XI Quarterly Test

, Requirements: Verify forward-flow operability quarterly, (IWV-3521)

Pash for Rollef: The only way to verify full forward-flow operabl!!ty during normal operating or cold -

shutdown would be by using the pumps and injecting a large quality of water into the containment. Spraying the containment would result in extensive damage to safety-related equipment located inside the contalnment.

4 Partial exercising using air as a test medium is not possible during normal operation because Technical Specifications requires primary containment integrity in operating modes 1 4 and attachment of test connections would violato containment Integrity.

Alternate Testing: One of those valves will be disassembled and manually full stroke tested at each refueling on a staggered test basis. The valve internals will be verified as structurally sound (no loose or corroded parts) and the disk manually exercised to verify full stroke capability, if the disassembled valve is not capable of being full.

stroke exorcised or there is binding or failure of valve Internals, the remaining valve must also be disassembled, inspected, and manually full stroke exercised during the same outage.

The disassembled valves will be part stroked with alt flow after reassembly Flow indication will be through Installed instrumentation, observod pressure chan.ps, level changes or through the use of ultrasonic (or similar) flow measuring devices.

Additionally, these valves will be partially exorcised using air as a test medium during cold shutdown. If multiple shutdowns occur, testing frequency is not to exceed quarterly.

Note: This relief request is applicable until the Unit 2 modification which supports full flow containment spray pump testing is implemented.

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i FNP 2 M-007 RELIEF REQUEST 02E13-RV 1 (Vorsion 2) 1 ,

j System: Containment Spray

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Valve: OV002A, OV0028, OV014 l Category: C Class: 2 Function: Containment spray syatem inside containment isolation check valves (OV002A, B) and RWST to containment spray pump suction line check valve (OV014).

ASME Section XI Quarterly Test

rot;lroments

Verify forward flow operability. (IWV 3521)

Basis for Rollef: The only way to verify full forward-flow operability during normal operation or cold shutdown would be by using the pumps and injecting a largo quality of water into the containment. Spraying the containment would resutt in extensivo damage to safety related equipm9nt located inside the containment.

Partial exercising using air as a test medium is not possible during normal operation becauso 'Tochnical Specifications requires primary containment integrity In operating modos 1 4 and attachment of test connections would violate containment Integrity.

Alternate Testing: The system has been modified such that spool plecos can be Installed downstream of these check valves. During refueling, these spool plecos will bo Installod and a full-forward-flow test performed by pumping water through these full-flow test lines to the contalnment refueling cavity. Because of the timo involved in installing tho spool pieces and the large q"sntity of water necessary, this test can only be performed at refueling.

Additionally, QV014 will bo partial-forward-flow veriflod during quarterly pump testing, and valves OV002A(B) will be partially exercised using air as a test medium during cold shutdown. If multiple shutdowns occur, testing frequency for valves OV002A(B) is not to exceed quarterly.

l Note: This relief request is not applicable until the Unit 2 modification which supports full flow testing of the containment spray pumps is completed.  ;

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FNP 2 M 067 RELIEF REQUEST 02E21-RV-4 1

1 System: Sl/CVCS i

l Valve: Group 1 OV002A, OV002B, OV0020 Group 2 OV006A OV000B, QV006C

! Group 3 - QV078A, QV0788, OV0780 Group 4 OV079A, OV0798, QV0790 i Category: C Class: 1 l 3

Function: Safety injection to the RCS check valves.

j ASME Section XI Test Requirements: Verify full forward flow operability quarterly or at cold shutdown. (IWV 3521)

Basis for Rollef: It is impractical to full or part stroko any of those check valves with flow during l normal operation because all of the associated flow paths bypass the regonorative l l heat exchanger and establishing flow through thoso valves would result in relatively 4

cold wator being injected into the RCS. The thermal stresses produced by Injocting cold water could greatly reduce the service life of the injection nozzles.

Those valves cannot be full stroko exercised during cold shutdowns because the RCS may not contain sufficient expansion volume to accommodate the flow required and a low temperature overpressure condition could occur.

It is also impractical to perform a part stroke exercise of these valves during cold shutdowns. Part-stroke testing would requito lowering the pressurizer level to accommodate the Insurge volume and would result in an increased risk of a low temperatt:ro overpressure condition and possibly delay plant start up. In addition, Initiating flow through Group 3 and Group 4 valves would also disturb RCS pressure isolation valves leading to further technical specification required testing, ALARA concerns, and possible delay of plant start up.

Alto. nato Testing: All valvos will be full stroke exercised with flow during each refueling outage. Either permanently installed or removable instrumentation will be utilized to confirm check valve exercising. Confirmation of full stroke exercising will be either by flow measutomont or by the use of non-intrusivo check valve testing technology at the discretion of FNP.

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FNP 2-M 007 REUEF REQUEST 02E13 RV-4 (Version 1)

System: Containment Spray f

! Valve: QV014 Category: C Class: 2 Function: RWST to containment spray pump suction line check valve.

ASME Section XI i Quarterly Test

. Requirements: Verify forward-flow operability. (IWV 3521)

Basis for Relief: The only way to verify forward-flow operability using flow would be by using the pumps and injecting a large quantity of water into the contalnment. Spraying the containment would result in extensive damage to safety-related oquipment located inside the containment.

There are no valves betwoon OV014 and the RWST to shut off flow during valve disassembly. The valve has been disassemblod, inspected and manually full stroke exercised three times since 1985 by freeze plugging the 12 in line just upstream of the valve. This has been done at refueling outages with the RWST dralned to minimum lovel. In each case the valve was found to be in excellent condition, with no visible signs of degradation. With the RWST at mlnlmum lovel there is a 06 foot head of water on the frooze plug. If the plug does not hold during disassembly a minimum of 30,000 gallons of water will flood the auxillary building with potential i severo damage to safety-related equipment.

Alternate Testing: The valve will be disassembled and manually full stroke exercised once overy three refueling outages using the freeze plug method described above. The valve i internals will be verifled as structurally sound (no loose or corroded parts) and the disk manually exercised to verify full stroke capability,

The disassembled valve will be part stroked with flow after reassembly. Flow Indication will be through Installed instrumentation, observed pressure changes, level changes or through the use of ultrasonic (or similar) flow measuring devices.

Additionally, this check valve is partla!!y exercised quarterly during containment spray pump surveillance testing when flow is recirculated to the RWST.

Note: This relief request is applicable until the Unit 2 modification which supports full flow testing l of the containment spray pumps is implemented.

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FNP 2.M407 i

l RELIEF REQUEST 02E21-RV 15 i l 1

System: SI/CVCS i

Valve: OV115A, B, C I

) Category: C Class: 2 Function: Prevent loss of RCS inventory upon break in the seal injection line, 1 ASME Section XI Quarterly Test a Requirements: Verify reverse flow closure quarterly or at cold shutdown. (IWV-3521) 1 Basis for Rollef: Reverse flow closure testing this valve will require isolation of seat injection flow to i the reactor coolant pumps therefore testing during normal operation (quarteriy) is Impractical.

Test performance will require personnel entry into the containment to position

associated system valves and to set up testing equipment. Personnel entry into the containment and performance of this test has the potential to

Increase personnel radiation exposure, increase the potential for RCP seal and bearing damage due to interruption of seal Injection flow, and

prolong the shutdown due to the stringent regulrements on personnel entry into containment and the time required to perform the test.

Therefore the only practical method available to verify reverse flow closure is by pressure decay or leak testing at each refueling outage.

l Alternate Testing: Roverse flow closure will be confirmed by a pressure decay type test or leak test procedure (similar to Appendix J, Type C test) at each refueling outage. This type test will confirm that the check valve is capable of reverse flow closure.

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l FNP 2-M467 l REUEF REQUEST 02N23 RV 1 System: Auxillary Feodwater Valve: OV000, OV007A, OV0078 Category: C Class: 3 Function: Condensate storage tank to auxillary foodwater pump suction lino check valves.

ASME Section XI Quarterly Test Roqulromonts: Verify reverse flow closuro quartorly. (lWV-3521)

Basis for Rellof: There are no system design provlsions for verification of reverse flow closuro. The only possible test method would involvo isolating the condensate storage tank and performing a pressure decay type test which confirms that the check valve is closed. Performing this type test is impractical during normal operation sinco it would render the auxillary foodwater system inoperable for an extended period of timo.

Alternate Testing: Reverse flow closure will be confirmed by performing a pressure decay type test during cold shutdown and at each refueling outage. This pressuro decay type test will confirm that the check valve is capable of reverso flow closure. If multiple shutdowns occur, testing frequency is not to exceed quarterly.

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FNP 2-M-067 i

1 COLD SHUTDOWN TEST JUSTlFICATION f O2P19 CS 2 1

j System: Instrument Air i

Valve: QV004 i Category: AC

! Class: 2 I

i Function: Backup nitrogen supply to pressurizer PORVs. l l

ASME Section XI )

Quarterly Test Requirements: Verify forward flow operability (IWV-3521).

} Cold Shutdown Test i

Justification: The only practical way to forward flow exercise this valve would be to isolate the

! normal Instrument air supply to the PORVs and utilize the backup nitrogen supply and exercise a PORV. Isolating the instrument air supply outside the containment (01P19HV3611) results in isolation of the normal air supply to all components located inside the contalnment that rely on normal instrument air for their supply i thus rendering them inoperable. Isolating the normal instrument air supply to the PORVs only (01P19NV139) requires a containment entry which is not practical i during normal operation.

i Quarterly Part Stroke Testing: None, these are rapid acting valves and controllogic does not allow for partial exercising.

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! Cold Shutdown Testing: Valve will be forward flow exercised by exercising a PORV at cold shutdown. If multiple shutdowns occur, testing frequency is not to exceed quarterly.

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'; a FNP 2-M467 RELIEF REQUEST 02P19-RV 2

', (Withdrawn seo 02P19-CS 2)

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A FNP 2-M-067 REUEF REQUEST 02P19-RV 3 (Withdrawn) 0 Page 1 of 1

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