ML18087A867

Safety Evaluation Supporting Relief from Inservice Insp Requirements Per 10CFR50.55a(g).Alternative Procedures & Schedules Defined

ML18087A867
Person / Time
Site:	Salem
Issue date:	04/12/1983
From:	NRC
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8304270117 830412 PDR ADOCK 05000272 P

PDR Enclosure SAFETY EVALUATION REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING.STATION, UNIT NO. 1 DOCKET NO. 50-272 I

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TABLE OF CONTENTS INTRODUCTION EVALUATION A.

General Considerations

1.

Safety-Related Components

2.

Valve Exercising Requirements

3.

Stroke Testing of Check Valves

4.

Stroke Testing of Motor Operated Valves

5.

Test Frequency of Check Valves Tested at Cold Shutdowns

6.

Licensee Request for Relief to Test Valves at Shutdown

7.

Valve Testing at Cold Shutdown

8.

Category A Valve Leak Rate Test Requirements Containment Isolation Valves (CIVs)

9.

Application. of Appendix J Testing to the IST

10.

Category A Valve Leak Rate Test Requirements Pressure Isolation Valves (PIVs)

B.

Drawing List C.

Auxiliary Feed System Relief Requests D.

Chemical and Volume Control System Relief Requests E.

Containment Spray System Relief Requests F.

Main Steam System Relief Requests G.. Nitrogen System Relief Requ~sts H.

Residual Heat Removal System Relief Requests I.

Safety Injection System Relief Requests J.

Spent Fuel Cooling System Relief Requests K.

Station Air System Relief Requests L.

Waste Disposal - Liquid System Relief Requests M.

Valves Not Tested during Power Operations ENVIRONMENTAL CONSIDERATIONS*-:

CONCLUSIONS Page 1

1 1

1 2

3 3

3 Cold 3

4 for 4

Program 4

for 5

6 6

8 9

10 12 13 14 19 19 20 21 25 26

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INTRODUCTION Technical Specification 4.0.5 for the Salem Nuclear Generating Station, Unit No. 1 states that inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda, as required by 10 CFR 50.55a(g).

10 CFR 50.55a(g)(6)(i) authorizes the Commission to grant relief from Code requiremen~s upon making the necessary findings.

By letter dated March 10, 1980, Public Service Electric and Gas Company (PSE&G) (the licensee) submitted its pump and valve inservice testing program for the period July 1, 1977 to June 30, 1987.

This program was revised by letter from the licensee dated April 29, 1981.

In its submittals, the licens-ee requested relief from certain requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through the Summer of 1975 Addenda (The Code).

The program and each individual relief request were reviewed by the staff and its contractor EG&G Idaho, Inc.

Part of this review was conducted at the plant site January 30-31, 1980 and again August 31 and September 1-3, 1982; the latter review is documented in NRC Inspection Report 50-272/82-23.

EVALUATION The IST program submitted by PSE&G for Salem Unit 1 was examined to verify that class 1, 2, and 3 safety related pumps and valves were included in the program and that those components are subjected to the periodic tests as required by the ASME Code,Section XI and the staff 1 s positions and guidelines identified below in Section A.

In addition to the FSAR, a list of system drawings (Piping Diagrams) used for this review is contained in Section B.

Each PSE&G request for relief from testing valves, the code requirement for testing, the PSE&G basis for requesting relief, and the staff evaluation of that request is summarized in Sections C through M and is grouped according to system.

Determinations made from each evaluation are included at the end of that section; those determinations requiring additional action by the licensee are repeated in the Conclusion Section.

A.

General Considerations

1.

Safety Related Components This review was limited to safety-related pumps and valves.

Safety-related components are defined as those components that are needed to mitigate the consequences of an accident and/or to shutdown the reactor and to maintain the reactor in a safe shutdown condition.

Components in this category would typically include certain ASME Code Class 1, 2 and 3 components and could include some non-code Class components.

The staff 1 s review found that all appropriate safety-related pumps and valves were included in the IST program, except those in the Fire Protection and Emergency Diesel Generator Auxiliary systems.

The staff recognizes the potential for certain code te~t r

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2 requirements to be impractical for some of these components and the existence of adequate alternate surveillance testing.

However the staff position is that safety-related pumps and valves in.these systems be included in the IST program.

The staff has discussed this matter with the licensee.

The licensee has agreed to review the safety~related pumps and valves in these s~stems, determine the feasibility of conducting meaningful opera-tional readiness tests in accordance with the Code, and amend the

!ST program accordingly.

This amended program, along with any additional requests for relief, is required to be submitted. to the NRC rro later than twelve months from the issuance of this SER.

The staff concludes that granting this temporary relief for 12 months provides adequate time for proper program development and does not increase the probability or consequences of accidents or decrease the existing operational safety margin.

The basis for this determination is that most inservice testing activities required by the Code are in addition to surve)llance requirements of original Technical Specifications and other regulations.

As such, the formal

!ST program currently being implemented has upgraded the operational surveillance program; further improvements in it will enhance safety.

Valve Exercising Requirements Subsection IWV-3410(a) of the Section XI Code (which discusses full stroke and partial stroke) requires the Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-1), (e), and (f).

IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3520(b).

IWV-3700 requires no regular testing for Code Category E valves.

Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are comp 1 eted and sha 11 verify that each valve is locked, or sealed.

The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in a~cordance with IWV-3410(c).

In the above exceptions, the code permits the valves to be tested at cold shut down where:

a.

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

b.

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

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3.

Stroke Testing of Check Valves The staff stated its position to the licensee that check valves whose safety function is to open are expected to be-full stroked.

If only limited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valves shall be partial stroked.

Since disk position.is not always observable, the NRC staff stated that verification of the plant's safety analysis design flow rate through the check valve would be an adequate demon-stration of the full stroke requirement.

Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve 1s disk position at the lower flow rate would be equivalent to or greater than the design flow rate through the valve.

The licensee agreed to conduct flow tests to satisfy the above position.

4.

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

The licensee has stated that none of the Category A or B power operated valves identified can be part-stroked becauie of the design logic of the operating circuits. These circuits are such that when an open or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction.

We find that the above relief request from part-stroking is warranted and is granted because the required function of the valves involves only full open or full. closed positions.

5.

Test Frequency of Check Valves Tested at Cold Shutdowns

6.

The Code states that, in the case of cold shutdowns, xalve t~sting need not be performed more often than once every three months for Category ~ and B valves and once every nine months for Category C valves.

It is NRC 1 s position that the Code is inconsistent and the Category C valves should be tested on the same schedule as Category A and B valves.

The licensee has agreed to modify his procedures on cold shutdowns to reaq, 11 In the case of frequent cold shutdowns, valve testing will not be performed more often than once every three (3) months for Category A, 8 and C valves.

11 Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to be tested at cold shutdowns, the Code conditions under which this is permitted are noted in paragraph A.2.

These valves are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code.

Since the licensee is meeting the requirements of the ASME Code, it.will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and we agree with the licensee's

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7.

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4 basis.

These valves are identified and appropriate justifications summarized in Section L of this Evaluation Report.

It should be noted that the NRC differentiates for valve testing purposes between the cold shutdown mode and the refueling mode.

That is, for testing purposes the refueling mode is not considered as a cold shutdown (See A.7 below).

Valve Testing at Cold Shutdown Inservice valve testing at cold shutdown is acceptable when the following conditions are met:

It is understood that the licensee is to commence testing as.soon as the cold shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown and continue until complete or plant is ready to return to power.

Completion of all valve testing is not a prerequisite to return to power.

Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing frequen~y.

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

Category A Valve Leak Rate Test Requirements for Containment Isolation Valves (CIV)

All CIVs are classified as.Ca.tegory A valves.

The licensee has requested relief from leak rate testing requirements of IWV-3420 for CIVs b"ased on the existing containment leakage rate test program required by 10 CFR 50 Appendix J and Technical Specifications.

I The staff has concluded that relief from paragraph IWV-3420 (a-e) for C!Vs presents no safety problems since the intent of IWV-3420 (a-e) is met by Appendix J requirements.

However, the licensee shall comply with Sections f and g of IWV-3420 for CIVs which receive a Type C leakage rate test.

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

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

However, dur~ng this IST review, it was noted that the scope of the Type C leakage rate test program was not in complete conformance with 10 CFR 50 Appendix J.

The licensee is conducting a special review and expects to revise the Type C

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5 leakage rate test program and Technical Specification to include more CIVs and to achieve conformance with Appendix J.

These changes to the containment leakage testing program, once approved, will be directly applicable to the !ST program and the. lice~see is required to amend it accordingly.

10.

Category A Valve Leak Rate Test Requirements for Pressure Isolation Valves (PIV)

Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure.

Redundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems protect the low pressure systems from. pressures which exceed their design limit.

In this role, the valves perform a pressure isolation function.

The staff considers the redundant isolation provided by these valves to be important and as s~ch classjfies them as Category A valves requiring seat leak rate tests in accordance with IWV-3420.

These valves are:*

11-14SJ139 11-14SJ144 11-14SJ56 11-14SJ156 11-14SJSS 11-14SJ43 13-14RH27 lRHl 1RH2 The !ST program does not classify these PIVs as Category A.

However, Technical Specification (TS) 3/4.5.6.3 requires periodic.

leakage testing of all these valves except 11-14 SJSS and lRHl and 1RH2.

Surveillance Procedure SP (0) 4.4.6.3 is used to satisfy the TS requirement and includes'all of these valves except lRHl and 1RH2.

The staff has reviewed the above surveillance procedure and TS and concluded that they give reasonable assurance of valve operability, thus meeting the intent of IWV-3420.

The staff has discussed this matter with the licensee.

He has agreed to include valves lRHl and 1RH2 in the surveillance procedure and change the classification of all 28 identified PIV(s) to Category A.

The-amended IST program and appropriate relief request is required to be submitted to the NRC no later than 3 months from the issuance of this SER.

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6 Drawing Li st The P&IDs listed below were used during the course of this review.

System Auxiliary Feedwater Steam Generator Feed and Condensate Chemical and Volume Control, Boric Acid Recovery Chemical and Volume Control Operation P&ID 205236 205202 205229 Rev.

8 13 10 1

Chilled Water Component Cooling Containment Spray 205228 205216 205231 205235 205247 12 17 12 8

14 Reactor Containment and Penetration Area Control Air Demineralized Water Restricted Areas Fire Protection Steam Generator Drains and Slowdown Main Reheat and Turbine Bypass Steam Reactor Coolant Residual Heat Removal Safety Injection Sampling Service Water Nuclear Area Spent Fuel Cooling Compressed Air Reactor Containment Ventilation Waste Disposal Liquid Chemical and Volume Control, Primary Water Recovery Diesel Generator Auxiliary Fuel Oil C.

Auxiliary Feed

1.

Category C Valves

a.

Relief Request 205246 205222 205225 205203 205201 205232 205234 205244 205242 205233 205217 205238 205239 205230 205241 205249 8

16 11 17 12 8

12 9

14 8

12 10 10 10 8

8 The licensee requested specific relief from exe,rc1s1ng Category C valves 11-13AF53, demineralized water check valves, in accordance with the requirements of Section XI and proposed a manually full stroke exercising during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

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7 Licensee's Basis for Requesting Relief The line in which this valve is installed is maintained empty and vented to the atmosphere.

We do not fill this line except in need _as it is routed through a vital relay room and a leak would cause extensive damage and trip the reactor.

These valves will be manually full stroke exercised per Section XI during refueling.

Evaluation The staff agrees with the licensee's basis and therefore grants

• relief for the Category C valves ll-13AF53 from the exercising requiremerits of Section XI.

The licensee has demonstrated that the only method available to exercise these valves is by disassembly and manual full stroke exercising.

This portion of the system is normally kept drained and vented to prevent the possibility of leakage into the vital relay room which could result in equipment damage and a reactor trip.

We conclude that disassembly and manual full stroke exercising during refueling outages should demonstrate proper valve operability.

Relief Request The licensee requested specific relief from exercising Category C valve 13AF4, #13 auxiliary feed pump suction check, in accordance with the requirements of Section XI and proposed partial stroking during power operation and manually full stroking during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee 1s Basis for Requesting Relief This valve cannot be full stroke exercised during Power Opera-tion without the~mally shocking the feed n~zzles. The normal feed path to the steam generators (SG) is the only available full flow path.

The valve cannot be tested in Cold Shutdown for Refueling because the steam must be available to drive the turbine to operate the #13 Auxiliary Feed Pump to exercise 13AF4.

This valve is partially stroked through~ the recircu-lation path during power operation.

This valve will be manually full stroke exercised per Section XI during refueling.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valve 13AF4 from the exercising require-ments of Section XI.

The licensee has demonstrated that the r

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only available full flow path is into the steam generators which would result in thermal shocking of the feed nozzles.

Only partial stroke exercising is possible during power opera-tion due to the limited size of the pump recirculation line.

Exercising during cold shutdown or refuenng with auxiliary feed system flow is not possible because steam i~ not available to operate the turbine driven pump.

We conclude that disassem-bly and manual full stroke exerci~ing during refueling outages should demonstrate proper valve operability.

Relief Request The licensee requested specific relief from exercising Category C valve 13AF8, #13 auxiliary feed pump discharge check in accordance with the requirements of Section XI and proposed manually full stroke exercising during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee 1 s Basis for Requesting Relief This valve cannot be tested during power operation without thermal shocking the feed nozzles on the SGs.

It cannot be flow tested during cold shutdown or refueling because there is no steam available to drive the #13 Auxiliary Feed Pump Tur-bine. This valve will be manually full stroke exercised per Section XI during. refueling.

Evaluation The staff agrees with the licensee's *basis and therefore grants relief for Category C valve 13AF8 from the exerc1s1ng require-ments of Section XI.

The licensee has demoristrated that the only available full flow path is into the steam generators which would result in thermal shocking of the feed nozzles.

Exercising during cold shutdown or refueling with auxiliary feed system flow is not possible because steam is not available to operate the turbine driven pump.

We conclude that disassem-bly and manual full stroke exercising during refueling outages should demonstrate proper valve operability.

Chemical and Volume Control

1.

Category C Va 1 ves

a.

Relief Request The licensee has requested specific relief from exercising Category C valve 1CV196, chemical addition tank outlet check, in accordance with the requirements of Section XI.

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9 Code Requirement Refer to valve testing paragraph A.2 and A.3.

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

• Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valve 1CV196 from the exercising require-ments of Section XI.

This valve is in its safety-related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We

• conclude that *quarterly stroke exercising is meaningless for

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E.

Containment Spray (CS)

1.

Category C Valves

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Relief Request The licensee requested specific relief from exerc1s1ng Category C valves11-12CS4 and ll-12CS48, containment spray discharge header check valves, in accordance with the requirements of.

Sectitin XI and proposed exercising these valves during refuel-ing outages.

Code Requirement

• Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief These valves cannot be exercised during power operation or cold shutdown without spraying down the containment, causing equip-ment and lagging damage requiring extensive cleanup and repair.

The full flow test connection is connected to the refueling cavity and can only be used during refueling.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valves11-12CS4 and 11-12CS48 from the exercising requirements of Section XI.

The licensee has demon-strated that exercising these check valves during power opera-tion or cold shutdown is not possible without spraying borated water into the reactor containment building resulting in

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Main Stearn 10 lagging and equipment damage.

The 15censee has proposed to full stroke valves11-12CS4 and ll-12CS48 during refueling outages when a test spool piece can be installed and the borated water discharged to the reactor refueling cavity.

We conclude the licensee's proposed alternate testing_ frequency should be sufficient to ensure proper valve operation.

Relief Request The licensee has requested specific relief from Category C valve 11-12CS21, spray additive tank accordance with the requirements of Section XI.

partial stroke exercising quarterly and manually exercising these valves during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Reguest1ng Relief exercising checks, in They proposed full stroke The safety-related position is open to allow the caustic solution in the spray additive tank to be educed into the CS system and sprayed into the containment.

Only partial stroking is possible due to the limited size of the recirculation line.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valves11-12CS21 from the full stroke exercising requirements of Section XI.

We conclude that the proposed alternate testing frequency should be _sufficient to ensure proper valve operation.

However, subsequent to the application of this relief request the -licensee has recon-sidered the need for it and stated that the minimum-design flow rate through the valve is demonstrated with the monthly pump operability test. After assurance of this test condition, the licensee need not manually stroke the~e valves and this relief request can be officially deleted with a future program submit-tal.

1.

Category B Va 1 ves

a.

Relief Request The licensee has requested specific relief from exerc1s1ng Category B valve 1MS52, auxiliary feed pump turbine steam supply valve, in accordance with the requirements of Section XI.

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

Licensee's Basis for Requesting Relief This is a passive valve.

It is always in the position required*

to allow the pump to operate during an incident.

Eva 1 uation

_The staff agrees with the licensee's basis and therefore grants relief for Category 8 valve 1MSS2 from the exercising require-ments of Section XI.

This valve is in its safety-related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

b.

Relief Request

c.

The licensee has requested specific relief from stroke timing Category B valve 1MS53, auxiliary feed pump turbine governor valve, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A.2.

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

Evaluation The staff agrees,with the licensee's basis and therefore grants relief for Category B valve 1MS53 from the stroke timing requirements of Section XI.

The licensee has demonstrated that stroke timirg a modulating valve will not provide any meaning-ful data for valve degradation.

We conclude that verifying proper system operation is the most practical m~thod of ensur-in~ proper modulating valve operability.

Relief Request The licensee has requested specific relief from exerc1s1ng and stroke timing Category B valves11-14MS168, MSIV three-way pilot valves, in accordance with the requirements of Section XI.

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

Licensee's Basis for Requesting Relief This is a passive valve always maintained in its safety-related position (i.e., open to the MS169s and MS171s).

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category B valves11-14MS168 from the requirements of Section XI.

These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

Nitrogen

1.

Category A/C Valves a_

Relief Request The licensee has requested specific relief from exerc1s1ng Category A/C valve 1NT26, pressurizer relief tank nitrogen supply check, in accordance with the requirements of Section XI.

Code Requirement Refer to va1ve testing paragraph A.2*and A.3.

Licensee's Basis for Requesting Relief This valve has no position indication and is located inside the containment.

This valve can only be verified shut during refueling.

Evaluation The staff agrees with the ficensee's basis and therefore grants relief for Category A/C valve 1NT26 from the exercising re-quirements of Section XI.

The licensee has demonstrated that the only method available to verify valve closure (its safety related position) is during leak testing.

This valve is not equipped with valve position indication and some of ~he required test connections are located inside the containment.

We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate

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testing at refueling outages should demonstrate proper valve operability.

H.

Residual.Heat Removal System

1.

Category C Valves

a.

Relief Request

b.

The licensee has requested specific relief from exerc1s1ng Category C valves 13-14RH27, hot leg injection checks, in accordance with the.requirements of Section XI.

Code Requirement Refer to valve testing paragraph A.2.

Licensee 1 s Basis for Requesting Relief This is a passive valve.

During an incident, LPSI is through a:nother path.

Evaluation The staff agrees with the licensee 1 s basis and therefore grants relief for Category C, valves 13-14RH27 from the exercising requirements of Section XI.

These valves are in their safety related positions and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke is meaning-less for passive valves.

Relief Request The licensee requested specific relief from exerc1s1ng Category C valves 11 and 12 RHB, RHR (LPSI) pump discharge checks, in accordance with the requirements of Section XI and proposed partial stroke e~ercising these valves during power operation and cold shutdown and full stroke exercising these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief These valves cannot be full stroke exercised during power operation because the RHR (LHSI) pumps cannot overcome RCS operating pressure and the pump test recirculation lines limit exercising to partial stroking.

During cold shutdown RCS

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14 pressure is greater than design accident pressure; thus, only partial stroke exercising is possible.

These valves will be full stroke exercised during refueling outage~.

Evaluation The ~taff agrees with the licensee's basis and, therefore, grants relief for Category C valves 11 and 12 RH8 from the requirements of Section XI.

The licensee has demonstrated that, due to plant design and RCS pressures, these valves can be only partial stroke exercised.during power operation and cold shutdowns.

We conclude that partial stroke exercising

~hese valves during power operation and cold shutdowns, and full stroke exercising these valves during refueling -0utages when the RCS is at atmospheric pressure should demonstrate proper valve operability.

Safety Injection

1.

Category C Valves

a.

Relief Request The licensee requested specific relief from exerc1s1ng Category C valves ll-14SJ17, and 1SJ150, safety injection to the reactor coolant system, in accordance with the requirements of Section XI and proposed exercising these valves during refueling:

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief For power operation, testing would require pumping 2,000 ppm borated water into the RCS.

This would render the reactor subcritical and would also violate Technical Specification LCO 3.5.4.1.

For co\\d shutdown, testing would ultimately require significant RCS dilution and boric acid recovery operation. It would also present a possible low-temperature RCS overpres-surization and would violate Technical Specification 3.5.4.1 and certain operating procedures.

These valves will be ex-ercised during refueling per Section XI.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valves ll-14SJ17 and 1SJ150, from the exercising requjrements of Section XI.

The licensee has demon-strated that e:,erci sing these valves during power operation would require injecting 2000 ppm bora~ed water into the reactor

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These valves cannot be exercised during cold shutdown without the possibil-ity of creating a low temperature-overpressurization condition in the reactor coolant system.

In addition, injecting 2000 ppm boron into the reactor system could delay reactor startup due to the extensive cleanup required to. return reactor system chemistry to operating specifications.

We conclude that exercising these valves during refueling outages when an expansion volume is available and chemistry requirements do not restrict reactor operation should demonstrate proper valve operability.

Relief Request The licensee requested specific relief from exerc1s1ng Category C valve 1SJ31, safety injection suction check, in accordance with the requirements of Se~tion XI and proposed partial stroke exercising during power operation and full stroke exercising during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief Only a partial stroke is possible due to design o( the recircu-lation line.

Flow to loop cannot be attained at power opera-tion because the RCS pressure is greater than safety injection pump shutoff head.

During cold shutdown, the possibility of a low temperature overpressurization of the RCS exists.

This valve wi'll be full stroke exercised during refueling.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valve 1SJ31 from the exercising require-ments of Section XI.

The licensee has d~monstrated that the only available full flow path is into the reactor coolant system and is not attainable during power operation because the safety injection pumps cannot overcome RCS pressure.

Only partial stroke exercising is possible during power operation due to the limited size of the pump recirculatiqn line.

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

We conclude that full stroke exercising this valve during refueling outages when an expansion volume is available should demonstrate proper valve operability.

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16

c.

Relief Request The licensee requested specific relief from exerc1s1ng Category C valves ll-12SJ34, safety injection pump discharge checks, ll-14SJ139, ll-14SJ156, safety injection hot leg injection checks, and ll-14SJ144, safety injection cold leg injection checks, in accordance with the requirements of Section XI and proposed full stroke exercising these valves during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief During power operation, testing is not possible since RCS pressure is greater than safety injection pump shutoff head.

During cold shutdown, the possibility of a low temperature-overpressurization of the RC$ exists.

These valves will be full stroke exercised during refueling outages.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valves 11-12SJ34; 11-14SJ139, ll-14SJ156, and ll-14SJ144 from the exercising requirement of Section XI.

The licensee has demonstrated that the only available full flow

.path is into the reactor coolant system and is not attainable during power operation* because the* safety injection pumps cannot overcome RCS pressure.

These valves cannot be full stroke exercised during cold shutdown without the possibility of creati~g a low temperature-overpressurization conditiDn in the RCS.

We conclude that full stroke exercising these valves during refueling outages when an expansion volume is available should demonstrate proper valve operability.

d.

Relief Request I

The licensee requested specific relief from exerc1s1ng Category C valves 11-14SJ55, safety accumulator discharge checks, in a~cordance with the requirements of Section XI and proposed partial stroke exercising during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basi~ for Requesting Relief During power operation, the RCS pressure is greater than accumulator pressure.

During cold shutdown, testing of this

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17 valve by accumulator discharge could result in low temperature-overpressurization of the RCS.

These valves will be part stroke tested during refueling per Section XI.

In addition the licensee will investigate a means to full stroke exercise these valves.

Evaluation The staff agrees with the licensee's basis and therefore grants temporary relief for Category C valves 11-14SJSS from the exercising requirements of Section XI.

The licensee has demonstrated that the only available full flow path is into the reactor coolant system arid is not attainable during power operation because the safety accumulator pressure cannot overcome RCS pressure.

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

During normal plant coo ldown for refuel fog outag-es, part-stroke exercise of these valves is demonstrated.

This is accomplished by lowering the RCS pressure to match the accumulator pressure of approximately 600 psig and observing a level decrease prior to closing the motor operated isolation valves 11-14 SJ 54.

The flowrate attained using this method is usually very low.

The staff reviewed the surveillance procedure used to perform this activity and determined that several means were available to increase the flowrate which would demonstrate the valves ability to open more fully and provide better assurance of proper valve operabil1ty.

The staff has discussed this matter with the licensee.

He agreed that improvements could be made in the part-stroke testing of these valves currently being done and stated that several considerations were being reviewed along with the investigation for a means to satisfy the NRC full-stroke exercise criterion (demonstrate safety analysis design flowrate through the chec~ valve).

The staff has concluded that. the existing part-stroke testing of these valves provides some degree of assurance that they can adequately perform their safety function and is acceptable until the licensee develops an improved test method.

The licensee is requi*red to complete his investigat~on and submit th~ results along with a revised relief request to the NRC no later than 6 months from the issuance of this SER.

e.

Relief Request The licensee requested specific relief from exerc1s1ng Category C valve 1SJ70, RWST to LPSI pump suction check, in accordance

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18 with the requirements of Section XI and proposed partial stroke exercising during power operation *and full stroke during refueling.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief Only part stroke exercising is possible during power operation due to the limited si~e of the recirculation line and because LPSI pump discharge cannot overcome RCS pressure.

This valve will be full stroke exercised during refueling when the LPSI pump discharge can be lined up to fill the reactor cavity.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category C valve -1SJ70 from the exercising require-ments of Section XI.

The licensee has demonstrated that the only full flow path available is into the reactor coolant system and is not attainable during power operation because LPSI (RHR) pump discharge pressure cannot overcome reactor

.coolant system pressure. This valve cannot be full stroke exercised during power operation due to the limited size of the recirculation line. This valve cannot be full stroke exercised during cold shutdown without the possibility of creating a low temperature-overpressurization in the RCS.

We conclude that full stroke exercising during refueling when the vessel head is removed and the refueling cavity is being filled should demon-strate proper valve operability.

f.

Relief Request The licensee requested specific relief from exercising Category C valves ll-14SJ56, safety accumulator RHR/LPSI header checks, and 11-14SJ43, RHR/LPSI checks, in accordance with the require-ments of Section'XI and proposed full stroke exercising these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2 and A.3.

Licensee's Basis for Requesting Relief These valves cannot be exercised during power operation or co]d shutdown because the RHR/LPSI pumps cannot overcome RCS operat-ing pressure or cold shutdown pressure.

These valves are full stroke exercised during refueling outages.

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19 Evaluation The staff agrees with the licensee's basis and, therefore, grants relief for Category C valves ll-14SJ56 -and 11-14SJ43 from the requirements of Secti~n XI.

The licensee has demon-strated that these valves cannot be exercised during power operation or cold shutdown because the RHR/LPSI pumps cannot overcome RCS operating pressure or cold shutdown pressure.

We conclude that full stroke exercising these valves during refueling outages when the RCS is at atmospheric pressure should demonstrate proper valve operability.

Spent Fuel Cooling

1.

Category A/E Valves

a.

Relief Request The licensee has requested specific relief from exercising Category A/E valves 1SF22 and 1SF36, spent fuel cooling iso-lation valves, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Passive valves not required to change position to fulfill their function.

Valves are kept locked shut per Technical Specifica-tion 3.6.3.1, Table 3.6-1.

_Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category A/E valves 1SF22 and 1SF36 from the ex-ercising require~ents of Section XI.

These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

Station Air (Compressed Air)

1.

Category A/E Valves

a.

Relief Request The licensee has requested specific relief from exerc1s1ng Category A/E valve 1SA118, station air containment isolation valve, in accordance with the requirements of Section XI.

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

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

Valve is locked shut per Technical Specification 3.6.3.1, Table 3.6-1.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category A/E valve 1SA118 from the exercising requirements of Section XI.

This valve is in its safety related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke and stroke time measurements ar*e meani~gless for passive valves.

L.

Waste Disposal - Liquid

1.

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Category A/E Valves

a.

Relief Request The licensee has requested specific relief from exerc1s1ng Category A/E valves 1WL190 and 1WL191, reactor cavity to spent fuel cooling pump containment isolation, in accordance with the requirements of Section XI.

Code Requirement Refer to valv~ testing paragraph A.2.

Licensee's Basis for Requesting Relief Passive valves n9t requi.red to change position to fulfill their function.

Valves are kept locked shut per Technical Specifica-tion 3.6.3.2.d, Table 3.6-1.

Evaluation The staff agrees with the licensee's basis and therefore grants relief for Category A/E valves 1WL190 and 1WL191 from the exercising requirements of Section XI.

These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

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21 M.

Valves Not Tested during Power Operations The following are Category A, 8, and C valves that meet the requirements of the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during. cold shutdowns and ref~l1ng outages.

The staff has reviewed.all valves in this list and agrees with ~he licensee that testing these valves during power operation is not possible due to the valve type and location, system design, or because this action would.place the plant in an unsafe condition.

We conclude these valves should not be exercised during power operation.

These valves ar~ listed below and grouped according to the system in which they are located.

1.

Auxiliary Feedwater

a.

Category C/E valves 11 through 14AF23, auxiliary feedwater header checks, cannot be exercised during power operation.

Exercising these valves with. relatively cold auxiliary feed-water would thermally shock the Steam Generator feed nozzles resulting in possible nozzle damage.

These valves are full stroke exercised during cold shutdown.

b.

Category C valves 11-12AF4 and 11-12AF8, auxiliary feed pump suction and discharge checks, cannot be full stroke exercised during power operation.

The only available full flow path is into the steam generators.

Exercising these valves with relatively cold auxiliary feedwater would thermally shock the Steam Generator feed nozzles resulting in possible feed nozzle damage.

11-12AF4 are partial stroke exercised during power operation through the recirculation test line:

All valves are full stroke exercised during cold shutdown.

2.

Steam Generator Feed and Condensate

a.

Category C/E valves 11 through 14BF22, feedwater header checks cannot be exercised during power operation.

Exercising these valves would reqyire 3 loop reactor operation which is not permitted.

A plant trip would also result.

These valves will be full stroke exercised during cold shutdowns.

3.

Chemical and Volume Control

a.

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

Ex-ercising this valve would isolate normal letdown flow thr*ough the regenerative heat exchanger causing the injection of cold water into the RCS resulting in thermal cycling of injection nozzles and possible cracking damage.

This. valve is full stroke exercised during cold shutdown.

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b.

c d.

e 22 Category A valves 1CV68 and 69, regenerative heat exchanger containment isolations, cannot be exercised during power operation.

If these valves failed shut during testing, loss of pressurizer level control would result requiri~g a reactor trip. These valves are full stroke exercised during cold shutdown.

Category A valves 1CV116 and 284, Reactor Coolant Pump (RCP) seal water containment isolations, cannot be exercised during power operation.

Shutting these valves would cause a RCP trip which would then cause a reactor trip.

These valves will be exercised during cold shutdown.

Category A/C valve 1CV74, regenerative heat exchanger contain-ment isolation, cannot be exercised during power operation.

Shutting this valve during power operation would cause a loss of pressurizer level control. A reactor trip would result.

This valve is full stroke exercised during cold shutdown.

Category A/C va 1 ve 1CV296, R'tp sea 1 return 1 i ne overpressure protection containment isolation, cannot be isolated during power operation without tripping a RCP which will cause a reactor trip. This valve cannot be exercised without shutting 1CV284.

This valve is full stroke exercised during cold shutdown.

Category B valves 1CV40 and 41, Volume Control Tank (VCT) outlet isolations, cannot be exercised during power operation.

Closing these valves during power operation requires lining up the alternate source of water from the refueling water storage tank to the suction of the charging pumps.

This is 2,000 ppm borated water which would render the reactor.subcritical.

These valves are exercised during cold shutdown.

Category C valve 1CV42, VCT outlet check, cannot be exer-cised during power operation.

Exercising (closing) would result in a loss of normal makeup to the RCS, pressurizer level control, and RCP,seal flow.

Use of the only alternate suction for the charging pumps, the RWST, which is water borated to approximately 2000 ppm, would result in a reactor shutdown.

This valve is full stroke exercised during cold shutdown.

h.

Category C valves 11 through 14CV99, RCP seal water check valves, and category A/E valves 11-14CV98, RCP seal water throttle valves, cannot be exercised during power operation without securing seal water to an RCP resulting in a loss of an RCP and requiring a reactor trip.

These valves are full stroke exercised during cold shutdown.

i.

Category C valve 1Cl76, rapid boration check, cannot be ex-ercised during power operation.

Testing during power operation

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23 would require injecting highly borated water into the RCS resulting in a reactor shutdown.

This valve is full stroke exercised during cold shutdown.

4.

Component Cooling (CC)

Category A valves 1CC117, 118, 131, 136, 187, and 190, CC to RCP supply and return containment isolations, cannot be ex-ercised during power operation because if the valves failed shut a loss of RCP cooling would occur requiring the RCP be secured and thus requiring a reactor trip.

These valves are exercised during cold shutdown when RCPs are ~ecured.

Category A/C valves 1CC186 and 208, overpressure protection for containment isolation piping, cannot be exercised during power operation without isolating CC to RCPs requiring RCPs to be secured which would result in a reactor trip.

These valves are full stroke exercised during cold shutdown when RCPs are secured.

5.

Containment Spray

6.

7.

a.

Category 8 valves 11 and 12CS36, LPSI to containment spray, cannot be exercised during power operation.

These valves are interlocked shut with 11 and 12SJ44, containment sump suction isolations.

These valves are full stroke exercised during cold shutdown.

Main Steam

a.

Category 8 valves, 11 through 14MS167, main steam isolation valves, *and 11 through 14MS169 and 11 through 14MS171, backup valves for shutting main steam isolations, tannot be exercised during power operation.

Shutting one main steam valve will cause a steam flow/feed flow mismatch in the corresponding SG because the steam flow would go to zero.

This would cause a reactor trip. Testing the shutting backup valves would result in the associated main steam isolation valve closure.

These valves are full stroke exercised during the startup following cold shutdown.

Residual Heat Removal

a.

Ca~egory 8 valves lRHl and 2, RHR injection hot leg isolations, cannot be exercised during power operation.

These valves are pressure interlocked shut and cannot be opened when RCS pres-sure is greater than 590 psig.

These valve~ are full stroke exercised during startup following a cold shutdown.

b.

Category B valve 1RH26, RHR to hot leg isolation cannot be exercised during power operation because valve is shut with

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I 24 power removed (per Technical Specification 4.5.2) to prevent overpressurization of the RHR system (low pressure SI system).

Also if the valve failed open, flow would be diverted from the injection flow path. This valve will be full ~troke exercised during cold shutdown.

Safety Injection

a.

b.

c.

d.

e.

f.

g.

Category B valves lSJl and 2, RWST to chargfog pump suction isolations, cannot be exercised during power operation without injecting 2000 ppm boron into the RCS resulting in a reactor shutdown.

These valves will be exercised during cold shutdown.

Category B valves 1SJ4 and 5, BIT inlet isolati*ons, cannot be exercised during power operation.

Opening these valves during power operation would dilute the BIT below 20,100 ppm boron, the concentration required by Technical Specification 3.5.4.1 to ensure safe plant shutdown of the reactor during an inci-dent.

These valves will ~e ~xercised during cold shutdown.

Category B valve 1SJ30, RWST to SI pump suction isolation, cannot be exercised during power operation.

Stroking this valve requires isolating the suctions of both safety injection pumps from the RWST.

Failure of this valve would disable both ECCS trains.

This valve is full stroke exercised during cold shutdown.

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

These valves will be exercised during cold shut-down.

Category 8 valves "11 and 12SJ45, LPSI pump discharge to the SI and HPSI pumps, cannot be exercised during power operation because the 11 and 12SJ44 must be opened to exercise these va~ves due to interlocks between them.

See relief ~equest for 11 and 12SJ44.

These valves will be exercised during cold shutdown.

Category 8 valve 1SJ69, LPSI pumps suction isolation, cannot be exercised during power operation.

This is a p~ssive valve always maintained in the open position (Technical Specification 4.S.2 requires this valve to be open with the power removed during power operation).

Failure of this valve in the closed position during testing would render the ~HR. (LPSI) system inoperable.

This valve will be exercised during the startup following cold shutdown.

Category B valve 1SJ135, SI pump discharge to RCS cold legs, cannot be exercised during power operation because if it fails

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25 shut during testing cold leg injection would be isolated. This valve will be full stroke exercised during cold shutdown.

Category B valves 11 through 14SJ54, accumulator outlet iso-lations; cannot be exercised when the accumulators are at normal pressure and the RCS is less than 1000 psig to prevent a possible low temperature-overpressurization of the RCS.

These valves will be stroke timed and exercised while:

(1) The accumulators are at normal pressure and RCS is greater than 1000 psig, or (2) The accumulators are depressurized and the RCS is less than 1000 psig.

Category C valve 1SJ3, which prevents'backflow from the VCT to the RWST, cannot be exercised during power operation.

In order to test this valve lSJl or 1SJ2 must be *opened.

lSJl and 2 cannot be exercised during power operation without inje~ting 2000 ppm boron into the RCS resulting in a reactor shutdown.

This valve will be full stroke exercised during cold shutdown.

9.

Service Water

a.

Category C valves 11 and 12SW51, which prevent backflow from the containment fan coil units to the nuclear service water

• header, cannot be exercised during power operation.

Testing these valves requires isolating service water to 2 fan coil units. This places the plant in. a limiting condition for operation (Technical Specification 3.6.2.3).

These valves will be full stroke exercised during *cold shutdown.

b.

Category C valves 11 and 12SW79, service water overload dis-charge checks, cannot be exercised during power operation because both nuclear headers.are required (Technical Specifica-tion 3.7.4.1). If these valves failed shut while exercising, a plant shutdown would be required.

These valves are full stroke exercised during.cold shutdown.

10.

Containment Ventilation

a.

Category A valves lVCl through 4, containment ventilation isolations, need not be exercised during power Dperation.

These valves are passive during power operation.

They cannot be opened per commitment to NRC in LER 50-272/79-55/0lT.

These valves will be exercised during cold shutdown.

ENVIRONMENTAL CONSIDERATIONS We have determined that granting relief from specific ASME Section XI Code requirements does not authorize a change in effluent types or total amounts

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26 nor an increase in power level and will not result in any sig~ificant environ-mental impact.

HaviAg made this determination, we have further concluded that this is an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 51.S(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the granting of this relief.

CONCLUSIONS Based on the review summarized herein, the staff concludes that the relief granted and alternate testing imposed through this document, for Code require-ments that are considered impractical, give reasonable assurance that the pump and valve operational readiness. intended by the Code will be satisfied.

1 Additionally, we have concluded that this relief does not involve a signifi-cant increase in the probability or con.sequences of accidents previously considered and does not involve a significant decrease in a safety margin; and that there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.

As described in the evaluations.contained herein, the following items require additional actions by the licensee.

They involve both administrative and technical amendments to the IST program and related requests for relief.

Each has been discussed with the licensee as documented in NRC Inspection Report 50-272/82-23.

1.

The staff identified twenty eight reacto.r coolant system pressure iso-lation valves which should be classified as Category A valves and should be leak rate tested as required by IWV-3420 of the Code.

Currently, the licensee performs periodic leakage testini of all these valves except lRHl and 1RH2.

The staff has reviewed these test methods, acceptance criteria, and test frequency and has concluded that they give reasonable assurance of valve operability and meet the intent of IWV-3420.

The licensee has committed to change the classification of all 28 valves to Category A and to include valves lRHl and 1RH2 in the existing leakage testing program.

The amended IST program and appropriate code relief requests describing the existing alternate test are required to be submitted to the NRC no later than 3 months from the date of this letter.

I

2.

The staff's review found that safety-related pumps and valves in the Fire Protection and Emergency Diesel Generator Auxiliary systems were not included in the IST program.

The licensee has committed. to:

(1) identify applicable p~mps and valves in these systems; (2) determine the feasibility of conducting meaningful operational readiness tests in accordance with the Code; and (3) amend the IST program accordingly.

This amended program, along with any addi-tional requests for relief is required to be submitted t6d~he NRC no later than 12 months from the date of this letter. Temporary relief is granted for applicable components in these systems until such time as the licensee amends the IST program and initiates testing in accordance with the code or the staff has reviewed and evaluated applicable requests for relief.

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3.

The staff's review found that the method of part-stroke testing the four Safety Injection Accumulator discharge check valves 11-14 SJ 55 could be improved to better demonstrate the valve's ability to o~en fully and perform its safety function.

These tests are conducted during refueling outages as an alternate for the code required full-stroke exercise testing.

The licensee has committed to further investigate *possible means to satisfy the full-stroke test requirement a*nd improved methods for the alternate* part-stroke testing. Results of this investigation and appro-priate revisions to the existing code relief request are required to be submitted to the NRC no later than 6 months from the date of this letter..

Based on the alternate testing currently being conducted, temporary relief is granted from quarterly full stroke exercising check valves 11-14 SJ 55 until such time as the licensee initiates testi~g in accor-dance with the code or the staff has reviewed and evaluated the revised request for relief expected no later than 6 months from the date of this 1 etter.

We have determined that where stated the Code requirements are impractical,

. the granting of this relief is authorized oy law and will not endanger life or property or the common defense and security, and is otherwise in the public interest considering the burden that could result if they were imposed on your facility.

Conclusion We have concluded, based on the considerations discussed above, that:

(1) because the action does not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possi-bility of an accident of a type different from ~ny evaluated previously, and does not involve a significant reduction in a margin of safety, the action does not involve a signif_icant hazards consideration, (2).there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance 0ith the Commission's regulations and the issuance of this action will not be inimical to the conm,on defense and security or to the health and safety of the public.

Date:

Principal Contrib~tor:

W. Rekito

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