ML20009F126

Ser,Inservice Testing Program,North Anna Nuclear Power Station Unit 2.

ML20009F126
Person / Time
Site:	North Anna
Issue date:	06/30/1981
From:	Cook T, Hanek J EG&G IDAHO, INC., EG&G, INC.
To:	Capucci A NRC
References
CON-FIN-A-6265 EGG-EA-5463, NUDOCS 8107290233
Download: ML20009F126 (45)

Text

EGG-EA-5463 June 1981 SA ETY EVALUATION REPORT, INSERVICE TESTING PROGRAM, 8

' NORTH ANNA NUCLEAR POWER STATION UNIT 2, 99 4-DOCKET NO. 50-339

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l . This is an informal report inte.ided for use as a preliminary or working document Prepared for the U.S. Nuclear Regulatory Connission Under DOE Contract No. DE-AC07-761001570 FIN No. A6265 0 g EGnG ,s.u.

8107290203 810630 PDR RES 8107290233 PDR

$4 EGzG ,.. . ,-

FORM EGAG.396 (Rev.1179)

. INTERIM REPORT Accession No.

d Report No. EGG-EA-5463 Contract Program or Project

Title:

Review of Pump and_ Valve Inservice Testing Programs for Operating Plants St.bject of this Doct: ment:

Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the FP 5 Anna Nuclear Power Station Unit 2 (Docket No. 50-339) for the Period (TBS) eough (TBS)

Type. :urnent:

Safety EvoluoLion Report Author (s):

T. L. Cook I J. F. Hanek anf }gghD C3l Date of Document: C Researc

. June 1981 ksg stance Report Responsible NRC Individeci and NRC Office or Division:

A. J. Cappucci, NRC-DE This document was prepared primarily for preliminary or internal use. it has not received full review and approval. Since there may be substantive changes, this document sh 3uld not be coraidered final.

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

Under DOE Contract No. DE / C07 761D01570 NRC FIN No. A6265 ,

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lNTERIM REPORT l I

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CONTENTS 1 1

i I. INTRODUCTION ..................................................

2

11. PUMP TESTING PROGRAM ..........................................

2

• 1. Component Cooling Pumps .................................

Relief Request .................................. 2 1.1 3

2. Charging Pumps ..........................................

9 5 2.1 Relief Request ..................................

3

3. Boric Acid Transfer .....................................

3.1 Relief Request .................................. 3 4

4. Inside Recirculation Spray Pumps ........................

4 4.1 Relief Request ..................................

Outside Recirculation Spray Pumps ....................... 4 5.

4 5.1 Relief Request ..................................

6. Low Head Safety Injection ............................... 5 4

6.1 Relief Request .................................. 5

. 7. Service Water ........................................... 5 7.1 Relief Request .................................. 5 6 i

8. Auxiliary Service Water .................................

8.1 Relief Request .................................. 6

9. Radiation Monitoring Sample Pumps ....................... 7

9.1 Relief Request. .................................. 7

10. Casing Cooling Pumps .................................... 8 i 10.1 Relief Request .................................. 8 i

l III. VALVE TESTING PROGRAM EVALUATION .............................. 9

1. General Considerations .................................. 9

! 1.1 Testing of Valves Which Perfonn a

! Pressure Isolation Function ..................... 9

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1.2 ASME Code, Section-XI, Requirements ............. 10 1.3 Stroke Testing of Check Valves .................. 10 1.4 Stroke Testing of Motor-Operated Valves ......... 10 1.5 Test Frequency.of Check Valves Tested '

at Cold Shutdowns ............................... Il l.6 Licensee Request for. Relief to Test Valves at Cold Shutdowns ........................ 11 '

1.7 Changes to the Technical Specifications ......... 11 l.8 Safety-Related Valves ........................... 12 1.9 Valve Testing at Cold Shutdowns . ............... 12 1,10 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs) ......... 12 1.11 Application o, Appendix J Testing to the IST Program ................................. 13 1.12 Pressurizer Power Operated Relief Valves ........ 13 1.13 PORV Block Valves ............................... 13

2. Compelent Cooling ....................................... 14 2.! C a t e g o ry A V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.2 Category A/C Valves ............................. 14 i

' 15

3. Chemical and Volume Control .............................

3.1 Category A Valves ............................... 15 i 3.2 Category A/C Valves ............................. 17 3.3 Category B Valves ........................ ...... 17 1

4. Containment Vacuum ...................................... 19 4.1 Category a 'lalve ................................ 19 4.2 Category A/C Valve .............................. 20

5. Containment Sump Drains ................................. 20 4 5.1 Category A/C Valve .............................. 20 5.2- Category A/E Valves ............................. 21

6. Feedwater ............................................... 21 6.1 Category B Valves ............................... 21 6.2 Category C Valves ............................... 22

7. Instrument Air .......................................... 23 7.1 Category A/C Valves ............................. 23

8. Main Steam .............................................. 23 8.1 Category B Valve ................................ 23 .

8.2 Category C Valves ............................... 24 ii

1 1

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9. Compresr" Air .......................................... 24 l l

+ 9.1 Category A/C Valve .............................. 24

10. Quench Spray ............................................ 24 10.1 Category A/C Valves ............................. 24

11. Recirculation Spray ..................................... 25 11.1 Category A/C Valves ............................. 25 11.2 Category C Valves ............................... 26

12. Reactor Coolant ......................................... 26 12.1 Category A/C Valve .............................. 26 12.2 Category A/E Valves ............................. 27 i

j 13. Safety Injection ........................................ 27 13.1 Category A Valves ............................... 27 13.2 Category A/C Valves ............................. 28 13.3 Category A/E Valves ............................. 30 13.4 Category C Valves ............................... 32

14. Service Water ........................................... 34 14.1 Category A/C Valves ............................. 34 14.2 Category B Valves ............................... 34 4

. 14.3 Category C Valves ............................... 35

15. Steam Generator Wet Layup ............................... 35 15.1 Category A/E Valves ............................. 35

16. Refueling Purification System ........................... 36

]

16.1 Category A/E Valves ............................. 36

17. Residual Heat Removal ................................... 36 17.1 Category A/E Valves ............................. 36 IV. APPENDIX A .................................................... 37

1. Code Requirement--Valves ................................ 37 E. Code Requirements--Pumps ................................ 37

V. ATTACHMENT I .................................................. 38'

1. Component Cooling ....................................... 38 iii

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1.1 Category A Valves ............................... 38 l Chemical and Volume Control ............................. 38

2. ,

2.1 Category A Valves ............................... 38 2.2 Category B Valves ............................... 38 ,

2.3 Category C Valves ............................... 39

3. Feedwater ............................................... 39 3.1 Category B Valves ............................... 39

4. Air Cooling and Purging System Reactor Containment ............................................. 39 4.1 Category A Valves ............................... 39

5. Main Steam .............................................. 39 5.1 Category B Valves ............................... 39 5.2 Category C Valves ............................... 39

6. Recirculation Spray .... ............................. .. 40 6.1 Category B Valves ............................... 40

7. Residual Heat Removal ................................... 40 .

7.1 Category A Valves ............................... 40 7.2 Category C Valves ............................... 40

8. Safety Injection ........................................ 40 8.1 Category A Valves ............................... 40 8.2 Cat. gory B Valves ............................... 40 8.3 Category C Valve ................................ 41

o. Service Water ........................................... 41 9.1 C a tego ry A a nd B V a l ves . . . . . . . . . . . . . . . . . . . . . . . . . 41 VI. ATTACHMENT ll .................................... .. ........ 42 VII. ATTACHMENT III ................................................ 43 Vill. ATTACHMENT IV ................................................. 44 i

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L I. INTRODUCTION

. Contained herein is a safety evaluation of the pump and valve inser-vice testing (IST) program submitted by the Virginia Electric and Power 't Company on January 31, 1979 for its North Anna Nuclear Power Station Unit 2.

, The program applies to North Anna Unit 2 for the period (TBS) through ITBS).

The working session with North Anna Unit 2 and Virginia Electric and lower ,

Company representatives was conducted on September 9 and 10, 1980. The '-

licensee resubmittal was issued on Feburary 13, 1981 and was reviewed by EG&G Idaho, Inc., to verify compliance of proposed tests of safety-related r Class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Pressure Vessel Code,Section XI,1974 Edition, through the summer of 1975 Addenda. Virginia Electric and Power Company has also requested relief 1 f rom the ASME code from testing specified pumps and valves because of prac- t tical reasons. These requests have been evaluated individually to determine whether they have significant risk implications and whether the

• tasks as required are indeed impractical.

The evaluation of the pump testing program and associated relief ,

I requests is contained in Section II; the evalu3 tion of the valve testing  ;

program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, ,

Inc.

A summary of pump and valve testin3 requirements is contained in Appendix A. ,

i Category A, B, and C valves that meet the requirements of the ASME code, Sect'on XI and are not excercised every three months are contained in Attachment I. ,

Valves that are never full stroke exercised or that have a testing interval greater than each refueling outage, and relief requests with  ;

insufficient technical basis where relief is not recommended are summarized in Attachment 71.

A listing of P& ids used for this review are contained in Attachment III.

Items discussed with the Licensee which may appear as differences uttween this report and the North Anna Unit 2 IST pr'1 ram are discussed in .

Attachment IV. I i

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II. PUMP TESTING PROGRAN The IST program rubmitted by Virginia Electric and Power Company was

• examined to verify that Class 1, 2, and 3 safety-related pumps were included in the program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that all Class 1, ,

2, and 3 safety-reiated pumps were included in the IST program and, except for those pumps icentified below for which specific relief from testing has been requested, the pump tests and frequency of testing comply with the code. Each Virginia Electric and Power Company request for relief from testing pumps, the cous requirement for testing, the basis for requesting relief, and the EG&G evaluation of that request is summarized below.

1. Component Cooling Pumps 1.1 Relief Request The licensee has requested specific relief from measuring differential pressure (AP) and flowrate (Q) for the Component Cooling pumps 2-CC-P-1A and 2-CC-P-1B in accordance with the requirements of Section XI and proposes to record AP and Q for each of these pumps but not compare to reference values for head curve verification. Additionally, motor current will be recorded for comparison purposes.

1.1.1 Code Requirement. Refer to Appendix A.

1.1.2 Licensee's Basis for Requesting Relief. The accuracy of flow instrumentation at nc emal operating flows is about +8%. This accuracy does not lend itself to satisfying the requirements of Table IWP-2100-2 where the acceptable range is + 24 - 6%. In addition, varying flow rates inter-fere with normal plant operation since flows have been balanced to meet heat load requirements. Therefore, the AP and Q for each of these pumps will be recorded but not compared to reference values for head curve veri-fication. Additionally, motor current will be recorded for comparison purposes.

1.1.3 Evaluation. We agree with the liciensee's basis and, therefore, feel that relief should be granted for the Component Cooling pumps 2-CC-P-1A and 2-CC-P 1B from the Section XI requirements to measure AP and Q. The

'icensee has demonstrated that a-'e lines have not been provided with a suitable means to assure or determine the presence or absence of liquid when the presence or absence could produce a difference of more than 0.25%

in the indicated value of the measured pressure. Reference values and subsequent test values will all be taken with the gage lines as designed.

Therefore, any error would be common to all values recorded and not affect the evaluation of the data. Instrumentation inchJded under this relief request is only +4% accurate. We conclude that the licensee's proposal to record AP, Q and motor c"rrent and measuring all other parameters rcquired ,

by Section XI should provide sufficient data to determine any pump degrada-tion (the intent of Section XI). .

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2.. Charging Pumps

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. 2.1- Relief Request i 1The licensec has requested specific relief from measuring inlet pres-

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. som the Char ;;ng Pumps 2-CH-P-1 A,- 2-LH-P-1B and 2-CH-P-lC in

, d' ;h the requirements of Section-X1 and proposed to observe vc .rol tank pressure to assure repeated initial test conditions.

2.1.1 Code Requirement. Refer to Appendix A.

2.1.2 Licensee's Basis for Requesting Relief. Suction pressure instrumentation is not installed or required. These pumps are capable of l prod u ng greater than 2400 psig discharge pressure, while the duction pressure would nominally be 15 to 20 psis. The Volume Control rank pres-sure will be recorded using Control Room indication to establich initial i conditions for testing. This indication is about 4% accurate.

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

! f eel relief should be granted for the Charging Pumps 2-CH-P-1 A, 2-CH-P-1B and 2-CH-P-IC f rom the Section XI requirement to measure ')j. The licen-see has. demonstrated that, since no suction pressure irstrumentation is installed, observing VCf pressure to establish repeated test conditions is an acceptable alternative. We conclude that observing VCT pressure to  !

. establish repeated test conditions for Pj and measuring all other para-meters required by Section XI should provide sufficient data to deterrine any pump degradation (the intent of Section XI).

3. Boric Acid Transfer

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3.1 Relief Request The licensee has requested specific relief from measuring Pj, vibra-tion amplitude (V), lub-icant level or pressure, and bearing temperature (Tb) for the Boric Acid pumps 1-CH-P-2C and 1-CH-P-20 in accordance with

the requirements of Section XI and proposed to observe Boric Acid Storage Tank level to establish initial test conditions.

3.1.1 Code Requirement. Refer to Appenc'ix A.

1 3.1.2 Licensee's Basis for Requesting Relief. Monitoring discharge i pressure n:Onthly is considered sufficient since these pumps provide the driving force to deliven boric acid to the charging pump suction and

! operator observation of boration and chemical analysis of boron concentra-tion will indicate whether desired results have been achieved. The Boric Acid Tanks serv as the head for these pumps. Tank level will be observed

f rom the Control Room to establish initial conditions for testing. This indication is about 4% accurate. The pump is totally eacased in insulation i

making Tb, V and lubricant level or pressure impossible to measure or observe.

1 - 3.1.3 Evaluation. We agree with the licensee'c basis and, therefore.

feel that temporary relief should be granted for the Boric Acid Transfer 3

pumps 1-CH-P-2C and 1-CH-P-20 from the Section XI requirements to measure Pi, V, lubricant level or pressure and Tb. The licensee has demonstrated that using boric acid storage tank level to establish repeated test condi- .

tions is an acceptable alternate for Pj measurements. We conclude that the hydraulic characteristics of these pumps can be sufficiently analyzed to determine any pump degradation. However, we feel the licensee should ,

further investigate some means to determine the mechanical characteristics (V, Tb) of these pumps to assure that mechanical degradation has not occurred.

4. Inside Recirculation Spray Pumps 4.1 Relief Request The licensee has requested specific relief from measuring all para-meters for the Inside Recirculation Spray Pumps 2-RS-i%lA and 2-RS-P-18 in accordance wi h the requirements of Section XI and proposed to monitor pump rotation and vibration monthly.

4.1.1 Code Requirement. Refer to Appendix A.

4.1.2 Licensee's Basis for Requesting Relief. These pumpr. are run dry to verify opera *-jal readiness; theretore Pi, AP, Q, and proper lubricar.t level or pressure cannot be mu3sured. Each pump is equipped with a sensor to detect pump rotation. In addition, a vibration alarm associated with each pump will alert Control Room personnel to excessive pump vibration.

4.1.3 Evaluation. We ogree with the licensee's basis and, therefore, f eel that temporary relief should be granted for the Inside Recirculation Spray Pumps 2-RS-P-1A and 2-RS-P-1B from the requirements of Section XI. ~

The licensee has demonstrated that, with the present plant design, all parameters required by Section XI cannot be measured. We conclude that the 1icensee's proposed alternate test of monitoring rotation and vibration to demonstrate pump operability is the only proctical test /dilable. However, we also feel that the licensee should further investigate alternate test methods and possible plant modification. to allow pump testing that will provide more adequate data to determine if any hydrauli: or mechanical degradation of these pumps has ocurred.

L. Outside Recirculation Spray Pumps 5.1 Relief Request The licensee has requested specific relief from measuring all pcca-meters for the ou'. side Recirculation Spray Pumps 2-RS-P-2A and 2-RS-P-28 in accordance with the requirements of Section XI and proposed to verify oper-ational readiness and rotation.

5.1.1 Code Requirements. Refer to Appendix A.

b.l.2 Licensee's Basis for Requesting Relief. These pumps will be run dry or wet to verity operational readiness. Each will be observed to -

verify rotation. At least once per 18 months, each will be tested on its 4

recirculation path when flow and discharge pressure will be observed. A vibration alarm associated with each pump will alert Control Room personnel to excessive pump vibration. Due to pump design, it is not possible to mea-sure a suction pressure'. Proper lubricant level or pressure is not required since the bearings are in the main flow path.

5.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that temporary relief should be granted for the Outside Recirculation Spray Pumps 2-RS-P-2A and 2-RS-P-28 from the requirements of Section XI.

-The licensee has demonstrated that, with the present plant design, all

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parame ers required by Section XI cannot be measured. We conclude that the licensee's proposed alternate test to verify operational readiness o..d rotation to demonstrate pump operability is the only practical test avail-able. However, we also feel that the licensee should further investigate

-alternate test methods and possible plant modifications to allow pump test-ing that will provide more adequate data to determine if any hydra'lic cr mechanical degradation of these pumps his occured.

6. Low Head Safety Injection 6.1 Relief Request The licensee has requested specific relief f rom measuring Pj and lubricant level or pressure for the LHSI pumps 2-SI-P-1A and 2-SI-P-1B in dCCordance with the requirements of Section XI ano proposed to establish a reference level in the Refueling Water Storage Tank to assure repeated test conditions.

6.1.2 Licensee's Basis for Requesting Relief. These pumps take suc-tion f rom the RWSI f or pump perf orme1ce testing. This tank has a minimum level required by Technical Specifications, which will be observed from the Control Room. This indication is about 4% accurate. Proper lubricant level or pressure cannot be observed since bearings are in the main flow path.

6.1.3 Evaluation. We agree witn the licensee's basis and, therefore, feel that relief should be granted for the LHSI Pumps 2-SI-P-1A and 2-SI-P-1B from the Section XI requirements to measure Pj and lubricant level or pressure. The licensee has demonstrated that, since no suction pressure instrumentation is nnstalled, observing RWST leiel to establish repeated test condition is an acceptable alternative. Also, we feel that

ince the bearings are cooled by the liquid pumped, proper lubricant level or reeusure cannot be observed. We conclude that ocserving RWST level to i establish repeated test cont'itions frr Pi and measuring all other para-meters required by Section XI should provide sufficient data to determine any pump degradation (the intent of Sectica XI).

7. Service Water 7.1 Relief Request

. The licensee has requested specific relier from measuring Pj, Q, and lubricant level or pressure for the Service Water Pumps 2-SW-P-1A and 5

2-SW-P-1B in accordance with the requirements of Section XI and proposed to record flow and service water reservoir level to establish initial condi-tions for testing. .

7.1.1 Code Requirement. Refer to Appendix A.

7.1.2 Licensee's Bas;s for Requesting Relief _. The accuracy cf flow instrumentation at normal operating flows is about +8%. This accu,acy does not lend itself to satisfying the requirements of Table IWP-2100-2 where the acceptable rar ge is +2% -6%. In addition, varying flow rates interfere with normal plant operation since flows have been balanced to meet heat load requirements. Therefore, the discharge pressure and Q for each pump will be recorded but not compared to reference values for head curve verifica-tion. -These pumps take suction f rom the Service Water Reservoir, which bcts a minimum level required by Technical Specifications. This level indica-tion, which is about 4% accurate, will be otserved f rom the Control Room to establish initial conditions for testing. Froper lubricant level or pres-sure cannot be observed since bearings are in the mait. flow path. Motor current will be recorded for comparison purptses.

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! 7.1.3 Evaluation. We agree with the 1 censee's basis and, therefore, feel that relief should be granted for the Service Water Pumps 2-SW-P 1A and 2-SW-P-1B from the Section XI requirements to measure Pj, ~ and lubri-cant level or pressure. The licensee has memonstrated that the accuracy of the flow instrumentation does not satisfy tre requirements of Section XI, and that comparing motor current is an acceptable alternate parameter. We conclude that using Service Water Reservoir level to establish initial test '

< conditions for Pj is an adequate alternate parameter. Also we feel that e since the pumps are submerged and tLe bearings are cooled by the liquid i pumped, proper lubricant level or pressure cannot be observed. Thus, we '

feel that adequate data is available to determine any puir, degr2Jation (the intent of Sertion XI).

8. Auxiliary Service Water 8.1 Relief Request The licensee has requested specific relief frc1 measuring Pj, Q, and lubricant level or pressure for the Auxiliary Service Water Pump 2-SW-P-4 in accordance with the requirements of Section XI and proposed to record i flow and monitor Lake Anna level to establish initial conditions for testing.

8.1.1 Code Requirement. Refer to Appendix A.

8.1.2 Licensee's Basis for Requesting Relief. The accuracy of flow instrumentation at normal operating f lows is about +8%. This accuracy dnes not lend itself to satisf ying the requirements of Table IWP-2100-2 5.3ere

( the acceptable range is + 2% - 6%. In addition, varying flow rates inter- .

fere with normal plant operation since flows have been balanced to meet heat load requirements. Therefore, the discharge pressure and Q for this pump will be recorded but not compared to reference values for head curve .

verification. This pump takes suction from Lake Anna, which has a minimum 6

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level required by Technical Specifications. This level indication, which is about 4% accurate, will be observed from the Control Room to establish

• initial conditions for testing. Proper lubricant level or pressure cannot be observed since bearings are in the main flow path.

• 8.1.3 Evaluation. We agree with the licensee's basis and, therefore, f eel that relief should be granted for Auxiliary Service Water Pump 2-SW-P-4 from the Section XI requirements to measure Pj, Q and lubricant level or

-pressure. The licensee has demonstrated that instrumentation does not exist to measure inlet pressure and that the accuracy of the flow instru-mentatinn does not conform to the requirements of Section XI, but some alternate parameters can be monitored to evaluate pump performance and degradation. We conclude that using reservoir level to establish initial test conditions for Pi is an adequate alternate parameter. 'Also, we feel that since the bearings are cooled by the liquid pumped, adequate data is available to determine any pump degradation (the intent of Section XI).

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9. Madiation Monitoring Sample Pumps 9.1 Relief Request The-licensee has requested specific relief from measuring all parameters for the Radiation Monitoring Sample Pumrs 2-SW-P-5, 2-SW-P-6, 2-SW-P-7, and 2-SW-P-8 in accordance with the requiretants of Section XI and proposed to run these pumps dry monthly to verify operability and to run these pumps every 18 ronths and measure vibration (V).

- 9.1.1 Code Requirement. Refer to Appendix A.

. 9.1.2 Licensee's Basis for Requesting Pelief. The flow paths f these pum p; are normally dry. These pumps will be run monthly, but because the system flow path is dry, they are not run long enough to record any parameters. No instrumentation is installed to record any of tne para- ,

meters required by Section XI. At least once per 18 months, each psmp will be automatically started in conjunction with a test signal for Containment Depressu.ization Actuation. Pump vibration will be measured and the radia-y Lion monitor associated with each pump will be observed to determine if the Low Flow Alarm resets, thus verifying flow.

9.1.3 Evaluation. We agree with the licensee's basis and, therefore, f eel that relief shou?d be granted for the Radiation Monitoring Sample i Pumps 2-SW-P-5, 2-SW-P-6, 2-SW-P-7, and 2-SW-P-8 f rom the reqL e rements of Section XI. The licensee has demonstrated that with the present plant ,

design, the parameters required by Section XI cannot be measured. We ,

conclude that the licensee's proposed alternate tests of verifying pump operability monthly and measuring vibration and verifying flow once per 18 months is the only practical test avtilable. However, we also feel that the licensee should further investigate alternate test methods ard possible plant modifications to allow more adecuate data to determine if any hydrau-lic or mechanical dec adation of these pumps has occured.

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10. Casing Cooling Pumps 10.1 Relief Request ,

The licensee has requested specific relief from measuring proper lubricant level or pressure for the C;31ng Cooling Pumps 2-RS-P-3A and .

2-RS-P-3B in accordance with the requirements of Section XI'and proposed to replace the grease once per year.

10.1.1 Code Requirement. Refer to Appendix A.

10.1.2 Licensee's Basis for Requesting Relief. The bearing lubrica-tion for these pumps is grease instead of oil. The manufacturer's recom-mended maintenance schedule specifies that the grease be replaced after 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of operation. The anticipated yearly operating time of these pumps is considerably less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. There are no means available to check the lubricant level of these ' earings o without replacing the grease.

10.1.3 Evaluation. We agree with the licensee's basis and, tnerefore, f eel that relief should be granted f or the Casing Cooling Pumps 2-RS-P-3r and 2-RS-P-3B from the Section XI requirements to measure proper lubricant level or pressure. The licensee has demonstrated that, because of the limited operating time of these pumps, replacing the grease on a yearly f requency is sufficient to prevent any pump degradation (the intent of Section XI).

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1 Ill. VALVE TESTING PROGRAM EVALUATION

• The IST program submitted by Virginia Electric and Power Company was examined to verify that Class 1, 2, and 3 safety-related valves were included in the program and that those valves are subjected to the periodic

• tests required by the ASME Code,Section XI, and the NRC positions and guidelinas. Our review found that all Class 1, 2, and 3 safety-related.

valves were included in the IST program and, except for thcse valves iden-I tified below for which specific relief from testing has been requested, the valve tests and frequency of testing comply with the code requirements ar.d the NRC positions and guidelines listed in Section 1. Also included in Section 1 is the NRC position and valve listings for the leak testing of valves that perform a pressure isolation function and a procedure for the licensee's use to incorporate these valves.into the IST program. Each Virginia Electric and Power Company request for relief from testing valves, the Code requirement for testing, Virginia Electric and Power Company's basis for requesting relief, and the EG&G evaluation of that request is summarized below and grouped according to each specific system.

1. General Considerations 1.1 Testing of Valves Which Perform a Pressure Isolation Functior There are several safety systems connected to the reactor coolant pressure boundary that have design pressure below the rated Reactor Coolant

. System (RCS) pressure. Also included are those systems which are rated at full reactor pressure on the discharge side of pumps that have pump suction below RCS pressure. In crder to protect these systems from RCS pressure, i . two or more isolation valves are placed in series to form the interface i between the high pressure RCS and the low pressure systeas. The leak tight integrity of these valves must be ensured by periodic leak testing to pre-vent exceeding the design pressures of the low pressure systems causir.j a LOCA.

It is GRC's position that these valves be classified as Category A or j A/C, as described in Section XI, Subsection IWV, ci the ASME Boiler and Pressure Vessel Code and leak tested in accordance with IW"-3420 of the above mentioned Code at least once per refueling outage. !he allowable leakage limit for each valve should not exceed 1.0 gallcns per minute

( gpa) .a The NRC has discussed this matter with the licensee and has identified the valves that parform a pressure boundary isolation function.

1 4

Pressure boundary isolation valves have been included in the IST pro-gram and categorized properly, i.e. two of three valves in series have been categorized A or AC between the high pressure system and the piping class change. Test frequency has been specified as each refueling for leakage tests.

1 d

a. See NUREG 0677, "The Probab.iity of Intersystem LOCA: Impact Due to Leak Testing and Operat.onal Changes," and the proposed Appendix A to SRP Section 3.9.6, " Leak Testing of Pressure Isolation Valves."

9

1.2 ASME Code,Section XI, Requirements Subsection IWV-3410(a) of the Section XI Code (which discusses full .

stroke and partial stroke testing) requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IWV-3410(b-1), (e), and (f). DV-3520(a) requires that Code Category C ,

valves be exercised once every three months, with the exception as defined in IWV-3520(b). IWV-3700 requires no regular testing for Code Category E vilves. Operational checks, with appropriate record entries, shall record

he position of these valves before operations are performed and after verations are completed and shall verify that each valve is locked or sealed. The limiting value of full stroke time for each power-operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where

1. It is not practical to exercise the valves to the position required to fulfill their function, or to the partial position, during power ope ition

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

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

limited operation is possible (and it has t,een demonstrated by the licensee and agreed to by the NHC), the check valve shall be partial stroked. Since disk position is not a s ays observable, the NRC staff stated that verifi- ,

cation of the plant's i tty analysis design flow rate through the check valve would be an adeqt._ ~ demonstration of the full stroke requirement.

Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or greater than the design flow rate through the valve. The licensee agreed to conduct flow tests to satisfy the above position.

l.a 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 l stroked because of the design logic of the operating circuits. These cir-cuits 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 should be granted because the required f unction of the valves involves only full open or full clored positions. .

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1.5 Test Frequency of Cneck Valves Tested ~at Cold Shutdov..s_

• The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Cateogry A and B valves and once every nine months for Category C valves. Itis the NRC's position that the Code is inconsistent and that Category C valves

~

should be tested on the same schedult as Category A and B valves. The licensee has agreed to modify his procedures on cold shutdowns.to read, "In the case of frcquent cold shu'. downs, valve testing .need not be performed .

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

1.6 Licensee Request for Relief- to Test Valves at Cold Shutdowns The Code permits valves to be tested at cold shutdowns, and these 2

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 require-i ments of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST progrom, we have verified that it i was not practical to exercise these valves during power operation and that we agree with the licensee's bacis. It should be noted that the NRC dif-ferentiates, for valve testing purposes, between the cold shutdown mode and l

the refuel ug mode. Thet is, for testing purposes, the refueling mode is ,

not considered as a col' shutdown.  !

!- 1.7 Changes to the Technical Specifications  ;

in a November 1976 letter to the licensee, the NRC pr(vided an attach- f

. ment entitled, "NRC Guidelines for Excluding Exercising-(Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that, when i

! one train of a redundant system such as the Emergency Core Cooling System  !

j (ECCS) is inoperable, nonredundant valves in the remaining train should not 4

! be cycled if their failure in a non-safe position would cause a loss of i total system function. For example, during power operation in some plants, l there are stated minimum iaquirements for systems which allow certain -

limiting conditions for operation to exist at any one time and, if the j system is not restored to meet the requirements within the time period  ;

specified in a plant's Technical Specifications (T.S.), the reactor is required to be put in some other mode. Furthermore, prior to initiating  !

repairs, all valves and interlocks in the system that provide a duplicate f i function are required to be tested to demonstrate operability immediately [

and periodically thereaf ter during power operation. Ftr some plants, this situation could be contrary to the NRC guideline as stated in the document mentioned above. It should be noted that a reduction in redundancy is not i a basis for a T.S. change nor is it by itself a basis for relief from exer-cising in accordance with Section XI. The licensee has agreed te review  !

the plant's T.S. and to consider the need to propose T.S. changes which i would have the effect of precluding such testing. Af ter making this review, if the licensee determines that the T.S. should be changed becaus, the guidelines are applicable, the licensee will submit to the NRC, in con-  :

jection with the proposed T.S. change, the inoperab b condition for each

system that is affected which demonstrates that the valve's failure would l 4

i I

s 11

cause a loss of system function or if the licensee determines that the 1.b.

should not be chnged because the guidelines are not applicable or cannot be followed, the licensee will submit the reasons that led to their deter- .

mination for each potentially affected section of the T.S.

1.8 Safety-Related Valves .

This review was limited to safety-related valves. Safety-related valves are defined as those valves that are needed to mitigate the conse-quences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this cateogry would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-code class valves. It should be noted that the licensee may have included nan-safety-related valves in their IST program as a decision on the licensee's part to expand 1he scope of their program.

1.9 Valve Testing at Cold Shutdowns Inservice valve testing at cold shutdowns is acceptable when the fol-lowing conditions are met:

1. It is understood that the licensee is to commence testing as soon as the cold shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> af ter shutdown, and continue until complete or the plant is ready to return to power l 2. Completion of all valve testing is not a prerequistite tc return ,

! to power

3. Any testing not completed at one cold shutdown should be per- ,

formed during any subsequent cold shutdowns that may occur before refueling to meet the code-specified testing frequency.

For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for test ing in the cold shutdown mode.

exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

1.10 Category A Valve Leak Check Requirements for Containment Iselation Valves (CIVs)

All CIVs shall be classified as Category A valves. The Category A valve-leak rate test equiremcnts of IWV-3420(a-e) have been superseded by Appendix J requi emen s for CIVs. The NRC has concluded tnat the appli-cable leak-test procec' res and requirements for CIVs are determined by 10 CFR 50, Appendix J. Relief from Paragraph IWV-3420(a-e) or CIVs pre-sents no safety problem since the intent of IWV-3420(a-e) is met by Appenuix J requirements.

The licensee shall comply with Sections f and 9 of IWV-3420 ut til .

relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C, Appendix J leak test is performed. Based on the considerations discussed above, the NRC concludes .

12

- __ ~ - .

?

l .that the alternate testing proposed above will give the reasonable assur-ance of valve operability intended by the Code'and that the relici thus

+ -granted will not endanger life or property or the common defense and security of the public.

- 1.11. Application of Appendix J-Testing to the IST Program 4

The Appendix J review for this plant is a completely separate review from the IST program review. However, the determinations made by that' review has determined thuc the current'IST program as submitted by the

, licensee correctly reflects the NRC's interpretation of Section XI i vis-a-vis Appendix J. The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.

l 1.i2 Pressurizer Power Operated Relief Valves

' The NRC has adopted the position that-the pressurizer power operated relief valves should be included in the IST program as Category B valves and tested to the requirements of Section XI. However, since the PORVs have shown 'a high probability of sticking open and are not needed for over-pressure protection during power operation, the NRC has concluded that routine exercising during power operation is "not pratical" ano, therefore,

! not required by IWV-3412(a).

The PORVs' function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low temperature-overpressuriza-tion conditions and should be exercised prior to initiation of system con-

. ditions for which vessel protection is needed.

The following test schedule is recommended:

1 1. Full stroke exercising should be performed during cooldown prior 3

to achieving the water solid condition in tha pressurizer and

during cold shutdown prior to heat up.

2. Stroke timing should.be performed at each :old shutdown or, as a i minimum, once each refueling cycle.

i

3. Fail safe actuation testing is permitte' by the Code to be per-formed at each cold shutdown if the valves cannot be tested dur-ing power operation. This testing should be performed at each cold shutdown.

The power operated relief valves PCV-24SS and PCV-2456 are not included in the IST program but are tested in accordance with the above recommended test schedule.

i~

1.13 PORV Block Valves 3

The PORV block valves, MOV-2535 and MOV-2536 are not included in the IST program but are tested in accorJance with Techn cal Specifica- i l

tion 4.4.3.2.2. 4 l- l

l 13 i.__-_ _ . . _ . _ _ - _ _ _ _ . _ _ . _ _ _ . , _

l

2. Component Cooling

! 2.1 Category A valves .

I:

l 2.1.1 Relief Request. The licensee has requested specific relief l from exercisTng Category A valves TV-CC-201 A, and B, reactor coolant pumps, .

I thermal barrier containment i:olation valves; TV-CC-202A, B, C, D, E, and F, and TV-CC-204A, B, and C, reactor coolant pumps upper bearing lube oil, lower bearing lube oil, and stator cooler containment isolati m valves, in accordance with the requirements of Section XI. The licensee has proposed to exercise- trese valves during cold shut:10wns when the reactor coolant pumps are secured and during refueling outages.

2.1.1.1 Code Requirement. Pefer to Appendix A.

2.1.1.2 Licenseu's Basis far Requesting Relief. Component cool-ing water flow to the reactor coolant' pumps is required ~t all times the pumps are in operation. Failure of one of these valves-in a closed posi-tion during cycling would result in a loss of the cooling flow to the pump.

Power operated valves in these systems-will be cycled at each cold shutdown and refueling when the reactor coolant pumps are sJcured.

2.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves TV-CC-201A, and B; TV-CC-202A, B, C, D, E, and F; and TV-CC-204A, B, and C from the exercising requirements of Section XI. The licensee has demon-strated that exercising any of these valves while the RCPs are operating

• would result in a loss of RCP cooling whis,h could result in RCP damage requiring a reactor shutdown for repairs. We conclude that exercising these valves during colu shutdown when the RCPs are secured and at least ~

once each refueling outage should demonstrate proper valve operability.

2.2 Category A/C Valves 2.2.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 2-CC-78, 115, and 152, RCPs upper bear-ing lube oil, lower bearing lube oil and stator cooler inlet check valves; 2-CC-194 and 199 RHR heat exchanger inlet check valves and 2-CC-276, 289, and 302 containment recirculation air cooler isolation check valves, in accordance with the requirements of Section XI. The licensee has proposed to verify valve closure (their safety-related position) during each refuel-ing outage.

2.2.1.1 Code. Requitement. Refer to Appendix A.

2.2 '.2 Licensee's_ Basis for Requesting Relief. These cheer valvec remain in a normally open position with component cooling flow. The only method for verifying these valves closed is during the refueling outage leak rate test.

l 2.2.1.3 Evaluation. We agree with the licensee's basis and i I

therefore, feel that relief should be granted for Category A/C valves .

2-CC-78,115, and 152, 2-CC-194 and 199, and 2-CC-276, 269, and 302 from l-14 i

-the exercising requirements of Section XI. The licensee has demonstrated

that, due to plant design, the'only method available to verify valve

- closure (their safety-related position) is leak testing. .These valves are not equipped with valve position indication and some of the required test connections are located inside the containment. . We conclude that the pro-

- posed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

3. Chemical and Volume Control 3.1 Category A Valves

^

3.1.1 Relief Request. The licensee has requested specific relief from exercising categary A valve FCV-2160, auxiliary reactor coolant system

^

charging control valve, in accordance with the requirements of Section XI and proposed to test this valve each refueling outage.

3.1.1.1 Code Requirement. Refer to Appendix A.

3.1.1.2 License 9's Basis for Requesting Relief. Valve FCV-2160 cannot be exercised during power operation or cold shutdown. FCV-2160 is r.ormally closed and its accident position is closed (containment isolation function).

i 3.1.1.3 Evaluation. We agree with the licensee's basis and,

. therefore, feel that relief should be granted for Category A valve FCV-2160 f rom the requirements of Section XI. This valve is in itr safety-related pos; tion and is not required to open or close to mitigate the consequences

. of an accident or safely shut down the plant. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke time mea-surements are meaningless for a passive valve.

3.1.2 Relief Request. The licensee has requested specific relief from excersing Category A valve MOV-2289A, normal charging header isolation valve, in accordance with the requirements of Section XI and proposed to exercise this valve when the charging system is not in use during cc?d shutdown and refueling outages.

j 3.1.2.1 Code Re<1uirement. Refer to Appendix A.

3.1.2.2 Licensee's Basis for Requesting Relief. Failure of this valve in a closed position during exercising would cause a loss of charging flow and could result in an inability to maintain reactor coolant inventory.

This valve will be exercised when the charging system is not in use during cold shutdown and refueling outages.

!* 3.1.2.3 Evaluation. We agree with the licensee's basis and, i therefore, feel that relief should be granteu for Category A valve MOV-2289A  ;

from the 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 tne plant. Therefore, the operability I  ;

15

of this valve is inconsequential with regard to the safety function which it perfonns. We conclude that the quarterly stroke and stroke timing mea-surements are meaningless for a passive valve. . ,

3.1.3 Relief Request.-

The licensee has requested specific relief from exercising Category A valves MOV-2380 and MOV-2381, reactor coolant .

pump seal water return containment isolation valves, in accordance with the requirements of Section XI and proposed to exercise thesa~ valves when the ,

reactor coolant pumps are secured during cold shutdown and refueling outages.

3.1.3.1 Code Requirements. Refer to Appendix A.

3.1.3.2 Licensee's Basis for Requesting Relief. To protect pump

.eals, flow to them is required at all times during power operation. Exer-cising of these valves will be performed during cold shutdown and refueling outages when the risk of equipment damage is eliminated by securing the pumps.

3.1.3.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves MOV-2380 and MOV-2381 from the exercising renuirements of Section XI. The licensee has demonstrated that exercising th.se valves while the RCPs are operating would result in a loss of seal water flow and could result in RCP damage requiring a reactor shutdown for. repairs. We conclude that exercising these valves during cold shutdown when the RCPs are secured and at least once each refueling outage should demonstrate proper valve operability. ,

3.1.4 Relief Request. The licensee has requested specific relief from exercising Category A valve TV-2204, letdown header containment isola- '

tion valve, in accordance with the requirements of Section XI and prcposed to exercise this valve when the charging system is not.in use during cold shutdown and refueling outages.

3.1.4.1 Code Requirement- Refer to Appendix A.

3.1.4.2 Licensee's Basis for Requesting Re'ief. This valve cannot be exercised when the charging and letdown systenis are in operation due to the high risk of sverpressurization of the RCS. It will be exercised at cold shutdown and refueling outages when the charging and letdown systemc are secured.

3.1.4.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valve TV-2204 from the exercising requiremtqts of Section XI. The licensee has demon-strated that exercising this valve when the charging system is in operation would result in a loss of reactor coolant system pressure and level control.

We conclude that exercising this valve during cold shutdown when the charg- l

, ing system is secured and at least once each refueling ou* age should demon- .

l strate proper valve operability.

1 I

t 4

i 16 l

,,,.,,_..,..,_,_,,n. , . , , _ - . _ , , _ _ , , . _ , _ ,

3.2 Category A/C Valves l

- 3.2.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valve RV-2203, letdown header relief valve, in .

accordance with the requirements of Article IWV-3410 and proposed to exer- t

. cise this valve per the requirements of Article IWV-3500.

3.2.1.1 Code Requirement. Refer to Appendix A.

3.2.1.2 Licensee's Basis for Requesting Relief. The frequency and quantity of relief valves subject to test at each refueling outage will be in accorJance with IWV-3500. RV-2203 will be exercised in accordance ,

with the frequency in IWV-3500. .

1 3.2.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C relief valve RV-2203 from the exercising requirements of Section XI. The licensee has i demonstrated that this valve which is located inside the containment is inaccessible during power operation. RV-2203 provides a containment isola-  !

tion function from the pressurizer relief tank when shut and exercising this valve per the requirements of Article IWV-3410 will not provide any increase in piant safety. We conclude that exercising this valve in accord-ance with Article IWV-3500 and reverse flow leak rate testing at refueling outages should demonstrate proper valve operability.

3.2.2 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 2-CH-331, 332, 335, 308, 284 and 260, reactor coolant system chargir.g containment isolation valves, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety-relatec position) during refueling outages 3.2.2.1 Code Requirement. Refer to Appendix /.

3.2.2.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation or cold snutdown. The 0: ly ,

method available to verify that these valves close is during the refueling leak rate test.

3.2.2.3 Evaluation. We agree wit:. *he licensee's basis and, therefore, feel that relief should be granted for Category A/C valves 2-CH-331, 332, 335, 308, 284, and 260 f rom the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (their safety-related posi- i tion) is during leak rate testing. In addition, these valves are not equipped with valve position indicators. We conclude that the proposed alternate testing frequency of verifying valve closure during the perfor-

mance of leak rate testing at refueling outages should demonstrate proper valve operability.

3.3 Category B Valves

. 3.3.1 Relief RevJes . The licensee has requested specific relief from exercis ng Category B valve MOV '2898, normal charging header isola-tion valve, in accordance with the requirements of Section XI and proposed 17

to exercise this valve when the charging system is not in use during cold shutdown and refueling outages.

3.3.1.1 Code Requirement. Refer to Appendix A.

3.3.1.2 Licensee's Basis for Requesting Relief. Failure of this ~

valve in a closed position during exercising would cause a loss of charging flow and could result in an inability to maintain reactor coolant inventory.

This valve will be exercised when the charging system is not in use during cold shutdown and refueling outages.

3.3.1.3 Evaluation. We agree with the licensee's basis and, 4

therefore, feel that relief should be granted for Category B valve MOV-22898 i

from the requirements of Section XI. This valve js 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. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke timing mea-surements are meaningless for a passive valve.

3.3.2 Relief Request. The licensee has requested specific relief from exercising Category B valve MOV-2373, charging pump recirculation header isolation valve, in accordance with the requirements of Section XI and pro-posed to exercise this valve when the charging system is not in use during cold shutdown and refueling outages.

3.3.2.1 Code Requirement. Refer to Appendix A.

3.3.2.2 Licensee's Basis for Request : Relief. This valve cannot be exercised without possible damage to ti charging pumps. It will be exercised with the charging pu.nps secured at cold shutdown and refueling -

outages.

3.3.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief shall be granted for Category B. valve MOV-22698 from the requirements of Section X1. 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. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke timing measurements are meaningless for a pass' /e valve.

3.3.3 Relief Pequest. The licensee has requested specific relief from exercising Cattgory B valve MOV-2373, charging pump recirculation h a der isolation valve, iii accordance with the requirements of Section XI and proposed to exercise this valve when the charging system is not in use during cold shutdown and refueling outages.

3.3.3.1 Code Requirement. Refer to Appendix A. ,

3.3.3.2 Licensee's Basis for Requesting Relief. This valve cannot be exercised without possible damage to the charging pumps. It vill ,

( 18

be exercised with the charging pumps secured at cold shutdown and refueling outages.

4 3.3.3.3 Evoluation. We agree with the licensee's basis and, the,'efore, feel'that relief should be granted for Category B valve MOV-2373 f rom the exercising requirements of Section XI. This normally open valve provides a flow path for the minimum flow recirculation header for the charging pumps. MOV-23?3 receives a safaty injection signal to shut. The licensee has demonstrated that shutting this valve when'the charging pumps are operating could cause pump damage if it failed in the shut pw iuon.

We conclude that exercising this valve during cold shutdown and refueling ,

outages when the charging pumps are not operating should demonstrate proper valve operability.

3.3.4 Relief Request. The licensee has requested specific relief I f rom exercising Category B valves MOV-2267A and B, 2269A and B, 2270A and B, charging pumps suction valves, MOV-2286A, B, C, 2287A, B, and C, charging pump discharge valves, in accordance with the req"irements of Section XI and proposed to exercise these valves during cold shuudown when the charging pumps are secured and during refueling cutages.

3.3.4.1 Code Requirement. Refer to Appendix A.

a 3.3.4.2 Licensee's Basis for Requesting Relief. Category B valves MOV-2267A and 8, 2269A and B, 2270A and 8, charging pump suction valves, MOV-2286A, B, C, 2287A, B and C, charging pump discharge valves, cannot be exercised during power operation. These valves are in their intended safety position (open). A failure in the closed position may damage the charging pumps in the event of an automatic start. Th2se valves will be exercised at cold shutdown when the charging pumps are not reouired to be operating and during refueling outages.

3.3.4.3 Evaluation. We agree with the licensees basis and.,

therefore, feel that relief should be granted for Category B valves MOV-2267A and B, 2269A and B, 2270A and B, 2286A, B and C, and 2287A, B and C fmm the exercising requirements of Section XI. The licensee has demonstrated that these valves arc in their intended safety position and that a f ailure of these valve. during testing could damage the charging pumps. These valves are not required to operate to mitigate the conse-quences of an accident or safely shut down the plant. Therefore, the .

operability of these valves is inconsequential with regards to the safety function which they perform. We conclude that the licensee's proposed '

alternate testing shotid demonstrate nroper valve operability.

4. Containment Vacuum 4.1 Category A Valve

. 4.1.1 Relief Request. The licensee has requested specific relief from exercising Category A valve TV-CV-200, containment vacuum trip valve, in accordance with the requiremer.ts of Section XI and proposed to exercise

, this valve each refueling outage.

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I 4.1.1.1 Code Requirement. Refer to Appendix A.

4.1.1.2 Licensee's Basis for Requesting Relief. TV-CV-200 is '

normally closed and its accident position is closed. The'palve will be exercised during refueling nutages when establishing containment vacuum.

4.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A valve TV-CV-200

from the requirements of Section XI. -This valve is in its safety-related 00sition and is not required to open or close to mitigate the consequences of an accidnet or safely shut down the plant Therefore, the operability of this valve is inconsequential with rega" , to the safety function which it performs. We conclude that the quarterly stroke and stroke time measure-ments are meaningless for a passive valve.

4.2 Category A/E Valve l

) 4.2.1 Relief Request. The licensee has requested specific relief from exercising Category A/E valve 2-CV-4, containment vacuum jector iso-lation valve, in accordance with the requirements of Section XI and proposed to exercise this valve each refueling outage.

4.2 1.1 Code Requirement. Refer to Appendix A.

4.2.1.2 -Li nsee's Basis for Requesting Relief. 2-CV-4 is a manual valve and is in its intended safety position (closed). This valve will be exercised during refueling outages when establishing containn.ent

• vacuum.

4.2.1.3 Evaluation. We agree with the licensee's basis and,  ;

therefore, feel that relief should be granted for Category A/E valve 2-CV-4

• 6 f rom the 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. Therefore, the operability of this valve is inconsequential with regards to the safety function which  !

it performs. We conclude that the quarterly stroke and stroke time measure- l ments are meaningless 'or a manual, passive valve.

t 5, Con'.ainment Sump Drains t 5.1 Category A/C Valve  ;

5.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valve 2-DA-49, post accident sample system  !

return line check valve, in accordance with the requirements of Section XI '

and proposed to verify valve closure (its safety-related position) during  ;

each refueling outage.  ;

5.1.1.1 Code Requirement. Refer to AppenJix A.

5.1.1.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation or cold shutdown. The only , e i

r t

20 I

l l - _ - _ , .

methcd available to verify that these valves close is during the refueling

~

. leak rate test.

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

. 2-DA-49 from_the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design,-the only method available to verify valve closure.(its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test-connections are located inside the containment.

5.2 Category A/E Valves 5.2.1 Relief Request. Tne licensee has requested specific relief from exercising Category A/E valves 2-DA-7 and 2-DA-9, primary drain transfer line isolation valves, in accoraance with the requirements of Section XI.

5.2.1.1 Code Requ0 .. int. Refer to Appendix A.

5.2.i.2 Licensee's Basis for Requesting Relief. These are manual i valves and will not be exercised because they are in their accident position (closed).

t 5.2.1.3 Evaluation. We agree with the licensee's basis and, l therefore, feel that relief should be granted for Category A/E valves 2-DA-7 and 2-DA-9 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.

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

6. Feedweter 6.1 Category B Valves 6.1.1 Relief Request. The licensee has requested specific relief from stroke timing Category B valves PCV-FW-259A and B, auxiliary feed water control valves, in accordance with the requirements of Section XI.

6.1.1.1 Code ReqJirement. Refer to Appendix A.

6.1.1.2 Licensae's Basis for Requesting Relief. PCV-FW-259A and B will be exercised quartu-ly but will not be timed. Stroke time is not important because these are modulating valves.

i . 6.1.1.3 Evaluation. We agree with the licen;ee's basis and, therefore, feel that relief should be granted for Category B valves PCV-FW-259A and B from the stroke timing requirements of Section XI. The

, . licensee has demonstrated that stroke timing a modulating valve will not 21

provide any meaniful data for valve degradation. We conclude that verify-ing pr per system operation is the most practical method of ensuring proper valve operability.

! 6.2 Category C Valves I

6.2.1 Relief Request. The licensee has requested specific relief -

from exercising Category C valves 2-FW-62, 94, and 126, main feedwater check valces at the penetration, in accordance with the requirements of j Section XI and propcsed to exercise these valves when entering or leaving j cold shutdown.

6.2.1.1 Code Requirement. Refer to Appendix A.

l l 6.2.1.2 Licensee's Basis for Requesting Relief. Closure of l mainsteam or feedwater valves during normal operations would result in i turbine and reactor trips. These valves are closed during the process of shutdown and rec,sened during plant start-up. Operation of these valves +

l will be verified when entering or leaving cold shutdown.

I 6.2.1.3 Evaluation. We agree with the licensee's basis and, l therefore, feel that relief should be granted for Category C valves 2-FW-62, 94, and 126 from the exercising requirements of Section XI. The licensee has demonstrated that exercisirg these valves during power r- ration to their safety related position (closed) would require securing feedwater to the respective steam generator anc would result in a reactor trip. We conclude that full stroke exercising these valves when entering or leaving cold shutdown should demonstrate proper valve operability. -

6.2.2 Relief Request. The licensee has requested specific relief from exercising Category C valves 2-FW-70, auxiliary feedwater header check -

valve at the main feedwater header, 2-FW-150 and 156, auxiliary feedwater pumps discharge and recirculation chock valves, and 2-FW-279, auxiliary feedwater header check valve, during cold shutdown.

l 6.2.2.1 Code Requirement. Refer to Appendix A.

! 6.2.2.2 Licensee's Basis for Requesting Relief. 2-FW-70, 2-FW-150, 2-FW-156, and 2-FW-279 cannot be exercised during cold shutdown because stea;ti is not available to operate the turbinc driven auxiliary I feedwater pump.

6.2.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 2-FW-70, 2-FW-150, 2-FW-156, and 2-FW-279 f rom the exercising requirements of Section XI. The licensee has demonstrated that since steam is not available uuring cold shutdown there is no practical method available to

exercise these valves. We conclude that the licensee's proposed alternate l method of exercising these valves during power operation should demonstrate '

i proper valve operability.

l l

i 22

l

< 7. Instrument Air

, 7.1 Cf.tegory A/C Va_lve 7.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valve 2-IA-428, air radiation monitor return line check-valve, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety-related position) du'ing each refuelfat outage.

7.1.1.1 Code Requirement. Refer to Appendix A.

7.1.1.2 Licensee's Basis for Requesting Relief. This valve can-not be exercised during power operation or cold shutdown. The only methud available to verify that this valve closes is during the refueling leak rate test,,

1 7.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C valve 2-IA-428 from the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related p ition) is leak testinc. This valve is not equipped with valve position inaltation and some of the required test connections are located inside the containment.

8. Main Ste ;m i

8.1 Category 8 Valve 1 8.1.1 Relief Request. The licensee has raquested specific relief from exercising and stroke timing the Terry Turbine tr p valve on the tar-bine driven auxiliary feed pump and proposed to exercise but not time this valve every 18 months.

8.1.1.1 Code hequirement. Refer to Appendix A.

s 8.1.1.2 Licensee's Basis for Requesting Relief. This is the governor valve for the steam driven auxiliary feed pump. This valve is normally open and will be exercised but not timed every i8 months during the overspeed trip test.

8.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for the Category B Terry Turbine trip ive. This valve admits steam to the auxiliary feed pump turbine when open. ihe only method available to shut this valve is with an actual overspeed on the turbine which is only required at 18 month inter-vals. Stroke timing of this valve is inconquential with regards to the safety function it perfcems. We conc 1Loe that the licensee's proposed alternate testing is sufficier.t to ensure proper valve operabilits.

I 23

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

5 8.2 Category C Valves I 8.2.1 Relief Request. The licensee has requested specific relief ,

, from exercising Category C valves 2-MS-??7, 119, and 121, main steam to auxiliary feedwater turbine pump check valves, in accordance with the requirements of Section XI and proposed to full stroke exercise these ,

valves during power operation only.

I 8.2.1.1 Code Requirement. Refer to Appendix A.

3.2.1.2 Licensee's Basis for Requesting Relief. These valves will be tested during power operation. These valves cannot be tested during cold shutdwon or refueling because steam is not available to run the turbine driven auxiliary feedwater pump.

+

8.2.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 2-MS-ll7,119, and 121 f rom the exercsing requirements of.Section XI. The licensee has demonstrated that since steam. 's not available during cold j shutdown there is no practical method available to exercise these valves.

We conclude that the licensee's proposed alternate method of exercising i these valves during power operation should demonstrate proper valve operability.

4

9. Compressed Air 9.1 Category A/C Valve 4

9.1.1 Relief Request. The licensee has requested specific relief j from exercising Category A/C valve 2-IA-250, containment instrument air return line check valve, in accordance with the requirements of Section XI

• and proposed to verify valve closure (its safety-related position) during i each refueling outage.

9.1.1.1 Code Requicoment. Refer to Appendix A. ,

9.1.1.2 Relief Request. This valve cannot ce exercised during pcwer operation or cold shutdown. The only method available to verify that

! this valve closes is'during the refueling leak rate test.

4 9.1.1.3 Evaluation. We agree with the licensee'c basis and, therefore, feel that relief should be granted for Category A v valve f i 2-It-?50 frora the exercising requirements of Section XI. The licensee has I demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is j

not equipped with valvc position indication and some of the required test connections are located inside the containment.

10. Quench Spray _ .

.0.1 Category A/C Valves

~

10.1.1 Relief Request. The licensee has requested specific relief '

from exercising Category A/C valves 2-QS-Il and 2-QS-22, querch spray pump 24

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

I containment isolation check valves, in accordance with the requirements of Section XI and proposed to manually exercise these va.ves open during refueling outages and verify them closed during the ccntainment leak rate test.

10.1.1.1 Code Requirement. Refer to Appendix A.

}

10.1.1.2 Licensee's Basis for Requesting Relief. It is not possible to verify that tiese normally closed check vahes open without initiation of spray through the upper containment header or by visual observation inside the containment. These valves shall be exercised during

refueling outages as per the Technical Specification requirements for weight loaded check valves.

10.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category n/C valve 5

2-QS-ll and 2-05-22 from the exercising requirements of Section XI. The licensee has demonstrated that since these valves are located inside the i

containment, the only method available fer exeicising them open is with system flow or manual operation which requires containment access. Using flow ti exercise these vTlves would result in spraying the containment l

causing electrical equipment damage and an extensive containment clean up.

Manual exercising requires containment access end venting which is not t

! always possible during cold shutdown. The onlj method available to verify valve closure is during the Type C containment leak rate test. We conclude that, with the present plant design, the liccnsee's proposed alternate testing should lemonstrate proper valve operability.

11. Recirculation Spray 11.1 Category A/C Valves i 11.1.1 Relief Re",uest. The licensee has requested specific relief

from exercisir.g Category A/C valves, 2sRS-20 and 2-RS-30, outside recircu-lation pump discharge and containment isolation check valves, in accordance 4 with the requirements of Section XI and proposed to manually exercise these 1 valves open during refueling outages and verify them ciased during the containment leak rate test.

11.1.1.1 Code Requirement. Refer to Appendix A.

j 11;1.1.2 Licensee's Basis for Requesting Relief. It is not possible to verify that these normally closed check valves open without initiation of spray through the upper containment header or by visual observation inside the containment. ~5ese valves shall be exercised during refueling outages as per the Technical Specification requirement- for weight loaded check valves.

11.1.1.3 Evaluation. We agree with the licensee's basis and J

j therefore, feel that relief should be granted for Category A/C valves

}

2-RS-20 and 2-RS-30 from the exercising requirements of Section XI. The i licensee nas demonstrated that sinct these valves are located inside the containment, the only method available for exercising them open is with un

I i system flow or manual operation which requires containment access. Using

flow to exercise these valves would result in spraying the coitainment i causing electrical equipment damage and an extensive containment clean up.

Manual exercising requires containment access and venting which is not *

always possible during cold shutdown. The only method available to verify valve closure is during the Type C containment leak rate test. We conclude that, with the present plant design, the licensee's proposed alternate

• 1 testing should demonstrate proper balve operability.

11.2 Category C Valves 11.2.1 Relief Request. The licensee has reonested specific relief

' from exercising Categury C valves, 2-RS-103 and 2-hS-ll8, caring cooling pump discharge check valves to outside recirculation pumps, in accordance

with the requirements of Section XI and proposed to exercise these valves j ,during refueling outages.

11.2.1.1 Code Requirement. Refer to Appendix A.

1 11.2.1.2 Licensee's Basis for Requesting Relief. It is imprac-

tical to exercise this check valve dur ing power operation per IWV-3520.

4 Opening the test valve would break conta 5 ment vacuum. The check valves I shall be exercised at refueling outages.

i 11.2.1.3 Evaluation. We agree with the licensee's basis and, l therefore, feel that relief should be granted for Category C valves l 2-RS-103 and 2-RS-ll8 from the exercising requirements of Section XI. The

! licensee has demonstrated that exercising these valves would break contain- .

i ment vacuum, which would cause a reactor trip. These valves cannot be exercised during cold shutdown unless containment vacuum is broken, which is not always possible. We conclude that the licensee's proposed alternate . ,

4 testing should demonstrate proper valve operability. l t

j 12. Reactor Coolant I i 12.1 Category A/C Valve ,

i 12.1.1 Relief Request. The licensee has requested specific relief  !

from exercising Category A/C valve 2-RC-162, primary grade water to pres-surizer relief tank check valve and s proposed tc verify valve closure (its i safety-related position) during each refueling outage. i 12.1.1.1 Code Requirement. Refer to Appendix A. ,

f 12.1.1.2 Licensee's Basis for Requesting Relief. This valve cannot be exercised during power operation or cold shutdown. The only method available to verify that this valve closes is during the refueling  !

leak rate test.  !

s 12.1,1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C valve 2-RC-162 from the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design, the only method available to verify

• r 26 i _ -_ , _

c. ,_ _ ._ _ . _ _ _ _ _ _ _ _ _ _ .__ _ _ . _ _ _ _ ..

.r valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test  !

connections are located inside the containment.

I 12.2 Category A/E Valves 12.2.1 Relief Request. The licensee has requested specific relief from exercising Category A/E valves 2-RC-143 and 2-RC-145, pressurizer pressure dead weight tester containment isolation valves, in accordance with the requirements of Section XI.

12.2.1.1 Code Requirement. Refer to Appendix A.

l 12.2.1.2 Licensee's Basis for Requesting Relief. These are '

manual valves and will not be exercised because they are in their accident l position (closed). l l 12.2.1.3 Evaluation. We agree with the licensee's basis and,  !

! therefore, feel that relief should be granted for Category A/E valves -

2eRC-143 and 2-RC-146 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 cn.1 sequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequen -

tial with regard to the safety function which they perform. We conclude i that the quarterly stroke and stroke time measurements are meaningless for manual, passive valves.

13. Safety Injection 4'

13.1 Category A Valves ,

. t

' 13.1.1 Relief Request. The licensee has requested specific relief i from exercising Category A valves MOV-286/C and 0, baron injection tank outlet valves, in accordance with the requirements of Section XI and pro-

posed to exercise these valves during refueling outages.

13.1.1.1 Code Requirement. Refer to Appendix A.  !

i i 1 13.1.1.2 Licensee's Basis for Requesting Relief. To exercise these valves would require leakage testing as per Technical Specifica-l tion 4.4.6.2.2. This leakage testing disturbs the downstream check valve 2-S1-93 which would require a containment entry to leak test. These valves will be exercised at refueling when the containment is accessable.

i

13.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves MOV-2867C and D from the exercising requirements of Section XI. The  !

licensee has demonstrated that exercising these valves would disturb the i

downstream check valve and require a containment entry to leak test this valve per the Technical Specifications. Lecause the containment is not

{ always accessible during cold shutdown, this would delay plant startup. We ,

conclude that the licensee's proposed alternate testing of exercising these i

l valves during refu ng outages should demonstrate proper valve operability. ,

i 27 i__ - _ _ - - . , . . . - . - - _ , .- -- . - , . .-.--

13.1.2 Relief elequest. The licensee has requestsd specific relief f rom exercising Category A valves MOV-2S90C and 2890D, LHSI to cold legs, in accordance with the raquirements of Section XI and proposed to exercise these valves during refueling outages.

• 13.1.2.1 Code Requirement. Refer to Appendix A. .

13.1.2.2 Ljensee's Basis for Requesting Relief. These valves are in their required safety position with power to their operators removed during power operation. To exercise these valves would require leakage testing as per Technical Specification 4.4.6.2.2. The leakage testing would disturb the downstream check valve which would require a containment entry to leak test tais valve. As an alternative these valves will be exercised during refueling outages.

13.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves MOV-2890C and 28900 from the exercising requirements of Section XI. The licensee has demonstrated that these valves are,in their intended safety position and are not required to operate to mitigate the consequences of an accident or safely shut down the plant. Exercising these valves would disturb the downstream check valve and require a containment entry to leak test this valve per the Technical Specifications. Because the containment is not always accessible during cold shutdown, this would delay plant startup. We conclude that the licensee's proposed alternate testing of exercising these valves during refueling outages should demonstrate proper valve operability.

13.2 Category A/C Valves 13.2.1 Relief Request. The licensee has requested specific relief -

from exercising Category A/C valves 2-51-85, 93, 107, and 119, high head safety injection to cold legs containment isolation iheck valves, and 2-51-92, 100, and 106, cold leg safety injection adm;ssion check valves, in .

accordance with the reauirements of Section XI. The licensee has proposed -

to exercise these check valves during refueling outaces.

13.2.1.1 Code Requirement. Refer to Appendix A.

13.2.1.2 Licensee's dasis for Requesting Relief. The only way to verify that these normally closed check valves open is by initiating flow, using the charging pumps, into the reactor coolant system hot and cold legs. If charging flow was directer. to the reactor coolant system in this manner it could cause overoressurization during old shutdown or pro-vide a loss in charging flow control during operati,n. As an alternate, these check valves shall be exercised open during refueling cutages.

13.2.1.3 Evaluation. We agree with .ne licensee's basis 'ano, therefore, feel that reliet should be granted for itegory A/C valv?s 2-SI-85, 93, 107, 119, 92, 100, and 106 from the exenising requirejents of Section XI. The licensee has demoatrated that exercising these valves during power operation would cause a loss of charging flow t.ontrol and '

thermal shock to t..e injection nozzles and possible nozzle darrfge. Also, 28

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

4 1

during cold shutdown, a low temperature-overpressurization accident could occur while exerciting these valves. We conclude that full stroke exer-cising these valves during refueling outages, when the vessel head is removed to provide an adequate expan<,1on volume, should demonstrate proper valve operability.

13.2.2 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 2-51-91, 105, and 99, low head safety injection check valves, and 2-51-126 and 128, low head safety injection to the hot legs containment isolation check valves, in accordance with the

requirements of Section XI. The licensee has proposed to exercise these valves during refueling outages.

13.2.2.1 Code Requirement. Refer to Appendix A.

i 13.2.2.2 Licensee's Basis for Requesting Helief. The only way 4 to verify that these'normally closed check valves can open is by initiating i

flow, using the low head safety injection pumps, into the reactor coolant system hot and cold legs. During operation or cold shutdown, reactor coolant system pressure will be higher than the low head pump discharge J pressure precluding flcw into the vessel. As an alternate, these valves shall be exercised open at refueling outages.

13.2.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C valves 2-S1-91,105, 99,126, and 128 from the exercising requirements of Sec-tion XI. The licensee has demonstrated that the LHSI pumps cannot overcome

- operating RCS pressure. Aho, during cold shutdown, RCS pressure is greater than design accident pressure and the LHSI pumps cannot achieve design flow through these valves. We conclude that full strGke exercising these valves

- during refueling outages, when the vessel head is removcd and the RCS has minimum back pressure, should demonstrate proper valve operability.

13.2.3 Relief Request. The licensee has requested specific relief f rom exercising Category A/C valves 2-SI-136 and 2-SI-132, accumulator

makeup and nitrogen supply check valves, in accordance with the require-ments of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

13.2.3.1 Code Requirement. Refer to Appendix A.

13.2.3.2 Licensee's Basis for Requesting Relief. These valves Cannot be exercised during power operation or Cold shutdown. The only method available to verify that these valves close is during the refueling leak rate test.

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

> 2-51-136 and 2-51-132 from the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design, tne only method avail-I able to verify valve closure (their safety-related position) is during leak

! rate testing. In addition, these valves are not equipped with valve posi-i

• tion indicators. We conclude that the proposed alternate testing frequency l

29 l

I

{ of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.-

1 13.2.4 Relief Reonest. The licensee has requested specific relief f rom exercising Category 470 valves 2-51-151, 153, 168, 170, 185, and 187,

+ accw1ulator discharge check valves, in accordance with the requirements of tection XI and proposed to parital stroke exercise these valves during -

refueling outages.

13.2.4.1 Code Requirement. Refer to Appendix A.

2

} 13.2.4.2 Licensee's Basis for Requesting Relief. To exercise i these normally closed check valves would require the simulation of a loss

} of coolant accident, i.e., low RCS pressure. These valves shall be verified operable by initiating accumulator injection to the RCS with the

! vessel head removed during each refueling outage. 2-51-170 and 2-51-187 I will be exercised when the RHR System is in service during cold shutdown.

13.2.4.3 Evaluation. We agree with the licensee's basis and, therefore, feel that temporary relief should be granted for Category A/C j valves 2-SI-151, 153, 168, 170, 185, and 187 from the exerciring require-i ments of Section XI. The licensee has demonstrated that these valves can-

! not be exercised during powar operation because the accumulators cannot i overcome RCS pressure. During cold shutdown, exercising these valves could l result in an RCS low temperature-overpressurization accident. We conclude i that, with the present plant design, a partial stroke exercise during refueling outages is the only test possible. However, we recommend that i the licensee further investigate some alternate test method to full stroke .

exercise these valves at least once each refueling outage.

j 13.3 Category A/E Valves .

i 13.3.1 Relief Request. The licensee has requested specific relief from exercising Category A/E valve 2-51-47, accumulator make-up isolation, ,

in accordance with the requirements of Section XI.

13.3.1.1 Code Requirement. Refer to Appendix A.

13.3.1.2 Licensee's Basis for Requesting Relief. This i*s a

! manual valve and wilt iiot be exercised because it is in its accident posi-

! tion (closed).

r 13.3.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/E valve 2-51-47 f rom the exercising requirements of Section XI. This valve is in its safety-related position and is not required to open or close to miti-gate the consequences of an accident or safely shut down the plant. There-fore, the operability of this valve is inconsequential with regards to the safety function which it performs. We conclude that the quarterly stroke and stroke time measurements are meaningless for a manual, passive valve.

13.3.2 Relief Request. The licensee has requested specific relief from exercising category A/E valves MOV-2836, MOV-2869A and 2869B, high -

! 30

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

head safety injection off charging header, in accordance with the require-ments of Section XI and proposed to exercise these valves during cold shut-

- down when the charging pumps are secured and at refueling outages.

13.3.2.1 Licensee's Basis for Requesting Relief. These normally closed valves are directly attached to the charging pump discharge header.

During operation or cc!d shutdown the charging system must be in operation.

If these valves were oper.ed during these periods, uncontrolled flow to the reactor coolant system may cause overpressurization. As an alternate, these valves shall be cycled at refueling outages and at cold shutdown when the charging pumps can be secured.

13.3.2.2 Evaltation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/E valves MOV-2836, MOV-2869A and 28698 from the exercising requirements of Sec-tion XI. The licensee has demonstrated that the charging pumps are required to be operating when the reactor coolant pumps are operating. The .

- licensee has demonstrated that opening these valves with the charging pumps running would allow uncontrolled flow to the re6ctor coolant system and cause a loss of pressurizer level or reactor coolant system overpressuriza-tion. We conclude that exercising these valve during cold shutdown when the charging pumps are secured and during refueling outages should demon-strate proper valve operability.

13.3.3 Relief Request. The licensee has requested specific relief from exercising Category A/E valves MOV-2890A and 28908, LHSI to hot legs, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling outages.

13.3.3.1 Code Requirement. Refer to Appendix A.

13.3.3.2 Licensee's Basis for Requesting Relief. These valves are in their required safety position with power to their operators removed during power operation. To exercise these valves would require leakage testing as per Technical Specification 4.4.6.2.2. The leakage testing would disturb the downstream check valve which would require a containment entry to leak test this valve. As an alternative these valves will be exercised during refueling outages.  ;

i 13.3.3.3 Evaluation. We agree with the licensee's basis and, {

therefore, feel that relief should be granted for Catego.y A/E valves MOV-2890A and 2890B from the exercising requirements of Section XI. The licensee has demc.istrated that these valves are in their intended safety position and are not required to aperate to mitigate the consequences o' an accident or safely shut down the plant. Exercising these valies would disturb the downstream check valve and require a containment entry to 1s'k l test this valve per the Technical Specifications. Because the containment l is not always accessible during cold shutdown, this would delay plant  ;

startup. We conclude that the licensee's proposed alternate testing of <

exercising these valves during refueling outages should demonstrate proper j valve operability. ,

i l

31

.I

13.4 Category C Valves-13.4.1 Relief Request. The licensee has requested specific relief

• from exercising Category C valves 2-51-1 and 2-SI-21, low head safety i:.jection pump check valves from containment sump, in accordance with the requirements of Section XI and p-oposed to manually exercise these valves ,

at refueling outages.

' .4.1.1 Code Requirem_ent. Refer to Appendix A.

13.4.1.2 Licensee's Basis for Requesting Relid. These normally closed check valves cannot be exercised during plant operation or cold shutdown. No connections exist downstream of the check valve to input flow or pressure which could promote movement of the disc away from the seat. A test connection is required between the isolation valve and 1ae check valvD but cannot be installed. The isolation valve and check valve are butt welded together with no spool piece between them to provide a place for the test connection. As an alternate test, the check valve bonnet shall be removed at refueling outages and the disc shall be exercise i trachanically to verify free movement without binding.

13.4.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 2-51-1 and 2-S1-21. The licensee has demonstrated that no test connections exist to open the valves with a test medium without using flow from the contain-ment sump. We conclude that the proposed alternate testing method of manual exercising at re'ueling outages should demonstrate proper valve operability. .

13.4.2 Relief Request. The licensee has requestea specific relief f rom exercising Category C valves 2-S1-9 and 37, LHSI pump discharge check

• valves, and 2-SI-19, LHSI check valve ' rom refueling water storage tank, in accordance with the requirements of Section XI and proposed to exercise them during refueling outages.

13.4.2.1 Code Requirement. Refer to Appendix A.

13.4.2.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation because the discharge pressure of the low head S.I. pumps cannot overcome RCS pressure. These valves will be exercised during refueling outages when the reactor vessel head is removed to provide enougn volume to accomodate the large flow rate. 2-51-19 will be partially stroked during the monthly pump test.

13.4.2.3 E,aluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 2-S1-9, 32, and 19 from the exercising requirements of Section XI. The licensee has demonstrated that the low head safety injection pump cannot overcome operating RCS pressure. During cold shutdown, the LHSI pumps cannot achieve design flow because the RCS pressure is greater than design accident pres-sure. We conclude that partial stroke exercising these valves quarterly on nump recirculation and full stroke exercising these valves during refueling outages, with the vessel head removed to provide minimum back pressure anJ ,

permit _ design flow, should demonstrate proper valve operability.

I 32

13.4.3 Relief Request. The licensee has requested specific relief f ror exercising Catt;ory C valves 2-51-90, 98, and 104, high head safety injection to cold i w s, and 2-S1-113, lif., and 125, hot leg safety injec-tlon admission checA valves, in accordance with the requirements of Sec-tion XI and proposed to exercise them during refueling outages. ,

13.4.3.1 Code Requirement. Refer to Appendix A.

13.4.3.2 Qcensee's Basis for Requesting Relief. The only way to verify that these norma'ly closed check valves open is by initiating flow, using the charging pumps, into the reactor coolant system hot and -

cold legs. If charging flow was directed to the reactor coolant system in this manner it Lould cause overpresseization durinq cold shutdown or pro-vide a loss in charging flow control during operation. As an alternate, these check valves shall be exercised open during refueling outages.

13.4.3.3 Evaluation. We agree with t e licensee's basis and, therefore, feel that relief should te granted for Category A/C # as 2-SI-90, 98, 104, 113, 118, and 125 from the exercising require ents of -

Section XI. The licensee has demonstrated that exercising these valves during power operation would cause a loss of charging flow control and

• thermal shock to the iniection nozzles and possible nozzle damage.

Also, during cold shutdown, a low temperature-ove. pressurization acci-I dent could occur while exercising these valves. We conclude that full stroke exercising these valves dt. ring refueling outages, when the vessel head is removed to provide an adequate expansion volume, should demonstrate .

proper valve operability.

13.4.4 Relief Request. The licensee has requested specific relief from exercising Category C valves 2-S1-112,117, and 124,, low head safety injection to hot legs, in accordance with the requirarnents of Section XI and proposed to exercise these valves during refueli: outages. l 13.4.4.1 Code Requirement. Refer to App A.

13.4.4.2 Licensee's Basis for Requestine c 'ef. The only way to verify that these normally closed check valves co.- open is by initiating flow, using the low head safety injection pumps, :..M the reactor coolant system hot and cold legs. During operation or cold .autdown, reacter cool-ant system pressure will be higher than the low head pump discharge pres-sure precluding flow into the vessel. As an alternate, these valves shall be exercised open at refueling outages.  ;

13.4.4.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 2-S1-112, 117, and 124 from the exerci g requirements of Section XI. The licensee has demonstrated that the Le pumps cannot overcome operating RCS I

. p ressure. Also, during cold shutdown, RCS pressure is greater than design accident pressure and the LHS1 pumps cannot achieve design flow through these valves. We conclude that full stroke exercising these valves during

. refueling outages, when the vessel Sead is removed and the RCS has minimum ,

back pressure, should demonstrate proper valve cperability. ,

33

. 1

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14. Service Water 14.1 Category A/C Valves ,

14.1.1 Relief Request. The licensee has requested specific relief

! from exercising Category A/C valves 2-SW-74, 84, 94, and 104, recirculation ,

spray heat exchanger inlet centainment isolation check valves, in accordance with the requiremer ts of Section XI and prcposed to exercise these valves during refueling outages.

Code Requirement. Refer to Appendix A.

14.1.1.1 1 14.1.1.2 Licensee's Basis for Requesting Relief. A commitment j has been made to the ACRd prohibiting the introduction of service water into the recirculation spray heat exchangers when not in use. These heat '

exchangers are maintained in a s*andby condition filled with primary grade makeup water. Exercising these valves will be done at refueling outages when containme t access is possible and the heat exchangers can be dr.ained and refilled with primary grade makeup water.

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

! 2-SW-74, 84, 94, and 104 from the exercising requirements of Section XI.

i The licensee has demonstrated that, because of a commitment to the ACRS to keep service water out of the heat exchangers when not in use, these valves 6+

1 cannot be operated during power operation or cold shutdown because contain-

! ment access is required to drain the hcat exchangers. We conclude that the j licensee's proposed alternate testing during refueling outages should '

demonstrate proper valve operability.

14.2 Category B Valves i

j 14.2.1 Relief Request. The licensed has requesteo specific relief l from exercising Category H valves MOV-SW-201A, B, C, and D, and MOV-SW-205A, i B, C, and D, recirculation spray heat exchanger isolation valves, in accor-dance with the requirements of Section XI and proposed to exercise these i valves turing refueling outages.

14.2.1.1 Code Requirement. Refer to Appendix A.

I 14.2.1.2 Licensee's Basis for Requesting Relief. A commitment has been made to the ACRS prohibiting the introduction of service water

into the recirculation spray heat exchangers when not in use. These heat exchangers are maintained in a standby condition filled with primary grade i makeup water. Exercising these valves will be done at refueling outages when containment access is possible and the heat exchangers can be drained and refilled with primary grade makeup water.

14.2.1.3 Evaluation. We agree with the licensee's basis and, .

i therefore, feel that relief should be granted for Category B valves 4 MOV-SW-201A, B, C, and D and MOV-SW-205A, B, C, and D from the exercising requirements of Section XI. The licensee has demonstrated that, because of .

a Commitment to the ACRS to keep service water out of the heat exchangers 34

when not in use, these valves cannot be operated during power operation or i cold shutdown because containment access is required to drain the heat

1. 'exchangers. We conclude that the licensee's proposed alternate testing during refueling outages should demonstrate proper valve operability.

. 14.3 Category C Valves 14.3.1 Relief Request. 7he licensee has requested specific relief f rom exercising Category C vahes 2-SW-68 and 2-SW-70, ser vice water to recirculation spray heat exchangers check valves, in accordance with the requirements of Section XI and proposed to exercise these. valves during refueling outages.

]

14.3.1.1 Code Requirement. Refer to Appendix A.

l i

14.3.1.2 Licensre's Basis for Requesting Relief. A commitment has been made to the ACRS prohibiting the introduction of service water into the recirculation spray heat exchangers when not in use. These heat exchangers are maintained in a standby condition filled with primary grade makeup water. Exercising these valves will be done at refueling outages when containment access is possible and the heat exchangers can be drained 4

and refilled with primary grade makeup water.

14.3.1.3 Evaluation. We agree with the licensee's basis and, i therefore, feel that relier should be granted for Category C valves 2-SW-68 and 2-SW-70 f rom the exercising requirements of Section XI. The licensee has demonstrated that, because of a commitment to the ACRS to keep service water out of the heat exchangers when not in use, these valves cannot be operated during power operation or cold shutdown, because containment access is required to drain the heat exchangers. We conclude that the. licensee's proposed alternate testing during refueling outages should demonstrate proper valve operability.

15. Steam Generator Wet Layup 15.1 Category A/E Valves 15.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/E valves 2-WT-437, 438, 439, 446, 447, and 448, steam generator wet layup isolations, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling outages.

15.1.1.1 Code Requirement.. Refer to Appendix A.

15.1.1.2 Licensee's Basis for Requesting Relief. These are manual valves and they are in their intended safety position (closed).

They will be exercised during refueling when the wet layup system is placed

, in operation.

i 15.1.l.3 Evaluation. We agree with the licensee's basis and,

! . therefore, feel relief should be granted for Category A/E valves, 2-WT-437, 438, 439, 446, 447, and 418 from the requirements of Section XI. These l l 1 2

35 l ________ . .

valves are in their safety-related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with

• regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for manual, passive valves. ,

16. Refueling Purification System 16.1 Category A/E Valves 16.1.1 Relief Request. Tne licensee has requested specific relief from exercising Category A/E valves 1-RP-50, 1-RP-84, 2-RP-6, and 2-RP-7, refueling purification system containment . isolation valves, in accordance with the requirements of Section XI.

16.1.1.1 Coje Requirement. Refer to Appendix A.

16.1.1.2 Licensee's Basis for Requesting Relief. These are manual valves and will not be exercised because they are in their accident  ;

position (closed).

16.1.1.3 Evaluation. We agree with tne licensee's basis and, therefore, feel relief should be granted for Category A/E valves 1-RP-50, 1-RP-84, 2-RP-6, and 2-RP-7 from the rcquirements of Section XI. These valves are in their safety-related position and are not required to cpen or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with .

regard to the safety function which they per'orm. ne conclude that the quarterly stroke and stroke time measurements are meaningless for manual, passive valves. .

l

17. Residual Heat Removal

) 17.1 Category A/E Valves 17.1.1 Relief Request. The licensee has requested specific relief l

l from exercising Category A/E valves 2-RH-37 and 2-RH-38, RnR containment j isolation valves, in accordance with the requirements of Section XI.

i 7.1.1.1 Code Requirement. Refer to Appendix A.

l

. 1/.l.1.2 Licensee's Basis for Requesting Relief. These are

! manual valves and *tiTi not be exercised heceuse they are in their accident position (closed).

17.1.1.3 Evaluaticn. We agree with the licensae's basis and, j therefore, feel that relief should be granted for Catego"y A/E valves i 2-RH-37 and 2-RH-38 from the exercising requirements of Section XI. These

valves are in their safety-related position and are not required to open or i

close to mitigate the consequences of an accident or safaly shut down the plant. Therefore, the operability of these valves is inconsequential with ~

regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for manual, i passive valves.

36

, - . , - . . . . , _ - , . - _ . . , - . - , . - - , -.a. _

IV. APPENDIX A

1. Code Requirement--Valves Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code j (which discussed full stroke and partial stroke requirements). requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). IWV-3520(a) (which discusses full stroke and partial stroke requirements) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above exceptions, the Code permits the  ;

valves tt be tested at cold shutdown where:

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

2. It is not practical to observe the operation of the valves (with failsafe ar.tuators) upon loss of actuator power.

Sub3ection IWV-3410(c) requires all Category A and B power-operated

- valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time.

2. Code R+;quirements--Pumps An inservice test shall be condacted on all safety-related pumps, nominally once each month during normal plant operation. Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

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37 1

V. ATTACHMENT I-Tne following are Category A, B and C valves that meet the exercising

• requirements of the ASME Code,Section XI, and are not full stroke exer-cised every three n:onths during plant operation. These valves are specifi-cally~ identified by the owner and are full stroke exercised during cold

• shutdowns and refueling outages. EC&G has reviewed all valves in this

attachment and agrees with the licensee that testing these valves during power operation is not possible, due-to the valve type ard location, system design, or because this action would place the plant in an unsafe condition.

We feel that these valves should not be exercised during power operation.

These valves are listed below and grouped according to the system in whic'.i they are located.

1. Component Cooling 1.1 Catego_ry A Valves J Category A valves, TV-CC-200A, B, C and TV-CC-205-A, B, and C, con-tainment air recirculation coils isolation valves, cannot be exercised during power operation. Closing of these valves during power operations would seriously impair the heat removal capability of the containment '

i ventilation system. These valves are vital for continued power

] operations. As an alternative, they will be cycled each cold shutdown.

! 2. Chemical and Volume Control 2.1 Category A Valves

! Category A valves, HCV-2200A, E, and C, hand control letdown valves, -

cannot be exercised during power operatlon. These valves cannot be exer-

cised when the charging and letdown systems are in operation due to the

high risk of overpressurization of the 7 actor coolant system. They will I be exercised at cold shutdown and refueling outages.

2.2 Cacegory B Valves Category B valves MOV-21158, C, D, and E, charging pump suction isola-tion valves, cannot be exercised during power operation. Exercising these valves during power operation would require the charging pump suctions to ba aligned with the refueling water storage tank. This would cause a sud-den increase in RCS boron inventory. They will be exercised during cold shutdown when the RCS is borated to shutdown conditions.

3 Category B valve MOV-2350, emergency boration valve, cannot be exercised during power operation. Exercising this valve during power operation could cause a sudden increase in RCS boron inventory. It shall i be exercised at cold shutdown when the RCS is already borated to shutdown conditions.

38 i ..

_ -. . - _ ._. . . = _ __

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2.5 Category C Valves

. Category C valves 2-CH-157 and 159, emergency boration path check '

> valves, cannot be exercised during power operation. Exercising these a'

valves during power operation could cause a sudden increase in RCS boron -

. inventory. They shall be exercised at cold shutdown when the RCS is ,

already borated to shutdown conditions.

i

3. Feedwater

. 3.1 Category B Valves Category B valves, HCV-FW-200C and MOV-FW-200B, and D, auxiliary feed-water pump admission valves to steam generators, canrot be exercised during power operation. These valves are in the position required to fulfill their function. Exercising these valves will not improve their operational read-4 iness. Exercising these valves may actually decrease system reliability if i they fail in a nonconservative position. As an alte.'nate, they will be exercised at cold snutdown and refueling outages.

l

4. Air Cooling and Purging System Reactor Containment i 4.1 Category A Valves

) Category A valves MOV-HV-200A, B, C, D and MOV-HV-201 and 202, conti in-ment purge and exhaust, cannot be exercised during power operation. Opering

' these valves during power operation would break containment vacuum and vio-late containment integrity. These valves shall be exercised each cold shut- '

down, but not more than once every 92 days.

5. Main Steam 5.1 Category B Valves Category B valves TV-MS-201 A, B, and C, main steam trip isolation >

valves, cannot be exercised during power operation. Closure of these 5 valves during power operation will result in a reactor trip. As an alter-native, they will be cycled each cold shutdown, but not more than once every 92 days.  !

s 5.2 Category C Valves I

l Category C valves, NRV-MS-201 A, B, and C, main steam non-return valves, cannot be exercised during power operation. Closure of these valves during

, power operation will result in a reactor trip. As an alternative, they will be cycled each cold chutdown, but not more than once every 92 days. l

! Category C valves 2-MS-19, 58, and 96, main steam cieck valves, cannot

. Le exercised during power operation. 2-MS-19, 58, and F6 Tre located in a high temperature area that would be hazardous to enter during power opera-tion. These valves will be exercised closed during cold shutdown and

. refueling outages. 3 l

39

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

6. Recirculation Spray 6.1 Category B Valves 4

Category B valves MGV-RS-255A, B and MOV-RS-256A, B, outside recircu-lation spray pump suction and discharge, cannot be exercised during power

~

operation. These valves are in the position required to fulfill their func-tion. Exercising these valves will not improve their operational readiness.

Exercising these valves may actually decrease system reliability if they fail in a nonconservative position. As an alternate, they will be exercised at cold shutdown and refueling outages.

7. Residual Heat Removal 7.1 Categorv A Valves Cate<Jory A valves MOV-2700, 2701, 2720A and B, RHR system isolation valves, connot be exercised during power operation. Operation of RHR sys-tem valves during power operations would subject the RHR system to full RCS pressure. Valves in the RHd system will be exercised each time the RHR

system is put into operation during the cooldown and shutdown of 'he reac-tor coolant system. These valves will be leak tested in accordance with Technical Specifications.

7.2 Category C Valves Category C valves 2-RH-7 and 2-RH-15, RHR pump discharge check valves, cannot be exercised during power operation. Operation cf RHR system valves -

during power operations would subject the RHR system to full RCS pressure.

Valves in the RHR system will be exercised each time the RHR system is put into operation during the cooldown and shutdown of the reactor coolant -

system. These valves will be leak tested in accordance with Technical Specifications.

8. Safety Injection 8.1 Category A Valve Category A valve HCV-2936, accumulator tank purge control valve, can-not be exercised during power operation. HCV-2936 is in its safety posi-tion and will be exercised during cold shutdown and refueling outages.

8.2 Category B Valves Category B valve MOV-2863B, LHSI to charging pump suction, cannot be exercised during power operation. Exercising this valve during power operation would require the charging pump suctions to be aligned with the refueling water storage tank. This would cause a sudden increase in RCS boron inventory. It will be exercised during cold shutdown when the RCS is '

borated to shutdown conditions.

Category B valves MOV-2864A and 28648, LHSI pump cold leg discharge ~

stop valves, cannot be exercised during operation. These valves are in the 40 i

position required to fulfill their function. Exercising these valves will not improve their operational readiness. Exercising these valves may actually decrease system reliability if they fail in a nonconservative position. As an_ alternate, they will be exercised at cold shutuown and refueling outages.

Category 8 Valves MOV-2865A, B, and C, accumulator outlet valves, can-not be opera *ed during cold shutdown. These normally open valves are in the required position for an accident and are required by Technical Speci-fications to remain open during power operations. They are closed in the normal process of shutdown to cold conditions and reopened during subsequent heat up.

8.3 Category C Valve Category C valve 2-51-18, refueling water storage tank to charging pump suction check i lve, cannot be exercised during power operation.

Exercising this valve during operation could cause a sudden increase in RCS boron inventory. It shall be exercised at cold shutdown when the RCS is already borated to shutdown conditions.

Service Water 9.

9.1 Category A and B Valves i

Category B valves MOV-SW-202A, B and 206A, B, Unit 2 recirculation spray heat exchangers cross connect valves, and Category A valves MOV-SW-203A, B, C, D and 204A, B, C, D, recirculation spray heat exchanger containment isolation valves, cannot be exercised during power operation.

These valves are in the position required to fulfill their function. Exer-cising these valves will not improve their operational readiness. Exercis-ing these valves may actually decrease system reliability if they fail in a nonconservative position. As an alternate, they will be exercised at cold shutdown and refueling outages.

I a

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4 41 1

VI. ATTACHMENT II

1. The following item concerns valves that are never full stroke exercitad- *

• or that have a testing frequency greater than each refueling outage,

a. Valve Testing Program (1) 13.2.4 9

e-l 42

VII. ATTACHMENT Ill The following P& ids were used during the course.of this review:

. Air Cooling and Purging Sys. Reacto* Containment FB-7C Main Steam FM-70A and B Feedwater FM-74A Service Water FM-78A, B and C Component Cooling 12050-FM-79A and B ll715-FM-79A Compressed Air FM-82B Sampling System FM-89A and B Vent and Drain FM-90A and B Containment Quench & Recirculation Spray Subsystems FM-91A and B Containment Vacuum & Leakage Monitor aystem FM-92A Reactor Coolant System FM-938 Residual Heat Removal System FM-94A Chemical and Volume Control System FM-95A, B anri C Safety Injection System FM-96A and B Steam Generator Blowdown FM-98A Steam Generator Wet Layup ll715-FM-38A Refueling Purification System ll715-FM-88A O

e I

l 43

VIII. ATTACHMENT IV I

The following items were discussed with David Heacock of North Anna l Unit 2 and may appear as differences between this report and their IST program. The Licensee has agreed to send revised pages of their report to '

reflect the below-listed changes.

l. 2-CC-37 will be exercised every 3 months.

2. HCV-2200A, B, ard C will be exercised at cold shutdown.

1 3. Relief request 9 was revised.

l f 4. 1-CH-113 is changed to 1-CH-133.

)

l S.  ?-CV-4 will have relief request 30 instead of 38.

6. HCV-FW-200C will be exercised at cold shutdown.

7 MOV-FW-200B and D will be exercised at cold shutdown.

8. 2-IA-250 will be categorized A/C and exercised at refueling.

Relief request 28 will apply to this valva.

i 9. NRV-MS-201A, B, and C, will be categorized C instead of E.

2

10. MOV-RS-255A, B, and MOV-RS-256A, B will be exercised at cold ,

shutdown.

l 11. 2-RS-103 and 118 will be categorized C instea.1 of B/C.

! 12. MOV-SW-202A, B and 206A, B will be exercised at cold shutdown.

Relief request 10 will apply to these valves.

13. MOV-SW-203A, B, C, 0 and 204A, B, C, D are exercised at cold shutdown.

14. 2-WT-437, 438, 439, 446, 447, and 446 are categorized A/E instead of A.

15. 1-RP-50, 84 and 2-RP-6, 7 will be included in the program as i Category A/E valves. Relief request 30 will apply to these valves.

I

16. Relief Request 12 will also apply to 2-FW-150.

17. Relief Request 34 will change 2-MS-98 to 2-MS-96.

18. Charging Pumps 2-CH-P-lA, IB, and 1C AP will be measured monthly.

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d

19. Boric acid transfer pumps 1-CH-P-2C and 20 AP will be calcu-lated monthly.

20. Screenwash pumps 2-CW-P-2A and 2-SW-P-2 will be deleted from the program, not safety related.

21. Auxiliary feed pumps 2-FW-P-2, 2-FW-P-3A, and 3B-Q will be ,

measured monthly.

22. Residual heat removal pumps 2-RH-P-1A and 18 will be deleted from the program, not safety related.

23. Low head safety injection pumps 2-SI-P-1A and 1B Q will be mea-sured monthly. Note I will apply to AP.

24. Service water pumps, 2-SW-P-1 A,1B, and 4 AP and Q will be mea-sured monthly.

25. iiCV-2200A, B, and C will be exercised at cold shutdown. Relief Request 9 will apply to these valves.

26. MOV-2267A and B, 2269A and b, 2270A and B, 2286A, B, and C, 2287A, B, and C will be exercised at cold shutdown when the charging pumps are secured and at refueling outages. Relief.

Request 38 will apply to these valves.

27. MOV-2267C and 0 will be exercised at refueling outages. Relief

- Request 39 will apply to these valves.

28. MOV-2836 and 2869A and B will be exercised at refueling outages.

Relief Request 18 was revised and will apply to these valves.

29. MOV-2890A, B. C, and D will be exercised at refueling outages.

Relief Request 20 was revised and will aprly to these valves.

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• 1 45