ML20056C204

Pump & Valve IST Program,North Anna Power Station,Units 1 & 2, TER

ML20056C204
Person / Time
Site:	North Anna
Issue date:	04/30/1993
From:	Cain R EG&G IDAHO, INC.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20056C205	List: ML20056C204 ML20057C039 ML20057C040
References
CON-FIN-A-6812 EGG-RTAP-10520, TAC-M77125, TAC-M77126, NUDOCS 9305050175
Download: ML20056C204 (70)

Text

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ENCLOSURE 2 l 4  :

EGG-RTAP-10520 h

TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM NORTH ANNA POWER STATION, UNITS ONE AND TWO j Docket Nos. 50-338 & 50-339 l

R. S. Cain .

C. B. Ransom

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i Published April 1993 i

Idaho National Engineering Lab EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 4

Prepared for the U.S. Nuclear Regulatory Commission  :

Washington, D.C. 20555 I Under DOE Contract No. DE-AC07-761001570  :

FIN No. A6812 i TAC Nos. M77125 & M771263

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ABSTRACT j This EG&G Idaho, Inc., report presents the results of our. evaluation of ~

the Virginia Electric and Power Company, North Anna Power Station Units One  :

and Two, Inservice Testing Program for pumps and valves whose function is

.4fe ty-rel ated.

PREFACE This report is supplied as part of the " Review of Pump and Valve i Inservice Testing Programs for Operating Reactors (111)" program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear

• Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc.,

Regulatory and Technical Assistance Unit.

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f B&R 920-19-05-02-0 FIN No. A6812 Docket Nos.-50-338 & 50-339  :

TAC Nos. M77125 & M77126 l

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l CONTEN15 ABSTRACT .......................... . . . . ii i

PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii  ;

1. INTRODUrTION ............................ I 1.1 IST Proaram Description ................... I 1.2 IST Reauirements . . . . . . . . . . . . . . . . . . . . . . . 1  ;

1.3 Scope and Limits of the Review . . . . . . . ......... '

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2. PUMP TESTING PROGRAM . . . . . ...... ........ . . . . 3 2.1 General Pump Relief Reauests . . . . . . . . . . . . . . . 3 -

2.1.1 Vibration and Bearina Temperature Measurements . . . 3 2.1.2 Instrument Accuracy . .... .. . . . . . . 5 l 2.2 Emeraency Diesel Generator Fuel Oil Pumps ....... . . 7 2.2.1 Test Duration . ................... 7 2.3 Residual Heat Removal Pumps ................ 7 ,

2.3.1 Test Freauency . ................... 7 -

2.4 Recirculation Spray Pumps .................. 8 2.4.1 Test Freauency . ................... 8 2.5 Outside Recirculation Spray Pumps .............. 10 2.5.1 Test Freauency and Duration ... .. ....... 10 2.6 Service Water Pumps . ........... ..... . 13 2.6.1 Measurement of Test Ouantities . ... . . . . 13 -

2.7 Component Coolina and Service Water ... .. . . 15 2.7.1 Reference Test Values ... . . . ... . . . 15 2.8 Auxiliary Feedwater . . ....... ........... . 17 2.8.1 Test Duration . ............... . . . 17 >

2.9 Boric Acid Transfer Pumps ..... ............. 17 l 2.9.1 Test Freauency and Duration .............. 17 j

3. VALVE TESTING PROGRAM . . . . . ................... 20 3.1 General Valve Relief Reauests .............. . . 20 3.1.1 Stroke Time Measurement ....... .... . . . . 20 3.1.2 Valve Leakaae Rates .... ... .......... - 21 3.1.3 Stroke Time Criteria ~. . . . . . . . . . .... . . 23 3.2 Safety In.iection System ......... .. ... . . . . 23 3.2.1 Cateaory A Valves .... ... . . .... . . . 23 3.2.2 Cateaory A/C Valves ....... .......... 25 3.2.3 Cateaory C Valves .......... ........ 28- i 3.3 Component Coolina Water System . ............... 37 .

3.3.1 Cateaory A/C Valves ................. 37 3.3.2 Cateaory C Valves .................. 40 .

3.4 Reactor Coolant System . . . . . . . ............. 41 3.4.1 Cateaory A/C Valves ............. . . . . 41 3.4.2 Cateaory B Valves ..... . . .s. . . . 42 3.4.3 Cateoory B/C Valves . .. . ...... .. . . . 43 3.5 Chemical and Volume Control ....... . . ... . . . 43 3.5.1 Category A Valves ...... . . . .... . . . . 43 3.5.2 Cateaory A/C and C valves ............. . 44 '

3.6 Instrument Air System . ...... ... . ......... 45 3.6.1 Cateaory A/C Valves ................. 45 3.6.2 Cateaory C Valves .................. 46 3.7 Service Water Systems . ................... 46 i

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3.7.1 Cateaory C Valves .................. .46  !

3.8 Recirculation Soray System . . . ............... 49  ;

3.8.1 - Cateaory A/C Valves ................ 49  ;

3.8.2 Cateaory C Valves .................. 50  ;

3.9 Charoina System ....................... 50  !

3.9.1 Cateaory C Valves . . . . . . . . . . . . . - . . . 50 l 3.10 Vacuum Primina System . . . . . . . ............. 51 l 3.10.1 Cateaory A/C Val ves . . . . . . . . . . . . . . . . . 51 3.11 Main Steam System . . . . . . . . . . . . . . . . . . . . . . 52 3.11.1 Cateoory C Valves . . . . . . . . . ....... 52 3.12 Emeroency Diesel Air Services . . . . . . . . . . . . . . .. 53 3.12.1 Cateaory B and C Valves . . . . . . . . . ..... 53  !

3.13 Control Room Bottled Air .................. 54 5 3.13.1 Cateoory B and C Valves . . . . . . . . . . . . . . . 54 i 3.14 Containment Vacuum System . . . .......... .... 54 3.14.1 Cateaory A Val ve s . . . . . . . . . . . . . . . . . . 54 3.15 Fire Protection System ..... 55

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3.15.1 Cateaory C Valves . . . . . . . . . . . . . . . . . . 55 3.16 Post Accident Hydroaen Removal System . ........... 56 3.16.1 Category A/C Valves . . ..... ......... 56 l 3.17 Fuel Oil Transfer System ................ . 57 3.17.1 Cateaory C Valves . . . . . . . . . . ....... 57 i APPENDIX A ....... ....................... ] l APPENDIX 8 .............................. 1- l t

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TECHNICAL EVALUATION REPORT i

PUMP AND VALVE INSERVICE TESTING PROGRAM VIRGINIA ELECTRIC AND POWER COMPANY  :

NORTH ANNA UNITS ONE AND TWO

1. INTRODUCTION This report provides the results of the technical evaluation of certain #

relief requests from the pump and valve inservice testing (IST) program for North Anna Power Station, Units 1 and 2, which was submitted by the Virginia Electric and Power Company (VEPCO).

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

Appendix A lists program inconsistencies and omissions, and identifies '

needed program changes. -

t Appendix B is a listing of the P& ids used for this review.

1.1 IST Proaram Description VEPCO submitted Revision 6 of the North Anna Power Station, Units 1 and 2, pump and valve IST program with a letter dated June 14, 1990. This program ,

covers the second 120 month IST interval, which began on December 14, 1990, for both units. A revised group of relief requests and supplemental information transmitted by letter dated October 17, 1990, were considered in this report. The relief requests pertain to requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI,1986 Edition, and the Code of Federal Regulations (CFR),

10 CFR 50.55a.

1.2 IST Reouirements 10'CFR 50.55a requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed per the ASME Code,Section XI, Subsections IWP and IWV, except where relief is granted by NRC in accordance with 10 CFR-50.55a(a)(3)(i), (a)(3)(ii), or (f)(6)(i). VEPCO requests relief from the ASME Code testing requirements for specific pumps and valves. Certain of these requests are evaluated in this Technical Evaluation Report (TER) using j the acceptance criteria of the Standard Review Plan, Section 3.9.6, NRC i Generic Letter No. 89-04 (GL 89-04), " Guidance on Developing Acceptable Inservice Testing Programs," and 10 CFR 50.55a. Other requests in the .

licensee's IST program that are not evaluated in this TER, may be granted by provisions of GL 89-04.  ;

1.3 Scope and Limits of the Review The scope of the detailed review was limited to the relief requests and  :

cold shutdown justifications submitted with the licensee's~IST program. Other '

portions of the program, such as general discussions, pump and valve test tables, etc., were cursorily reviewed. Endorsement of these aspects of the program by the reviewer is not stated.or implied. Any deviation from the Code 1

' i test method, frequency, or other requirement should be identified in_ the IST  !

- program and submitted according to 10 CFR 50,55a for. review and approval.by NRC.

The evaluations'in this TER are applicable only to the components or groups of components identified by the submitted requests. These evaluations-may not be extended to apply to similar components that are not identified tor t the request at this or any other. comparable facility without separate review. ,

Further, the evaluations and recommendations are limited to the requirement (s) and/or function (s) explicitly discussed in the applicable TER section. For '

example, the results of an evaluation of a' request involving testing of the containment isolation function of a valve cannot be extended to allow the test .

to satisfy a requirement to verify the valve's pressure isolation function,  :

unless that extension is explicitly stated.

VEPC0 provided several cold shutdown justifications for exercising  ;

Category A, B, and C valves during cold shutdowns and refueling outages  ;

instead of quarterly. Valves identified to be tested during cold shutdowns i need not be tested if testing was performed within three months of the cold i shutdown. These justifications were reviewed and found to be acceptable i except as noted in Appendix A. j l

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2. PUMP TESTING PROGRAM l The following relief requests were evaluated against the requirements of the 1986 Edition of the ASME Code,Section XI,10 CFR 50.55a, and applicable NRC positions and guidelines. A summary is presented for each relief. request  ;

followed by the licensee's . basis for relief and the evaluation with the i reviewer's recommendations. The evaluations are grouped according to topic or system. Each relief request evaluation is applicable to both units unless specified otherwise. The pump identification numbers will have a prefix of  ;

"l " for unit one, "2 " for unit two, and "l(2) " for both units.  ;

2.1 General Pumn Relief Reouests 2.1.1 Vibration and Bearina Temperature Measurements 2.1.1.1 Relief Reauest. P-1 requests relief from measuring annual bearing temperatures and vibration displacement, in mils, for all pumps in the -

IST program in accordance with Section XI, Paragraphs IWP-3100 and -3300 The  ;

licensee proposes to measure vibration velocity, in inches per second, and not to measure bearing temperature at all. Furthermore, the licensee wants to 1 apply a minimum reference value of 0.05 in/sec to all velocity measurements '

and include the emergency diesel generator fuel oil pumps which are positive  ;

displacement screw type pumps not mentioned in ANSI /ASME OM-6 1988.

2.1.1.1.1 Licensee's Basis for Reouestino Relief--Pump vibration and bearing temperature measurements are used to detect changes in the -

mechanical characteristics of a pump. Regular testing should detect i developing problems, thus repairs can be initiated prior to a pump becoming '

inoperable. The ASME Section XI minimum standards require measurements of the vibration amplitude (displacement) in mils every three months and bearing  :

temperatures once per year.

Our proposed program is based on vibration readings in velocity units rather  :

than vibration amplitude in mils displacement. This technique is an industry accepted method which is more sensitive to small changes that are indicative j of develop.ing mechanical problems and hence more meaningful. Velocity t measurements detect not only high amplitude vibrations that indicate a major  :

mechanical problem, but also the equally harmful low amplitude high frequency i vibrations due to misalignment in balance, or bearing wear that usually go undetected by simple displacement measurements.

In addition, these readings go far beyond the capabilities of a bearing '

temperature monitoring program. A bearing will be seriously degraded prior to the detection of increased heat at the bearing housing. Quarterly vibration velocity readings should achieve a much higher probability of detecting developing problems than the once per year reading of bearing temperatures. -

Bearing temperature tests present problems which include the following:

1. Certain systems have no recirculation test loops and a limited ,

source of water. An enforced thirty minute run time would deplete the source.

2. The lubrication fluid for some pumps is taken from the process water, which can change temperature depending on ambient conditions. Data trending for these cases is not meaningful.

The small probability of detection of a bearing failure by temperature measurement does not justify the additional pump operating time required to obtain the measurements. In addition, it is impractical to measure bearing 3

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t temperatures on many pumps. Therefore, the detection of possible bearing

- failure by a yearly temperature measurement is extremely unlikely.  ;

Alternate Testino: Pump vibratio_n measurements will be taken in vibration velocity (in/sec).. The evaluation of the readings will be per the attached t table. The ranges of test parameters given in the attached table were taken i from ANSI /ASME OM Part 6, An American National Standard In-Service Testing of Pumps.

Ranoes of Test Parameters (1) f i

ACCEPT- REQUIRED PUMP PUMP TEST ABLE ALERT ACTION  ;

TYPE SPEED PARAMETER RANGE RANGE RANGE '

Centri- >600 rpm Vv <2.5 Vr >2.5 Vr >6 Vr ,

fugal, (2) (4) to 6Vr but not Vertical but not >0.70 line shaft >0.325 in/sec  !

and in/sec  :

positive i displace-ment screw  !

pumps (3) ,

(1) Vr is the vibration reference value in the selected units  !

Vv is vibration velocity measured peak, unfiltered

-l (2) There are no pumps in this program that operate below 600 rpm ,

(3) OM-6 does not address positive displacement screw pumps. The emergency diesel generator fuel oil pumps are of this type and will be subject to the '

OM-6 criteria. ,

Small values for Vr will produce--small acceptable ranges for pump (4) operation. Based on a small acceptable range, an adequately and  :

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smoothly running pump could be subject to corrective action. To i avoid this situation, a minimum value for Vr of 0.05 in/sec has '

been established for velocity measurements. Pumps with a measured reference value below 0.05 in/sec shall have subsequent test results compared to an acceptable range based on 0.05 in/sec. '

t 2.1.1.1.2 Evaluation--Pump bearing degradation results in increased bearing noise at frequencies 5 to 100 times the rotational frequency  !

of the pump. These high frequency bearing noises would not produce a significant increase in pump vibration displacement measurements and could go >

undetected. However, the high frequency noises would result in relatively i large changes in pump vibration velocity measurements. This could be detected.

and permit corrective action prior to catastrophic failure of the bearing. .

Because of the high frequencies of the vibrations associated'with the pump l bearings, vibration velocity measurements are generally much better than  !

vibration displacement measurements in monitoring the mechanical condition of  ;

pumps and detecting pump bearing degradation. ]

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Annual pump bearing temperatures provide limited information on the mechanical condition of the pump. Several factors affect the temperature measured at the bearing housing. These factors, such as, the temperature of the working fluid, ambient room temperature, and lubrication temperature, could mask a change in the bearing condition (short of catastrophic failure).

Furthermore, many pumps have a limited capacity source which makes it impractical to run the pumps long enough for bearing temperatures to stabilize.

The use of vibration velocity can provide a great deal of information about pump mechanical condition that could not be obtained using' pump '

vibration displacement readings or by measuring the temperature of the bearing housing.

An alternative acceptable to the staff is that relief may be granted from the annual pump bearing temperature measurement and the quarterly vibration displacement measurement requirements of the Code provided the licensee performs quarterly vibration velocity testing on the affected pumps in accordance with the guidelines of ANSI /ASME OM-6. The licensee has included a positive displacement, screw type, pump in the program. The staff

. finds this addition acceptable so long as the vibration velocity measurements l are taken at an appropriate position on the pump so as to detect minute changes in vibration velocity. The licensee has proposed assigning a minimum reference value of 0.05 in/sec. This value of vibration velocity, with speeds  !

greater than 600 rpm, is indicative of a pump in excellent operating j condition. Values of pump vibration velocity which are 2.5 times higher than this reference value is representative of a pump which is still in good operating condition. Values of pump vibration velocity which are 6 times higher than this reference value is representative of significant degradation although the pump may still be in fair operating condition. . Therefore, a vibration velocity value of 0.05 in/sec is a reasonable reference value which would provide indication of significant degradation, while preventing excessive testing and unnecessary maintenance on pumps which are in good operating condition.

Based on the determination that the licensee's testing is essentially equivalent to the Code and provides an acceptable level of quality and safety, the proposed alternative is authorized pursuant to 550.55a $(a)(3)(i).

2.1.2 Instrument Accuracy 2.1.2.1 Relief Reauest. P-13 requests relief from the instrument accuracy requirements of Section XI, Paragraph IWP-4110, for the pumps listed below. The licensee proposes to use flow accuracy of 2.5% or 2.69%, discharge pressure accuracy of 2.69%, and a differential pressure accuracy 2.8%.

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Instrument Component Parameter Accuracy  ;

FI-ll22/2122 1(2)-CH-P-1A,B,C Flow 2.50%

FI-ll24/2124 1(2)-CH-P-1A,B,C Flow 2.50%

FI-1127/2127- 1(2)-CH-P-1A,B,C Flow 2.50% i FI-1130/2130 1(2)-CH-P-1A,B,C _ Flow 2.50%_  :

FI-CC-100A,-200A 1(2)-CC-P-1A Flow 2.69%-  :

FI-CC-1008,-200B 1(2)-CC-P-1B Flow 2.69% l FI-SW-111A 1(2)-SW-P-1A Flow 2.69%  ;

FI-SW-Il0B 1(2)-SW-P-1B Flow 2.69%

PI-SW-101A,-201A 1(2)-SW-P-1A Discharge Press 2.69%  !

PI-SW-101B,-201B 1(2)-SW-P-1B Discharge Press 2.69%  ;

PI-SW-110,-210 1(2)-SW-P-4 Discharge Press 2.69%

2.1.2.1.1 Licensee's Basis for Reauestino Relief--Instruments used to measure certain pump parameters receive their signal at the equipment, which is transmitted to a process rack and then to a control room indicator. {

The sensor and rack accuracy can be affected by drift, temperature, and I calibration accuracy. The indicator has a limit of accuracy. The total loop  :

accuracy is found by the root sum of the squares. The only variables in this e formula are the sensor calibration accuracy and the indicator accuracy.

Installing new sensors and indicators to reduce the accuracy by one percent is l not warranted by the increase in safety obtained. ~

Discharge pressure gauges were purchased with 2% tolerance.

Considering the 2% tolerance of the inlet pressure gauges, the RMS accuracy for differential pressure is 2.8%. Therefore, the differential pressure calculations will have an accuracy equal to or less than 2.8%. See the PUMP f INSERVICE TEST TABLE for pumps with differential pressure calculations.

Alternate Testina: None 2.1.2.1.2 Evaluation--The licensee proposes a loop accuracy limit i of 2.50% or 2.69% for flow, 2.69% for discharge pressure, and 2.8% for [

differential pressure. The Code requirement for flow, discharge pressure, and i differential pressure is 2%. The 2% accuracy limit placed on the flow rate  !

instrumentation loop ensures that the diagnosis of a degrading pump is not  :

masked by inaccurate measurements.  ;

The installation of new sensors and indicators to reduce the accuracy error by 0.8% for differential pressure readings and 0.69% to 0.50% for flow and discharge pressure readings would not significantly impair the licensee's ability to monitor for pump degradation. To meet the Code requirements, the  :

licensee would have to buy and install new sensors and indicators. This would '

be a hardship for the licensee. Obtaining and replacing sensors and '

indicators to accomplish the Code requirements, would not significantly  !

increase plant safety or the licensee's ability to monitor for pump i degradation.  !

Based on the determination that compliance with the Code requirements would result in a hardship or unusual difficulty without a compensating  !

increase in the level of quality and safety, the proposed alternate is '

authorized pursuant to s50.55a 1(a)(3)(ii).  !

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2.2 Emeroency Diesel Generator Fuel Oil Pumps 2.2.1 Test Duration 2.2.1.1 Relief Reauest. P-4 requests relief from the pump run time, for emergency diesel generator fuel oil pumps,1-EG-P-lHA,-lHB,-1JA,&-1JB for unit one and 2-EG-P-2HA,-2HB,-2JA,&-2JB fnr unit two, as required by Section XI, Paragraph IWP-3500(a), respectively. The licensee proposes to obtain measurements when the pump automatically starts on icw day tank level signal.  ;

2.2.1.1.1 Licensee's Basis for Reauestina Relief--The pump operating time is limited due to operational restraints. While the diesels are running, these pumps start automatically when the fuel oil level in the day tank reaches the low level switch, and stop when the level reaches the high level switch. The pump run time can vary depending upon the diesel load and the resulting fuel consumption rate. If the pumps are allowed to run for five minutes prior to measuring the test quantities and the fuel consumption rate is low, not enough time is available to gather all of the required Section XI test data.

Alternate Testina: The measurement of Section XI quantities will begin when the pump automatically starts on a low day tank level signal.

2.2.1.1.2 Evaluation--These positive displacement pumps receive a start signal from the diesel fuel oil day tank low level switch and pump until the shutoff level is reached. Requiring these pumps to run fo the Code required 5 minutes could overflow the diesel fuel oil day tank. The 5 minute run might possibly be achieved if the diesel fuel oil tank is drained to a predetermined level. This alternative is unacceptable because it could render the emergency diesel generator inoperable. The licensee proposes to measure the Section XI quantities when the pump automatically starts on a low day tank level signal and runs until the shutoff level is reached. This should provide an acceptable method to assess operational readiness of the pumps. Because these pumps are not Code Class 1, 2, or 3 components, they are not within the scope of 10 CFR 50.55a; therefore, NRC approval of this alternative method is not required for implementation.

2.3 Residual Heat Removal Pumos j 2.3.1 Test Freauency 2.3.1.1 Re]ief Reauest. P-5 requests relief from the test frequency requirements for the residual heat removal (RHR) pumps,1(2)-RH-P-1A & IB, as required by Section XI, IWP-3400(a). The licensee proposes to test these pumps every cold shutdown when the RCS is below 200 psig and the reactor coolant pumps are secured, but not more frequently than once every three months.

2.3.1.1.1 Licensee's Basis for Reauestina Relief--The low pressure pumps take suction from and discharge to the Reactor Coolant System (RCS).which operates at 2235 psig. This pressure is well above the operating pressure of the pumps, therefore, testing during normal operation is. not possible.

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During cold shutdown, RCS pressure can vary from atmospheric pressure to 350 psig (375 for unit 2). When the RCS temperature is below 185 degrees F (195 for unit 2), the pressurizer power operated relief valve (PORV) setpoint is 350 psig (375 for unit 2). To ensure that the PORV does not lift, the test '

will be performed when the RCS is below 200 psig and when the reactor coolant pumps are secured.

Alternate Testina: Pump will be tested each cold shutdown when RCS pressure ,

is below 200 psig and when the reactor coolant pumps are secured (but not more

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frequently than once every three months).

2.3.1.1.2 Evaluation--The RHR pumps are low head centrifugal ,

pumps. These pumps cannot develop sufficient head to overcome RCS pressure at  ;

normal cperating pressure, therefore, it is impractical to test these pumps, quarterly, during power operation. It would be impractical to test these pumps during cold shutdown when RCS pressure is > 200 psig and the reactor coolant pumps (RCPs) are running. With RCS pressure < 200 psig and RCPs  ;

secured, when the RHR pump is started, the added discharge pressure will not exceed 350 psig (375 for unit 2) and inadvertently lift the PORV. The system would have to be redesigned and modified in order to perform the testing at ,

the Code required frequency. These system changes and modifications would be costly and burdensome to the licensee. The licensee's proposal to perform the testing at cold shutdown, when the RCS is less than 200 psig and RCPs are -

secured, provides a reasonable assurance of operational readiness.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the licensee's proposal, relief should be granted as requested pursuant to 550.55a $(f)(6)(i).

2.4 Recirculation Snray Pumps 2.4.1 Test Frecuency 2.4.1.1 Relief Reauest. P-6 requests relief from the test frequency requirements for the recirculation spray pumps, 1(2)-RS-P-1A and -1B as required by Section XI, Paragraph IWP-3400. The licensee proposes to dry run these pumps quarterly and design flow test the pumps every reactor refueling i outage. '

2.4.1.1.1 Licensee's Basis for Reauestina Relief--Flow testing of these pumps requires containment entry, the connection of a temporary  ;

recirculation line and the erection of a temporary dike to contain -

recirculated water. Approximately five to six days are needed to set up, ,

perform the test, and return the system to its normal configuration. Testing on a cold shutdown frequency would not allow enough time- to plan for and perform a five to six day flow test.

Because these pumps are designed to take suction from a sump,  :

measurement of inlet pressure is not practical. Because of the limitations in '

the test dike design, and the requirements for NPSH, the sump. level cannot vary more than one foot during testing. Therefore, inlet pressure can be calculated from sump level.

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Alternate Testina: These pumps will be run dry every quarter to verify operability. Each pump is equipped with a sensor to detect pump rotation.

Motor current will be recorded for each pump test. A flow test which includes vibration measurement will be performed every reactor refueling. Differential pressure will be determined from the measured discharged pressure and the '

calculated inlet pressure.

2.4.1.1.2 Evaluation--The two inside recirculation spray pumps are designed to pump the fluid that accumulates in the containment sump i (inside containment) following a loss of coolant accident through the '

recirculation spray heat exchangers to the recirculation spray headers. The containment spray system functions to remove heat from the containment post-  :

accident during the depressuri7ation period after a loss of coolant accident.

Normally, the containment sump it maintained in a dry condition. There is no l function related to these pumps other than post-accident. The sump is merely  :

a collection pool for the primary coolant and injection / spray fluid that will be recirculated to provide cooling following a discharge of the refueling water storage tank (RWST) for safety injection and containment spray flow. At a low level of the RWST, the suction for the containment spray system is changed to the recirculation spray header.

Inlet Pressure Determination >

The recirculation spray pumps are vertical deep-well type pumps. The pump impeller extends into the sump and there is no inlet pipe and no pressure gauge to measure inlet pressure. Therefore, the inlet pressure must be calculated based on the level of the sump at the time the flow test is performed. The test setup, as described in the licensee's basis for relief, allows for only I foot variance in the level of the sump based on the amount i of water that can be contained by a temporary dike and to ensure that there is ,

enough water available to meet the net position suction head (NPSH) requirements for the pump. If the required NPSH is not available, or is not maintained, the liquid could vaporize in the pump, resulting in cavitation and ,

pump damage. '

Section XI, IWP-4240, and OM-6 5 4.6.2.2 provide the requirements for determination of the differential pressure across a pump by either (1) a -

differential pressure gauge, (2) a differential pressure transmitter that provides direct measurement of pressure difference, or (3) the difference  :

between the pressure at a point in the inlet pipe and the pressure at a point in the discharge pipe. For the recirculation spray pumps, the " inlet pipe" is the pump casing for the impeller, as it is a vertical deep-well pump. The inlet pressure is essentially the head of water above the bottom of the pump impeller suction. Therefore, if pump discharge pressure is measured and inlet pressure is determined based on the head of water contained in the sump, the ,

determination is in accordance with the Code requirements. The determination i (calculation) must meet the accuracy requirements for pressure measurements v

( 2%). This method provides repeatable results because the licensee will be i able to control the level in order to perform the testing at the reference  !

values.

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Test Freauency Section XI, IWP, requirements do not address pumps such as these that lack fluid to perform quarterly testing. The licensee indicates that they perform a " bump" test each quarter. A " bump" test is simply a starting and stopping of the pump and is not required by Section XI, IWP, or OM-6, nor does it provide any information on the mechanical and hydraulic condition of the pumps. OM-6, j 5.5, " Pumps Lacking Required Fluid Inventory," provide testing requirements for pumps such as pumps in dry sumps. Further, j 5.5 specifies ,

that "the required fluid inventory shall be provided during this test." The test frequency specified in 1 5.5 is "at least once every 2 years." The .

frequency and test method (providing fluid inventory) the licensee proposes is in accordance with the requirements of OM-6 1 5.5. Therefore, the staff approves the proposed method and frequency pursuant to 10 CFR 50.55a(f)(4)(iv) which provides that licensees may perform inservice testing to requirements of later editions of the Code incorporated in 9 50.55a(b), or portions thereof provided all related requirements are met, subject to Commission approval.

The licensee must review the test implementation to ensure that all related requirements of OM-6 are met. Whether all related requirements are met is subject to NRC inspection.

Conclusion:

The determination of inlet pressure is in ;ccordance with the  ;

provisions specified in the Code, and therefore, relief is not required. The calculational method must be included in the test procedure and is subject to 4 NRC inspection. The test frequency proposed by the licensee is in accordance ,

with the requirements of a later edition of the Code incorporated into b of G 50.55a; therefore, with this approval by the staff, the licensee may implement the inservice testing of the recirculation spray pumps in accordance with OM-6 1 5.5 and all related requirements pursuant to S 50.55a(f)(4)(iv).

Because this is in accordance with Code requirements, relief from the Code is not required. Whether all related requirements are met is subject to NRC inspection.

2.5 Outside Recirculation Soray Pumns .

2.5.1 Test Freauency and Duration 2.5.1.1 Relief Reauest. P-7 requests relief from the test frequency requirements of Section XI, Paracraph IWP-3400(a), for the outside recirculation spray pumps, 1(2)-RS-P-2A and -28. Furthermore, the licensee requests relief from the pump run time requirements of Section XI, Paragraph IWP-3500(a), and proposes to calculate pump inlet pressure. The licensee proposes a test frequency of at least once every 2 years and a pump run test 4

time of two minutes for pump stabilization and data acquisition.  ;

2.5.1.1.1 Licensee's Basis for Reauestina Relief--The outside recirculation pumps take suction from the containment sump and discharge to the containment spray arrays. To test these deep draft pumps, the pump pit and the recirculation test loop must be filled with primary grade water and vented. The filling and venting process takes approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. After the test is completed, the pump pit and recirculation piping must be carefully drained to avoid flooding the quench spray basement.

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Testing is the only source of operational based degradation for the pumps. They are also maintained dry and therefore are not subject to normal i

corrosion or foul _ing. Considering the hardship of testing these pumps  ;

described above, the exposure to degradation caused by frequent testing and i the dry state in which the pumps are maintained, there is no compensating increase in safety achieved by testing these pumps every three months. This position is supported by ANSI /ASME OM Part 6, Paragraph 5.5, which states, 1

" Pumps lacking required fluid inventory, (e.g., pumps in dry sumps) need not

~

be tested in accordance with this part every 3 months. These pumps shall be  ;

tested at least once every 2 years except as provided in para. 5.4. The '

required fluid inventory shall be provided during this test." Paragraph 5.4 describes the testing frequency of pumps in systems which are declared inoperable or not required for service.

i The test loop for these pumps contains a.small volume of water. A four' ,

inch test recirculation line branches off the ten inch pump discharge line a  !

short distance from the pump. The recirculation line discharges into the pump pit which is a cylinder approximately 50 feet deep and two feet in diameter.

Because of the small volume in the test loop, the hydraulic parameters  ;

stabilize quickly. Therefore, a five minute stabilization period is not i necessary to achieve repeatable test results. In addition, if the pump is run ,

for too long of a period, the water will heat up due to the limited water .

volume. This heat up can lead to excessive pressures in the test loop. l Suitable suction pressure instrumentation is not installed. The j recirculation path will be filled ~ with water to establish initial conditions for testing. Therefore, inlet pressure can be calculated from the initial  !

water level in the test loop. j Alternate Testino: These pumps will be flow tested on their recirculation $

paths at least once every two years. After a two minute stabilization period, .j inlet pressure, differential pressure as determined from the calculated inlet -;

pressure and measured discharge pressure, flow rate and vibration measurements will be taken.

t 2.5.1.1.2 Evaluation--The outside recirculation spray pumps- are  ;

located in normally dry sumps _which must be flooded with primary grade water  !

in order to perform testing to the Code requirements, similarly to the inside  !

recirculation spray pumps discussed in Section 2.4.1.1 above. The  ;

recirculation spray pumps are vertical deep-well type pumps. The pump i impeller extends into the sump and there is no inlet pipe and no pressure i gauge to measure inlet pressure. l i

Inlet Pressure Determination The' recirculation spray pumps are vertical deep-well type pumps. The pump impeller extends into the sump and there is no inlet pipe and no pressure i gauge to measure inlet pressure. Therefore, the inlet pressure must be  ;

calculated based on the level of the sump at the time the flow test is j performed. The test setup, as described in the licensee's basis for relief,  !

allows for ohly 1 foot variance in the level of the sump based on the amount  ;

of water that can be contained by a temporary dike and to ensure that there is  !

enough weter available to meet the net position suction head (NPSH) j requirements for the pump. If the required NPSH is not available, or is not j i

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maintained, the liquid could vaporize in the pump, resulting in cavitation and :

pump damage.

Section XI, IWP-4240, and OM-6 1 4.6.2.2 provide the requirements for determination of the differential pressure across a pump by either (1) a differential pressure gauge, (2) a differential pressure transmitter that provides direct measurement of pressure difference, or (3) the difference between the pressure at a point in the inlet pipe and the pressure at a point in the discharge pipe. For the recirculation spray pumps, the " inlet pipe" is the pump casing for the impeller, as it is a vertical deep-well pump. The inlet pressure is essentially the head of water above the bottom of the pump impeller suction. Therefore, if pump discharge pressure is measured and inlet .

pressure is determined based on the head of water contained in the sump, the  !

determination is in accordance with the Code requirements. The determination (calculation) must meet the accuracy requirements for pressure measurements (1 2%). This method provides repeatable results because the licensee will be able to control the level in order to perform the testing at the reference values.

Test Frecuency Section XI, IWP, requirements do not address pumps such as these that lack fluid to perform quarterly testing. OM-6, j 5.5, " Pumps Lacking Required Fluid Inventory," provide testing requirements for pumps such as pumps in dry sumps. Further, 5 5.5 specifies that "the required fluid inventory shall be provided during this test." The test frequency specified in j 5.5 is "at least once every 2 years." The frequency and test method (providing fluid inventory) the licensee proposes is in accordance with the requirements of OM-6 1 5.5. Therefore, the staff approves the proposed method and frequency '

pursuant to 10 CFR 50.55a(f)(4)(iv) which provides that licensees may perform inservice testing to requirements of later editions of the Code incorporated '

in S 50.55a(b), or portions thereof provided all related requirements are met, subject to Commission approval. The licensee must review the test '

implementation to ensure that all related requirements of OM-6 are met. .

Whether all related requirements are met is subject to NRC inspection.

Duration of Test The requirements of 1WP-3500 requires a 5 minute run time prior to measuring test parameters. The duration of the test was changed in OM-6 to require a  :

run of at least 2 minutes to stable the pump conditions prior to measuring test parameters. The licensee's proposal is in accordance with OM-6, Paragraph 5.6, " Duration of Tests." Therefore, the proposed two minute stabilization period is in accordance witn the later Code requirements and may be implemented pursuant to 10 CFR 50.55a(f)(4)(iv).

Conclusion:

The determination of inlet pressure is in accordance with the-provisions specified in the Code, and therefore, relief is not required. The calculational method must be included in the test procedure and is subject to NRC inspection. The test frequency and test duration proposed by the licensee are in accordance with the requirements of a later edition of the Code ,

incorporated into j b of 5 50.55a; therefore, with this approval by the staff, the licensee may implement the inservice testing of the recirculation spray pumps in accordance with OM-615.5 and j 5.6 and all related requirements ,

12

pursuant to s 50.55a(f)(4)(iv). Because this is in accordance with Code  !'

requirements, relief from the Code is not required. Whether all related requirements are met is subject to NRC inspection. j 2.6 Service Water Pumps  :

2.6.1 tLeasurement of Test Ouantities l 2.6.1.1 Relief Reouest. P-9 requests relief from measuring pump inlet '

and differential pressure for service water pumps,1(2)-SW-P-1A and -1B, as required by Section XI, Paragraph IWP-3100. The licenses proposes to monitor ,

pump discharge pressure and use it in place of differential pressure to >

monitor for pump degradation. .

2.6.1.1.1 Licensee's Basis for Reouestino Relief--No inlet l pressure instrumentation is installed. These pumps take suction from.the  !

Service Water Reservoir. The Service Water Reservoir has a minimum level of -

313.1 feet as required by Technical Specifications. Reservoir level does not  ;

vary significantly (the maximum recorded level during past testing was 314.9  ;

feet), therefore, inlet pressure will be considered a constant. Discharge f pressure is directly related to pump performance. j

- Alternate Testina: Discharge pressure will be measured in place of [

differential pressure. '

2.6.1.1.2 fvaluation--The service water system is a variable  !

resistance system. As the service water temperature varies, the loads and the amount of cooling needed by running equipment changes. This requires making ,

adjustments in the service water system flow. These adjustments change the  ;

system's operating characteristics. Measuring discharge pressure and flow i would show changing discharge pressures with changing flow rates. These i measurements would have.no repeatability and no comparison could be made in which to monitor for pump degradation. However, pump differential pressure .

will remain relatively constant, as long as the pump does not degrade, and  !

provide a means for, trending, comparison and evaluation of a pump's hydraulic condition. ,

However, it is possible to perform a test by varying the system flows 4

and pump discharge pressure and recording these values as additional sets of 1

. reference values. This approach in establishing additional set (s) of 't reference values is explained in IWP-3112 of the Code. The licensee has not indicated that this approach was taken. Furthermore, with level instrumentation in the service water reservoir, it should be possible to calculate the pump inlet pressure given the height of fluid above the pump- '

suction. As long as this calculation is within the accuracy that would result .

from installed instrumentation meeting the Code accuracy requirements, it can -;

be used with pump discharge pressure to calculate pump differential pressure in accordance with IWV-4240, Differential Pressure," without a relief -

request.

It is possible to monitor for pump hydraulic conditions using discharge presce and. flow given that the inlet suction pressure is constant. However,  !

the Code bases acceptance criteria for pump hydraulic performance on reference differential pressure. The licensee has not provided sufficient information t 13 I

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i on how the acceptance criteria will be applied using only discharge pressure l and flow to justify granting relief.

Based on the determination that the licensee has not shown i impracticality, burden, or hardship due to the Code requirements and since the l possibility exists of calculating the pump inlet pressure to be used with  ;

discharge pressure to calculate pump differential pressure, relief should be i denied. ~

2.6.1.2 Relief Reauest. P-10 requests relief from measuring pump inlet pressure and differential pressure for service water pumps, 1(2)-SW-P-4, as l required by Section XI, Paragraph IWP-3100. The licensee proposes to measure -

pump discharge pressure and use this value in place of differential pressure. '

2.6.1.2.1 Licensee's Basis for Reauesting Relief--No inlet pressure instrumentation is installed. This pump takes suction from Lake Anna which has a minimum level required by Technical Specifications. The lake '

level, which does not vary significantly (the maximum and minimum recorded .i i

levels during past testing were 250.24 feet and 248.16 feet, respectively),

will be recorded to establish initial conditions for testing. Inlet pressure ,

will be considered a constant. Discharge pressure is directly related to pump performance and therefore will be measured in place of differential pressure. ,

Alternate Testino: Discharge pressure will be measured in place of differential pressure.

2.6.1.2.2 Evaluation--The service water system is a variable '

resistance system. As the service water temperature varies, the loads and the  ;

, amount of cooling needed by various running equipment changes, making  ;

adjustments in the service water system flow necessary. These adjustments  ;

change the system's operating characteristics. Measuring discharge pressure .

and flow would show changing discharge pressures with various flow rates. l These measurements would have no repeatability and no comparison could be made .

in which to monito.r for pump degradation. However, pump differential pressure  !

will remain relatively constant, as long as the pump does not degrade, and provide a means for, trending, comparison and evaluation of a pump's hydraulic  ;

condition.

i However, it is possible to perform a test by varying the system flows and pump discharge pressure and recording these values as additional sets of i reference values. This approach in establishing additional set (s) of reference values is explained in IWP-3112 of the Code. The licensee has not indicated that this approach was taken. Furthermore, with level instrumentation for monitoring lake level, it should be possible to calculate  !

the pump inlet pressure given the height of fluid above the pump suction. As long as this calculation is within the accuracy that would result from ,

, installed instrumentation meeting the Code accur'acy requirements, it can be  !

used with pump discharge pressure to calculate pump differential pressure in accordance with IWV-4240, " Differential Pressure," without a relief request.

It is possible to monitor for pump hydraulic conditions using discharge pressure and flow given that the inlet suction pressure is constant. However, >

the Code bases acceptance criteria for pump hydraulic pc ' armance on reference  :

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differential pressure. The licensee has not provided sufficient information on how the' acceptance criteria will be applied using only discharge pressure and flow to justify granting relief.

Based on the determination that the licensee has not shown impracticality, burden, or hardship due to the Code requirements and since the l possibility exists of calculating the pump inlet pressure to be used with i discharge pressure to calculate pump differential pressure, relief should be  ;

denied. '

2.7 Component Coolina and Service Water >

2.7.1 Reference Test Values '

2.7.1.1 Relief Reauest. P-12 requests relief from establishing fixed set (s) of values for reference values and comparing the test results to these  :

reference values for Component Cooling Water Pumps, 1(2)-CC-P-1A & -1B, and .

Service Water Pumps, 1(2)-SW-P-IA, -1B, & -4 as required by Section XI, Paragraphs IWP-3100 and -3110. The licensee proposes to test the pumps, when <

available, and record at least 6 pressure / flow points. From these points, the '

licensee will mathematically generate a pump curve. Data, taken from insitu testing, will be compared to the mathematical pump curve for monitoring of j pump degradation. '

i 2.7.1.1.1 Licensee's Basis for Reauestina Relief--Plant

• conditions may not be the same as when the reference values were established.

Many reference points must be established to anticipate future plant conditions. In the Component Cooling and Service Water Systems, reproducing i one of these reference flow points is difficult with the large butterfly .

valves installed and it may not be desirable to alter cooling because of other  ;

plant operating parameters.

Past vibration data for the subject pumps has been reviewed and it has  ;

been determined that pump vibration does not vary significantly with flow  ;

rate. ,  ;

Alternate Testina: All subsequent test results will be compared to calculated i reference values which are determined using the following method. A set of at e least six pressure / flow points will be recorded. From these points an equation for the line will be calculated by a computer using third order

, polynomial regression. This technique employs a least-squares fit of the data ,

by successive polynomials of order 1 through 3 and examines the standard i deviation about the regression line in each case. The coefficients are calculated to the twelfth decimal place. .The resulting third degree i polynomial equation describes the reference curve. Flow points will be taken  !

between the limits of the original data points. The resulting pressure is j then compared to the ASME XI, Table IWP-3100-2 limits. Pumps may then be  !

tested during normal operation without any valve throttling. An example of a reference curve is shown in Figure 1. The reference curve is-labelled "ref.

curve". Acceptance ranges are shown as 0.90, 0.93, 1.02, and 1.03 times the t reference curve.

2.7.1.1.2 Evaluation--The component cooling and service water  ;

systems operate under varying loads and changing heat sink temperatures

)

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'4 through out the year. Altering cooling flow to required safety systems may make them inoperable. With these systems inoperable, the licensee may be in  :

violation of their technical specifications. This would require the licensee to enter action statements and limiting conditions for operations (LCOs). Due to the possible damage to safety equipment and probable plant shutdown, . ,

altering the above cord'ng systems to previous set reference values would be impractical. In order 's the licensee to return to the previously recorded pump reference conditions, they may be required to shutdown and/or cooldown  ;

the plant. This would be burdensome and costly to the licensee. i The licensee's proposed alternate testing, calculation of a reference curve using at least 6 data points with third order polynomial regression and then comparing these values to insitu test values, should provide an acceptable alternative to the Code requirements.

However, the calculated curve must bound the operational band in which the pumps operate. The calculated curve cannot be extrapolated outside the data points to fit the operational band of the desired pump. Further, it is important that the calculated reference curve is developed, and/or the ,

manufacturer's curve is validated, when the pump is known to be operatii.g acceptably. This calculated curve should be based on, or validated by, an adequate number of measurement points.

In the licensee's example curves, the acceptance criteria was based on pump differential pressure and was conservative and equivalent to the Code -

requirements. However, in relief requests P-9 and P-10 the licensee has requested relief from measuring pump inlet pressure and pump differential pressure. Changes in pump hydraulic performance should be indicated by i changes in pump differential pressure (dp) measurements taken at a specific flow rate. The Code specified acceptance criteria for pump hydraulic performance is based on differential pressure. A change in pump discharge pressure at a given flow rate can also indicate a change in pump performance.

However, the same magnitude of change in pump hydraulic performance constitutes a larger percentage of dp than of discharge pressure. Therefore, acceptance. criteria should not be based on discharge pressure.

Acceptance criteria that is based on reference differential pressure -

could, however, be applied to discharge pressure measurements. For instance, for a pump with a constant inlet pressure of 20 psig, a reference dp of 80 psig, and a reference discharge pressure of 100 psig the maximum allowable decrease in hydraulic performance or dp would be 0.90

• 80 psig or 7.2 psig.

This acceptance criteria could be as effectively applied to either pump d/p or discharge pressure measurements as long as the inlet pressure is constant i.e., action would be required at either a dp of 72.8 psig or a discharge ~

pressure of 92.8 psig since both indicate the same amount of hydraulic degradation. .

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the licro 2e's proposal, relief should be granted pursuant to 650.55a 1(f)(6)(i) provided the licensee's calculated curve bounds the operating curve of tne designated pump. Also, the acceptance criteria should be applied as described above.

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l 2.8 Auxiliary Feedwater 2.8.1 Tpst Duration.

2.8.1.1 Relief Reauest. P-14 requests relief from the pump run time '>

requirements of Section XI, Paragraph IWP-3500 for feedwater pumps,1(2)-FW-P-2, 1(2)-FW-P-3A, and 1(2)-FW-P-38. The licensee proposes to run the pumps on  :

recirculation for more than five minutes, after which time full flow will be  :

opened to the steam generators for up to two minutes while test data is taken.

l 2.8.1.1.1 Ljcensee's Basis for Reauestina Relief--Flowing ~i auxiliary feedwater to the steam generators for five minutes during normal operation would upset the feedwater chemistry and cause thermal stress of the  !

feedwater piping. '

alternate Testino: The pumps will be operated on their recirculation paths l for more then five minutes, after which a full flow path will be opened to the steam generators. The full flow path will be maintained for up to two minutes

, while test data is recorded. ,

2.8.1.1.2 Evaluation--Injecting relatively cool feedwater from the auxiliary feedwater system into operating steam generators, could cause j thermal shock of the feedwater nozzles and piping. In addition, the chemistry  ;

of the condensate storage tank (CST) is not of the same high quality as the  !

main feedwater system. The injection of lower quality feedwater could upset the chemistry balance in the steam generators.  ;

The licensee's proposed alternative of running the pumps on minimum recirculation for more than five minutes and then admitting full flow to the j steam generators for up to two minutes while test data is recorded is in i accordance with the requirements of OM-6, Paragraph 5.6, " Duration of Tests,"  !

which. requires that "each pump shall be run at least 2 min. At the end of  ;

this time at least one measurement or observation of each of the quantities j required shall be made and recorded." Because the licensee's alternative is -

in accordance with the latest Code requirements incorporated _into 10 CFR 50.55a(b), approval to implement a minimum two minute run time is acceptable pursuant to 10 CFR 50.55a(f)(4)(iv), and relief is not required. There are no '

related' requirements for the duration of tests included in OM-6. l 2.9 Boric Acid Transfer Pumns 2 9.1 Test Freauency and Duration i

2.9.1.1 Relief Reauest. P-15 requests relief from the test frequency .

and test duration requirements for Coric Acid Transfer Pumps, 1-CH-P-2A, 1-CH-P-28, 1-CH-P-2C, and 1-CH-P-2D as required by Section XI, Paragraphs ,

IWP-3400 and -3500. The licensee' proposes to test these pumps quarterly on the recirculation loop. . During refueling outages, the licensee proposes to 1 place the pumps on the recirculation loop for three minutes and then direct full flow to the RCS for two. minutes. Test data will be recorded when flow'is  ;

directed to the RCS.

2.9.1.1.1 Licensee's Basis for Reauestina Relief--Permanent flow ,

instrumentation is not installed on the recirculation piping, which is the  :

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only test loop available for quarterly testing. To neasure flow, flow must be established to the emergency and alternate boration paths and then to the charging pump suctions. This flow would increase the RCS boron inventory and cause a reactivity transient during normal operation.

During cold shutdown, the emergency and altarnate boration path valves >

are tested with flow. However, this test is short in duration to minimize the ,

amount of boric acid injected into the RCS. The pt'mp test requires'an

• extended period of boric acid injection, which would upset the RCS boron balance and possibly impact the ability of the plant to restart. Therefore, this test should only be performed during cold shutdowe.s on the way to reactor refueling while the RCS is being borated or during reactor refuelings.

During RCS boration or during reactor refuelings, extended periods of ,

pump operation on high speed can either interfere with the boration process _or adversely affect the boron balance in the RCS. Therefore, to limit the amount of boric acid injected into the RCS during the pump tests, the pumps will be run for more than three minutes on the recirculation flow path, and then only two minutes with flow to the RCS before the test quantities are measured.

Alternate Testina: These pumps will be tested every quarter on the -;

recirculation loop, and inlet pressure, differential pressure and vibration 'i will be measured. Every reactor refueling, inlet pressure, differential j pressure, flow and vibration will be measured after the pumps have been run i for three minutes on the recirculation flow path, and then for two minutes ,

with flow to the RCS.  !

Note: The alternate testing complies with Generic Letter 89-04, Attachment 1, Position 9, except for the duration of the run period prior to measuring the  :

test quantities. ,

2.9.1.1.2 Evaluation--The quarterly test performed at power uses  ;

the recirculation line which is not instrumented. Inlet and differential #

pressure is monitored quarterly along with pump vibration but, due to the lack of instrumentation, it is impractical to measure flow. It is possible to use '

the instrumented line using the emergency and alternate boration paths to the .

charging pump suctions but this is impractical since it would inject highly concentrated boric acid into the RCS causing a reactivity transient and '

possible plant shutdown. ,

i During cold shutdown the alternate and emergency boration paths are tested with flow, but for a short time period only. Longer periods of pump ,

operation would significantly increase the amount of boron in.the RCS. The  :

higher concentrations of boron in the RCS would require large amounts of water t to dilute to critical boron concentration. In order to provide space for this dilution,_ water must be letdown from the RCS which must be treated as radioactive waste. The time and effort required to perform the dilution and i treat'the radioactive waste _ water could delay plant start-up. This would be.

costly and burdensome to the licensee.

The licensee's proposal to perform full flow testing during cold shutdowns for refueling outages, while the RCS is being borated for reactor refueling or during refuelings when boron concentration needs to be increased, should provide a reasonable assurance of operational readiness. The licensee 18 '!

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, I i

has further requested at refueling to run these pumps for 3 minutes on the I recirculation line' and then for 2 minutes at full flow into the RCS to prevent  ;

over boration of the RCS and maintain proper chemistry control. . This ,

proposal by the licensee would ensure the pump was run for a minimum of 5

' minutes prior to collecting data as required by the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the licensee's proposal, relief '

should be granted as requested pursuant to 50.55a S(f)(6)(i).

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3. VALVE TESTING PROGRAM

.The following valve relief requests were evaluated against the  :

requirements of the 1986 Edition of the ASME Code,Section XI, 10 CFR 50.55a, '

and applicable NRC positions and guidelines. A summary is presented for each  :

relief request followed by the licensee's basis for relief and the' evaluation I with the reviewer's recommendations. The evaluations are grouped according to l topic or system. Each relief request evaluation is applicable to both units unless specified otherwise. The valve identification numbers will generally have a prefix of "1 " for unit one, "2 " for unit two. Unit one relief requests identifiers are shown without parenthesis, while unit two request [

numbers.are shown inside parenthesis, e.g., V-65 (V-66). '

3.2 General Valve Relief'Reauests

{

3.1.1 Stroke Time Measurement 3.1.1.1 Relief Reauest. V-54 (V-55) requests relief from applying the .[

Section XI, IWV-3417(a), corrective action criteria, to valves with stroke e times less than 2 seconds. These valves are considered rapid acting valves  !

and the licensee proposes to apply the Section XI, IWV-3417(a), corrective i action criteria whenever these valves exceed the 2 second maximum stroke time.

The affected valves are listed in the licensee's IST program. ,

3.1.1.1.1 Licensee's Basis for Renuestino Relief--These valves '  !

have normal stroke times of less than 2 seconds, therefore, they are ,

considered rapid acting valves.  :

Alternate Testino: Whenever the stroke time of these valves exceeds 2 seconds, IWV-3417(a) will be applied.

l j

Notes: The list of valves in Table A may change due to maintenance activities which affect valve performance. An updated list of rapid acting valves will be maintained by the site ISI personnel.

This relief request was docketed before April 3, 1989. The alternate l testing presented in this relief request conforms to NRC Generic Letter 89-04, l Attachment 1, Item 6. When relief request V-66 is approved by the NRC, this I relief request may be withdrawn. 1 l

3.1.1.1.2 Evaluation--Generic Letter 89-04, Attachment 1, Item 6, I states in part: " Power operated valves with normal stroke times of 2 seconds  !

or less are referred to by the staff as " rapid-acting valves". Relief may be granted from the requirements-of Section XI, Paragraph IWV-3417(a) for these valves provided the. licensee assigns a maximum limiting value of full-stroke time of 2 seconds to these valves and, upon exceeding this limit, declares the valve inoperable and takes. corrective action in accordance with IWV-3417(b)".

The licensee stated their position conforms to the Generic letter 89-04, Attachment 1, item 6 position and therefore their proposed alternate testing would be in compliance with the staff position and is approved by GL 89-04.

Relief Request V-66 (V-67) is evaluated in Section 3.1.3.1.

i 20  !

4 _ _ ____, . _ _ _ _ _ . _ _ _ _ _ __ _ _ _ . , _ _ _ _ _ . . _ . . . _ . - . .

3.1.2 Valve Leakaae Rates 3.1.2.1 Relief Reauest. V-59 (V-59) requests relief from assigning  !

individual leakage rates to containment isolation valves as required by ,

Section XI, Paragraph IWV-3426. The licensee proposes to group these valves '

and assign a permissible leak rate to the entire group. '

3.1.2.1.1 Licensee's Basis for Reauestina Relief--The piping configurations for some containment penetrations do not allow for the individual leakage testing of the containment isolation valves.

Alternate testina: In cases where containment isolation valves cannot be .i individually leakage tested, the containment isolation valves are grouped based on the configuration restraints and the groups are assigned permissible leakages. The groups are subject to the acceptance criteria described in IWV- l 3427(a).

i 3.1.2.1.2 Evaluation--0M-10, Paragraph 4.2.2.2, provides the Code  :

requirements for leakage testing of containment isolation valves, referring to the requirements of 10 CFR 50, Appendix J. OM-10, Paragraph 4.2.2.3, provides the requirements for leakage rate testing of Category A valves other than _

containment isolation valves. However, in rulemaking dated August 6, 1992, effective September 8, 1992, the NRC modified the approval of the 1989 Edition  !

of Section XI, and thus the approval of OM-10, to impose the requirements of  :

Paragraph 4.2.2.3 to containment isolation valves. Paragraph 4.2.2.3 "

specifies the leakage testing requirements for valves or valve combinations.  !

Previous leakage testing requirements of the Code did not address valve ,

combinations. +

t Provided the licensee follows all the related requirements specified in OM-10, Paragraph 4.2.2.3, for leakage testing of valve combinations, the staff approves the use of this portion of OM-10 pursuant to 10 CFR 50.55a(f)(4)(iv).

The acceptance criteria for each group of valves must be established based on identifying leakage of any valve in the group. The methodology must be included in the IST program. Using the diameter of the smallest valve in the group, or using a conservative limit established to another criterion not related to the diameter of the valves, would be examples of the basis for the ,

acceptance criteria. Implementation of the requirements of OM-10 includes the requirements for corrective action except as modified by Section 3.1.2.2.2 ,

below. Whether.all related requirements are met is subject to NRC inspection.  ;

3.1.2.2 Relief Reauest. V-69 (V-70) requests relief from the corrective action requirements of IWV-3427(a) for containment isolation valves which demonstrate leakage rates exceeding the permissible values. As an .

alternative to repair or replacement, the licensee proposes to perform an  !

evaluation of the leakage rate in comparison to the allowable leakage criteria of 10 CFR 50, Appendix J, for overall containment leakage rates.

3.1.2.2.1 _ licensee's Basis for Reauestina Relief--The licensee i states: " Permissible valve leakage rates are based on each valve's possible  ;

contribution to the total leakage rate for the containment system. The total l containment leakage rate must be less than 0.6 L, as defined in Technical Specification 3.6.1.2. Exceeding an individual valve's permissible leakage  !

6 21 j

.i I

~

rate may have no affect on the containment's ability to maintain an overall ,

leakage rate less than 0.6 L,." i i

Alternate Testina: In addition to repair or replacement as corrective actions, an evaluation can be performed which demonstrates that even if a valve has exceeded its permissible leakage rate, the overall containment .

leakage rate will be maintained below 0.6 L until the next Type C tests No repair or replacement is necessary if the e, valuation is performed. l 3.1.2.2.2 Evaluation: Appendix J to Part 50, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," specifies the  ;

acceptance criterion for Type C tests of containment isolation valves, other '

than water sealed valves, as follows: "The combined leakage rate for all penetrations and valves subject to Type B and C tests shall be less than 0.60 The leakage limit of Appendix J for each valve is not based on L,dividual in valve leakage rates, but on a value (0.60 L,) based on the percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the calculated peak containment internal pressure related to the design basis accident and specified either in technical specifications or in associated bases. When leakage limits are assigned to individual valves to -

meet inservice testing requirements, the limits are related to monitoring for '

degrading conditions. When these individual limits are exceeded, the subject '

valve (s) should be repaired or replaced, or the degrading condition otherwise dispositioned. Performing an evaluation to determine if the excessive leakage affects the overall leakage rate (0.60 L may be appropriate under certain-  !

conditions, such as during an unplanned p )lant shutdown; howe'ver, depending on the degree of excessive leakage, the valve may no longer-be able to-perform its safety function _to close and isolate containment. That is, if the leakage ,

is above a level which can be quantified, and the valve is not repaired or replaced, it would have to be considered inoperable and the actions required '

by Technical Specifications for the affected penetration would have to be met.

• If the leakage is quantifiable, the evaluation may be appropriate; however, .

the evaluation would have to address the operability of the valve in relation to its capability to isolate the penetration in order to continue to meet -

single failure for.the affected penetration valve configuration. 3 AdditionalJy, the evaluation must address the leakage of all Type C- tested ,

valves and demonstrate that the leakage limit of 0.60 L, would not be exceeded if the leakage increases due to further degradation. Further, for any valves which are demonstrated closed for inservice testing purposes by performance- of an Appendix J leak test, the evaluation would have to address the capability i of the valve to close and further' testing or nonintrusive methods may be required to verify that the valve is closed but not leaktight. a t

. Because there may be plant conditions, or schedule constraints, that preclude  ;

repair or replacement of a valve when the individual leakage limit is exceeded, but the overall leakage limits for Type C-tested valves is met, it i would be an undue burden on the licensee to impose the Code requirements.  ;

Imposing an absolute leakage limit for each valve has no compensating benefit l to quality and safety when the bases for leakage limits is met for the overall limit necessary to ensure containment integrity. If the leakage of the  !

individual valve is such that its continued service is questionable, the ,

actions required by Technical Specifications would be required. These actions may include isolation of the affected penetration by the redundant containment isolation valve. However, when the plant conditions are not such that a P

22 1

repair or replacement would adversely impact plant startup and/or continued operations, an evaluation is not appropriate. ,

Therefore, provided the evaluation addresses the concerns discussed above and '

is used only when plant conditions preclude repair or replacement, the proposed alternative to the corrective action requirements is authorized pursuant to 1 (a)(3)(ii) as a hardship without a compensating-benefit in quality and safety. The evaluation must be documented in plant records, must-conclude that continued operation does not create a prohibited condition ,

unless other required actions are taken, and must require scheduling a repair '

or replacement when plant conditions and schedules allow.

3.1.3 Stroke Time Criteria 3.1.3.1 Relief Reouest. V-66 (V-67) requests relief from the requirements of Section XI, Paragraph IWV-3417(a), specifying corrective -

action based on " alert" criteria established from previous test time for all power operated valves. The licensee proposes to determine stroke time criteria per ASME/ ANSI OM (Part-10), Section 4.2.1.8 and implement corrective action per Section 4.2.1.9.

3.1.3.1.1 Licensee's Basis for Reauestina Relief--Testing of power operated valves will be performed to the guidelines presented in ASME/ ANSI OM (Part 10), Sections 4.2.1.8 and 4.2.1.9 as approved for use by Section XI, Article IWV-1000, 1986 Edition with Addenda through 1988. These guidelines represent current industry practices when using stroke times as a means for determining valve degradation and provide improved methods for determining acceptance criteria.

Alternate Testina: Determine stroke time acceptance criteria per ASME/ ANSI OM (Part 10), Section 4.2.1.8 and implement corrective action per Section 4.2.1.9.

L 3.1.3.l.2

. Evaluation--The licensee's proposed testing is in accordance,with OM-10 which has been incorporated into 10 CFR 50.55a(b) through the 1989 Edition of Section XI. Therefore, implementation of stroke time measurements in accordance with OM-10 is approved pursuant to 10 CFR 50.55a (f)(4)(iv), provided all related requirements are met, and relief is not required. The related requirements of OM-10 include Paragraphs 1.3, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 4.2.1.1-9, 5, and 6. Whether all related requirements are met is subject to NRC inspection.

3.2 Safety In.iection System 3.2.1 Cateaory A Valves 3.2.1.1 Relief Request. V-35 (Unit 2) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for safety injection valves 2-SI-MOV-2836, 2-SI-MOV-2869A, 2-SI-M0V-2869B, 2-SI-MOV-2890A, and 2-SI-MOV-2890B. The licensee proposes to full-stroke exercise and verify reverse flow closure of these valves each refueling outage not to exceed 24 '

months.

23

?

3.2.1.1.1 Licensee's Basis for Reouestino Relief--These valves provide isolation for alternate safety injection paths to the RCS. As required by Technical Specifications 3/4.5.2.a, they are closed with power removed from valve actuators during Modes 1, 2, and 3. Full or part-stroke ,

exercising these valves during power operation would be in violation of Technical Specifications. Also, the valve controllers do not allow for a part-stroke exercise test.

Technical Specification 4.4.6.2.2 requires that these valves be leak tested following valve actuation. They will be exercised only during refueling ,

outages because the small increase in safety gained by testing during cold shutdown does not justify performing leak rate tests.

1 Alternate Testina: Exercise for operability each refueling (not to exceed 24 months).

3.2.1.1.2 Evaluation--These valves perform a pressure isolation function during power operation. As such, it is impractical to exercise these valves during power operations because it would be in violation of plant technical specifications. In order for the licensee to perform testing at the l Code required frequency, the system would require design changes and modifications. These changes and modifications would be burdensome to the '

licensee. The licensee's technical specifications require leak testing these valves following valve actuation. A leak rate test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration.  :

Performing this test at cold shutdown could delay plant _ start-up. In '

accordance with OM-10,-Paragraph 4.2.1.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each ,

refueling outage, based on the impracticality of performing testing during i power operation or during cold shutdown conditions, is approved pursuant to .

10 CFR 50.55a (f)(4)(iv). The related requirements of 4.2.1.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to. returning the plant to operation" must be met for the extension of the test interval.

3.2.1.2 Relief Reauest. V-37 (Unit 2) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for safety injection  ;

valves, 2-SI-MOV-2867C and D, and 2-SI-MOV-2890C and D. The licensee proposes ,

to full-stroke exercise and verify reverse flow closure of these valves each

• refueling outage, not to exceed 24 months. [

I 3.2.1.2.1 Licensee's Basis for Reauestina Relief--Technical  ;

Specification 4.4.6.2.2 requires that these valves be leak tested following. '

valve actuation. They will be exercised only during refueling outages because the small increase in safety'g'ained by testing during cold shutdown does not

' justify performing leak rate tests. .;

Alternate Testina: Exercise for operability each refueling (not to exceed 24' -

months).

3.2.1.2.2 Evaluation--According to the licensee's technical specifications, these valves require a leak test following valve actuation. A .

leak test is a non-routine test requiring planning, specific plant modes, and -

24 '

I an elaborate test configuration. It would be impractical to exercise and then leak test these valves during power operations because of the' different plant  !

mode (s) required for testing. These modes could isolate a safety system (s) and make them inoperable'for an indeterminate amount of time. With safety systems inoperable, the licensee could enter LCOs and be required to stop power operations and shutdown the plant. Performing'a. leak test at cold shutdown' could delay plant start-up. This would be burdensome to the ,

licensee. In accordance with OM-10, Paragraph 4.2.1.2(e), "if exercising is l not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therofore, the implementation of testing each refueling outage, based on the impracticality of performing '

testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.2.1.2(h) i that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met-for

• the extension of the test interval.

3.2.2 Category A/C Valves 3.2.2.1 Relief Reauest. V-40 (V-41) requests re' lief from the test  :

frequency requirements of Section XI, Paragraph IWV-3521 for safety injection accumulator make-up and nitrogen supply check valves 1-SI-106, -110, 2-SI-132, and -136. The licensee proposes to verify reverse flow closure of the valves every refueling outage, not to exceed 24 months. '

3.2.2.1.1 Licensee's Basis for Reauestina Relief--These check valves must seat upon reversal of flow in order to fulfill their safety t functions. The only method to verify this actuation is to perform a leak rate /back pressure test. Since'the valves are located inside containment,  !

they cannot be tested every three months. A part-stroke exercise test is not possible during plant operation. They will be exercised only during refueling  !

outages because the small iacrease in safety gained by testing during cold  ;

shutdown does not justify draining the lines and performing a leak rate test. i i

Alternate Testina: Exercise for operability every refueling (not to exceed 24 e months).  !

3.2.2.1.2 Evaluation--These are simple check valves which are  ;

located inside containment. It appears the only practical method to verify -l reverse flow closure is by performing a leak rate /back flow test. It is i impractical to verify reverse flow closure during power operations because  :

this would require containment entry. Containment entry is restricted during  !

power operations due to high radiation levels and other personnel safety l hazards. A leak rate test is a non-routine test requiring planning, special i plant modes, and an elaborate test configuration. Performance of this leak  ;

test at cold shutdown could delay plant start-up. This would be burdensome to  ;

the licensee. The licensee's proposal to verify reverse flow closure every l refueling outage, 'not to exceed 24 months, is acceptable. In accordance with 0M-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling  :

outages." Therefore, the implementation of testing each refueling outage, i based on the impracticality of performing testing.during power operation or l during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a  ;

(f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing 25 ,

required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

3.2.2.2 Relief Reauest. V-41 (V-42) requests relief from the test i frequency requirements of Section XI, Paragraph IWV-3521 for safety injection cold leg check valves,1-SI-83, -86,-89, -195, -197, and -199 for Unit One, and 2-SI-85, -91, -93, -99, -105, -107, -119, -126, and -128 for Unit Two. ,

The licensee proposes to exercise these valves open and closed during refueling outages. '

3.2.2.2.1 Licensee's Basis for Reauestina Relief--These Safety Injection check valves must open and close to fulfill their safety functions. ,

They can not be full or part-stroke exercised to the open position during ,

power operation because this would thermally shock the injection system and  ;

cause unnecessary plant transients. Flow cannot be established in the low  :

head injection lines during normal plant operation. j During cold shutdown, the RCS pressure still prevents full design flow.  ;

Also, a partial-stroke or full-stroke test could cause an overpressurization  ;

of the RCS and force a safety system to function.

These valves can only be tested to the closed position by draining the  !

lines and performing a back seat leak test.  ;

Alternate Testina: Exercise to the open position using flow every reactor l refueling. Exercise to the closed position every reactor refueling per Technical Specification 4.4.6.2.2.  ;

I 3.2.2.2.2 Evaluation--It is impractical to full or partial-stroke  !

exercise these valves, during power operation, because of the possibility of l thermal shock to the injection system and the unnecessary plant transients  ;

which could develop because of testing. During cold shutdown, with the RCS i intact, full design flow cannot be met which prevents a full-stroke exercise  !

of these valves. A partial-stroke exercise of these valves at cold shutdown  !

with the RCS pressure boundary intact could create an overpressurization  ;

concern and possibly lead to pressurized thermal shock (PTS). Therefore, it

. is impractical to full or partial-stroke exercise these valves during cold  !

shutdown. In order to full or partial-stroke exercise these valves at the  ;

Code required frequency, the system would need design changes and i modifications. These changes would be burdensone to the licensee. l l

These valves are simple check valves and the only practical method to i verify reverse flow closure is to perform a leak /back flow test. In order to perform this test, the lines must be drained, making the system inoperable.  :

It is impractical to drain these lines during power operation. With the lines  !

drained, the system would be inoperable for an undetermined time span and put -

the licensee in violation of technical specifications. A leak rate test is a  ;

non-routine test requiring planning, special plant modes, and an elaborate  ;

test configuration. Performance of this leak test at cold . shutdown could i delay plant start-up. This would be burdensome to the licensee. 1 In.accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not i practicable during plant operation or cold shutdowns, it may be limited to l 26 f

full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, based on the impracticality of performing. .

testing during power operation or during cold shutdown conditions, is approved '

pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval. '

3.2.2.3 Relief Reauest. V-43 (V-44) requests relief from the test ,

frequency requirements of Section XI, Paragraph IWV-3521 for safety injection check valves in the following table. The licensee proposes to-full-stroke exercise and verify reverse flow closure of these valves at refueling outages. ,

Unit One Unit Two 1-SI-79 l-SI-201 2-51-92 1-SI-90 1-SI-206 2-SI-100 l 1-SI-95 1-SI-207 2-SI-106  :

1-SI-99 l-SI-209 l l-SI-103 1-51-211 l 1-SI-185 1-SI-213 l 3.2.2.3.1 Licensee's Basis for Reauestina Relief--These safety injection check valves must open and close to fulfill their safety function.

They cannot be full or part-stroke exercised to the open position during power operation because this would cause safety injection flow into the RCS which -

would thermally shock the injection system and cause unnecessary plant  ;

transients. Flow cannot be established in the low head injection lines during normal plant operation.  !

I During cold shutdown, the RCS pressure still prevents full design flow.

Also, a partial or full-stroke test could cause an overpressurization of the -

RCS and force a safety system to function.

These valves. can only be tested to the closed position by a back seat leak test,, which requires the draining of the lines.  ;

Alternate Testina: Exercise to the open position using flow every reactor refueling. Confirm valve closure by leakage testing every reactor refueling.  :

3.2.2.3.2 Evaluation--It is impractical to full or partial-stroke i exercise open these valves during power operation because the injection of ,

relatively cool water could thermally shock the injection system and cause  ;

unwanted plant transients. It is impractical to full or partial-stroke <

-exercise open these valves during cold shutdown because, the safety injection 1 system cannot meet design flow conditions, and with the RCS pressure boundary  ;

intact, the potential exists for pressurized thermal shock (PTS). This l overpressurization could force a safety system to function. The injection  !

piping system would require design _ changes and modifications in order to j comply with the Code required test-frequency. These changes and modifications l would be burdensome to the licensee.

These safety injection check valves perform ; safety function in the open and closed direction. In order to check the reverse flow capability of '

these valves, the lines must be drained of fluid. It is impractical to drain s

27 l

, . - ~. . - . .

these lines to verify reverse flow closure during power operation because this would render the' safety injection system-inoperable for a undetermined amount of time. A leak rate test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. Performance of this test at j cold shutdown could delay plant start-up. This would be burdensome to the '

licensee. l In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not ,

practicable during plant operation or cold shutdowns, it may be limited to l full-stroke during refueling outages." Therefore, the implementation of '

testing each refueling outage, based on the impracticality of performing' >

testing during power operation or during cold shutdown conditions, is approved  ;

pursuant to 10 CFR 50.55a'(f)(4)(iv). The related requirements of 4.3.2.2(h) j that "all valve testing required to be performed during a refueling outage 1 shall be completed prior to returning the plant to operation" must be met for l the extension of the test interval. ,

r 3.2.3 Cateaory C Valves

'3.2.3.1 Relief Reauest--V-44 (V-45) requests relief from the test -i frequency requirements of Section XI, Paragraph IWV-3521 for safety injection '

check valves listed in the table below. The licensee proposes to full-stroke '

exercise open and verify reverse flow closure for the valves each refueling  !

outage.

5 Unit One Unit Two j 1-SI-190 2-SI-90 2-SI-ll2 +

l-SI-192 2-SI-98 2-SI-113 ,

1-SI-194 2-SI-104 2-SI-117 2-S1-118 2-SI-124 i

3.2.3..l.1 Licensee's Basis for Reauestino Relief--These safety ,

injection check valves must open and close to fulfill their safety function.

They cannot be full or part-stroke exercised to the open position during power operation because this would thermally shock the injection system and cause unnecessary plant transients.  ;

Ouring cold shutdown, the RCS pressure prevents full design flow. Also, a partial or full-stroke test could cause an overpressurization of the RCS and-  !

force a safety system to function. l The only test methods to individually back seat these valves are to i perform leak tests or to use downstream pressure provided by the low head safety injection pump tests. Either test can only be performed during reactor-refueling.

Alternate Testina: Exercise to the open position using flow and to the closed position every reactor refueling. j 3.2.3.1.2 Evaluation--It is impractical to full or partial-stroke i exercise open these valves during power operation because the injection of -

relatively cool water could thermally shock the injection system and cause '

28 ,

i

,. .- ,- .. ----,#, ,,-v y-, .

. v.-- .,

+  ;

i unwanted plant transients. It is impractical to full or partial-stroke  ;

exercise open these valves during cold shutdown because, the safety injection '

system cannot ' meet design flow conditions and with the RCS pressure boundary intact, the potential exists for pressurized thermal shock (PTS). This overpressurization could force a safety system to function. The injection  !

piping system would require design changes and modifications in order to i comply with the Code required test frequency. These changes and modifications -l would be burdensome to the licensee.

These safety injection chuk valves perform a safety function in the '

open and closed direction, k order to check- the reverse flow capability of the valves a leak /back flow test must be performed. It is impractical to i leak /back flow test these valves to verify reverse flow closure during power  :

operation because this would render the safety injection system inoperable for i a undetermined amount of time. A leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration.

Performance of this test at cold shutdown could delay plant start-up. This would be burdensome to the licensee.

In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to 4 full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, based on the impracticality of performing '

testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage  ;

shall be completed prior to returning the plant to operation" must be met for the extension of the test interval. l 3.2.3.2 Relief Reouest. V-53 (V-54) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for the low head l safety injection pump seal water supply check valves 1-51-4, -21, 2-SI-6, and

-29 . The licensee proposes to partial-stroke exercise these valves open quarterly and full-stroke exercise the valver open each refueling outage.

Furthermore, the licensee proposed to verify reverse flow closure by sample i disassembly and inspection per the Generic Letter 89-04, Attachment 1, Position 2.  ;

3.2.3.2.1 Licensee's Basis for Reouestina Relief--These check  ;

valves cannot be full flow tested every quarter because the low head safety I injection pumps cannot be run at full flow until reactor refueling. Also,  !

they cannot be verified closed using flow. J 1

Alternate Testina: These valves will be partial flow tested every three  !

months and full flow tested every reactor refueling. l To verify closure, these valves will be grouped together and one valve from this group will be disassembled and inspected every reactor refueling. A different valve will be disassembled every reactor refueling.

3.2.3.2.2 Evaluation--From information supplied in Valve Relief Requests, V-38 for Unit One, and V-39 for Unit Two, TER Section 3.1.2.3, it is impractical to full-stroke exercise open these valves during power operation.

The low head safety injection pumps do not develop adequate discharge pressure 29

l to overcome 'RCS pressure and the recirculation flow path does not _ allow. full l design flow. It is impractical to full-stroke exercise these valves open

• during cold shutdown, with the RCS intact, because there is insufficient surge volume in the RCS and the potential exists for pressurized thermal shock and low temperature over pressure (LTOP) concerns. In order to perform this  !

testing during cold shutdown, the licensee would have to depressurize and drain the RCS to provide adequate surge volume. This could delay plant start-up. This would be costly and burdensome to the licensee. The licensee's proposal to partial-stroke exercise open these valves quarterly and full-stroke exercise open the valves at refueling outages should provide a reasonable assurance of operational readiness.

These valves have a safety function in the open and closed direction.

According to P&lD's supplied by the licensee, there are no test taps available to perform a leak /back flow test for these valves. The only practical way to ,

verify reverse flow closure is the use of non-intrusive diagnostics or sample  ;

disassembly and inspection. The. licensee proposed to verify reverse flow closure by sample disassembly and inspection according to Generic Letter 89-04, Attachment 1, Position 2. Position 2 states that "[t]he NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full stroke exercise open or of

- verifying closure capability, as permitted by IWV-3522." Therefore, provided 3 the guidance in Position 2 is followed, the alternative is approved per GL 89- >

04 for verifying the full-stroke (open/close) function of these valves. ~!

For the open direction, in accordance with OM-10, Paragraph 4.3.2.2(d), "if exercising is not practicable during plant operation and full-stroke during cold shutdowns is also not practicable, it may be limited to part-stroke .

during cold shutdowns, and full-stroke during refueling outages " Therefore, the implementation of part-stroke testing during cold shutdowns and full- '

stroke testing each refueling outage, based on the impracticality of performing testing during power operation and limiting testing to a part-stroke during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a >

(f)(4)(iv). The related requirements of 4.3.2.2(f), (g), and (h) must be met for the extension of the test interval.

3.2.3.3 Relief Reauest. V-38 (V-39) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for the low head  :

safety injection pump suction and discharge check valves,1(2)-SI-9,1-51-18, -

1-SI-26, 2-SI-19, and 2-SI-32. The licensee proposes to partial-stoke

• exercise. valves,1-SI-18 and 2-SI-19, quarterly with the mini-flow loop and full-stroke exercise the valves every reactor refueling outage. Valves 1(2)-SI-9, 1-SI-26, and 2-SI-32 will be full-stroke _ exercised open and closed each reactor refueling outage, not to exceed 24 months. I 3.2.3.3.1 Licensee's Basis for Reauestina Relief--Due to system -

design, check valves 1(2)-S1-9, 1-SI-26 and 2-SI-32 are not in the low head _ '

safety injection [LHSI] pump test flowpaths. They cannot be full or .

partial-stroke tested during power operation because the LHSI pumps cannot j overcome RCS pressure. Valves,1-SI-18 and 2-SI-19, can only be partial-stroked every quarter'because the quarterly test loop is a mini-flow -

loop. '

i i

I 30 l

a

1 During cold shutdown, the RCS pressure still prevents full flow testing I of the check valves. Partial-stroke exercising the valves with flow could cause an overpressurization condition during cold shutdowns.

To verify closure of Valves,1(a-SI-9,1-SI-26, and 2-SI-32, using back flow, the low head safety injection pumps must be tested at design conditions,  ;

which can only be done at reactor refueling. By achieving design conditions, adequate seat tightness is verified on the discharge valve to the non-running pump.

Alternate Testina: Valves,1(2)-SI-9,1-SI-26, and 2-51-32 will be exercised to the full open and closed position every reactor refueling (not to exceed 24 i months). Valves, 1-SI-18 and 2-SI-19 will be partial-stroke tested every quarter and full flow tested every reactor refueling.  :

3.2.3.3.2 Evaluation--Check valves 1(2)-S1-9,1-51-26, and 2-SI-32 are not located in the quarterly mini-flow path for testing the low i head safety injection pumps. These valves can only be full or partial-stroke exercised by injecting flow into the RCS (RCS). It is impractical to exercise r these valves during power operation because the low head safety injection >

pumps do not have sufficient discharge pressure to overcome RCS pressure.  !

During cold shutdown, full or partial-stroke exercising these valves with the RCS intact is impractical because the low head safety injection pumps develop sufficient head to raise pressurized thermal shock (PTS) concerns and possibly develop a low temperature overpressurization (LTOP) situation. In order for the licensee to meet the Code required test frequency the system would require design changes and modifications. These changes and modifications would be i burdensome to the licensee. Check valves 1(2)-SI-9, 1-SI-26, and 2-SI-32 need to be verified closed. Closure verification of these valves with back flow can only be done with the safety injection pumps running at full design flow.  !

This can only be accomplished at refueling outages because of insufficient  !

developed head during power operations and LTOP concerns when in cold shutdown. The licensee's proposal to full-stroke exercise open and closed valves 1(2)-51-9, ,1-SI-26, and 2-SI-32 at refueling outages is acceptable. In  :

accordance,with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable '

during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each  ;

refueling outage, based on the impracticality of performing testing during  ;

power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of  !

the test interval. l Check valves 1-SI-18 and 2-SI-19 are located in the mini-flow path which  !

provides for quarterly pump testing. Because this path is a mini-flow path, t these valves are only partial-stoke exercised quarterly during pump testing.  ;

Pump testing-is not performed during cold shutdown conditions unless the plant ,

is in an extended outage; therefore, it would be impractical to perform a  :

part-stroke or a full-stroke of these valves during cold shutdown conditions -!

except when pump testing can be performed. The licensee's proposal to  ;

partial-stroke exercise valves 1-SI-18 and 2-51-19 during power operation and  !

full-stroke exercise the valves at refueling outages is acceptable. In  ;

accordance with OM-10, Paragraph 4.3.2.2(b), "if full-stroke exercising during 31 1

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

t O.

k plant operation is not practicable it may be limited to nart-stroke during +

plant operation and full-stroke during cold shutdowns," and Paragraph ,

4.3.2.2(d), "if exercising is not practicable during plant operation and full-  !

stroke during cold shutdowns is also not practicable, it may be limited to  !

part-stroke during cold shutdowns, and full-stroke during refueling outages."  !

The licensee's proposed test frequency is a combination of these two  ;

requirements. Therefore, the implementation of part-stroke testing during t power operation and full-stroke testing each refueling outage, based on the

. impracticality of performing full-stroke testing during power operation and '

cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). l The related requirements. of 4.3.2.2(f), (g), and (h) must be met for the l extension of the test interval.

P 3.2.3.4 Relief Recuest. V-39 (V-40) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for the refueling (

water storage tank (RWST) supply to charging pump suction header check valves l-SI-47 and 2-S1-18. The licensee proposes- to partial-stroke exercise these valves open and verify reverse flow closure at cold shutdown. They propose to  ;

full-stroke exercise the valves open at refueling outages.  !

3.2.3.4.1 Licensee's Basis for Recuestino Relief--Full or partial-stroke exercising these valves during power operation would require >

charging pump suctions be aligned with the Refueling Water Storage Tank. This alignment would cause a sudden increase in RCS Boron Inventory. Full ' flow for i the charging system can only be established during reactor refueling when the RCS is depressurized. j

^

To verify valve closure, the refueling water storage tank must be isolated which is a violation of Technical Specification 3.1.2.1.b during normal operation. -

Alternate Testino: E;:ercising to the partially open and closed positions i during cold shutdown, exercise to the full open position every reactor .'

refueling.  ?

3.2.3.4.2 Evaluation--It is impractical to full or partial-stroke  :

exercise these valves open or verify reverse flow closure during power-operations. In order to exercise the valves to the open position, the charging' pump suction must be~ aligned to the RWST. Aligning the charging pump .

suctions to the RWST, during power operations, would inject highly concentrated boric acid into the RCS causing power transients and a possible  !

reactor shutdown and/or-trip. Verifying reverse flow closure of these valves, during power operations,.would require isolating the RWST from the charging pumps. This would be a violation of plant Technical Specification 3.1.2.1.b.  ;

Full-stroke exercising these valves at cold shutdown would create a t concern for LTOP conditions and could cause possible pressurized thermal shock l (PTS) to the reactor vessel. The system would require design changes and modifications to perform the testing at the Code required frequency. These  :

changes and modifications would be burdensome to the licensee. The licensee.

proposes to partial-stroke exercise these valves open and verify reverse flow l closure during cold shutdown. Further, they proposes to full-stroke exercise  ;

the valves open every refueling outage. i l

32

J In accordance with OM-10, Paragraph 4.3.2.2(d), "if exercising is not practicable during plant operation and full-stroke during cold shutdowns is also not practicable, it may be limited to part-stroke during cold shutdowns, and full-stroke during refueling outages." Therefore, the implementation of part-stroke testing during cold shutdowns and full-stroke testing each refueling outage, based on the impracticality of performing testing during power operation and limiting testing to a part-stroke during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(f), (g), and (h) must be met for the extension of the-  ;

test interval.

3.2.3.5 Relief Recuest. V-42 (V-43) requests relief from the test frequency requirements of Section X1, Paragraph IWV-3521'for accumulator  ;

discharge and cold leg injection check valves, 1-SI-125, -127, -142, -144, '

-159, and -161 for Unit One and 2-SI-151, -153, -168, -170, -185, and -187 for '

Unit Two. The licensee proposes to exercise the valves at refueling outages -

using sample disassembly and inspection for open verification and a back flow 1 test for reverse flow closure verification. The test methodology for the proposed relief is discussed separately in Section 3.2.3.6.

3.2.3.5.1 Licensee's Basis for Recuestina Relief--These valves cannot be partial or full flow tested during normal operation because the ,

accumulator pressure (600 to 650 psig) is below RCS pressure and the injection of borated water would upset the reactor coolant chemistry. -

During cold shutdown, the RCS pressure may still prevent full flow testing. Also, discharging the accumulators would challenge the Low  ;

Temperature Overpressure Protection System.

t To verify valve closure using back flow for Valves 1-S1-125, -142, -159, j for Unit One, and 2-SI-151, -168, and -185 for Unit Two a containment entry r must be made to manually manipulate the test configuration. The accumulators i must be isolated to verify closure using back flow for all six valves. The i small increase in . safety gained by performing the back seat check valve tests  !

every cold shutdown versus every reactor refueling does not justify the added burden of the increased test frequency.

Alternate Testina: These valves were placed into two groups. Valves 1-SI-144, -161 are in one group and Valves 1-SI-125, -127, -142, and.-159 are  ;

in the other group for Unit One. For Unit Two, Valves 2-S1-170 and -187 are in  ;

one group and Valves 2-51-151, -153, -168, and -185 are in the other group.

Because 1-SI-144 and -161 and 2-SI-170 and -187 are downstream from RHR, they experience different service conditions than the other valves. To verify that ;

these valves will stroke to the open position, one valve from each group will  !

be disassembled and inspected every other refueling outage. Inspecting one [

valve every other refueling outage is a deviation from the frequency of  !

inspection described in Generic Letter 89-04, Position 2. Justification for-going to an extended inspection interval is provided below.  !

All six S1 accumulator check valves in each unit were inspected after 8 years of service and were observed to be in "like new condition." However, an t inspection report was generated for only one of the six valves from each unit. '

During the following outage for Unit 2 (1990 outage), the one documented valve i from the previous outage was disassembled and inspected, along with one valve -  ;

e 33  !

~

from the other group. Both valves were found to be in "like new condition."

Because no degradation was detected, it can be concluded that the valves in each group for Units 1 and 2 are in' good condition and that an extended interval is justified for both Units 1 and 2.

The "like new condition" of these valves is expected because during normal operation they remain closed and are subject to low flow conditions only during reactor refueling when a partial flow test is performed and when RHR is operating.

Given the lack of degradation observed in the SI accumulator discharge check valves, disassembling these valves presents a hardship with no compensating increase in safety. The average dose received during the disassembly and inspection for the check valves farthest from the accumulator (Valves 1-SI-127, -144, and -161 for Unit I and Valves 2-SI-153, -170, and

-187 for Unit 2) was from 1500 to 2000 mrem per valve, and the average dose for the check valves nearest to the accumulator (Valves 1-SI-125, -142, and

-159 for Unit 1 and Valves 2-SI-151, -168, and -185 for Unit 2) was approximately 400 mrem per valve. To open the valves, the vessel inventory must be reduced which can significantly increase the dose rate for areas near the vessel and increase the probability and consequences of a. loss of decay heat removal. Generic Letter 88-17 addresses the problems associated with loss of decay heat removal. Because of the increased dose rate, most work in the vessel area must be delayed until the vessel is refilled.

The use of non-intrusive monitoring techniques may still be evaluated.

If the evaluation is performed and if it shows that the full-stroke of the check valve can be verified and documented, one Si accumulator discharge line will be flow tested every reactor refueling. During every reactor refueling, a different line will be tested. If the flow test is successful, these valves will not be subject to disassembly.

These valves will be individually confirmed closed by back seat testing

! every reactor refueling.

3.2.3.5.2 Evaluation--It is impractical to full or partial-stroke !

exercise these valves open during power operations. The safety injection i accumulators are pressurized to 600 to 650 psig which is insufficient pressure to overcome RCS pressure. It is impractical to full or partial-stroke exercise these valves during cold shutdown with the RCS intact. The potential exists to create an LTOP situation and challenge the Low Temperature Overpressure Protection System and/or cause pressud 7ed thermal shock (PTS).

In order to full-stroke exercise these valves open at the Code required  ;

frequency, the system would require design changes and modifications. These changes and modifications would be burdensome to the licensee.

However, it may be practical to part-stroke exercise these valves when shutting down the plant to the cold shutdown condition. Stabilizing RCS temperature (consistent with RCS pressure) with RCS pressure at approximately 600 to 650 psig, until a small level decrease is indicated in the safety injection accumulators with a stable or slight increase in RCS pressure would indicate a partial-stroke open of these valves. Further, the small amount of borated water injected would not adversely effect RCS chemistry since an increase in boron concentration is required for plant shutdown. The licensee 34

should investigate the possibility of performing a part-stroke exercise open for these valves when shutting down the plant to the cold shutdown condition.

The findings'should be documented in the IST program.

It is impractical to verify reverse flow closure during power operations because containment entry is required to perform the valve manipulations for the test. Containment ' entry during power operations is restricted because of high radiatior, levels and other personnel safety. hazards. During cO d shutdown, the licensee would have to perform valve manipulations and set up.

the test equipment to perform the test. A reverse flow closure test is a non-routine test requiring planning, special plant modes and elaborate test configuration. Performance of this test at cold shutdown could delay plant start-up. This would be burdensome to the licensee. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling -

outages." Therefore, the. implementation of testing each refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

3.2.3.6 Relief Reauest. V42 (V43) (continued) The licensee requests relief from the test methodology of Section XI, Paragraph IWV-3522 for accumulator discharge and cold leg injection check valves, 1-SI-125, -127,

=-142, -144, -159, and -161 for Unit One and 2-SI-151, -153, -168, -170, -185, and -187 for Unit Two. The licensee proposes to use sample disassembly and inspection to verify full-stroke open capability of these valves and propose to extend the sampling interval.

3.2.3.6.1 Licensee's Basis for Reauestino Relief--These valves cannot be partial or full flow testeo during normal operation because the accumulator pressure (600 to 650 psig) is below RCS pressure and *.he injection of borated, water would upset the reactor coolant chemistry.

During cold shutdown, the RCS pressure may still prevent full flow testing. Also, discharging the accumulators would challenge the Low Temperature Overpressure Protection System.

To verify valve closure using back flow for Valves 1-SI-125, -142, -159, for Unit One, and 2-SI-151, -168, and -185 for Unit Two a containment entry must be made to manually manipulate the test configuration. The accumulators must be isolated to verify closure using back flow for all six valves. The small increase in safety gained by performing' the back seat check valve tests every cold shutdown versus every reactor refueling does not justify the added burden of the increased test frequency.

Alternate Testing: These valves were placed into two group:,. ' val ves 1-SI-144, -161 are in one group and Va!ves 1-SI-125, -127, -142, and -159 are in the other group for Unit One. For Unit Two, Valves 2-51-170 and -187 are in one group and Valves 2-51-151, -153, -168, and -185 are in the other group.

Because 1-SI-144 and -161 and 2-S1-170 and -187 are downstream from RHR, they experience different service conditions than the other valves. To verify that 35

.. ~

-i i

r

~

these valves will stroke to the open position, one valve from each group will  !

- be disassembled and inspected every other refueling outage. Inspecting one i valve every other refueling outage is a deviation from the frequency of inspection described in Generic Letter 89-04, Position 2. Justification for going to an extended inspection interval is provided below.  :

All six Si accumulator check valves in each unit were inspected afte'r 8 years of service and were observed to be in "like new condition." However, an l ,

inspection report was generated for only one of the six valves from each unit. l During the following outage for Unit 2 (1990 outage), the one documented valve t from the previous outage was disassembled and inspected, along with one valve i from the other group. Both valves were found to be in "like new condition." i Because no degradation was detected, it can be concluded that the valves in i each group for Units I and 2 are in good condition and that an extended j interval is justified for both Units 1 and 2. ,

The "like new condition" of these valves is expected because during  !

normal operation they remain closed and are subject to low flow conditions ,

only during reactor refueling when a partial flow test is performed and when t RHR is operating.

• Given the lack of degradation observed in the S1 accumulator discharge f check valves, disassembling these valves presents a hardship with no compensating increase in safety. The average dose received during the disassembly and inspection for the check valves farthest from the accumulator (Valves 1-51-127, -144, and -161 for Unit I and Valves 2-SI-153, -170, and

-187 for Unit 2) was from 1500 to 2000 mrem per valve, and the average dose for the check valves nearest to the accumulator (Valves 1-S1-125, -142, and .

-159 for Unit 1 and Valves 2-SI-151, -168, and -185 for Unit 2) was  ;

approximately 400 mrem per valve. To open the valve.s, the vessel inventory ,

must be reduced which can significantly increase the dose rate for areas ~near '

the ves:e1 and increase the probability and consequences of a loss of decay heat removal. Generic Letter 88-17 addresses the problems associated with-loss of decay heat removal. Because of the increased dose rate, most work in a

the vessel area must be delayed until the vessel is refilled.

The use of non-intrusive monitoring techniques may still be evaluated. l If the evaluation is performed and if it shows that the full-stroke of the  !

check valve can be verified and documented, one SI accumulator discharge line l will be flow tested every reactor refueling. During every reactor refueling, a different line will be tested. If the flow test is successful, these valves i will not be subject to disassembly. l These valves will be individually confirmed closed by back seat testing I every reactor refueling. j 3.2.3.6.2 Evaluation--The licensee divided these valves into two  !

groups for each unit and proposed to sample disassemble and inspect these -

valves per the Generic Letter 89-04, Attachment 1, Position 2, with the I exception of extending the test interval to every other refueling outage. The I licensee's basis for extreme hardship to cxtend the interval appears to be '{

adequate. The reduction of radiation doses received (ALARA Program) and the added concern for loss of decay heat removal with low reactor vessel levels, situations which occur because of the disasserrSly and inspection, are valid j 36 i i

i y

'[

' ' t concerns. However, Generic Letter 89-04, Attachment 1, Position 2, describes [

certain guidelines in order to extend the inspection. interval which are-not- l addressed in the relief request. The licensee should ensure that each of the j items listed in Pos'ition'2 are -reviewed, documented in the IST program, and  :

available for inspection by NRC. The use of a sample disassembly and  :

inspection program in accordance with the guidelines of GL 89-04, Attachment .!

1, Position 2, is approved per GL 89-04. t The use of non-intrusive diagnostic techniques to determine that a check l valve opens sufficiently to pass maximum required accident flow during L partial-stroke exercising or closes fully to prevent backflow is considered an -

acceptable -"other means" to meet the Code requirements. If the licensee's 1 evaluation shows that this method is acceptable, then sample disassembly and j inspection is not needed. In order to implement. a sampling program for i testing using nonintrusive techniques, during the first refueling outage, all .i valves in the selected group are to be tested to verify the techniques verify  !

valve obturator movement. During subsequent refueling outages, flow testing l

is required for all valves in the group, but the nonintrusive techniques need i be applied to only one valve in the group, on a rotating basis, unless  !

indications of problems are identified, in which case all valves should be j subjected to the nonintrusive techniques. If the licensee determines that  :

nonintrusive techniques can be used, relief is not required for the test  !

method, as the techniques are considered in accordance with the Code.

However, the sampling nonintrusive schedule must be described in the IST i 4

program and is subject to review. The extended test frequency to refueling  !

outages is in accordance with OM-10 (see Section 3.2.3.5 above).

3.3 Component Coolina Water System j 3.3.1 Cateaory A/C Valves 3.3.1.1 Relief Reouest. V-3 (V-3) requests. relief from the test i frequency requirements of Section XI, IWV-3521 for the component cooling water 1 supply to RCP auxiliaries containment isolation check valves 1-CC-84, -119, l and -154 fpr Unit One and 2-CC-78, -115, and -152 for Unit Two . The licensee  ;

proposes to verify reverse flow closure capability each refueling outage. l 3.3.1.1.1 Licensee's Basis for Reouestina Relief--These check i valves must seat upon reversal of flow in order to fulfill their safety functions. The only exercise method to verify this actuation is to perform a '

leak rate test /back pressure test. A part-stroke exercise test during plant operation is not possible. Since the valves are located inside containment

• and/or their systems are required during power operation, they cannot be tested every three months. i Alternate Testina: Exercise for operability each refueling (not to exceed 24 '

months).

3.3.1.1.2 Evaluation--These are simple check valves which must l seat upon reversal of flow to perform their safety function. These valves are  ;

located inside containment or in cooling systems that are vital during plant ~ '

operation. It is impractical to verify reverse flow closure of these valves i during power operation because containment entry is required and/or isolating l a vital cooling system would be necessary. Containment entry is restricted j 37  :

i l

4

?

during power operation because of high radiation levels and other personnel safety hazards. Isolating vital cooling to various vital components, such as, reactor shroud cooling coils and RCP services, could cause plant transients  ;

and/or plant shutdown. A leak /back flow test is a non-routine test requiring l planning, special plant modes, and an elaborate test configuration.  ;

Performance of this test at rold shutdown could delay plant start-up. This  ;

would be burdensome to the licensee. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold '

shutdowns, it may be limited to full-stroke daring refueling outages." "

Therefore, the implementation of testing each refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The ,

related requirements of 4.3.2.2(h) that "all valve testing required to be .

performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval. .

3.3.1.2 Relief Reauest. V-62 (V-63) requests relief from the test '!

frequency requirements of Section XI, Paragraph IWV-3521 for the component cooling water supply to air cooling coils containment isolation check valves, t

1-CC-546, -559, and -572 for Unit One and 2-CC-276, -289, and -302 for Unit Two. The licensee proposes to verify reverse flow closure for the valves each refueling outage, not to exceed 24 months.

3.3.1.2.1 Licensee's Basis for Reouestino Relief--These check valves must seat upon reversal of flow in order to fulfill their safety 3 functions. The only exercise method to verify this actuation is to perform a leak rate test /back pressure test which would involve isolating the containment air cooling coils. The containment recirculation air cooling coils are required for normal operation to maintain containment temperature  ;

below technical specification limits. Therefore, these valves cannot be  ;

tested every three months. They will be exercised only.during refueling  !

outages because the small increase in safety gained by testing during cold  ;

shutdown does not justify draining the lines and performing a leak rate test.  !

Alternate Testina: Exercise for operability every reactor refueling (not to exceed 24 months)  !

t 3.3.1.2.2 Evaluation--These check valves must seat upon reversal of flow to perform their safety function. The only practical method to verify reverse flow closure capability is to perform a leak rate /back flow test.

This requires isolating the containment air cooling coils. It is impractical to verify reverse flow closure of these valves, during power operation, t because isolating containment air cooling coils for an undetermined amount of i time while testing occurs could allow the containment temperature to exceed technical specification limits. A leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. -

- Performance of this test at cold shutdown could delay plant start-up. This  !

would be costly and burdensome to the licensee. The licensee's proposal to  !

exercise these valves for operability each refueling outage, not to exceed 24 ,

months, is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if l exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown 38 4

~

)

I

p ':

p.  ;

l

-l

' ~ -!

1 conditions, is approved pursuant to 10 CFR 59.55a-(f)(4)(iv). The related -

requirements of 4.3.2.2(h) that "all valve testing required to be performed  :

during a refueling outage shall be completed prior to returning the plant to .{

operation" must be met for'the extension of the test interval.

3.3.1.3 Relief Request. V-70 (V-71) requests relief from the test  ;

frequency requirements of Section XI, Paragraph IWV-3521 for the component  !

cooling water supply to the RHR heat exchangers check valves 1-CC-193 and -198  :

for Unit One and 2-CC-194 and -199 for Unit Two. The licensee proposes to  :

verify reverse flow closure each refueling outage, not to exceed 24 months.  ?

They propose to part-stroke exercise open these valves quarterly and l full-stroke exercise the valves open when the reactor vessel is defueled.  !

i 3.3.1.3.1 Licensee's Basis for Reauestino Relief--Valves 1-CC-193, 1-CC-198, 2-CC-194, and 2-CC-199 are check valves in the component  ;

cooling lines to the RHR heat exchangers and must close for isolation and open '

to allow RHR flow. The only exercise method to verify closure is to perform a  ;

leak rate test /back pressure test. These lines cannot be drained for back '

seat testing because the RHR system is needed during cold shutdown to control the RCS temperature.  !

i To establish full flow through Valves 1-CC-193,1-CC-198, 2-CC-194, and l 2-CC-199 for testing to the full open position, increased component cooling flow must be directed through the RHR heat exchangers. During cold shutdown ,

and reactor refueling when fuel is in the vessel, increased flow to the RHR  ;

heat exchangers reduces the volume of the RCS inventory by reducing the RCS l temperature. This reduction in volume can be large enough as to cause  ;

excessive make up demands to the RCS. Therefore, the full flow test should be ,

perfermed during reactor refueling when the vessel is defueled.  ;

Alternate Testina: Exercise for closure each refueling (not to exceed 24  !

months) and full open every reactor refueling when the vessel is defueled. l Partial-stroke open every quarter.

3.3.1.3.2 Evaluation--These check valves perform a safety i function in the open and closed position. The only practical method to verify  ;

reverse flow closure of these valves is to perform a leak rate /back flow test. ,

A leak rate /back flow test is a non-routine test requiring planning, special ,

plant modes, and an elaborate test configuration. These requirements would  !

result in the RHR system being out of service for an undetermined amount of .

,. time. Should the need for an immediate shutdown and cooldown occur and a  :

L single failure of the other RHR system occur, the licensee could be in an >

unanalyzed condition. Therefore, it is impractical to perform a reverse. flow ,

closure test during power operations. A leak rate /back flow test is extremely. l time consuming. The performance of this test at cold shutdown could delay l plant start-up. This would be burdensome to the licensee. The licensee's

• l proposal to verify reverse flow closure each refueling outage, not to exceed i 24 months, is acceptable. For the closure verification, in accordance with j OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant '

operation or cold shutdowns, it may be limited to full-stroke during refueling  :

outages." Therefore, ne implementation of testing each refueling outage, '

based on the impractica ity of performing testing during power operation or  ;

during cold shutdown conoitions, is approved pursuant to 10 CFR 50.55a  :

(f)(4)(iv). The related requirements of 4.3.2.2(h) th'at "all valve testing 39 i .i l l t

=

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

i required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

The licensee is partial-stroke exercising these valves open quarterly.

However, the licensee proposes to full-stroke exercise these valves open when the reactor vessel is defueled. There is no frequency or time interval for ,

defueling the reactor vessel other than at least once per 120 months for inservice inspection requirements. The relief request does not indicate whether the reactor is defueled each refueling outage, or any other outage ,

other than the outage for vessel inspection. Relief cannot be granted for an '

unspecified time interval. The licensee's partial-stroke exercise, quarterly,  :

provides some assurance of operational readiness for the interim period.  !

However, since the licensee has not specified how often the reactor vessel will be defueled, and thereby indicated an interval for a full-stroke exercise, the licensee's proposal is inadequate for the long term.

The licensee's proposal to verify a full-stroke of these valves when the reactor vessel is defueled is inadequate for long-term relief. Interim relief, however, is appropriate based on the partial-stroke exercise and the closure verification being performed. Immediate imposition of the Code requirements would, therefore, be a hardship without a compensating benefit in  !

safety for an interim period. Pursuant to 10 CFR 50.55a (a)(3)(ii), interim  ;

relief shou') be granted for a period of one year or until the next refueling  !

outage, whichever is later, to allow the licensee time to reevaluate the i testing frequency and to resubmit the relief request.  :

3.3.2 Cateaory C Valves t

3.3.2.1 Relief Reauest. V-65 (V-66) requests relief from the test  ?

frequency requirements of Section XI, IWV-3521 for the component cooling water i supply to the RCP thermal barrier check valves 1-CC-111, -146, and -181 for i Unit One and 2-CC-107, -144, and -181 for Unit Two The licensee proposes to  ;

verify reverse flow closure each refueling outage. '

4 -

3.3.2.1.1 Licensee's Basis for Reauestina Relief--These check l valves must be locally back pressure tested to verify closure. Since the valves are located inside containment, they cannL be back pressure tested during normal operation. The valves will be tested every refueling outage l because the small increase in safety gained by testing during cold shutdown i does not justify performing a back pressure test. l Alternate Testina: Exercise to the close position every reactor refueling.

t 3.3.2.1.2 Evaluation--It is impractical to verify reverse flow -j closure of these valves quarterly, during power operation, because containment entry is required to perform the back flow test. Containment entry is restricted during power operation due to high radiation levels and other personnel safety hazards. A leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration.

Performance of this test at cold shutdown could delay plant start-up. This would be costly and burdensome to the licensee. The licensee's proposal to verify reverse flow closure of these valves each refueling outage is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is 40 1

i

l i

not practicable during plant operation or cold shutdowns, it may be limited-to 'l full-stroke during refueling outages." Therefore, the implementation of i testing each refueling outage, based on the impracticality of performing l testing during power operation or during cold shutdown conditions, is approved l pursuant to 10 CFR 50.55a-(f)(4)(iv). The related requirements of 4.3.2.2(h) that."all valve testing required to be performed during'a refueling outage ,

shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

3.4 Reactor Coolant System i 3.4.1 Cateaory A/C Valves f

3.4.1.1 Relief Reauest. V-28 (V-28) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for the primary grade ,

water supply to RCP seal standpipe containment isolation check valves 1-RC-149 and 2-RC-162. The licensee proposes to exercise these valves for operability i each refueling outage not to exceed 24 months.

3.4.1.1.1 Licensee's Basis for Reauestina Relief--These check valves must seat upon reversal of flow in order to fulfill their safety -

function. The only method to verify this actuation is to perform a leak rate l test. Since these valves are located inside containment, they cannot be <

tested every three months. A part-stroke exercise test during normal l' operation is not possible. 1-RC-149 and 2-RC-162 are in the primary grade water to pressurizer relief tank and the #2 seal stand pipes. This line 1 cannot be drained during short cold shutdowns because the PRT [ pressurizer l relief tank] is required during normal cold shutdowns. Standpipe level must r be maintained when the RCS [ reactor coolant system] is pressurized to control  !

leakage. These valves will be exerri*:d only during refueling outages because the small increase in safety gained by testing during cold shutdown does not justify draining lines and performing a leak rate test.

Alternate Testing: Exercise for operability each refueling (not to exceed 24 months) .

3.4.1.1.2 Evaluation--These are simple check valves located '

inside containment and must seat upon reversal of flow to perform their safety t function. According to the P&ID's, the only practical method to verify reverse flow closure is to perform a leak rate test. It is impractical to perform this test during power operation because these valves are located i inside containment. Containment entry is restricted during power operation i because of high radiation levels and other personnel safety hazards. A leak l rate /back flow test requires planning, special plant conditions, and an .!

elaborate test configuration. The performance of this test at cold shutdown could delay plant start-up. This would be burdensome and costly to the licensee. The licensee's proposal to verify reverse flow closure each ,

refueling outage, not to exceed 24 months, is acceptable. In accordance with-OM-10, Paragraph 4.3.2.E'e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling 4 outages." Therefore, the 1mplementation of testing each refueling outage,

-based on the impracticality of performing testing during power operation or i during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a l

(f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing 1

41 ,

- required to be performed during a refueling outage shall be completed prio'r to ,

returning the plant to operation" must be met for the extension of the test i interval. '

3.4.2 Cateaory B Valves 3.4.2.1- Relief Reauest. V-57 (V-58) requests relief from the test i frequency requirements of Section XI, Paragraph IWV-3411 for the reactor >

vessel head and pressurizer vent valves listed in the following table. The  !

licensee proposes to exercisethe valvesfor operability during cold shutdown  ;

when the RCS is depressurized but not more frequently than once every three months.

i Unit One Unit Two 1-RC-SOV-10]A-1 2-RC-S0V-201A-1 I l-RC-SOV-101A-2 2-RC-S0V-201A-2 1-RC-S0V-1018-1 2-RC-SOV-2018-1 ,

1-RC-SOV-1018-2 2-RC-SOV-201B-2 1-RC-S0V-102A-1 2-RC-SOV-202A-1 -

1-RC-50V-102A-2 2-RC-S0V-202A-2 4 1-RC-SOV-102B-1 2-RC-SOV-202B-1 .

1-RC-S0V-1028-2 2-RC-S0V-2028-2 I t

3.4.2.1.] Licensee's Basis for Reouestina Relief--These vilves are the Reactor Vessel. Head and Pressurizer Vent Valves. Full or pa t-stroke i exercising these valves at power would relvase reactor coolant into the  :

reactor vessel refueling cavity. These vaives will be exercised during cold 1 shutdown when the RCS is depressurized.

- Alternate Testina: Exercise for operability during cold shutdown when the RCS- l is.depressurized (but not more frequently than once per three months), t 3.4.2.1.2 Evaluation--These valves are solenoid operated vent valves which relieve RCS pressure to the reactor vessel refueling cavity / containment atmosphere. These valves are set in an arrangement with two valves in series which is then in parallel with two other valves in .

series. They are susceptible to line pressure surges. Exercising these '

valves quarterly, during power operations, would be impractical because of the

• possibility of burping the other in-series valve. This unintentional lifting of the other in-series valve could release reactor coolant to the containment atmosphere increasing the contamination levels. Exercising these valvet '

during cold shutdowns would require depressurizing the RCS each cold shutdown.

Depressurizing the RCS each cold shutdown would delay plant startup and would  :

be burdensome to the licensee. The licensee proposes to exercise these valves during cold shutdowns when the RCS is depressurized, but not more frequently than once every three months. This proposed frequency is not in accordance ,

with Code requirements; however, the proposal should provide a reasonable assurance of operational readiness for these valves. j However, while in cold shutdown with the RCS intact and at a reduced RCS pressure, exercising these valves, one at a time, is less likely to affect the  ;

42 I s

4

other in-series valve with pressure surges large enough to cause inadvertent opening. The licensee should investigate the possibility of exercising these valves each cold. shutdown, but not more frequently than once every three 4 months. If the valves are tested each cold shutdown, this relief request should be changed to a cold shutdown justification.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the licensee's proposal, relief  ;

should be granted as requested pursuant to 550.55a j(f)(6)(i).

3.4.3 Cateaory B/C Valves 3.4.3.1 Relief Reouest. V-27 (V-27) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for the pressurizer  ;

power operated pressure control valves 1-RC-PCV-1455C and -1456 for Unit One and 2-RC-PCV-2455C and -1456 for Unit Two. The licensee proposes to exercisethe valvesduring cold shutdowns when the RCS is depressurized. .

3.4.3.1 1 Licensee's Basis for Reouestina Relief--Full or part-stroke exercising these valves during power operations would cause high ,

differential pressure across the PCV Block Valves. Although these valves are designed to accommodate this differential pressure, cycling would eventually degrade the block valves seating capability, thus decreasing plant safety.

Also, the valve controllers do not allow for a part-stroke exercise test.

These valves will be exercised during shutdowns when the RCS is depressurized. -

Alternate Testina: Exercise for operability during cold shutdowns when the 3 RCS is depressurized. '

3.4.3.1.2 Evaluation--During cold shutdowns, the RCS is at a '

reduced pressure to prevent PTS concerns, low temperature overpressure situations, and exceeding NDT [ nil ductillity temperature] limits. Although the RCS is not depressurized, the lower RCS pressure should not create a large enough differential pressure to dE jrade the seating capability of these valves. These valves should be exercised every cold shutdown but not more than once every 3 months. '

Based on the determination that the licensee has not shown hardship, burden or impracticality, relief should be denied. The licensee should exercise these valves according to the Code and withdraw this relief.

3.5 Chemical and Volume Control 3.5.1 Cateaory A Valves 3.5.1.1 Relief Reouest. V-9 (V-9) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for reactor coolant pump seal water return containment isolation valves, 1-CH-MOV-1380 and -1381 for Unit One, and 2-CH-MOV-2380 and -2381 for Unit Two. The licensee proposes to exercisethe valvesevery cold shutdown when the reactor coolant pumps are ,

secured and the RCS pressure is above 100 psig. ,

3.5.1.1.1 Licensee's Basis for Reouestina Relief--Charging flow to the reactor coolant pump seal t is required at all times while the pumps are 43

a in operation. Fail %re of one of these valves in the closed position could  ;

result in damage to the reactor coolant pump seal, thus placing the plant in .

an unsafe condition. Also, the valve controllers do not allow for a l

part-stroke exercise test. The reactor coolant pumps must be secured and i reactor coolant pressure must be above 100 psig to perform the exercise tests.

Alternate Testina: Exercise every cold shutdown when the reactor coolant ,

pumps are secured and reactor coolant pressure is above 100 psig. .

3.5.1.1.2 Evaluation--It is impractical to exercise these valves, during power operations, because it would isolate seal return from the reactor coolant pumps. Isolating seal return from the reactor coolant pumps (RCPs),

could possibly damage the RCP seal. A damaged or leaking RCP seal is actually a small break loss of coolant accident (LOCA) These valves full-stroke on i initiation signal and, therefore, a partial-stroke exercise is not possible.  ;

The full-stroke exercise of these valves require that the RCPs be secured. .

Securing RCPs every cold shutdown would require decay heat operations, different plant configurations, and other procedural and operational concerns.

This would be burdensome to the licensee. The licensee's proposal to exercise '

these valves every cold shutdown when the RCPs are secured and the RCS ,

pressure is greater than 100 psig should provide a reasonable assurance of operational readiness. The proposed frequency is not in accordance with Code requirements.

Based on the determination that compliance with the Code requirements is I impractical and burdensome, and considering the licensee's proposal, relief should be granted as requested pursuant to 650.55a 1(f)(6)(i).

3.5.2 Cateaory A/C and C valves f

i 3.5.2.1 Relief Reauest. V-10 (V-10) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for charging water containment isolation check valves, 1-CH-322, -330, -336, -358, -380, and -402 for Unit One, and 2-CH-260, -284, -308, -331, -332, and -335 for Unit Two.

These valves are located in the following systems, normal charging line, RCP seal water supply lines, and RCP seal water return line. The licensee proposes to exercise these valves every refueling outage, not to exceed 24 months.

3.5.2.1.] Licensee's Basis for Reauestina Relief--These check valves must seat upon reversal of flow in order to fulfill their safety functions. The only method to verify this actuation is to perform a leak rata /back pressure test. A part-stroke exercise test during plant operation is not possible. Since the valves are located inside containment and/or their systems are required during power operation, they cannot be tested every three months. 1-CH-322 and 2-CH-335 are in the normal charging line to the RCS.

These lines cannot be drained during short cold shutdowns because charging ,

flow is often maintained. 1-CH-336, -358, and -380 (Unit One), and 2-CH-260,

-284, and -308 (Unit Two), are in the RCP seal water supply lines, and ,

1-CH-402 and 2-CH-331 are in the RCP seal water return lines. Seal flow is used during cold shutdown to reduce RCS leakage and float the RCP seals.

1-CH-330 and 2-CH-332 are the charging supply to loop fill header, inside containment isolation valves. The valves will be exercised only during refue'ing outages because the small increase in safety gained by testing 44 ,

. . .~ - -. .- . . - . . - - .

. I l

1

~

during cold shutdown does not justify draining lines and performing leak rate j tests, j l

Alternate Testino: Exercise for operability every refueling (not to exceed 24 i

/

months) 3.5.2.1.2 Evaluation--These are simple check valves located l inside containment or in systems required to be in operation during power  !

operations. Containment entry is restricted during power operation due to '

high radiation levels and other personnel safety hazards. Isolating systems, l such as, charging or RCP seal water injection / return, could adversely affect '  ;

plant operations by requiring plant shutdown due to loss of RCS inventory or {

RCPs being secured. Therefore, it is impractical to full or partial-stroke  ;

exercise these valves during power operation. These valves must seat upon '

loss or reversal of flow in order to perform their safety functions. The only practical method to verify reverse flow closure capability of these valves is  :

to perform a leak /back flow test. A leak /back flow test is a non-routine test  :

requiring planning, special plant modes, and an elaborate test configuration.

If these tests are performed at cold shutdown it could delay plant start-up. .

This would be costly and burdensome to the licensee. The licensee's proposal  !

to verify the reverse flow closure capability of these valves during every refueling outage, not to exceed 24 months, is acceptable. In accordance with ,

OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant  :

operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, .

based on the impracticality of performing testing during power operation or  !

during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test .

interval.  !

3.6 Instrument Air System 3.6.1 Category A/C Valves  !

i 3.6.1.1 Relief Reauest. V-21 (V-21) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for instrument air j inside containment isolation check valves,1-IA-55 and -149 for Unit One, and 2-IA-250 and -428 for Unit Two. The licensee proposes full-stroke exercising  ;

these valves each refueling outage, not to exceed 24 months.  !

3.6.1.1.1 Licensee's Basis for Reauestino Relief--These check l valves must seat upon reversal of flow in order to fulfill their safety '

functions. The only method to verify this actuation is to perform a leak- rate  ;

test. Since the valves are located inside containment, they cannot be tested l every three months. A part-stroke exercise test is not possible during plant  :

operation. 1-1A-55 and 2-IA-250 are_in the instrument air supply line to  :

containment. Testing these valves renders the instruments and components  :

supplied by instrument air inside containment inoperable. l They will be exercised only during refueling outages because the small increase in safety gained by testing during cold shutdown does not justify performing leak rate tests.  ;

45

1 Alternate Testina: Exercise for operability each refueling (not to exceed 24 months) 3.6.1.1.2 Evaluation--These are simple check valves, located inside containment, that must seat upon cessation or reversal of flow in order to perform their safety function. The only practical method to verify reverse ,

flow closure is to perform a leak /back flow test. It is impractical to full or partial-stroke exercise these valves, during power operations, because this would require containment entry. Containment entry is restricted during power operations due to high radiation levels and other personnel safety hazards. A ,

leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. If these tests are performed at cold shutdown it could delay plant start-up. This would be costly and burdensome to the licensee. The licensee's proposal to verify the reverse flow closure capability of these valves during every refueling outage, _not to exceed 24 months, is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages."

Therefore, the implementation of testing each refueling outage, based on the .

impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be I performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

3.6.2 Cateoory C Valves 3.6.2.1 Relief Reauest. V-64 (V-65), requests relief from the test i method of Section XI, Paragraph IWV-3522, for instrument air safeguard area ,

fans air receiver isolation check valves,1-IA-925, -926, -934, and -935 (Unit One), 2-IA-396, -397, -405, and -406 (Unit Two). The licensee proposes to  ?

back seat testthe valvesin groups.

3.6.2.1.1 Licensee's Basis for Reauestina Relief--To back seat these valves with flow to verify valve closure would require venting the lines upstream of the valves. The 1-IA-925, -926, 2-IA-396, and -397 valves are series with no vent valves in between, as are 1-IA-934, -935,'2-IA-405, and

-406. Therefore, there is no way to individually back seat these valves.

Alternate Testina: These valves will be back seat tested in groups. The test volume will be pressurized upstream of the two valves in series and vented downstream of the valves. If the group fails the back seat test, both valves in the group will be disassembled, inspected and repaired as necessary.

3.6.2.1.2 Evaluation--The relief request identifies that these -

valves are non-Code components. Therefore, NRC approval of the relief request i is not required for implementation.  ;

3.7 Service Water Systems '

3.7.1 Cateaory C Valves 3.7.1.1 Relief Recuest. V-63 (V-64) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for service water  :

46

• k pump discharge check valves,1(2)-SW-3,1(2)-SW-10,1-SW-22,' and 2-SW-24. The licensee proposes to partial-stroke test the valves open quarterly, and full-stroke exercisethe valvesopen and verify reverse flow closure capability  ;

every refueling outage. 1 3.7.1.1.1 Licensee's Basis for Reauestina Relief--These check  !

valves cannot be full flow tested during normal operation or cold shutdown ,

because the Recirculation Spray Heat Exchangers must be included in the flow i path in order for full flow conditions to be established. As described in .

Relief Requests V-45 and V-46, introduction of service water to the f Recirculation Spray Heat Exchangers is prohibited without subsequently e draining the heat exchangers. This requirement makes testing during normal  !

operation or cold shutdown impractical.

The verification of valve closure using back flow can only be performed when design flow is achieved during the service water pump tests. Verification of design flow for the running pump demonstrates adequate back seating for the discharge check valves of the non-running pumps. 4 i

Alternate Testina: These valves will be partial flow tested every three months and full flow and closure tested every reactor refueling.

3.7.1.1.2 Evaluation--These check valves are located at the discharge of the service water and auxiliary service water pumps. In order to full-stroke exercise these valves with design flow the recirculation spray heat exchangers, located inside containment, must be included in the flow path.

The licensee committed to the NRC to drain these heat exchangers whenever service water has been introduced into them. Containment entry during power operations is restricted because of high radiation levels and other personnel '

hazards. Therefore, it is impractical to full-stroke exercise these valves with design flow during power operations. Exercising these valves with design  !

flow during cold shutdown would require draining the recirculation spray heat

• exchangers. Draining these heat exchangers is a non-routine evolution ,

involving a large number of man-hours and equipment set-up. This could delay  !

plant star.t-up and be burdensome and costly to the licensee.

However, the licensee is partial-stroke exercising these valves quarterly. If during these partial-stroke tests, the licensee can verify that

• these check valves full-stroke then the licensee can use this test for a full-stroke exercise. The licensee should investigate into the use of diagnostics or some other means for verifying these check valves full-stroke during a partial-stroke test, t i

Verification of reverse flow closure for category C valves can be done by visual observation, by an electrical signal initiated by a position-indicating device, by observation of appropriate pressure indication in the system, by leak testing, or by other positive means. According to the licensee's P&lD's, there is a pressure transmitter upstream of the check valves being tested. When one or more of these service water pumps are idle, the idle pump's pressure transmitter can be compared to service water header '

pressure along with other indications to verify reverse flow closure of the idle pumps discharge check valve. The licensee should investigate an alternate method to verify reverse flow closure other~ than full design flow at  !

refueling outages and modify the testing schedule as appropriate.

47 i

f

i In accordance with OM-10, Paragraph 4.3.2.2(d), "if exercising is not ,

practicable during plant operation and full-stroke during cold shutdowns ~ is '

also not practicable, it may be limited to part-stroke during cold shutdowns,  :

and. full-stroke during refueling outages." Therefore, the implementation of part-stroke testing during cold shutdowns and full-stroke testing each  !

refueling outage, based on the impracticality of performing testing during ,

power operation and limiting testing to a part-stroke during cold shutdown j conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(f), (g), and (h) must be met for the extension of the test interval. ,

3 3.7.1.2 Relief Reauest. V-45 (V-46) requests relief from the test l frequency requirements of Section XI,. Paragraph IWV-3521 for service water  :

supply to recirculation spray heat exchanger check valves 1-SW-114, -116, 'j

-120, -130, -140, and -150 (Unit One); 2-SW-68, -70, -74, -84, -94, and -104 ';

for Unit Two. The licensee proposes exercisingthe valvesfor operability every  ;

refueling outage, not to exceed 24 months.

~

j 3.7.1.2.1 Licensee's Basis for Reauestino Relief--Full or '

part-stroke exercising these valves would flow service water into the . q recirculation spray heat exchangers. A commitment has been made to the NRC +

. prohibiting the introduction of service water into the recirculation spray heat exchangers without subsequently draining the heat exchangers. The .

logistics of this procedure make testing at cold shutdown impractical  !

considering the small increase in system safety gained from exercising.  :

Alternate Testino: Exercise for operability every refueling (not to exceed 24 ,

months) j 3.7.1.2.2 Evaluation--Full-stroke exercising ~these check valves  !

would allow service water to enter the recirculation spray heat exchangers, j which are located inside containment. The licensee has made a commitment to '

the NRC to drain these heat exchangers whenever they have been subjected to  ;

service water injection. It is impractical to full or partial-stroke exercise these valves during power operations because containment entry would be r required to drain and flush these heat exchangers. Containment entry is restricted during power operations due to high radiation levels and other i personnel hazards. Full or partial-stroke exercising these valves during cold shutdown would require draining and flushing these heat exchangers. This-is a ,

non-routine evolution requiring a large number of man-hours and equipment 1 set-up. This could delay plant start-up and be burdensome and costly to the licensee. The licensee's proposal to full-stroke exercise these valves during i refueling outages, not to exceed 24 months, is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during. plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.  ;

48

P 3.8 Recirculation Spray System 3.8.1 Cateaory A/C Valves 3.8.1.1 Relief Reauest. V-67 (V-68) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for outside recirculation spray pump and quench spray pump inside containment isolation check valves,1-RS-18 and -27, 2-RS-20 'and -30,1-QS-11 and -19, 2-0S-11 and

-22. The licensee proposes to exercise the valves to the open and closed

[

positions every reactor refueling outage. '

3.8.1.1.1 Licensee's Basis for' Reauestina Relief--These valves must seat to maintain containment integrity and open to allow flow to the containment spray headers. Partial or full flow testing these valves would flow water to the spray arrays and saturate containment. These valves can be mechanically exercised to the open and closed positions. However, the valves i are located inside containment and require the construction of scaffolding before they can be exercised. The small increase in safety gained by .

exercising the valves during cold shutdown does not justify the burden of '

constructing the scaffolding. These valves are containment isolation valves and are leak tested every reactor refueling.

Alternate Testina: These valves will be exercised to the open and closed positions every reactor refueling.

3.8.1.1.2 Evaluation--These valves have a safety function in both the open and closed direction. They must open to allow containment spray flow -

to the spray headers and close to provide containment integrity. Full or ,

partial-stroke exercisingthe valvesopen with flow would spray down containment, possibly causing equipment damage and creating a large clean-up effort. The licensee stated that these valves can be mechanically exercised open and closed.

e

^

These check valves are located inside containment. It is impractical to exercise these check valves during power operation because they require containment entry. Containment entry is restricted during power operations because of high radiation levels and other personnel safety hazards. In order to mechanically exercise these valves, scaffolding must be erected to reach the valves. The erection of scaffolding during cold shutdown requires a large number of man-hours and clean up when the scaffolding is removed. This could delay plant start-up and would be burdensome to the licensee. The licensee's proposal to mechanically exercise these valves open, closed, and leak test each reactor refueling outage is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke.during refueling outages." ,

Therefore, the implementation of testing each refueling outage, based on the '

impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The '

related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

49 i

- . .-~-. ~ n. - - -- - - - - -, -

f 3.8.2 Cateaory C Valves t 3.8.2.1 Relief Reouest. V-33 (V-33) requests relief from the test  ;

method as required by Section XI, Paragraph IWV-3522 for casing cooling pump  ;

discharge check valves 1-RS-123, -138, 2-RS-103, and -118. The licensee  :

proposes to groupthe valvesand disassemble and inspect one valve every  ;

refueling outage.  !

3.8.2.1.1 Licensee's Basis for Reouestino Relief--These check  !

valves must open and backseat in order to perform their safety functions. Due  ;

to system design, they are not in the casing cooling pump test flowpath.

Partial of full-stroke exercising these valves with flow would flood the containment sump.

l Alternate Testina: These valves will be grouped together and one valve from ,

this group will be disassembled and inspected every reactor refueling. A l different valve will be disassembled every reactor refueling.

• 3.8.2.1.2 Evaluation--These valves cannot be tested with flow  !

during power operations, during cold shutdowns, or during refueling outages without flood the containment sump. This testing could damage equipment and t would create a large clean-up effort, burdening the licensee. Because there is no practical means of full-stroking these check valves, the guidance in GL 89-04, Attachment 1, Position 2, may be applied as an acceptable alternative' and is approved by GL 89-04. The licensee should ensure that the guidance i delineated in Position 2 is followed. The implementation of the guidance is subject to NRC inspection.

l 3.9 Charaina System 3.9.1 Cateoory C Valves '

3.9.1.1 Relief Recuest. V-47 (V-48) requests relief from the test l frequency requirements of Section XI, Paragraph IWV-3521 for charging pump discharge check valves,1-CH-254, -267, and -279 (Unit One) and 2-CH-178, '

-193, and -208 (Unit Two). The licensee proposes to partial-stroke I exercisethe valvesopen quarterly, when the charging train is in service, and  ;

exercisethe valvesclosed each quarter. The licensee will full-stroke exercise these valves open every refueling outage.

j' 3.9.1.1.1 Licensee's Basis for Reauestino Relief--With present .

plant design, these valves can only be part-stroke exercised during power operation because the charging pumps cannot achieve design accident flow when pumping into the RCS at operating pressure. The only available flow path to i test these valves is into the RCS. During cold shutdown, exercising these  !

valves could result in overpressurization of the RCS and could force a safety  ;

system to function. l Alternate Testino: Exercise closed every three months and exercise full open every reactor refueling. Valves are partial exercised open during normal  !

operation when the charging train is in service.

3.9.1.1.2 Evaluation--It is impractical to full-stroke exercise these valves open during power operation. The charging pumps do not develop  !

50 1

sufficient head to inject design accident flow into the RCS at normal ,

operating pressure. These valves are partial-stroke exercised open when the charging train is in service. Furthermore, these valves are exercised closed .

quarterly.

Full-stroke exercising these valves during cold shutdown with the RCS_

intact could result in overpressurization of the RCS. This could cause a safety system to function or violate the RCS brittle fracture curves. The licensee would have to depressurize the RCS and set-up special test conditions to perform the Code required testing each cold shutdown. This could delay plant start-up and create a burden for the licensee. The licensee's proposal '

to verify closure and partial-stroke exercise the valves open quarterly, and full-stroke exercise the valves open each refueling outage, is acceptable. In -:

accordance with OM-10, Paragraph 4.3.2.2(d), "if exercising is not practicable during plant operation and full-stroke during cold shuto swns is also not practicable, it may be limited to part-stroke during cold shutdowns, and full-stroke during refueling outages." Therefore, the implementation of part-stroke testing during cold shutdowns and idll-stroke testing each refueling outage, based on the impracticality of performing testing during power operation and limiting testing to a part-stroke during cold shutdown t conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(f), (g), and (h) must be met for the extension of the test interval.

3.10 Vacuum Primina System 3.10.1 Cateaory A/C Valves l 3.10.1.1 Relief Reouest. ?-46 (V-47) requests relief from the test I frequency requirements of Section XI, Paragraph IWV-3521 for the condenser air.

removal inside containment isolation check valves 1-VP-12 and 2-VP-24. The licensee proposes to exercise these valves closed each refueling outage. ,

3.10.1.1.1 Licensee's Basis for Reauestina Relief--These check valves mus,t seat u'pon reversal of flow in order to fulfill their safety function. The only method to verify this actuation is to perform a leak rate a test. Since these valves are located inside containment, they cannot be  :

tested every three months. A part-stroke exercise test is not possible during  :

plant operation. These valves will be exercised during refueling outages  !

because the small increase in safety gained by testing during cold shutdown does not justify performing a leak rate test. ,

Alternate Testina: Exercising for operability each refueling (not to exceed -

24 months) 3.10.1.1.2 Evaluation--These are simple check valves, located-inside containment, that must seat upon cessation or reversal of flow in order to perform their safety function. The only practical method to verify reverse  ;

flow closure is to perform a leak /back flow test. It is impractical to full  !

or partial-stroke exercise these valves during power operations because this '

would require containment entry. Containment entry is restricted during power operations due to high radiation levels and other personnel safety hazards. A leak /back flow test is a non-routine test requiring planning,'special plant modes, and an elaborate test configuration. If these tests are performed at 51

• w v , e- --- - , e. + - . - --

- r- m -

T v-T-= *8

g x - s n . .u.-s -n j

.i cold shutdown it could delay plant start-up. This would be burdensome to the l licensee. -The licensee's proposal to verify the reverse. flow closure  ;

capability of these valves during every refueling outage, not to exceed 24 -

months, is acceptable, in accordance with OM-10, Paragraph 4.3.2.2(e), "if i exercising is not practicable during plant operation or cold shutdowns,~it may a be limited to full-stroke during refueling outages." Therefore, the j implementation of testing each refueling outage, based on the impracticality.

of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed prior to returning the plant to ,

operation" must be met for the extension of the test interval. '

3.11 Main Steam System 3.11.1 Category C Valves 3.11.1.1 Relief Reauest. V-52 (V-53) requests relief from the test i frequency requirements of Section XI, Paragraph IWV-3521 for main steam header supply check valves to the auxiliary feedwater pump, 1-MS-119, -122, and -124 ,

(Unit One), and 2-MS-Il7, -119, and -121 (Unit Two). The licensee proposes to exercise the valves closed every refueling outage.

3.11.1.1.1 Licensee's Basis for Reouestina Relief--These check valves cannot be exercised to the closed position during power operation or during ..

cold shutdowns when the RCS is pressurized because this test would require the  :

venting of process steam while verifying the closed position. Venting of '

process steam would endanger test personnel.  :

The only method to verify closure other than disassembly is to perform a local back pressure test. The valves will be back pressure tested every refueling' outage because the small increase in safety gained by-testing during cold shutdown does not justify the burden of performing a back pressure test.

]

Alternate Testina: Exercise to the closed position every reactor refueling.

The valves will be full flow tested every three months.

3.11.1.1.2 Evaluation--These valves are located in the main steam  ;

lines to the auxiliary feedwater pumps. During power operation, these lines '

are pressurized. In order to verify reverse flow closure of these valves .

steam would have to be vented to create the required differential pressure.  !

This would be impractical because it would pose a safety hazard to station '

personnel. It appears the only practical method to verify reverse flow  :

closure capability is to perform a leak /back flow test. A leak /back flow test '

is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. If these tests are performed at cold shutdown  ;

it could delay plant start-up. This would be burdensome to the licensee. The licensee's proposal to verify the reverse flow closure capability of these valves during refueling outage and full-stroke exercisethe valvesopen, ,

quarterly, 'is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e),'"if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each refueling outage, based on the impracticality >

of performing testing during power operation or during cold shutdown  ;

52 1

. . - - - .~

conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related -

requirements of 4.3.2.2(h) that "all valve testing required to be performed

• during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval.

3.12 Emeroency Diesel Air Services 3.12.1 Category B and C Valves 3.12.1.1 Relief Reauest--V-55 (V-56) requests relief from the stroke time measurement and test frequency requirements of Section XI, Paragraphs -

IWV-3411, -3413, and -3521 for emergency diesel generator air start solenoids  :

and check valves 1-EG-S0V-600HA, -60lHA, -600HB, -600JA, -607JA, and -600JB, i 1-EB-15, -34, -65, and -84 (Unit One), 2-EG-50V-700HA, -70lHA, -700HB, -700JA,

-707JA, and -700JB, 2-EB-15, -34, -61, and -78 (Unit Two). The licensee proposes using emergency. diesel generator start times and air bank pressure drop instead of measuring individualistroke times for these valves. -

3.12.1.1.1 Licensee's Basis for Reauestina Relief--The solenoid valves have actuation times considerably under a second and there is no visual ,

reference on the solenoid valve to determine when it has stroked. Therefore, '

the. stroke time cannot be measured. The solenoid valves are activated every month to start the diesels. Both air banks are discharged when performing the monthly test. After the test, the air bank pressure is recorded to verify a l decrease in pressure, which confirms that the air banks discharged properly.

Flow through check valves 1-EB-15, -34, -65, and -84 (Unit One) and 2-EB-15, -34, -61, and -78 (Unit Two) cannot be measured because instrumentation is not installed. However, failure of these . valves to full open promptly will affect the starting time of the diesel when the diesel is j

started from just one air bank. A diesel alarm will activate if the starting time exceeds start failure requirements. Verification that the diesel starts without an alarm constitutes a full-stroke test for the check valves. The test to start the diesels on one air bank is performed on a rotating basis 3 once every, six months. Based on this rotation, each check valve will be full .

flow tested once every 18 months.

Alternate Testina: The solenoid valves will be full-stroke exercised and check valves will be part-stroke exercised monthly by observing that the valves perform their intended function (if the diesel starts and the air bank pressures decrease, then the solenoid and check valves were stroked successfully).

Every 18 months, the check valves will be full-stroke tested by discharging only one air bank to start the diesel. The failure of either the solenoid or check valves to stroke properly will promptly give a diesel alarm.

Further investigation would identify problems with the operability of these valves. The diesel start time will be recorded and compared to a maximum >

allowable start time during this test. i 3.12.1.1.2 Evaluation--The relief request identifies that these valves are non-Code components. Therefore, NRC approval of the relief request is not required for implementation. i 4

53- i i

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4 I

i 3.13 Control Room Bottled Air 3.13.1 'Cateaory B and C Valves 3.13.1.1 Relief Reauest. V-71 (V-72) requests relief from the test  !

frequency requirements of Section XI, Paragraphs IWV-3411 and -3521 for .,

control room bottled air supply trip valves and check valves,1(2)-CA-26, 1-HV-TV-1306A, -1306B, 2-HV-TV-2306A, and -2306B. The licensee proposes to ,

exercise these valves every refueling outage.

3.13.1.1.1 Licensee's Jasis for Recuestina Relief--These check valves must open to permit bottled air flow to the control room on either a Unit 1 or Unit 2 SI signal initiation. Full or part-stroke testing of these '

valves would reduce the bottled air pressure below 2300 psig as required by 1 Technical Specification 4.7.7.2. Both bottled air banks are required for operation, therefore, one bank cannot be isolated for testing. Also, after  ;

full flow testing, the bottles take up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to refill.

l The actuator system for valves 1-HV-TV-1306A and B, and 2-HV-TV-2306A  ;

and B act in parallel. When or.e trip valve is actuated, the other Unit 1

• valve for Unit 1 or Unit 2 valve for Unit 2 actuates, thus both bottled air banks are discharged. Performing this test would reduce the bottled air pressure below 2300 psig as required by Technical Specification 4.7.7.2.

After the test, the air bottles would have to be pressurized to above 2300 psig before the system can be restored to operable status. The valve controllers do not allow for a part-stroke exercise test.

Also, to perform this test for the check valves and trip valves, the bottled air system would have to be removed from service. Per Technical Specification 3.7.7.1, the bottled air system must be inservice during Modes  :

1, 2, 3, and 4 or the plant enters a seven day limiting condition of f operation. The small increase in safety gained by exercising these valves i every quarter or cold shutdown does not justify removing the system from service and placing the plant into a degraded safety condition, nor does it justify the effort associated with discharging and restoring the control room bottled air system. ,

Alternate Testing: Valves 1(2)-CA-26 will be full-stroke exercised to the open position and valves 1-HV-TV-1306A and B, and 2-HV-TV-2306A and B will be '

exercised to the open and closed positions every reactor refueling.

3.13.1.1.2 Evaluation--The relief request identifies that these '

valves are non-Code components. Therefore, NRC approval of the relief request is not required for implementation. ,

3.14 Containment Vacuum System 3.14.1 Cateaory A Valves l

3.14.1.1 Relief Reauest. V-14 (V-14) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for inside containment vacuum ejector isolation valves 1-CV-TV-100 and 2-CV-TV-200. The licensee proposes to exercisethe valvesduring cold shutdowns when containment vacuum is broken and use of the containment air ejector is required.

54

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

l i

3.14.1.1.1 Licensee's Basis for Reouestina Relief--This  !

containment isolation valve must remain closed during Modes 1, 2, 3, and 4 per ,

Technical Specification 3.6.5.l_and must be pressure tested after each stroke '

before containment integrity can be established per Technical Specification 4.6.1.1.d. Full or part-stroke exercising during power operation would decrease plant safety and be in violation of Technical Specifications. Also, the valve controller does not allow for a part-stroke exercise test.

Alternate Testina: Exercise for operability during cold shutdowns when ,

containment vacuum is broken and use of the containment air ejector is ,

required. '

3.14.1.1.2 Evaluation--It is impractical to exercise these valves ,

during power operation. These valves must be closed and pressure. tested in  :

order to establish containment integrity. Cycling these valves during power operation would violate containment integrity and plant technical specifications. These valves are located inside containment. They require a ,

pressure / leak test after operation. During cold shutdowns, when containment

• vacuum is being maintained, the licensee would have to break containment  :

vacuum to pressure / leak test these valves after being exercised.

Re-establishing containment vacuum could delay plant start-up and is impractical and burdensome to the licensee. The licensee's proposal to exercise these valves during cold shutdowns when containment vacuum is broken and containment air ejector system is required should provide a reasonable assurance of operational readiness. Testing must also be performed each r refueling outage, at a minimum. The proposed schedule is similar to the Code, ,

but not addressed specifically in the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the licensee's proposal, relief should be granted as requested pursuant to 950.55a 5(f)(6)(i).

3.15 Fire Protection System 1

3.15.1 Cateaory C Valves 1

3.15.1.1 Relief Reouest. V-16 (V-16) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for inside  ;

containment fire protection supply check valves 1-FP-272 and 2-FP-79. The '

licensee proposes to exercise these valve every refueling outage, not to  ;

exceed 24 months.

i 3.15.1.1.1 Licensee's Basis for Reouestina Relief--These check I valves must seat upon reversal of flow in order to fulfill its safety  ;

function. The only method to verify this actuation is to perform a leak ,

rate /back pressure test. A part-stroke exercise test is not possible during plant operation. Since the valve is located inside containment, it cannot be  :

tested every three months. 1 FP-272 and 2-FP-79 are in the containment fire  !

protection system. Testing these valves will render the fire protection L system inoperable. It will be exercised only during refueling outages because the small increase in safety gained by testing during cold shutdown does not justify draining the lines and performing a leak rate test.

l 55

Alternate Testina: Exercise for operability every refueling (not to exceed 24  !

months) 3.15.1.1.2 Evaluation--These are simple check valves which are ,

located inside containment. It appears the only practical method to verify reverse flow closure is by performing a leak /back flow test. It is  ;

impractical to verify reverse flow closure during power operations because l this would require containment entry. Containment entry is restricted during  !

power operations due to high radiation levels and other personnel safety hazards. A leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. Performance of this test at cold shutdown could delay plant start-up. This would be costly and '

burdensome to the licensee. The licensee's proposal to verify reverse flow closure every refueling outage, not to exceed 24 months, is acceptable. In '

accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable during plant operation or cold shutdowns, it may be limited to full-stroke -

during refueling outages." Therefore, the implementation of testing each ,

refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 CFR 50.55a (f)(4)(iv). The related requirements of 4.3.2.2(h) that "all valve testing required to be performed during a refueling outage shall be completed  ;

prior to returning the plant to operation" must be met for the extension of '

the test interval.

3.16 Post Accident Hydroaen Removal System 3.16.1 Cateaory A/C Valves  !

3.16.1.1 Relief Reauest. V-20 (V-20) requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for the inside i containment isolation hydrogen analyzers and recombiner check valves, 1-HC-14, '

-18, 2-HC-15, and -20. The licensee proposes to exercise the valves every refueling outage not to exceed 24 months.

3.16.1.1.1- licensee's Basis for Reauestina Relief--These check valves must seat upon reversal of flow in order to fulfill their safety e functions. The only method to verify this actuation is to perform a leak rate test. Since the valves are located inside containment, they cannot be tested every three months. A part-stroke exercise test is not possible during plant operation. They will be exercised only during refueling outages because the small increase in safety gainec by testing during cold shutdown does not justify performing leak rate tests.

Alternate Testina: Exercise for operability every refueling (not to exceed 24 months).

3.16.1.1.2 Evaluation--These are simple check valves which are located inside containment. It appears the only practical method to verify reverse flow closure is by performing a leak rate /back flow test. It is impractical to verify reverse flow closure during power operations because i this would require containment entry. Containment entry is restricted during power operations due to high radiation levels and other personnel safety hazards. A leak /back flow test is a non-routine test requiring planning, special plant modes, and an elaborate test configuration. Performance of this 56

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

i test at cold shutdown could delay plant _ start-up. This would be costly and 'l burdensome to the licensee. The licensee's proposal to verify reverse flow '

closure every refueling outage, not to exceed 24 months, is acceptable. In accordance with OM-10, Paragraph 4.3.2.2(e), "if exercising is not practicable l during plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages." Therefore, the implementation of testing each r refueling outage, based on the impracticality of performing testing during power operation or during cold shutdown conditions, is approved pursuant to 10 ,

CFR 50.55a (f)(4)(iv). The related requirements of 4.3,2.2(h) that "all valve ,

testing required to be performed during a refueling outage shall be completed prior to returning the plant to operation" must be met for the extension of the test interval. I 3.17 Fuel Oil Transfer System 3.17.1 Cateaorv C Valves i

3.17.1.1 Relief Reouest. V-49 (V-50) requests relief from the exercising procedure of Section XI, Paragraph IWV-3522 for emergency diesel -!

generator pump discharge check valves, 1-EG-254, -266, -278, -295, -260, -272,  !

-289, and -284. The licensee proposes to verify valve operability during '

quarterly pump testing.

3.17.1.1.1 Licensee's Basis for Reouestina Relief--These check ,

valves cannot be full flow tested because instrumentation is not installed to I measure flow or differential pressure. Verifying system operability every '

three months is adequate for verifying valve operability. l t

Alternate Testina: Verifying system operability during the quarterly pump test is adequate for verifying valve operability. No further valve testing is ,

necessary. 1 3.17.1.1.2 Evaluation--lhe relief request identifies that these i valves are non-Code components. Therefore, NRC approval of the relief request  ;

is not required for implementation. '

i 9

L 1

i 57  !

! r i

t i

t a

-t .

h l8 l

s I

5 i

s APPENDIX A i

IST PROGRAM ANOMALIES -!

i

'h a

?

t f

P k

i t

I i

i

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i

.t i

P b

1 A-1 .l

-i

- . ~. - .. , .

,~ . -

I APPENDIX A l IST PROGRAM ANOMALIES

]

Inconsistencies and omissions in the licensee's program noted during the J course.of this review are summarized below. The licensee should resolve these  ;

items in accordance with the evaluations, conclusions, and guidelines  ;

presented in this report. ~l

1. In TER section 2.6.1.1, Pump Relief Request 9, the licensee requests relief'from measuring pump inlet and differential pressure for service water pumps, 1(2)-SW-P-1A and -18 as required ,

by Section XI, Paragraph IWP-3100. The licensee did not consider 4 calculating inlet pressure and using this to calculate differential pressure. Furthermore, the licensee'did not provide sufficient information on how the Code acceptance criteria will be '

applied using only discharge pressure and flow. Therefore, relief 4 should be denied. .

I

2. In TER section 2.6.1.2, Pump Relief Request 10, the licensee i requests relief from measuring pump inlet and differential  :

pressure for service water pumps, 1(2)-SW-P-4 as required by Section XI, Paragraph-IWP-3100. The licensee did not consider calculating inlet pressure and using this to calculate differential pressure. Furthermore, the licensee did not give  !

enough'information on how the Code acceptance criteria will be applied using only discharge pressure and flow. Therefore, relief should be denied.

3. In TER section 2.7.1.1, Pump Relief Request 12, the licensee requests relief from establishing fixed set (s) of reference values for component cooling water pumps 1(2)-CC-P-1A and -1B,- and ,

service water _ pumps 1(2)-SW-P-1A, -1B, and -4 as required by  :

Section XI, Paragraphs IWP-3100 and -3110. Relief should be granted prov.ided the licensee's calculated curve bounds the ,

oper.ating curve of'the designated _ pump and that the acceptance criteria is applied as described in the above TER section.  ;

4. In TER section 3.2.3.5, Valve Relief Requests 42, for Unit One, and 43 for Unit Two, the licensee requests relief from the test -

frequency requirements of Section XI, Paragraph IWV-3521 and  ;

proposes to use disassembly and inspection per Generic Letter  ;

89-04, Attachment 1, Position 2 with an extended interval for i various safety injection check valves. According to the  ;

licensee's P&lDs, it appears that a part-stroke exercise open of ,

these valves could be performed when shutting the plant down to ,

the_ cold shutdown condition. The licensee should investigate into r the possibility of performing a part-stroke exercise open for '

these valves when shutting down the plant to the cold shutdown t condition. The licensee should doce.cnt their findings in their  ;

IST program.

5. In TER section 3.2.3.6, Valve Relief Requests 42, for Unit One, i and 43 for Unit Two, the licensee requests relief from the test t

A-2 ,

I

l

. i methodology of Section XI, Paragraph IWV-3522 and proposes to use disassembly and inspection per Generic Letter 89-04, Attachment 1, ,

Position 2, with an extended interval for various safety injection check valves. The licensee's basis for hardship.to extend the interval appears adequate. However, Generic Letter 89-04,  !

Attachment 1, Position 2, includes cer tain guidelines for extending the inspection interval. The licensee should review these guidelines which are not addressed in the relief request.

Further, if the licensee finds that non-intrusive techniques prove .;

adequate for determination of valve full-stroke open capability,  !

relief is not required; however, the implementation of a sampling nonintrusive testing method may need to be modified according to the discussion in TER section 3.2.3.6. [

6. In TER section 3.3.1.3, Valve Relief Requests 70 for Unit One and 71 for Unit Two, the licensee requests relief from the test i frequency requirements of Section XI, Paragraph IWV-3521 for component cooling water check valves 1-CC-193 and -198 (Unit One) and 2-CC-194 and -199 (Unit Two). The licensee's proposal to verify a full-stroke of these valves when the reactor vessel is .

defueled is inadequate. Relief cannot be granted for an l unspecified time interval. Interim relief should be granted for  ;

the licensee to reevaluate the testing frequency and resubmit this '

relief request.

7. In TER section 3.4.2.1, Valve Relief Request VR-57 (Unit One) and VR-58 (Unit Two), the licensee requests relief from the test  ;

frequency requirements of Section XI, Paragraph IWV-3411 for the '

reactor vessel head and pressurizer vent valves. The licensee proposes to exercise these valves during cold shutdown when the .

RCS is depressurized, but not more frequently than once every three months. However, while in cold shutdown with the RCS intact and at a reduced RCS pressure, exercising these valves, one at a time, is less likely to affect the other in series valve with pressure surges large enough to cause inadvertent opening. The -

licensee should investigate- the possibility of exercising these valves each cold shutdown, but not more frequently than once every  ;

three months.

8. In TER section 3.4.3.1, Valve Relief Request 27, the licensee requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411 for reactor coolant valves 1-RC-PCV-1455C and -1456 (Unit One) and 2-RC-PCV-2455C and -1456 (Unit Two). The licensee did not show impracticality and that exercising these i valves is burdensome or a hardship without a compensating increase in the level of safety and quality. Therefore, relief should be denied.

9. In TER section 3.7.1.1, Valve Relief Request 63 (Unit One) and 64 (Unit Two), the licensee requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for service water discharge check valves 1(2)-SW-3, 1(2)-SW-10, 1-SW-22, and '

2-SW-24. Verification of reverse flow closure for category C ,

A-3

t valves can be done by visual observation, by an electrical signal l initiated by a position-indicating device, by observation of 6 appropriate pressure indication in the system, by leak testing, or  ;

by other pasitive means. According to the licensee's p&lD's, l there is a ,nressure transmitter upstream of the check valves being' .

tested. When one or more of these service water pumps are idle, the idle pump's pressure transmitter can be compared to service ~ t water header pressure along with other indications to verify ,

reverse flow closure of the idle pumps discharge check valve.

Relief should be granted provided the licensee investigates into  ;

an alternate method to verify reverse flow closure other than full j design flow at refueling outages and document their findings. '

s

10. For Relief Requests (Unit 1/ Unit 2) V37/V38, V42/V43, V53/V54, and '

V61/V62 the licensee proposes to use sample disassembly and inspection '

where a nonintrusive technique with a partial-flow test may be practical. Disassembly together with inspection to verify the full-stroke capability of check valves is an option only where full-stroke  !

exercising cannot practically be performed by flow or by other positive j

means. The NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not a test and not equivalent to the }

exercising produced by fluid flow. This procedure has some risk which may make its routine use as a substitute for testing undesirable when some method of testing is possible. Check valve disassembly is a l valuable maintenance tool that can provide a great deal of information _i about a valve's internal condition and as such should be performed under 4 the maintenance program at a frequency commensurate with the valve type l and service.

i The use of valve diagnostics to determine that a check valve opens or -

shuts fully or sufficiently to pass maximum required accident flow or prevent backflow during a partial-flow test is considered an acceptable means to satisfy the Code requirements. The licensee should investigate the use of-a.iternate testing methods to full-stroke exercise these -e valves, such as using non-intrusive diagnostic techniques to' demonstrate I whether they swing fully open or closed during -a partial flow test. If the licensee's investigation reveals that a full-stroke test with flow  ;

is not feasible, then valve disassembly may continue to be used as an ~

alternative to Code testing provided that the licensee performs this i procedure in accordance with Generic Letter 89-04 and provides an  ;

assurance of proper reassembly by performing a part-stroke test or reverse flow closure test of each valve prior to returning it to service >

following disassembly and inspection procedure, where practical. i

11. For Relief Requests V-69 (Unit 1) and V-70 (Unit 2), TER Section 3.1.2.2, the proposed alternative to perform an evaluation rather than a repair / replacement if leakage exceeds a target /specified rate is acceptable. However, several factors discussed in the evaluation must be considered to ensure the adequacy of the evaluation. The licensee should review their methods for performing the evaluation and I incorporate the recommendations.

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APPENDIX B P&ID LIST i

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APPENDIX B P&lD LIST The following is a list of P& ids used during the review of the North Anna Power Station, Units One and Two:

System P&ID No.

Air Cooling and Purging System 11715-CBB-006A Yard fuel Oil Lines 11715-CBB-035A Main Steam 11715-CBM-070A Il715-CBM-070B Aux Steam'and Air Removal 11715-CBM-072A Feedwater System ll715-CBM-074A Service Water System ll715-CBM-078A 11715-CBM-078B  !

11715-CBM-078C 11715-CBM-078G-11715-FM-78H-Component Cooling Wat9r Sys. 11715-CBM-079A 11715-CBM-079B 11715-CBM-079C-11715-CBM-079D L Compressed Air System Il715-CBM-082A l

11715-CBM-082C 11715-CBM-082F

, 11715-CBM-082N Fuel Pit and Refueling Pur. 11715-CBM-088A Sampling System 11715-CBM-089B ll715-CBM-089D L

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I System P&lD No.  ;

Vent and Drain 11715-CBM-090A i 11715-CBM-090C i Cont. Quench and.Recirc. Spray 11715-CBM-091A ll715'-CBM-091B Leakage Monitor 11715-CBM-092A Containment Vacuum 11715-CBM-092A Reactor Coolant 11715-CBM-093A 11715-CBM-093B '

13075-CBM-093C 13075-CBM-093D i

Residual Heat Removal ll715-CBM-094A Chemical- and Volume Control 11715-CBM-095A Il715-CBM-095B 11715-CBM-095C

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Safety Injection 11715-CBM-096A Il715-CBM-096B '!

Steam Generator Blowdown ll715-CBM-098A l

Chemical Feed ll715-CBM-102A '

13075-CBM-102C i Interior Fire Protection & Hose Rack 11715-CBB-102B Secondary Plant Gas Supply 11715-CBM-105B  !

Miscellaneous Gas Supply ll715-CBM-105C j Containment' Atmosphere Cleanup ll715-CBM-1004  :

Emergency Diesel Air Services ll715-CBM-107A ]

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