ML20072Q025

Technical Evaluation Rept Pump & Valve IST Program for Plant

ML20072Q025
Person / Time
Site:	San Onofre
Issue date:	05/31/1994
From:	Ransom C EG&G IDAHO, INC.
To:	NRC COMMISSION (OCM)
Shared Package
ML20072Q005	List: ML20072Q025
References
CON-FIN-L-2594 EGG-RTAP-1121, TAC-M87283, TAC-M87284, NUDOCS 9409090071
Download: ML20072Q025 (41)

Text

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EGG-RTAP-11221 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 Docket Numbers 50-361 and 50-362 C. B. Ransom Published May 1994 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission 4 Washington, D. C. 20555 Under DOE Contract Number DE-AC07-76IDO1570 ,

FIN Number L2594, Task Order Number 8 j TAC Number M87283 and M87284 9409090071 940831 PDR ADOCK 05000361 p PDR

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l ABSTRACT This report presents the results of our evaluation of the San Onofre Nuclear Generating Stadon, Units 2 and 3, Inservice Testing program for safety-related pumps and valves.

PREFACE This report is part of the " Technical Assistance in Support of Operating Reactors Inservice Testing Relief Requests" program conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., DOE /NRC Support Programs.

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FIN No. L2594 B&R No. 920-19-05-02-0 Docket Nos. 50-361 and 50-362 TAC Nos. M87283 and M87284 ii

CONTENTS ABSTRACT ..................................... .... ..- ii PREFACE ....................................,.......... 11

1. INTR O D U CTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1.1 IST Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1.2 IST Requirements .................................... I 1.3 Scope and Limits of the Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2. PUMP TESTING PROGRAM ................................. 3 2.1 General Pump Request ................................. 3 2.1.1 Inlet and Differential Pressure Determination . . . . . . . . . . . . . . 3

3. DEFERRED TEST EVALUATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1 Bases for Deferring Valve Exercising . . . . . . . . . . . . . . . . . . . . . . . . . 7

3. 2 Con cl u sion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.3 Disassembly and Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 APPENDIX A - IST PROGRAM ANOMALIES ........................A-1 TABLES 3.1 Deferred Test Evaluations San Onofre Nuclear Generating Station, Units 2 and 3 . . 9 I

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SAN ONOFRE NUCLEAR GENERATING STATION. UNITS 2 AND 3

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 the San Onofre Nuclear Generating Station, Units 2 and 3, submitted by Southern California Edison Company.

Section 2 presents Southern California Edison Company's bases for requesting relief from the requirements for pumps followed by an evaluation and conclusion. Section 3 presents a summary of the evaluations of deferred test justifications that involve the frequency of testing safety-related valves.

Appendix A lists program inconsistencies and omissions,

• and identifies needed program changes.

1.1 IST Program Description Southern California Edison Company (SCE) submitted their Second 120 month Inspection Interval IST program with a letter to the Nuclear Regulatory Commission (NRC) dated April 4,1994. The IST program covers the Second ten-year interval starting August 18, 1993, and ending August 17, 2003. The relief requests pertain to requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI,1989 Edition and the Code of Federal Regulations (CFR),

10 CFR 50.55a. This Edition of the Code prescribes that the pump and valve testing be performed in accordance with the requirements of the ASME/American National Standards Institute (ANSI) Operations and Maintenance (O&M) Standards Parts 6 and 10, respectively.

1.2 IST Recuirements 10 CFR 50.55a(f) states that IST of certain ASME Code Class 1,2, and 3 pumps and valves will be done according to the ASME Code,Section XI, Subsections IWP and IWV, except where the alternative is authorized or relief is granted by NRC in accordance with 10 CFR 50.55a(a)(3)(i), (a)(3)(ii), or (f)(6)(i). SCE 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 the acceptance criteria of the Standard Review Plan, Section 3.9.6, NRC Generic Letter No. 89-(M (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 or include non-Code Class 1,2, or 3 components.

In rulemaking to 10 CFR 50.55a effective September 8,1992 (Sec 57 Federal Recister 34666), the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 Edition of Section XI provides that the rules for IST of pumps and valves are as specifled in ASMEIANSI O&M Part 6 (OM-6), inservice Testing of Pumps in Light-Water Reactor Power Plants, and Part 10 (OM-10), Imervice Testing of Valves in Light-Water Reactor Power Plants.

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1.3 Scope and Limits of the Review The scope of this review includes, but is not limit xi to, the cold shutdown justifications, refueling outage justifications, and relief sequests for safety-related Code Class 1,2, and 3 pumps and valves submitted with the licensce's IST program. Other portions of the program, such as general discussions, pump and vahe test tables, etc., are not necessarily reviewed. Endorsement of these aspects of the program by the reviewer is not stated or implied.

The Containment Spray, Chemical and Volume Control, Steam Generator Feedwater, and Safety Injection Systems were specifically reviewed for scope and completeness of the licensee's IST program. The system drawings were reviewed and many valves evaluated to determine if they perform a safety-related function. Although this review was more detailed than normally performed, it was a spot check and does not constitute a comprehensive system review or endorsement of the licensee's scope. The spot check of the IST program plan and the piping and instrumentation drawings (P& ids) for these systems did not reveal any omissions or other problems with the IST program.

The evaluations in this TER are applicable only to the components or groups of components identified by the submitted requests. 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.

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2. PUMP TESTING PROGRAM The following relief request is evaluated against the requirements of ASME/ ANSI OMa-1988, Part 6; 10 CFR 50.55a; and applicable NRC positions and guidelines. A summary is presented for the relief request followed by the licensee's basis for relief aad the evaluation with the reviewer's recommendations.

2.1 General Pumo Request 2.1.1 Inlet and Differential Pressure Determination 2.1.1.1 Relief Recunt. Pump Relief Request No.12 requests relief from the instrument full-scale range requirements of OM-6, Subsection 4.6.1.2, for the saltwater cooling and reactor charging pumps, P112, P113, P114, P307, E190, P191, and P192. The licensee proposes to use the installed station instruments that are more accurate than required by the Code, but with ranges that do not meet the Code requirement.

2.1.1.1.1 Licensee's Basis for Reauestine Relief--The following text is quoted from Pump Relief Request No.12 in the San Onofre Nuclear Generating Station, Units 2 and 3, Second Inspection Interval IST Program dated April 4,1994:

Relief is requested from the full scale range requirements of OM-6 for SWC pump discharge pressure, and Charging pump suction pressure and flow.

Though the existing installed station instruments do not meet the code range requirements, their accuracy is significantly better than the code requirements. Thus the combination of range and accuracy of the installed equipment provides for the acquisition of repeatable data that meets the intent of the code.

The instruments listed in the attached table do not meet the OM-6 requirement (e.g., the full-scale range of each instrument shall not be greater than three times the reference value). However, the manufacturer's stated accuracy for each pressure instrument listed in the attached table exceeds the OM-6,4.6.1.1 required accuracy (plus or minus two percent) for pressure instruments by a factor of four. Similarly, although the range for charging pump flow instrument FI-0212 is approximately 3.5 times the reference value, the combined loop accuracy of 1.28% exceeds the OM-6 required accuracy (plus or minus two percent) for flow instruments.

Even accuracy determination based on the square root of the sum of the squares of the inaccuracies of each component in the loop per OMa 1988 Part 6, Section 1.3, instrument accuracy.

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• b Pump Parameter Instrument Instrument Reference Error Permined As Installed Accuracy Range Value by Code

• at Full scale (Range + Ref) (error at fuU scale) saltwater Cooling system Pumps P112 Disch. Press. PI-6230 0-160 32.4 psig 1.94 psig 0.5% (0.8 psig)

(5.1)

P113 Disch. Press PI-6231 0-160 31 psig 1.86 psig 0.5% (0.8 psig)

(5.2)

P114 Disch. Press PI-6233 0-160 27 psig 1.62 psig 0.5% (0.8 psig)

(5.9)

P307 Disch Press PI-6232 0-160 29 psig 1.74 psig 0.5% (0.8 psig)

(5.5)

Reactor Charging Pump ,

P190 suction Press. PI-9284 0-160 46.0 psig 2.76 psig 0.5% (0.8 psig)

(3.5)

P191 suction Press. PI-9285 0-160 44.0 psig 2.64 psig 0.5 % (0.8 psig)

(3.6)

P192 suction Press. PI-9286 0-160 50.0 psig 3 psig 0.5% (0.8 psig) 0.2)

P190, Flow H '".12 0 150 44.9 gpm 2.69 poig 1.28% (1.92 psig) i (3.3)

P191, 0-150 44 gpm 2.64 psig 1.28% (1.92 psig) l

& (3.4) 0-150 45 gpm 2.7 psig 1.28% (1.92 psig) )

P192 (3.3)

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• The information in this column represents the gauge error permitted by the code (3 times the reference value times the code requtred accuracy of 2%)

2.1.1.1.2 Evaluation--The Code requires measurement and analysis of pump )

differential pressure and flow rate quarterly. These measurements are evaluated to assess pump hydraulic condition and detect degradation. OM-6, Paragraph 4.6.1.2(a) states that the full-scale range of analog instruments shall not be greater than three ti nes the reference  !

value of the parameter. This requirement is to ensure that the instrumentation used for i testing is sufficiently readable and accurate. The licensee proposes to measure the saltwater l cooling pump discharge pressure, the reactor charging pump suction pressure, and the reactor charging pump flow rate using the existing station instruments that have full-scale ranges in excess of three times the applicable reference values. l OM-6 does not require measurement and evaluation of pump discharge pressure for pumps (except for positive displacement pumps). However, since there is no direct reading differential pressure instruments for the saltwater cooling pumps, discharge pressure must be measured to determine the differential pressure developed across the pumps. Therefore, the Code quality and range requirements apply to the saltwater cooling discharge pressure instrument to assure that measurements are sufficiently accurate and readable to permit detection of pump degradation. The installed discharge pressure instrument full-scale ranges 4

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are greater than three times the test reference values (160 psig in lieu of approximately 90 psig). The higher range instruments may be necessary to prevent instrument damage due l' to over-ranging during certain system operating conditions, therefore, installing instruments that meet the range requirements may not be prudent. The accuracy of the installed instruments (10.5%) is better than is required for pressure instruments in OM-6, Table 1

( 2%). The proposed discharge pressure instruments reading inaccuracy might be as great as i0.8 psi (i2.47% to i2.96% of the reference values). Use of the installed discharge pressure instruments, that are accurate to at least i2.96% of the reference values, should l

provide measurements sufficiently accurate to evaluate the condition of these pumps. Test instruments that meet the Code could have up to a 11.94 psi inaccuracy at the reference value, which is more inaccurate than the i0.8 psi inaccuracy provided by the installed j instruments. Therefore, installing instruments that comply with the Code for testing would I be a hardship without a compensating increase in the level of quality and safety. The proposed alternative provides sufficiently accurate data for assessing pump degradation. l Based on the determination that compliance with the Code full-scale range requirements for the saltwater cooling pump discharge pressure instruments is a hardship without a compensating increase in the level of quality and safety, we recommend that the alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii). If the system is modified or the instruments are replaced for other reasons, we recommend that accurate instruments that meet the Code full-scale range requirements be installed if practicable.

The supplied system piping and instrumentation drawing (40124BS03, Rev.17) shows  !

l the reactor charging pumps to be positive displacement pumps. OM-6 does not require measurement and evaluation of pump suction pressure for positive displacement pumps. The only pressure measurement required for these pumps is discharge pressure. Therefore, the Code quality and range requirements do not apply to the reactor charging pump suction pressure instruments and relief is not necessary for these instruments.

The OM-6 quality and range requirements apply to the reactor charging pump flow rate l

instruments to assure that measurements are sufficiently accurate and readable to permit detection of pump degradation. The installed flow rate instrument full-scale ranges are  ;

i greater than three times the test reference values (150 gpm in lieu of approximately 133.5 gpm). The higher range instruments may be necessary to prevent instrument damage due to I over-ranging during certain system operating conditions, therefore, instaliing instruments that l meet the range requirements may not be prudent. The accuracy of the installed instruments i

(il.28%) is better than is required for flow rate instruments in OM-6, Table 1 (i2%). The l

proposed flow rate instrument reading inaccuracy might be as great as it.92 gpm (i4.27%

to 14.36% of the reference values). Test instruments that meet the Code could have up to a 12.7 gpm inaccuracy at the reference values, which is more inaccurate than the 1.92 gpm ,

inaccuracy provided by the installed instruments. Therefore, installing instruments that (

comply with the Code would be a hardship without a compensating increase in the level of quality and safety. The proposed alternative provides sufficiently accurate data for assessing l pump degradation.

Based on the determination that compliance with the Code full-scale range requirements for the reactor charging pump flow rate instruments is a hardship without a compensating 5

increase in the level of quality and safety, we recommend that the alternative be authorized j pursuant to 10 CFR 50.55a(a)(3)(ii). If the system is modified or the instruments are i

replaced for other reasons, we recommend that accurate instruments that meet the Code full-scale range requirements be installed if practicable.

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3. DEFERRED TEST EVALUATIONS The following Alternate Testing Justifications (ATJs) involve the frequency of testing safety-related valves. These justifications are listed in Table 3.1 and are evaluated in accordance with the exercising frequency requirements of Oht-10, Paragraph 4.2.1.1 or 4.3.2.1 as discussed below.

The IST program breaks ATJs into sections based on plant systems, but does not include specific identifiers for the ATJs within each section. Where there are more than one ATJ in a section, we designated the first one "Part 1," the second "Part 2," etc.. The reader can determine which ATJ is being discussed in Table 3.1 by using these designations along with the valve numbers.

3.1 Basn for Deferrine Valve Exercising Obi-10, Paragraphs 4.2.1.2 and 4.3.2.2, permit deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or cold shutdowns. The justification for deferral of stroke testing should be documented in the Test Plan in accordance with Oht-10, Paragraph 6.2(d).

3.2 Conclusion For all of these relief requests and deferred test justifications where the licensee has demonstrated the impracticality of full-stroke exercising the listed valves quarterly and/or during cold shutdowns, deferral of this testing until cold shutdowns or refueling outages is covered by Oht-10. Accordingly, the licensee's proposed alternate testing is in compliance with the Code. Cases where the licensee has not adequately demonstrated the impracticality of full-stroke exercising these valves quarterly and/or during cold shutdowns, are identified in Table 3.1 and in anomalies in Appendix A to this report.

Where full-stroke exercising is impractical quarterly and/or during cold shutdowns, Oht-10 requires part-stroke exercising quarterly and/or during cold shutdowns if practical.

Where full-stroke exercising is deferred until cold shutdowns or refueling outages, the licensee should part-stroke exercise the applicable valves as specified by Ohi-10, Paragraph 4.2.1.2 or 4.3.2.2, as appropriate.

3.3 pisassembly and Insnection Several of the licensee's deferred test justifications propose check valve disassembly and inspection in lieu of full-stroke exercising the applicable valves open and/or closed with system pressure or flow. There are valves that cannot practically be verified to full-stroke exercise open and/or closed using system pressure or flow. Therefore, the staff approved the use of disassembly and inspection during refueling outages in GL 89-04 for those cases where it is impractical to verify a full-stroke exercise by testing.

Ohi-10, Paragraph 4.3.2.4(c), permits the use of disassembly and inspection to verify check valve obturator movement. This testing is to be performed at refueling outages, 7

however, no provisions are made to allow use of a sampling program. GL 89-04, Position 2, provides guidelines for check valve disassembly and inspection on a sampling basis. This technique is approved for groups of identical valves in similar applications provided that it is performed in accordance with all of the provisions of the generic letter. This topic is also addressed in Appendix A, Item 4 8

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Table 3.1

- DEFERRED TEST EVALUATIONS SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 Item Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 1.0 Drain valve from Technical Specification (TS) 3.7.1.3, Test this valve at cold It is impractical to full-Part I condensate storage condensate storage tanks, invokes an shutdown intervals. stroke exercise this tank sump; action statement of four houn if either valve quarterly.

S2(3)1305MUO88 condensate tank is inoperable. The herefore, the MUO88 exercise test involves installing alternative is in a plug on tank T-121 outlet rendering accordance with the tank inoperable. Both tanks T-120 ASME/ ANSI O&M, and T-121 provide the water for Part 10, para. 4.2.1.

auxiliary feedwater (AFW) pump l suction. Isolating these tanks from each -

other renders the makeup water supply and therefore the AFW system inoperable for the duration of the tcst.

Hence, the exercise test for this valve is not practical duang plant operation.

ATJ 1.0 AFW pump Exercising these valves while the plant Test the valves at cold It is impractical to full-Part 2 discharie check is at power requires injection of AFW shutdown. His stroke exercise these valves: into the Steam Generators. This result avoids injecting cold valves quanerly.

S2(3)l305MU121, places unnecessary and deleterious water into hot herefore, the 126,532, and 547 thermal stresses on the feedwater piping feedwater piping and alternative is in j and could result in premature failure of consequent thermal accordance with this piping. The connection between stresses. Part 10, para. 4.3.2.

the AFW pump discharge piping and the main feed piping usually runs at  !

over 350*F, however, the AFW pumps l inject condensate directly from the l )

condensate storage tanks.

Consequently, during the test of these l valves at power, the piping experiences i a rapid cooldown to approximately 70*F. His constitutes a problem of  ;

fatigue over the life of the plant and ,

f therefore is considered impractical for a quarterly test. i ATJ 1.0 AFW pump suction Closing the suction isolation valve will Test the valves at cold ATJ 1.3 does not Part 3 valves from the cause the associated AFW pump to be shutdown intervals adequately demonstrate condensate tank: inoperable. This is contrary to the the impracticality of S2(3)l305MU468, requirements of TS 3.7.1.2.1. Stroking exercising these valves 469, and 538 the AFW pump suction isolation valve quarterly (see ,

closed every three months will result in Appendix A, item 2). J the affected pump being declared inoperable each time the valve is ,

stroked closed. His exacerbates the l unavailability of the AFW pumps.

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Item Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 2.0 Boric acid makeup Opening these valves would result in Test the valves at cold it is impractical to full-Part I tank to gravity feed injecting concentrated boric acid into shutdown. This stroke exercise these line and chargir.g the reactor coolant system (RCS), avoids uncontrolled valves quarterly.

causing plant shutdown. boration and Therefore, the pump suction:

2(3)HV9235, consequent reactor altemative is in 9240, and 9247 shutdown. accordance with Part 10, para. 4.2.1.

ATJ 2.0 Boric acid makeup ne only flow path through these valves Test the valves at cold It is impractical to full-Part 2 pump discharge that will allow full flow is into the shutdown. His stroke exercise these check valves: volume control tank (VCT) or to the avoids uncontrolled valves quarterly.

suction of the charging pumps. He boration and herefore, the S2(3)1218MUO33 and 035 only source of water to open these consequent reactor attemative is in valves to demonstrate full flow is from shutdown. accordance with the boric acid makeup pumps and is Part 10, para. 4.3.2.

concentrated boric acid. As a result, full-stroke exercising these valves during plant power operation would result in uncontrolled boration of the RCS and the effect would be reactor plant shutdown.

ATJ 3.0 Charging pumps to Exercising while the plant is at power Test the valve at cold It is impractical to Pcrt I regenerative heat would isolate normal charging to the shutdown. His shifts exercise this valve exchanger isolation RCS. This would result in a the testing to a period quarterly during power valve: non-compliance with TS 3.1.2.2, whi b during which it is operations. Herefore, 2(3)HV9200 requires two flow paths for boration allowed by the TS and the alternative is in during power operation. avoids RCS pressure accordance with and boration control Part 10, para. 4.2.1.

problems or complications.

ATJ 3.0 Regenerative heat Exercising these valves while the plant Test these valves at It is impractical to full-Port 2 exchanger to is at power would isolate normal cold shutdown. This stroke exercise these letdown heat letdown through both the regenerative shifts the testing to a valves quarterly, exchanger isolation heat exchanger and the letdown heat period during which Derefore, the valve: exchanger. Exercising these valves temperatures are much alternative is in 2(3)HV9205, and during power operation would result in closer to ambient on accordance with letdown interruption of flow and allow the both sides of the heat Part 10, para. 4.2.1.

contamment associated heat exchanger temperatures exchanger. As a isolation valve: to equalize for a short period. Later, result, the thermal 2(3)TV9267 upon restoration of flow as the valves transients from ,

are opened, the hot reactor coolant flow momentary through the regenerstive heat exchanger interruption of flow would result in return to the former are almost completely

• equilibrium

• temperatures. This avoided.

would result in damaging thermal stress transients on the regenerative heat ,

exchanger and RCS charging nozzles. l 10

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d Itan Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 3.0 VCT outlet valve: Testing these valves closed requires Test these valves at It is impractical to Part 3 2(3)LVO227B, and shifting charging pump suction and cold shusdown. This exercise these valves VCT to charging injecting highly concentrated boric acid avoids econtrolled closed quarterly.

pump suction check into the RCS, causing plant shutdown, and ussanted boration %erefore, the valve: during te period that alternative is in 52(3)1208MU015 these valves and the accordance with associased VCT are Part 10, paras. 4.2.1 out of service for their and 4.3.2. (See closed smoke test. Appendix A, item 6)

ATJ 3.0 Chemical addition This test requires a backpressure from Open smoke test at It is impractical to full-Part 4 tank to charging the charging pump suction header that cold sinadove stroke exercise this pump suction can only be achieved when the charging intervsk valve quarterly.

header check pumps are secured for a period of time, ,

Derefore, the valve: thus requiring Modes 5 and 6. alternative is in S2(3)1208MUO45 Additionally, an exercise test would accordance with result in dilution of the RCS if Part 10, para. 4.3.2.

performed during power operation.

ATJ 3.0 Charging pumps When valve is stroked open using the Open smoke test at It is impraciical to full-Part 5 combined discharge auxiliary charging path, cold borated cold skandown stroke exercise this valve to HPSI water will be injected into the RCS via intervals. valve quarterly, header: the HPSI header because the %erefore, the S2(3)1208MUO66 regenerative heat exchanger is alternative is in bypassed. His results in extreme chill accordance with shock, and consequent damage to the Part 10, para. 4.3.2.

associated system connection / nozzles.

ATJ 3.0 Check valves in the Testing these valves in the open Test thevalves at cold It is impractical to full-Part 6 line from the boric direction would result in injecting shutdosa. stroke exercise these acid makeup tank concentrated boric acid into the RCS, valves quarterly.

to the charging causing plant shutdown. Therefore, the pump suctions: alternative is in S2 (3)1208MUO82 accordance with and 083 Part 10, para. 4.3.2.

ATJ 3.0 Charging pump This valve cannot be stroked closed Test the valve during It is impractical to Part 7 discharge to during normal operation as it would cold shadown. exercise this valve regenerative heat isolate CVCS and charging pumps to quarterly. Therefore, exchanger manual the RCS. This uould result in a the alternative is in isolation valve: non-compliance with TS 3.1.2.2, which accordance with S2(3)1208MU084 requires two flow paths for boration Part 10, para 4.2.1.

during power operation. (See Appendix A, items 2 and 3)

ATJ 3.0 Check valve from This valve is normally closed and will Test this valve at cold it is impractical to full-Pcat 8 the coolant cause an unplanned dilution of the RCS shutdous intervals. stroke exercise this ~

polishing and potential power excursions if a valve quarterly.

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demineralizer to close stroke test is performed during Therefore, the charging pump power operation, alternative is in suction header: accordance with 52(3)1208MUO94 Part 10, para. 4.3.2.

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Item Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification f ATJ 3.0 Charging line This contamment isolation valve opens his valve will be It is impractical to Part 9 check valve to the to allow normal charging flow to the verified closed during exercise this valve regenerative heat RCS. It is located inside containment refueling outages closed quarterly or exchanger: and is in constant use. Closing this while performing during cold shutdowns.

valve during power operation (or any Appendix J testing. Therefore, the S2(3)1208MU122 time reactor charging flow is required) Also, this valve will alternative is in results in cessation of flow through the be exercised open accordance with regenerative heat exchanger and results quarterly during Part 10, para. 4.3.2.

in an extreme thermal transient, routine inservice Additionally, the system arrangement testing of the charging provides no source of backflow or pumps.

pressure to provide for a closure test other than the containment penetration leak rate testing connections. He -

refueling interval seat leakage test is used to verify valve closure.

Stroke test this valve It is impractical to  !

ATJ 3.0 Charging pump Exercising this valve would result in Part 10 discharge to admission of cold charging pump open and closed at exercise this valve l auxiliary discharge to the pressurizer spray and cold shutdown quarterly. Herefore, i pressunzer spray an unnecessary thermal transient and intervals, the alternative is in containment stress on the pressurizer spray noz.zle. accordance with l isolation valve: Part 10, para. 4.2.1. ,

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S2(3)1208MU130 ATJ 4.0 Component cooling Exercising these valves durmg operation Stroke these valves at It is impractical to ,

would secure or direct cooling water cold shutdown exercise these valves Port la water (CCW) non-critical loop flow from RCP seals, which could intervals. quarterly. Therefore, containment result in seal darnage and plant the alternative is in shutdown. accordance with isolation valves:

2(3)HV6211, 6216, Part 10, para. 4.2.1.

6223, and 6236 (See Appendix A, Item 6)

CCW supply to Exercising HV6212 and 6213 would Stroke these valves at It is impractical to ATJ 4.0 non-critical loops isolate the non-criticalloop supply from wid shutdown exercise these valves Part Ib isolation valves: the discharge of CCW beat exchanger u.wrvals. quarterly. Therefore, IA and 2B and secure CCW flow to the the alternative is in 2(3)HV6212 and RCP seals with the same result as accordance with 6213 above. Part 10, para. 4.2.1.

CCW return from Exercising HV6218 and 6219 would Stroke these valves at It is impractical to ATJ 4.0 non-critical loop isolate the non critical loop return flow cold shutdown exercise these valves Port le isolation valves: from CCW critical loops return piping intervals. quarterly. Therefore, and have the same effect. the alternative is in 2(3)HV6218 and accordance with 6219 Part 10, para. 4.2.1.

Exercising HV6500 and 6501 would Stroke these valves at It is impractical to ATJ 4.0 CCW heat 1 initiate flow in the shutdown cooling cold shutdown exercise these valves Part Id exchanger outlet heat exchanger and therefore bypass mtervals. quarterly. Herefore, isolation valves:

flow to the normal CCW heat loads the alternative is in 2(3)HV6500 and momentarily. accordance with 6501 Part 10, para. 4.2.1.

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item Valve Justification for Deferring Valve Proposed Altemate Evaluation of the Number Identification Exercising Testing Justification ATJ 4.0 CCW surge tank The operability of these valves can be Test these valves at n ese are pressure Part 2 nitrogen verified when the valves are being refueling intervals. regulating valves that backpressure calibrated. nese valves are used for are exempted from IST regulator: system control, such as pressure by Part 10, 2(3)PCV6358 and regulating valve, therefore they are para.1.2(a)(2), NRC 6361 exempted from IST under OM-10 approval is not Section 1.2(a)(2). In order to stroke required, these valves closed, the backup nitrogen system must be isolated thus renders the CCW train and equipment that this CCW train supports inoperable.

Clearing a CCW train for the test is time consuming and labor intensive and it in the event of a plant emergency, the .

system cannot be quickly realigned for operation. During plant refueling, each CCW train is taken out of service for system component maintenance. j System availability is not essential to  :

plant safety and therefore it is practical  !

to test these valves at that time.

ATJ 4.0 Isolation valves in In order to stroke open these valves Remote manually test It is impractical to l Port 3 the CCW return remotely from the control room, the valves at cold exercise these valves from RCP seal heat valves will first have to be closed and shutdown intervals and quarterly. Therefore, exchangers: then stroked open. The closure of these manually stroke valves the alternative is in 2(3)TV9144, valves dunng RCP operation could when plant conditions accordance with 9154, 9164, and result in RCP seal damage. allow containment Part 10, para. 4.2.1.

9174 Containment entry is required to entry at cold manually open stroke these valves. shutdowns of a long enough duration.

ATJ 4.0 CCW pump To achieve full Dow to stroke these Stroke at cold It is impractical to full-Part 4 discharge check check valves open requires a tedious shutdown intervals stroke exercise these valves: and complicated adjustment of the flow when plant conditions valves quarterly.

52(3)1203MU101, balance between numerous CCW loads, allow adjustment of nerefore, the 102, and 103 This usually results in high temperature CCW flow without the attemative is in alarms and results in a temperature complexity represented accordance with cycle on the components serviced by by the Mode 1 Part 10, para. 4.3.2.

CCW as a minimum. Restoration of configuration.

normal CCW flow is equally complicated.

ATJ 4.0 Service water line To achieve a close stroke of these check Stroke at cold It is impractical to full- l Part 5 check valves in valves, the upstream volutne of the shutdown intervals stroke exercise these j supply to CCW: associated piping must be isolated and when plant conditions valves quarterly.

allow CCW loops to Therefore, the l, S2(3)1203MU268 depressurized. This renders the and 269 associated CCW surge tank and be inoperable without alternative is in [

therefore the associated CCW loop to rendering several TS accordance with be inoperable. Le result is entry into required components Part 10, pan. 4.3.2.

multiple TS LCO Action Statements if inoperable. (See Appendix A, done during plant operation. Item 2) 13

l.'

Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Item Nurnber identification Exercising Testing Justification Check valves in the Exercising these check valves both Stroke at cold it is impractical to full-ATJ 4.0 CCW supply to the closed and open would interrupt flow to shutdown intervals stroke exercise these Part 6 RCP seals: the RCP seals. Closure during RCP when plant conditions valves quarterly.

allow containment Therefore, the 52(3)1203MU280, operation would result in seal damage.

281,282, and 283 Accordingly, the valves can be entry for valve testing. alternative is in exercised only when the RCPs are accordance with secured. Additionally, testing these Part 10, para. 4.3.2.

valves requires a containment entry.

These valves cannot be full-stroke Test these valves at It is impractical to ,

ATJ 5.0 Feedwater bypass valves for steam exercised during power operation as cold shutdown exercise these valves  !

Peri I generators: this would disturb steam generator level intervals. quarterly. Therefore, l' control, which could result in plant the attemative is in 2(3)HV1105 and shutdown. accordance with 1106 ,

Part 10, para. 4.2.1.

ATJ 5.0 Feedwater block Full-stroke exercising these valves Test these valves at It is impractical to and isolation during power operation would result in cold shutdown exercise these valves Part 2 valves: loss of feedwater flow to the steam intervals. quarterly. Therefore, 2(3)HV4047, 4048, generator, which could result in a plant the alternative is in 4051, and 4052 shutdown, accordance with Part 10, para. 4.2.1.

ATJ 5.0 Main feedwater to OM-10, Section 4.3.2.2(e) stipulates if At cold shutdowns, It is impractical to full-steam generator exercising is not practicable during full-stroke open each stroke exercise these Part 3 plant operations or cold shutdowns, it valve using flow. At valves closed quarterly check valves:

may be limited to full-stroke during refueling outages, or during cold S2(3)l305MUO36 and 129 refueling outages. Section 4.3.2.4(c) partially disassemble, shutdowns. The further states, " As an alternative to the inspect and manually alternate method for testing in (a) or (b) above, disassembly stroke on a rotating closure verification is every refueling outage to verify basis (one valve per approved by GL 8944 operability of check valves may be refueling). During provided that the used.* GL 8944, Position 2, allows disassembly visually testing complies with for development of staggered schedules inspect the valve all of the provisions of for testing of like components by internals for worn or GL 8944, Position 2 establishing an inspection plan for corroded parts, and (see Appendix A, similar groups of valves. manually exercise the item 4).

disk. If the full-stroke capability of the valve is in question, the other valve will be disassembled and inspected during the same outage.

Following reassembly, the valve will be tested by partial stroking using system flow.

3 14

)

l Item Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 5.0 AFW check valves Exercising these valves while the plant Test these valves at It is impractical to Port 4 to steam is at power would result in plactog cold shutdown exercise these valves generators: unnecessary thermal stresses on the intervals. quarterly. Therefore, ,

S2(3)l305MU124 feedwater piping, which could result in the alternative is in and 448 premature failure of this piping, accordance with Part 10, para. 4.3.2.

ATJ 6.0 Containment purge Rese valves are passive except in Test these valves at It is impractical to valves: Modes 5 and 6, at which time they are cold shutdown exercise these valves 2(3)HV9948, 9949, tested. In addition, exercising these intervals quarterly. Therefore, 9950, and 9951 valves during plant power operation the alternative is in would result in non-compliance with the accordance with  :

TS. Part 10, para. 4.2.1. l l

ATJ 7.0 Isolation valves Applying power or opening these valves Teit these valves at ATJ 8.2 does not Part I between the while the plant is at power would result cold shutdown adequately demonstrate shutdown cooling in non-compliance with the TS. intervals, the impracticality of heat exchangers Opening these valves could defeat both exercising these valves and LPSI header: trains of LPSI. open quarterly dunng 2(3)HV8150 and power operation (sec 8151 Appendix A, Item 5).

i ATJ 7.0 Containment spray Rese valves are in the line leading At each refueling It is impractical to full- ; i Part 2 (CS) header stop from the CS pump discharge to the riser outage, part-stroke test stroke exercise these check valves: inside the containment building that (open) each valve valves closed quarterly i S2(3)1206MUOO4 leads up to the ring headers and spray using flow and test the or during cold t i and 006 nozzles. Full-stroke exercising these valves by partial shutdowns. He  :

valves through this flow path would disassembly, alternate method for result in a containment spray down an inspection and manual closure verification is i potential equipment damage as well as stroking on a rotating approved by GL 89-04  !

create additional liquid radwaste to be basis (one valve per provided that the i removed from the containment building refueling). During testing complies with sump. A usable flow path does not disassembly, the valve all of the provisions of exist in any plant mode to allow a internals shall be GL 89-04, Position 2 full-stroke of these valves using flow. visually inspected for (see Appendix A, The full-stroke testing using flow could worn or corroded Item 4).

only be performed after considerable parts, and the disks system modification, such as installation will be manually of an instrumented test loop. He high exercised. If the full-costs involved would not be justified by stroke capability of the the improvement of the valve testing. valve is in question, Further, the additional valves, piping, the other valve will be i supports and penetrations could result in disassembled and l reduced plant reliability. GL 89-04, inspected during the Position 2, identifies partial disassembly same outage.

and inspection as an acceptable Following reassembly, alternative for stroking a va've when it the valve will be tested is impractical to use flow, by part-stroking using system flow.

15

Itan Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Nurnber Identification Exercising Testing Justification CS pump minillow To verify closure of these valves Test these valves at It is impractical to ATJ 7.0 line stop check requires placing the miniflow line out of cold shutdovm exercise these valves Par 23 valves: service for the HPSI, LPSI, and CS intervals. quarterly. Therefore, systems. This renders those systems the alternative is in S2(3)1206MU010 and 011 inoperable and is only practical in accordance with modes during which these systems are Part 10, para. 4.3.2.

not required to be operable.

ATJ 8.3 does not ATJ 7.0 CS pump discharge Full-stroke exercising thes,e check Test these valves at valves while the plant is at power cold shutdown adequately demonstrate Port 4 check valves:

S2(3)1206MU012, would require disabling both trains of intervals. the impracticality of 014,029, and 030 LPSI. exercising these valves open quarterly during power operation (see Appendix A, Item 5).

Diesel generator Each component is demonstrated Verify proper The diesel generator ATJ 8.0 skid mounted lube operable by virtue of the fact that the operation of the diesel skid mounted oil, fuel oil, and air engine (s) start in the requisite time, generators during components are tested start valves listed carnes the required load, and exhibits regularly scheduled during the diesel in ATJ 8.0 operating parameters (temperatures, " loaded run* generator loaded run pressures, etc.) that fall within the surveillance. Record surveillance tests. The vendori recommended values. Monthly engine run data per loaded run tests are surveillance runs of the diesel OM-16 and vendor perfonned at least once generators load the engine to recommendations. each quarter, which is

~4840KW, 'Ibe anticipated Mode 1-4 in accordance with accident loading is 4700KW (Mode 5/6 Part 10, paras. 4.2.1 loading is -80 % of this value). and 4.3.2. (See Engine parameters are recorded and Appendix A, item 7) transmitted to technical division for review and trending. The OM-16 code committee has takeo the position that Section XI testing daes not enhance the j reliability of the 6esels.

Isolation valve in Exercising these valves during plant Test these valves at It is impractical to ATJ 9.0 the fire protection power operation will activate the fire cold shutdown exercise these valves supply to protection system in the respective intervals. quarterly. Therefore, contment: containment building. the alternative is in accordance with 2(3)HV$686 Containment Part 10, para. 4.2.1.

isolation valves: (See Appendix A, SA2301MUO61 and Item 3) 095 Openmg these valves would result in Test these valves at it is impractical to ATJ 10.0 Valves in the line injecting highly concentrated boric acid cold shutdown exercise these valves fmm the RWST to the charging pump into the RCS, causing a plant shutdown. intervals. quarterly. Therefore, suction: the alternative is in accordance with 2(3)LVO227C and Part 10, paras. 4.2.1 2(3)1219MUOS2 and 4.3.2.

16

Itesn Valve Justification for Deferring Valve Propo<ed Alternate Evaluation of the Nurnber Identification Exercising Testing Justification ATJ 11.0 Nitrogen rupply Testing requires containment entry. Test these valves at It is impractical to Part i line containment These valves are tested under the cold shutdown exercise these valves isolation check Appendix J procedures. intervals.

valves:

quarterly. Therefore, the alternative is in S2(3)2418MU002 and 108 accordance with Part 10, para. 4.3.2.

ATJ 11.0 The check valves This valve requires placing the Test at cold shutdown it is impractical to Part 2 for the CCW surge associated CCW loop out of service. intervals. exercise these valves tank backup his can only be done in a mode in quarterly. Therefore, mtrogen cylinders which the TS permit one CCW Loop to the alternative is in be inoperable, accordance with Part 10, para. 4.3.2.

, (See Appendix A, Item 6)

ATJ 11.0 Nitrogen line check To achieve a close stroke of these check Test at cold shutdown it is impractical to Part 3 valves in supply to valver, the upstream volume of the intervals.

g CCW surge tanks: exercise these valves W associated piping must be isolated and quarterly. Therefore, S2(3)2418MU395 depressurized. This renders the and 402 the alternative is in associated CCW surge tank and accordance with therefore the associated CCW loop Part 10, para. 4.3.2.

inoperable. The result is entry into (See Appendix A, multiple TS LCO Action Statements if Item 2) done during plant operation.

ATJ 12.0 Nuclear service The close stroke verification requires Test these valves at It is impractical to water containment containment access. This is only cold shutdown exercise this valve isolation check practical dunng plant shutdown. intervals.

valve:

quarterly. Therefore, the alternative is in S2(3)l415MU236 accordance with Part 10, para. 4.3.2.

ATJ 12.0 Reactor head and These valves are part of the RCS Stroke these valves It is impractical to Part I pressunzer vent boundary isolstion. Opening these open and closed at exercise these valves valves: valves while the RCS is pressurized cold shutdown quarterly. Therefore, 2(3)HVO296A, would release reactor coolant to the intervals. the alternative is in 296 B., 297 A, 297B, vent system. Further, power is 298, and 299 accordance with normally removed from the solenoids.

~ Part 10, para. 4.2.1.

The licensee's basis should be clariScd (see Appendix A. hem 3).

ATJ 13.0 Auxiliary spray Exercising would result in usuccessary Stroke the valves at it is impractical to Part 2 line valves: severe thermal transients and seress on cold shutdown exercise these valves 2(3)HV9201, the pressurizer spray nozzle. intervals. quarterly. Therefore, S2(3)12OIMU019, the alternative is in and 129 accordance with Part 10, paras. 4.2.1 and 4.3.2.

17

{

Itern Valve Justification for Deferring Valve Proposed Altemate Evaluation of the Number lderitification Exercising Testing Justification ATJ 13.0 Isolation valves in These valves must remain open during Stroke the valves open It is impractical to Part 3 the line from the power operation in order to ensure and closed at the cold exercise these valves regenerative heat consistency with assumptions made shutdown interval. quarterly. Therefore, exchanger to the regarding system flow to the RCS cold the alternative is in RCS: legs in the accident analysis and to accordance with 2(3)HV9202 and comply with the intent of LCO 3.5.2. Part 10, para. 4.2.1.

9203 (See Appendix A, Item 2) l ATJ 13.0 Letdown isolation Exercising these valves during power Stroke the valves It is impractical to i Part 4 valves: operation would result in unnerassary closed at cold exercise these valves 2(3)HV9204 and thermal stress transients on the shutdown intervals. quanerly. Therefore, 2(3)TV0221 regenerative heat exchanger and RCS the alternative is in charging nozzles. , accordance with Part 10, para. 4.2.1.

ATJ 13.0 RCS bleed off to Exercising these valves could result in Stroke the valves ATJ 13.0, Part 5 does Part 5 the VCT isolation reactor coolant pump seal failure and closed at cold not contain an valves: subsequent reactor sht Swn. shutdown intervals, adequate justification 2(3)HV9217 and for not exercising these l 9218 valves quarterly (see Appendix A, Jtem 3).

l ATJ 13.0 Charging line This valve cannot be tested without Test valve at ti.e cold It is iropractical to l Part 6 check valve to RCS closing HV9203 which must remain shutdown frequency. exercise this valve loop 2A: open during power operation in order to quarterly. Therefore, S2(3)12OIMUO20 ensure consistency with assumptions the alternative is in made regardmg system flow to the RCS accordance with in the accident analysis. Part 10, para. 4.3.2.

ATJ 13.0 Charging line This valve cannot be tested without Test valve at the cold It is impractical to Part 7 check valve to RCS closing HV9202 which must remain shutdown frequency. exercise this valve loop 1 A: open during power operation in order to quarterly. Therefore,  ;

S2(3)120l M 't ensure consistency with assumptions the alternative is in made regarding system flow to the RCS accordance with in the accident analysis. Part 10, para. 4.3.2.  :

ATJ 13.0 LPSI pump suction These valves can only be exercised Test these valves at It is impractical to j P:st 8 check valves: when the plant is on shutdown cooling. cold shutdown exercise these valves 52(3)1201MU200 intervals. quarterly. Therefore, j and 202 the alternative is in  ;

accordance with Part 10, para. 4.3.2.

The licensee's basis should be clarified (see A Prendix A, leem' 3).

ATJ 13.0 &ck valves in the To close these valves requires closing Test valves at the cold It is impractical to Part 9 piessuruer spray the upstream control valve and isolating shutdown frequency. exercise these valves line from the RCS: the spray line. This would cause RCS quarterly. Therefore, S2(3)120!MU976 pressure and pressurizer level the alternative is in and 977 perturbations. In addition, the valves accordance with are inside contamment and require a Part 10, para. 4.3.2.

Contammet entry to perform the test, 18

i. . .. . . _ _ _ _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ __ _

l.' '

Iran Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Tating Justification ATJ 14,0 2(3)HV5388 Exercising this valve during plant Test this valve at cold it is impractical to Part 1 power operation isolates instrument air shutdown intervals. exercise this valve to the contmment and could result in a quanerly. Therefore, plant shutelown. the alternative is in accordance with Part 10, para. 4.2.1.

ATJ 14.0 Instrument air There is no way to place a back Test this valve at cald It is impractical to Part 2 containment pressure on this valve without !osing shutdown intervals. exercise this valve isolation check control of the SIT drain valves, hence quarterly. Therefore, valve: this valve can only be tested when the the alterna'ive is in 52(3)2417MU016 SITS are not required (i.e. Modes 5 accordance with and 6). Part 10, para. 4.3.2.

ATJ 14.0 Service air This valve is = contaimnent isolation Teit this valve at ATJ 14.0, Part 3, does Port 3 containment valve and is not used during power reactor refueling not contain an isolation check operation. Stroking this valve during intervals, adequate justification valve: operation would require opening the for not exercising these S2(3)2417MU017 containment penetration and valves during cold performance of operations within the shutdowns (see containment. Appendix A, item 3).

ATJ 15.0 Shutdown cooling Full-stroke testing of these valves Test these valves at it is impractical to full-Pen 1 valves: during power operation would result in cold shutdown stroke exercise these 2(3)HV0396, 8152, non-compliance with TS 3/4.5.2, which intervals. valves quarterly.

8153, 9420, and regires these valves to be closed with Therefore, the 9434 power to the valve operators removed. alternative is in accordance with Part 10, para. 4.2.1.

He justification should be clarified (see Appendix A, item 2).

ATJ 15.0 Shutdown cooling Full-stroke exercising of these valves Test these valves at it is impractical to full- l Port 2 valves: during power operation would result in cold shutdown stroke exercise these i 2(3) HV8160, non smpliance with TS 3/4.5.2, which intervals. valves quanerly. '

8161, 8162, and requires these valves to be open with herefo e, the 8163 power removed, alternative is in accordance with Part 10, para. 4.2.1.

(See Appendix A, Item 2).

ATJ 15.0 Refueling water Closing HV9300 or HV9301 during Test these valves at It is impractical to Pan 3 tank outlet valves: normal plant operation will isolate the cold shutdown exercise these valves 2(3)HV9300 and pump suction and therefore cause the intervals. quarterly. Therefore, 9301 associated train (s) of safety injection the alternative is in (CS, HPSI, and LPSI) to become , accordance with inoperable. This is contrary to the Part 10, para 4.2.1.

requirements of TS 3/4.5.2. and puts (See Appendix A, the plant in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> netion statement. Item 2) 19

Valve Justification for Defening Valve Proposed Alternate Evaluation of the item Identification Exercising Testing Justification Number ne manual stroke test is a non-Code Manually exercise at It is impractical to ATJ 15.0 Shutdown cooling test. These valves are used to establish cold shutdown manually exercise Part 4 valves:

shutdown cooling flow. He manual intervals. these valves quarterly.

2(3) HV9336 and Therefore, the 9379 stroke test is only required to be a part-stroke to demonstrate the operation of alternative is in the valve manually, including the ability accordance with to engage the clutch. Part 10, para. 4.2.1.

These valves are required by TS Test these valves at It is impracticat to ATJ 15.0 Shutdown cooling 3/4.5.2 to be interlocked to prevent cold shutdown exercise these valves Part 5 LPSI suction ,

opening whenever RCS pressure intervals. quarterly. Therefore, isolation valves:

exceeds 376 psia. the alternative is in 2(3)HV9337, 9339, accordance with ,

9377, and 9378 '

Part 10, para. 4.2.1.

Ressoring power to these valves or Test these valves at It is impractical to ATJ 15.0 Safety injection closing them while the plant is at power cold shutdown exercise these valves Part 6 tank outlet valves wou'd result in non. compliance with the intervals. quarterly. Therefore, r to the RCS loops:

TS. the afternative is in 2(3)HV9340, 9350, accordance with 9360, and 9370 Part 10, para. 4.2.1.

(See Appendix A, item 6)

Dunng plant operation, these valves are Close stroke test these It is impractical to ATJ 15.0 Safety injection closed. To exercisc a valve, it unust be valves at cold exercise this valve Part 7 tank fill and drain opened and then stroked closed. shutdown intervals. quarterly. Therefore, line isolation Opening these valves causes the the alternative is in valves:

associated safety injection tank to accordance with 2(3)HV9341, 9351, depressurize, contrary to TS 3/4-5.1. Part 10, para. 4.2.1.

9361, and 9371 This results m a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action statement.

During power operation, TS require Test these valves at It is impractical to ATJ 15.0 Safety injection power to be locked out for these valves. cold shutdown exercise these valves Part 8 tank vent valves:

2(3)HV9345, 9355 This prevents inadvertent intervals. quarterly. Therefore, depressurization of the safety injection the alternative is in 9365, and 9375 accordance with tanks.

Part 10, para. 4.2.1.

Openmg these valves during normal Test these valves at It is impractical to ATJ 15.0 Shutdown cooling  ;

plant operation would required entry cold shutdown exercise these valves Part 9 warm-up valves:

into a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> TS action statement. It frequency when quarterly. Therefore, 2(3)HV9353 and the alternative is in renders both trains of LPSI out of shutdown cooling is 9359 service. Opemng these valves will placed in service, accordance with ,

cause diversion of safety injection flow Part 10, para. 4.2.1.

sway from the RCS loop 2A.

Stroke these valves it is impractical to fail-ATJ 15.0 Reactor coolant hese valves are inside contamment and closed at quarterly safe test these valves Pt.rt 10 loop hot leg it requires personnel entry into mmainment during normal plant intervals and conduct a quarterly. Therefore, injection drain operations to perform a fail-safe test. fail-safe test at cold the alternative is in valves:

His renders the test impractical on a shutdown intervals. accordance with ,

2(3)HV9433 and Part 10. para. 4.2.1.  ;

94'i7 regular basis.

20

.' 1 I

Itern Valve Justification for Deferring Valve Proposed Alternate Evahation of the Number Identification Exercising Testing Justification l

ATJ 15.0 ne check valves These valves are in the 24* supply line Quarterly, perform a It is impractical to full-Pert i1 in the line from the from the RWST's to the suction headers part-stroke test (open) stroke exercise these RWST to CS pump of the HPSI, LPSI and CS pumps. of each valve using valves quarterly or suction header: These valves cannot be full-stroked system flow. At each during cold shutdowns.

S2(3)12(MMU001 using flow during power operation, for refueling outage, test %e alternate method and 002 the following reasons: a) The HPSI the valve by partial for full-stroke (shutoff head 1500 psi) and LPSI disassembly, exercised is approved (shutoff head 200 psi) pumps are unable inspection and manual by GL 8944 provided to overcome RCS pressure. There is stroking on a rotating that the testing no full flow recirculation to the RWST basis (one valve per complies with all of from either pump. As a result, only refueling). During the provisions of pump recirculation through the partial disassembly, GL 89-CM, Position 2 ,

(see Appendix A, I miniflow line is produced using these the valve internals will pugr., while the RCS is pressurized. be visually inspected Item 4). f Although this is sufficient for a part- for worn or corroded j stroke test, flow for a full-stroke test is parts, and the valve not available. b) A quarterly test at disk will be manually power, using the only available flow exercised. If it is path, would either inject borated water found that the full-into the RCS or spray down the stroke capability of the containment building, or both. If disassembled valve is injection were possible during in question, the other operation, the test would not be valve will be similarly performed because the result would be disassembled and an immediate, uncontrolled and mspected and complete reactor shutdown (as a result manually full-stroked of the borated water) and/or flooding during the same and r-sultant degradation of the outage. Following components and systems located in the reassembly, the valve containment building. c) ne CS will be tested by pumps cannot be utilized to full-stroke partial stroking using these valves using flow, as the only full system flow, flow path during plant operation is through the containment spray nozzles.

nese valves cannot be full-stroked using flow during cold shutdown for the following reasons: a) Sufficient flow to full-stroke these valves is not achievable in this condition. Return flow from the HPSI and LPSI pump discharge lines is limited to mini-flow recirculation flow and RCS vent flow, b) The CS pumps have a 6" recirculation line to the RWST's, but these pumps by themselves cannot j develop full-stroke flow for the valves. I I

l l

l l

l l

l 21

-. a - .n - _ ;. - 2 ----r .u nn _. _ n

,i ,

I t

Itern Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Nurnber Identification Exercising - Testing Justification ATJ 15.0 c) Stroking the RWST outlet check Part 11 valves with flow from the LPSI pumps (cont.) is pmhibited by the TS in cold shutdown because the LPSI pumps must ,

be aligned to take suction from the RCS  :

to provide shutdown cooling. d) The ,

equivalent of the combined CS, LPSI, and HPSI flow rate cannot be developed with the HPSI punm alone. The HPSI pumps cannot be used to exercisc these valves during cold shutdown because of the risk of exceeding cooldows rate limits. The water in the RWST is ,

normally at an ambient temperature of -

= 65'F and the cooled down RCS is nominally at = 135'F. e) The Code i required testing while the plant is in cold shutdown could only be performed  !

after significant redesign of the system.  ;

such as the addition of an instrumented full flow test line. f To full-stroke these valves using flow during refueling with the reactor vessel bend removed, would require that the .!

system achieve a test-flow of i approximately 6500 gpm. Full flow from the RWST through these check valves is only achieved with all of the pumps in one train running at the same time (one HPSI, one LPSI and one CS).

With the reactor pressure vessel head removed, flow would first fill and then overflow the reactor pressure vessel into the refueling cavity. Injection of the borated RWST water could result in a cool-down rate in violation of the TS for the reactor vessel.

From the above discussion, it can be seen that no allowable flow path esists in any plant mode for a full-stroke of the RWST outlet check valves using flow. Testing of these valves could only be accomplished after significant redesign of the system. such as ,

installation of a full flow test loop.

NRC Generic letter 89-04, Attachment 1, Position 2, i.ientifies partial disassembly and inspection as an acceptable alternative for stroking a valve when it is impractical to use flow.

22

^' ,

s Justification far Deferring Valve Proposed Alternate Evaluation of the l Jtesn Valve Exercising Testing Justification  !

Number Identification The only source of water to the inlet of The valves will be It is impractical to full-ATJ 15.0 Check valves in the the contamment sump outlet check partially disassembled, stroke exercise these Part 12 lines from the valves is the contamment building mspected and valves quarterly or contamment sump manually full-stroked during cold shutdowns.

to the suction of sump. During normal plant operation this sump is required to be kept dry and each refueling outage ne alternate method the ECCS pumps:

the isolation valves shut. His system on a rotating basis. for full. stroke 52(3)1204MUOO3 exercised is approved lineup precludes either full-stroke or During disassembly, and OM the valve internals will by GL 89-04 provided part-stroke of these check valves using be visually inspected that the testing flow in this mode.

for worn or corroded complies with all of In cold shutdown or reactor refueling parts, and the valve the provisions of disk will be manually GL 89-04, Position 2 modes, part-stroke exercising of these valves is possible with flow from the exercised. If it is (see Appendix A, contamment sump, however, the sump found that the full- Item 4).

is not maintained at a cleanliness level stroke capability of the consistent with the internals of the disassembled valve is Safety injection or RCS piping. The in question, the other cleanup of the containment sump to a valve will be similarly cleanliness level consistent with the disassembled and internals of the Safety injection or RCS mspected and would be labor intensive. manually full-stroked during the same If part-stroke exercising were conducted outage. A method of by filling the sump with water and flow partial flow testing testing these valves, this would will be developed and potentially contammate the safety used following the injection systems, the RWST, and the disassembly prior to RCS with low quality water. This returning the valve to would cause accelerated corrosion and service.

degradation. Extensive flushing and cleanup following such testing would be required.

The Code required testing could only be performed after significant system modifications involving considerable costs. NRC Generic Letter 89-04, Attachment 1, Position 2, identifies partial disassembiy -id inspection as an acceptable alternative for troking a valve when it is impractical e use flow.

These valves will be it is impractical to full-ATJ 15.0 HPSI pump suction This check valve cannot be full-streke exercised during power operations full-stroke exercised stroke exercise these Port 13 check valves:

because the high pressure safety each refueling by valves quarterly or S2(3)12NMU006 during cold shutdowns.

injection pumps cannot overcome RCS using the HPSI pumps and 008 Herefore, the pressere. During cold shutdowr. full- to fill the refueling stroke exercising this valve could result pool canal, and part- alternative is in stroke exercised accordance with in a low temperature over-pressurization quuterly. Part 10, para. 4.3.2.

of the RCS.

23

Itern Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 15.0 HPSI pump These valves cannot be exercised while Test these valves at It is impractical to full-Pert 14 discharge check the plant is at power because the HPSI cold shutdown stroke exercise these valves: pumps cannot overcome RCS pressure. intervals. valves quarterly.

S2(3)1204MUO12, To exercise the disks to the fully open Therefore, the 015,016, and 017 position requires 200 GPM, which is altemative is in not available, accordance with Part 10, para. 4.3.2.

ATJ 15.0 HPSI combined Exercising these valves while the plant Test these valves at It is impractical to full I Port 15 header to RCS is at power would result in cold shutdown stroke exercise these check valves: non-compliance with TS 3/4.5.2. intervals. valves quarterly.

52(3)1204MU018 Therefore, the >

019,020, and 021 alternative is in

. accordance with Part 10, para. 4.3.2.

ATJ 15.0 RWST isolation These valves are locked open during Test these valves at ATJ 15.0, Part 16, Part 16 valves to LPS! normal operation. Closing them will cold shutdown does not adequately pump suction: cause the associated train of LPSI to be intervals. demonstrate the S2(3)12NMUO22 inoperable and fail to meet the impracticality of and 023 requirements of TS 3/4.5.2, which exercising these valves requires two independent ECCS closed quarterly during subsystems to be operable and restore power operat ions (see the inoperable subsystem to operable Appendix A, Item 2).

status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

ATJ 15.0 LPSI pump Whi!e the plant is at power, LPSI Test these valves at It is impractical to Part 17 dischcrge stop pumps cannot overcome RCS pressure. cold shutdown exercise chese valves check valves: Additionally, aligning the system intervals. quarterly. Therefore, S2(3)1204MUO24 discharge to the RWST would defeat the alternative is in and 025 both trains of LPSI. accordance with Part 10, para. 4.3.2.

ATJ 15.0 Safety injection During power operation there is no full Test these valves at It is impractical to full-Pcrt 18 headers to the RCS flow path available to stroke test these cold shutdown stroke exercise these check valves: valves. LPSI or HPSI pumps cannot intervals. valves quarterly.

S2(3)1204MUO27, overcome the RCS pressure. Requires Therefore, the 029,031, and 033 2000 GPM for full-stroke. alternative is in accordance with Part 10, para. 4.3.2.

ATJ 15.0 Safety injection Verifying closure of these valves Test these valves at It is impractical to Pcrt 19 pump miniflow line requires placing the miniflow line out of cold shutdown exercise these valves check valves: service for the HPSI, LPSI, and CS intervals. quarterly. Therefore, S2(3)1204MUO34, systems. This renders those systems the alternative is in 035, 036, 037, out of service and is only practical in accordance with 063, and IN modes where these systems are not Part 10, para. 4.3.2.

required to be operable.

24

--. . . . - ~ . - .

item Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 15.0 Safety injection Opening these valves during power Part-stroke on a cold It is impractic'i a to full-Part 20 tank outlet check operation is not possible against normal shutdon interval. At stroke exercise these valves: RCS operating pressure. A part-stroke refueling intervals valves quarterly or S2(3)1204MUO40, test is the only test possible during cold disassemble and hand during cold shutdowns.

041,042, and 043 shutdon due to system configuration. stroke. The valve The alternate method OM-10 Section 4.3.2.4(c) states, *As internals shall be for full-stroke exercised an alternative to the testing in (a) or (b) visually inspected for is approved by above, disassembly every refueling worn or corrodal parts. GL 89-04 provided that outage to verify operability of check Verify that the valve is the testing complies valves may be used." GL 89-04 allows capable of full-stroking with all of the development of staggered testing of like and that the internals provisions of GL 89-04, components by establishing an are structurally sound. Position 2 (see mspection plan for similar groups of Tnis shall be done at Appendix A, Item 4).

valves. This is stated in position 2 of each refueling outage GL 89-04. on a rotating basis.

Test one group valve each refueling outage, until the entire group has been tested. If the disassembled valve is not capable of being exercised or there is binding or failure of the internals, the remammg group valves shall be disassecioled, mspected, and manually exercised during the same outage. A partial flow test shall be )

performed before returning the valve to service.

ATJ 15.0 LPSI injection check There are ne flow paths to exercise these Test these valves at It is impractical to full-Par' 21 valves to the RCS: valves during power operation. The cold shutdown stroke exercise these 52(3)12NMUO72. LPSI pumps cannot overcome RCS intervals. valves quarterly.

073, 074, and 075 pressure while the plant is at power. Therefore, the alternative is in accordance with Part 10, para. 4.3.2.

l 25

- - ~

Itein Valve Justification for Deferring Valve Proposed Alternate Eraluation of the Number Identification Exercising Testing Justification ATJ 15.0 LPSI pump suction ne cold shutdown interval for the Quarterly, part-stroke It is impractical to full-Part 22 header check valves: closed test is required due the exercise these valves. stroke exercise this S2(3)1204MUO77, impracticability of erecting scaffolding A flow path exists valve quarterly.

084,199, and 201 and handling the heavy radiography during the filling of the herefore, the apparatus in the vicinity of the safety refueling canal with the alternative is in injection equipment. Full-stroke LPSI pumps in plant accordance with exercising these valves with flow Mode 6 (refueling). Part 10, para. 4.3.2.

requires the passage of maximum The suction of the LPSI required accident flow rate through the pumps can be aligned valves. These valves cannot be to the RWST and the full-stroke exen:ised using flow during discharge to the LPSI power operation, for the following header or shutdown reasons: a) ne mini flow recirculation cooling header. Flow lines cannot provide enough flow could then be directed ihrough these valves. b) During power through the LPSI operation, the shutdown cooling system suction header check ,

is isolated and must remain so due to valves at full flow interlocks controlled by TS 3.4.5.2.d. c) (LPS1 pump design Injecting water into the RCS during flow is 4150 gpm at power operation is not possible. The 400 psid) for a short LPSI pumps are unable to overcome period of time sufficient RCS system pressure. If a test at power to full-stroke these could be conducted, it would result in valves with flow.

injection of borated water into the RCS, Therefore, the valves resulting in a reactor shutdown. will be full-stroke exercised using flow at The TS require that the LPS! pumps reactor refue. ling remain aligned to provide shutdown intervals.

cooling at all times while the plant is in cold shutdown. Rese valves are bypassed and cannot be full-stroke tested using flow. Compliance with the Code requirement to perform quarterly testing could only be accomplished after a major 1 modification of the system design. l l

ATJ 15.0 CS pump suction No flow path exists to exercise these Test these valves at It is impractical to l Part 23 check valves: valves to the open position during plant cold shutdown exercise these valves l S2(3)1204MUOB7 operation without removing both trains intervals. quarterly. %erefore,  !

pad 088 of CS and LPSI from service. the alternative is in  :

accordance with Part 10, para. 4.3.2. ,

\

ATJ 15.0 Manual containment Opemng this valve at power for test Part-stroke test this AD 17.22 does not 1 Port 24 isolation valve in the requires entry into a TS Action valve at a cold adequately demonstrate drain line from the Statement due to breach of contamment shutdown intervals. the impracticality of safety injection integrity. exercising this valve tanks to the RWST: quarterly (see S2(3)1204MUO99 Appendix A. Item 2).

26

,o > ,

Itern Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 15.0 HPSI to RCS bot Valve cannot be stroked at power Test this valve at cold It is impractical to Part 25 leg injection check because the HPSI pumps cannot shutdown intervals. exercise this valve valve: overcome RCS pressure. Additionally, quarterly. Therefore, S2(3)12NMU152 opening the HPSI header isolation valve the alternative is in during power operation would result in accordance with non<ompliance with TS 3/4.5.2. Part 10, para. 4.3.2.

ATJ 15.0 HPSI header to the Full or part-stroke exercising of these Test these valves at It is impractical to full-Part 26 RCS hot leg check valves while the plant is at power would cold shutdown stroke exercise these valves: result in non-compliance with TS intervals. valves quarterly.

S2(3)1204MU155, 3/4.5.2. In addition, while the plant is nerefore, the 156,157, and 158 at power, the HPSI pumps cannot alternative is in overcome RCS pressure. accoidance with

, Part 10, para. 4.3.2.

ATJ 16.0 Steam line to AFW ne manual stroke is a non-Code Manual stroke (partial) It is impractical to Part I pump isolation required test and a cold shutdown at cold shutdown in exercise these valves va'ves: interval has been judged as adequate to addition to normal quarterly. Therefore, 2(3;HV8200 and show tnat the valves can be manually testing. the alternative is in 8201 actuated if necessary in accordance with accordance with EOls. Part 10, para. 4.2.1.

ATJ 16.0 Steam generator Full-stroke exercising at full power Perform a full-stroke It is impractical to Pert 2 main steam isolation would cause a loss of 50% of the heat close test at cold exercise these valves valves (MSIVs): removal from the pnmary coolant shutdown. quarterly. Hertfore, 2(3)HV82N and system, a reactor trip on asymmetric the alternative is in 8205 power in the core and actuation of the accordance with steam and pressurizer reliefs. A part- Part 10, para. 4.2.1.

stroke of the MSIVs can be used as an indication of the ability of the MSIV to close during an accident. He part-stroke test could result in an inadvertent closure of an MSIV and a reactor trip.

A probabilistic risk assessment of the part-stroke test of the MSIVs and determined that the risk to the health and safety of the public is reduced by approximately an order of magnitude by eliminating the part-stroke test of the MSIVs. He calculated off site dose impact from inadvertent closure of an MSIV during the part-stroke testing is estimated to be 0.5 man-rem per yt ar.

He calculated off site dose from faiure of an MSIV to close during an accident due to elimmarmg the part-stroke testing is estimated to be 0.045 to 0.075 man-rem per year. Therefore, the rat-stroke testing should be eliminated.

27

Justification for Deferring Valve Proposed Alternate Evaluation of the !

Item Valve Number Identification Exercising Testing Justification ATJ 16.0 Main steam Full-stroke exercising these valves Test these valves at It is impractical to atmospherie dump during powcr operation could result in a cold shutdown exercise these valves Port 3 valves: reactor plant transient due to energy intervals. quarterly. Therefore, 2(3)HV8419, and released via the steam dump. Fully the alternative is in 8421 opening an ADV without isolation of the accordance with steam flow path at power risks plant Part 10, para. 4.2.1.

upset and trip as this allows a large steam release, approximately 5% of 3410 MW thermal, and a resultant pressure transient when the ADV is tripped closed. The pressure transient could result in RCS temperature excursions that could cause an engineered safety feature (ESF) initiation with the associated reactor trip. There is a maintenance block valve upstream of the ADV. This valve could be closed to block steam flow to allow the ADV to l be fully opened for test without releasing  !

steam. However, an isolated ADV is  !

unavailable to perform its function with the block valve closed necessitating entry into the action requirements of TS 3.7.1.6 and aggravatmg the unavailability of the ADV's from a plant reliability point of view.

A part-stroke of the ADV can be performed, while the ADV is experiencing full system pressure, by opening the valve to approximately 25%.

The ADV's are designed with integral pilot valves that assist in opening the ADV when it is under pressure. He pilot valve equalizes pressure across the ADV (partially) dunng the open stroke.

Part-stroke exercising with main steam pressure appl.ied followed by closing the ADV in a similar manner as would a

> MSIS actuation, demonstrates the ADV and its pilot valve's ability to open and close under actual operating conditions.

The pilot valve stroke length is the first 5 % of the stem travel. This fully exercises the pilot valve and piston ring, and partially exercises the main plug.

The pilot valve serves no function when the ADV is not under system pressure.

The depressurized stroke test is an artificiality that does not demonstrate the ,

ability of the ADV to function under design conditions.

28

ij, . . ,

Itan Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 16.0 ADV nitrogen These valves are pressure control valves Test at cold shutdown It is impractical to Part 4 accumulator and are therefore excluded from intervals in conjunction exercise these valves pressure control inservice testing n:quirements under with the testing of the quarterly. Therefore, valves: OM-10, Section 1.2. The backup associated ADV. the alternative is in 2(3)PCV8463 and nitrogen gas supply to the ADV will not accordance with 8465 be available while pressure control Part 10, para. 4.3.2.

valves are stroked open. This The licensee's basis necessitates an entry into the action should be clarified (see requirements of TS 3.7.1.6. These Appendix A, Items 2 valves are open stroked during IST of and 5).

the respective ADV's at cold shutdown intervals. Therefore the practical test frequency is cold shutdown in conjunction with the ADV IST.

• ATJ 16.0 ADV equalir.ing ball These valves are not Code valves. In Test these valves at Non-Code Class Part 5 valves: spite of the fact that they are exempted cold shutdown components, NRC S2(3)1301MU1264 from IST since they are provided for intervals. approval is not and 1265 operating convenience, they have been required. The included in the IST program to assure licensee's basis should functionality. MU1264 and MU1265 are be clarified (see open and closed stroked durmg IST of Appendix A, item 5).

the associated ADV at cold shutdown intervals. In order to stroke the valve closed, the associated ADV must be declared inoperable because normal control air must be isolated. Therefore the practical test frequency is cold shutdown in conjunction with the ADV IST. The response to Question 53 in Reference 2.5.2 is followed for guidance in these cases.

ATJ 16.0 ADV nitrogen The ADV is inoperable when the backup Test these valves at Non-Code Class Part 6 supply isolation nitrogen source is isolated. MU1328 and cold shutdown cor:ponents, NRC valves: MUO21 are not Code valves and are also intervals. approval is not 52(3)l30lMU1328 exempted from IST since they are for required.

and 021 opersting convenience. These valves are opened and closed during IST of the associated ADV's at cold shutdown intervals. Therefore the practical test frequency is cold shutdown in conjunction with the ADV IST.

l l

29

~- - ._ -

h Itan Valve Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification ATJ 16.0 Check valves in the During normal plant operation, main Quarterly, perforin a It is impractical to full-Part 7 steam supply lines steam preasure tends " open these part-stroke test (open) stroke exercise these to the AFW pump valves. No pressure _ ice exists to of each valve using valves quarterly or turbines: reverse this pressure in the steam line system flow. At each during cold shutdowns.

S2(3)l3OIMUOO3 where these valves are located and allow refueling outage, test The alternate method and 005 detection of valve closure or valve the valves by partial for full-stroke exercised leakage. Verifying closure of the AFW disassembly, inspection is approved by pump steam supply check valves by leak and manual stroking on GL 89-04 provided that testing or with reverse flow, while the a rotating basis (one the testing complies plant is operating, is not practical. valve per refueling). with all of the Although a temporary external pressure During disassembly the provisions of GL 89-G4, l source could be booked up to the down valve internals will be Position 2 (see stream piping, and apoly reverse visually inspected for Appendix A, Item 4).

pressure to these check valves, the worn or corroded parts, required valve lineup would cause the and the valve disks associated AFW pump to be inoperable shall be manually during the test. Regardless of plant exercised. If it is found mode, there is no positive means of that the full-stroke verifying that the valve disc travels to capability of the the closed position. System connections, disassembled valve is in i such as vents and drains (and appropriate question, the other ,

line isolation valves) are not present to valve will be similarly allow verification that a pressure disassembled and i i

differential exists across these valves, mspected during the Testing tt.ese valves could only be same outage. i accomplished after significant redesign, Following reassembly such as installation of additional isolation and prior to return to valves and appropriate vents and drains service, the valve will in the high pressure steam piping. The be tested by partial high costs of the necessary design stroking using system changes involved would not be justified flow, by the improvement of the valve testing.

Further, the addition of valves, supports l and necessary piping modifications could g

result in reduced plant reliability.

1 30 l

= =. : =. -- -- -

==:=== -- - ' -

Itan Valre Justification for Deferring Valve Proposed Alternate Evaluation of the Number Identification Exercising Testing Justification  !

Check valves in the Full or part-stroke exercising using flow Exercise these valves at It is impractical to ATJ 17.0 is not possible with the current system reactor refueling exercise these valves drain lines frem the CCW pump room to configuration. There is no source of shutdown intervals or quarterly or dur'.ng cold flow to either make these valves go open justify removal from shutdowns. Therefore, the CCW sump:

S2(3)2426MUO56, or closed. There are no connections the IST program. the alternative is in  ;

057, and 058 associated with these valves to facilitate accordance with temporary pumps for testing. Access to Part 10, para. 4.3.2.

these valves is not physically practical at this time. Following a design change, these valves will be accessible for disassembly and hand exercising. These j

valves were part of a cross flooding calculation to providejustification for removal from the IST program. The calculation showed that removal from the IST program is possible with a minor ,

modification. In either case, testing or removal from the IST program cannot be done until modifications are pedormed in the cycle 8 outage.

5 l

l 31

-e ,

m- ,,,n, ,

' ~ ' ~ ' ' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ - - - ~ - ~---

r . . - - - - . . , . . .. . . - . . . . , , . . ~ .. .- ~~~.~~~

e ** .

9 9

APPENDIX A ,

IST PROGRAM ANOMALIES i

i l

A-1

APPENDIX A IST PROGRAhi ANOhfALIES Anomalies or inconsistencies found during the review are given below. These anomalies summarize concerns with the IST program that require additional actions by the licensee for resolution. The licensee should resolve these items as indicated.

1. The IST program breaks Alternate Testing Justifications (ATJs) into sections based on plant systems, but does not include specific identifiers for the ATJs within each section.

This makes it difficult to refer to specific ATJs in this report and in future correspondence between the licensee and the NRC. We recommend that the licensee include a unique identifier for each valve or valve group ATJ in subsequent IST program submittals. For the purpose of this report, where there are more than one ATJ in a section, we designated the first one "Part 1," the second "Part 2," etc.. Using these designations along with the valve numbers from Table 3.1, the reader can determine which ATJ i:; being discussed.

2. ATJs 1.0 Part 3, 3.0 Part 1, 3.0 Part 7, 4.0 Part 5,13.0 Part 3,15.0 Part 1,15.0 Part 2,15.0 Part 3,15.0 Part 18,15.0 Part 24, and 16.0 Part 4 contain statements such as "To achieve a close stroke of these valves . . causes entry into a Technical Specification LCO Action Statement." In GL 87-09, the NRC stated its position that the structure of the referenced TS accounts for entry into an LCO to perform surveillance testing. The NRC issued guidance on the entry into an LCO as documented in NRC Inspection hianual Part 9900, " Technical Guidance - hiaintenance - Voluntary Entry into Limiting Conditions for Operation Action Statements to Perform Preventive hiaintenance."

When removing a train from service to perform surveillance testing, a licensee must j ensure that the other train is operable. The probability of a design basis accident l occurring during the short period of time that a train is out of service is considered low, l while the assurance of component operational readiness achieved through surveillance l testing provides an increased level of safety. However, IST which results in a system being completely removed from service may not be acceptable for safety. Entry into multiple LCO should be avoided, such that IST of different systems at the same time may be prohibited by the safety analysis, although the safety analysis may not prohibit certain situations and plant configurations.

hiany of the listed ATJs involve manual valves with LCO Action Statements of at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. A plant operator would have to be present at the valve in order to exercise the valve. This evolution should take only a few minutes and the valve could be immediately repositioned by the operator if the system were needed to mitigate the consequences of an accident. Therefore, system unavailability due to this testing should be extremely small. Unless accompanied by other acceptable rationale, a required entry into an LCO to perform IST would not justify deferring testing until a cold shutdown or refueling outage. The listed ATJs should be revised to adequately justify the deferral of valve testing or the valves should be tested at a more frequent Code interval.

A-2

---: ;--c-- r-- - __ _ --------------2---------------------------

i l '

3. Several of the ATJs do not adequately demonstrate the impracticality of testing the subject valves quarterly during power operation or during cold shutdowns (if testing is deferred until refueling outages). OM-10, Paragraphs 4.2.1.2 and 4.3.2.2, permit deferral of full-stroke exercising until cold shutdowns when this exercising is not practicable during plant operation and permit deferral until refueling outages when this exercising is not practicable during plant operation or cold shutdowns. OM-10, Paragraph 6.2(d), requires the owner to include the justifications for these deferrals in their test plans. These justifications should provide technical bases that show why testing more frequently is impracticable. These bases should explain the negative consequences that may result if the valve is tested during power operation or during cold shutdowns (if applicable). Examples of negative consequences of testing that i

adequately demonstrate impracticality are that the testing could cause equipment damage, represent a safety hazard to test personnel, or result in a significant power reduction or plant trip. M ATJ 3.0, Part 7, is an example of where the justification does not identify any negative consequence that may make more frequent testing impracticable. The licensee states that testing would "... isolate the Chemical and Volume Control System and charging pumps to Reactor Coolant System." The reader is left to determine if the duration of the disruption would be sufficient to cause a decrease in pressurizer level that could result in a plant trip, cause sufficient fluctuations of RCS pressure to be of concern, cause thermal stress and possible damage to the regenerative heat exchangers, or result in some other negative consequence.

Other ATJs that do not provide adequate justifications for not testing at power operation l

and/or during cold shutdowns are listed below along with the frequency for which l

additionaljustification is needed. In most of these cases the reviewer can confidently postulate the negative consequences of performing testing during power operations and/or during cold shutdowns (as applicable). However, due to differences in plant design and operation, ths reviewer should not have to make these assumptions, therefore, the pertinent information should be furnishe.S by the licensee. This is not to suggest that the licensee should change the proposed testing frequency for the affected valves, although, upon further evaluation, the licensee may elect to change these frequencies as is justified. These ATJs should be revised to adequately justify the deferral of valve testing.

9.0 Quarterly 13.0, Part 1 Quarterly 13.0, Part 5 Quarterly 13.0, Part 8 Quarterly 14.0, Part 3 Cold Shutdown 15.0, Part 19 Quarterly

4. In ATJs 5.0 Part 3,7.0 Pan 2,15.0 Part 11,15.0 Part 12,15.0 Part 20, and 16.0 Part 7, the licensee proposes to verify the required obturator movement of the affected check valves by disassembly and inspection. The NRC considers valve disassembly and inspection to be a maintenance procedure and not a test equivalent to the exercising A-3

produced by fluid flow. This procedure has some risk, which make its routine use as a substitute for testing undesirable when some method of testing is pracdcable.

Disassembly and inspection, to verify the full-stroke open or closure capability of check valves should 'oe used only where exercising cannot be practically performed by system pressure, flow, or other positive means. Check valve disassembly is a valuable maintenance tool that can provide much information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service. Regarding several of these DTJs, the licensee has not adequately demonstrated the impracticality of vedfying the required obturator movement by testing. Some test method may be feasible to verify the required exercise of these valves. The licensee should consider methods such as using non-intmsive techniques (e.g., acoustics, ultrasonics, magnetics, radiography, and thermography) to verify a full-stroke exercise of the subject check valves. This testing may only be practical at cold shutdowns or refueling outages. The licensee should perform their investigation and if a test method is found tcr be practicable, the IST requirements of the applicable valves should be satisfied by testing instead of disassembly and inspection. The licensee should respond to this concern.

Check disassembly and inspection that deviates from that prescribed in OM-10, Para.

4.3.2.4, and/or GL 89-04, Position 2, should not be performed unless specific relief is requested and approved. Whether the licensee complies with the provisions of GL 89-04 is subject to NRC inspection. If the licensee intends to deviate from a GL 89-04 position, a relief request must be submitted for review and approval prior to implementing the testing.

5. Some of the licensee's ATJs are confusing due to inconsistencies or other problems.

The following lists the affected ATJs and briefly describes the points of confusion. The licensee should consider clarifying these ATJs, if necessary.

7.0 Pan 1 This ATJ indicates that opening the subject valves could defeat both trains of LPSI. It is highly undesirable to defeat both trains of LPSI, however, it is not clear why the valves could not be tested one at a time, which should disable only one train of LPSI at a time.

7.0 Part 4 This ATJ indicates that full-stroke exercising the subject check valves would disable both trains of LPSL It is highly undesirable to disable both trains of LPSI, however, it is not clear why the valves could not be tested one train at a time, which should disable only one train of LPSI at a time.

16.0 Part 4 This ATJ states that the listed valves are normally closed and required to open to provide nitrogen backup to instrument air for small break LOCA when manual operation of the ADV is not possible. It also states that the valves are designed to fail open. However, this ATJ indicates that the valves are pressure control valves that are excluded from IST under OM-

10. If the valves are required to open and/or have a required fail-safe function, they are not excluded from IST under OM-10.

A-4

l s0 16.0 Part 5 This ATJ states that the listed valves are normally open but are required ,

to close to isolate the ADV nitrogen supply to allow manual ADV j operation which is r. quired if remote operation is not possible during a ]

steam generator tube rupture, ain steam line break, feedwater line  ;

break, fire and control room t - '1ation. However, the ATJ further '

states that the valves are for operating convenience and exempted from IST. If the valves perform a required safety function, they are not operating convenience valves.

6. Some of the licensee's ATJs contain errors that do not have a major impact on the implementation of the program, however, they should be corrected to make the program more accurate.

3.0 Part 3 The ATJ lists the wrong OM-10 paragraph for Category C check valves.

This error occurs in several other ATJs involving check valves or a combination of valve types.

4.0 Part 1 No basis is specifically identified for not testing valves 2(3)HV6223 and 6236 quarterly. However, it is the reviewer's opinion that the basis listed for valves 2(3)HV6211 and 6216 also applies to valves 2(3)HV6223 and 6236.

11.0 Part 2 This ATJ states that the listed valves admit backup nitrogen to the CCW surge tanks. However, the Alternate Testing states that the valves will be tested at cold shutdown intervals in conjunction with the testing of the associated ADV. There does not appear to be any connection between the listed valves and the ADVs.

15.0 Part 6 Tnis ATJ states that opening the subject valves while the plant is at power would result in non-compliance with the TS. These SIT block valves are required to be open during power operation.

7. ATJ 8.0 deals with the emergency diesel generator skid mounted valves. The NRC position is that until the scope of components for 10 CFR 50.55a is expanded to include all safety-related pumps and valves, and until the OM codes and standards specifically address skid-mounted components, the testing of the major component is an acceptable means for verifying the operational readiness of the skid-mounted and component subassemblies. These components may be listed separately in the IST program, if desired, noting that they are not in the required scope of 10 CFR 50.55a. Appendices A and B to 10 CFR Part 50 may require, for some plants, testing of certain of these components, and the IST program is an acceptable program for safety-related pumps and valves outside the Code class boundaries.

There are some aspects of ATJ 8.0 that are confusing and the licensee may desire to make changes to address these situations. ATJ 8.0 deals with an alternate test method while all other ATJs in the IST prog"am provide bases for other than the quarterly test interval. There may be a more appropriate place in the IST program for the A-5

t. information provided in ATJ 8.0. The third paragraph following the " Alternate Testing" includes the following statement "...a single failure of any active component cannot affect the ability to store and deliver fuel." In addition, the fourth paragraph following the " Alternate Testing" includes the statement "A single failure in the starting air system will not prevent a diesel start." These statements indicate that there is total redundancy in the diesel fuel oil and starting air systems such that one train could fail and the diesel would still be capable of performing its function. However, the fifth paragraph following the " Alternate Testing" states: "Each of the components identified in the attached tables is demonstrated operable by virtue of the fact that the engine (s) start in the requisite time, carries the required load, and exhibits operating parameters (temperatures, pressures, etc.) that fall within the vendors recommended values." This paragraph does not appear to take into account the total subsystem redundancy referred to in the previous quotations.

A-6