ML20126J158

Safety Evaluation Supporting Request for Relief from ASME Section XI Code Requirements for Inservice Testing Requirements

ML20126J158
Person / Time
Site:	Hatch
Issue date:	06/04/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20126J136	List: ML20126J134 ML20126J158 ML20126J213
References
TAC-11260, TAC-11261, NUDOCS 8506180539
Download: ML20126J158 (39)

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' g UNITED STATES NUCLEAR REGULATORY COMMISSION 5 j WASHINGTON, D. C. 20555

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ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS GEORGIA POWER COMPANY EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 000KET NO. 50-321 PDR I

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% o t a TABLE OF CONTENTS Subject Pm  !

Introduction............................................................ 1 Evaluation.............................................................. 2  ;

A. Genera 1............................................................. 2 B. Pump Testing Program and Relief Requests............................ 2

1. Program......................................................... 2

2. Specific Requests for Relief.................................... 3 '

a. Standby Liquid Control Pumps................................ 3

b. Plant Service Water and RHR Service Water Pumps............. 4

c. Residual Heat Removal and Core Spray Pumps.................. 5

d. Jockey Pumps................................................ 6 C. Valve Testing Program and Relief Requests........................... 7

1. General Considerations.......................................... 7

2. Program........................................................ 10

3. General Requests for Relief.................................... 12

4. Specific Requests for Relief................................... 13

a. Mai n Steam a nd Feedwate r ( B21) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

b. Reactor Recirculation (B31)................................ 14

c. Standby Liquid Control (C41)............................... 15

d. Re sidua l Hea t Remova l ( E1.1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

e. Coie Spray (E21).......... ................................ 18

f. HPCI (E41)................................................. 20

g. RCIC (E51)................................................. 23

h. Reactor Wa te r Cleanup (G31) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 .

1. Pl a nt Se rvi ce Wate r ( P41) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

j. Reactor Building Closed Cooling Water (P42). . . . . . . . . . . . . . . . 30 -

k. D rywe l l P re uma t i c ( P 70 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

1. Control Rod Drive.......................................... 31 i

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. ce s ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS GEORGIA POWER COPPANY EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. I j DOCKET NO. 50-321 INTRODUCTION This report provides a safety evaluation of the Hatch Unit 1 program for inservice testing of pumps and valves; and, in particular, of the licensee's i requests for relief from regulatory requirements applicable to the subject

program. The Code of Federal Regulations [10 CFR 50.55a(g)] requires that inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel i Code and applicable addenda. 10 CFR 50 550.55a(g)(6)(1) authorizes the Commission to grant relief from code requirements for testing upon determining that the testing requirements are impractical. It also authorizes imposition of i

alternste requirements and augmenting requirements upon making the necessary i determination.

The IST program for Hatch Unit I and its associated relief requests addressed in

, this report were submitted to the Commission with the licensee's transmittal letter dated August 12, 1933. The program was prepared to comply with ASME Section XI, 1980 edition with addenda through Winter 1980 (the Code), which is the applicable code required by 10 CFR 50.55a(g). -

1 The Final Safety inalysis Report for Hatch Unit 1 and selected piping drawings (itsted in Attachment 2) were the primary sources of plant-specific information used in this evaluation. Additional information was obtained from the licensee as follows:

During an inspection at the Hatch site March 14 - 18, 1983 (documented in NRC Inspection Report 321,366/83-08).

• During a meeting with licensee personnel held at the NRC Region II offices e on June 23, 1983.

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Enclosure 1 2 During an inscettien at the Hatch site February 27 - March 2,19Ec (eccu-rented in NE: Inspection Repcrt 321,366/Sc-06.)

Additional infermation provided by the licensee in its letter cate:

March 26, 1954.

Recuireeents and interpretations censidered applicable to the licensee's precra- "

and used in the staff's evaluation include the follo.ing:

(1) Code requirezents referred to above, and (2) Posittens and interpretations described in the evaluations below.

EVALUATION A. GENEEAL lt is the staff's position that the licensee's IST program must include all pueps and valves irportant to safety (i.e., pumps and valves required to shut down the plant to cold shutdown, maintain the plant in cold or het '

shutdown condition, or sitigate the consequences of an accident) and that i they must be tested in acccedance with the appropriate Ccde requireeents unless relief is granted.

It is also the staff's position that where relief from the Code is requested, it is the licensee's responsibility to provide an adequate basis for granting 1

relief. The staff found that some of the licensee's relief requests were not adequately justified; consequently, additional inferration was recuested by letter dated February 23. 1954 The licensee responded in a letter cated March 26, 19S4 ,

B. pow? TESTI C pR33;Aw AC RELIEF RE00EST 1

1. procra-A review of the puep portion of the IST program has shown that the program includes all pumps that are important to safety and that east i

be tested as recuired by the Code. All criteria are in coepitance with Code requireeents except the allowable upper lietts for dif ferential pressure (AP) and flow rate (Q). The Code specifies that these lietts cust be no mere than 102% of the reference values. The Itcensee's proposed limits for both paraeeters are 110*. for all Service Water Pumps (that take suction from the river) and 105*. for pumps that are located within the plant. These less restrictive limits have been specified by the licensee, through its ir.terpretation of Paragraph IW:-3210 of the Code, on the basis that the accuracy of gauge reasu*e-rents and the fluctuation of river level make it difficult to rett the lower limits. Also, a review'of previous test cata by the licensee has sho n that the higher values had not accurately reflected cegradatter of pu p cperatice, O

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Enclosure 1 3 The staff accepts the use of the less restrictive upper limits for the remainder of the current IST period; however, we do not consider these limits provide the sensitivity in detection of hydraclic performance that is intended by the Code. Prior to submission of the Hatch program for the next IST period, the licensee should determine if improved sensitivity can be achieved by such.means as: use of more sensitive instrumentation; use of multiple reference valves if hydraulic performance can be traced to factors that are not indicative of pump degradation; use of improved vibration tests to monitor pump degrada-tion; trending pump test data and statistically evaluating the results for degradation. The licensee's efforts in these areas will be addressed during inspections of the licensee's implementation of the current IST program.

2. Specific Requests for Relief

a. Standby Liquid Control (SLC)

Relief Request The licensee has requested specific relief for SLC pumps C41-C001 A&B from the requirements of Table IWP-3100-1 for measuring inlet pressure (P1), differential pressure (AP), and flow rate and proposes to measure only outlet pressure and to determine flowrate by an alternative method.

Licensee's Basis for Requesting Relief No direct means of measuring pump inlet pressure is available.

The SLC pumps are positive displacement pumps for which differen-tial pressure is constant, regardless of inlet pressure. Flowrate is measured by the change in the SLC Test Tank level during a two-minute test period.

At the staff's request, the licensee, in a letter dated March 26, 1984 elaborated on the above Basis as follows:

Standby Liquid Control (SLC) is aligned so that each pump takes suction from a domineralized water source and discharges through a throttle valve to a test tank. The pump is placed into operation and the throttle valve adjusted to obtain a reference discharge pressure. The level of the test tank is then measured and the pump then run for two minutes. After the two minute run the tank i level is again measured. Flowrate is then determined by the j following equation:

Flow (gpm) = A Tank level (in.) x 4.81 gal./in.

2 min.

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For a situation in which the flowrate is measured by instrument, a 0-100 gpm instrument would normally be used for the SLC pump flowrate of approximately 43 gpm. The required accuracy of this instrument would be 12% or 2 2 gpm. This corresponds to 2 .83 inches of water level in the test tank. Therefore, the accuracy

, of the measured flowrate should be well within code allowable.

Evaluation j We agree that the configuration of the Standby Liquid Control system and the two SLC purps make it impractical to determine P1 and AP. We also approve the alternate method of establishing flowrate and the licensee's request for relief.

b. plant Service Water and RHR Service Water Pumps (1) Relief Request

! The licensee has requested specific relief for Plant Service Water pumps P41-C001 A thru D and RHR Service Water pumps  :

E11-C001A thru D from the requirements of Table IWP-4110-1 to I measure inlet pressure and differential pressure within i 2%

of full scale.

Licensee's Bases for Requestina Relief  ;

Inlet pressure for these pumps is determined by measuring the river level at the intake structure. The differential pressure is then: AP = Po + (114.5 f t. - River Water Level)'

x 0.433.

The licensee claims that this method of measurement is well within the Code requirement for the determination of AP.

Evaluation These pumps are vertical design and have no direct means for measuring Pi; therefore, Pt is calculated from the depth of the river (i.e., depth (ft) x 0.433 psig/f t). Differential pressure is then determined by subtracting 91 from Po (the pressure measured in the outlet pipe of the pump). We conclude that this procedure will provide pressure values of acceptable accuracy and, therefore, we approve the licensee's request for relief.

(2) Relief Request The licensee has also requested specific relief for pumps P41-C001 A thru D and E11-C001 A thru 0 from the requirement of IWP-4310 to measure the temperature of bearings outside the main flow path.

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Enclosure 1 5 Licensee's Basis for Requesting Relief For these pumps the bearings (or bearing surfaces) are cooled by the process fluid that is being pumped. Rather than measure the temperature of this lubricant, the licensee proposes to inspect the bearings for wear whenever the pump is disassembled for maintenance. Also, the bearing tempera-ture of the pump motor will be monitored.

Evaluation We agree with the licensee's basis that measurement of the temperature of the bearing coolant (river water) does not provide indication of the bearings' conditions. Conse-quently, we approve the alternative visual surveillance and grant the requested relief. It is the staff's position that the mechanical operability of pumps is best monitored through very frequent bearing temperature measurements (when i possible) or by emphasizing the accuracy and sensitivity of l vibration measurements.

. (3) Relief Requested I

The licensee has also requested specific relief for pumps p41-C001 A thru D and E11-C001 A thru 0 from the requirement of Table IWp-3100-1 that the proper lubricant level or t pressure be observed.

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Licensee's Basis for Requesting Relief These pumps are being lubricated by the process fluid that is being pumped; therefore, the requirement is impractical. The licensee proposes to monitor the lubricant level of the pump motor to assure the motor is operable.

Evaluation We agree that the requirement is not needed for these pumps and approve the requested relief.

! c. Residual Heat Removal and Core Spray Relief Request The licensee has specifically requested relief for Residual Heat Removal pumps E11-C001 A thru 0 and Core Spray pumps E21-C001 A and 8 from the requirements to measure the temperature of bearings

, outside the main flow path (IWP-4310) and the periodic observation of lubricant level or pressure (Table IWP-3100-1).

Licensee's Basis for Requesting Relief Same as for pumps P41-C001 A thru D and E11-C001 A thru D.

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b C f I Enclosure 1 6 Evaluation Same as for pumps P41-C001 A thru D and E11-C001 A thru D. The licensee's requests are approved.

d. Jockey Pumps i (1) Relief Request The licensee has requested specific relief for pumps E21-C002 A and B from the requirement of Table IWP-3100-1 that both differential pressure and flowrate be measured and proposes to measure only differential pressure.

Licensee's Basis for Requestino Relief The only function of these pumps is to maintain a water inventory in the RHR and Core Spray piping system, and flow

, rate instrumentation is not required. However, the pumps discharge into a fixed resistance system; therefore, measure-ment of both parameters is not required to determine degrada-tion of the pump.

Evaluation We agree with the licensee's basis and approve the requested i relief. In a fixed resistance system the measurement of l either AP or flow rate is sufficient to verify the operabi -

lity of these pumps.

(2) Relief Request The licensee also requested specific relief for pumps E21-C002 A and B from the requirement of Table IWV-3100-1 to observe lubricant level or pressure.

Licensee's Basis for Requestino Relief These pumps are lubricated by the process fluid that is being pumped.

Evaluation We agree with the 11cansee's basis and approve the requested relief. This requirement is not appitcable when a pump is lubricated by the pumped fluid. -

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, o f 8 Enclosure 1 7 C. VALVE TESTING PROGRAM AND RELIEF REQUESTS

1. General Considerations The following Code requirements, staff positions and staff interpreta-tions of requirements for IST valves are listed because of their particular applicability to the evaluation described herein.

a. Valve Test Frequency Requirements '

Subsection IW-3411 of the Code (which discusses full stroke and part stroke testing) requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IW-3412(a), IW-3415, and IW-3416. IW-3413 requires the owner to specify the full-stroke time of each power operated Category A and B value and to check the time whenever the valve is full stroke exercised.

IW-3521 requires that Code Category C check valves be exercised i once every three months, with the exceptions as defined in IW-3522.

In the above exceptions for Category A, B and C check valves, the

] Code permits the valves to be tested at cold shutdowns where:

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

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

b. Passive Power Operated Valves i

IW-3700 states that passive valves need not be exercised; however, it is the staff's position t5at power operated valves which are not required to change position for any accident condi-tion of the plant must have their positions verified quarterly and each time the valves are cycled.

c. Testino of Normally Open Check Valves Requirements for testing normally open check valves are stated in IW-3522 as follows:

" Check valves shall be exercised to the position required to -

fulfill their function... Valves that are normally open during plant operation and whose function is to prevent reversed flow, shall be tested in a manner that proves that the disk travels to the seat promptly on cessation or reversal of flow. Confirmation that the disk is on its seat

e o Enclosure 1 8 shall be by visual observation, by an electrical signal initiated by a position indicating device, by the cbservation of appropriate pressure indications in the system, or by

other positive means."

In its program, the licensee proposes to verify closure for certain normally open check valves at each refueling, by reversing flow through the check valves and measuring the leakage as part of I

the local laak rate tests. The staff believes that this alterna-tive method will verify if the valve's disk has returned to its seat.

d. Testing of Normally Closed Check Valves 1 Requirements for testing normally closed check valves are stated in IWV-3522, in part, as follows:

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" Check valves shall be exercised to the position required to fulfill their function... Valves that are normally closed ,

during plant operation and whose function is to open on '

reversal of pressure differential shall be tested by proving that the disk moves promptly away frca the seat when the closing pressure differential is removed and flow through the valve is initiated, or a mechanical opening force is applied 1

to the disk. Confirmation that the disk moves away from the l seat shall be by visual observation, by electrical signal

! initiated by a position indicating device, by observation of substantially free flow through the valve as indicated by j

appropriate pressure indications in the system, or by other .

positive means. This test may be made with or without flow 1

through the valve."

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The staff considers that these requirements can be met if any of the following four methods are used as confirmation:

a i (1) By demonstrating that the valve can pass the maximum, accident-design flow for which credit has been taken in FSAR j analyses.

, (2) By showing that, for the measured flow, the pressure less j through the valve is such that the valve can only be fully

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(3) By using a mechanical exerciser which can be observed to move 1 through a full stroke.

(4) By partial disassembly of the valve and manually moving the ,

disk through a full stroke.

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Enclosure 1

e. Leak Rate Testing of Category A Valves By Mean: of Differt:ntial Pressure IW-3423 requires that valve seat leakage tests shall be made with the pressure differential in the same direction as will be applied wnen the valve is performing its function, with certain specified exceptions. The licensee has requested relief for eleven Category A containment isolation valves that cannot be tested in the required manner, because of the configuration of tSe system, and proposes to leak-rate test these valves in a noncenservative direction. The correct direction is to pressurize fmm the inboard side of these valves; however, the piping on the inboard side runs directly from the valve to either the torus or to the reactor vessel and is difficult to pressurize for testing. The staff considers that the intent of the Code is met by the licensee's proposed method if a redundant containment isolation valve is leak tested in the correct direction. When the system does not have redundant containment isolation valves (i.e., does not meet Criterion 56 of Appendix A of 10 CFR 50) the single isolation valve is recstred to be leak tested from the correct direction. For containment isolation valves, correct pressuriza-i tion direction may be obtained during integrated leak tests.

f. Stroke Times for Category A and B Power Operated Valves IW-3413 requires the licensee to specify limiting values of full stroke times for power operated valves. These limiting values must be verified each time the valves are full stroke tested and .

they must be trended (as specified in IW-3417.) The limiting values of full stroke time specified for these valves must assure that any design safety analysis requirements are met.

For fast acting valves, such as solenoid valves and air pilot operators, the staff considers two seconds to be a suitable maximum stroke time. The absence of indicator lights will not normally be considered an adequate basis for relief from stroke timing,

g. Deviations in Leak Test Mediums IW-3425 requires that the test medium be specified by the owner.

Where leakage rate is to be determined using a different test medium than the service medium, IW-3423 requires that the deter-mination compensate for the test medium difference, Where the licensee proposes to leak test a valve with a different medium than the service medium, as for example in proposing to test .

pressure isolation valves (PIVs) with air when their service medium is water, the licensee must use a proven correlation l

between the two mediums *or the subject conditions.

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h. Valve Testing at Cold Shutdowns i

The staff considers che following conditions to apply to inservice testing valves at cold shutdown:

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

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

(3) Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code-specified testing frequency.

For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode the licensee need not begin testing within the specified 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

1. Leak Test Requirements for Containment Isolation Valves (CIVs)

All CIVs are required to be classified as Category A or AC. It is the staff's position that the leak rate test requirements for Category A valves (IWV-3420 through IWV-3425) are met by the requirements for CIVs in 10 CFR 50, Appendix J. Relief from the' requirements of these paragraphs does not present safety problems since the requirments are met by Appendix J testing; however, the requirements of IWV-3426 and IWV-3427 must be implemented.

J. Application of Appendix J Review to the IST Program The Appendix J review for this plant is a completely separate review from the IST program review. However, with regard to valves subjected to Type C tests, the determinations made by that review are directly applicable to the IST program. Should the Appendix J program be amended, the licensee is required to amend the IST program accordingly, i

2. Program The valve portion of the IST program was examined to verify that all valves important to safety are included in the program and are subjected to the testing required by the Code. The following valves '

and systems, which apparently should be considered important to safety, were not included on the program:

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i SYSTEMS

- Portions of the Instrument and ' Control Air System that perform a function important to safety VALVES

- Standby Gas Treatment System valves F002A and F0028 ,

The licensee has committed to review the functions of these valves and the I consequences of their failure. These valves will either be included in the revised IST program to be submitted by the licensee in June 1985 or justifi-cation for their omission will be given to the NRC.

The Itcensee has stated that the following valves, that are listed in the IST program, are exempted from testing per IWV-1200(a); i.e.,

" valves used only for operating convenience (such as manual vent, drain, instrument, and test valves), valves used for system control (such as pressure regulating valves), and valves used only for main-tenance."

Category B Valves E11-F068 A and B (RHR Heat Exchanger Service l

Water Discharge) modulating pressure or flow valves.

l Category 8 valves E11-F200 A, B, C, and D (RHR Service Water Pump 4 Flow) air-operating pressure control valves that open and close at j set pressures.

• i j Category B valve E51-F019 (RCIC Pump Minimum Flow - Torus Isola-tion) minimum flow valve that opens and closes at set pressures.

1 Category B valves P41-F208 A, B, C, and'D (Service Water Pressure d

Regulator) air-operated pressure control valves that open and close at set pressures.

!' The NRC staff has been advised by the ASME that the exemptions provided by IWV-1200(a) apply to valves that are used only for the purposes listed in this subsection of the Code. The licensee's positions on the app 1tcability of the code to these valves were discussed during the meeting between the staff and the licensee on June 23, 1983. It is the staff's position that all valves that are important to safety should be i stroke tested to show that two criteria are being met, i.e., each valve i is opening or shutting in the time required in the FSAR and the move-i ment of the valve stem has not been degraded. In its response of March 26, 1984, the licensee stated that further evaluation of the .

i failure of these valves to perform their designated function is required and the results of the evaluation will be transmitted to the NRC. Untti the staff has received and approved further bases for esemption, the valves listed above must be tested per the requirements of the code. .

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3. General Request for Relief

a. Relief Request The licensee has requested relief from the requirements of IWV-3417(b) and IWV-3523. These sections of the Code state that when corrective action is required as a result of tests made

! during cold shutdown the condition shall be corrected before startup.

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Licensee's Basis for Requesting Relief j Under the conditions stated in these sections of the Code, startup should be permitted as provided in the Technical Specifications.

4 Evaluations

. When a valve is found to be inoperable at cold shutdown with respect to the Code acceptance criteria, the use of plant Technical Specifications to determine acceptable conditions for restart is acceptable.

b. Relief Request i

The licensee has requested relief from the requirements of 4

IWV-3417(a) for valves normally tested during cold shutdown. This section of the Code states that if an increase in stroke time of

25% or more from the previous test for valves with stroke times

• less than or equal to ten seconds is observed, test frequency

-l shall be increased to once each month until corrective action is taken.

l Licensee's Basis for Requesting Relief Valves that are normally tested during cold shutdown or refueling cannot be tested once each month. Stroking these valves during power operation may place the plant in an unsafe condition.

Evaluation We agree with the licensee's basis and approve the requested reitef on the condition that the licensee stroke time the affected valves each cold shutdown until the corrective action is taken.

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4. Specific Requests for Relief

a. Main Steam and Feedwater (1) Relief Request The licensee has requested specific relief from exercising Category AC valves B21-F010A&B and B21-F032A&B (Feedwater Inboard and Out-board Containment Isolation) on the test frequency required by IWV-3421 and proposes to exercise them during each refueling.

Licensee's Basis for Requestino Relief These isolation valves are normally-open, simple check valves with flow through them during normal operation. The only means of verifying closure is to introduce reverse flow through the valves and measure the leakage. This verifica-tion is performed each refueling during the local leak rate tests.

Evaluation We agree with the licensee's basis and approve relief for these valves from the exercising requirements of the Ccde during power operation and cold shutdown. The valves are verified as open during normal operation and will be verified as closed during the local leak rate tests.

(2) Relief Request The licensee has requested specific relief from the leak rate test requirements of IWV-3423(d) for Category A valve B21-F016 and proposes to test this gate valve by pressurizing

! from a non-conservative direction as addressed in the containnent leak rate test program for the type C leakage tests.

, Licensee's Basis for Requestino Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.

Evaluation We agree with the licensee's basis and approve the requested .

relief. By pressurizing this 3-inch line between B21-F016 and 821-F019, the redundant outboard valve (F019) will be leak tested in a conservative direction and thereoy ensure leak tightness outside of primary containment. This test

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Enclosure 1 14 will also give a nonconservative indication of the leakage of F016 inside of containment (Refer to section C.I.e of this Safety Evaluation).

(3) Relief Request The licensee has requested specific relief from the valve exercising test of IWV-3521 for Category C valves 821-F037 A through L (Vacuum Breaker MSRV Discharge) and proposes to use an alternative test.

Licensee's Basis for Requestina Relief 1

These valves are designed to prevent a water leg from forming in the relief valve discharge lines under vacuum conditions.

Since there is no flow through these valves, and they are simple check valves, there is no means to test operability.

The licensee proposes to observe the movement of the disk, to see that it moves freely, during each refueling outage (when the Containment is de-inerted).

Evaluation We agree with the licensee's basis, and proposed alternative test, and approve the requested relief. The failure of these valves to open could result in damage to the discharge lines, preventing them from properly functioning in subsequent operation. Failure of the vacuum breakers to properly seat ,

could result in discharge through these valves rather than as designed.

b. Reactor Recirculation System (1) Relief Request The licensee has requested specific relief from exercising 4

Category A/C valves B31-F013 A&B and B31-F017 A&B (Recircula-tion Pump Seal Water) on the frequency required by IWV-3521 and ,+oposes to exercise them during each refueling.

4 Licensee's Basis for Requestina Relief Same as C.4.a.1 (Valves B-21-F032 A and B)

Evaluation Request approved. '

$ame as C.4.a.1 i

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Enclosure 1 15 (2) Relief Request The licensee has requested specific relief for Category B valves B31-F031 A&B (Reactor Recirculation) from the quarterly test frequency of IWV-3411.

Licensee's Basis for Requesting Relief These valves are reactor recirculation loop closure valves.

Closure of these valves during normal power operation would reduce cooling water flow to the core by one-half and place the plant in an unsafe condition.

The licensee also requests relief from part-stroking these ,

valves during normal operation because of the design circuitry of the valve and proposes to full-stroke both valves during each cold shutdown (not to exceed once every three months).

Evaluation We agree with the licensee's basis and approve the relief requested. The licensee has demonstrated that these valves cannot be full-stroked or part-stroked during plant opera-tion. We conclude that full-stroking during cold shutdown will be sufficient to verify the operability of these valves.

c. Standby Liquid Control -

(1) Relief Request The licensee has requested specific relief for Category AC '

valves C41-F006 and C41-F007 (SLC Containment Isolation) from the exercising test frequency required by IWV-3521 and proposes to exercise these valves once per 18 months.

Licensee's Basis for Requesting Relief These normally closed check valves cannot be opened without introducing flow through them with a pressure greater than reactor pressure. Such a test is performed at least once per operating cycle per Technical Specification 4.4A when the pump flowrate is verified.

Evaluation We agree with the licensee's basis and approve the requested relief. Both of these isolation valves are between the explosively actuated vtives (C41-F004 A&B) and the reactor

Enclosure 1 16 coolant in the reactor vessel. We conclude that the opera-bility of both check valves will be verified by an acceptable test of the two SLC pumps.

d. Residual Heat Removal (1) Relief Request The licensee has requested specific relief for Category A valves E11-F007 A&B (RHR Pump Minimum Flow Torus Isolation) and E11-F011 A&B (RHR Condensate Discharge to Torus) from the method of performing leak rate tests as prescribed by IWV-3423 and proposes to leak test these gate valves in a nonconservative direction as addressed in the containment leak rate test program for the type C leakage tests.

Licensee's Basis for Requestino Relief These valves cannot be leak tested by pressurizing from the inboard side because the piping on the inboard side runs directly from the valve to the torus and cannot be pres-surized for testing.

Evaluation The licensee has identified, in Section 3.7 of the Hatch 1 Technical Specifications, those isolation valves that cannot be tested in the direction required for isolation. These -

valves will be leak tested by applying pressure between inboard and outboard valves, or between the isolation valve

, and other system valves. These tests are required to yield equivalent or more conservative results than required by the

Code. We consider this Technical Specification to be adequate for leak-testing this valve and approve the requested relief.

(2) Relief Request The licensee has requested specific relief for Category AC valves E11-F050 A&B (LPCI Injection Isolation) from valve exercising requirements of IWV-3521 and plans to fulfill these criteria by alternative means.

Licensee's Basis for Requesting Relief These normally closed check valves do not receive " full-open" .

flow during normal operation or shutdown conditions. There has been no practical method demonstrated to fully stroke these valves.

Enclosure 1 17 i These valves were su;pifed with a test switch to allow partial stroking during operation; however, the design of the  :

test sechanism coes not provide proper testing. Modifica-tions are to be performed, and if they prove successful, the valves will be partially stroked once per 3 months.

. At least one of the RHR systes check valves will receive shutdown cooling flow through it during cold shutcewn condi-tions; however, the flow is not sufficient to fully open the valve.

Valve integrity will be proven during leak rate tests each j refueling outage because this valve is a pressure isolation valve and must pass the leakage tests.

j One of the two valves in the system will be disassembled on a rotating basis every other refueling outage. If the valve is determined to be non-functional, so that cesign flow would 4

not pass through the valve, the other valve would then be disassembled and inspected.

Evaluation These isolation valves are 24 swing-type check valves that

, are designed to be tested by the use of an actuator rod that '

will partially lift the valve free its valve seat as the

, actuator red rotates through the final 30' of a 180' arc.

Consequently, only part-stroking of these valves can be -

achieved by the current test procedure. Part-stroking will l

also be attained for one of these valves each time this line is used to go to cold shutdown. The capability of these r

, valves to perform their other safety-related function (i.e.,

isolate the low-pressure RNA lines from the high-pressure reactor cooling water) will be estabitshed during leak rate tests. Consequently, we conditionally approve tie licensee's i

request on the basis that the valves be disassembled on the ,

a schedwie proposed by the licensee until a procedure is i developed to achieve full-stroke testing.

(3) Relief Request i

The itcensee has requested specific relief for Category C ,

j valves E11-F078 A&8 (RHR Heat Enchanger Service water Inter- '

1 tie) free the 3-oonths test frequency required by IW-3521 and proposes to test these valves during refueling outages

but not more frequently than once per 3 months. .

i a

I I

Enclosure 1 18 Licensee's Basis for Requesting Relief Testing of these valves during normal operation requires removing the associated RHR train from operation due to differential pressure across the valve, thereby decreasing the level of plant reliability.

Evaluation We agree with the 1icensee's basis and approve the requested relief. Not only is there a pressure differential across the v41ve, but, since the RHR Service Water is drawn from the river, exercising this valve when the RHR pumps are not running would degrade the quality of the water downstream of the RHR pumps. It is not the policy of the staff to cause 4

degradation of the plant by meeting the test frequency stated in IWV-3521.

e. Core Spray System (1) Relief Request The licensee has requested specific relief for Category AC valves E21-F006 A&B (Core Spray Injection) from the exercise tests required by IWV-3520 and proposes an alternative procedure for verifying operability.

Licensee's Basis for Requesting Relief .

Same as C.4.d.2 (Valves E11-F050 A and B)

Evaluation Request conditionally approved.

Same as C.4.d.C

_ (2) Relief Request

^'

The licenste has requested specific relief for Category AC valves E21 F036 A&B (Core Spray Test Line - Containment Isolation) from the valve exercising test of IWV-3520 and leak rate test of IWV-3420. ,

_L_icensee's Basis for Relief Request These valves are required to close to fulfill their safety function; however, since there is no valve between the check '

valves and the torus, closure cannot be verified by a leak 1 rate test. 'here are no practical means to verify closure of the valves. .

e p #

-~. - . ---_ _ _

Encicsure 1 19 This valve has been designated as an inboard centair.nent isolatten valve in the A;pendix J progras; therefere, it was included in the inservice testing progras. This valve is sealed free the primary containment be:ause the test line terminates below water level and outboarc of the valve is a seisste seal water systes. Therefere, any leakage througn the valve during a 1 css of ecolant accident (LOCA) would cct be released to the environment. The integrated leak rate test (ILRT) is censiderec te be acequate testing. 01 sa's s er-bly of this valve for inspection wculd net increase the level of safety and is not censidered justifiable.

Evaluatien These normally clcsed valves perfern a dual function; i.e.,

to cpen to allow the Centainment Spray Purp to be tested and to c1cse and provide isolation of the Containment in case cf an a:cident. In the latter case, the function of the valve is to prevent reverse flow, and the cperability test must show that the disk travels to the seat promptly, if it is open, or resath tight against the seat if it is closed.

IWV-3520 states that confirmation that the disk is en its seat shall be by visual cbservation, by electrical signal initiated by a p sition-indicating device, by ctservation cf appropriate pretsure indications in the systee, cr by ctber positive seant We agree with the licensee that eene cf these specific tests are practical fer these valves.

The ILRT will provide an indication of the leak tightness of these check valves; however, the staff believes it would be difficult to identify leakage into the outbcard systes unless leakage could be observed at a pump seal er etter point in the system that is sensitive to the increased pressure of water.

The staff agrees with the licensee's basis that even if the cisk is not fully on the seat, centainment isolatten could be saintained by the water seal in the suppression chancer and by the outbcard containment isolation valve E21-F031. Alsc, testing the operability of these check valves threugh disassembly weuld not ensure complete cicsure after each pure test unless the valves were disassembled on the same schecule as the pump tests. Therefore, the staff approves the licensee's request and the use cf ILRT to test the closure of these check valves.

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Enclosure 1 l 20 l l

f. High Pressure Core Injection (HPCI)

(1) Relief Request The licensee has requested specific relief for Category A valve E41-F002 (HPCI Steam Supply Isolation) from the leak rate test requirements of IWV-3423(d) and proposes to test the valve in a nonconservative direction.

Licensee's Basis for Requesting Relief The correct direction for testing this valve is to pressurize from the inboard side of the valve; however, the piping on the inboard side runs directly from the valve to the reactor (via the main steam lines) and cannot be pressurized for testing.

Evaluation We agree with the licensee's basis and approve the requested relief. Although this inboard containment isolation valve will be pressurized in a nonconservative direction, the same test will pressurize the outboard valve, E41-F003, in the correct direction and provides redundant and simultaneous proof of valve integrity (See C.I.e).

(2) Relief Request The licensee has requested specific relief for Category A Valve E41-F006 and Category B Valve E41-F007 from the test frequency required by IWV-3411 and proposes to demonstrate the operability of these valves during each cold shutdown but not more frequently than once per three months.

Licensee's Basis for Requesting Relief Valve E41-F007 cannot be closed during normal operation because its failure in the closed position would result in the loss of the HPCI system. Valve E41-F006 cannot be opened during normal power operation without first closing E41-F007.

Evaluation We agree with the licensee's basis and approve the requested relief as provided by the Code.

Enclosure 1 21 (3) Relief Reouest The licensee has requested specific relief for Category A valve E41-F012 from the leak test requirements of IWV-3423(d) and proposes to leak test this valve in a non-conservative direction.

Licensee's Basis for Requesting Relief The correct direction to pressurize this valve is from the inboard side; however, the piping to the inboard side runs directly from the valve to the torus and cannot be pres-surized for testing.

Evaluation We agree with the licensee's basis and approve the requested relief. Valve E41-F012 will be leak tested by pressurizing between this valve and the outboard check valve E41-F046. We conclude that this test will provide an acceptable level of verification of leakage in this 4-inch line (See C.I.e).

(4.1) Relief Request The licensee has requested specific relief for Category AC valves E41-F021 (HPCI Turbine Exhaust - Inboard Isolation) and E41-F022 (HPCI Turbine Exhaust Drain - Torus Isolation) from the leak test requirements of IWV-3423 and proposes to .

use an alternative method to verify operability of these valves.

Licensee's Basis for Requesting Relief These turbine exhaust isolation valves are normally-closed stop check valves with the closure mechanism in the " locked-open" position. The valves then function as simple check valves. The only means to verify positive closure in the

" locked open" position is to introduce reverse flow from the inboard side and measure leakage; however, the piping on the inboard side runs directly from the valves to the torus and cannot be pressurized for testing. As an alternative, the valves are closed with the closure mechanism and leak tested from the reverse side. The leak test, to be conducted in accordance with the containment leak rate test program, is conservative since the test pressure tends to lift the disc from the seat. .

Enclosure 1 22 Evaluation Valves E41-F021 and E41-F022 are not amenable to the leak-rate tests of the Code. We agree with the licensee's basis and approve the alternate method of verifying valve closure

, by means of leak rate testing of these valves during each refueling outage.

(4.2) Relief Request The licensee has also requested specific relief for valves E41-F021 and E41-F022 as well as for Category AC valves E41-F040 (HPCI Turbine Exhaust Drain - Torus Isolation) and E41-F049 (HPCI Turbine Exhcust - Outboard Isolation) from tSe schedular requirement of IWV-3521 and proposes to test the y valves for operability by an alternative method.

Licensee's Basis for Requesting Relief These check valves are located on the HPCI turbine steam exhaust lines. During quarterly pump testing, these valves are partially stroked during system operation; however, tes; conditions do not provide sufficient flow to prove that the valves are fully open. One of these valves will be disassembled on a rotating basis each refueling outage. If 4

the valve is determined to be non-functional, so that the design flow would not pass through the valve, an additional valve will be disassembled. Failure of this valve would -

require disassembly of the remaining valves.

Evaluation These four valves have a dual function - isolation of the torus and control of flow of water from the HPCI turbine exhaust and turbine exhaust drain when the HPCI pump is operating. The closure function is tested as described in Section 4.1 above. We agree with the licensee's proposal to test the full-open function of these valves by periodic disassembly. The quarterly pump tests and partial exercising of these valves will verify that the valves are not frozen shut. We, therefore, approve the licensee's request for relief.

(5) Relief Request The licensee has requested specific relief for Category C .

valve E41-F045 (HPCI Pump Suction) from the valve exercising requirement of IWV-3520 and proposes to use an alternative  !

method of verifying the operability of this valve.

i

Enclosure 1 23 Licensee's Basis for Requesting Relief Valve E41-F045 is a normally closed check valve located on the HPCI pump suction line and cannot be stroked. This valve does not see flow during any normal mode of reactor opera-tions or shutdown conditions. Testing of this valve would require pumping water from the torus to the condensate storage tank, thereby lowering the water quality in the tank.

Degradation of this valve is not expected because wear does not occur in a closed check valve. To ensure that the valve will open if needed, it will be disassembled every other refueling outage to prove that the disc is free to move.

Evaluation We agree with the licensee's basis and approve the requested relief. Inasmuch as this valve is isolated from the environ-ment of the Torus (by valves E41-F042 and F41-F051) and from the normal suction line for the HPCI pump (by valve E41-F041), there is little likelihood that valve E41-F045 will degrade or become stuck between disassembly tests.

(6) Relief Request The licensee has requested specific relief for Category A valve E41-F111 (HPCI Vacuum Relief - Torus Isolation) from the leak rate test requirements of IWV-3423 and proposes to leak test this valve in a nonconservative direction.

Licensee's Basis for Requesting Relief The correct way to leak rate test this containment isolation valve is to pressurize from the inboard side of the valve.

However, the piping on the inboard side runs directly from the valve to the torus and cannot be pressurized for testing.

Evaluation We agrer with the licensee's basis and approve the requested relief (See C.I.e).

g. Reactor Coolant Injection Cooling (RCIC)

(1.1) Relief Request The licensee has requested specific relief for Category AC valves E51-F001 (RCIC Turbine Exhaust to Torus Isolation) and E51-F002 (RCIC Vacuum Pump Discharge to Torus - Isolation) from the leak test requirements of IWV-3423 and proposes to

- . - - ~

4 Enclosure 1 24 use an alternative method to verify operability of these valves.

Licensee's Basis for Requestino Relief These turbine exhaust isolation valves are normally-closed stop check valves with the closure mechanism in the " locked-open" position. The valves function as simple check valves.

The only means to verify positive closure in the " locked-open" position is to introduce reverse flow from the inboard side and measure leakage; however, the piping on the inboard side runs directly from the valves to the torus and cannot be pressurized for testing. As an alternative, the valves are closed with the closure mechanism and leak tested from the j reverse side. The leak test, to be conducted in accordance with the containment leak rate test program, is conservative

since the test pressure tends to lift the disc from the seat.

Evaluation Valves E51-F001 and E51-F002 are not amenable to the leak rate tests of the Code. We agree with the licensee's basis and approve the alternate method of verifying valve closure by means of leak rate testing of these valves during each refueling outage.

(1.2) Relief Request The licensee has also requested specific relief for Category AC valves E51-F001 and E51-F002 as well as for Category AC valves E51-F028 (RCIC Vacuum Pump Discharge

- Torus Isolation) and E51-F040 (RCIC Turbine Exhaust - Torus Isolation) from the schedular requirement of IWV-3521 and proposes to test these valves for operability by an alter-

! native method.

Licensee's Basis for Requestino Relief These check valves are located on the RCIC turbine steam )

exhaust lines. During quarterly pump testing, these valves are partially stroked during system operation; however, test conditions do not provide sufficient flow to prove that the valves are fully open. One of these valves will be disassembled on a rotating basis each refueling outage. If the valve is determined to be non-functional, so that the design flow would not pass through the valve, an additional .

t valve will be disassembled. Failure of this valve would require disassembly of the remaining valves.

Enclosure 1 25 Evaluatten These four valves have a cual function - isolation of the torus and control of flow of water from the RCIC turbine exhaust and exhaust drain when the HPCI pump is operating.

The closure function is tested as described in Section C.4.g.1.1 above. We agree with the licensee's proposal to test the full-open function of these valves by periodic 4 disassembly. The quarterly pump tests will verify that' the valves are not frozen shut. We, therefore, approve the licensee's request for relief.

l (2) Relief Request The licensee has requested specific reitef for Category A valve E51-F003 (RCIC Pue: Suction - Torus Isolation) free the 4

leak rate test requirements of IWV-3423(d) and proposes to test the valve in a nonconservative reverse direction as addressed in the containment leak rate test progran for the type C leakage tests.

] Licensee' Basis for Requesting Relief f The correct direction for testing this valve is to pressurize from the inboard side of the valve; however, the piping on 4

the inboard side runs directly froe the valve to the torus and cannot be pressurized for testing.

a.

Evaluation j We agree with the licensee's basis and approve the requested relie f. Although this containment isolation valve will be

, pressurized in a nonconservative direction, the same test

{ will evaluate valve E51-F031 in the correct direction. Valve

, E51-F031 is in the same line as valve E51-F003 and provices redundant assurance of isolation in the event of a leak through valve E51-F003 (See C.I.e).

(3) Relief Request

. The licensee has also requested specific relief from the leak ,

l rate test requirements of IWV-3423(d) for valve E51-F007 (RCIC Steae Supply - Inboard Isolation) and proposes to test this gate valve by pressurizing from a nonconservative direction.

Licensee' s Basis for Requesting Relief  !

This valve cannot be pressurized from the conservative .

(inboard) side because the inboard piping is open to the  !

torus. i i

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Enclosure 1 26 Evaluation We agree with the licensee's basis and approve the requested relief. By pressurizing this 4-inch line between E51-F007 and E51-F008, the outboard valve (F008) will be tested in the conservative direction and, thereby, ensure leak tightness outside of the primary containment. The test will also give a nonconservative indication of the leakage of F007 inside the primary containment (See C.1.e).

(4) Relief Request The licensee has also requested specific relief from the leak rate test requirements of IW-3423(d) for valve E51-F019 (RCIC Pump Minimum Flow - Torus Isolation) and proposes to test this gate valve by pressurizing from a non-conservative direction.

Licensee's Basis for Requesting Relief This valve cannot be pressurized from the conservative (inboard) side because the inboard piping is open to the torus.

. Evaluation i

We agree with the licensee's basis and approve the requested relief. By pressurizing this 4-inch line between E51-F019 .

and E51-F021, the outboard valve (F021) will be tested in the conservative direction and, thereby, ensure leak tightness outside of the primary containment. The test will also give a nonconservative indication of the leakage of F019 inside ,

the primary containment (See C.I.e). '

l (5) Relief Request .

The licensee has also requested specific relief from the leak rite test requirements of IW-3423 for valve E51-F105 (RCIC Vacuum Breaker - Torus Isolation) and proposes to test this gate valve by pressurizing from a nonconservative direction.

i Licensee's Basis for Requesting Relief This valve cannot be pressurized from the conservative I (inboard) side because the inboard piping is open to the  ;

torus. .

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Enclosure 1 27 Evaluation We agree with the licensee's basis and approve the requested relief. By pressurizing this 4-inch line between E51-F105 and E51-F104, the outboard valve E51-F104 will be tested in the conservative direction and, thereby, ensure leak tight-ness outside of the primary containment. The test will also give a nonconservative indication of the leakage of valve E51-F105 inside the primary containment (See C.I.e),

h. Reactor Water Cleanup (1) Relief Request j- The licensee has requested specific relief from exercising Category A valve G31-F039 (RWCU Discharge Isolation) on the test frequency required by IWV-3521 and proposes to exercise

, it during each refueling.

i Licensee's Basis for Requesting Relief This isolation valve is a normally-open check valve with flow through it during normal operation. The only means of verifying closure is to introduce reverse flow through the valve and measure the leakage. This verification is performed each refueling during the local leak rate tests.

Evaluation .

i We agree with the licensee's basis and approve relief of this l valve from the exercising requirements of Section XI during power operation and cold shutdown. The valve is verified as open during normal operation and will be verified as closed during the local leak rate tests.

1. Plant Service Water 4

(1) Relief Request The licensee has requested specific relief for Category C valves P41-F024A and B (HPCI Pump Room Cooler), P41-F025 A and B (RHR and Core Spray Pump Room Cooler), P41-F026 A and B (RHR Pump Cooler) and P41-F028 A and B (RCIC Pump Room Cooler) from the valve exercising requirements of IWV-3521 e

and has proposed an alternate method for verifying that the valves fulfill their functions. .

I

i l- Enclosure 1 28 i

f

Licensee's Basis for Requestino Relief Normally closed check valves P41-F024 A and B, P41-F025 A and ,

i B, P41-F026 A and B, and P41-F028 A and B supply service  ;

water to RHR and Core Spray, HPCI, and RCIC oump and pump room coolers. During quarterly testing of the pumps, the i j coolers are placed in operation, thereby stroking these valves. However, the design of the system does not provide .

l. for positive verification of the flow rate through each l valve.

i

! One valve will be disassembled each refueling outage on a i

{ rotating basis to ensure that the design function of the .

! valve can be achieved. If the valve is determined to be j non-functional an additional valve will be disassembled.

Failure of this valve will require the disassembly of the remaining valves for that unit.

[i Evaluation j We agree with the licensee's basis and approve the requested j relief. These valves are normally closed and are controlled by temperature elements in each of the pump rooms. The

{ position of the valve, therefore, is a function of the 4 4

temperature of each Pump Room and can be indirectly verified  :

i by verifying that sufficient cooling is being provided. We  ;

consider this indirect indication, in addition to the

periodic disassembly of each valve, to fulfill the intent of- ,

the Code.

i (2) Relief Request [

f-The licensee has requested specific relief for Category B  ;

valves P41-F035 A anc B (HPCI Pump Room Cooler), P41-F036 A  ;

and B (RHR and CS Pump Room Cooler), P41-F037 A, B, C and D (RHR Pump Cooler), P41-F039 A and B (RHR Pump Cooler),  !

P41-F040 A and B (RCIC Pump Room Cooler, and P41-F042 A and B l (CR0 Pump Room Cooler) from the stroke-time requirements of  !

, IW-3413(b) and IW-3417 and proposes to assign a maximum  !

stroke time for these valves. I Licensee's Basis for Requesting Relief

) IW-3413(b) requires stroke times shall be measured to the nearest second, for stroke times 10 seconds or less,105 of the specified limiting stroke time for full-stroke times .

longer than 10 seconds.

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

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

Enclosure 1 29 IW -3417 requires that if the stroke time increases by 25%

from the previous test for valves with full-stroke times greater than 10 seconds or 50% for valves will full-stroke times less than 10 seconds, the test frequency shall be ircreased to once each month uni.11 corrective action is taken.

These valves are air-operated valves without indicating lights or control switches. Measurement of stroke times can be performed only by observation of the stem movement when the associated room cooler is placed into operation. This type of testing does not provide the accuracy required by IW-3413(b) and IW-3417.

A maximum stroke time will be assigned to each valve. If the measured stroke time exceeds this value the valve will be declared inoperable.

Evaluation The staff's position on stroke times is summarized in Sections C.1.f and C.4.d.14 of this Safety Evaluation. We approve the requested relief on the condition that the maximum stroke time assigned to each valve will be as short as practical and will not be so long that degradation of the valve cannot be identified.

(3) Relief Request .

The licensee has requested specific relief for Category A valves P41-F049 and P41-F050 (Drywell Air Cooler - Isolation) from the schedular requirements of IW-3411 and proposes to exercise these 8-inch valves during cold shutdown but not more frequently than once per three months.

Licensee's Basis for Recuestine Relief IW-3411 requires that valves be exercised at least once per three months.

Closure of this normally open valve would totally interrupt flow to the drywell coolers. This interruption may cause an increase in drywell temperature which would require removing the unit from operation. The valve cannot be partially stroked due to control circuitry.

This valve will be stroked every cold shutdown but not more frequently than once per three months.

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

Enclosure 1 30 1

Evaluation We agree with the licensee's basis and approve the requestej relief as permitted by the Code, i

(4) Relief Request

The licensee has requested specific relief from part-stroke or full-stroke exercising Category B valves P41-F310A, F3103, F310C and F3100 (Turbine Butiding Supply Shutoff) on a

! quarterly frequency 'as required by IWV-3411.

Licensee's Basis for Requesting Relief

! Closure of these valves during normal operation would inter- t i rupt flow to the turbine building equipment that is normally

{ cooled by service water. Also, the valves cannot be part- ,

stroked because the control circuitry will not permit part-  :

j strokirg. The required exercising will be performed during  !

=

cold shutdowns (not to exceed a frequency of once every three

• j months).

t i

Evaluation t l

During the June 23, 1983, meeting between staff and licensee, ,

! the licensee informed the staff that both cooling trains must be available to provide sufficient cooling to the equipment 1

in the turbine building. We agree with the licensee's basis-that part-stroking or full-stroking cannot be achieved during normal rower operation and we approve the required relief.

i

j. Reactor Building Closed Cooling Water l Reitef Request i

, The licensee has requested specific relief for Category A valves l

P42-F051 and F052 (RBCCW to Recirc.-Containment-Isolation) as j required by IWV-3411.

Licensee's Basis for Requestine Relief IWV-3411 requires that valves be exercised at least once per three 3 months; however, closure of this valve during normal operation would shut off the cooling water to a Reactor Water kecirculating 4 System Pump. These valves will be stroked every cold shutdown but j not more frequently than once per three months. .

4 j Evaluation ,

I w

! The staff has examined and agrees with the bases for permitting l

! the requested relief. The requested relief is granted.  :

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Enclosure 1 31

k. Drywell pneumatic Relief Request The licensee has requested specific relief from exercising Category AC valve P70-F020 (Drywell Pneumatic - Containment Isolation) on the quarterly test frequency required by IWV-3521 and proposes to exercise it during each refueling outage.

Licensee's Basis for Requesting Relief This isolation valve is a normally-open check valve with design flow passing through it during normal operation. The only means of verifying that it has exercised to closure 'the position required to fulfill its safety function) is leak testing. This verification is obtained each refueling outage through the local leak rate (Appendix J) test.

Evaluation The staff agrees that the Code requirement is impractical for this valve. Relief is granted.

1. Control Rod Drive Relief Request The licensee has requested specific relief for the valves in the Control Rod Drive System from the requirements of the Code -

(IW-1100) and proposes to test these valves only to the require-ments of the plant Technical Specifications.

Licensee's Basis for Requesting Relief IW-1100 provides the rules and requirements for inservice testing of certain Class 1, 2 and 3 valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident. The plant Technical Specifications require all operable withdrawn control rods to be exercised at least once per week when above a designated power level. After each refueling cutage, all control rods capable of normal insertion shall be scram timed from the fully withdrawn position. Also, 10% of the rods shall be scram timed from the fully withdrawn position at least once per 120 days of operation. The Technical Specifications give the allowable insertion times for these tests. The Technical Specifications adequately demonstrate the operability of the control rod drive -

system and the additional requirements of Section XI would not increase the level of safety. Therefore, Technical Specifications testing will be used in lieu of the Section XI requirements.

4 f

Enclosure 1 32 i

i.

l Evaluation 1

j We agree that the Technical Specifications for Hatch Unit 1

, (Technical Specifications 4.3.0, 3.3.B.2, 3.3.C.2, and 4.3.C.2) i d

provide for surveillance that verify that the valves (especially j the scram inlet and outlet valves) in each Hydraulic Control Unit t i are operable, will function upon demand, will cycle within the specified time limit, and will indicate evidence of deterioration l j (through stroke time). We agree that it would be impractical to

test each Hydraulic Control Unit separately when the plant is L j operating. We, therefore, approve the licensee's relief request.  :

! (

]

CONCLUSIONS i

in its evaluation of the licenste's relief requests described above, the l staff concluded that certain of the requests should be oranted and others  !

conditionally granted. A summary tabulation of these conclusions is provided ,

. in Attachment 1. Based on its evaluations, the staff concludes that the

! indicated reliefs thus granted will not endanger life or property or the f j cour.on defense and security of the public. In its evaluation of the ,

licensee's program, the staff identified possible deficiencies in the scope of j the program, These are summarized in Section C.2. The licensee should

] esamine the functions of the s.vstems and individual valves identified in ,

j Section C.2. considering the NRC staff position described in Section A, and l j should revise the IST program accordingly. if necessary. I I

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. ~ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ __ _ _ . ~ . _ _______.. _ - _ _ _ _ . _ _ _ . _ . _ . _ _ _ _ . . __..._ _ ,______.____._m._.._ ... __. _ _.- - _m...__ _ _ _ _ . _ , . . - _ _ _ ._ _ .__ _

l Enclosure 1 ,,,y,,,,, .

. W OF PtIBOPS ASIS VALVES FOR t011CDI RELIEF REQUESTS ARE APPROVED, COEIDITICIBALLY APPIBOVED, OR DElllED TASLE A - SepetARY TAAULAffell 0F Puger ftELIEF lttelltST EVALUAfl0NS Roller moeuest References Pusqrs neller noeutis StR penm Eve _Lue_111we Aperoved Standby Lleguld Centrol 7.1.2 Sect. 5.2.e. x and 7.1.5 i

Plant Service 1 deter and 7.1.3 Sect. B.2.b.(1) x IIIIIt Service tieter F.1.1 Sect. B.2.b.(2) x 7.1.4 Sect. 3.2. b. ( 3 ) x asist and Core sprey 7.1.1 Sect, s.2.c. x and 7.1.In x  ;

Jectiey Pueys 7.1.7 Sect. 3.2.d.(1) x 7.1.6 Sect, s.2.d.(2) x i i

l I

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cwrw -mv -n.--- - ,.e-. w_ - ~ - . -,e a.n ._ ., -,

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Enclosure 1 ""*C""

SWSMAY OF PtSIPS AM VALVES FOR tesim REll[F Rf0DESTS ARE APMBOVED, COISITIOIIALLY APPeOVED. OR DEWIED TASLE 3.1 - SWOMAY OF MetaAL VALVE Inst tEF REGu[STS EVALUAil0IBS Evelvetion Consfitionally Generet Cateeerv ef Velves llellef D8489_11 SER Sectlen Denled Granted Cronted Velves regasiring correctlwe 6.1.1 C.3.s X action in accordence with IW-3W3 before startesp free cold sanastdown Wolves meree88y tested at 6.1.2 C.3.h X cold s8eestdowse er refaseIIng 18est regesf re Ireressed test fregasency In accordence with tw-34 s 7(e) f 1

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l 1

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

l Enclosure 1 ^ " *CE*' '  !

SMIWehnY Of PUBIPS AND VALVE $ FOR teIICet RELIEF REQUE$TS ARE APPROWED, COWOITICIIALLY APPROVED, OR DENI[0 TASLE 3.2 - N TASIBLAT10m OF SPECf Ff C VALVE RELf EF REGiff 5i EVAL 11ATIONS ConditloneIly Wolves Rollef ReestSt SER ISect.) D98tfCW Aseroved Amoroved Seein Stees and Feedweter (821- ) '

6.1.1 C.4.e.1 X

.F010 3 A Gr S and F032 A F016 6.1.2 C.4.e.2 X l F037A thru L 6.1.3 C.4.e.3 X l

Seector AscIreuf atIen Systoe l test- 3 .

F013 Aes and F017 Ae4 6.1.1 C.4.b.1 X F031 Att 6.1.4 C.4.4.2 X C. II . D. 2 X Standby Liguld Centrol System (C41- 3 F006 ond F007 6.1.5 C.4.c.1 x '

nesidues sloot memoves '

System (E11- )

F007 AGS and F011 AAS 6.1.2 C.4.d.1 X FOSO AGS 6.1.7 C.4.d.2 X F0FS A38 6.1.8 C.4.d.3 X Core Spray System (E?i- ) '

X F006 Aes 6.1.7 C.4.e.1 F036 Aes 6.1.5 C.4.e.2 X Nigge Pressure Coelant enjection System (E41- 3 F002 6.1.2 C.4.f.1 X F006 6.1.10 C 4.f.2 X FOO7 6.1.10 C. 4. f.2 X F012 6.1.2 C.4.f.3 X j F021 and F022 6.1.11 C.4.F.4.1 X t 6.1.12 C.4.f.4.2 X .

F040 6.i.12 C.4.r.4.2 x FOM 6.1.13 C.4.f.5 X .

F049 6.1.12 C.4.f.4.2 X '

F111 6.1.2 C. 4. f. 6 X

Enclosure 1 '

TASLE 3.2 - $4500ARY TAGOLAT105 0F SPECf FIC VALVE RELIEF REQUE$T EVALUAT*0855 - '

(Centaneed)

ConditioneIIy Wetves hlfer_meeug11 SER f$ect.) Denied Asereved Aseroved Iteector Coolent Injection Coeling System (ESt- 3 FOO1 and FOS 2 6.1.11 C.4.g.1.1 x 6.1.12 C.4.g.1.2 x F003 6.1.2 C.4.g.2 x F00F 6.1.2 C.4.g.3 x I FOI9 6.1.2 C.4.g.4 x l

F020 and F040 6.1.12 C.4.g.1.2 x F105 6.1.2 C.4 3 5 x Seector Water Cloenup System (C31- )

F039 C.4.h x Plant Service Water ( P41- )

F024 Aes 6.1.14 C.4.1.1 x F025 Aes 6.1.14 c.4.5.1 x i F026 Aes 6.1.14 C.4.3.1 x

! F020 AGS 6.1.14 C.4.3.1 x '

l F035 Aes 6.1.15 C.4.3.2 x F036 AGS 6.1.15 C.4.5.2 x F03F Aes 6.1.15 C.4.3.2 x '

F039 Aes 6.1.15 C.4.5.2 -

x Foes Aes 6.1.15 c.4.1.2 x F002 Aes 6.1.15 C.4.5.2 x .

F049 and FOSO 6.1.16 C.4.5.3 x l F310 A, 3, C, 4 D 6.1.17 C.4.1.4 x

, steacter Building Closed l Coeling Water (P42- )

F051 and F052 mete 52 C.4.J x i

Drywe a I PneusetIc (P70- )

F020 6.1.1 C.4.k X Centrol Ited Drlwe 6.1.22 C.4.8 x l

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j Enclosure 1

, Attachment 2 i P& ids Used in the Staff's Review System Drawing No, i

Nuclear Boiler H-16062 Reactor Recirculation H-16066 r Standby Liquid Control H-16061 Residual Heat Removal H-16329. H-16330 Core Spray H-16331 I

! HPCI Pi-16332 RCIC H-16334 Radwaste H-16176 Reactor Water Cleanup H-16188 Primary Containment Atmosphere I

H, and 02 Analyzer H-16276 Reactor Building Service Water H-16011

! Reactor Building Closed Cooling Water H-16009 -

Reactor and Radwaste Buildings Service Air H-16013 t

Drywell Pneumatic H-16286 '

Nitrogen Purge and Inerting H-16000, H-16024 l

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