ML19225C975

Safety Evaluation Supporting Amend 46 to License DPR-40

ML19225C975
Person / Time
Site:	Fort Calhoun
Issue date:	07/02/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML19225C970	List: ML19225C969 ML19225C972 ML19225C975 ML19225C983
References
NUDOCS 7908030433
Download: ML19225C975 (49)

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SAF m E'/AuUATICN 3Y THE CFFICE F NUCLEAR REACTCD REGULATICN moc^RTI"'; luE9 cut!T NO.16TO MCILIT' OPE 7AT!T MCENSE NO. 2PR 20 CMAHA PUELIC PCWER DISTRICT FCRT CAUiCUN STATICN. UNIT NO.1 OCCXET NO. 50-235 Introduccion 3y application transmittec by letter cated August 22, 1977, Cmana Puolic Power District (the licensee) reccestec cnanges to the Technical Scecificaticns accendec to Facility Ccerating Licensa No. CPR-40 for the Fort Calhoun Station, Unit No.1.

The prcposed cnanges would establisn surveillance recuirements for steam generator tubes and delete inservice inscection and testing re-quirements anich are replacec by the For: Calhoun Inservice Inspection and Testing Drogram.

Steam Generater Inscection Procram On July 18, 1974, we requested that the licensee submit proposed Technical Specification enanges that would estabitsh requirements for a program of steam generatcr tube ins ection. To rovice guidance in developing an inspection program at that time, the licensee was to refer to Regulatory Guide 1.33, " Inservice Inspection of Pressurirec Water Reactor Steam Generator Tubes ', dated June 1974 (R.G.1.33). The licensee submitted croposec Technical Soecifications for inservice inspection of steam generator tubes at Fort Calhoun, Unit No. I, cn lovem:er 20, 1974 Revision 1 to R.S. 1.33 was issued in July 1975 after receiving ccmments frem the industry. Sy letter datac Jct cer 23, 1976, as revised on Maren 22, 1977, and Augus :2, 1977, the licensee arctosed Tecnnical Saecifications whicn reflec: :he provisions of R.3.

1.33, Rev. 1, with exceptions as discussed with the NRC staff.

The Technical Specifications proposed for the Fort Calhoun, Unit No. 1.

steam generator tube ins:ections are, therefore, in general agreement witn R.3. i.33, Rev. 1, catac July 1975, but devia:a in : nose areas wnera se nave te:arminec :nat ne overall ins:ec en program wcula te ennancac :ver :na: : vered in R.3. i.32, sev. i.

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7e licensee's ;r0 osed :nanges, is radified by :iscussions witn :*e NRC staf', will i clement steam geners:Or tute in:er/ ice ins::ecti:n re uirements.

Evaluation - Steam Generator Insrection Precran Surveillance Recuirrents for Stean Genernor Tubes Structures, systems, and components imcortant to safety of a nuclear power plant are designed, facricated, construc ed, and tested so as to provide reasonable assurance tha: the facility can be acerated withcut undue risk to the nealth and safety of the ;:uolic. To continucusly maintain sucn assurance, General design Criterion 32 recuires

• hat cocconents wnicn are part of ne reactor c:olant oressure boundary (RC?3) be cesigned to perni: pericdic inscection and testing of incertant areas and features to assess their structural and lea <:ignt integrity.

The steam generator tubing is part of the RCFB and is an imcortant part of a m.ajor barrier against fission product release to be anvirenment.

It also acts as a barrier against steam release to the containment in the even: Of 3 f.oss of Coolant Accident (LCCA). For this reason, a crogram of periodic inservice insoection is being estaolisned Oc assure the continued integrity of the steam generator tubes over the sertice. -

life of the plant.

Generally, the major elements of the steam generator':ube insertice inspection pregram for Fort Calhoun, Unit No.1, consist of scecified:

(a) samole selection, (b) examination methods, (c) inspection interials, (d) acceptance criteria, and (e) reporting requirements. Eacn of these major elements of -he progrvn is ses-arately evaluated beicw.

1.

Samole Selection The procesed samoling is generally atterned after R.3.1.33, Rev.1, *Insertice Ins;:ection of Pressurized Water React:r Steam Generator Tuces. Mcwever. -here are scme deviations frcm R.G.1.33 that we require to improve the program and/or reduce the potential radiation ex::osure of personnel who cer'orn the inscections. The licensee's or: gram includes these acditional requirement:. :evia-i ci"I frcm 0.3. 1.33 sucolemen:Iry samoiing recuirement: are evalua:ec beicw:

a.

Requiatory 30sition C.5.2, ~'Succierentary Samoling Recuirement-' etc =encs -hat if ne eccy :urrent 40,2 053

2 ins:ecticn results :uring an inservice ins;ection incicate anv :uces with previously uncetec:ac it erfec:Toiis of 20% ar greater cep:n, Idcitional*n steam generators, if any, snould e inscected.

other words, because of a sincie :;be in one steam genera:or with previously uncetected imcerfection of 20% or greater depth but still well below the plugging limit, all steam genera ors in ne plant snculd te inspected.

3.l though the cetec:icn of any defect warrants further inscection to cetemiae

ne extent of degradation in the steam cenerators, ne delieve that :nis ins:ection snould te 2x;anced initially to deter aine the extent of any further degracation in the one steam generator uncer inspection.

If :ne ex anded inspection indicates more extensive defect conditions, thi.1 expansion to the other steam genera:cr is required. This 3poroach will Orovide careful stepwise excansion of ins:ection based on :ne results of successive steps, whi19 tending to minimi:e the excesure of inspection personnel resulting frem initial ?csittening of inscection equipment in a steam generator. This inscection accreacn, u s:ecified in the licensee's pro-posed secnnical Specifications, is accropriate for this facility in wnich system characteristics are such that both steam generators are expected to perform in a similar manner.

b.

Revision 1 of R.G.1.33 requires additional inscections if the initial ins ection results indicate that more inan 10". of the inspected tubes have detectacle nall senetration of greater

nan 20" cr that one or more tutes ins:ected have an incicaticn in excess of the :1ugging lini:. The additional inspections recuire 1 ::molete uce insoec.

tion of an additional 3". and, i' re uired, a :nied inspection of 6% of the tuces. The recuirements set forth in the Fact Calhoun Tect cal Scecifications are acceptable becausa they recuire a second ins:ection tcucling -he numcer of tubes ins ected in the first Iamole if 5", :f the uces incw :egraca:icn :f :C" aail nicxness or more. Again, if mars nan 5% in -he second samole af :ne :utes Incw a ce:ec acie :ene: ration ;reater than 20% or 1" Ire defective :uces,1 :nird samole is recuired again doucling :ne num er of :uces ins:ected 'n n :.e #d es: Iamoie, samci'ng 's ::

One sec:nc Iam0ie.

n 442 054

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concantrate on areas af :ne tute array nner?

Orior inspections or ex:erience nave indicated

otential preciems, anc full leng

n raverse of eacn inspected tuce is recuirec.

cr a second or third samole, if recuired, ne inscec-tion may concentrate on areas of :ne tute array and ;ortions of the tube in wnica the fir::

samole or the sec:nd sample incicated potential problems.

Sased on the c:nsicerations discussed above, we have c:ncluced tha: :ne samole selection Icneme preposed by -Me licensee is accectacle.

2.

Examination v t".cd e

The prcposed examination methocs incluce nondestructive examination by eddy cur ent testing. The scecified methods are capaole of locating anc identifying stress corrosion cracks and tube wall thinning fr:m enemical wastage, mechanical damage or other causes. Basec on our review of these methods, and experience gained using these methocs by the incustry, we have concluded that the examination methods are act?ptable.

3.

Inscection Intervals The proposed inscection inter'.ais are ccmcatible with those rec mmended in R.G. l.33, Rev.1, anc thus, are acceptable.

a.

Ac:eatance Criteria The crincipal parameter used to determine wnetner any one s' elm genera:cr tuce is acceptacle for continued service is the measured im erfec:icn dectn. A tuce plugging limit has been establisned 2nd defined in the precosed Tecnnical Soecifications as the imperfection deptn :eycnd wnien the tJbe must be remcVed fr0m Service. The plugging limit, as modified by the NRC staff and concurred in by the licensee, is ICP. Of the ncminal tuce wall-:Mickness.

The 31ugging lici: is basec :n (1} :he minimum uce vail thickness neeced :a maintain steam genera:Or tuce integrity 442 055

3 during :ne limiting stress Icacings associated witn 3 L::A comoined w1:n a Safe Shu::cwn Ear ncuake (SSE), and (2) 3n ocera-icnal 111cwanca to ac: un: for the time interval between inspecticns.

3ased en 0:ner evaluatiens mace by the 1EC staf, we have concluced that a minimum tube wali thickness of 5C% is 3decu3:e to sustain all the forces associatec with a LCCA ccmcined with an SSE. To provice an acditional margin of safety, an acerational allowance of 10% has been added to the 50 tube thickness value.

This alicwance is considered adequate to ensure that tube integrity will be maintained until the next inservice ins:ec fon, taking into account the controlled seconcary water chemis:ry conditic,ns that are nor.: ally maintained at Fort Calhoun.

Therefere, the accectable tute wall thickness needed for contir.ued ser ice is 60%. Tha piugging limit is tne dif#erence between 60% and the full tube thickness or 20%.

This limit will provide adecuate protection agains:

wastage - type corrosion or part-througn wall cracks.

Based un our review, the acceptarce criteria, as mcdified by the NRC staff and 7ncurred in by the licensee, are acceptable.

5.

Recortino.. Inscecticn Results Regulatory Positien C..d of R.G.1.33, states that a lics.1see should recor: co the Ccamission, for resolution and approval, procosed remedial action if the inspection resul:s exceed the limits scecified inthe Guide.

It also states that additional samcling and more frecuent inscection may te recuired. The procosed Technical Scecifications clearly sLecify accitional inscections :ne licensee mus:

er orm for : nose inscection results that fall in Technical 5:erification Categories C-1 and C-2.

mmediate recorting of ;5ese results would not be -ecuired.

Immedia e recort;ng would be required :nly if :he inspection results fall into the most severe Category. C-3, as cescribed in able 3.3 of the Technical Specifications.

We 00nc!ude that the above described reccrting recuirements, as Oraccsed by the licensee and mco ad :y us. are

'Iucclemental Testimcny :f James 3

<nign: before ne 2:0mic iafety anc.f cansing 'c:eal 3 car; in ne mattar af ':cr:nern Ita:as 2cwer ; meany, :ccxe:2 'c.

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reasonable and will facilita e recer ing of Jertiment information without unnecessarily increasing :lant downtime, and tnas constitute an accectacle alternative methed for meeting NRC recorting recuirements.

II. Summary - Steam Generator Inscection ?rocram In sur=ary, we have concluded that the proposed steam generator tube inser/ ice inspection program will provide added assurance of the continued integrity of the steam generatcr tuces, and thus is accectac'e.

442 057

. Inservice Ins:ection and Testinc ?-ccran As recuired by 10 CFR 50.55a, :ne licensee a:catec the :nservice :ns;ection and Tes:'ng :rogram for the Fort Calhoun Station Uni: 1 to ne recuire-ments of -he ASME Soiler anc Pressure 7essel Cace, Secticn X:,19 a Eci:icn varen 1977, as and Accenca nrcugh the Summer 1975.

he program, ca:ec revised in Aucus: 1977 anc Sectember 1978, has teen reviewed for comoiiance with :ne Recuiation.

Evaluations of those recuirements anica :ne licensee has determinec to be imoractical for the facility anc for wnica relief from those requirements is being requested are given :eicw.

I.

INSERVICE INSPECTION PRCGRAM A.

CLASS 1 CCMFCNENTS 1.

Recuest relief from :er#crming 100% volumetric exaninations of nose nc::le-:c-reac:Or vessel nelds on wnicn succorts are located. (l{etam 31,4, Examination Category 3-0 from Table f

IWL.E500)

Code Recuirament volumetobeinspectedasshowninFigureIW2-25CCD.(]C0%af:ne The extent of examination of eacn no::le shall cover

) All no::les snall be examined during each inspection interval, a ten-year period.

Licensee Basis for Recuestino Relief The no::le-to-vessel welds cannot be 100% volumetrically examined since the no::le supports present an interference to currently available ecuipment. Equipment development is underway to provide inscection of the no::le weld behind the succorts. When ecuip ent is available, consideration will :e given o 1005 volumetric examination of no::le-to-vessel welds. The welds will be examined volumetrically to tne extent possible and ac:Ording o the schedule desicnated in the Examination Plan.

Evaluation The vessel succort cesign prevents a 100% volumetric examinaticn of the nor:le-to-vessel welds. The licensee nas stated tha: the welds and base metal will be examined in accordance with the Ccde but only 50% - 70% of the racuired volume. The.'iRC staff has deter-mined inat the volume accessible for examination # rom the no::le-to-vessel extarnal sur' ice in acciticn o -he volume examinec #-cn

ne nc::le o-vessel internal surface aill :over a suf"cien:

Imcun: Of One volume recuirec o be examinec to Orovi:e i qign degree by a:surance -hat inservics #iaws either to ac exis: :r vili :e :etected in ne vesse!-to-nc::le weid inc : ace reta:

5ME

ecticn 1: ::ce,

_72 Ic":icn h> s O C

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3 C-her recuired tests and ins ections of tne ec::!e-::-sessel weld,

.e., nycrostatic anc visual, will furtner increase ne :egree af assurance :na: the structural integrity of tne cressure bcuncary is maintained.

The.1RC staf# concluces that :ne limi:ec ex ernal volumetric examination aill not significantly liter -he cacacility of detecting unacceotacle inservice flaws in :ne no::le-:;-vessel welc and case metal and therefere relief frca :ne 1007 voi; metric examination requirement may be granted.

2.

Recuest relief from :erforming 1005 volumetric examination for the no::le- 0-snell welds and the insice radius section on :ne surge line connection to the pressuri:er.

(!:en 32.2, Examination Category 3-0 from Table IW3-2500)

Code Recuirement The extent of examination of eaca nc::le snail cover 1C0% of the volume to be inspected as sncwn in Figure IWB-25CCD.

All no::les snall be examined curing each inscection interval.

Licensee Basis for Recuestina Relief The no::le-to-shell weid and inside radiused secticn Of the surge line connection cannot be c=npletely inspected volumetrically due to interference frem the heater penetra:icns.

Evalua tion The design of the surge line connection to the pressuri:er presents interference with surrounding heater penetrations. This inter-ference makes it impractical to volumetrically examine 100% of the no::le weld and base metal and the inside radiused section.

The licensee has stated that the examination will be performed over 97" of the required volume and we c:nclude that this examina:icn will provide an acceptable level of assurance of the no::le-to-shell~

weld and base metal integrity. Relief from the 100% examination recuirement may be granted.

3.

Request relief fr m the examina:icn recuirements Of ASME Section XI for the folicwing items designated to be ins ectec in Section XI.

Code Items Examination Catescry Cemconent 32.5, 32.5, 32.7 3-G-i Pressuri:er 3 citing 32.1, 32.5, 32.5 3-G-1 3 team Genera cr ici-ing 34.2, 32.3, 34.1 3-G-1 Class 1 Jicing 3ci-ing 36.1, 36.2, 36.3 3-G-i Class i 'laive Soit ng 34.1 3-F 3afe enc in brancn Dicing

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Code Recuirement The examinations (volumetric, volumetric and surface, or visual, based on item No.) performed during each inspec-ion interval shall cover 100% of the bolts, studs, nuts, busnings, and threads in base metal and flange ligaments between threaded stud holes for pressure-retaining bolting two-inches and lar er in diameter. (3-G-1) For pressure-retaining dissimilar metal welds, the examinations (volumetric and surface] performed dur-ing each inspection interval shall :cver the circumference of 100*. of the velds. (3-F)

Licensee Basis #ar Recuestino Relief There is no boiting greater than 2 inches diameter in the faciltty for the pressurizer, steam generator, class 1 piping, and class 1 valves. Also, there are no safe ends in branch piping.

Evaluation The licensee is in compliance with Code recuirements and thers-fore relief is not necessary.

4.

Request relief fr m the volumetric examination of centrifugally cast stainless steel piping and the cast stainless elbcws of the primary pressure beundary (Item 4.5, Examination Category 3-J from Table IWB-2SCO).

Code Recuirement The examinations prefor:ed during each inscection interval shall cover all of the area of 25% of the cire=fenntial joints including the adjoining i ft. secticns of longitucinal joints and 25: of the pi;e b ranca connection joints.

Licensee Basis for Recuestina Relief The primary piping is fabricated fr:m centrifugally cast stainless steel pipe and cast stainless steel elbcws. Ex;:erience has shcwn da: cese materials and welds are no: iiways amenaole to ul:nsenic examina:icn. Technicues have been develocec to substantially ver-c0me this Or::iem. Volumetric examination will be :erfor-ed 3

ne extant:nc ical and ac::rding :: :ne senedula cesignatac in he Examination plan. Should other ::ecialized altnsanic examina:1cn

acnnicues bec=e :rsc:ical wnica are mere ef'ec:ive, : hey wili be incor:0ntad in -he Examina:1cn Slan.

he aitnscnic examina:icns

resently asec will :e sucoiementac by sur#2ca examina:icns 4nen

cssicie anc *ne n they wil' :revide accitional Issu n nca na:

ne integr' 7 f :ne :rimary :res:ure :cuncary is being maintainec.

442 060

- Evaivation The matarial cnaracteristics of centrifugally and conventiinally cas; stainless steel severely attenuates ultrasound. The licensee has statec that ultrasonic techniques have been developed to suo-stantially overc:me the problems as:ociated with ultrasonics and cast materials.

We have determinec that the tecnnicue to be used is adequate for examination of the inner portion (root) of the weld but will not provice acecuate results for full volu-metric examination of the weld and base metal. We have therefore concluded and the licensee has acreed that the ultrasonic technique used to examine the welds will be supplemented by a surface examination, wnere possible, to ensure that any discontinuities whicn may be cresent at the outer surfaces are detected and eva l ua ted.

The licensee nas also agreed Oc incerto-ate in nis Examination Prcaram ctner scecialized and cractical volumetric examination techniques wnica become avaiiaole anc are acre effec-tive : nan those presently in use.

The ultrasonic examination technique used, supplemented by surface examination as well as One required pressure testing of the primary cicing, will subject :ne

'iping and elbcws to examination and test methccs wnich should reveal any Code unacceptacle flaws and therefore provice an adequate level of assurance of the structural integrity of the primary pressure boundary. Therefore relief fecm the full volu-metric examinaticn requirement may be granted.

5.

Recuest relief from full volume:ric examination of the integraTly welded succorts of the Class 1 pumps.

(Item 35.4, Examination Category 3-K-1 from Table IWB-2500).

Ccde Recuirrent The examinations performed during each inspection interval shall cover 25" of the integrally welded sucports.

Licensee 3 asis for Recuestina Relief The feasibility of volumetric ex mination has not yet been deter-mined. The examination will be performed if feasible and according to the scnedule designated in the Examination Plan.

If extensive grinding is not recuired to prepare the surface of the pump casing adjacent to the weld for surface examina:1cn, surface examination will be perfor-red to supplement the volumetric examination.

Evaluation 3ecause af :he ;um:s anc sua:cr; :esign, the solume:ric axamina:icn recuirment is no: :ractical to meet. The ifcensee has statac that volumetric examination will be perf:rmed frca :ne su::cr: sica bbl

. but not frca the ?umo sice and tna surface examination will be ;erfor ec to succlement ne volumetric examina:icn i# ex-tensive grincing is not recuired to recare ne sur# ace :f the pumo.

Because of ne neid gecretry anc !aacing conci:icns, the. cst likely inservice de'ect.vcula accear an :ne surface of the weld or base retal ana.vould be revealed by -he examina-tien pretosec by the licensee. The NRC staf# concluces that the : reposed examination will provice assurance of tne suopor:s' structural integrity and nerefore relief ' rem volumetric examina-tion as requested by the licensee may be granted.

6.

Request relief frca volumetric examination of the reac:cr coolant pumo casing welds and, unless the pumo is disassem-bled for maintenance, visual examination of the internal surface of the ;umo casing.

(I: ems 35.5 anc 35.7, Examina-tion Categories 3L-1 and 3L-2).

Code Recuirement The volumetric examinations perfor ed during each inscecticn interval shall incluce 100", of the pressure-retaining welds in at least cne pump in each group of pumps performing similar functions in a system. Tne internal pressure bouncary surfaces of one pumo in eacn group of ?umos perfor ning similar functions in the system shall be examined visually during each inscection interval. Tne examination may be cerformed at or near tne end of the inspecticn interval.

Licensee Basis for Recuestinn Relief There is currently no kncwn technique available to volumetrically inspect the pumo casing welds. Research is under day to overcome this preolem. When preven technicues are availacle, consideration will be given to the inclusion of these welcs in the inspection

r gram. M external sur# ace examination of pumo surfaces and welds is not c

nsidered possible due to the rougnness of the castings.

An internal sur# ace examination is incractical cue to :ne nign ex:csures that wculd be involved.

(The exam would require a minimum of 15 man-nours; the raciation levels can be expected c be atcut 3R/hr area and 7R/hr contact.) The licensee's cositicn is that a visual examination, per#cr ed Only if -he pump is disassembled for maintenance per nitting such inspection, is judged to be adecuate based ucen design, fabricaticn and accessibility considerations.

Eval uation 3ecause of -he :umos' de:ign, ma:erial of construction, anc :ne inaccessibility to tne areas af :ancern, it is incracticai 1:

nis time to volumetrically examine the reac:Or ::alant :umo

asing *eics anc actain meaningful resui::. The licensee aa:

statec taa: researca is ancerway to : vere:me the roc; ems assccia:ac di:n meeting 1e cce. ecuiremen; and -ha: : nsidera:icn : inc: ce

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Of

. 3roven techniques into the inscection Oregram will te given wnen :nese technioues are available. The licensee is ;resently mmitted to erform system pressure and leakage tests anc to mcnitor system leakage of the reactor :colan: system criar Oc anc during clan: Oce rati cn.

Ne have determined :nat these tes:s crovice acecuata assurance of the :umo casing 3 ructural integrity because any defects of major significance snculd result in cetectacle leakage during pressure tests unica are performed prior to reactor operation after each refueling outage.

Therefore, relief from the recuirements may be granted.

7.

Recuest relief from the volumetric and/or surface examinaticn of inaccessible pioing welds wnien are identified as folicws (Categcry (3-J):

Ficure No.*

Line No.

Weld No.

A-22 12in.-SI-12 15 A-25 12i n. -SI-24 16 A-27 Sin.-SI-14 10 A-27 Sin.-SI-la 11 A-32 3in.-HFH-22 1

A-32 3in.-HPH-22 3

A-38 2in.-HPH.2-12 5

A-42 12in.-5DC-20 7

_~

Ccde Recuirament The examination performed during each inscection interval shall cover all of the area of 25% of the circumferential joints including the adjoining i ft. sections of Icngitudinal joints and 25% of the pice branch connection joints.

Licane=a :2eee ser coe.. e-dec calief The welds listed above are inaccessible becau:e :ney are iccatad in walls or ficcrs.

-valuatien Access tn volumetrically and/or surface examine :nese welds is not available because of the location of the welds in walls and floors.

The licensee has, stated that the araas of the nelds icentified acove as beinc inaccessible will :e visually ins ected durinc :ressure and hydrostatic :esting for signs of leakage.

ascections recuirec :y Section X: of a ner ac:essible 4eics in the system sili provice assurance that degraca:icn unica nould ::mcr: mise :ne :ressure bouncary intagrity las no Oc:urred. The licansee vill :antinue to tee: :ne :ercentage examination recuiremen

1. r ne af'ectec sys ams curing nis :ns:ection intervai We nerefore : nciace na-ne inscections vnica will be : erd -med in Iieu of : nose t-Cuitec vii: ;r0v"de 3cecuata assurance of ne system': 'ntagr :/ anc el:af ' :m ne ;cce ecuirement: nay :e ;rantec.

. ~m ne 20-Year Inservica u~ amina.icn Plan,.:or. :al houn k k :-

Sta:icn, Uni: No. l.catec :c::cer '973.

3 C'. ASS 2 COMPCNENTS 1.

Recuest relief frca volumetric examination of ::e inaccess-ible welcs anica are identified celcw (Category C ~

Ficure No.*

Line 40.

Weld No.

3 12 12in.-LPSI-12 4

3 13 12in.-L?SI-14 7

3 13 12in.-LPSI-11 10 3 13 12in.-LFSI-la il 3 la 12in.-LPSI-22 10 3 15 12in.-L?SI-24 2

Ccce 7ecuirement

'lolumetric examination sna11 cover 100% of the welds s:ecifiec

~

in I'4C-2411 during a 40-year period.

Licensee Basis for Recuestinc Relief The welds listed above are inaccessible bec.ause they are lccated in walls or floors.

Areas on either side of the walls or floors containing these piping welds will be examined for signs of leakage _

during the cressure testing of the piping system.

Evaluatien Access to volumetrically and/or surface examine these welds is not available because of their location in walls and ficors. The licensee has stated that the areas of the welcs icentified above is :eing inaccessible will be visually inspected for signs of leakage during the pressure tast. This examination and other volumetric examinations of other accessible welcs in this and other similar systems will provide assurance :nat degradation wnich would ccmcr0 mise the pressure Coundary integrity has not ccCurred curing the inspection pericc. We therefore concluce that relief frca the Code recuirement may be granted.

2.

Recuest to c:mply with the Summer 1975 Addenca of Section X in regard :: :ressure-retaining bolting. (I ams :1.1, CC.a, C3.2, anc C2.2 Examinati:n Ca:egory -0).

From tne iG-year Insarvice Ixaminatien Plan, fort Calhcun Nuclear Station, Unit 'fo. 1, dated 2ct cer 7373.

A/9 0 / <1 i

t tL t) U 't

-la-Code Recuiremen:

Visual and either surface or volumetric examination shall be performed on pressure-retaining bolting exceeding one-inch diameter. Visual examinations ;erformed during eacn ins::ection interval shall cover 1C05 of the bolts, studs, nuts, busnings, and threads in base material and flange ligaments be:seen threaded stud holes. Nondestructive examinations snall be performed on 105 of the bolting in each joint, but not less than do bolts or studs per joint. (1975 Addenda of 1974 Edition of Section XI).

Volumetric examination performed during esca inspection interval shall include 1C0% of boits and studs exceeding 2-inch diameter at each bolted connection of pressure-retaining com::enents recuired to be inspected. This examination may be ;erformed on bolting in place under load or upon disassemoly of the connection.

(1976 Addenda of 1974 Edition of Section XI).

Licensee 5 asis for Recuesting Relief The licensee proposes to ccmoly with the Summer 1976 Adcenca wnica mcdifies one bolting examination requirements to examine only :ne cressure-retaining bolting exceeding 2 inches in diam.eter.

~

Since the Sumer 1976 and all subsequent addenda to the Section #

XI Code have adopted the 2-inch diameter and greater examination requirement, the potential for failure and the consecuences thereof accear to be of little concern. The Code recuirement of the Sumer 1975 addenda is deemed to be impractical in relation to the level of safety achieved by performing the examination versus :ne man::ower and monetary expenditures involved.

Evaluation The licensee has stated and de acree : hat the Coce recuire-ment for examining pressure-retaining bolting of the smaller diameters is impractical and burdensame and no: -arranted in relation.o ne degree of safety added by the requirement. The Summer 1975 Addenca, which the licarsee ::roposes to use, has limited the examination of pressure-retaining bolting to those excesdino 2-incn diameter.

se find the change in the boiting examina:1cn requirements acceptable and conclude that relief fr:m the escuirements of the 197a Edition of Section X! may be grantec as recuested by the licensee.

A i ')

^'r f

}

M 1 L.

)Yb

1 3.

Recuest to use the system hycrestatic test recuirements of Article IWC-5C00 of :ne 1977 Wintar Accenca of :ne 1977 Icition of Section XI for Class 2 ccmcenents uith the excection of tre steam and feecwater systems whicn will be governed by One requirements of Technical Specifica:icn 2.1.l(7).

Code Recuirement The system hydrostatic tast pressure snail be at least 1.25 times the system design pressure and conducted at a test tem:erature not hss than 1000F (1974 Edition), The system hydrostatic test pressure snall be at least 1.10 times the system pressure P v for systems 3

witn Oesign Temperature of 200 F or less, and at least 1.25 times the system pressure P for systems witn Design Temcerature above sv 200*F.

The system pressure Psv shall be tne icwest pressure setting among the number of safety or relief valves arovided for overpressure protection within the bcundary of the system to be tested.

(Winter 1977 Addenda)

Licensee Basis for Recuestina Relief The majority of the Class 2 piping systems, subject to the Section XI pressure testing, can be tested only when the plant is in a cold shutdown condition. While in this mode, there does not exist,'

a means of heating the piping systems above ambient tem eratures.

Providing a means of heating long piping systems to ICO*F is consider-ed impractical, within the meaning of 10 CFR 50.55a.

The :ninimum tamperature requirement for performing a system hydrostatic pressure test was established to meet the recuirements scecified by fracture prevention criteria. Since the.: ort Calhoun ferritic ccmcenents' ambient rocm temceratures are sufficiently above trittle fracture temceratures (NDT tyoically s -200 ),

heating the systems to ICO*F is unnecassary. For tne austenttic stael ccm::cnents, the NOT temperature is typically -325'e, far celcw any possible testing temcernare. Again, heating :ne austanitic materials to 100*F is unnecessary.

Preservica hydrostatic tests were performed at ambient temperatures and it is the judcment of the licensee that hydrc-testing at amcient tempernures is still acc;ptable.

Evaluation 3ased an the informa:"cn given acove, we ::nciuce :na: resting :ne minimum :am::ernare recuiremen: (1C0*) for nycrostatic :ss inc : lass 2 picing systems, excac :ne s:aam inc faecwater systems, is incractical, ai:ncu tecnnicai justifica:icn and :na: :asting :nese systams 1: ancient (a::cve 50 t} -Ocm tem::erature wir 10: :cse 1

ncition f:r : ::le #racture of :ne ma:arialr. " sing :ne lycr0-

. static test requirements of Article :'WC-5CCO of :ne 1977 Edition of Section X: is therefore acceptacle anc relief frem the hycr0 static test recuirements of the 1974 Eci:icn may :e grantec.

C.

C'_ ASS 3 CCMp0NENTS 1.

Recuest relief frcm pressure test recuirements of IWD-ESCO (b) for the buried raw water lines frcm the intake strur 3

to :ne auxiliary building.

Code Recuirament In the case of buried ccm:anents (e.g., underground pioing), valves shall be provided to perni: isolation of tne curied ;cr:icns Of cicing for the pur:ose of conducting a system pressure tes-in lieu of the visual examination. A loss of system cressure during the tes: snall constitute evidence of cocoonent leakage.

Licensee Basis for cecuas-4no 7e14ef h design of the system does not allow for pressure testing the buried portions cf the system since the isolation valves in this system are butterfly-type valves and are not cacaole of tignt snut-off of the system. The installation of tight shut-off type valves wculd recuire major modifications to this system.

Evaluatien pressure testing of these welds is recogni:ed as imoractical because the design of the systemdoes not contain provisions for tight shut-off. Since the system operates at icw pressure (25 psi 30 psi), i:

ecuicced with ficw instruments capable of detecting sicnificant leaks, and thera exists a redundant system, we conciuce that assurance of adequate flow of raw water will be provided under normal and Ibnormal :enditions and that relief from the required pressure test may be granted.

3.

ULTRASONIC EXAMINATION 1.

Reques to use 100% of the reference level as the evalua:fon criterion for indications detected during ultrasonic examination of piping welds.

Coce Recui-emen:

'1:nsonic examination shall be :ancucted in ac:ortance 4ith the J

trovisians Of Accencix :. 'cihere Jocencix : 's not icoi'cacie, :ne

ravistens of Article 5 of Iection 'l snail tooly. All incica-icns unich :r:cuce a res::ense ;reatar than '"", of ne reference level Inali te evalua ac.

z2 067

. ' icensee Basis for Recuesting Relief Evaluaticn of indications at 20% of the reference level increases the num0er of inoications whicn have to be evaluated oy a '/ery signi ficant amount. To evaluate anc record the numerous incications would recuire examination personnel to stay longer :eriods of time in radiation areas.

Evaluation Evaluating indications at or above the 20% reference level places a great burden on the licensee tecause of the numerous and structurally insigniff'. ant inoications *nich would have to be evaluated. Examination :ersonnel would be recuired to remain in raciction areas for longer :eriods of time evaluating indica-tions wnich would not increase the level of safety of the facility.

We have concluded tna the 100% reference level evaluation criter-ion is sufficiently reliable for detection of defects aarranting evaluation except those indications at 20% DAC or greater wnich are interpreted to be cracks. We have determined and the licensee has agreed that the ultrasonic procedur) will contain the following items:

a.

All indications it or above 50% DAC shall be recorded.

5.

All indications 100% DAC or greater shall be recorded and. -

evaluated in accordance with the rules of Section XI.

c.

Indications 20% DAC or greater wnich are interpreted to t 3 a crack must be identified and evaluated to the rules of Section XI.

Based on the above, relief from the 20% reference level criterion may be granted.

442 063

. II.

?'JMP TEST *NG DRCGRAM A

L0w Pressure Safety Injection ?umo SI-lA, 3 Containment S;: ray Pum;s SI-2A, 3, C Hign Pressure Safety Injection Pum:s SI-Za, 3. C 1.

Relief is requested fr a measuring inle and differential pressure.

Code Recuirement Inlet and differential ::ressure measurements are required monthly during normal plant operation.

Licensee Basis for Recuestine Relief System does not include instrumentation for measuring these parameters.

Alternate Testine Inle: pressure to thesa aumps will be taken from the static head pressure of the saiety injection and refuelii.g water tank. Outlet pressure will be measured at the discharge of the pumps and pressure differential will be calculated.

Eval ua tion We agree that the recuired measurements are imorac-tical within the limitation of cesign of these pumos and that the alternate testing proposed will not result in a decrease in the level of plant safety. Mocification of design to c nform to the Cade requirements would not sig-nificantly acd any additional increase in the level af ::lant safety and therefore is not warranted.

'cle c::rci uce that relief from the recuirement may be granted tecause ne alterna e, me:noc will :rovice the :nfor-nation neeced :o assess :ne nycrautic cnaracteristics of the pumes.

?.

Relief is requested frcm the code requirement of measuring the pump parameters on a monthly basis. The requested fre-quency is to conduct these tests on a quarterly basis.

" ace Recuiremen Tne testing interval for measuring :umo :arimeters, excea:

bearing tem::erature, is an a mon:niy :as:s :uring nor a'

? tan acera:1on.

442 069

. Licensee ? asis #ce Recuestire :elde7 The ;umes operate infrecuentif, and de.aca:icn is more likely to result from usage than from serices of inactivity.

Mcnthly tasting im oses a man ~ power hardship tnat is not commensurate with an increase in quality or safety. -acn test of the eight safety injection and containment spray pumps requires 30 man-hours.

Monthly testing subjects the persons conducting the test to adverse working conditions such as hign noise levels, tem;erature, and humidity for extended pericas of :i,e.

Two men are required in the pump rooms at all times during the tast. The puma rooms typicall / have a radiation level of 10 mrem /hr. resulting in a total exposure of 0.3 man-rem during the perfor.ance of each test.

In acdi' ion, running the pum:s represents a noise nazard.

During the test, each pump is unavailable to perform its safeguard furction.

The safety injection and containment spray pumps are low-maintanance, low-failure rate items. The containment spray pumps SI-3A, 3 and C operate essentially only during tests.

Maintenance records show these -"aps have not required recair in six years. The hign pressure safety injection pumps S!-2A, 3 and C are ocerated only during tcats, to fill safety injec-tion tanks during plant operation, and to fill the reactor cavity during refueling. Maintenance recorcs show that one seal was replaced in six years. The icw pressure safety injection pumps operate during tests and as shutdcwn cooling

umps during cold shutdcwn periods. These pumps operate for consideraoly longer periods than the other aum:s, and main-tenance records indicate that each pump has recuired seal re: air once. Thus, the plant maintanance rec:rds tend to su: port the elief that the sumos are reliaole and degraca icn is the result of use. Monthly testing recuires that eacn :umo be run eignt (3) hours longer per jear than quartarly testing would require.

Little or no additional increase in the level of safety or

uality wcuid accom:any monthly :asting because tne :umos are historically reliaole; recundant ::mconents axist for tacn pum:; :ne :umes are lined ;o for : heir sa fety function inc are essentially inac ive during nor al c:eraticns. '8cntni/

tests furtner Oe:ract from a level af safe y ay sucjecting acrxar: to unnecascary raciation ex osure, naren aceting

cncitions, and :y increasing ne 4 ear an :ne pum:s.

442 070

- Evaluation We ha;.e dete. mined that the ocerating history of trese sumos coes not supoly an adecuate data base to justify -he conclusions drawn that more frecuent testing tencs to cegrace tne cumo ani:e cro-viding no aeditional assurance of pumo coersaility.

We feel that the first six (6) years of cumo aceration will not provide a reliable base to extrapolate a failure pattern for a forty (40) year plant life.

We concluce that the burden of conducting the Ougo test at the c de required monthly interval ex:ressed in tne basis, and the pump maintenance nistory co n; provide reasonable assurance that the level of piant safety will not be reduced oy cuarterly testing of cumes; tnerefore, this relief 1s not granted.

3.

Component Cooling puros p.elief is requested frem measuring inlet and differential 1.

pressure and flow rate.

Code Recuirement Monthly inlet and differential pressure and ficw rate measure-ments are recuired during normal plant operation.

c lie #

Licensee ? asis #ce :acuastina e

The system does not include instrumentation for measuring the pressure or flow parameters and adding this equipment is estimated to cost thousands of dollars. The level of safety of the plant is not significantly decreated by not performing this testing due to the following: 1) eidundancy in the ccm onent cooling system pumos, 2) the raw datar pumcs can be realigned t: cool all of the critical neat loads in case of a pump failure and 3) the discharge pressure, vibration level and bearing tenperature will be measured at the required inter-vals to mcnitor possible pump degradation.

4fi9 n'

rc u,

Evaluation Secause of the systen design, we ::ncluce :nat One cost and time involved in adcing acdi-icnal oressure and ficw rate measurement equipment will not be justi fied 3y a commensurate increase in the level Of plant safety. The recundancy of the 00mponent cooling pumcs anc the fact na if a failure of all these pum:s occurs, the essential heat loads can be cooled oy the raw water pucos, establishes a reasonable assurance that the level af plant safety is not significantly recuced by this relief. We therefore find :nat this relief may be granted.

2 Relief is requested from observing bearing luoricant level.

The bearincs for the ccmconent coolinc sumps are pre-cacked and sealed tyCe bearings. We intercret this require-ment in :ne Code does not a:cly :o aacked and sealec : earings as in T.any cases the bearings wcuid be damaged or destroyec by checking the lubricant. Measurement of bearing temper-ature will provide adeqt. ce assurance of proper lucricant l evel. A relief is not required.

C.

Boric Acid Pumps CH aA, 3 Relief is requested from measuring inlet and differential pressere.

Code Recuirement Inlet and differential pressure are required to be measured monthly during varmal plant operation.

Licensee Basis for Recuesting Relief The system does not include instrumentation for measuring these para-me:ers.

Alternate Testine The boric acid pumos will ce aligned to inject into a fixed resis:-

ance system. The inlet pressure will be measured frem tne baric acid tank level. The outle: pressure will be measured and tne differential pressure calculated.

Evaluation The alternate testing pr00csed by -he licensee ac mplishes measure-ment of One pum: :ifferen-ial pressure wnich ne C;ce recuires.

Je lave :eterminec na: ne alterna a :esting ;riccsec wili :rav ce i icecuate a a a etec :nanges in ne lycraui'c :naracteri::ics af :ne :umas anc Na cl in mcci#ications 0 ::nfern o : ace e-

ui emen:: vcuic acc in insigni" can: "ncrease in :ne Tevel of aian:

Id#ety.

. 4e conc:uce that the al arnate testing is acceptacie anc na:

relief frem -he recuirement may be rantec.

J.

Raw Water pumps AC-lCA, 3, C, O l.

Relief is recuested from measuring inlet and cifferential pressure and ficw rate.

Code Recuirement Inlet and differential pressure and flow rate measurements are required monthly during normai piant operation.

Licensee Sasis 'Or Recuestinc Relief The system does not incluce ins:rumenta:icn for inlet and differ-ential pressure measurements and flow rates are not considered accurate due to river water fouling.

Alternate Testina The licensee has agreed that the pumo cischarce cressure and motor amcerage will be measured on a monthly basis and ccm;ared to :ne following perfamance standards.

An accerage acceptance value to be detemined by acceptance-testing.

Discharge pressure 25 througn 40 psig Evaluation We have determined that the alternate testing croccsed ay the licensee will provide adequate infomation to detect changes of the pu:ros' hydraulic characteristics and to give in early indicaticn of pumo degradation as intended by the tests recuired oy the Co c.

Due :o conditions sucn as changes in the river level, fouling of flow instrumentation and sand accumulation in cuma iniet, the recuired measurements for puro :arameters will not yield useful infor ation if installed. We conciuce :na this mouest. for relief and alternate :esting are acceptacle anc will not reduce the level of plant safety.

2.

Relief is requested from bearing temcerature reasurements on the bottom bearings of raw watar pum s.

Cace 7ecuireren 3 earing amcerature reasurocent is r?cuirec Once yearly :uring inservice asting.

442 073

, Licensee 3 asis f0r Recuestina Relief The icwer bearings are sucrerged in water and are inaccess-ible for tencerature measurements.

~ valuation The measurement of bearing tem:eratures of tnese pumcs is imoractical because of the ;umos design. 'de conclude tnat measurement of vibration amplituce, along witn :ne other recuired carameters, will arcvide sufficient information to cetermine the mechanical cnaracteristics. including nearing degradatica, of the pumos and that relief from tne bearing temperature measurement may be granted.

a

. I:I.

Valve Testinc 3-ccram A.

General 1.

Leak Testinc of Valves wnicn car #c m 3 P-assure :soiation

unc::an There ar? severai safety systems connected to the reactor coolant pressure coundary tnat have cesign pressures tnat are telow the reactor coolant system coerating pressure.

There are redundant isolation valves feming the interfaca between these high and low pressure systems to prevent the low pressure systems from being suojected to pressures wnich exceed their design limits.

In tnis role, the valves are perfoming a pressure isolation function.

It is our view that the isolation recuncancy croviced by these valves regarcing their a lssure isolation functicn is important. We consicer it recessary to provide assur-ance tnat the concition of each of nese valves is acecuate to maintain this recundant isolation anc system integrity.

For this reason we believe that some metnocs, such as leak testing, should be used :o assure their concition is sufficient to maintain this pressure isolation func:icn.

In the event that leak testing is selected.as. the acpropriate..-

procedure for reaching this objective, we believe '

~

that the following valves sr.]uld be categori:ed as A or AC and leak tested in accordance with IW-3420 of Section XI of the acplicacle edition of the ASME Coce.

These valves are:

HCV-327, HCV-328, SI-196, SI-195, SI-194, SI-207, SI-208, SI-199, SI-198, SI-197, SI-211, SI-212, SI-202, SI-201, SI-200, SI-216, SI-215, SI-208 SI-202, SI-203, SI-220, SI-219.

We have discussed this matter anc identified the vaives listec above with the licensee. The licensee has acroed to review leak :esting -hese valves in accorcance with "WV-Ia 0 of the acclicaole edition of the ASME Code and to categorize these vaives with the appropriate designation.

If the licensee detemines nat leak testing is not necessary because there are other methods that they have and will use to detenine each valve's condition, they will provide to the,*1RC for evaluation, on a valve by valve basis, the details of :ne method Jsec tna: :learly demonstrates the cancition O' eacn valve. The licensee nas acreec o cravice the 2:cve informa::cn y July 1, 1979.

2.

2;osect an :'WV-ZaiO(3) of ne Sec-icn (I ::ce ynicn :i:-

us:es ful 2:rexe ind :artia! ::roxe recuirement:; re-ruires na: Coce :a:egory A inc 3 vaives :e exercizec

nca every :nree cntns, witn excect"ons as :efinec in

vV-Za10( b )

'), 'ej anc ;

.w/-;S20ia; recuires na:

442 075

s

. Coce Category C valves te exercised once every :hree months, with excso ions is defined in :%V-25CC(3:.

n

he a cve cases of exceptions, ne Ccce cer :i : :ne valves to :e tested 1: cid shutdcwn anere:

(a) It is not practical to exercise the valves.o the position recuired to fulfill taeir function er to the partial position durino ecwer coerition.

(b) It is not practical to observe the coeration of :ne valves (with fail-safe actuators) uoan loss of actuator pcwer.

IWV-3520 requires than normally ocen valves be par -stroke exercised cuar erly and full stroked at c0!d shutcowns. A relief has been requested by ne licensee for nor-'aily Ocen power acerated vaives wnicn are cnly full s:~:ked at calc shutcowns.

It snould be notec 'ta: in this SER, if -elief is recuested for a ner-' ally open valve o be exercised at cold snutdcwns, it is understood tha: the valve :ust re-main acen and cannot ce part-stroked.

The licensee nas stated that ncne of the Cateccry A cr 3

cwer

::erated valves listed on :ne following paces can be par -stroked because of the cesign logic of tne opera-ting circuits.

These circuits are sucn that when an caen or close signal is received the valve must cocolete a full stroke before the relay is released to allcw the valve to stroke in the other direction. We find that the above re-lief recuest fra:n part-stroking is warranted and should be granted because the required function of the valves invol /es only full open or full cicsed positicns. These valves wili be full stroked at a frequency wnicn will assure adecuate reliability.

3. !nsertice valve tasting at cold shutdown is cefined as:

Valve testing shou 1c comence not latar than 18 nours after snutdown and c:ntinue until c:moieta or plant is ready to return to power.

Comoletion of all valve tasting is not a prerecuisite to return to power.

Any tasting not comoieted at one cold snutdown should be performec curing the subsequent cola snutdowns to meet the Code required testing frequency.

a. The 20ce states that, in the case af coid snut:cwns vaive tasting neec.o: be ; erfartec nore aftan : nan onca every three months for Catagory A anc 3 vaives and :nca every nine mentns for :ategory C valves.

I-is Our Ocsition na: ne :Oce is inconsi2 an: Inc na Cata-

ory C vaives Inouia

e tastac on ne ame Icnecule is Category A Inc 3 valves.

~he 'icansee las acreec Icci'y qis note :n coic : nut:cwn o eac, ':5 ne :ase

f 'recuent col: Inut:cwns, va!ve astine wii',at :e

er#cr-ec Icre ]f an nan :nca everf trie '2; mntns fo r '1:2go ry '. 3 In c C va l ve s. '

442 076

-E6-S. Chances in the Technical Sceci'ications In a Novemcer 1976 letter to the Cmaha Dublic Power District, de provided an attachment entitled "NRC Staf' Guidelines for Excluding Exercising (Cycling) Tests of Cartain Valves ::uring Plant Oceration."

The attachment stated that when one train of a redundant system such as in ne Emergency Core Ccoling System (ECCS) is incperable, nonreduncant valves in the remaining train should not be cycled since their failure would cause a loss of total system function. For examole, during cower oceration in some plants, there are stated minimum requirements for systems wnica make up the ECCS whica allow certain limiting conditions for operation to exist at any one time and if the system is not restored to meet the recuirements within the time period specified in a clant's Technical Soecifications. the reactor is recuired to be put in some otner mode. Further-tore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate function are recuired to be tested to demonstrate operability immediately and

eriodically thereafter during ccwer operation. For such plants this situation would be contrary to the NRC guideline as stated in the document mentioned above.

The licensee has agreed to review the Ft. Calhoun Technical Specifications and to consider the need to procose Technical Specificaticn changes which would have the effect of pre-cluding such testing.

!f, after taking -his review, the licensee determines that -he 75 shoula not be changed because tne guidelines are not acolicaole or iannot be followed, the licensee will submit to the NRC the reasons that led to their deter nination for each ;otentially affected valve. !n the licensee submittal, the potentially affected sections of the TS, in addition to the valves, will be identifiec.

The licensee will submit tne acove informatien by July 1,1979.

5.

Safety Relatea '/alves Tnis review was limited to those Class 1, 2 and 3 valves of Section XI of :he ASME code that were safety related. Safety related valves are defined as those that are neeced to mitigate the :nsecuences of an acci:ent inc/or o snutccwn :ne react:r and to maintain :ne eactor in a snutccwn :encit:cn.

sncuid :e actec nat -he licensee may qave inclucec nonsafety reiated

/aives "n neir :nservice es 3 cgram is a :ecision :n ne licensee's

art : ex::ana tne scc::e of neir :nserv ce est :- gram.

n [13

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A

~

r t.

. 3.

Catecorv A velves 1.

Relief Recuest The licensee nas preposed to exercise tne following Category A valves at refueling outages:

a.

HCV-Zal Reactor coolant pumo controlled bleed off isolation.

b.

HCV-206 Centainment penetration M7 isolation.

Cece Recuirement Refer to paragracn III.A.2.

Licensee Basis for Recuestina Relief.

These valves cannot be closed when the reactor coolant system is pressurized.

Controlled bleed-off ficw must be maintained to prevent damage to the reactor C0olant pump seals.

Evaluation In view of the need for maintaining ficw to the reacter coolant pumo seals to preclude failure of the pumos and prevent leakage of primary coolant during normal coeration and cold shut cwns, the cuarterly stroke recuirements of ASME Ccde Section XI is imoractical for tnese valves.

.cr tnis reason and the reasons set forth in section 3.3 belcw, we find that the propcsed relief is accectable and snould be granted.

2. Relief Recuest The licansee has precosed to exercise the following Category A valves at refueling cutages:

a.

TCV-202 RCS 1cco 2A let cwn isciation anc tem:eratur? requittien.

MCV-201 Cantainment ceretration M2 isolation ana 'etecwn ::ntrol.

Cece Recui ement Refer to :aragracn :::.A.:.

z1 i 7 070

/r L.

ti i O t

Licensee 3 asis for Recuestina Relie#

Closing these valves would result in termination :f t.9e This woulo aisc isolate tne cnarging and letcown flows.

borencmeter rocess -aciaticn monit:r, anc reactor c0olant system :urification and nould cause a :ressure transient in the primary system.

Evaluation Inasmucn as continuous oceration of the letcown system is necessary to maintain the recuired water enemistry, and procer water inventory (i.e., interruotion of the cnarging or letcown flows of the CVCS auring normal operation anc cold snutdcwns would introduce ressure transients to tne primary system), the quarterly stroke recuirement of For tnisSection XI for these valves is imoractical.

reason and the reascns set forth in section 3.3 belcw, we fino that the proposed relief request is warranted and snould be granted.

3. Relief Recuest The licensee has proposed to exercise the following Category A valves at refueling outages:

Containment purge air isolation.

PCV-740A a.

Containment purge air isolation, b.

PCV-7423 Containment purge air isolation.

c.

PCV-742C Containment ourge air isolation.

d.

PCV-7a2D HCV-681 Containment nycr gen purge a.

isolation.

Containment hycrogen purge f.

HCV-382 isolation.

Containment nydrogen purge g.

VA-250 i sol ation.

cntainment mycragen : urge VA-239 isciation.

4/117 0~(

fL ll s

, Code Recuirentent Refer to paragrach III.A,2.

Licensee Basis for Recuestina Relief These valves provide a direct patn for release of contaminants from the containment.

Cycling these valves will result in a potential release of contaminants.

Evaluation These valves are containment isolation valves that are closed during normal operations and cold snutdowns.

Inasmucn as these valves are in the oosition required to fulfill their function, the quarterly stroke requirement is imoractical for these valves. Moreover, since opera-bility of these valves is not recuired for safety reascris but, instead, tneir safety function is perforced wnen the valves remain in their closed cosition, coerability test-ing of these valves on a quarterly bases would nct be meaningful and, in fact, should be avoided.

'.ie, there fore,

find that the pr,ocosed relief request is warranted and snould be granted.

4, Relief Recuest The licensee has proposed to exercise the folicwing Category A valves at refueling outages:

a.

HCV-425A C:ntainment :enetration M39 ccmcenent cooling systam isolation.

c.

HC'/-4053 Containment penetration M29 ccmcenent cooling system : solation.

c.

HCV-425C Cantainment penetraticn M39 ccmconent cooling system isolation d.

HC'/-4250 0:ntainment penetration M39

mconent ::cting systam isolation.

C ce Recui ement Refer to :aragraca :::.A.2,

.fcensee ? asis for Tecues-inc 7el"e#

ce :yclec :ur ng :cwer :cerat":n i

hesa /ai/es : anno:

sinca " cw is neecec it ti:

imes to :ne 3: :ank leakage

clers.

This ::ci3 ~.he 31 OneCX Vii Ve ' eaK-o f' Ind OP? vents Camage :3 Ine 3'/C3 Pesins.

. Evaluatien In view f the neea to maintain Occling vatar to : ci

.r.e safety injection leakage

.o arevent amage to :ne CVCS esins curing normal aceration Inc cold snut cwns. One

uar erly stroke requirement for :nese valves is f cracti-cal.

For :nis reason and One reasons set for n in section 3.3 below, we find tna: One are:osec relief -ecuest: are warrantad anc :nculd :e grantea.

5. Relief Recuest The licensee nas proposed to exercise tne felicwing Category A valves at refueling outages:

a.

HCV-438A Containment penetr nion M19

mconent cooling system isolation.

3.

HC'i-a383 Containment cenetration M19 ccmconent cooling system isolation.

c.

HCV-a38C Containment penetration M18 ccmconent cooling system isolation.

d.

HCV-4380 Containment penetration MIS component cooling system isolation.

Ccde Recuirement Refer to paragraph III. A.2.

Licensee 9 asis for Recuestina Relief Closing these valves during Ocwer operation would result in damage to the reactor coolant pump seals.

Evaluation In view of the need to maintain ccoling watar, turing normal coeration and :alc snut cwns, :o cool the reactor coolant puco seal 'vatar and luce oil to orevent damage to reactor coolant :umo seals unica nould rasalt in eactor c olant pump damage, the cuar erly stroke racuirt ent for these valves is imoractical. For this reason and the reasons set forth in section 3.3 belcw, we find tna; the crocosed relief racuests are warrantad Inc shcula be grantaa.

5. Sel'ef Tecues:

'he iicansee has Oracosea o exercisa :ne fol'cwing Ca:agery A /si/es 1: ::Ta :nu::cwns 2nd refueling autages:

a.

HCV-167A

entainmen :enetration 915

mocnent : o:ing ;ystem sci n ion.

ICV-1673

entainment :ene rn on 115 00moonent ::c:i ng systam scia:icn.

442 001

. c.

MCV-267C Cantainment genetration 911

mconent c: cling systam isciation.

d.

HCV-267C Containment enetration Mli c:moonent ::aling sjstam isolation.

C0ce Recuirement Refer to paragrach I:!.A.2.

Licensee Basis for Recuestina pelief Closing these valves would result in isolation of cooling to tne nuclear detector wells. This would result in exceeding the concrete tamcerature ucce.- limits of Technical Scecification 2.13.

Evaluation Since the interruption of coolant to the nuclear detactor well cooling units would result in the concreta exceeding its Tecnnical Specification uccer temcertture limit, the quarterly strcke requirement for these valves is imcractical.

For this reason and the reasons set forth in section 3.3 belcw, we find the proposed relief recuest is warranted and

~

snculd be granted.

7.

Relief Recuest For Category A valves HCV-2916, HCV-2936, HC7-2956, and HCV-2976, full-stroke exercising and leak testing will te done at refueling Outages.

Ocde Recuirement Refer to caragracn III. A.2.

Licensee Basis for Recuestinc c ldef e

Stroking these valves will crain -he accumulators.

Evaluation

'hese normally :10 sed vaives are :niy usec 'er craining inc 3"I'ng accumulatars.

~ hey eceive i safety inf ection sicnai a ::::e in ne event of 1 LCCA.

Stroxing,ne va' te vi'l : rain :ne accu-mulater.

Therefore, ne agree nat nese val"es Incuic nct :e e.xer-

ised :ur ng carmai aceraticn r : cia snu".:cwns.

-Or n;; -eason i

Inc 'or :ne reascns set fortn in secticr. 3.3 :eicw. ve #inc nat exerciting :ur'ng efueling Outages is,c: acta:

3.

. 3.

Conclusion for '/alves in 3.1 hroucn 3.7 The Category ' nlves listed in relief recuest: 3.1 tnrougn 3.'

are either ;:assive anc/or recuncan valves.

The cotimum :est interval for acerability testing aassive anc/cr redundant valves

vas determinec cy :ne staff using actual valve failure ra:e data and stancarc precabilistic tecnn cues, to be in :ne rsrce of d

three months to 27 months. I.efue'ing intervals, wnica have been croposed as the exercise interval for the valves in 3.1 :nrcugn 3.7, occui' every 12 to 18 months wnich is within the optimum range for operability testing of these valves.

Furthermore, the ASME Code, which recuires testing be done quarterly and onica has been ade::tec in 10 CFR 550.55a, also allcws testing at cold snutdcwns if cuarterly testing is imeractical. Cold : nut:cwns can cc:ur at interials up to refueling outages. Therefore, chan7ing the test inter /al frem quarterly to refueling does not differ signiff-cantly from :ne Code pernitted change fran quarterly to cold smitdcwn testing.

Basec on the consid'erations discussed above the staff concludes that the alternate testing frequencies procesed above will give the reascnacle assurance of valve operability intended By the Code and that the relief thus granted will not endanger life or property or the cormon defense and securi ty.

9.

Relief Recuest Die licensee has requested relief f Om stroking the following categcry A/E valve:

a.

S1 185 5: Accumulator fill 1:ne isola:ian Ccde ?ecuire m nt Refer to ;:aragracn IM.A.2.

Licensee Basis for Recuestinn Relie#

Tais vaive is used to isciate the fill line f0r *.ne safety inje-tion tanks (accu: lators).

The valve is locked closed and therefore, not subject to a stroke test.

-Eviiua.icn 7te tafety ' unction af nis taive 1: c form a leak limi tinc _

a r-i e r.

This valve is 1 con ainmen; iscla:icn va ve vnica is

!csec, i safety :cs:.icn, Inc act ecuirec o ::en o liti;a:a

ne consecuences :f an accicent or :afe'y :nu::cwn :ne ;iant.

here'ere, ne :ceracil e y ;f - it ;;1ve i: 'ncensecuent a: vi 7 egar ne Iafety 'unc:icn vn.cn 4- :e r'O r-s.

se : nc!;ce

a: the :uar ar y scr ke inc ::rc<e

"-e reasuremen: Ire rean mc-t Ies 0F Ca:CiV8 /aives. na: "ne "? cues ac aelie" vii' 1c:

^

encancer e

r :meer:y Or :he ::.=cn :e'enre inc recur'-" inc

~..T

~.ne 'eIief Incu *. 28 Jrantec.

'42 003

4 lO.

9I#a#

efj e '

• The licensee has requested relief for these valves frem the stroke requirement and the stroke time measurement requirement:

a.

HCV-1559B Containment cenetration M80 deminerali:ed water isolation.

b.

HCV-1559A Contain=ent penetration M80 demineralized water isolation, c.

HCV-1560A Contairment penetration M79 ceminerali:ed water isolation.

For quench tank.

d.

HCV-15608 Containmer* cenetration M79 demineralled water isolation.

For quencn tank.

Ccde Recuirement The exercising recuiremants are noted in paragract III.A.2.

The stroke time of all power coerated valves shall be measured to the nearest second or 10% of 'the maximum 2-allowable stroke t h e, whichever'is less, whenever such a

~

valve is full-stroke tested.

Licensee Basis for Recuestina Relief

~

Cycling these valves would decrease containment integ.-ity.

These valves are not required to be coened cu"ing power oceration.

DaT;stien

~~

~ ~~

The safety functior. of these valves are to form ieak limiting barriers. These valves are containtmnt isolation valves wnicn are closed, their safety position, and not required o open to mitigate the ccnsequences of an accident or to safely shutdown the plant. Therefore, the o;:erability of these valves is incon-secuential with regard c 'he safety function vnich they ter#0rm.

'ie concluce -ha: the war:erly s rcke anc stroke tire measurement are meaningiess for ascive vaives na: ne recuestac relief will act encancer life or crocer y ar ne :: mon :efense and security and -ha, the relief sncuic ce ;rintac.

442 084

'.1,

ielief 7ecues:

The licensee has requested relief for inis Jaive 'acm :ne stroke recuirement anc frca :ne strcKe time measurement recuirement:

a.

MCV-1749 Containment penetration M74 c:=oressed air isolation.

Coce Recuirement The exercising recuirements are noted in paragraco III. A.2.

The stroke time of all ::cwer acerated valves sna11 be measured to the nearest second or 10% of the.naximum allowacle stroke time, wnicnever is less, wnenever sucn a valve is 'ul'-stroke tested.

Licensee ? asis for Recuestinc Relief Cycling this valve during gewer operation could result in a breacn of containment integrity.

Cperating this valve could result in air leakage into the containment, contributing to excess pressure build-uo in the containment.

This valve is to remain closed during power cceration and is not required to cpen curing pcwer operation.

Evaluation The safety function of this valve is to form a leak limiting ba rrier.

This valve is a containment isolation valve wnich is closed, its safety at

' ion, and not required to ccen to mitigate the consequences of an accident or safely shutdown the 31 ant.

Therefore, the acerability of this valve is inconsecuential wi:n regard to the safety function wnich it ::erfcrms. We conclude that the uarterly stroke and st oke time measurement are meaning-

'ess for passive valves that the recuested relief will not encanger life, crocer y or the ccmmon defense anc security and tha: One re-lief snould be granted.

t, t 2 085 t

. C.

Catecery 3 /aives 1.

Pelief Recues:

The licensee has crocosed to exercise the following valves at refueling outages:

a.

LCV-101-1 Pressuri:er level control.

b.

LCV-101-2 Pressurizer level control.

Coce Recuirement Refer to paragracn !II.L 2.

Licensee Basis for Recuestina 7elief These valves cannot be cycled during cower coeration since they would isolate the CVCS letcown and cnarging and thereby cause pressure transients.

Evaluation Inasmuch as continuous operation of the letdown system is recuired to maintain the required water enemistry, and proper water inventory (i.e., interruption of the chargf ng

~_e or letdown flows of the CVCS during normal operation or cold shutdowns would introduce pressure transients to the primary system), the quarterly stroke requirement of Section XI for these valves is imoractical.

For this reason and the reasons set forth in section C.10 below, we find that the brotosed relief request is warranted and snculd be granted.

442 0 f%',

. 2.

Relief Recuest The licensee nas ;reccsed ta exercise the folicwing valves at :cid shutccwns and refueling outages:

a.

HCV-1385 Main feecwater isolation to tne steam generators, b.

HCV-1286 Main feedwater isolation to the staam generators Ccde Recuirement Refer to paragrapn ITi.A.2.

Iicensee Basis for Recues33na Relief These are tne main feedwater pipe isolation valves and cannot be cycled during power oceration. To do so would result in a reactor trip.

Evaluation We agree with the licensee that exercising these valves would trio the reactor and concur that the cuarterly strcke require. ment for these valves is ir.cractical. For this ressen and the reasons set forth in section C.10 beluw, we find that the proposed relief request is war-ranted and should be granted.

3.

Relief Recuest The licensee has proposed to exercise the folicwing valves at refueling outages:

a.

HCV-258 Concantrated oric acid gravity faec isolation.

b.

HCV-255 Cancentrated :oric acid gravity feed isolation.

Code Recuirement Refer :s caragracn '!:.A.2.

Licensee 3as's "or 7ecuestinc Relief These valves are ' act c:osed uring :cwer Oceration to 3revent : ncantratac :oric acic from :eing fac cir?ctiy ta ne :narging cumos anc sucsecuently in;ectac into the crimary loco.

4l 4 c7 bi n /

o

. Evaluation The stroking of these valves would : orate the crimary system by injecting concentratad :oric acid inrougn the gravity feed line.

Inasmucn as baration of the primary system during normal aceration would cause reactivity transients and possibly shutdcwn the plant anc curing cold shutdowns would delay start-uo, tne cuarterly stroxe

~

recuirement for these valves is imoractical.

For this reason and the reasons set forth in section C.10 below, we find that the proposed relief request is warranted and should be granted.

4 Relief leouest The licensee has proposed to exercise the following valve at refueling outages:

a.

HCV-263 Permitt direct feed of concentrataa boric acid solution to the cnarging pump suction header.

Code Reouirement Refer to paragrach III.A.2.

c lief Licensee Basis for Recuestinn e

This valve cannot be cycled during power oceration since that would result in emergency boration of the reactor coolant system. To prevent such boration, both boric acid pumps would have to be isolated. This is in conflict with Technical Specifications 2.2.(2)3. and d.

Evaluation The stroxing of this valve would borate tne primary system by injecting concentrated boric acid through the emergency baration line.

Inasmucn as : oration of the primary system during normal operation would cause reac*ivity transients and possibly shutdown the plant and during cold shutdowns would delay start-up, the quarterly stroke recuirement for these valves is imoractical. For tnis reason and the reasons set forth in section 0.10 beicw, we fina -hat the :rocosec relief is war *antad inc sncuic :e granted.

5. Re <ef Recuest he licensee 7as procosed to axercise :ne foilcwing salves at refueling Outages:

1.

HCV-244 Cantainment soray isciaticn.

3.

4C7-245 Can airmen sar2y isolation.

4U 088

.n

33-Code Recuirement Refer to paragraph III.A.2.

Licensee Basis for Recuestino Relief Cycling these valves could result in an inaaver'.ent containment spray.

Evaluation We agree with the licensee's basis and concur that the quarterly stroke recuirement is imoractical for these valves.

For this reason and for tne reascns set for:n in secticn C.10 belcw, we find that the procosed -e-lief request is warranted and snoula :e granted.

5.

Relief Recuest The licensee has proposed to exercise the following valves at cold shutdcwns and refueling outages:

a.

HCV-1387 A, 3 Isolation of steam generator cicwdown line.

~

b.

HCV-1388 A, B Isolation of steam ganarator blowdown line.

Code Recuirement Refer to paragraph III.A.2.

Licensee ? asis for Decuestino Felief These valves cannot be cycled during power coeration since to do 50 would stop stcam generator blowdown and disruDt the feedwater chemistry control.

Evaluation In view of the need to maintain proper feedwater chemistry control to prevent corrosion of steam generator tubes, the cuarterly stroke rsquirement for these valves is imoractical.

For tais reascn Ina tne reasons se for n in secticn C.10 teicw, we fina tna: :he creccsec re-lief -ecues is warranted and snculd be grantec.

14p7 ria IL Li r)

, 7.

Relief Recuest The licensee has prcoosed to exercise the foilowing Category 3 valves at cola snutccwns anc refueling outages:

a.

HC'/-2506A Containment penetration,63 v

blowdcwn sample line isolation.

b.

HC'/-25063 Containment penetration M63 blowdown sample line isolation.

c.

HC'/-2507A Containment penetration M49 blowcown sample line isolation.

d.

HC'/-2507B Containment penetration M49 blcwcown samole line iscaltian.

Cace Reouirement Refer to paragraon III,A,2,

~

Licensee 3 asis for Re9uestina Relief Cycling these valves would result in isolation of the steam generator blowdown sampling in violation of Technical Specification 2.9(1)d. Continuous steam generator blowdown must be maintained for prcper all-volatile chemistry control during power operation.

Evaluation In view of the need for maintaining continuous blowcown frem the steam generator for proper all-volatile enemistry control during power operation, and the fact that cycling these valves would isolate steam generator blowcewn samoling, a violation of Tecnnical Soecification 2.3(i)d, tne cuarterly strcka recuirement for :nese valves is impractical. For tnis reason and the reascns set fortn in section C.10 below, we find : hat the artposed relief request is warranted and should be granted.

3.

Relief Recuest The licensee nas arcoosed to exercise :ne following valves at :cic snutacwns anc refueling cutages:

w in staam neacer isolation.

a.

HC'/-iCaiA a

.ain steam neacer isolation.

W c.

mC'/-iCJEA Coce Recui ement Refer :o :aragra:n ::.A.I.

4t2 070 i

. Licensee Basis for Recuestine Relief Cycling these valves would trip the reactor.

Evaluation These valves are the ma'n steam isolation valves. We agree witn the licansee that exercising these valves would trip the reactor and that the quarterly stroke requirement for these valves is impractical.

For this reason and the reasons set forth in section C.10 :eicw, we find that the procosed relief request is e.rranted and should be granted.

9 Relief Recuest The licensee has proposed to exercise the folicwing valves at cold snutdowns and refueling outages:

a.

400 A, B, C, D Ccmponent cooling isolation to containment air cooling and filtering Unit VA-iA.

b.

401 A, B, C, D Component cooling isolation to containment air cooling and filtering Unit VA-18.

c.

402 A, B, C, O Component cooling isolation to containment air cooling and filtering Unit VA-SA d.

303 A, B, C, O Com,onent cooling iolation to containment air c:oling and filtering Unit VA-88.

Code Recuirement Refer to ::aragraon m. A,p.

Licensee Basis for Recuestina Reliaf Cycling these valves during pcwer coeration would disrupt the balanced coolant ficw to various neat exchangers.

Resultant tamcerature osciliations ::uia cause damage to some acui;: ment, carticular!y tne reactor c:alant ;uma seals.

~VaIUati0n d'e igree di~.h ~Me liCanSee'3 JaSiS Inc Concur Onat tne Oua narly 3M OKe recuirement for *.nese valves 's 'mor1CC-

iC3I, R0r INi! reasCn inc.ne reasCns Ie! 0rin in

'eC0i;n 3.!b OelCW,.ve #inc ~na!.r,e Or0CCsec 'elief "ecues! '3 varr3ntec ICC INCuic Oe JPin!2c.

442 091

al-IO. Canclusion for Valves C.1 Throuen C. 9 The Category 3 valves listed in relief reauests C.1 througn C. 9 are either passive and/or redundant valves. The ac imum est interval for Openbility testing passive and/or recundant valves was detemined by the staff using actual valve failure m:e data and standard Drobacilistic techniques, to be in :ne nnge af three montns to 27 months. Refueling intervais, wnica have been

rocoseo as the exercise interval for the valves in C.1 through C.3 cccur every 12 to 18 months wnica is within the optimum range for cperability testing of these valves.

Further ore, the ASME Code, wnich recuires testing be dcne cuarterly and wnich has been adcoted in 10 CR 550.5Ea, also allcws testing at cola shutdcwns if quarterly testing is imcractical. Cold snutdcwns can occur at intervals up to refueling outages. Therefore, changing the test interval from quarterly to refueling does not differ signifi-cantly frcm the Ccde ::ermitted change frcm cuarterly to cold shutdcwn testing.

Based on the consideraticns discussed above the staff concludes that the altarnate testing frecuencies proposed above will give the reasonaole assunnce of valve coerability intended by the Code and that the relief thus granted will not endanger life or procerty or the cerTnon defense and securi ty.

11 Relier Recuest The licensee has proposed to exercise the folicwing valve at refueling outages:

a.

LCV-218-2 Volume control tank level control.

Code Recuirament Refer to paragraph III.A.2.

Licensee's Basis for Recueltine Relief This valve cannot be cyclei during pcwer operation since it would isolate the CVCS letdown and charging. pressure transients could be expected.

Evaluatien Inasmucn as continuous coeration of he le:down system is recuired to maintain the recuired water :hemistry, anc procer water inventory (i.e., interrupticn of :ne charging 442 092

32-or letdown #1cws of the C'!CS during nomal operation or cold shutdowns would intrcduce pressure transients to :ne primary systam}, the quarterly stroke recuirement of Section XI for these valycs is imoractical.

An analysis by the staff of the effects of varying the testing interval for this valve frcm quarterly to refuelinc was ;er-Based on the present kncwledge and the assumptions for-ed.

ace with regard to the centributiens to the C'/CS system un-availability of certain ccmcenents in the C'/CS, the contribution of this valve to the total C'/CS unavailacility is not significant valve and testing at refueling frecuencies is adecuate to assuraBased o acerability.

concludes that the requested relief will not endanger life or procerQ f

or the ccanon defense and security and -hat sucn relief snculd be granted.

D.

atecory C Valves

1. Relief Recuest For Category C valves SI-207, SI-211, SI-215, and SI-219, full-stroke exercising will be done at refueling cutages.

O Recuirwent

-e Refer to paragrach III..A,.2._

Licensee Basis for Requestino Relief Cycling there valves would lower the watar levei in safety infecticn tanks (accumulators).

Evaluation Eaca of these caeck valves is one of tne two cneck valves in series that isolate the safety injection tanxs from the reactor coolant system. We agree that cycling Mese valves w uic lower the safety injection tank level, unica is uncesiracle during normal operation.

Furtnermore, it is our position that any safety-related valve anica could put the plant in an unsafe condition if failed should not be testad during nomal alant oceration.

Since all fcur safety injection tanxs must te avaiiacie in :ne event of 2 CCA, anc a f ailure of one of nese caecx ealves :cula rencer a safety injection tank inccerative, these vaives sncutc not ::e cyclec :uring nornal c::eration. : r ni reascn and the reascns set #crth in Sec fon 3.5 beicw3ve #ina :na:

ycling 3: -efueling cutages is adecua a and ha: :ne recuestac r?Mef :hcuid be ;rantad.

k k ")

QQ

/

. 2. Relief Recuest For Category C valves 5I-208, SI-212, SI-2'6, ana 5I-220 full-stroke exercising will be done at refueling cutages.

Coce Recuirement Refer to paragraph III.A.2.

. Licensee Basis for Recuestina Relief In order ta cycle these valves, cold water would have to be injected into the reactar coolant system.

Evaluation Each of tnese check valves is one of the 50 check valves in series that isolates the safety injection system (Hign Pressure Safety Injection (HPSI), L?SI, or SI tanks) frcm the raactor coolant system. We agree that to cycle these valves would recuire injecting cold water into the reactor coolant systen, which is undesiracle during power oceration because it will trip the reactor.

Furthermore, it is our position that any safety-related valve wnich could put the plant in an unsafe condition if failed should not be tested during nor.al plant operation. Since all four SI tanks must be available in the event of a LOCA, and a failure of one of these check valves ccild render an SI tank inoperative, these valves _ihculd not be cycled.during nornal acerition; For this_re_ason.nd the reasons set forth in Section 0.6 below, se find that cycling at refueling cutages is adecuate and that the recuested relief should be grantad.

3. ReTief Recuest For Category C valves SI-194, SI-195, SI-196, SI-197, SI-198, SI-199, SI-200, 5I-201, SI-202, SI-203, SI-20a, and SI-205, full-stroke exercising will ce cone at refueling cutages.

Coce Recuirement Refer to paragracn III. A.?.

Licensee Basis for 7ecuesting Oeifef In orcer to ycle inese valves (excact SI-197 and 5I-200),

aler atar cuia nave :s :e infectac 'nto the eactor coolant system.

7here are crains to ne ::ntainment sumo dcwnstream 3f valves SI-!97 anc SI-200, :ut :nen :ne licuic racicactive vasta system acuic nave to :e usec :n

ne varar in :ne succ aftar :ne :yc!ing :f inesa no sa nes.

442 094

~

a:-

Evaluation Each of these twelve cneck /alves is one of the two eneck valves in series that isolatas tne LPS! or HPSI from ne reactor coolant system.

We agree that eitner injecting water into the reactor coolant system or the cntainment is uncesiracle curing power coeration because it will trip the reactor anc, therefore, concluce that exercising

~

on a quarterly basis is impractical. For tnis reason and for the reasons set fortn in Section D.5 below, ne 'ina :na: exercising at refueling outages is adecuata and that the requestea relief snould be granted.

J.

Relief Recuest For Category C valves SI-139 ana SI-140, part-stro(e exercising will be cone every :nree months and full-stroke exercising will be done at refueling cutages.

Code Recuirement Refer to paragrapn III. A.2.

Licensee Basis for Recuestine Relief To fully open these check valves would recuire cumoing cooler water into the reactor coolant system.

The recir-culation 1% that are used for testing the LPSI and HPSI pumps are not large enough to allow enougn flow to fully open the check valves.

Evaluation These two check valves are in the discharp lines of the safety injection and refueling water tank and they prevent back flow :o this tank. We agree with the licensee that injecting cold water into the reactor coolant system during Ocwer acera-ion, as would resuit frcm full-stroking is undesireable and ae, therefore, conclude that full-streking on a quarterly basis is imoractical.

If either of these two valves should fail Oc open wnen needed, enough flow would be orovided through the other valve :r aitigate the conse-cuences of a LCCA. Apart frcm this fact, assurance of the acerability of these valves will be provided by the precosed cuarterly artial stroking.

or these reasons and the reasons set forth in Secticn 3.5

~

elcw, we #ind -hat the ecuestad relief shculd be grantac.

5 3elief Recuest Excluce Iatagory C nack valves SI-100, SI-iO2, 5I-103' 5I-ll3, 5!-115, SI-121, SI-129, SI-135, SI-143, and SI-I49 f om -he ASME Section XI hree- :enta exercising recuirement.

Instaad, valves SI-100 ana SI-1!3 vili :e

ar.-stroxec ouarterly, anc all tan valves.iii

e full stroxec at refueling cutages.

4 /} 2 0)b

. Code Recuiremer Refer to paragraph III.A.2.

Licensee Basis for Recuestino Relief In orcer to full-stroke these valves : fd water wculd nave to be injected into tne reactor coolant system.

Evaluation Valves SI-139, SI-143, SI-149 are on the containment spray pump discharge lines; SI-121 and SI-129 are on the LPSI pumo discharge lines; SI-iO2, SI-108, and 5I-115 are on the HPSI pumo discnarge lines; and SI-100 and SI-li3 are on the HPSI pump suction lines.

Testing the HPSI puros using the 3" recirculation lines to the safety injection and refueling water tanx allows valves SI-100 and SI-113 to be part-stroked.

However, the discnarge valves for all three set of pumps are downstream of the recirculaticn lines and cannot be part-stroked curing the pumo sini-flow test. The HPSI discharge check valves cannot be exercised without injecting cold water into the reactor coolant system. Such action curing pcwer operation would cause a reactor trip.

The c:ntainment spray p =o and LPSI pump discharge check valves cannot be exercfsea because these pu=ps cannot overcome primary system pressu*e.

Fcr these reasons and those set forth in Section 0.5 belcW We find that the licensee's proposed exercising or' these tan check valves is 3decuate to 3ssure their operability and that the' pr0:osed reif ef sncule' :ie innted.

5.

Conclusion for Valves in 0.1 'hmuch J.5 The Category C valves listed in relief request: 0.1 tnreugh J.5 are either passive and/or redundant valves. The cotimum tast interval for c erability testing passive and/or recundant valves are de:armined by the staff using actual vaive failure rate ca a ino standard crocabilistic techniques, to be in the range of three months to 27 months. Refueling interials, wnich have been crc:osed as the exercise interval for the valves in D.1 through 0.5 cccur every 12 to 18 mcnths wnich is within the optimum range for operability tasting of these valves.

rurther cre, the ASM5 Ccce, wnich recuires estinc be ::ne :uar ariv inc wnica has been adcored in 10 CFR 550.55a, lis5 alicws tastinc a':

001c snu-dcwns if quar arly tasting is imcractical. :cid snu:: Ons :an occur a-in:artais uo to refueling cutages.

,nere :re, :nancinc :ne intartai #r m cuar arly a refueling does no: :i'fer sicnifi-tas antly from -he Occe perni tad change f-:m :uar:ar!y :: ::ic inu :cwn asting.

?asec :n ne ::ncidentions ciscus ec accve the 3:sf' :enciuces na:

ne li:arna a :asting #recuencies :reccsec 1 cve ; vill -ive ne sasenacie issunnce of valve :cen61;ity intancec ay ne :cce anc

..a-ne relief nus ;nntac vill no: encanger l'fe ar ;recerty or :he : mm:n :afense inc

ecur :y.

3g9 Ugf/0 t i t-

36-

7. ?elier Recuest The licensee nas procesed to dele:a the #alicwing vaives frem

he testing requirements af Secticn.C:

a '; SI 175 00ntainment spray beacer isolation enecP valve b) SI 175 Containment spray header isc1ation check valve Code Recuirement Catecory C valves shall be exercised at leas: once every three months.

Licensee Basis for Racuestino Relief Relief is requested frem the testing requirements of Section :(I due to imoracticai tty because the system 1-asign does not pernit stroking the valves without spraying dcwn the containment /essal.

Not stroking the valves poses no safety imcact for the fc1:owing reasons:

(1) Adequate heat removal frem containment can be achieved during a Design Basi _s_ Accident (CBA) oy use of only onee (1) cantainment spray header and three (3) containment spray puros. Hence, only one (1), but not boti of the check valves is required to open.

(2) The containment air filtra tion and cool f-*

fully redundant to the mainment spray (3) The centair. rent air filtra-icn and 'ccoling.

.e en-tains redundant ccmcenents. During a CBA, suf# c.cnt iodine removal f: effectuated with 505 of the system acerating and suf#icient Oressure reduction ace:molis' 'd with any nree air coolers ocerating.

Evaluation We igree wita ne '.'censee's : asis anc ::ncur ra-ne testing

-ecui rement of Section.(I are 'mcractical for nese ic!;::.

Therefore, we Save cetarmined :na: :ne ;rc asec eife# uili 10: :ecrease the Ievel of Jian: Iafety Or encanger I'#e, O ra cer:7 Or ne : mmon cefense and recurity ana nus Incu c i

e ;rantac.

4. 4. 7 no7 U/

47-3.

Relief Recuest or Category C valves SI-159 and SI-150, reaues: -elief ' rem

~

exercising requirements.

Code Recuirament Refer to paragraph III.A.2.

Licensee Basis for Recuestino Relief In order to fully open these check valves, the containment ficar must be filled with water. Furthermore, these valves are in redundar.: lines; if either check valve fails to open in the re-circulation.: ode, there would be sufficient ficw :nrougn the other line to safely cool the rasctor.

Evaluation These cNeck valves, redundant to each other and independent, are physically located in the recirculation piping imediately dcwn-stream of the centainment sump and are used to block any direct ficw of emergency coolant from the refueling water storage tank to the containment sump. At least one of these valves must open _ ~

to provide for the long tem recirculation of spilled coolant from the sump to the reactor core folicwing a LCCA. ASME Code raquirements for the inservice testing of these valves were not in axistence at the time the plant was designed and constructed; therefore, no provisions had been made for in-service testing these valves. We agree that with the present piping arrangements it is iteractical to test these valves to ASME Code requiraments.

Mcwever, we have detemined, and the licensee has agreed, that these valves have a vital safety function and that ways be investi-gated by the licansee for per#cming operability tests of these val ves.

The licensee has proposed (Omana ?ublic power Of strict letter dated 12/3/78) that one of the foiicwing two approaches will be used at the next refueling cuttle to demonstrate the operability of these valves:

a) A mcdification aill be per#cr ec a permi: Jericcic

1. ~cw testing af these valves or b) SI-159 will :e -amoved, ins;ected and sstad.

The rasult:

of -his ins::ection can te asec c de: amine ne need ' r ins::ecting II-MO and :ne neec for fur ner inscections.

/d2

[] 0,

i * *-

/

48-The results of the inscection/ test will be sutnittac 00 :ne !!aff for review, alcng with rec =endations for future inscection anc testing as deemed accrocriate.

'4e car-ied out an investigation to determine if there exists any mechanism of failure wnica could, over an extended time ceriod sucn as tne interval to One nex refueling 'scneculec for recruary 192C) a-creposed ay the licensee, result in the failure of :ne neck valves to c::erate wnen required. Some obvicus mechanisms examined were scaie or crud builduo in the stagnant water within the line ultimately inhibiting or failing the check valves. Because of tne purity of the water the plant maintains and stainless steel construction of the line, these type failures do not accear precable. There were no other apoarent mechanisms of failure found other than :he expected random failures of the check valves.

An examination # Licensee Event Reports (SER's) pertaining to check valves, pern rmance of a failure mcde and effects analysis en the check vr.1ves to icentify parts failure mcdes and a visual examination of the instal led valves were made in pursuit of the data neaded to make the e sternination mentioned above.

Since there were no other aparent failure mechanisms found other chan the expected randem failures of the check valves, the staff has determined that the effect on safety of extending the test a

interval until the next refueling is insignificant and therefore canc!udes there is reasonable assurance that temcorary relief until the next refueling will not endanger life or property or the ccmon defense and security and that such relief should be granted.

7.

Relief Recuest The licensee has proposed to delete the folicwina valve f cm the testing recuirements of Section U :

~

a) CH-198 Charging line reverse #1cw : heck valve Coce lecuirement Category C valves shall be exercised at least cnce every three months.

Licensee Basis #0e Recuestinc Relief seiief is recuestec #5m asting recuirements Of Ieccion U due to 'moracticality because -he system was designec uitnaut 1 methcc #cr ver4fying ne :Osition Of the Onec< valve.

' lot veri-fying :ne stroking af nis valve cases no 3afety :r cism :ecause this systam is designea o inject :cra:ac na:er, ' i n i m.m f wo curs :cs:-_:CA, nraugn -hi: vaive.

After :na: cer CC, :ne 'unc :an d

f :ni: tai re is to : lose so is o aiccx :acx-:saxage.

cwev

~

-.-g

ne : nta" ament 3res:ure vil' have :ecreasec encugn :na- -- :er, :v Se c ;

,c; e2 2 ;n - can:.eakage Ca h.

442 099

T 29-Evaluatien

'ie agree with the ifcensee's basis and concur that tne testing recuirements of Section XI are imcractical for :nis valve.

de finc tha: the Orc;osed relief sill not decrease tne level af

ant safety or endanger life or procerty cr the comren defense ard_ security and thus should be grantec.

I't. Summary - Inservice Ins action and Testina The licensee has submitted information to succort his determinations th certain ASME Section XI Code (1974 Edition through Summer 1975) recuire-We have evaluated the licensee's bases for nis determination relief from the s:ecific Ccce requirements recuested may be granted except that for cuartariy tas:1ng of Cum:s, recuest II.A.2.

We lave also granted tr.teria 91ief foe the exercising requirements for valves SI-159 and SI-160,

.0. 3, for tha reasons given in the evaluation. 3ased en *"e recues:

foregoing, we find that the relief requested is authori:ed by law, wi.1 not endanger life or property or the common defense and security and is in the ;ublic interest considering the burden on the licensee that could result if the relief were not granted.

Program meets the requirements of 10 CFR 50.'55a(g).We conclude Invironmental Consideration We have determined that this amendment does not authorize a change in effluent types or total amounts nrr an increase in pcwer level and will not result in any significant environmental imcact.

Having made this determination, we have fur:her concluded thar the amencment involves an acticn *nich is insicnificant frca the stand:cin of environmental inoact and, pursuant :: 10 CFR 151.5(d)(a), that an environmental ineact statement, or negative declaration anc environ-mental im:act accraisal neec not be precared in c:nnecti:n with tne issuance of his amencment.

~ rciusien We have concluded, based on the consicerations discussed above.,

(1) because :ne.amencment dces not involve a significant increase in

nat:

the probacility.or c:nsecuences cf accidents creviously : nsidered anc coes nct inve're a significan decrease in a safety margin, One amencment :ces nc. Invcive a sieni#ican: na: arcs ::nsicera:icn, (2;

nere is reascnacie assuranca 5a: :ne,eal:n anc safety of :ne :u lic

• ill no te encangerec :y : eration in :ne Orc csec manr,er, anc (3) sucn activities w1'l :e : ncuc:ac in ccm liaoca siin the ~;mnissitn's requiations anc :ne is:uanca Of inis amencment wiil no

e 'nin" cal

:ne ::m :n :afense anc securd:y Or :: ne nealin anc safety Of

ne :u::':.

a:ac: July 2, 1:.73 1kp?

PA iL i VU