A07250, Forwards Addl Info Re Third 10-yr Interval Inservice Testing Program,Per NRC 880511 Request.Revised Third 10-yr Inservice Testing Program Will Be Submitted by 880901

Forwards Addl Info Re Third 10-yr Interval Inservice Testing Program,Per NRC 880511 Request.Revised Third 10-yr Inservice Testing Program Will Be Submitted by 880901

ML20195H726
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/20/1988
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
A07250, A7250, B12952, TAC-65687, NUDOCS 8806280364
Download: ML20195H726 (23)

Text

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O General Offices

• Selden Street, Berlin, Connecticut 9 EiY Es5 Nec**~ P.O. BOX 270 HARTFORD. CONNECTICUT oS1414270 k L J $.'U U N $."cc~.~m (20N 665-5000 June 20, 1983 Docket No. 50-213 A07250 B12952 Re: IST Program U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Reference:

A. B. Wang letter to E. J. Mroczka, "Request for Additional Information Regarding the Haddam Neck Plant Third Ten-Year Interval Inservice Testing Program for Pumps and Valves," dated May 11, 1988.

Gentlemen:

Haddam Neck Plant Additional Information Inservice Testina Proaram (TAC No. 65687)

By letter dated May 11, 1988 (Reference 1), the NRC Staff requested additional information regarding Connecticut Yankee Atomic Power Company's (CYAPC0) third ten-year interval Inservice Testing (IST) program for pumps and valves for the Haddam Neck Plant. Specifically, the Staff provided meeting notes from a January 13, 1988 working meeting at the Haddam Neck Plant on four items in the I pump program and on 32 items in the valve program.

The May 11, 1988 letter requests that CYAPCO:

1) provide a schedule for submitting the additional information required to resolve the open items in the meeting notes from the January 13, 1988 ineeting, and

2) inform the Staff of the date by which the revised third ten-year IST program would be submitted.

Regarding the second item above, CYAPCI' will submit the revision to the third ten-year interval IST program (Revision 1) by September 1, 1988.

Regarding the first item above, though several of the open items will be resolved by information provided with the revised IST program submittal (September 1, 1988), CYAPC0 hereby provides a response to each of the items (four pump questions, and 32 pump questions) of the January 13, 1988 meeting notes, t

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U.S. Nuclear Regulatory Comission i B12952/Page 2 June 20, 1988 If you have any questions, please contact us.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY 4- Zh E. J. fr6c'zka //

Seniot Vice Pretident cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant 1

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i Docket No. 50-213 A07250 B12952 ,

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j Attachment 1 Haddam Neck Plant i

) Questions and Responses on the Third Ten-Year Interval IST Program

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i June 1988

Attachment 1 B12952/Page 1 Ouestions and Resoonses on the Third Ten-Year Interval IST Proaram Pumos

1. Question:

The licensee's IST submittal states in part, "...shall be tested within 1 week after the plant is returned to steady state operation...". This is not consistent with ASME Section XI, IWP-3400 which requires testing within 1 week after the plant is returned to normal operation which by Section XI definition includes plant startup.

Resoonse:

CYAPC0's third ten-year interval IST program (Revision 1) will be revised to be consistent with the requirements of ASME Section XI, IWP-3400.

2. Question:

There are no test frequencies listed in Table IWP-1 as stated in Section 2.5.2 of the program.

Response

CYAPC0 will revise Table IWP-1 of the third ten-year interval IST program (Revision 1) to include the test frequencies as stated in Section 2.5.2 of the program.

3. Question:

Where are the test methods of measurement and test durations defined?

Resoonse:

The test method of measurement and test duration are addressed in Connecticut Yankee test procedures SUR 5.7-19, inservice Inspection Pump Surveillance, Revision 9 and SUR 5.7-10, Inservice Inspection Pump Analysis and Documentation, Revision 10.

4. Question:

Pump RR2 asks for relief from differential pressure measurement in the Test Requirement section, however, the basis for relief section asks for relief from inlet pressure measurement.

Buppgyt:

CYAPC0 will amend relief request #2 of the third ten-year interval IST program (Revision 1) to be consistent with the request for relief from inlet pressure measurement.

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Attachment 1 812952/Page 2 Valves  ;

1. Question:

Are there any Category D valves at the facility? ,

Resoonse:

ASME Section XI defines Category D valves as Class 1, 2 and 3 valves which are actuated by an energy source capabis of only one operation, such as rupture disks or explosively actuated valves. Also, only rupture '

disks of testable design require testing. CYAPC0 has no Class 1, 2 or 3 rupture disks or explosively actuated valves.

2. Question:

P The licensee's submittal in Section 2.3.3 states in part, "...shall be tested to extent necessary to demonstrate that the performance parameters which could have been affected are within acceptable limits...." Section XI specifies that testing be performed prior to returning the valve to service.

Resoonse:

CYAPC0 will amend the third ten year interval IST program Section 2.3.3 to the following:

"Valver, or their control systems which are replaced, repaired, or have undergone maintenance which could affect thair operation shall be tested to the extent necessary to demonstrate that the performance parameters which could have been affected are within acceptable limits prior to returning to service."

3. QMattian:

The licensee has not established limiting values (for determining the need for corrective action in accordance with Section XI, IWV-3417(b))

for the opening and closing times of all power operated valves in the program.

Resoonse:  ;

Limiting values for determining corrective action are being established for Class 1, 2, and 3 power operated valves by following the guidelines of ANSI /ASME OM-10. CYAPCO is incorporating the limiting values in the

Inservice Testing (IST) procedures as part of the current station procedures upgrade program which is scheduled for completion by December 1989.

4. Question:

Does the licensee test all Air Operated Valves (A0Vs) in the fail safe position by observing operation of the valve upon loss of actuator power?

i If not, provide justification in the form of RR's for each valve not

Attachment 1 B12952/Page 3 tested. The licensee must also change the program to list all tests required by Section XI in the "test required column" and then submit RR's to justify why some tests are not performed.

I Response:

CYAPC0 tests each Class 1, 2 and 3 Air Operated Valve in the fail safe i position by observing operation of the valve upon loss of actuator power.

The IST Prog:am "Test Required Column" will be amended to include Fail Safe Tests.

5. Qw.11qn: ,

Are all containment isolation valves (CIVs) local leak rate tested?

Resoonse:

CYAPC0 has identified two containment isolation valves (CH-CV-399 and l SI-V 860) that are not local leak rye tested. However, these valves have been granted temporary relief. All other CIVs are local leak i rate tested in accordance with the IST program.

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6. Question:

The licensee's submittal in Section 2.3.7 states in part, "

... exercised within 30 days of returning the system to service...", however, ,

l Section XI states in part " ... within 30 days prior to return to '

l service...".

I Response:

1 CYAPC0 will amend the Third Ten-Year Interval IST Program Section 2.3.7  ;

j to the following: l

, "Valves in systems that have been declared inoperable or are not required l to be operable do not need to be exercised in accordance with the normal schedule. These valves, however, must be exercised within 30 days prior l to return to service and the test schedule resumed as required by  ;

l paragraph IWV-3416 of ASME Section XI." l

7. Question:

How are corrective actions controlled for power operated and check

valves?

CYAPCO provided procedure ENG 1.7 55 which was then reviewed by the staff. The staff determined that the procedure did not (a) address evaluation and corrective act.on for check valves, (b) :pecify "monthly" (1) See the D. M. Crutchfield letter to E. J. Mroczka, "Exemption fr am Certain Requiremonts of ,10CFR50, Appendix J," dated September 29, 1987.

Attachment 1 B12952/Page a ac the inco sed frequency In Section 6.2.1, and (c) specify "doubled" as j the increase in "requentf 'n note Ia.

Response

CYAPC0 will amend ENG 1.7 55 (Attachment 3) incorporating the evaluation and corrective action for check valves and specify "monthly" as the increased frequency in Section 6.7.1 and "doubled" as the increase in frequency note Ia. The revision to ENG 1.755 will be made as part of the

, current station procedures upgrade orogram. ENG 1.7-55 is scheduled for completion by April 15, 1989.

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How are expanded frequencies and corrective actions controlled for re'ief and safety valves?

gang:

The CYAPC0 Maintenance Depar+ ment controls the test procedure and corrective action in accordance with ASME Section XI IWV 3512 and 3514 respectively. W test procedure and correctivo action is administered through procedcas SUR 5.1-1, 5.2 2, and 5.5-28. IST Engineering centrols the test frequency and additional tests (i.e., expanded frequenciat) in accordance with IWV 3511 and 3513 respectively. A revision to ENG 1.7 55 (Attachment 3) will be made in:orporating the requirements of IWV 3511 and 3513 as part of tha current station precedures upgrade program schedule.

9. Question:

Were any valves added or dropped fres the program due to modifications 4

made during the 1087 cutage?

Rescanse:

W fes were added and deleted from the program due to modifications during the 1%7 outage. CYAPCO will amend the inird ten-year interval IST program ...aorporating the changes in Revision 1 of the program.

10. ouestion:

How are the analysis of leakage rates and corrective actions, for leek rates exceeding specified values, controlled to meet the requirements of Section XI, IWV 3426 and 3427.

Resoonsq:

Analysis of leakage rates and corrective actions for specific valves are controlled thrcNqh indivioual IST procedures and administratively controlled through procedure ENG 1.7-55 (Attachment 3). CYAPC0 will review the program, and if necessary amend ENG 1.7-55 to bo conshtent with Section XI requirements. Procedure ENG 1.7-55 will be amended by April 15, 1989, i

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Attachment 1 B12952/Page 5

11. Question:

Valves SI-MOV-24, RH-MOV-874, RH-FCV-796, RH-FCV-602 and SW-V -271 A, B, C, 0 are listed on noth the tested and not subject to testing tables.

Which is correct?

Resocnse:

Valves SW-V-271 A, B, C and D are not tested and are correctly listed in Table IWV-3 of the Third Ten-Year IST Program. SW-CV-271 A, B, C and D are tested and are correctly listed in Table IWV-1. Valves SI-MOV-24 and RH-M0V-874 are tested and will remain in Table IWV-1. RH-FCV-796 and RH-FCV-602 will be removed from Table IWV-1. SI-H0V-24 and RH-M0V-874 will be removed from Table IWV-3. This change will be reflected in the Third Ten-Year Interval IST Program (Revision 1).

12. !hteilign:

Why was the category of RC-CV-509, 523, 536 and 545 changed from B to C?

Were these valves tested during the 1987 outage?

Respong :

RC-CV-509, 523, 536 and 545 are check valves and are therefore Category C type. These valves were tested during the 1987 outage. Note 5 will be removed from Table IWV-1 in the .hird Ten-Year 14 erval IST Program (Revision 1).

13. Question:

Why was the category of valves CA-CV-823, 826 changed from C to AC?

Response

Valves CA-CV-825 and 826 were always category AC and the previous classification was a typographical error. The correction will be incorporated in the Third Ten-Year Interval IST Program (Revision 1).

14. Question:

Is the RR for position indication for valves SI MOV-871A, B correct in Table IWV-1?

Resoonse:

The relief request is not for position indication for valves SI-MOV-871A and B. The relief request is for leak tett requirements and will be corrected in Table IWV-1 of the Third Ten-Year Interval IST Program (Revision 1).

15. Question:

Please provide the normal position, the required safety position and the l procedures used for operability testing for all check valves in the program.

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Attachment 1 1 B12952/Page 6 '

Resoonse:

See Attachment 2  !

16. QugLtigft: l Is DH-MOV-310 tested even though it is listeci as passive in the remarks section?

Resoonse:

Valve DH-MOV-310 is tested even though it is normally closed and its safety function is to close.

17. Question:

Is DH-V-311 tested even though it is listed as passive in the remarks )

section? '

Response

Valve DH-V-311 is not operability tested and it will be deleted from '

Table IWV-1. I

18. Question:

Why is there no stroke time (MT) or fail safe (FT) testing specified for valves BD-TV-1312-1, 2, 3, 4? j 1

Response: i CYAPC0 will provide the stroke time and fail safe testing information in the Third Ten-Year Interval IST Program (Revision 1).

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19. Question:

Please provide missing information for valves SW-TV-2365A, B; SW-A0V-738A, B; and CC-RV-763A, B in Table IWV-1.

Response

CYAPC0 will provide the information in the Third Ten-Year Interval IST Program (Revision 1).

20. Question:

Why is there no MT listed for CC-TV-1411 :nd CH-TV-3347

Response

4 CYAPC0 will provide the information in the Third Ten-Year Interval IST Program (Revision 1).

21. Question:

Why was valve RH-MOV-31 changed from Quarterly to Cold Shutdown? Where is the justification?

Attachment 1 812952/Page 7 Resoonse:

Valve RH-MOV-31 testing frequency will be changed to Refueling.

Justification for this change will be provided in the Third Ten-Year Interval IST Program (Revision 1).

22. Question:

Where is the justification for each CIV tested at Cold Shutdown rather than Quarterly?

Response

CYAPC0 will provide individual justification as to why each CIV is tested at cold shutdown rather than Quarterly in the Third Ten-Year Interval IST Program (Revision 1).

23. Quercion:

Are valves PW-CV-139 and FH-CV-296 leak tested? What happened to the RR's for operability and leak testing which were in the second ten year interval program?

Resoonse:

Valve PW-CV-139 and FH-CV-296 are leak tested as Containment Isolation Valves (CIVs). A relief request for leak testing these valves is not required since we comply with ASME Section XI in that we perform leak tests at least every two years. An operability relief request with justification will be submitted with the Third Ten-Year Interval IST Program (Revision 1).

24. Question:

Are MT and FT tests performed on valves SS-S0V-150A, B, t, D and SS-S0V-151A, B, C, D?

Resoonse:

CYAPC0 will provide this information in the Third Ten-Year Interval IST Program (Revision 1).

25. Question:

Why were valves BD-TV-1312-1, 2, 3, 4; BD-V-506, 515, 522, 529; and FW-CV-192, 194, 196, 198 dropped from the program? The licensee was informed that components cannot be dropped from the program without prior approval by the NRC.

BLsoonse:

CYAPC0 will list the subject vahes in the revised IST program and provide justification for why the valves were deleted from the program.

Attachment 1 B12952/Page 8

26. Question:

Where are the RRs listed in Table IWV-2 from valve DH-RV-1847 to the end of the table?

Resoonse:

The relief requests for operability testing will be included in the Third Ten-Year Interval IST Program (Revision 1).

27. Question: -

Why is there a quarterly test requirement listed for manual valve SI-V-860? Should the valve be listed as locked closed?

Response

Valve SI-V-860 is not tested and it should be listed as locked closed.

These changes will be incorporated in the Third Ten-Year Interval IST Program (Revision 1).

28. Question:

Why are valves CH-CV-305A, B, C, D Integrated Leak Rate Tested (ILRT) instead of Local Leak Rate Te-ted (LLRT)?

Resoonse:

The valves are local leak tested and the corrections will be incorporated in the Third Ten-Year Interval IST Program (Revision 1).

29. Question:

Why were valves VH-V-588; PU-V-242A, BV-1-1A, B; HCV-1101; CC-V-884, VH-V-522, 525; RH-M0V-31; SI-V-860; WG-V-984A; SS-SOV-150A, B, C, D; SS-SOV-151A, B, C, D SS-V-998A AND HC-V-220B dropped from Table IWV-3?

Are they in another Table?

Response

Valve SS-V998A was a typographical error previously listed in Table 3.

CYAPC0 corrected the valve number (SS-V-999A) and listed it in Table 2 as a CIV. All other subject valves are CIVs that are now listed ii Table 2 of the program under "Containment Isolation Valves". These cht.nges will be reflected in the Third Ten-Year Interval IST Program (Revision 1).

30. Question:

Should CH-H0V-292 be locked open?

Resoonse:

CYAPC0 will evaluate the requirements for this valve and provide the information in the Third Ten-Year Interval IST Program (Revision 1).

l l Attachment 1 l B12952/Page 9 l l

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31. Questions: '

What function does valve CC-CV-802 perform? Why is it listed as passive?

Why are there no tests required?

Response

Check Valve CC-CV 802 isolates the Component Cooling Water Surge Tank Relief line from the containment sump to RHR suction line. The line penetrates containment (P-75). The test required for this valve is a local leak test and operability test. The valve is normally closed and its safety function is An exemption to Type C water test this valve was granted.(g go closed.

CYAPC0 will incorporate the information listed above and the relief request justification in the Third Ten-Year Interval IST Program (Revision 1).

32. Question:

Why was LD-RV-205 dropped from the program?

Resoonse:

CYAPC0 will list LD-RV-205 in the revised IST program submittal and provide justification for deleting this valve from the program.

(2) See the D. M. Crutchfield letter to E. J. Hroczka, Exemption froni Certain Requirements of 10CFR50, Appendix J", dated September 29, 1987.

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Docket No. 50-213 A07250 B12952 l

l Attachment 2 Haddam Neck Plant IST Program Check Valves i Position and Operability Test Procedures Infonnation l l

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June 1988

Attachment 2 B12952/Page 1 Normal Safety. Surveillance Valve # Position Position Procedure FW-CV-143-1 Open Open 5.7-22 FW-CV-143-2 Open Open 5.7-22 FW-CV-143-3 Open Open 5.7-22 FW-CV-143-4 Open Open 5.7-22 FW-CV-153 Closed Open 5.7-103 FW-CV-182 Closed Open 5.7-103 N-CV-184 Closed Open S.7-103 W f-156-1 Closed Open 5.7-96 F t'- CV- 156 - 2 Closed Open 5.7.-96 FW-CV-156-3 Closed Open 5.7-96 FW-CV-156-4 Closed Open 5.7-96 RC-CV-509 Closed Open 5.7-130 RC-CV-523 Closed Open 5.7-130 RC-CV-536 Closed Open 5.7-130 RC-CV-545 Closed Open 5.7-130 CA-CV-825 Closed Close 5.7-112 CA-CV-826 Closed Close 5.7-112 SI-CV-103 Closed Open 5.7-135 SI-CV-107A Closed Open/ Closed 5.7-135 SI-CV-107B Closed Oper,/ Closed 5.7-135 i SI-CV-856A Closed Open/ Closed 5.7-135 1 SI-CV-8568 Closed Open/ Closed 5.7-135 )

SI-CV-862A Closed Open/ Closed 5.7-65 j SI-CV-862B Closed Open/ Closed 5.7-65 SI-CV-862C Closed Open/ Closed 5.7-65 l SI-CV-862D Closed Open/ Closed 5.7-65 SI-CV-872A Closed Open 5.7-111 SI-CV-872B Closed Open 5.7-111 RH-CV-783 Closed Open 5.7-5 RH-CV-788A Closed Open/ Closed 5.7-71 RH-CV-7882 Closed Open/ Closed 5.7-71 RH-CV-808A Closed Open 5.7-5 CH-CV-263 Open Open/ Closed 5.1-4 CH-CV-272 Open Open/ Closed 5.1-4 CH-CV-293 Open Open 5.7-20 BA-CV-320 Closed Open 5.7-20 BA-CV-361 Closed Open/ Closed 5.7-69 BA-CV-370 Closed Open/ Closed 5.7-69 BA-CV-372 Closed Open 5.7-31 BA-CV-387 Closed Open 5.7-31 ,

FW-CV-135-1 Closed Close 5.7-129 i FW-CV-135-2 Closed Close 5.7-129 i FW-CV-135-3 Closed Close 5.7-129  !

FW-CV-135-4 Closed Close 5.7-129 SW-CV-276A Open Open/ Closed 5.7-89 SW-CV-276B Open Open/ Closed 5.7-89 SW-CV-276C Open Open/ Closed 5.7-89 SW-CV-276D Open Open/ Closed 5.7-89 SW-CV-271A Open Open 5.7-118 SW-CV-2718 Open Open 5.7-118 SW-CV-271C Open Open 5.7-118

Attachment 2 812952/Page 2 Normal Safety Surveillance Valve # Position Position Procedure SW-CV-271D Open open 5.7-118 SF-CV-812 Open Open/Close 5.7-30 SF-CV-812 Open Open/Close 5.7-30 CC-CV-885 Open Close 5.7-93 VS-CV-1103 Open Close 5.7-57 VS-CV-1104 Open Close 5.7-57 CC-CV-731 Closed Close 5.7-52 CC-CV-853 Open Close 5.7-39 PW-CV-139 Closed Close 5.7-78 FW-CV-140 Closed Close 5.7-78 FH-CV-296 Closed Open/ Closed 5.7-54 NG-CV-557 Closed Close 5.7-55 CH-CV-399 Open Open/ Closed 5.7-20 2 CH-CV-305A Open Open/ Closed 5.7-11e a 5.7-121 CH-CV-3058 Open Open/ Closed 5.7-116 & 5.7-121 CH-CV-305C Open Open/ Closed 5.7-116 & 5.7-121 CH-CV-305D Open Open/ Closed 5.7-116 & 5.7-121 NOTE 1: CYAPC0 will amend the IST Program to include the data listed above.

NOTE 2: Valve CH-CV-399 is verified opened by procedure SVR 5.7-20. The valve is not verified closed during ILRT. The relief request will be incorporated in the Third Ten-Year Interval IST Program (Revision 1).

Docket No. 50-213 A07250 B12952 Attachment 3 Haddam Neck Plant Engineering Procedure 1.7-55 (Revision 0) 4 l

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ENG 1.7-55 Original ENGQA3 APR 281987 n

1 T OPERATIONS REVIEW COMMITTEE APPROVAL Connecticut Yankee g Engineering Procedure 1.7 }(

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Documentation and Evaluation of Inservice Valves Testing ^

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1 p APPRO NT rNf errtenvr oATe < //

1.0 OBJECTIVE N h The objective of this procedure is to provide instruction for evaluating and documenting inservice valve test results.

2.0 APPLIC BILITY Inservice Inspection Engineering shall perfonn this procedure for all inservice testing of valves. These valves include those wilich are required to be tested Monthly, Quarterly, 6 month, Cold Shutdown, Refueling and Retest as required.

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3.0 REFERENCES

3.1 Technical Specification, Section 4.10, Inservice Inspection and Reactor Vessel Surveillance.

3.2 Technical Specification, Section 4.4, Containment Testing.

3.3 Technical Specification, Section 1.8, Containment Integrity.

3.4 Technical Specification, Section 3.14, Primary System Leakage.

3.5 Technical Specification, Section 4.3, Core Cooling System -Periodic

, Testing. l 3.6 Technical Specification, Section 4.9, Main Steam Isolation Valves..

3.7 Procedure ACP 1.0-24, Inservice Inspection Engineering Program.. I 3.8 ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWV.

3.9 Inservice Inspection Program: Class 1,2 and 3 Components, r

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, Original- APR 281987 ENGQA3 O

3.10 Procedure, ACP 1.2-11.3, Retests.

3.11 Prcuoure, ACP 1.2-11.2, Review of Test Data, 3.12 Procedure, ACP 1.2-15.1, Nonconformance Control.

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3.13 Procedure, ACP 1.2-16.1, Plant Infortnation Report.

3.14 Procedure, ACP 1.2-5.1, PMMS Trouble Reporting System and i Automated Work Order.

3.15 Unit Policy 11.0, Root Cause Evaluation Policy. )

' l 4.0 DEFINITIONS 4.1 Active valves - valves which are required to change position to accomplish a specific function.

4.2 Passive valves - valves which are not required to change position to accomplish a specific function.

l 4.3 IST Category A - valves for which seat leakage is limited to a l specific maximum amount in.the closed position for fulfillment of I their function. . I w

(g ,Uj 4.4 IST Category B - valves for which seat leakage in the closed position is inconsequential for fulfillment of their function.

4.5 IST Category C - valves which are self'-actuating in response to some system characteristic, such as pressure (relief valves) or flow direction (check valves).

4.6 Exercising - the demonstration based on direct or indirect visual or other positive indication that the moving parts of a valve function satisfactorily.

4.7 Inservice test - a special test procedure for obtaining

. information through measurement or observation to detennine

. the operational readiness of a valve.

4.8 Maintenar.ce - routine.. valve servicing or work on a valve undertaken to correct or prevent an abnormal or unsatisfactory condition.

4.9 Operational readiness - the capability of a valve to fulfill its fcaction.

4.10 Non-relevant Discrepancy - A discrepancy within ISI acceptance criteria for operability.

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4.11 Relevant Discrepancy - A discrepancy which does not meet the

. , .) ISI acceptance criteria for operability.

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1 ENG 1.7-55

. Original ENGQA3 APR 281987 O  :

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5.0 RESPONSIBILITIES Inservice Inspection Engineering shall be responsible for implementing the requirement 3 of this procedure.

6.0 INSTRUCTIONS 6.1 Test Review NOTE: Review Reference 3.11 "ACP 1.2-11.2 Review of Test Data". .

6.1.1 Ensure that the procedure test date is withift the required surveillance test interval.

6.1.2 Ensure that the procedure sections perfonned by the department performing the test have been completed.

6.2 Stroke Time Evaluation 6.2.1 Compare-the valve stroke times to the previous test.

If an increase in stroke time of 25 percent or more from the pervious test is observed for valves with full stroke times greater than 10 seconds, or of 50 3 percent or more for valves with full stroke times g>$) less than or equa.1 to 10 seconds, the following corrective action shall apply:

6.2.1.1 Tests frequency shall be increased until corrective action is taken or the valve is dispositioned as acceptable.

6.2.1.2 Valves tested at cold shutdown shall be evaluated for corrective action before

,- being returned to service.

6.2.2 Valves with stroke time which exceeds their ,

. spccified time limit shall be repaired / reworked or replaced.

6.2.3 Complete an ISI analysis sheet, per section 6.4, if a relevant or non relevant discrepancy is identified.

6.3 Leak Test Evaluation

• l 6.3.1 The measured leak rate of each valve'shall bs i compared to the leak rate limit in the surveillance '

test procedure.

6.3.1.1 Valves with leak rates exceeding their specified leak rate limit shall be C .- reworked / repaired or replaced.

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ENG 1.7-55

. . Original APR 281987 ENGQA3 O.

NOTE I: . Trending: For valves of 6 in, nominal size er larger,

a. If the leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between the measured leak rate and the maximum permissible leak rate by 50% or greater, the test frequency shall be increased. The test shall be scheduled to coincide with a cold shutdown until corrective action is taken or the valve is tfispositioned as acceptable, at which time the original test frequency shall

. be resumed,

b. If tests show leakage increasing with time, and a projection based on three or more tests indicate that the leakage rate of the next scheduled tes.t.will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be repaired or replaced.

g.g s 6.4 Analysis Sheet Instruction -

Qf*W~~ I NOTE 1: All relevant and non relevant discrepancies shall be evaluated per the analysis sheet.

NOTE 2: If a nonconforming condition based on the analysis of the data is identified, a Nonconformance Report shall be filed in accordance with ACP 1.2-15.1, Reference 3.12.

, '6 . 4 .1 ,- Identify the component to be evaluated.

6.4.2 Identify the documentation in which the

. component were ' inspected by. This shall include the date.

6.4.3 Provide a detailed description of the discrepancy.

6.4.4 The following items should.be included in determining the reason for the discrepancy, a) Verify validity of the data b) Review the test method c) Consult with test personnel d) Perform trend analysis 7 .i e) Review operation condition Q.9 f) Disassemble and inspect

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ENGQA3 Ap p g 7gg7

( 6.4.5- Identify action required to correct the discrepancy. This may include the following:

a) Rework b) Repair-c) Replace d) Redesign e) Other action may be identified.

NOTE 1: Imediate corrective action may be required to restore-system back,to within its acceptable limit, where long tenn corrective action may be required to prevent reoccurren,ce.

NOTE 2: Make sure action taken is consistent with reason for the discrepancy.

NOTE 3: There may be more then one corrective action or preventive action required to resolve the discrepancy.

6'. 4 . 6 Action Completed: i Prov'de status of all action completed.

6.4.7 Review and. provide disposition on the above g@: . ~

items to ensure that the problem has been addressed.

Preventive action if not corrective shall be documented here.

6.5 Report 6.5.1 Test Report.

The test report shall include the following as

/ applicable,

~

a) Valve teste'd

. b) Surveillance procedure <

c) Valve stroke time l d) Valve exercising result I e) Valve remote position indicator result I f) Valve fail safe result g) Test date h) As found and as. left. set pressure of safety and relief valves.

i) Leak test result 6.5.2 The following additional report may be necessary.

rj a) Trouble Report .

y b) Plant Infonnation Report c) Licensee Event Report -

., d) Nonconfortnance Report Page 5 of 7

ENG 1.7-55 kf $" ' .iAPR.2'81987 a

s-NOTE: Any such report shall be identified on analysis sheet.

6.5.3 Corrective Action Report The corrective Action Report shall' include the folTowirg as applicable.

a) 'ncrease test frequency NOTE: This may be done

. singular cases, .by memo for b) Identify corrective action performed to restore the system to oporability.

c) Corrective action complete or required to prevent recurrence.

6.6 Records ,

6.6.1 The ISI Analysis sheet, when completed, shall be attached. to the applicable documentation, c:s 7.0- FIGURES '

'+"

%5ft:- .

7.1 Figure (1) Inservice Inspec' tion analysis sheet.

8.0 ATTACHMENTS.

N/A 9.0 FOOTNOTES N/A ,-

t G[ " _. '

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. Original

,, 'ENGQA3 APR 28 iS87 FIGURE - (1-)

CONNECTICUT YANKEE ATOMIC POWER COMPANY /

INSERVICE INSPECTION ANALYSIS SHEET Components (6.4.1) Applicable Document: (6.4.2)

Discrecancy: (6.4.3)

Reason for Discrecancy: (6.4.4) fejy$h Q,'? ,

. Corrective Action: (6.4.5) Action Completed (6.4.6) l ISI Disposition: (6.4.7)

ISI Engineering -

Date: .

ISI Enginee' ring Date:

p. . i )

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