LIC-95-0120, Forwards Response to Anomalies Noted in SER for Third 10-yr Interval IST Program for Fcs,Ist Selection Philosophy & Rev 2 to ISI Program Plan for 1993-2003 Interval
| ML20085M001 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/21/1995 |
| From: | Tira Patterson OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20085M006 | List: |
| References | |
| LIC-95-0120, LIC-95-120, NUDOCS 9506280796 | |
| Download: ML20085M001 (34) | |
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Omaha Public Power District 444 South 16th Street Mall Ornaha. Nebraska 68102-2247 402/636-2000 June 21, 1995 LIC-95-0120 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk j Mail Station P1-137 Washington, DC 20555
References:
- 1. Docket No. 50-285
- 2. Letter from 0 PPD (T. L. Patterson) to NRC (Document Control Desk) dated November 13, 1992 (LIC-92-0320)
- 3. Letter from NRC (W. D. Beckner) to OPPD (T. L. Patterson) dated June 21, 1994 (TAC No. M84936)
- 4. Letter from OPPD (T. L. Patterson) to NRC (Document Control Desk) dated October 1, 1994 (LIC-94-0180)
SUBJECT:
Response to Anomalies Identified in the Safety Evaluation Report (SER) for the Third 10-Year Interval Inservice Testing (IST) Program for Fort Calhoun Station (FCS) l In Reference 3, the NRC provided the SER and associated Technical Evaluation Report (TER) identifying anomalies / inconsistencies with the third 10-year interval IST Program for FCS. The Omaha Public Power District (0 PPD) was j requested to respond to the NRC describing actions taken, actions in progress, or actions to be taken, to address each of the anomalies /incensistencies identified. In addition, the NRC requested that any IST Program changes involving any new or revised relief requests be submitted for staff review.
OPPD has completed its review of the SER/TER and is providing the attached responses to the anomalies / inconsistencies identified by the NRC in Reference 3 (see Attachment 1).
Attachment 2 "FCS Inservice Testing (IST) Selection Philosophy- is a description of the process used in determining and maintaining the IST Program, as requested I by the NRC in Reference 3. Most of the information in this attachment was l extracted from the FCS ISI Program Basis Document. }
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LIC-95-0120' l Page 2 l l
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In addition, OPPD has reviewed the following relief requests and has revised the FCS Inservice Inspection (ISI) Program Plan as noted:
- 1) Relief Request E3 for charging pumps has been withdrawn and OPPD 1 will comply with the " Operation and Maintenance of Nuclear Power i Plants Manual (0M)" 0M-6 requirements for pumps. ;
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- 2) Relief Request G1 for valves has been revised to clarify which i thermal relief valves will be excluded from the Program and is being j resubmitted for staff review. l
- 3) Relief Requests E1, E2 and E3 for valves have also been revised to ,
provide assurance that the provisions of Generic Letter (GL) 89-04 ,
Position 2 are met, as required. t
- 4) Relief Request E5 for valves has been deleted as the proposed alternative is in accordance with 0M-10 and the rulemaking of September 18, 1992 (as stated by the NRC in Reference 3).
- 5) Relief Request E6 for valves Las been revised and is being resubmitted for staff review. i Attachment 3 is a copy of the FCS ISI Program Plan, Revision 2. The ISI Program Plan contains revised or updated relief requests and frequency justifications as required to address anomalies / inconsistencies identified in the SER/TER. In ,
addition, Attachment 3, Enclosure A contains a summary of changes made to the FCS ISI Program Plan since Revision 0 (Reference 2).
If you should have any questions, please contact me.
Sincerely,
_f. I N, (il/ ~
T. L. Patterson l Division Manager 1 Nuclear Operations TLP/dll Attachments i
c: Winston and Strawn (w/out Attachments)
L. J. Callan, NRC Regional Administrator, Region IV l T. Y. Liu, NRC Acting Project Manager W. C. Walker, NRC Senior Resident Inspector i
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. . i LIC-95-0120 ATTACHMENT 1 INSERVICE TESTING PROGRAM ANOMALIES i j
l OPPD ACTIONS / RESPONSES I
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h ATTACHMENT 1 l
INSERVICE TESTING PROGRAM ANOMALIES l
& OPPD ACTIONS / RESPONSES l l
Anomalies or inconsistencies found in the NRC's Safety Evaluation Report i (SER)/ Technical Evaluation Report (TER) (Reference 3) are given below. These anomalies sumarize the NRC's concerns with the Inservice Testing (IST) Program j and require additional actions by OPPD for resolution. Each anomaly is followed by OPPD's action / response for resolution of the SER items.
SER Anomalv #1: ,
I The IST Program does not include a description of how the components were l selected and how testing requirements were identiffed for eaci component. }
The review performed for this Safety Evaluation (SE)/TER did not include ;
verification that all plaps and valves within the scope of 10CFR50.55a and '
Section XI are contained in the IST Program, and did not ensure that all appitcable testing requirements have been identified. Therefore, the ifcensee is requested to include this information in the IST Program. The Program should describe the development process, such as a ifsting of the documents used, the method of deterwining the selection of components, the .
basis for the testing required, the hasfs for categorfzing valves, and the method or process used for maintaining the Program current with design ;
modifications or other activities performed under 10CFR50.59.
OPPD Action / Response:
b Attachment 2, the " Fort Calhoun Station (FCS) Inservice Testing (IST)
Selection Philosophy" document is being supplied to the NRC to resolve -
this anomaly. This document provides the listing of documents used to i develop the IST Program, the method of determining the selection of '
components, basis for testing required, and the basis for categorizing valves. The Inservice Inspection (ISI) Coordinator is responsible for maintaining the IST Program current with design modifications and other activities performed under 10CFR50.59. This is accomplished through the i ISI Coordinator's reviews of modification packages and Engineering Change Notices (ECNs) prior to final acceptance of configuration changes by the plant. These reviews are controlled and required by various plant i administrative control documents.
SER Anomalv #2:
Punp Request E3 requests relief from the flow rate acceptance criteria for the charging pumps and proposes to not have an Alert Range for these pumps >
and to set the Required Action Range at <35 gpm and >40 gpa (refer to l Section 2.2.1.1 of this report). The proposed Required Action Ranges do not differ significantly from the Code ranges, however, the proposed
- Acceptable and Alert Ranges are non-conservative in comparison with the Code requirements. The ifcensee's justification supporting this deviation ,
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1 from the Code is that there is no afninum flow rate mentioned in the USAR for the charging psaps. However, the criteria of Table 3 are not based on speciffed systen operatianal requirements, they are hased on an amount af j pump degradation that causes concern about continued pump operational !
readiness. These Ifnf ts should not be ignored unless it can be shown that they may not be indicative of pump degradation that could increase the 1ikelthood af the pump not being capable of perfanning its safety function. Therefore, we reconnend that reifef be denied. l l
OPPD Action / Response.
l Pump Relief Request E3 for flow rate was deleted from the FCS ISI Program Plan (Attachment 3). OPPD will comply with the " Operation and Maintenance of Nuclear Power Plants Manual (0M)" OM-6 requirements for flow rate acceptance criteria for the charging pumps. i l
SER Anomalv #3:
Valve reifef requests E1, E2, and E3 deal with sanple disassembly of check valves (refer to Sections 3.2.1.1, 3.2.2.1, and-3.3.1.1 of this report).
OM-10 permits the use of disassembly of check valves to verify obturator movement as an alternative to exercfsing with flow or a mechanfcal l exerciser. However, when using this method, DN-10 requires disassembly of l each valve every refueling outage. GL 89-04, Position 2, permits the use l of a sampling program for identical valves in sinflar appifcations. GL l 89-04 also provides a mechanism for extending the valve disassembly !
interval in cases of extreme hardship. The ifcensee's basis supports '
extending the disassembly interval based on the low failure rate of these spectfic valves and sinflar valves in the nuclear industry. However, the criteria for extending the interval in GL 89-04 requires the ifcensee to l disassemble and inspect each valve in the group and to document in detail .
the valve condition and its capability of being full-stroke exercised.
The request indicated that each valve had been disassembled and found to be "If ke new". Stating that a valve is "Ilke new" may be a subjective evaluation unless supported by a quantitative assessment such as taking critical dinension measurements and conparing then with new valve haseline measurement data. The GL 89-04 interval extensfon criteria do not provide spect fic evaluation requirements (e.g., trending critical dimension )
nessurements), however, the ifcensee's evaluation should be adequate to ;
provide reasonable assurance that degradation is not occurring in the group valves at a rate that could result in a valve becoming incapable of perforning its function prior to the next exanination. The GL 89-04 interval extension criteria also require a review af the installation of each valve addressing the "EPRI Appiications Guidelines" for Check Valves in Nuclear Power Plants". It is not clear from the reifef request that this review has been performed and that the installation of these valves is satisfactory from that respect. l PAGE 2 0F 10 l
Disassembly and inspection is permitted by OM-10 and relief is granted to perform it on a sampling basis by GL 89-04, therefore, these valves may be disassembled and inspected every refueling outage on a sampling basis provided that it is performed in accordance with all of the provisions of GL 89-04. In addition, the disassembly interval may be extended if all of the interval extension criteria of GL 89-04, Position 2, are met.
Reifef is not granted for the above reifef requests for testing that deviates from that prescribed in GL 89-04, Position 2, unless the request specifically identifies otherwise. Whether the ifcensee compf fes with the provisions of GL 89-04 is subject to NRC inspection. If the ifcensee intends to deviate from a GL 89-04 position other than indicated in the current relief request, a revised reifef request must be submitted for review and approval prior to implementing the testing.
Some test method may be feasible to verify the full-stroke open capability of the affected valves in Ifeu of disassembly and inspection. The ifcensee should consider methods such as using non-intrusive techniques (e.g., acoustics, ultrasonics, magnetics, radiography, or thermography) to verify a full-stroke of these check valves. The ifcensee should perform their investigation and if a test method is found to be practicable, the IST requirements for these valves should be satisfied by testing instead of disassembly and inspection.
OPPD Action / Response:
Valve Relief Requests El, E2 and E3 have been revised in the FCS ISI Program Plan to clari fy the "like new" evaluation and to provide additional basis for extending the disassembly interval from one valve every refueling outage to one valve every other refueling outage. This extension is in accordance with Generic Letter (GL) 89-04, Position 2, and ensures that each valve is disassembled and inspected once every six (6) years.
SER Anomalv #4:
In valve relief requests E2 and E3 (refer to Sections 3.2.1.1 and 3.2.2.1 of this report), the licensee states, "the sample disassembly of these check valves is in accordance with the NRC guidelines estabitsbed in Generic letter 89-04, Attachment 1, Position 2, with the exception of partial-stroking." Position 2 states that "if possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly must be per formed. " Not performing part-stroke exercising in accordance with Paras. 4.2.1.2(b) and (d) is acceptable if the ifcensee identifies the technical basis that makes this testing impractical. However, the part-stroke exercise after reassembly required by Position 2 is to demonstrate that valve disassembly and reassembly has been performed in a manner that has not rendered the valve incapable of performing its function. This testing is to meet the post maintenance testing requirements of Para. 3.4.
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Not performing past maintenance testing to verify proper reassembly af these valves following their disassembly and inspection is unacceptable.
If a part-stroke exercise following reassembly is impractical, this should be identified in the Program and an alternate proposed that offers reasonable assurance of the valve's operational readiness following the maintenance procedure. The OM-10, Para. 3.4, must be met for the disassembly and inspection activity unless specific reifef is requested and approved.
OPPD Action / Response:
Valve Relief Requests E2 and E3 have been revised in the FCS ISI Program Plan (Attachment 3) to address the partial-stroke requirement for the disassembly and inspection activity as required by GL 89-04, Position 2.
In addition, the relief requests have been revised to include the OM-10, Paragraph 3.4 requirements.
SER Anomalv #5:
Valve Request G1 requests reifef from the scope of OM-1 for thermal relief valves on safety-related systems and proposes to control the testing of these valves under the preventive maintenance program (refer to Section 3.1.1.1 of this report). In the 1986 edition of Section XI, the Code committee increased the scope of the valves subject to IST to include those valves which protect certain Code-Class safety-related systems from overpressure. Thermal reifef valves installed to protect portions of safety-related systems against overpressure may be included in this expanded scope. The reifef valves that may be involved are those that meet the following criteria: a) they protect a portion of a safety-related system, b) the protected piping and/or component may be isolated during a plant operating mode where credit is taken for operation of the safety-related system, c) the protected section is subject to a mechanism that could overpressurize it when fsolated, and d) the integrity of the protected section (e.g., the absence of a rupture or stuck open reifef valve) is required for the system to meet its safety function. Because some of the thermal reifef valves at Fort Calhoun Station may be included in the expanded scope as discussed above, we recommend that general reifef not be granted as requested for all thermal reifef valves. The ifcensee should justify exclusion of those thermal reifef valves that do not protect portions of safety systems that may be isolated during a plant operating mode where credit is taken for operation of the safety-related system. Reifef valves that protect portions of safety-related systems that may be isolated during a plant operating mode where credit is taken for operation of the system should be included in the IST Program and tested to the Code requirements.
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~OPPD Action / Response:
Valve Relief Request G1 has been revised in the FCS ISI Program Plan (Attachment 3), to clarify which thermal relief valves will be excluded from the IST Program and the justification for not testing those relief valves in the IST Program. The criteria provided by the NRC in Reference 3, has been used in determining the justification for exclusion of the thennal relief valves as identified above and in the FCS ISI Program Plan (Attachment 3). As a result of this review / evaluation, 35 thermal relief valves have been removed from the FCS ISI Program Plan from a total number ;
of 120 relief valves. 1 SER Anomalv #6- !
1 Valve request E6 requests reifef from the test frequency requirements of M-1 for the auxiliary feedwater pump oil cooler reifef valve and proposes to test this valve every third refueling outage (refer to Section 3.4.1.1 of this report). Valve FW-1525 is the only one of its type and manufacturer, therefore, it forms a one valve sample group. M-1 requires a minimum of 207, of the valves of each type and manufacturer be tested within any 48 months. The current refueling outage frequency is 18 months, therefore, the minimum time between three refueling outages would be 54 months. The 54 month period is not significantly longer than the 48 month period, therefore, this extensfon may be acceptable depending on the failure and repair record of thfs valve.
Discussions with members of the Working Group on Safety and Relief Valves (M-1) indicate that the working group did not consider one valve groups when writing the Code. It is the impression of the working group members contacted, that the working group's intent is to have this type of valve tested at least once every ten years. The working group will meet on June 20 and 21, 1994, and will include this issue on their agenda. We reconnend that the alternative be authorized pursuant to 10CFR50.55a(a)(3)(f) until the M-1 Working Group clariffes this issue.
After the working group has clarifled thefr posf tion on thfs issue, the ifcensee should either modify or delete reifef request E6.
OPPD Action / Response:
On June 20,1994, the OM-1 subcomittee working group determined to leave the test frequency as stated presently in the Code (Reference OM-1 Committee Action Item 94-2-5). Therefore, based on the OM-1 Committee's decision, no modification to the original Relief Request E6 is necessary and OPPD is resubmitting the valve request E6 for FW-1525 relief valve to the NRC for approval (reference valve Relief Request E6 in Attachment 3).
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SER Anomalv #7:
Several of the Deferred Test Justifications (DTas) do not adequately demonstrate the impracticality of testing the subject valves quarterly during power operation or during cold shutdowns (if testing is deferred until refueling outages). 0M-10, Paragraphs 4.2.1.2 and 6.2(d), requires the owner to include the justifications for these deferrais in their test plans. These justifications should provide technical bases that show why testing more frequently is impracticable. These bases should explain the j negative consequences that may result if the valve is tested during power l operation or during cold shutdowns (if appifcable). Examples of negative l consequences of testing that adequately demonstrate impracticality are that the testing could cause equipment damage, represent a safety hazard to test personnel, or result in a significant power reduction or plant !
trip.
l J19 is an examle of where the justification does not identify a negative consequence that may make more frequent testing impracticable. The ifcensee states that testing would, "... expose the HPSI header to charging pressure at a time when this is not a desired charging flow path." The reader is left to determine if this could overpressurize the HPSI header, cause an operational problem, or result in some other negative i consequence. :
Other DTJs that do not provide adequate justifications for_not testing at power operation and/or during cold shutdowns are Ifsted below along with the frequency for which additional justification is needed. In some of these cases the reviewer can confidently postulate the negative consequences of performing testing during power operations and/or during .
cold shutdowns (as applicable). However, due to differences in plant design and operation, the reviewer should not have to make these assumptions, therefore, the pertinent information should be furnished by the ifcensee. This is not to suggest that the ifcensee should change the proposed testing frequency for the affected valves, although, upon further evaluation, the ifcensee may elect to change these frequencies as is justifled. These DTJs should be revised to adequately justify the ;
deferral of valve testing.
JS Cold Shutdowns J8 Cold Shutdowns J11 Quarterly and Cold Shutdowns ;
J21 Quarterly :
J29 Quarterly J35 Cold Shutdowns OPPD Action / Response: i (a) Justification J19 for valves HCV-308 and HCV-2988 has been deleted.
Valves HCV-308 and HCV-2988 will be tested quarterly in accordance ,
with 0M-10 requirements (see Attachment 3).
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(b) Justification J5 for check valves CH-143, CH-155 and CH-156, has been changed to reflect a Cold Shutdown testing frequency in accordance with the FCS ISI Program Plan (Attachment 3) administrative / implementing procedures. Check valves CH-143, CH-155 and CH-156, will be tested at a Cold Shutdown frequency in
[ accordance with the OM-10 requirements.
l (c) Justification J8 for valves HCV-176, HCV-177, HCV-178, HCV-179,
HCV-180 and HCV-181, has been changed to reflect a Cold Shutdown testing frequency in accordance with the FCS ISI Program Plan (Attachment 3) administrative / implementing procedures. Valves HCV-176, HCV-177, HCV-178, HCV-179, HCV-180 and HCV-181, will be tested at a Cold Shutdown frequency in accordance with the OM-10 requirements.
(d) Justification J11 for check valves SI-196, SI-199, SI-202, SI-205, SI-343 and CH-469, has been revised to provide a more detailed basis for not full-stroke exercising check valves SI-196, SI-199, SI-202 and SI-205 during Cold Shutdowns. In addition, justification has ,
been provided for not full-stroke exercising CH-469 Quarterly or at j Cold Shutdown. Check valve CH-469 will be partial-stroke exercised '
open during Cold Shutdowns. Check valve SI-343 cannot be partial-stroke exercised during Cold Shutdowns because using the High Pressure Safety Injection (HPSI) pumps could cause an over-pressurization of the RCS. The HPSI pumps are therefore tagged out to prevent inadvertent operation and potential overpressurization of the RCS. The justification J11 for check valves has been revised to provide further basis for justification of deferred test frequency in accordance with 0M-10 (see Attachment 3).
(e) Justification J21 for valves HCV-344, HCV-345, and check valve IA-HCV-344C provides a Cold Shutdown frequency justification for stroke testing / exercising these valves. These valves cannot be opened during plant operation since the potential for spraying down the J Containment due to an inadvertent containment spray pump actuation is greatly increased. Spraying down the Containment could cause equipment damage, electrical grounds and unnecessary corrosion /
equipment malfunctions (due to electrical shorts) and unnecessary plant trips. The small benefit gained from stroke testing /
exercising these valves is far outweighed by the potential hazard and risk of testing these valves quarterly with the containment spray in an " active" state. Valves HCV-344 and HCV-345, and check valve IA-HCV-344C will be tested / exercised during Cold Shutdowns in accordance with 0M-10 (see Attachment 3).
(f) Justification J29 for valves HCV-1387A, HCV-1387B, HCV-1388A and HCV-1388B was deleted upon further engineering evaluation. Valves HCV-1387A, HCV-13878, HCV-1388A and HCV-1388B will be tested Quarterly in accordance with OM-10 requirements (see Attachment 3).
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(g) Justification J35 for check valve CH-166 has been changed to a Cold .
Shutdown testing frequency in accordance with the FCS ISI Program l Plan administrative / implementing procedures. Check. valve CH-166 !
will be tested at a Cold Shutdown frequency in accordance with 0M-10 requirements. ;
SER Anomalv #8:
The Basis for Justification paragraphs in J25, J32, and J37 contain statements such as, "
... failure of these valves during testing would '
render...fnoperable". The objective of testing is to verify the operational readiness of safety related components. Testing can reduce the availability of these components, however, any reduction in '
availabfif ty may be more than offset by the increase in reliablif ty i afforded by the testing. If a conponent is in a degraded state that could l cause it to fal1 during testing, it may not be capable of performing its i safety function. It is far better to detect this degraded condition during testing than to have the conponent faf f when required to actuate to mitigate the consequences of an accident. These DTJs should be revised to '
adequately justify the deferral of valve testing or the valves should be ,
tested at a more frequent Code interval. '
OPPD Action / Response:
1 (a) Justification J25 for valves HCV-467A, HCV-467B, HCV-467C and HCV- !
467D has been deleted. Valves HCV-467A, HCV-467B, HCV-467C and HCV-467D will be tested Quarterly in accordance with OM-10 requirements i (see Attachment 3). l (b) Justification J32 for valve HCV-2987 and Instrument Air accumulator check valve IA-HCV-2987-C has been deleted. Valve HCV-2987 and check valve IA-HCV-2987-C will be tested Quarterly in accordance ,
with OM-10 requirements (see Attachment 3). !
(c) Justification J37 for valve HCV-474 has been deleted. Valve HCV-474 will be tested Quarterly in accordance with 0M-10 requirements (see Attachment 3). ;
SER Anomalv #9: j The Alternate Testing paragraphs in J6 and J13 indicate that the subject \
valves wf11 be tested during Cold Shutdowns. However, these paragraphs i include further restrictions on when the Ifsted valves can be tested '
(i.e., provided the feedwater system is able to be isointed from the steam generator and the feedwater 1ines are able to be drained). Because of i these provisions, these valves cannot be tested during many Cold Shutdowns. Therefore, these Cold Shutdown Justifications should be i changed to Refueling Outage Justifications and a more detailed l Justification demonstrating the impracticality of testing these valves 1 every Cold Shutdown should be included in the Basis for Justification. i 1
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OPPD Action / Response:
(a) Justification J6 for check valves FW-161 and FW-162 has been revised to reflect changes in the plant testing philosophy. The check valves FW-161 and FW-162 will be exercised closed at a frequency of Cold Shutdown in accordance with the FCS ISI Program Plan (Attachment 3) administrative / implementing procedures.
(b) Justification J13 for valves TCV-202 and HCV-204 has been revised to reflect changes in the plant testing philosophy. Valves TCV-202 and HCV-204 will be tested at a frequency of Cold Shutdown in accordance with the FCS ISI Program Plan (Attachment 3) administrative /
implementing procedures.
SER Anomalv #10:
J7 states "Since failure of these valves to function in the reverse flow direction would not interfere with the plant's abfif ty to shutdown or to mitigate the consequences of an accident, these check valves shall be full-stroke exercised only in the open direction." Excessive back leakage of hot feedwater through similar valves at other facilities can render the associated AfW train inoperable due to vapor binding of the AFW pump or by exceeding the design temperature rating of system piping. In addition, the Working Group on Check Valves (0M-22) and the NRC have taken the position that a check valve exercise test should involve verifying a valve in both the open and the closed positions. The ifcensee should respond to this concern.
OPPD Action / Response: l l
Justification J7 for check valves FW-163 and FW-164 has been revised to further justify 0 PPD's position of not requiring reverse flow exercising of these check valves. In summary, FW-163 and FW-164 are not the sole means of preventing excessive bac~kleakage to the discharge piping of the Auxiliary Feedwater (AFW) pumps as identified in the revised justification J7 (Attachment 3). As a result of other valves serving to prevent excessive backleakage to the AFW pumps (as identified in J7), check valves FW-163 and FW-164 do not provide a safety-related function in the closed direction. OPPD is presently evaluating the guidance provided in OM-22 3 for requiring check valves to be exercised both open and closed {
(regardless of the valve's safety position), to determine the safety benefit of the OM-22 guidance commensurate with cost. Valves FW-163 and ,
FW-164 will be exercised in the open direction only during Cold Shutdowns I in accordance with the FCS ISI Program Plan (Attachment 3) administrative / I implementing procedures. I PAGE 9 0F 10 1 _ - _ _ _ _ _ _ _ _ _ _
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- SER Anomalv #11:
The Alternate Testing of J11 does not address valves SI-196, SI-199, SI-202, and SI-205. What testing is performed on these valves? In addition, the Basis for Justification needs to be clarf fled and augmented. The first two sentences do not apply to valve CH-469, because flow can be established through it using the charging pumps. Therefore, there is no justification for not exercising CH-469 during power operation. The third sentence appifes only to valves SI-196, SI-199, SI-202, and SI-205. The basis should be clarifled to indicate that this sentence does not apply to valves SI-343 and CH-469. The last sentence appifes only to valve SI-343.
There does not appear to be a technical basis that demonstrates the impracticality of full-stroke exercising valves SI-196, SI-199, SI-202, and SI-205 during Cold Shutdowns. The ifcensee should respond to these concerns. ,
OPPD Action / Response:
OPPD has revised Justification J11 as required to address this SER anomaly. (See SER Anomaly 7(d) for OPPD's action / response to resolve this SERanomaly).
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LIC-95-0120 ATTACHMENT 2 FORT CALHOUN STATION INSERVICE TESTING (IST) SELECTION PHILOSOPHY l
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e ATTACHMENT 2 FORT CALHOUN STATION INSERVICE TESTING (IST) SELECTION PHILOSOPHY This document describes the philosophy used at the Fort Calhoun Station (FCS) to ,
develop and implement the IST Program. This is a guideline used by the Omaha ,
Public Power District (OPPD) in determining components to be tested, tests to be performed, test frequencies, acceptance criteria, etc., pertaining to the FCS IST Program. The FCS ISI Program Plan may in some cases deviate from this philosophy.
1.0 REFERENCES
A. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI 1989 Edition B. NRC Generic Letter (GL) 89-04 dated April 3,1989 ASME " Operation and Maintenance of Nuclear Power Plants Manual" 1987 C.
Edition, 1988 Addenda (0M)
D. Fort Calhoun Station ISI Program Plan E. Fort Calhoun Station ISI Basis Documents ;
F. Station Engineering Instructions SEI-11 " Trend Monitoring and Trend Analysis" and SEI-14 " Surveillance Testing" G. Production Engineering Division Quality Procedure PED-QP-33 " Inservice Inspection Program" H. Fort Calhoun Station Standing Orders (S0s):
- 1. S0-G-21 " Modification Control" ISI Coordinator reviews all modification packages prior to final acceptance, for compliance with the ISI Program Plan.
- 2. 50-G-23 " Surveillance Test Program" ISI Coordinator reviews all ISI related surveillance (3000 series) for compliance with the ISI Program Plan.
- 3. S0-G-30 "Setpoint/ Procedure Changes and Generation" ISI Coordinator reviews all ISI related surveillance test (3000 series) procedure changes for compliance with the ISI Program l Plan.
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I. USNRC NUREG 1482 " Guidelines for Inservice Testing at Nuclear Power Plants" J. Various meetings / correspondence with the NRC K. Various industry /NRC meetings / symposiums L. Previous inspections / plant experience 2.0 DEFINITIONS A. Active Valves Valves which are required to change obturator position to accomplish a specific function.
B. Passive Valves Valves which maintain obturator position and are not required to change obturator position to accomplish a specific function.
C. Valve Categories Category A - Valves for which seat leakage is limited to a specific ;
maximum amount in the closed position for fulfillment of '
their required function. 4 Category B - Valves for which seat leakage in the closed position is inconsequential for fulfillment of their required function.
Category C - Valves which are self-actuating in response to some system characteristics, such as pressure (relief valves) j or flow direction (check valves) for fulfillment of the {
required function (s). l l
Category D - Valves which are actuated by an energy source capable of only one operation, such as rupture disks or explosive-actuated valves.
D. Exercising l The demonstration based on direct or indirect visual or other positive indication that the moving parts of a valve function satisfactorily.
E. Operational Readiness The capability of a valve to fulfill its function.
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F. Pressure Isolation Valves (PIVs)
- 1. Two normally closed valves in series that isolate the Reactor Coolant System (RCS) from an attached low pressure system. PIVs are within the Reactor Coolant Pressure Boundary (RCPB).
- 2. Event V PIVs - Two check valves in series at a low pressure /RCS interface whose failure may result in a loss of coolant accident (LOCA) that bypasses containment.
G. Check Valve Full-Stroke A check valve's full-stroke to open position is verified by passing the maximum required accident condition flow through the valve. This is the maximum flow rate for which credit is-taken for this component in a safety analysis in any flow condition. The safety analyses are those contained in the FCS Updated Safety Analysis Report (USAR), or-equivalent, but are not limited to the accident and transient analyses.
In lieu of this testing methodology, alternatives or reliefs are also used such as:
- 1) Sample Disassembly
- 2) Safety Injection (SI) Tank Reduced Flow Test H. Check Valve Partial-Stroke Any flow rate less than " full-stroke" is a " partial-stroke."
- 1. Cold Shutdown Justification When it is not practical to perform a test at the Code required frequency of " Quarterly", acceptable technical justification shall be given in the ISI Program Plan and the test will then be performed at a frequency of " Cold Shutdown" in accordance with the requirements of the ASME Section XI/0M Codes.
J. Refueling Outage Justification When it is not practical to perform a test at the Code required frequencies of " Quarterly" or " Cold Shutdowns", acceptable technical justification shall be given in the ISI Program Plan and the test will then be performed at a frequency of." Refueling Outage" in accordance with the requirements of the ASME OM Manual.
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K. Relief Request.
When~ a Code requirement cannot be met and a deviation from the ,
criteria of the Code is necessary, a Relief Request ** shall be submitted to the NRC* prior to implementation of the deviation. !
- Pending guidance given in references B and I. }
- It should be noted that technical justification or data must be ;
submitted to support the relief request. " Stating without '
substantiation that a change will not affect the quality level is unsatisfactory (i.e.. because a licensee does not agree with a ,
Code requirement is on_t considered justification for the granting _
of relief)." This statement is also equally' applicable to " Cold Shutdown" or " Refueling Outage" frequency justifications.
L. IST Program
- 1. Interval - FCS ISI Program Plan complies with the requirements of Inspection Program B as defined in IWA-2420 of ASME Section XI.
The ISI Program Plan is divided into four intervals consisting of ,
ten years each. Prior to the beginning of each ' interval, a revised ISI Program Plan shall be submitted to the NRC for review -
and approval. The requirements of the' latest approved - ASME '
Section XI Code that is accepted by the NRC* within 12 months of the beginning of the upcoming interval shall be incorporated into the ISI Program Plan.
- Pending guidance given in references B and I. .
)
- 2. Period - Each interval consists of three periods of 40 months l each.
M. Rapid Acting Valve Power operated valves with normal stroke ' times (open or closed) of two seconds or less.
I N. Normal Plant Operation The conditions of startup, operation at power, ~ hot standby, and- !
reactor cooldown, as defined by the FCS Technical Specifications.
O. Reference Values / Baseline Data i
One or more values of test parameters measured or determined when the !
equipment is known to be operating acceptably. These values also have shown consistency.
4 0F 12 j
P. Instrument Accuracy The allowable inaccuracy of an instrument loop based on the square root of the sum of the squares of the inaccuracies of each instrument or component in the loop. (i.e., the tolerance of an instrument *2%
for flow and pressure; and 5% for vibration and temperature. In addition, FCS has established an upper tolerance limit of 15% for all instruments used to determine the operability of components in the ISI -
u Program Plan, whenever possible.)
Q. Instrument Loop Two or more. instruments or components working together to provide a single output (e.g., a vibration probe and its associated signal conditioning and readout devices).
R. Routine Servicing / Maintenance The performance of planned, preventive maintenance (e.g., replacing or adjusting valves, adjusting packing, adding packing rings, flushing the cooling system or mechanical seal maintenance or replacement,.
etc.) which does not require disassembly of the pump or' valve or-replacement of parts.
S. Valve Position Indication (VPI) Verification Valves with remote pc:ition indicators shall be observed locally in order to verify that the valve operation is accurately indicated.
Where practical, the local observations should be supplemented by other indications, such as use of flowmeter or other suitable instrumentation to verify obturatcr position. These observations need not be concurrent. Where local observation is not possible, other indication shall be used for verification of valve position / operation (e.g., for solenoid valves, use voltage / contact measurements). At FCS, the VPI verification is performed independent of the valve stroke time measurement and has a "once every two years" performance frequency.
T. Accident Any type of consequence or failure that could cause undue risk to the health and safety of the public. It should be noted that the term
" accident" as used by the NRC describes a broad range of possible adverse events at a nuclear power plant. Therefore, although most of the accidents of concern to IST are addressed in the accident analyses chapter (FCS USAR Chapter 14), be aware that there may be other accident analyses- to consider (e.g., complete loss of CCW).
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3.0- SELECTION CRITERIA FOR COMP 0NENTS TO BE TESTED A. Valves (including actuating and position indicating systems)
Selected active or passive Class 1, 2 or 3 valves (or valves important to safety) are ones which are required to perform a specific function in:
- 1. Shutting down the reactor to the Safe Shutdown condition.
- 2. Maintaining the reactor in a Safe Shutdown condition.
- 3. Mitigating the consequences of an accident (as described in 10CFR100 and stated in the FCS USAR).
B. Safety / Pressure Relief Devices (as defined by Article 2000 ASME Section III Subarticles NB, NC and ND)
- 1. Relief valves are tested in accordance with ANSI /ASME OM-1.
- 2. Safety or relief valves that are selected for testing under ASME XI are ones which protect systems or portions of systems which perform a required function in:
- a. Shutting down the reactor to the Safe Shutdown condition.
- b. Maintaining the reactor in a Safe Shutdown condition.
- c. Mitigating the consequences of an accident.
- 3. Do not test valves that protect a safety related component or safety related system when not required to operate during an ,
accident condition. I
- 4. Do not test valves whose only function is to provide thermal l relief. j C. Pumps (Positive Displacement and Centrifugal)
Selected centrifugal and positive displacement pumps are ones provided l with an emergency power source, which are required in. -
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- 1. Shutting down the reactor to the Safe Shutdown condition.
- 2. Maintaining the reactor in a Safe Shutdown condition.
I 3. Mitigating the consequences of an accident.
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4.0 EXCLUSIONS (COMPONENT NOT REOUIRING TESTING UNDER ASME XI)
A. Excluded Valves are:
J Valves that do not provide or are not Lrequired to perform a specific .:
safety function as described above, and l
- 1. ' Are used only for operating .. convenience such. as vent,- drain, instrument root 'and test valves; or, !
- 2. Are used only for systems' control, such as pressure regulating _ i valves; or,
- 3. Are used only for. system or component maintenance; or, .!
- 4. Are for external control and protection systems responsible for sensing plant conditions and providing signals for valve operation.
B. Excluded Pumps / Drivers are:
- 1. Drivers, except where the' pump and driver form an integral unit:
and the pump bearings are in the driver.
- 2. Class 1, 2 and 3 pumps that are: supplied with emergency power solely for operating convenience.
5.0 GENERAL TEST PHILOSOPHY - VALVE _S A. Manual Valves
- 1. Do not stroke time test.
- 2. Do not verify position indication (unless required).
- 3. May perform Appendix J or 0M Part 10 leak testing, if applicable.
B. Dampers
- 1. Do not stroke' test.
- 2. Do not verify position indication.
- 3. May perform Appendix J testing, if applicable.
- 4. Do not exercise.
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- 1. Test in direction that valve goes as a result of a safety signal if different than normal position.
- 2. Test in " fail" position if different than normal position or safety signal (tested by switch from Control Room).
- 3. Leak test valves if:
- a. Category A; or,
- b. Appendix J; or,
- c. Pressure Isolation Valve (PIV)
- 4. Stroke test valve closed, open or both as applicable:
- a. Time valve stroke from device actuation to end of valve travel (as indicated by lights). .
1
- b. Only stroke / time valves from Control Room. I
- c. Reference value (last three performances averaged) for most valves - established in 1990.
D. Check Valves
- 1. Test valve in directicn the yh x is required to travel in order to perform its safety function.
- 2. Full-stroke exercise valve in either the opened and closed directions as applicable " Quarterly." If not practical to perform full-stroke of the valve " Quarterly", as required, perform a partial-stroke " Quarterly", and full-stroke the valve at the first " Cold Shutdown" or " Refueling Outage" as able. If not able to perform either a partial or full-stroke of the valve, perform a sample disassembly and inspection of the valve in accordance with GL 89-04.
- 3. Exercise valve to close position and verify closed by:
- a. AP (pressure difference).
- b. Leakage.
- c. Other positive methods.
- 4. Perform leak test if required.
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E. Safety and Relief Valves
- 1. Test relief valves that "are protecting systems or portions of systems" which perform a required function in:
- a. Shutting down the reactor to the Safe Shutdown condition.
- b. Maintaining the reactor in a Safe Shutdown condition.
- c. Mitigating the consequences of an accident.
- 2. Perfonn setpoint pressure or " pop" tests in accordance with OM-1.
- 3. Perform reseat and seat leakage test per ASME OM-1.
- 4. Class 1 relief valves shall be tested once every five years:
- a. 33% of relief valves are tested every refueling outage.
- b. A minimum of 20% are tested every 24 months until 100% of the relief valves have been tested.
- 5. Class 2 and 3 relief valves shall be tested once every ten years after the initial test:
- a. 17% of relief valves are tested every refueling outage.
- b. A minimum of 20% are tested every 48 months until 100% of the relief valves have been tested.
6.0 GENERAL TEST PHILOS 0$Y - PUMPS A. Centrifugal
- 1. Perform operational test (AP vs flow):
- a. Fix flow, AP or speed (if required) and measure AP or flow whichever is not set. Typically, FCS sets flow and measures AP.
- b. Evaluate and compare with reference value or reference curve for degradation. Relief is required to use curves.
- 2. Measure vibration per 0M Part 6.
)
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B. Positive Displacement
- 1. Perform operational test (discharge pressure vs flow).
- 2. Measure flow and discharge pressure and compare to reference values for degradation.
- 3. Measure vibration per 0M Part 6.
7.0 ACCEPTANCE CRITERIA / CORRECTIVE ACTIONS A. Valves
- a. Alert Range:
- 1) 125% (or 15%) of reference value for POVs (M0'/s) if reference value >10 seconds.
- 3) No alert range for rapid acting valves.
- 4) Alert range may be developed based on Engineering judgement, if the safety analysis value is less than the calculated required action range.
- 5)
- Action taken:
a) Immediate retest (verification), and, b) Recalibrate instruments and retest valves; or, c) Repair or replace valve; or, d) Perform Engineering analysis to prove acceptability; or, e) Augment frequency of test.
- Actions may be combined, if appropriate.
- b. Required Action Range:
- 1) 2.5 times reference value (or conservative to safety analysis).
10 0F 12
- v. .
- 2) Action taken: .
I a) Valve is immediately declared inoperable, and, b) Repair or replace; or, c) Recalibrate and retest; or, 8
d) Perform an. Engineering ' analysis to prove operability.
- 2. Check Valves +
- a. Maximum required accident flow for "open"
- b. Minimum AP for "close"
- c. Set acceptance criteria to detect degradation as -soon as i possible without' requiring unnecessary actions due to normal or expected variations. '
- d. Visual inspection,
- e. Leakage criteria, if required.
- f. Sample disassembly:
- 1) If one valve fails sample disassembly, then all other valves in group require sample disassembly.
- 2) Typically, one valve every other refueling outage (e.g.,
all valves in class are disassembled in a six-year ,
cycle).
- 3) Partial stroke / leak test upon reassembly, if practical.
i
- 3. Relief / Safety Valves ,
l
- a. Class 1
- 1) If valve measured relief pressure exceeds >103% of stamped-set pressure criteria, additional valves of same ,
type and manufacture shall be set pressure tested on the.
basis of two additional valves for each valve failed up to the total number of valves of the same type and-manufacture in the system of concern. If any of the additional valves tested exceed the stamped set pressure criteria by >3%, then all valves of the same type and i manufacture shall be tested.
I 11 0F 12 a
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B. Pumps
.h.
1._ Centrifugal
- a. Alert Range: Tables 3A and 3B of.0M-6.
- b. Required Action Range: Tables 3A and 3B of OM-6.
- 2. Positive Displacement (Reciprocating)
- a. Alert Range: ' Tables 3A and 3B of OM-6.
- b. Required Action Range: . Tables 3A and 3B of OM-6.
NOTES:
- 1. Data is evaluated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of the completion of the test.
- 2. Class 1, 2 and 3 ten-year hydros are not performed (reference ASME Code Case N-498-1).
- 3. Components added to the ISI Program Plan as a result of plant / system modifications, engineering changes or re-evaluation of component eligibility-requirements are considered operable based on interim acceptance criteria (established by construction, preservice, post maintenance, or preoperational tests), until a trend can be established.
- 4. Corrective actions as defined in the ISI Program Plan can be one or more of the following:
- a. Check calibration and/or recalibrate instrument, then perform retest of component.
- b. Repair or replace component, then perform acceptable retest.
- c. Perform Engineering analysis to prove component is capable of performing its design function.
- 5. In determining selection of components to be included in the ISI Program, FCS does not consider passive failures of piping seismically qualified per the USAR and not included specifically in the safety analyses contained in the USAR.
- 6. Typically reference values are evaluated for three performances prior to revision.
- 7. Trending and trend analysis (related to IST actions) are monitored by the ISI Coordinator and any actions / recommendations to revision of reference values are made to the System Engineer for concurrence.
12 0F 12
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LIC-95-0120 ATTACHMENT'3 t
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.L ENCLOSURE A i
SUMARY OF CHANGES MADE TO FORT CALHOUN STATION ISI PROGRAM PLAN ,
l THIRD TEN YEAR INTERVAL (1993 - 2003) REVISION 2 :
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ATTACNMENT 3 ENCLOSURE A
SUMMARY
OF CHANGES MADE TO FORT CALHOUN STATION ISI PROGRAN PLAN THIRD TEN YEAR INTERVAL (1993 - 2003) REVISION 2 NOTE: Changes made from Revision 0 to Revision 1 were to Primarily ISI (Part 1) Section only.
CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 1 Part 1, Section 2.4.2 Updated snubber test Code reference 2 Part 1, Sections 8.2.2, 8.3.2, and Changed Code Case "N-498" to "N-498-1" to reflect NRC 8.4.2 approval and FCS implementation of Code' Case to Class 1, 2, and 3 components.
3 Table 1.1, Item B5.10 Added " Butt" 4 Table 1.1, Items B9.10, B10.10, Added "-1" and "or Volumetric" B10.20, B10.30 5 Table 1.1, Item B12.20 Changed "B-K-2" to "B-L-2" and changed " Volumetric" to
"* Visual VT-3" and added note "*Per Code Case N-481" 6 Table 1.2 Item C2.21, C5.10 Add "& Surface" 7 Table 1.3 Deleted reference to Code Case N-509 8 Appendix 1A Modified clarification for "IWA-2600" to reference SEI-27 9 Appendix IB Added clarification to RPV shell weld exam exception 10 Part 2, 1.0, 2.1, 2.2, 5.1, 7.1 Corrected typos / clarification 11 Part 2, Table Format, Item 2 Added "SW - Service Water System" to list Page 1 of 6
. _ _ __ _ _ _ _ ___ _ _ ____ _ _ _ _ _ _ _ _ _ _ .__ _ _..___ _ . . ~ . . . _ _ . _ . _ _ __.
ATTACHMENT 3 (Continued)
CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 12 Part 2, Table Format, Items 3, 14 Corrected typos / clarification 13 Part 2, Table Format, Item 17 Add Note #6 14 Part 2, Table 2.1 Added "NG-113, NG-142, NG-144, NG-146, NG-148 and AC-391" (EAR 94-143) 15 Part 2, Table 2.1, CH-143 Changed to " Cold Shutdown" frequency-16 Part 2, Table 2.1, CH-155, CH-156, Changed to " Cold Shutdown" frequency CH-166 17 Part 2, Table 2.1 Added AC-164, AC-165 to ISI Program Plan 18 Part 2, Table 2.1, HCV-176, HCV-177, Changed to " Cold Shutdown" frequency HCV-178, HCV-179, HCV-180, HCV-181 19 Part 2, Table 2.1, CH-187, CH-188, Added CH-187, CH-188, CH-189 Full Stroke "Close" to ISI CH-189 Program Plan ,
20 Part 2, Table 2.1 Added SI-187, SI-188, SI-189, SI-190, to ISI Program Plan 21 Part 2, Table 2.1 Added RW-220, RW-221, RW-222, RW-223, SW-240, SW-241, SW-242, SW-243, RW-254, RW-255, RW-256, ' and RW-257 to '
ISI Program Plan '
22 Part 2, Table 2.1 Added AC-283, AC-284, AC-285,-AC-286, VA-287, and VA-288 to ISI Program Plan 23 Part 2, Table 2.1 Added SI-298, SI-299,51-309, and SI-310, to ISI '
Program Plan 24 Part 2, Table 2.1, HCV-308 Changed HCV-308 frequency to " Quarterly", deleted J19 Page 2 of 6 l
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l ATTACHMENT 3 (Continued)
CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 25 Part 2, Table 2.1, HCV-383-3, Changed frequency to " Cold Shutdown" and provided J40 HCV-383-4, LCV-383-1, LCV-383-2 for justification -
26 Part 2, Table 2.1 Added NG-LCV-383-1-52, NG-LCV-383-2-S2, NG-HCV-400A-52, NG-HCV-400B-52, NG-HCV-401A-S2, NG-HCV-401B-52, NG-HCV-402A-S2, NG-HCV-4028-S2, NG-HCV-403A-S2, ;
NG-HCV-4038-52, NG-HCV-4388-S2, NG-HCV-4380-52 27 Part 2, Table 2.1, HCV-467A/B/C/D, Changed frequency to " Quarterly", deleted ~
HCV-474, HCV-478, HCV-480, HCV-481 justifications J25 and J37 28 Part 2, Table 2.1, HCV-1387A/B, Changed frequency to " Quarterly", deleted justification HCV-1388A/B J29 29 Part 2, Table 2.1, HCV-2988, HCV-2987 Changed frequency to " Quarterly", deleted J19 and J32 30 Part 2, Table 2.1, IA-LCV-383-1-C, Changed frequency to " Cold Shutdown" and provided J40 IA-LCV-383-2-C for justification 31 Part 2, Table 2.1, IA-HCV-2898A/B-C, Added IA check valves to ISI Program Plan and Note #6 '
IA-HCV-2899A/B-C (Modifications MR-FC-94-019 & MR-FC-94-020) 32 Appendix 2A , Item 5 Changed frequency to Cold Shutdown and revised justification per NRC SER (Reference Attachment #1, Item 7 of LIC-95-0120) '
33 Appendix 2A, Item 6 Clarification per NRC SER (Reference Attachment'#1,
, Item 9 of LIC-95-0120) 34 Appendix 2A, Item 7 Provided further justification / clarification per NRC SER (Reference Attachment #1, Item 10 of LIC-95-0120) 35 Appendix 2A, Item 8 Changed frequency to Cold Shutdown and revised justification per NRC SER (Reference Attachment #1, Item 7 of LIC-95-0120)
Page 3 of 6 4
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ATTACHMENT 3 (Continued)
CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 36 Appendix 2A, Item 11 Provided further justification / clarification per NRC SER (Reference Attachment #1, Item 7 of LIC-95-0120) 37 Appendix 2A, Item 13 Provided further clarification per NRC SER (Reference Attachment #1, Item 9 of LIC-95-0120) 38 Appendix 2A, Item 19 Deleted justification J19 (See NRC SER response, Attachment #1, Item 7 of LIC-95-0120) 39 Appendix 2A, Item 25 Deleted justification J25 (See NRC SER response, Attachment #1, Item 8 of LIC-95-0120) 40 Appendix 2A, Item 29 Deleted justification J29 (See NRC SER response, !
Attachment #1, Item 7 of LIC-95-0120) l 41 Appendix 2A, Item 32 Deleted justification J32 (See NRC SER, Attachment #1, Item 8 of LIC-95-0120) 42 Appendix 2A, Item 35 Changed frequency to Cold Shutdown and provided further justification / clarification per NRC SER (Reference Attachment #1, Item 7 of LIC-95-0120) 43 Appendix 2A, Item 37 Deleted justification J37 (See NRC FER response, Attachment #1, Item 8 of LIC-95-0120) 44 Appendix 2A, Item 39 Revised justification J39 to address concerns identified in NRC SER (See NRC response LIC-95-0120) 45 Appendix 2A, Item 40 Changed frequency from Quarterly to Cold Shutdown and provided justification )
46 Appendix 2A, Item 41 Changed testing of Raw Water / Component Cooling Water valves (manual valves per modification) and provided !
Refueling Outage justification Page 4 of 6
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ATTACHMENT 3 (Continued) .
- CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 1 47 Appendix 2A, Item 42 Deleted Cold Shutdown justification J42. Valves will be tested Quarterly 48 Appendix 2A, Item 43 Added valves NG-142, NG-144, NG-146 and NG-148 to ISI Program Plan and provided Cold Shutdown frequency justification.
49 Appendix 2B, Item G1 Revised relief request G1 for " thermal relief" valves provided additional justification and alternative testing as requested by NRC SER (Reference Attachment
- 1, Item 5 of LIC-95-0120) 50 Appendix 28, Items El, E2, and E3 Revised relief request to assure NRC requirements of GL 89-04 position 2 of LIC-95-0120 are addressed as
- requested by Items 3 and 4 of NRC SER (Reference Attachnent #1)
51 Appendix 28, Item 5 Deleted relief request E5. Valves will be tested per OM-1, per NRC SER (Reference Attachment #1 of LIC-95-0120) ;
52 Appendix 3A, Item 3 Deleted relief request E3. Charging pumps will be ,
tested per OM-6 per NRC SER (Reference Attachment #1 h of LIC-95-0120) 53 Appendix 3A, Item 4 Relief to use " Pump Curves" for " fixed valves" for testing Raw Water and Component Cooling Water Pumps.
Granted per NRC SER (Reference 2) ,
54 Table 2.1, HCV-385, HCV-366 Change test frequency to Cold Shutdown (Justification J34) for valves HCV-385 and HCV-386 55 Part 2, 2.4 Incorporate " ongoing" commitment for CIV caps
[
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a ATTACHMENT 3 (Continued)
CHANGE NO. SECTION/ PARAGRAPH DESCRIPTION OF CHANGE 56 Table 2.1 Modification MR-FC-89-032; added check valves IA-HCV-480-C, IA-HCV-481-C, IA-HCV-484-C, and IA-HCV-485-C to ISI Program Plan 57 Table 2.1, LCV-383-1, LCV-383-2, Changed test frequency to Cold Shutdown (J40) for HCV-383-3, HCV-383-4, LCV-383-1-C, valves.
and LCV-383-2-C 58 Table 2.1, SI-102, SI-108, SI-115, Add "close" position verification for check valves SI-121, SI-129, SI-135, SI-143, SI- SI-102, SI-108, SI-115, SI-121, S1-129, SI-135, SI-143, 149 and SI-149, including justification updates for frequency (J3, J4, J36) 59 Table 2.1, CH-129, CH-130 Add "close" position verification for check valves CH-129, CH-130 60 Table 2.1 Add Instrument Air (IA) check valves for IA-HCV-1107A/B-C, IA-HCV-1108A/B-C, FCV-1368-C, and FCV-1369-C. Update J38 61 Table 2.1 Add CA-555 to ISI Program Plan 62 Table 2.1 Add check valves F0-218 and F0-219 to ISI Program Plan 63 Table 2.1, HCV-400A/C, HCV-401A/C, Add "close" stroke time for HCV-400A/C, HCV-401A/C, HCV-402A/C, HCV-403A/C HCV-402A/C and HCV-403A/C 64 Part 3, E4, AC-10A/B/C/D and Add relief request for Raw Water (RW) and Component AC-3A/B/C Cooling Water (CCW) pumps - NRC Approved 65 Part 4, Item 8 Add Code Cases N-416, N-416-1 and N-498-1 to ISI Program Plan 66 Part 4 References updated / changed to reflect changes / additions / deletions Page 6 of 6
-LIC-95-0120 ATTACHMENT 3-
~
FORT CALHOUN STATION INSERVICE INSPECTION (ISI) PROGRAM PLAN REVISION 2 3
. - - . _ - _ _ - - _ - - _ _ _ _ - _ _ - - >