DCL-12-065, Response to NRC Request for Additional Information Regarding PG&E Letter DCL-11-01B, License Amendment Request 11-02, Revision to Technical Specification 3.7.1. Main Steam Safety Valves (Mssvs)

Response to NRC Request for Additional Information Regarding PG&E Letter DCL-11-01B, License Amendment Request 11-02, Revision to Technical Specification 3.7.1. Main Steam Safety Valves (Mssvs)

ML121850128
Person / Time
Site:	Diablo Canyon   (DPR-080, DPR-082)
Issue date:	07/02/2012
From:	Welsch J Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-12-065
Download: ML121850128 (63)

Text

Pacific Gas and Electric Company July 2,201 2 PG&E Letter DCL-12-065 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-BO Docket No. 50-323, OL-DPR-B2 Diablo Canyon Units 1 and 2 James M. Welsch Station Director 10 CFR 50.90 Diablo Canyon Power Plant Mail Code 104/ 5/ 502 P. O. Box 56 Avila Beach, CA 93424 805.545.3242 Internal: 691.3242 Fax: 805.545.4234 Internet: JMW1@pge.com Response to NRC Request for Additional Information Regarding PG&E Letter DCL-11-01B. "License Amendment Request 11-02. Revision to Technical Specification 3.7.1. 'Main Steam Safety Valves (MSSVs)'"

Reference:

1.

PG&E Letter DCL-11-01B, "License Amendment Request 11-02, Revision to Technical Specification 3.7.1, 'Main Steam Safety Valves (MSSVs),'" dated February 17, 2011

2.

PG&E Letter DCL-11-055, "Supplement to License Amendment Request 11-02 Revision to Technical Specification 3.7.1, 'Main Steam Safety Valves (MSSVs),'" dated April 21, 2011 In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a license amendment request to revise Technical Specification (TS) 3.7.1, "Main Steam Safety Valves (MSSVs)," Table 3.7.1-1, "Maximum Allowable Power Range Neutron Flux High Setpoint With Inoperable MSSVs," to remove a one-time note specific to Diablo Canyon Power Plant (DCPP), Unit 2 for Cycle 15, which is no longer applicable or needed. In Reference 1, PG&E also proposed to revise the TS Bases, applicable to DCPP, Units 1 and 2, to adopt a new analysis methodology for establishing the reduced power range neutron flux high setpoint for one inoperable MSSV as listed in TS Table 3.7.1 -1.

In Reference 2, PG&E clarified that the revision to the TS Bases requested in Reference 1 is a revision to the Final Safety Analysis Report Update (FSARU),

as the TS Bases are incorporated into the FSARU by reference. Reference 2 supplemented Reference 1 by providing proposed revisions to FSARU Sections 15.2.7.3, "Results," and 15.2.16, "References."

The NRC Staff provided a request for additional information (RAI) via e-mail, dated March 19, 2012. PG&E's responses to the staff's RAI are provided in the Enclosure.

A member of the STARS (Strategic Teaming and Resou r ce Shar i ng)

Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

m Document Control Desk

~&~ July 2,2012 Page 2 PG&E Letter DCL-12-065 PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.

This letter includes no revisions to existing regulatory commitments.

If you have any questions or require additional information, please contact Mr. Tom Baldwin at (805) 545-4720.

I state under penalty of perjury that the foregoing is true and correct.

Executed on July 2, 2012.

Sincerely, es M. Welsch Station Director d ngd/4955/50466545 Enclosure cc:

Diablo Distribution cc/enc:

Elmo E. Collins, NRC Region IV Michael S. Peck, NRC Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager Alan B. Wang, NRR Project Manager A

member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Enclosure PG&E Letter DCL-12-065 PG&E Responses to NRC Requests for Additional Information Regarding PG&E Letter DCL-11-018. "License Amendment Request 11-02. Revision to Technical Specification 3.7.1. 'Main Steam Safety Valves (MSSVs)'"

NRC Question 1:

Can PG&E provide the Crosby test data referenced in EPRI Report NP-4306-SR that supports a 5 psi max accumulation behavior for main steam safeties?

PG&E Response:

Westinghouse attempted to get the Crosby data referenced in EPRI Report NP-4306-SR from Crosby and was unsuccessful. However, Westinghouse was able to provide some relevant data covering Dresser Main Steam Safety Valve (MSSV) (Model 3777Q) testing performed at Wyle Laboratories. The tested valve belongs to Dresser relief valve Series 3700, which is the same series as the MSSVs installed in Diablo Canyon Power Plant (DCPP) (Model 3707). The test was performed as a qualification program of the MSSV to simulate the valve performance under different environmental transients by testing at various initial temperature conditions. A review of the test data concluded that it was more appropriate to cover the range of Dresser MSSV operating conditions at DCPP than the Crosby pressurizer safety valve (PSV) data in the EPRI report. Table 1 tabulates the "open" tested pressures at which the Dresser MSSV would achieve rated flow. From the table, Westinghouse calculated the average "open" pressure of the MSSV, and the standard deviation.

Valve Design and Setting Dresser Model 3777Q Spring Loaded Safety Valve Steam Relief MSSV Set Pressure 1235 plus or minus 1 percent Valve Lift approximately 0.94 inch Test Results j1 (mean) = 1213.36 psig (Test) a (standard deviation) = 25.44 psig (Test)

From Table 1, the difference between the average "open" pressure and the nominal set pressure is negative 21.64 pounds per square inch, gage (psig)

(i.e., 1235 -1213.36 = -21.64 psig). The difference between the average "open" pressure plus one (1) standard deviation and the nominal set pressure is 3.8 psig (i.e., 1213.36 +25.44 -1235 = 3.8). The test data indicates that the MSSVs statistically opened slightly lower than the set pressure. The Dresser MSSV valve test data indicates that it is statistically probable that the full open 5 psi accumulation will be reached at a value at or very near the set pressure. Therefore, with the valve set at 1

Enclosure PG&E Letter DCL-12-065 1235 plus or minus 1 percent and with a 5 psi accumulation, the MSSV would conservatively be expected to be "open" at 1252.35 psig (Le., 1235 + 12.35 + 5 = 1252.35 psig). It can be seen from the data that there is no "open" pressure that exceeds 1252.35 psig. This test data based on a plus or minus 1 percent set pressure supports the 5 psig accumulation and 3 percent drift assumption as being conservative for modeling the "open" pressure for Dresser MSSVs.

Table 1 Popping Pressure and Lift for Various Valve Body Temperature Conditions Body "Open" Temp Pressure Lift (OF)

(psig)

(in)

Set 266 1236 1.04 Pressure 250 1218 0.92 Test 248 1242 1.08 Following 250 1239 1.04 Repair 248 1239 1.0 jJ = 1213.36 psig Set 320 1174 1.0 Ll = (jJ-1235)

Pressure 317 1174 1.0

= -21.64 psig Following 317 1193 1.0 Condition 1 a = 25.44 psig Evaluation Set 276 1223 1.0 Pressure 281 1200 1.0 Following 286 1209 1.0 Condition 2 Evaluation NRC Question 2:

Can PG&E provide the Westinghouse evaluation that determines that the DCPP Dresser valves will perform in a similar manner?

PG&E Response:

The Westinghouse evaluation that shows that the Dresser MSSV will perform like the Crosby PSVs is a proprietary document of Westinghouse. However, the content of the evaluation is summarized herein. The evaluation considered the DCPP MSSV 5 psi accumulation assumption with respect to the safety valve opening characteristics. The evaluation determined that the Dresser MSSV would behave like the Crosby safety valve as referenced in the EPRI Report NR-4306-SR in that the relief valves without bellows (Le., Dresser MSSVs) would behave like safety valves with bellows as long as the back 2

Enclosure PG&E Letter DCL-12-065 pressure is no more than 10 percent of set pressure. The Westinghouse evaluation also utilized the information contained in the Dresser MSSV Instruction Manual to show how the MSSV operates during opening. From information obtained from the instruction manual and communication with Crosby, the evaluation showed that for a 5 psi accumulation, the Dresser MSSV would open in about 0.09 seconds. Finally, the Westinghouse evaluation estimated the pressurization rate of the MSSV to show that with a pressurization rate of 55 psi/second the accumulation is approximately 5 psi. The evaluation was performed because, at the time the report was prepared, Westinghouse had no access to the Dresser MSSV test data.

As stated in the response to NRC Question 1 above, Westinghouse was able to gain access to a Dresser test report. The availability of the newly acquired test data on the Dresser MSSV and the post TMI-EPRIIC-E PSV allows for a more realistic assessment of the performance of the Dresser valves. Using the two data sources, Westinghouse compared the results of the Dresser MSSV test data shown in Table 2 and the Dresser PSV test data shown in Table 3. The variation in the tested "open" pressures was not pertinent as the comparison focused on the relative opening characteristics of the safety valves with respect to the 5 psi accumulation assumption. Table 2 tabulates the Dresser MSSV test "open" pressure and the valve lift or stroke time, which are consistent with the evaluated pressurization rate and opening time discussed above. Table 3 tabulates the test data of Dresser safety valves performed by EPRI and shows the pre-test valve conditions, the "initial I itt" pressure at which the valve first begins to open, the "open" pressure, and the valve lift or stroke time. A comparison of the Table 2 and Table 3 data shows that the opening characteristics are linear and the stroke time is very rapid for the two Dresser valves. It is reasonable that the faster stroke times in the EPRI tests may be attributed to the different test conditions and pressurization rates associated with testing at the higher set pressure. However, the EPRI Dresser PSV test data supports the conclusion that a 5 psi accumulation is characteristic of Dresser valves.

Table 2 Dresser MSSV Opening Characteristics and Open Time Test Ramp Set Pressure Lift (inch)

Opening Stroke rate (psig)

Characteristics time (psi/sec)

(sec) 1 20 1200 1.04 Linear 0.12 2

18 1239 1.0 Linear 0.13 3

20 1205 1.04 Linear 0.15 4

15 1200 1.0 Linear 0.089 3

Table 3 Enclosure PG&E Letter DCL-12-065 Valve Transient Performance Data for the Dresser 31739A Safety Valve PRE-TEST VALVE CONDITIONS NOMINAL NOMINAL VALVE VALVE INITIAL INLET INLET LIFT "OPEN" STROKE TEST TEST PRESS.

TEMP.

PRESS.

PRESS.

TIME VALVE NO.

TYPE MEDIA (PSIA)

(oF)

(PSIA)

(PSIA)

(SEC)*

STABILITY 1003 STEAM STEAM 2300 SAT 2460 2460

.015 Stable 1005 STEAM STEAM 2285 SAT 2425 2431

.016 Chatter 1008 STEAM STEAM 2287 SAT 2446 2450

.014 Stable 1011 STEAM STEAM 2300 SAT 2478 2482

.016 Stable 1012 STEAM STEAM 2285 SAT 2490 2495

.021 Stable 1018 STEAM STEAM 2300 SAT 2455 2458

.024 Stable 1104 STEAM STEAM 2300 a

SAT 2550 2550

.013 Stable

• Linear characteristics NRC Question 3:

Can PG&E provide a description of the current inservice testing methodology for the MSSVs and a summary of the inservice test results over the period that this methodology has been used? Can PG&E also provide a summary of MSSV failures or unplanned maintenance actions during this same period?

PG&E Response:

The DCPP program for testing ASME Code Class 1, 2, and 3 safety and relief valves, which includes the MSSVs, is described in Surveillance Test Procedure (STP) M-77, "Safety and Relief Valve Testing." A copy of STP M-77 is provided in Attachment 1.

STP M-77 classifies the various safety and relief valves into groups based on valve type and manufacturer with the MSSVs comprising their own distinct group for testing purposes.

Test Frequency STP M-77 Step 1.3.5 specifies that although the MSSVs are ASME Code Class 2 valves, per the ASME Code for the Operation and Maintenance (OM) of Nuclear Power Plants, OM-2001, Appendix I,Section I 1350(a), they are tested on the same frequency as ASME Code Class 1 valves. STP M-77 Step 3.1.1 specifies that all MSSVs are 4

Enclosure PG&E Letter DCL-12-065 tested within a five year period, with a minimum of 20 percent of the MSSVs tested within any 24 month period.

On line Testing The MSSVs are testable at power using the Furmanite Trevitest System as detailed in DCPP Mechanical Maintenance Procedure MP M-4.18A, which is provided in. The Trevitest System places an external pulling load on the MSSV valve stem which overcomes the spring force allowing the valve to lift off its seat. Once the lift point is reached, the lift value is recorded as a permanent record. The Trevitest Mark VIII system currently used for MSSV testing per MP M-4.18A can be configured to measure the valve spindle deflection via a lift potentiometer or the valve discharge via acoustic detection. The Trevitest Mark VIII system also measures the valve inlet pressure with a pressure transducer, and the spring relaxation force with a load cell.

Test Acceptance Criteria The initial lift for the MSSVs except for the valves with the lowest setpoint is required to be within plus or minus 3 percent of the specified setpoint. The four valves with the lowest setpoint of 1065 psig are required to lift within plus 3 percent and only minus 2 percent to ensure the MSSV does not lift before the steam generator atmospheric dump valve, which is set at 1035 psig. If the initial lift of a MSSV is outside this acceptance criteria then a corrective action notification is issued to evaluate the potential impact on the plant, and the test scope is expanded to include two additional MSSVs.

At least two consecutive, lifts without adjustment are required to be within the plus or minus 1 percent "As Left" specification in order for the MSSV to be declared acceptable.

Summary of Testing Results Attachments 3 and 4 for Units 1 and 2, respectively, provide a detailed summary of the MSSV test data obtained for the time period since the Trevitest System has been used at DCPP.

The summary for Unit 1 shows that of the 166 MSSV tests performed, 23 valves were found with a lift setpoint greater than or equal to 2 percent and only 2 MSSVs were found Out of Tolerance with a lift setpoint greater than or equal to 3 percent. also shows that 36 MSSV tests required some adjustment to obtain an "As Left" setpoint within the required plus or minus 1 percent tolerance.

The summary for Unit 2 shows that of the 125 MSSV tests performed, 19 valves were found with a lift setpoint greater than or equal to 2 percent and only 3 MSSVs were found Out of Tolerance with a lift setpoint greater than or equal to 3 percent. also shows that 46 MSSV tests required some adjustment to obtain an "As Left" setpoint within the required plus or minus 1 percent tolerance.

5

Recent MSSV Maintenance / Failure Summary August 2009 - Failure MSSV MS-2-RV-224 Enclosure PG&E Letter DCL-12-065 During the on line Trevitest performance for Unit 2, MSSV MS-2-RV-224 was determined to be inoperable due to a linear crack indication on the valve spring.

Unit 2 reactor power was reduced and the Power Range High Flux trip setpoint was reduced toB7 percent in accordance with Technical Specification (TS) 3.7:1 Condition A.1. In addition, MSSV MS-2-RV-224 was gagged for the remainder of the operating cycle as a prudent measure. The remaining Unit 2 MSSVs and all Unit 1 MSSVs were subsequently inspected and no additional indications were identified.

The MSSV MS-2-RV-224 spring was replaced during the subsequent Unit 2 Refueling Outage 15 (2R15) in November 2009 and the valve was returned to service.

November 2009 - Prudent Replacement of 2 MSSVs During 2R15, two MSSVs were identified to have some corrosion similar to that observed on the MSSV MS-2-RV-224, which had a cracked spring as discussed previously. Although there was no adverse impact on the valves and they remained functional, they were replaced as a prudent measure.

December 2008 - Leakage MSSV-1-RV-11 Following the on-line performance of the Trevitest for Unit 1 MSSV MS-1-RV-11, the valve was found to be slightly weeping at a rate of about two drops per minute. The MSSV remained operable as the small leakage did not impact the valve functionality and the lift setpoint was verified to be within acceptable limits. The MSSV leakage was monitored for the remainder of the operating cycle and no adverse increase in the rate of leakage was noted through the time Unit 1 shutdown for refueling in late January 2009. The MSSV RV-11 spring was replaced during the Unit 1 Refueling Outage 15.

November 2005 - Leakage MSSV MS-1-RV-60 During the startup from Unit 1 Refueling Outage 13, the MSSV MS-1-RV-60 was observed to be weeping. The small amount of leakage was determined not to impact the valve function and the MSSV remained operable. A leakage monitoring program was established including administrative limits to shut down and replace the valve if the leakage exceeded the criteria. During a planned curtailment, the valve was gagged for several days in an attempt to reseal the valve seat; however, the weeping continued.

The valve leakage remained steady and never increased to an unacceptable level during the remainder of the operating cycle. The MSSV MS-1-RV-60 was replaced during Unit 1 Refueling Outage 14 in May 2007.

6

NRC Question 4:

Enclosure PG&E Letter DCL-12-065 Because the EPRI reporl identified that a safety valve's performance may vary based upon the physical plant piping configuration, the staff requests the licensee evaluate the individual plant configuration in which the safeties are installed for an effect on the valve's performance.

PG&E Response:

The EPRI Report NP-4306-SR evaluated various test configurations for both inlet and discharge piping effects with respect to safety valve performance. The DCPP MSSVs discharge directly to the atmosphere and therefore the discharge piping analysis documented in EPRI Report NP-4306-SR, Section 11, is not applicable for the DCPP MSSV piping configuration. In Section 6, the EPRI Section 6 Report NP-4306-SR evaluated two basic inlet test configurations; a short vertical inlet and a loop seal configuration. For configurations which did not incorporate a loop seal, the seal was drained and this test configuration was defined as a long inlet.

The only significant effects on the observed test results described in the EPRI Report NP-4306-SR Section 6 were due to the inlet piping configuration during two phase transition and liquid relief flow conditions. The DCPP MSSVs relieve only saturated steam conditions and these effects are not applicable. The EPRI test results did describe that the safety valve performance was characteristically less stable on longer inlet configurations and sometimes required ring adjustments to obtain stable performance under steam relief conditions.

Each DCPP unit has two of the four main steam leads that are located outside and the MSSVs are attached directly to the main steam line with essentially no inlet piping. The other two main steam leads pass through the auxiliary building with the MSSVs connected to the main steam line by a vertical header 25 to 30 feet long to enable them to discharge directly to the atmosphere. However, this MSSV header is almost as large (Diameter equals 24 inches) as the main steam line itself (Diameter equals 28 inches) and is a straight pipe run that is more representative of the short inlet configuration as tested in the EPRI report and not the loop seal or long configuration. Therefore, the only effect of the header configuration is a slight increase in the total pressure drop to the MSSV inlet that occurs during MSSV relief flow conditions.

Therefore, PG&E performed a design calculation to determine the maximum total system pressure drop from the steam generator exit to the MSSV inlet for the limiting main steam line configuration for both Unit 1 and Unit 2. When Westinghouse developed the current MSSV analytical model for DCPP, they conservatively adjusted the MSSV lift and full open setpoints to bound the effects of this maximum pressure drop during relief flow conditions. These setpoint adjustments were conservatively applied to all four main steam leads and MSSVs in the analysis model irrespective of whether the lead contained an actual header configuration or not.

7

Enclosure PG&E Letter DCL-12-065 In summary, the DCPP MSSV piping configuration is consistent with that tested in the EPRI Report NP-4306-SR, and the MSSV analytical model used conservatively bounds the maximum system pressure drop due to the limiting MSSV header configuration.

8

Diablo Canyon Procedure Enclosure PG&E Letter DCL-12-065 STP M-77, Safety and Relief Valve Testing

====================== Cover Sheet======================

Uni t (s) : 1&2 Procedure: STP M-77 Revision: 32 Classification: QUALITY RELATED Ti tIe: Safety and Relief Valve Testing Level of Use: Periodic Issued For Use By:

Date:

Expires:

Completion of this cover sheet satisfies the requirement to complete the "Issued for Use" banner on the first page of the attached document.

=========================================================

• • • ISSUED FOR USE BY:

DATE:

EXPIRES:

PACIFIC GAS AND ELECTRIC COMPANY NUMBER STP M-77 NUCLEAR POWER GENERATION REVISION 32 DIABLO CANYON POWER PLANT SURVEILLANCE TEST PROCEDURE PAGE UNITS 1 OF 6 TITLE:

Safety and Relief Valve Testing 03/02/09 EFFECTIVE DATE PROCEDURE CLASSIFICATION: QUALITY RELATED

1.

SCOPE 1.1 This test consists of verifying lift point settings (and recalibration IF required) of the safety and relief valves required by ASME Code for the Operation and Maintenance (OM) of Nuclear Power Plants, except as exempted.

1.2 Revision 28 of this procedure made extensive changes as required by the third 10 year In-Service Testing (IST) interval. Revision 17 of this procedure made extensive changes as required by the second 10 year 1ST interval. This procedure addresses the differences in test requirements between ASME Code Class 1 and ASME Code Class 2 or 3 components.

1.3 Conversion to the second 10 year 1ST interval added a significant number of Code Class 2 and 3 relief valves to the program. Testing of Code Class 2 and 3 relief valves was previously being performed under the Preventative Maintenance (PM) Program, so many of the valves now subject to 1ST have a test history. The following guidelines were used to determine when testing is first required for a valve group.

1.3.1 The previous PM testing of a valve was considered acceptable to satisfy the first 48 month interval, even though expanded testing was not part of the PM Program.

1.3.2 1.3.3 1.3.4 1.3.5 1.3.6 STP _M-77u3r32.DOC 06 For any valve group which does not have a recent PM test to satisfy the first 48 month interval, one valve was selected for testing in the Eighth Refueling Outage (lR8/2R8).

When a valve on only one unit would have required testing to ensure the first 48 month interval was met for that unit, the corresponding valve on the other unit was tested to ensure consistency.

Valve manufacturer, type, size, system application, and service media were used to determine acceptable valve groups. Resultant valve groups include a maximum of 5 valves.

Main Steam Safety Valves (MSSV's) are ASME Code Class 2 valves.

However, per Appendix I, section I-1350(a) ofOM-2001, they shall be tested on the same frequency as ASME Code Class 1 valves.

Setpoint, as used in this procedure, generally refers to the stamped set pressure of the valve. The exception is when the manufacturer's suggested temperature correction has been applied due to service conditions; valves in the Residual Heat Removal (RHR) flowpath fall into this category.

0215.0810

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT NUMBER STP M-77 REVISION 32 PAGE 2 OF 6 TITLE:

Safety and Relief Valve Testing UNITS lAND2

2.

RESPONSIBILITIES 2.1 Test Performer is responsible for operation of test equipment, as required, and forwarding the "As Found" data (from MP M-51.5) to the Test Director upon completion of testing Code Class 2 and 3 valves.

2.2 Test Performer is responsible for insuring test equipment used to determine valve set-pressure shall have an overall combined accuracy not to exceed +/-1 % of the indicated (measured) set-pressure per Appendix I, section 1-1400 ofOM-2001.

2.3 Test Director is responsible for reviewing test results for acceptance, reporting results, and for compiling data for Code Class 2 and 3 valves on Attachment 8.6 and 8.7.

2.4 Engineer is responsible for review of results.

3.

FREQUENCY 3.1 As required by Tech Spec 5.5.8 and ASME OM-2001 Code, valves shall be tested as follows:

3.1.1 ASME Code Class 1 Safety and Relief Valves NOTE: The 5 year test period referenced in step 3.1.1a starts from the date the Class 1 valve is last tested, not at the time of installation into service. (Refer to References 6.8 and 6.9)

a.

All valves of each type and manufacturer shall be tested within each 5 year period with a minimum of 20% of the valves tested within any 24 months. This 20% shall be previously untested valves, if they exist.

b..3 indicates minimum test requirements.

c.

MSSV's are testable at power. Test requirements for these valves may be satisfied anytime during the operating cycle, provided the 20% within any 24 months criteria of step 3.1.2a is met.

3.1.2 ASME Code Class 2 and 3 Relief Valves NOTE: The 10 year test period referenced in step 3.1.2a starts from the date the Class 2 or 3 valve is last tested, not at the time of installation into service.

a.

All valves within a valve group, with the exception of MSSV's, shall be tested within each 10 year period, with a minimum of 20% of the valves tested within any 48 months. This 20% shall be previously untested valves, if they exist.

3.2 Testing of Valves after Replacement with Pretested Valves.

3.2.1 ASME Code Class 1 Safety and Relief Valves STP _M-77u3r32.DOC 06

a.

If testing is satisfied by installing a partial complement of pretested valves for a valve group, the valves removed from the system shall be set pressure tested prior to the resumption of electric power generation. In practice, set pressure testing of removed valves shall be performed as soon as possible after the valve has been removed to allow any expanded testing (step 3.3) to be performed with minimum effect on the outage.

0215.0810

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT NUMBER STP M-77 REVISION 32 PAGE 3 OF 6 TITLE:

Safety and Relief Valve Testing UNITS 1 AND 2

b.

If testing is satisfied by installing a full complement of pretested valves for a valve group, the valves removed from the system shall be set pressure tested within 12 months of removal from the system.

c.

If "As Found" setpoint criteria is not met for any valve, then a Notification must be written to evaluate the condition. If the setpoint is exceeded by +/-3 %, expanded testing per step 3.3 is required.

3.2.2 ASME Code Class 2 and 3 Safety and Relief Valves

a.

Although the code required time interval for testing valves replaced with a partial complement of pretested valves is different for Class 2 and 3 valves, DCPP will apply the same criteria as is used for Code Class 1 valves outlined in step 3.2.1. This will allow the evaluation of the need for expanded testing, as required by the Code, prior to the resumption of electric power generation.

3.3 Expansion of Test Scope 3.3.1 Additional valves shall be tested in accordance with the following requirements.

a.

If the "As Found" set-pressure of any valve exceeds the greater of either its acceptance criteria, or the valve setpoint by +/-3%, 2 additional valves, in that group, shall be tested for each failure up to the total number of valves in that group.

NOTE 1: Expanded testing is based upon valve groups. In this section, references to testing 2 additional valves mean 2 additional valves within that valve group. Additionally, for groups with only 2 valves, testing the 1 additional valve in that group satisfies the Code requirements.

NOTE 2: If all valves within a valve group are tested, expanded testing requirements are not applicable.

b.

If any of the additional valves tested exceeds its setpoint criteria by +/-3%,

then all remaining valves within that group shall be tested.

4.

TECHNICAL SPECIFICATIONS 4.1 This procedure satisfies Technical Specification Surveillance Requirements 5.5.8, SR 3.4.10.1 and SR 3.7.1.1, and ECG SR 7.3.

STP_M-77u3r32.DOC 06 0215.0810

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT TITLE:

Safety and Relief Valve Testing

5.

ACCEPTANCE CRITERIA 5.1 Main Steam Safety Valves NUMBER STP M-77 REVISION 32 PAGE 4 OF 6 UNITS 1 AND 2 5.1.1 Initial lift acceptance criteria for all valves, except those set at 1065 psig, is +/-3 % of the specified setpoint.

a.

For valves with a setpoint of 1065 psig (RV-3, -7, -11 and -58), initial lift acceptance criteria is +3%, -2%.

5.1.2 At least two consecutive lifts without adjustment are required to be within the

+/-1 % "As Left" specification for the valve to be acceptable.

5.2 Pressurizer Safety Valves 5.2.1 Initial lift acceptance criteria is -3%, +2.3% of specified setpoint of 2485 psig?36485 5.2.2 At least two consecutive lifts without adjustment are required to be within the

+/- 1 % "As Left" specification for the valve to be acceptable.

5.3 Class 2/3 Relief Valves 5.3.1 Acceptance criteria is +/-3 % of setpoint for most valves. Exceptions are as follows:

a.

Valves with a setpoint of 70 psig or less - acceptance criteria is +/-2 psig of setpoint.

b.

Valves RV-930 and RV-931 (Spray Additive Tank Vacuum Breakers)-

acceptance criteria is -1.5 +/-0.9" Hg (0.6 to 2.4" Hg Vacuum).

5.3.2 Acceptance criteria for each valve is listed within the setpoint section of the applicable functional location within SAP. If no data is available in the setpoint section, guidance on acceptable criteria is provided in MP M-51.5.

5.4 IF setpoint criteria is not met on the initial lift during testing, THEN a Notification must be written. If lift point exceeds the setpoint by +/-3%, expanded testing is required. Refer to step 3.3.

STP_M-77u3r32.DOC 06 0215.0810

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT NUMBER STP M-77 REVISION 32 PAGE 5 OF 6 TITLE:

Safety and Relief Valve Testing UNITS lAND2

6.

REFERENCES 6.1 AD13.ID5, "Inservice Testing Program" 6.2 MP M-4.9, "Main Steam Safety Valve Setpoint Testing/Setting Using Steam" 6.3 MP M-4.18A "Verification of Main Steam Safety Valve Lift Point Using Furmanite's Trevitest Equipment" 6.4 MP M-7.36, "Pressurizer Safety Valve Lift Point Setting Using Steam" 6.5 MP M-51.5, "Testing and Maintenance of Safety Relief Valves" 6.6 Diablo Canyon Power Plant 1ST Program Plan 6.7 Engineering Calculation STA-211, System Overpressure Protection Devices Safety Function Design Basis for 1ST Program 6.8 Notification 50086229, "NRC 1 ASME Symposium on In-service Testing" 6.9 NUREG/CP-O 152, Volume 7 "Proceedings of the Tenth NRC 1 ASME Symposium on Valves, Pumps and In-service Testing" Pages 2A:28 - 2A:29 6.10 Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a (10 CFR 50.55a) 6.11 ASME OM Code-2001, "Code for Operation and Maintenance of Nuclear Power Plants,"

including addenda through the 2003 Addenda

7.

APPENDICES None

8.

ATTACHMENTS 8.1 "Valves Tested To ASME Class 1 Criteria," 06101/02 8.2 "Valves Tested To ASME Class 2/3 Criteria," 02115/09 8.3 "Test Schedule - Valves Tested to Class 1 Criteria," 06101/06 8.4 "Test Schedule - Valves Tested to Class 213 Criteria," 02/28/08 8.5 "Pressurizer Safety Valves Data Sheet," 03/23/07 8.6 "Main Steam Safety Valves Data Sheet," 03/23/07 8.7 "Class 2/3 Relief Valves Data Sheet," 06101/06 STP_M-77u3r32.DOC 06 0215.0810

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT NUMBER STP M-77 REVISION 32 PAGE 6 OF 6 TITLE:

Safety and Relief Valve Testing UNITS 1 AND 2

9.

PRECAUTIONS AND LIMITATIONS None

10.

PREREQUISITES 10.1 The potential for expanded scope should be evaluated and valves chosen to satisfy any additional test requirements prior to test performance.

11.

PROCEDURE 11.1 Pressurizer Safety Valves 11.1.1 Perform testing as detailed in MP M-7.36.

11.2 Main Steam Safety Valves NOTE: One valve per each steam lead can be tested in MODE 1 (Reference Tech Spec 3.7.1).

11.2.1 Perform testing as detailed in MP M-4.9 or MP M-4.18A.

11.2.2 After valve refurbishment, perform testing per MP M-4.9.

11.3 Class 2/3 Relief Valves 11.3.1 11.3.2 Perform relief valve testing as detailed in MP M-51.5.

Test the Spray Additive Tank Vacuum Breakers using a currently calibrated vacuum gage and a vacuum source of sufficient capacity to verify acceptance criteria per step 5.3.1b.

12.

DATA REDUCTION AND EVALUATION 12.1 Test Performer, Test Director and Maintenance Engineer complete and review the following Data Sheets, as appropriate:

12.1.1 12.1.2 12.1.3.5 - Pressurizer Safety Valves Data Sheet..6 - Main Steam Safety Valves Data Sheet..7 - Class 2/3 Relief Valves Data Sheet.

13.

REVIEW AND ROUTING 13.1 Data Sheets shall be placed in RMS and retained for the life of the component.

STP _M-77u3r32.DOC 06 0215.0810

06/01102 DUffiLOCANYONPOWERPLANT STPM-77 ATTACHMENT 8.1 TITLE:

Valves Tested To ASME Class 1 Criteria

1.

Pressurizer Safety Valves (Units 1 & 2)

VALVE 8010A 8010B 8010C

2.

Main Steam Safety Valves VALVE RV-3 RV-4 RV-5 RV-6 RV-7 RV-8 RV-9 RV-10 RV-11 RV-12 RV-13 RV-14 RV-58 RV-59 RV-60 RV-61 RV-222 RV-223 RV-224 RV-225 STP_M-77u3r32.DOC 06 0215.0810 SETPOINT 2485 2485 2485 SETPOINT 1065 1078 1090 1103 1065 1078 1090 1103 1065 1078 1090 1103 1065 1078 1090 1103 1115 1115 1115 1115 ASMECLASS 1

1 1

ASMECLASS 2

2 2

2 2

2 2

2 2

2 2

2 2

2 2

2 2

2 2

2 Page 1 of 1

02115/09 DUillLOCANYONPOWERPLANT STPM-77 ATTACHMENT 8.2 TITLE:

Valves Tested To ASME Class 2/3 Criteria VALVE NO.

GROUP NO.

DESCRIPTION (NOTE 1)

CVCS-8117 NIA PENETRATION 35 (LETDOWN)

RHR-8707 NIA RHR SUCTION RELIEF CS-930 B

SPRAY ADD TANK V AC BKR CS-931 SPRAY ADD TANK V AC BKR CVCS-8121 D

RCP SEAL RET HDR INSIDE CONTAINMENT CVCS-8123 SEAL WATER HX SI-8856A E

RHR DISCH HDR PP 1 SI-8856B RHR DISCH HDR PP 2 RHR-8708 F

RHR DISCH TO HOT LEG SI-8851 SICOLDLEG SI-8858 SI SUCTION RELIEF SI-8853A SIPP 1 DISCH SI-8853B SIPP 2 DISCH CS-8987 NIA SPRAY ADD TANK RELIEF FW-536 H

AFW PP SUCTION FW-537 AFW PP SUCTION SI-8855A J

SI ACCUMULATOR 1 SI-8855B SI ACCUMULATOR 2 SI-8855C SI ACCUMULATOR 3 SI-8855D SI ACCUMULATOR 4 CS-9007A K

CONTMT SPRAY PENETRATION CS-9007B CONTMT SPRAY PENETRATION CVCS-8125 CVCS SUCTION RELIEF STP _M-77u3r32.DOC 06 0215.0810 Page 1 of2 BENCH ASME SETPOINT CLASS (NOTE 2) 600 2

455 2

1.5 in. Hg vac 2

1.5 in. Hg vac 2

150 2

150 2

606 2

606 2

606 2

1750 2

220 2

1750 2

1750 2

10 2

100 3

100 3

700 2

700 2

700 2

700 2

260 2

260 2

220 2

02115/09 STP M-77 (UNITS 1 AND 2)

ATTACHMENT 8.2 TITLE:

Valves Tested To ASME Class 2/3 Criteria VALVE NO.

GROUP NO.

DESCRIPTION (NOTE 1)

CCW-45 P

CCW SURGE TANK CCW-51 RCP LUBE OIL COOLING CCW RELIEF CCW-52 EXCESS LETDOWN HX CCW-46 R

RHRHX 1 CCW-47 RHRHX2 CCW-41 S

RCP THERMAL BARRIER CCW-42 RCPTHERMALBARRIER CCW-43 RCPTHERMALBARRIER CCW-44 RCP THERMAL BARRIER Page 2 of2 BENCH ASME SETPOINT CLASS (NOTE 2) 30 3

150 3

150 2

70 3

70 3

2485 3

2485 3

2485 3

2485 3

NOTE 1: Valves are divided into groups for test purposes. When N/ A is present in this column, valve is unique and is tested on a nominal 48 month frequency.

NOTE 2: Setpoints noted here for convenience only. If a conflict exists between this number and the setpoint listed for the applicable functional location within SAP, the SAP functional location data shall be considered the official setpoint. Setpoints are PSIG unless otherwise noted. SAP functional location history must be used for setpoints of installed components if a setpoint change is in progress (refer to A0431672 for an example of this situation).

STP_M-77u3r32.DOC 06 0215.0810

06/01/06 Page 1 of 1 DIABLO CANYON POWER PLANT STPM-77 ATTACHMENT 8.3 TITLE:

Test Schedule - Valves Tested to Class 1 Criteria REFUELING OUTAGE SERVICE VALVE NO.

8 9

COMMENTS (1) This schedule to repeat in Outage 10 and beyond.

PZR Safety RCS-8010A X

(2) This schedule would satisfy code Valves RCS-8010B X

requirements if current practice (PSV's) changes. Current practice is to RCS-8010C X

change out and test all valves each outage.

Main Steam RV-3 X

(3) This schedule to repeat in Outage 10 Safety Valves RV-4 X

and beyond.

(MSSV's)

(NOTE 1)

RV-5 X

RV-6 X

RV-7 X

RV-8 X

RV-9 X

RV-IQ X

RV-ll X

RV-12 X

RV-13 X

RV-14 X

RV-58 X

RV-59 X

RV-60 X

RV-61 X

RV-222 X

RV-223 X

RV-224 X

RV-225 X

NOTE 1: Testing may be performed in MODES 1 through 6, either pre-outage or post-outage.

STP _M-77u3r32.DOC 06 0215.0810

02/28/08 DUffiLOCANYONPOWERPLANT STPM-77 ATTACHMENT 8.4 TITLE:

Test Schedule - Valves Tested to Class 2/3 Criteria REFUELING OUTAGE NUMBER GROUP VALVE 8

9 10 11 12 13 14 15 16 17 NIA CVCS-8117 X

X X

X X

NIA RHR-8707 X

X X

X X

B CS-930 X*

X*

X*

X*

X*

CS-931 X*

X*

X*

X*

X*

D CVCS-8121 X

X X

CVCS-8123 X

X E

SI-8856A X

X SI-8856B X

X X

STP _ M -77u3r32.DOC 06 0215.0810 Page 1 of3 1

AND 2 18 19 20 21 X

X X

X X*

X*

• (NOTE 1)

X*

X*

• (NOTE 1)

X X

X X

02/28/08 TITLE: Test Schedule - Valves Tested to Class 2/3 Criteria GROUP VALVE 8

9 10 F

RHR-8708 X

SI-8851 X

SI-8858 SI-8853A X*

SI-8853B X*

NIA CS-8987 X*

H FW-536 X

FW-537 X

J SI-8855A X*

SI-8855B X

SI-8855C X

SI-8855D STP _M-77u3r32.DOC 06 0215.0810 STP M-77 (UNITS 1 AND 2)

ATTACHMENT 8.4 REFUELING OUTAGE NUMBER 11 12 13 14 15 16 X

X X

X X

X X

X X*

X*

X*

X X

X X

X X

X X

X Page 2 of3 17 18 19 20 21 X

X X

X X

• (NOTE 2)

X

• (NOTE 2)

X*

X*

X*

• (NOTE 1)

X X

X

• (NOTE 3)

X X

X X

02/28/08 TITLE: Test Schedule - Valves Tested to Class 2/3 Criteria GROUP VALVE 8

9 10 K

CS-9007A X

CS-9007B X

CVCS-8125 X*

P CCW-45 X*

CCW-51 X

CCW-52 X

STP M-77 (UNITS 1 AND 2)

ATTACHMENT 8.4 REFUELING OUTAGE NUMBER 11 12 13 14 15 16 X

X X

X X

X X

X X

X X

X Page 3 of3 17 18 19 20 21 X

X X

X X

• (NOTE 4)

X X

• (NOTE 2)

X X

X R

CCW-46 X

X*

X

• (NOTE 5)

I CCW-47 X

X S

CCW-41 X

X CCW-42 X

X CCW-43 X

CCW-44 X*

X NOTE 1: Testing may be performed in MODES 1 through 6, either pre-outage or post-outage.

NOTE 2: Testing not required for either unit in Outage 8; block is marked for future rotation.

NOTE 3: Testing required for Unit 2 only in Outage 8.

X X

X X

X X

X X

X

• (NOTE 2)

NOTE 4: Testing not required for either unit in Outage 8; block is marked for future rotation. Testing marked for Outage 11 for CVCS-2-RV-8125 was deferred to Outage 12 (A0569796). Testing marked for outage 14 for CVCS-2-RV-8125 is deferred to outage 15 (A0719824). Return CVCS-2-RV-8125 to schedule as shown in outage 17.

NOTE 5: Test marked for Unit One RV-46 is deferred on a one time basis to lR15, Ref. A0695761.

STP _ M-77u3r32.DOC 06 0215.0810

TITLE:

03/23/07 DIABLO CANYON POWER PLANT STPM-77 ATTACHMENT 8.5 Pressurizer Safety Valves Data Sheet Page 1 of 1 WORK ORDER __ _

UNIT REFUELING OUTAGE __

VALVE SERIAL SET-NO.

POINT 8010A 2485 8010 B 2485 8010 C 2485 Test Director:

Valves Acceptable (As Left)

AS FOUND ACCEPT.

RANGE 2411-2542 2411-2542 2411-2542 WORK ORDER AS FOUND Yes __ _

AS LEFT

(+/-1% OF S ETP OINT)

No ---

Valves meet design and functional requirements

• Yes No __ _

PERFORMED BY

• IF all valves are not changed out in any given outage AND this is no, THEN contact Shift Foreman Test Director Date Engineer Review:

Engineer Date STP _M-77u3r32.DOC 06 0215.0810

TITLE:

UNIT VALVE 3

4 5

6 7

8 9

10 11 12 13 14 58 59 60 61 222 223 224 225 03/23/07 DVillLOCANYONPOWERPLANT STP M-77 ATTACHMENT 8.6 Main Steam Safety Valves Data Sheet Page 1 of2 WORK ORDER REFUELING OUTAGE AS FOUND AS LEFT SERIAL SET-ACCEPT.

WORK AS

(+/-1% OF PERFORMED NO.

POINT RANGE ORDER FOUND SETPOINT)

BY 1065 1044-1097 1078 1046-1110 1090 1057-1123 1103 1070-1136 1065 1044-1097 1078 1046-1110 1090 1057-1123 1103 1070-1136 1065 1044-1097 1078 1046-1110 1090 1057-1123 1103 1070-1136 1065 1044-1097 1078 1046-1110 1090 1057-1123 1103 1070-1136 1115 1082-1148 1115 1082-1148 1115 1082-1148 1115 1082-1148 STP _M-77u3r32.DOC 06 0215.0810

03/23/07 STP M-77 (UNITS 1 AND 2)

ATTACHMENT 8.6 TITLE:

Main Steam Safety Valves Data Sheet Test Director:

Valves Acceptable (As Left)

Valves meet design and functional requirements *

• IF no, THEN contact Shift Foreman Test Director Engineer Review:

Engineer STP _M-77u3r32.DOC 06 0215.0810 Yes ---

Yes ---

Page 2 of2 No ---

No ---

Date Date

TITLE:

06/01/06 DIABLO CANYON POWER PLANT STP M-77 ATTACHMENT 8.7 Class 2/3 Relief Valves Data Sheet Page 1 of 1 WORK ORDER ----

UNIT REFUELING OUTAGE NOTE: Summarize testing of relief valves perfonned in the table below:

VALVE NO.

BENCH ACCEPTANCE AS WORK PERFORMED SETPOINT RANGE FOUND

• ORDER BY (PSIG**)

(PSIG**)

(PSIG**)

Continue on additional sheet(s) [ ]

• "As Left" data is not applicable for valves removed from the system; all valves are either refurbished and tested prior to installation by MP M -51.5 or discarded if refurbishment is not feasible.

"As Found" data only is required for this procedure.

• • If data is other than psig, include units in these columns.

The following signatures indicate that all RV testing required this refueling outage (including any scope expansion) is complete.

Test Director Date Engineer Review:

Engineer Date STP _ M-77u3r32.DOC 06 0215.0810

Diablo Canyon Procedure Enclosure PG&E Letter DCL-12-065 MP M-4.1BA, Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest

====================== Cover Sheet======================

Uni t (s) : 1&2 Procedure: MP M-4.18A Revision: 10 Classification: QUALITY RELATED Ti tIe: verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest Level of Use: Periodic Issued For Use By:

Date:

Expires:

Completion of this cover sheet satisfies the requirement to complete the "Issued for Use" banner on the first page of the attached document.

=========================================================

• • • ISSUED FOR USE BY: _________ DATE: _____ EXPIRES: _____ ***

DIABLO CANYON POWER PLANT MECHANICAL MAINTENANCE PROCEDURE UNITS 1 &2 MP M-4.18A Rev. 10 Page 1 of 19

1.

1.1

2.

2.1 2.2

3.

3.1 Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest QUALITY RELATED Table of Contents 03/16/11 Effective Date

1.

SCOPE........................................................................................................... 1

2.

DiSCUSSiON.................................................................................................. 1

3.

REFERENCES............................................................................................... 1

4.

ACCEPTANCE CRITERIA.............................................................................. 2

5.

PREREQUISITES........................................................................................... 2

6.

PRECAUTIONS AND LIMITATIONS.............................................................. 3

7.

INSTRUCTIONS............................................................................................. 4 7.1 Main Steam Safety Test Preparation............................................................... 4 7.2 Trevitest Equipment Pre-Test Calibration........................................................ 5 7.3 Safety Valve Preparation................................................................................ 6 7.4 Trevitest Valve Testing Equipment Setup........................................................ 8 7.5 Main Steam Safety Valve Testing................................................................... 9 7.6 Main Steam Safety Valve Restoration........................................................... 15 7.7 Trevitest Equipment Post-Test Calibration.................................................... 16 7.8 Documentation and Notification.................................................................... 16 ATTACHMENTS:

1.

Main Steam Safety Valve Test Data Record................................................. 17

2.

Calculations.................................................................................................. 19 SCOPE Provide direction for lift point verification of the Main Steam Safety Valves (MSSVs) using the Trevitest System utilized by Furmanite.T3113o DISCUSSION Trevitest System places an external pulling load on the relief valve stem. This overcomes spring forces allowing valve to lift off its seat. Once lift point is reached, the relief valve closes. Lift point is then recorded and becomes a permanent record. Calibration checks are also recorded and placed permanently in the order package.

The Trevitest Mark VIII can measure spindle deflection, (lift potentiometer) or valve discharge J (acoustic detection), as well as inlet pressure (pressure transducer). This is in addition to measuring the spring relaxation force (load cell) that had been available with the Mark V.

REFERENCES AD1.ID2, "Procedure Process Control" MP _M-4!18Au3r10.DOC 0314.0655

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest 3.2 MP M-4.16, "Main Steam Safety Valve Leakby Mitigation" 3.3 OP1. DC20, "Sealed Components" 3.4 OP 0-12, "Operation of Manual Containment Isolation Valves" 3.5 STP M 77, "Safety and Relief Valve Testing" 3.6 Tech Spec 3.7.1, "Main Steam Safety Valves (MSSVs) 3.7 Tech Spec 3.6.3, "Containment Isolation Valves" 3.8 BD M-4.18A, "Basis Document for Main Steam Safety Valve Lift Test" 3.9 Furmanite's Trevitest Operations Manual

4.

ACCEPTANCE CRITERIA 4.1 Acceptance criteria is the satisfactory completion of the applicable parts of the procedure.

5.

PREREQUISITES 5.1 Furmanite's Trevitest operations manual for the test equipment being used (Mark V or Mark VIII) has been approved for use on site PER AD1.ID2.

5.2 Plant shall be in either of the following conditions for testing:

5.2.1 Mode 1, power between 30% and 1000/0 (750 - 820 psig).

5.2.2 Mode 3, Tave at approximately 520°F (750 - 900 psig).

MP M-4.18A R10 Page 2 of 19 UNITS 1&2 Testing outside the indicated pressure may be performed with an engineering evaluation to consider adequate test equipment capacity and adequate valve spring closing force.

MP _M-4! 18Au3r1 O.DOC 0314.0655 1

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest

6.

PRECAUTIONS AND LIMITATIONS MP M-4.18A R10 Page 3 of 19 UNITS 1&2 6.1 Operations shall be notified immediately after any valve lifts outside of the acceptable range provided in Attachment 1.

6.2 This is to allow required actions of Tech Spec 3.7.1 to be met in the required completion time in the event the valve is declared inoperable.

Required actions of Tech Spec 3.7.1 include having I&C reduce the power range high neutron flux trip setpoints.

Only one valve at a time can be tested on each steam generator header.

6.3 To avoid risk of damage to Trevitest equipment, do not exceed recommended working ranges or use it in situations for which it was not designed.

6.4 MSSV lift point verification requires opening of the following containment isolation valves which can only be opened in accordance with OP 0-12:

6.4.1 Header 1 PT-515 Test Connection Valve 1-04P-12A 6.4.2 Header 2 PT-514 Test Connection Valve 2-04P-117 6.4.3 Header 1 PT-524 Test Connection Valve 1-04P-1 00 6.4.4 Header 2 PT-524 Test Connection Valve 2-04P-1 00 6.4.5 Header 1 MS-1-909 6.4.6 Header 1 MS-1-908 6.4.7 Header 2 MS-2-909 6.4.8 Header 2 MS-2-908 6.5 MSSV lift point verification in Mode 1 requires two-way communication between test site and Control Room.

Pager/phone at test site is acceptable.

MP _M-~!18Au3r10.DOC 0314.0655

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest

7.

INSTRUCTIONS 7.1 Main Steam Safety Test Preparation 7.1.1 Recognize that the steps in this section may be performed in any order.

7.1.2 Notify Radiation Protection for any special restrictions on valve discharge before lifting safety valves (required in the event that a primary to secondary leak exists).

7.1.3 Ensure tailboard includes the following:

Ensuring craft persons, contractors and test directors understand critical test points.

Requirement that engineering always be present during actual testing (not necessarily during setup, delays or teardowns).

Persons taking pressure readings are fully informed as to correct method and timing of readings.

Appointed engineer will serve as test director.

Requirements of OP1.DC20 for sealed components.

Requirements of OP 0-12 for containment isolation valves.

7.1.4 Gather required equipment, gauges, fitting, hoses, etc., and assembling test equipment prior to scheduled start of this test.

At the start of testing, 2 sets of calibrated test equipment should be available.

Load cell Digital Trevitest recorder Hydraulic box MP M-4.18A R10 Page 4 of 19 UNITS 1&2 Ensure high accuracy pressure gauges (e.g., Heise) to be used have appropriate ranges for testing.

7.1.5 For tool list, see EDMS/NPG Library/

Maintenance Services/Mechanical MaintenancelT ools IF only one set of calibrated test equipment is available at the start of testing, THEN supervisor authorization shall be obtained prior to testing.

MP _M-4! 18Au3r1 O.DOC 0314.0655

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest NOTE:

Expected lift point is setpoint of valve being tested.

MP M-4.18A R10 Page 5 of 19 UNITS 1&2 CAUTION 1:

Main Steam pressure must be no higher than 100 psi below the valve's expected lift point to ensure rapid closure of safety valve after lifting.

CAUTION 2: !E system pressure approaches a lift setpoint, THEN lifted safety must be immediately closed or testing must be aborted immediately.

7.1.6 Record the following information in order summary:

Pressure gauge number, range and calibration due date.

Temperature gauge number and calibration due date.

7.1.7 Record/SELECT the following information on Attachment 1:

Unit, valve, serial number and order Setpoint, As Found and As Left Acceptance Range 7.1.8 Trevitest to record the following information on their calibration report printout:

Trevitest Recorder serial number Ring gauge size and serial number Load cell serial number and size 7.1.9 Trevitest operator to verify testing equipment is sized properly for valve lifts for Consolidated 3707 Rs prior to testing.

a.

Calculate force required to lift valve using formula on Attachment 2.

b.

Calculate hydraulic pressure setting using formula on Attachment 2.

7.2 Trevitest Equipment Pre-Test Calibration 7.2.1 Perform Pre-Test Calibration PER Furmanite's Trevitest Operations Manual.

a.

Pre-test calibration is required only once per shift at the beginning of the test.

b.

Calibration from the last shift's post-test calibration may be used as the current pre-test calibration.

HOLD POINT:

The following step requires verification on Attachment 1 before continuing this procedure.

7.2.2 Engineer initial indicating pre-test calibration of Trevitest test equipment is complete and acceptable.

MP _M-4!18Au3r10.DOC 0314.0655

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest MP M-4.18A R10 Page 6 of 19 UNITS 1&2 7.3 Safety Valve Preparation 7.3.1 Remove valve cap.

7.3.2 Visually inspect spring as follows:

a.

Check spring for cracks.

b.

Check spring and spindle area for any problems which could bind or interfere with valve operation.

c.

Check general condition of entire valve.

d.

Document inspection on Attachment 1.

7.3.3 Ensure no accumulation of rust, scale, or other foreign substance that could interfere with free operations of valve, is on valve body or in vent piping.

7.3.4 Verify current calibration of test gauges prior to testing.

CAUTION:

7.3.5 CAUTION

7.3.6

a.

Recognize that ranges to be used are as follows:

750 - 820 psig - Mode 1 testing.

750 - 900 psig - Mode 3 testing.

b.

Document verification on Attachment 1.

A voltage drop will occur if more than two 40' leads are used.

Locate Trevitest equipment as far away as necessary from valve being tested.

There is a potential for a momentary bistable trip when valving in test gauges.

Prior to connecting pressure transducer adapters and pressure transducer to Main Steam vent valve or test connection, perform the following:

a.

Prior to installing or valving in test gauges to any pressure tap (Steam leads 1 and 2 only), contact Control Room to verify no coincident bistables are tripped.

b.

Notify SFM that the plant is about to be placed in Tech Spec LCO 3.6.3.

MP _M-4!18Au3r10.DOC 0314.0655

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest MP M-4.18A R10 Page 7 of 19 UNITS 1&2 CAUTION 1 :

There is a potential for a momentary bistable trip when valving in test gauges.

CAUTION 2:

Lines must not be blown out when connecting pressure gauges.

CAUTION 3:

Root valves must not be repositioned closed.

7.3.7 Connect pressure transducer adapters and pressure transducer to Main Steam vent valve or test connection.

a.

Recognize that test gauge should be placed +/-6" from point of attachment to root valve vertically.

NOTE:

Depending on test results, STP M-77 may require testing of additional valves.

b.

IF working on Unit 1, THEN make connections as follows:

1. IE testing valves on Header 1-1,

THEN connect to PT-515 Test Connection Valve 1-04P-12A.

2.

I F testing valves on Header 1-2, THEN connect to PT-524 Test Connection Valve 1-04P-1 00

3.

IF testing valves on Header 1-3, THEN connect to MS-1-909.

a)

Recognize that this valve is a seal closed valve and subject to the requirements of OP1.DC20.

b)

IE vent valve is not available, TH EN use PT -536A.

4.

I F testing valves on Header 1-4, THEN connect to MS-1-90B.

MP _M-4!18Au3r10.DOC 0314.0655 a)

Recognize that this valve is a seal closed valve and subject to the requirements of OP1.DC20.

b)

I F vent valve is not available, THEN use PT-546A.

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest 7.4 NOTE:

Depending on test results, STP M-77 may require testing of additional valves.

c.

IF working on Unit 2, THEN make connections as follows:

1.

IF testing valves on Header 2-1, THEN connect to PT-514 Test Connection Valve 2-04P-117.

2.

IF testing valves on Header 2-2,

THEN connect to PT-524 Test Connection Valve 2-04P-1 00.

3.

IF testing valves on Header 2-3, THEN connect to MS-2-909.

a)

Recognize that this valve is a seal closed valve and subject to the requirements of OP1.DC20.

b)

IF vent valve is not available, THEN use PT-536A.

4. IE testing valves on Header 2-4,

THEN connect to MS-2-90B.

a)

Recognize that this valve is a seal closed valve and subject to the requirements of OP1.DC20.

b)

IF vent valve is not available, THEN use PT-546A.

Trevitest Valve Testing Equipment Setup MP M-4.18A R10 Page 8 of 19 UNITS 1&2

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A

[ ]N/A 7.4.1 Setup testing equipment PER Furmanite's Trevitest Operations Manual.

[]N/A l MP _M-4! 18Au3r1 O.DOC 0314.0655

Verification of Main Steam Safety Valve lift Point with the Furmanite Trevitest 7.5 Main Steam Safety Valve Testing MP M-4.18A R10 Page 9 of 19 UNITS 1&2 7.5.1 Recognize that a separate Attachment 1 is required to be completed for each valve tested.

7.5.2 Before valve is lifted off seat, perform the following:

a.

Notify RP in case primary to secondary leakage requires extra RP measures to be in place on valve discharge.

CAUTION 1 :

Only one valve at a time may be tested on each S/G header.

CAUTION 2:

Trevitest equipment must be post calibration checked at the end of each shift.

This calibration can be used as the pre-test calibration for the next shift.

b.

Obtain permission to test from SFM.

1.

Communicate with Control Room immediately prior to and immediately after testing each valve.

c.

Ensure system pressure is correct as follows:

NOTE 1: Main Steam Relief Valve header pressure is no higher than 900 psig or an engineering evaluation is required.

NOTE 2: Expected lift point is the setpoint of the valve being tested.

1.

Verify Control Room steam header pressure indication is within 5% of test pressure gauge indication.

2.

IF testing in Mode 1, THEN verify system pressure is 750 psig (minimum).

3.

Record system pressure on Attachment 1.

d.

Input into Trevitest database, the following information:

Valve 10 Test Number System Pressure Serial Number

e.

Record valve spring temperature on Attachment 1.

MP _M-4!18Au3r10.DOC 0314.0655

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest

f.

Perform As Found leak tightness check.

MP M-4.1BA R10 Page 10 of 19 UNITS 1&2

1.

Verify seat leakage tightness by audible and/or visual means as described below:

Audible: no simmer or chugging noise.

Visual: no steam vapor emitting from valve discharge.

2.

Document As Found leak tightness on Attachment 1.

3.

IF seat leakage is evident, THEN recognize that engineering is to evaluate via notification.

Evaluation is to consider gagging the affected valve in accordance with MP M-4.16 or reduce main steam line pressure or both prior to lift point testing.

MP _M-4! 18Au3r1 O.DOC 0314.0655

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest 7.5.3 Notify Senior Control Operator (SCO) or Control Operator (CO) that testing is ready to begin.

7.5.4 Ensure Trevitest, set-up is in Ready to Test status.

7.5.5 Lift test valve as follows:

a.

Ensure lift needle valve is open enough to achieve lift as per calculations.

b.

Fully open lower needle valve.

c.

Position lower operated control valve to lift position.

d.

Operate Trevitest equipment to lift valve spindle.

1.

Exercise care when using low forces to ensure that hydraulic pressure regulator is set correctly.

2.

I F valve sticks OR stays open after lifting TH EN immediately perform the following:

a)

Stop test.

b)

Apply hydraulic force to open valve beyond point of sticking, then quickly release hydraulic pressure.

3. IE valve sticks OR stays open after lifting THEN perform the following:

a)

Notify SFM that valve remained open after lifting.

b)

Obtain permission to continue with test from SFM.

e.

Observe graph or trace being produced.

When lift force, and acoustic detection if used, have been recorded, release control valve lever. It automatically returns to neutral position.

f.

Record data from test on Attachment 1.

NOTE:

Lift point must be calculated/verified using lift point formula on.

MP _M-4!18Au3r10.DOC 0314.0655 MP M-4.18A R10 Page 11 of 19 UNITS 1&2

[ ]N/A

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest 7.5.6 Perform 2 lifts starting with step 7.5.4 before making any valve compression screw adjustments..

a.

Recognize the following:

A five minute duration is required between lifts.

A minimum of 2 verification lifts within As Left specifications are required to comply with ASME Code testing requirements.

No adjustment is permitted between verification lifts.

Additional verification lifts may be performed at engineering test director's discretion to confirm the setpoint is within As Left specifications.

Two lifts are required to provide data for evaluating seat sticking.

Mark V bridge voltage will tend to fluctuate during testing but it should not affect test results if within 0.030" of pre calibration bridge voltage.

MP M-4.18A R10 Page 12 of 19 UNITS 1&2 CAUTION:

Delay in notifying SFM for lifts that are not within specifications of Attachment 1 could cause tech spec requirements not to be met.

b.

IF first lift is not within As Found specifications (see ),

THEN perform the following:

1.

Immediately notify SFM.

2.

Create a notification.

3.

Document out of specification condition on.

MP _M-4!18Au3r10.DOC 0314.0655

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest

c.

IE second lift is not within As Left specifications (see ),

THEN perform the following:

1.

IF NOT already performed for the valve being tested, THEN perform the following:

a)

Immediately notify SFM.

b)

Create a notification.

2.

Prior to making adjustments to MSSV, ensure test equipment (see step 7.5.4) and MSSV are functioning properly.

NOTE:

For MSSV compression screw, there is approximately 15 +/-5 psig per flat of adjustment.

3.

Adjust compression screw and retest valve starting with step 7.5.4.

4.

Following adjustment, tighten adjusting nut/locknut assembly prior to any additional testing.T35414

d.

Document As Left leak tightness Attachment 1.

1.

Verify seat leakage tightness by audible and/or visual means as described below:

Audible: no simmer or chugging noise.

MP M-4.18A R10 Page 13 of 19 UNITS 1&2

[ ]N/A Visual: no steam vapor emitting from valve discharge.

MP _M-4!18Au3r10.DOC 0314.0655

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest NOTE:

At engineer's discretion, leaking valves may have their setpoint re-established to a higher value within Acceptance Range.

e.

Recognize that MSSVs that leak after testing shall have their lift point setting reanalyzed by test director and a notification is to be initiated.

f.

IF test results become suspect indicating unusual behavior, THEN stop test and evaluate as follows:

1.

Do not make excessive (more than three flats) adjustments without thoroughly verifying equipment and valve are functioning properly.

2.

Based on prior As Left data, check that adjustments are reasonable and valve is responding in a predictable manner.

3.

Verify test connections are correct and test equipment is responding correctly.

IF suspect, THEN use backup test equipment to proceed with verification of test results.

4.

Perform a post calibration check PER Section 7.7 at the first opportunity.

NOTE:

Engineer is to determine whether continued valve lifting will affect lift point setting or whether valve is damaged making lift point setting indeterminate.

7.5.7 Notify seo or CO that:

Setpoints have been established.

Test is complete.

7.5.8 Remove Trevitest equipment from valve.

Perform post calibration check PER Section 7.7 after each shift.

NOTE:

This post calibration check can be the pre-test calibration for the following shift.

MP _M-4! 18Au3r1 O.DOC 0314.0655 MP M-4.18A R10 Page 14 of 19 UNITS 1&2

[ ]N/A

[ ]N/A

Verification of Main Steam Safety Valve lift Point with the Furmanite Trevitest 7.6 Main Steam Safety Valve Restoration MP M-4.18A R10 Page 15 of 19 UNITS 1&2 CAUTION 1 :

There is a potential for a momentary bistable trip when valving in test gauges.

Prior to removing or valving out test gauges to any pressure tap (steam leads 1 and 2 only), Control Room must be notified to verify no coincident bistables are tripped.

CAUTION 2:

Lines must not be blown out when connecting pressure gauges.

CAUTION 3:

Root valves must not be repositioned closed.

7.6.1 Recognize the following test connection restoration requirements:

After all safety valves on a header have been tested, the test connections shall be disconnected and the caps reinstalled.

Independent verification of test gauge removal is required to be documented on Attachment 1 (test data record).

I F test connections are needed for testing of additional safety valves on a header, THEN record on Attachment 1 which safety valve test data record will document the independent verification of test gauge removal.

7.6.2 Check tightness of compression locknut.T35414 7.6.3 Install valve cap and lead seal.

NOTE:

Sealing may be accomplished by Furmanite or the company.

7.6.4 Complete Attachment 1 and forward to engineer for review.

7.6.5 At the end of testing, have all pressure gauges rechecked for range calibration.

a.

Calibration check should be made at pressures within 10 psig of line pressure used during testing.

MP _M-4! 18Au3r1 O.DOC 0314.0655

[ ]N/A

Verification of Main Steam Safety Valve Lift Point with the Furmanite Trevitest 7.7 Trevitest Equipment Post-Test Calibration 7.7.1 Perform Post-Test Calibration PER Furmanite's Trevitest Operations Manual at the end of each shift. This calibration may be used as the pre-test calibration for the next shift.

7.7.2 All discrepancies noted in the post calibration verification will be resolved prior to accepting test results.

7.7.3

a.

IF any post calibration test fails, THEN notify engineering.

IF retesting is required, THEN SFM will be notified and retesting started as soon as possible.

HOLD POINT:

The following step requires verification on Attachment 1 before completing this procedure.

7.7.4 Post calibration of Trevitest test equipment is complete and acceptable.

7.8 Documentation and Notification 7.8.1 Appointed engineer, will serve as test director, and shall ensure:

a.

Test results are signed and dated thereby verifying, to the best of his/her knowledge, their accuracy, and that the test was conducted per this procedure.

b.

Instrumentation used in testing has not exceeded its calibration period.

c.

Test results are fully documented on STP M-77 data sheets, as required, and are forwarded to work planner for package/surveillance test procedure closeout.

d.

Test results and recommendations relating to test or equipment are summarized in order.

7.8.2 Verify acceptance criteria met and documentation complete; e.g., signoffs, data, and N/As have been entered as appropriate.

MP _M-4!18Au3r10.DOC 0314.0655 MP M-4.18A R10 Page 16 of 19 UNITS 1&2

[ ]N/A

[ ]N/A

MP M-4.1BA R10 Page 17 of 19 Main Steam Safety Valve Test Data Record U 1 &2 Attachment 1: Page 1 of 2 Unit ---

RV ____ Serial Number _____ _

Order --------

1.

'step 7.1.7)

Test Criteria Acceptable Acceptable RV Setpoint As Found (PSIG)

As Left (PSIG)

(PSIG)

Min Max Min Max

[ ] 3, 7, 11, 58 1065 1044 1097 1054 1076

[ ] 4, 8, 12, 59 1078 1046 1110 1067 1089

[ ] 5, 9, 13, 60 1090 1057 1123 1079 1101

[ ]6,10,14,61 1103 1070 1136 1092 1114

[ ]222,223,224,225 1115 1082 1148 1104 1126

2.

Test Equipment Pre-Calibration

a.

Trevitest Equipment Calibration Acceptable Initials ___ Date ___ (step 7.2.2)

b.

Plant Equipment Calibration Acceptable Initials ___ Date ___ (step 7.3.4)

3.

Test Conditions

a.

Mode ---

b.

Control Room Average Line Pressure PSIG (PPC@SGPRESS) (step 7.5.2c)

c.

Valve Spring Temperature (OF) (step 7.5.2e)

d.

Spring visually inspected and there are no apparent cracks.

(step 7.3.2a)

Initials --

e.

As Found leak tightness acceptable YES[ ] NO[ ] (step 7.5.2f)

4.

Operations Contacted and Testing Approved Initials ___ (step 7.5.3)

MP _M-4!18Au3r10.DOC 0314.0655

Main Steam Safety Valve Test Data Record

5.

Test Results (step 7.5.5f)

Lift 1

Line Pressure (PSIG)

Assist Force

(% of L.C.)

MP M-4.18A R10 Page 18 of 19 U 1 &2 Attachment 1: Page 2 of 2 Lift Point (PSIG)

Adjustment (Flats)

(-) = CCW

(+) = CW (7.5.6)

Notification Required YES[ ] NO[ ]

Notification Number:

(7.5.6b) 2 3

4 5

6 7

8 9

10

6.

As Left leak tightness acceptable YES[ ] NO[ ] (step 7.5.6d)

7.

Operations Notification of Test Results Initials ___ (step 7.5.7)

8.

Test Gauge Removal

[ ]N/A - See Test Report for RV __ (step 7.6.1)

a.

Test Gauge Isolation Valve Number _____

[ ] Cap Installed

b.

Removed By: ___ ~

Date Time

c.

Verified By: ___________ _

Date Time

9.

Test Equipment Post Calibration Plant Equipment Initials ----

Date ____ (step 7.6.5)

Trevitest Equipment Initials ----

Date ____ (Section 7.7)

Test Director:

Date:

Engineering Review: ________________ _

Date: -------

MP _M-4!18Au3r10.DOC 0314.0655

Calculations MP M-4.18A R10 Page 19 of 19 U 1 &2 Attachment 2: Page 1 of 1 For this procedure, data may be rounded to the least significant digit in the MSSV setpoint calculation.

Data for the calculation may have digits to the right of the decimal point and mayor may not be used in determining the final answer. However, the final answer will be rounded off to the least significant digit (e.g., 1065.4 is 1065, 1065.5 is 1066, 1065.6 is 1066, etc.).

When using a calculator that is set to display digits to the right of the decimal point, rounding off will be as described above. If the calculator is set to display no digits to the right of the decimal point, then rounding off will be automatic, in either case the above is held constant.

Force Required to Lift Valve The force required to lift the valve is provided by the pressure stored in the hydraulic unit.

On-line or "hot" lifting is where the system applies the differential forces between the available line pressure and the set pressure.

Fs = Pressure Differential x Mean Seat Area (MSA)

= (Ps - PL) x MSA Where Fs = Force of Load Cell Ps = Set Pressure of Valve PL = Line Pressure/System Pressure This is applicable whenever there is pressure on the underside of the valve acting on the seating area.

In "cold" lift situations the system applies the total force between zero and the set pressure or:

Fs = Ps x MSA In finding the value of Fs, it allows one to choose the proper load cell needed for testing. It should be noted that the force is the ideal force needed if the valve is properly set.

Hydraulic Pressure Setting The lift force is provided by the hydraulic unit, therefore, the pressure setting of the hydraulic unit must be determined.

Where Rv = Hydraulic Pressure Setting RA = Ram Area Used (usually 2.76 in2) x 1.25 RA 1.25 = Factor to Overcome Friction/Expansion Lift Point Trevitest Mark V Trevitest Mark VIII

[(Lc) (OloFS)] - W Lo Lift Point =

+ PL Lift Point =

+ PL MSA MSA PL = Line Pressure, PSI (from test gauge)

PL = Line Pressure, PSI (from test gauge)

Lc = Load Cell, Ib Lo = Opening Load, Ib,

°loFS = Percent of Full Scale - Chart Recorder from Mark VIII Recorder W = Weight of Piston/RAM, Ib MSA = Mean Seat Area of 23.046 in2 MSA = Mean Seat Area of 23.046 in2 MP _M-4!18Au3r10.DOC 0314.0655

Enclosure PG&E Letter DCL-12-065 Summary of MSSV Test Data for Unit 1

Date Lead I Set As As As Tested Valve Point Found Found Found No.

(psig)

Min Max Lift 1 (psig)

(psig)

(psig) 6/25/1997 Lead 3 11 1065 1044 1097 1068 12 1078 1046 1110 1089 13 1090 1057 1123 1105 14 1103 1070 1136 1125 224 1115 1082 1148 1129 6/26/1997 Lead 4 58 1065 1044 1097 1071 59 1078 1046 1110 1088 60 1090 1057 1123 1082 61 1103 1070 1136 1120 225 1115 1082 1148 1112 8/26/1997 Lead 1 3

1065 1044 1097 1060 4

1078 1046 1110 1085 5

1090 1057 1123 1096 6

1103 1070 1136 1100 222 1115 1082 1148 1139 8/27/1997 Lead 2 7

1065 1044 1097 1069 8

1078 1046 1110 1092 9

1090 1057 1123 1097 10 1103 1070 1136 1108 223 1115 1082 1148 1145 8/28/1997 Lead 3 11 1065 1044 1097 1049 12 1078 1046 1110 1087 13 1090 1057 1123 1088 14 1103 1070 1136 1104 224 1115 1082 1148 1117 8/28/1997 Lead 4 58 1065 1044 1097 1067 59 1078 1046 1110 1080 60 1090 1057 1123 1089 61 1103 1070 1136 1104 225 1115 1082 1148 1109 1/20/1998 Lead 1 3

1065 1044 1097 1062 2

As Enclosure PG&E Letter DCL-12-065 As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP 0.3%

1056

-0.8%

0.0 1.0%

1079 0.1%

0.0 1.4%

1097 0.6%

0.0 2.0%

1110 0.6%

-2.0 1.3%

1117 0.2%

0.0 0.6%

1066 0.1%

0.0 0.9%

1084 0.6%

0.0

-0.7%

1090 0.0%

1.0 1.5%

1107 0.4%

0.0

-0.3%

1108

-0.6%

0.0

-0.5%

1061

-0.4%

0.0 0.6%

1072

-0.6%

-1.0 0.6%

1092 0.2%

0.0

-0.3%

1101

-0.2%

2.0 2.2%

1117 0.2%

-2.5 0.4%

1070 0.5%

-1.5 1.3%

1078 0.0%

-2.0 0.6%

1079

-1.0%

0.0 0.5%

1100

-0.3%

1.5 2.7%

1122 0.6%

-2.5

-1.5%

1064

-0.1%

1.0 0.8%

1076

-0.2%

0.0

-0.2%

1095 0.5%

0.0 0.1%

1105 0.2%

0.0 0.2%

1117 0.2%

0.0 0.2%

1069 0.4%

0.0 0.2%

1079 0.1%

0.0

-0.1%

1084

-0.6%

0.0 0.1%

1105 0.2%

0.0

-0.5%

1113

-0.2%

0.0

-0.3%

1061

-0.4%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 4 1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 1/21/1998 Lead 2 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 7/24/1998 Lead 3 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 7/24/1998 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 1/20/1999 Lead 1 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 1/20/1999 Lead 2 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 1/21/1999 Lead 3 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 3

As Found Lift 1 (psig) 1074 1093 1104 1116 1063 1069 1085 1104 1125 1069 1088 1105 1106 1125 1056 1078 1092 1106 1106 1060 1086 1108 1115 1122 1062 1083 1097 1128 1122 1079 1085 1112 1110 Enclosure PG&E Letter DCL-12-065 As As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP

-0.4%

1070

-0.7%

0.0 0.3%

1092 0.2%

0.0 0.1%

1106 0.3%

0.0 0.1%

1123 0.7%

0.0

-0.2%

1063

-0.2%

0.0

-0.8%

1073

-0.5%

0.0

-0.5%

1086

-0.4%

0.0 0.1%

1097

-0.5%

0.0 0.9%

1121 0.5%

0.0 0.4%

1068 0.3%

0.0 0.9%

1076

-0.2%

-0.5 1.4%

1098 0.7%

0.0 0.3%

1105 0.2%

0.0 0.9%

1123 0.7%

0.0

-0.8%

1060

-0.5%

0.0 0.0%

1076

-0.2%

0.0 0.2%

1084

-0.6%

0.0 0.3%

1108 0.5%

0.0

-0.8%

1106

-0.8%

0.0

-0.5%

1054

-1.0%

0.0 0.7%

1072

-0.6%

0.0 1.7%

1098 0.7%

0.0 1.1%

1109 0.5%

0.0 0.6%

1122 0.6%

0.0

-0.3%

1066 0.1%

0.0 0.5%

1074

-0.4%

0.0 0.6%

1092 0.2%

0.0 2.3%

1108 0.5%

-1.0 0.6%

1124 0.8%

0.0 1.3%

1076 1.0%

0.0 0.6%

1082 0.4%

0.0 2.0%

1100 0.9%

0.0 0.6%

1108 0.5%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 224 1115 1082 1148 1/21/1999 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 9/12/2000 Lead 1 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 9/13/2000 Lead 2 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 9/14/2000 Lead 3 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 9/14/2000 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 4/4/2002 Lead 3 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 4/5/2002 Lead 4 4

As Found Lift 1 (psig) 1134 1067 1075 1113 1123 1112 1068 1079 1104 1126 1131 1060 1074 1084 1113 1106 1087 1084 1119 1109 1137 1064 1093 1114 1110 1108 1064 1085 1106 1110 1129 As Enclosure PG&E Letter DCL-12-065 As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP 1.7%

1121 0.5%

0.0 0.2%

1067 0.2%

0.0

-0.3%

1069

-0.8%

0.0 2.1%

1095 0.5%

0.0 1.8%

1113 0.9%

-1.0

-0.3%

1119 0.4%

0.0 0.3%

1075 0.9%

0.0 0.1%

1068

-0.9%

0.0 1.3%

1094 0.4%

0.5 2.1%

1102

-0.1%

-1.0 1.4%

1122 0.6%

0.0

-0.5%

1062

-0.3%

0.0

-0.4%

1071

-0.6%

0.0

-0.6%

1090 0.0%

0.0 0.9%

1103 0.0%

0.0

-0.8%

1112

-0.3%

0.0 2.1%

1075 0.9%

0.0 0.6%

1081 0.3%

0.0 2.7%

1093 0.3%

-1.0 0.5%

1104 0.1%

0.0 2.0%

1115 0.0%

-1.0

-0.1%

1059

-0.6%

0.0 1.4%

1084 0.6%

-0.5 2.2%

1099 0.8%

0.0 0.6%

1105 0.2%

0.0

-0.6%

1109

-0.5%

0.0

-0.1%

1060

-0.5%

0.0 0.6%

1079 0.1%

0.0 1.5%

1094 0.4%

0.0 0.6%

1109 0.5%

0.0 1.3%

1121 0.5%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 2/17/2004 Lead 1 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 2/18/2004 Lead 2 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 9/20/2005 Lead 3 11 1065 1044 1097 12 1078 1046 1110 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 9/21/2005 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 3/28/2007 Lead 1 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 3/28/2007 Lead 2 7

1065 1044 1097 8

1078 1046 1110 5

As Found Lift 1 (psig) 1068 1080 1115 1106 1105 1074 1070 1113 1102 1110 1072 1072 1083 1093 1121 1063 1076 1079 1116 1118 1141 1066 1067 1090 1121 1101 1065 1089 1119 1078 1120 1066 1096 Enclosure PG&E Letter DCL-12-065 As As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP 0.3%

1058

-0.7%

0.0 0.2%

1075

-0.3%

0.0 2.3%

1093 0.3%

-0.5 0.3%

1105 0.2%

0.0

-0.9%

1106

-0.8%

0.0 0.8%

1071 0.6%

0.0

-0.7%

1067

-1.0%

1.0 2.1%

1092 0.2%

-0.5

-0.1%

1094

-0.8%

-1.0

-0.4%

1106

-0.8%

0.0 0.7%

1063

-0.2%

0.0

-0.6%

1085 0.6%

0.5

-0.6%

1088

-0.2%

0.0

-0.9%

1096

-0.6%

0.0 0.5%

1117 0.2%

0.0

-0.2%

1062

-0.3%

0.0

-0.2%

1080 0.2%

0.0 0.1%

1088 0.9%

1.0 2.4%

1092 0.2%

0.0 1.4%

1101

-0.2%

0.0 2.3%

1117 0.2%

-0.5 0.1%

1057

-0.8%

0.0

-1.0%

1080 0.2%

1.0 0.0%

1097 0.6%

0.0 1.6%

1109 0.5%

0.0

-1.3%

1106

-0.8%

0.8 0.0%

1066 0.1%

0.0 1.0%

1080 0.2%

0.0 2.7%

1090 0.0%

-1.5

-2.3%

1096

-0.6%

1.0 0.4%

1117 0.2%

0.0 0.1%

1075 0.9%

0.0 1.7%

1082 0.4%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 9 1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 12/11/2008 Lead 3 11 1065 1044 1097 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 12/11/2008 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 8/1712010 Lead 1 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 8/18/2010 Lead 2 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 3/6/2012 Lead 3 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 3/8/2012 Lead 4 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 6

As Found Lift 1 (psig) 1089 1098 1120 1057 1062 1070 1104 1113 1119 1070 1091 1112 1118 1092 1074 1102 1082 1117 1116 1078 1095 1085 1115 1115 1099 1070 1117 1123 1126 1076 1095 1129 1122 Enclosure PG&E Letter DCL-12-065 As As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP

-0.1%

1084

-0.6%

0.0

-0.5%

1100

-0.3%

0.0 0.4%

1115 0.0%

0.0

-0.8%

1063

-0.2%

1.0

-0.3%

1064

-0.1%

0.5

-0.7%

1073

-0.5%

0.0 1.3%

1092 0.2%

0.0 0.9%

1109 0.5%

0.0 0.4%

1112

-0.3%

0.0 0.5%

1062

-0.3%

0.0 1.2%

1081 0.3%

0.0 2.0%

1092 0.2%

0.0 1.4%

1114 1.0%

0.0

-2.1%

1104

-1.0%

0.0 0.8%

1070 0.5%

0.0 2.2%

1087 0.8%

0.0

-0.7%

1098 0.7%

1.0 1.3%

1096

-0.6%

0.0 0.1%

1110

-0.4%

0.0 1.2%

1072 0.7%

0.0 1.6%

1080 0.2%

0.0

-0.5%

1082

-0.7%

0.0 1.1%

1094

-0.8%

0.0 0.0%

1110

-0.4%

0.0 3.2%

1076 1.0%

-1.0

-0.7%

1089 1.0%

0.0 2.5%

1100 0.9%

0.0 1.8%

1104 0.1%

0.0 1.0%

1124 0.8%

0.0 1.0%

1067 0.2%

0.0 1.6%

1077

-0.1%

0.0 3.6%

1092 0.2%

-1.5 1.7%

1105 0.2%

-0.5

Date Lead I Set As As As Tested Valve Point Found Found Found No.

(psig)

Min Max Lift 1 (psig)

(psig)

(psig) 225 1115 1082 1148 1095 3/9/2012 Lead 2 (expanded 8

1078 1046 1110 1091 Scope) 9 1090 1057 1123 1076 Did not test 10 1103 1070 1136 1108 RV-7 223 1115 1082 1148 1112 Unit 1 Summary 166 MSSVs Tests 36 Tests As Left Adjusted 23 Tests As Found greater than or equal to 2 percent As Enclosure PG&E Letter DCL-12-065 As As Left Flats Found Left

%SP Adjust Drift (psig)

%SP

-1.8%

1109

-0.5%

1.5 1.2%

1073

-0.5%

0.0

-1.3%

1089

-0.1%

1.0 0.5%

1101

-0.2%

0.0

-0.3%

1107

-0.7%

0.0 2 Tests As Found Out of Tolerance greater than or equal to 3 percent 7

Enclosure PG&E Letter DCL-12-065 Summary of MSSV Test Data for Unit 2

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psi g)

(psig)

Lead 3 7/22/1998 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 Lead 4 7/22/1998 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 Lead 1 12/2/1998 3

1065 1044 1097 1/18/1999 3

1065 1044 1097 1/18/1999 4

1078 1046 1110 1/18/1999 5

1090 1057 1123 1/18/1999 6

1103 1070 1136 1/18/1999 222 1115 1082 1148 Lead 2 12/2/1998 7

1065 1044 1097 1/19/1999 7

1065 1044 1097 12/2/1998 8

1078 1046 1110 1/19/1999 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 Lead 1 9/8/1999 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 Lead 2 9/9/1998 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 2

As Found Lift 1 (psig) 1061 1080 1095 1104 1107 1063 1066 1075 1110 1102 1056 1074 1099 1067 1117 1116 1039 1086 1059 1096 1078 1104 1143 1080 1086 1108 1103 1137 1073 1084 1087 1092 1119 As Enclosure PG&E Letter DCL-12-065 As Left As Left Flats Found (psig)

%SP Adjust Drift

%SP

-0.4%

1058

-0.7%

0.0 0.2%

1073

-0.5%

0.0 0.5%

1096 0.6%

1.0 0.1%

1097

-0.5%

0.0

-0.7%

1111

-0.4%

1.0

-0.2%

1065 0.0%

1.3

-1.1%

1081 0.3%

1.5

-1.4%

1094 0.4%

1.5 0.6%

1103 0.0%

1.0

-1.2%

1108

-0.6%

1.0

-0.8%

1062

-0.3%

1.5 0.8%

1068 0.3%

0.0 1.9%

1087 0.8%

0.0

-2.1%

1088

-0.2%

3.0 1.3%

1100

-0.3%

0.0 0.1%

1122 0.6%

1.0

-2.4%

1067 0.2%

3.0 2.0%

1074 0.8%

-1.0

-1.8%

1074

-0.4%

1.5 1.7%

1089 1.0%

0.0

-1.1%

1096 0.6%

1.0 0.1%

1096

-0.6%

0.0 2.5%

1122 0.6%

0.0 1.4%

1072 0.7%

-0.5 0.7%

1087 0.8%

-1.0 1.7%

1087

-0.3%

-1.0 0.0%

1106 0.3%

0.0 2.0%

1113

-0.2%

-1.0 0.8%

1057

-0.8%

-0.8 0.6%

1081 0.3%

-0.3%

1087

-0.3%

-1.0%

1099

-0.4%

1.3 0.4%

1115 0.0%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig)

Lead 3 9/9/1998 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 Lead 4 9/10/1999 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 Lead 1 3/28/2001 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 Lead 2 3/29/2001 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 Lead 3 1/22/2003 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 Lead 4 1/22/2003 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 Lead 1 1/23/2003 3

1065 1044 1097 3

As Found Lift 1 (psig) 1087 1065' 1115 1112 1112 1064 1071 1103 1096 1115 1072 1078 1108 1100 1117 1069 1080 1075 1098 1119 1099 1101 1127 1100 1116 1057 1070 1074 1095 1122 1076 Enclosure PG&E Letter DCL-12-065 As As Left As Left Flats Found (psig)

%SP Adjust Drift

%SP 2.1%

1073 0.8%

0.0

-1.2%

1072

-0.6%

2.0 2.3%

1092 0.2%

-1.0 0.8%

1113 0.9%

0.0

-0.3%

1113

-0.2%

0.0

-0.1%

1057

-0.8%

0.0

-0.6%

1080 0.2%

0.0 1.2%

1093 0.3%

-2.0

-0.6%

1102

-0.1%

0.0 0.0%

1112

-0.3%

0.0 0.7%

1064

-0.1%

-1.0 0.0%

1073

-0.5%

0.0 1.7%

1088

-0.2%

0.0

-0.3%

1108 0.5%

0.0 0.2%

1119 0.4%

0.0 0.4%

1068 0.3%

0.0 0.2%

1087 0.8%

0.0

-1.4%

1081

-0.8%

0.0

-0.5%

1103 0.0%

0.0 0.4%

1117 0.2%

0.0 3.2%

1074 0.8%

-1.5 2.1%

1082 0.4%

-0.5 3.4%

1082

-0.7%

-1.0

-0.3%

1093

-0.9%

0.0 0.1%

1108

-0.6%

0.0

-0.8%

1054

-1.0%

0.0

-0.7%

1071

-0.6%

0.0

-1.5%

1085

-0.5%

1.5

-0.7%

1098

-0.5%

0.0 0.6%

1109

-0.5%

0.0 1.0%

1070 0.5%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 4 1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 Lead 2 1/24/2003 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 Lead 1 9/21/2004 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 Lead 2 9/22/2004 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 Lead 3 3/21/2006 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 Lead 4 3/22/2006 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 Lead 1 12/11/2007 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 4

As Found Lift 1 (psig) 1082 1096 1122 1121 1066 1095 1079 1097 1127 1072 1078 1091 1099 1110 1070 1079 1093 1079 1111 1057 1090 1105 1105 1112 1085 1072 1088 1113 1127 1061 1086 1093 1113 As Enclosure PG&E Letter DCL-12-065 As Left As Left Flats Found (psig)

%SP Adjust Drift

%SP 0.4%

1080 0.2%

0.0 0.6%

1084

-0.6%

0.0 1.7%

1103 0.0%

-0.5 0.5%

1113

-0.2%

-0.5 0.1%

1064

-0.1%

0.0 1.6%

1088 0.9%

-0.8

-1.0%

1083

-0.6%

0.5

-0.5%

1098

-0.5%

0.0 1.1%

1122 0.6%

0.0 0.7%

1075 0.9%

-0.5 0.0%

1068

-0.9%

0.0 0.1%

1086

-0.4%

0.5

-0.4%

1106 0.3%

0.5

-0.4%

1112

-0.3%

0.0 0.5%

1061

-0.4%

0.0 0.1%

1071

-0.6%

0.0 0.3%

1083

-0.6%

0.5

-2.2%

1095

-0.7%

1.5

-0.4%

1109

-0.5%

0.0

-0.8%

1062

-0.3%

0.0 1.1%

1070

-0.7%

0.0 1.4%

1089

-0.1%

1.0 0.2%

1095

-0.7%

0.0

-0.3%

1109

-0.5%

0.0 1.9%

1061

-0.4%

0.0

-0.6%

1072

-0.6%

0.0

-0.2%

1083

-0.6%

0.0 0.9%

1095

-0.7%

0.0 1.1%

1115 0.0%

0.0

-0.4%

1061

-0.4%

0.0 0.7%

1068

-0.9%

0.0 0.3%

1086

-0.4%

0;0 0.9%

1102

-0.1%

0.0

Date Lead I Set As As Tested Valve Point Found Found No.

(psig)

Min Max (psig)

(psig) 222 1115 1082 1148 Lead 2 12/12/2007 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 Lead 3 8/2512009 11 1065 1044 1097 12 1078 1046 1110 13 1090 1057 1123 14 1103 1070 1136 224 1115 1082 1148 Lead 4 8/27/2009 58 1065 1044 1097 59 1078 1046 1110 60 1090 1057 1123 61 1103 1070 1136 225 1115 1082 1148 Lead 1 8/28/2009 6

1103 1070 1136 222 1115 1082 1148 Lead 1 3/22/2011 3

1065 1044 1097 4

1078 1046 1110 5

1090 1057 1123 6

1103 1070 1136 222 1115 1082 1148 Lead 2 3/24/2011 7

1065 1044 1097 8

1078 1046 1110 9

1090 1057 1123 10 1103 1070 1136 223 1115 1082 1148 5

As Found Lift 1 (psig) 1112 1058 1086 1083 1099 1112 1080 1103 1118 1090 1036 1086 1091 1119 1127 1134 1129 1116 1071 1077 1104 1119 1096 1084 1101 1110 1118 1126 As Enclosure PG&E Letter DCL-12-065 As Left As Left Flats Found (psig)

%SP Adjust Drift

%SP

-0.3%

1110

-0.4%

0.0

-0.7%

1058

-0.7%

0.0 0.7%

1081 0.3%

0.0

-0.6%

1079

-1.0%

0.0

-0.4%

1097

-0.5%

0.0

-0.3%

1114

-0.1%

0.0 1.4%

1062

-0.3%

0.0 2.3%

1075

-0.3%

0.0 2.6%

1089

-0.1%

0.0

-1.2%

1106 0.3%

1.3

-7.1%

Gag 6.0 2.0%

1059

-0.6%

0.0 1.2%

1085 0.6%

1.3 2.7%

1090 0.0%

-0.5 2.2%

1098

-0.5%

0.0 1.7%

1110

-0.4%

0.0 2.4%

1104 0.1%

0.0 0.1%

1116 0.1%

1.0 0.6%

1071 0.6%

0.0

-0.1%

1078 0.0%

2.0 1.3%

1093 0.3%

1.0 1.5%

1104 0.1%

0.0

-1.7%

1114

-0.1%

2.0 1.8%

1071 0.6%

0.0 2.1%

1069

-0.8%

0.0 1.8%

1086

-0.4%

0.0 1.4%

1111 0.7%

0.0 1.0%

1120 0.4%

0.0

Unit 2 Summary 125 MSSV Tests 46 Tests As Left Adjusted 19 Tests As Found greater than or equal to 2 percent Enclosure PG&E Letter DCL-12-065 3 Tests As Found out of Tolerance greater than or equal to 3 percent 6