ML14353A441

Submittal of Revision 32 of Callaway Pump and Valve Inservice Testing Program

ML14353A441
Person / Time
Site:	Callaway
Issue date:	12/19/2014
From:	Maglio S Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06166
Download: ML14353A441 (95)

Text

~'t.

~Ameren MISSOURI Callaway Plant December 19,2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

ULNRC-06166 10 CFR 50.55a DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 SUBMITTAL OF REVISION 32 OF CALLA WAY PUMP AND VALVE INSERVICE TESTING PROGRAM Union Electric Company (Ameren Missouri) hereby submits Revision 32 of the Callaway Pump and Valve Inservice Testing (1ST) Program. This revision, included as an attachment to this letter, is provided for your information in accordance with regularly provided updates of the Callaway 1ST Program.

Revision 32 of the 1ST Program was primarily developed for implementation of the fourth 10-year inservice testing interval at Callaway, for which the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition (through OMb-2006 Addenda) is applicable. Included in the attached revision of the 1ST program are the 10 CFR 50.55a requests (Relief Requests) that have been approved to date by the NRC for the fourth 1 0-year 1ST interval. Callaway's fourth 1 0-year 1ST interval begins on December 20, 2014, and will conclude on December 19,2024.

This letter does not contain any new commitments. If there are any questions, please contact me at 573-676-8719 or Jim Kovar at 314-225-1478.

Sincerely,

~~~;li~

Manager-Regulatory Affairs PO Box 620 Fulton, MO 65251 AmerenMissouri.com STARS

• Alliance

ULNRC-06166 December 19,2014 Page2 JPK/nls

Attachment:

Callaway Nuclear Plant Inservice Testing Program, Revision 32

ULNRC-06166 December 19, 2014 Page 3 cc:

Mr. Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-06166 December 19,2014 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

F. M. Diya D. W. Neterer L. H. Graessle T. E. Herrmann B.L.Cox S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Attatchment to ULNRC-06166 Callaway Nuclear Plant Inservice Testing Program Revision 32

El90.0074 Inservice Testing Program Revision 3 2 Ameren Missouri 1901 Chouteau A venue Saint Louis, Missouri 63103 Callaway Energy Center POBox 620 Fulton, Missouri 65251

~ '~

WAmeren MISSOURI Date of Commercial Operation: December 19, 1984 APPROVALS:

Date:

Date:

Date:

Revision Date: 12/10/2014 ld./1/ 1&.01 y I I J'l.-/1 c;-/ Z-dl "'(

Page 1 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 IST PROGRAM REVISION INDEX Revision Description Reference Docs Date 32 IST Program Plan for the 4th Ten Year Interval CAR 201306877 12110/2014 Revision Date: 12/10/2014 Page 2 Attachment to ULNRC-06166

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope Callaway Energy Center TABLE OF CONTENTS 2.0 INSERVICE TESTING PLAN FOR PUMPS 2.1 Pump Inservice Testing Plan Description 2.2 Pump Plan Table Description 3.0 INSERVICE TESTING OF VALVES 3.1 Valve Inservice Testing Plan Description 3.2 Valve Plan Table Description 4.0 ATTACHMENTS 1

System and P&ID Listing 2

Pump Relief Request Index 3

Pump Relief Requests 4

Cold Shutdown Justification Index 5

Cold Shutdown Justifications 6

Refuel Outage Justification Index 7

Refuel Outage Justifications 8

Technical Position Index 9

Technical Positions 10 Inservice Testing Pump Table 11 Inservice Testing Valve Table Revision Date: 12/10/2014 Inservice Testing Program Revision 32 Page 3 Attachment to ULNRC-06166

Callaway Energy Center

1.0 INTRODUCTION

lnservice Testing Program Revision 32 The Fourth 10-Year Inservice Testing Program for Callaway Energy Center was developed in compliance with the rules and regulations of 1 OCFR 50.55a and American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants, (OM Code), 2004 Edition through 2006 Addenda. Code Cases, approved using relief requests, were utilized in developing Callaway's Inservice Testing Program. NRC Generic Letter 89-04 and NUREG 1482, Revision 1, were also used as guidance in the update of theIST Program.

For situations where the OM Code requirements were determined to be impractical or an excessive hardship, a relief request was developed.

These relief requests are included in Attaclunent 3 of this document.

This submittal of this Inservice Testing Program for pumps and valves will remain in effect through the next 1 0 year inservice testing interval ending December 19, 2024.

1.1 Purpose To provide requirements for the performance and administration of assessing the operational readiness of those pumps and valves whose specific functions are required to:

Shutdown the reactor to the safe shutdown condition, Maintain the safe shutdown condition, or To mitigate the consequences of an accident The Callaway Energy Center safe shutdown licensing basis is hot standby and the safe shutdown design basis is cold shutdown. [FSAR 5.4A] The Inservice Testing Program tests pumps and valves required to achieve and maintain hot standby. [CAR 1995021 05]

1.2 Scope The program plan was prepared to meet the requirements of the following subsections of the ASME OM Code (2004 Edition through 2006 Addenda).

• Subsection IST A, "General Requirements" IST A contains the requirements directly applicable to 1nserv1ce testing including the Owner's Responsibility and Records Revision Date: 12/10/2014 Page4 Attachment to ULNRC-06166

Callaway Energy Center Requirements.

lnservice Testing Program Revision 32 Subsection ISTB, "lnservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants" Establishes the requirements for inservice testing of pumps in light-water reactor nuclear power plants.

The pumps covered are those provided with an emergency power source that are required in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

Subsection ISTC, "lnservice Testing of Valves in Light-Water Reactor Nuclear Plants" Power Establishes the requirements for inservice testing of valves in light-water reactor nuclear power plants. The valves covered include those which provide overpressure protection and are required to perform a specific function, either actively by changing valve obturator position or passively by effectively maintaining required obturator position in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Po1tver Plants" Establishes the examination and testing requirements of nuclear power plant equipment dynamic restraints (snubbers) throughout the life of the plant. Snubbers are functionally tested under the Snubber Examination, Testing and Service Life Monitoring Program Plan, NED 140020 which has been submitted separately. Specific plant requirements are included in EDP-ZZ-01007, Mechanical Snubber Program document. This program meets the requirements of the ASME OM Code, Subsection, 1ST A, and ISTD, 2004 Edition, w/ Addenda through 2006. The examination boundaries shall include the snubber assembly from pin to pin inclusive.

Integral and nonintegral attachments for snubbers shall be examined within the Station lSI program, In accordance with the requirements of the ASME Code Section XI.

Revision Date: 12/10/2014 Page 5 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 Mandatory Appendix I, "lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants" Provides the requirements for performance testing and monitoring of nuclear plant pressure relief devices.

Methods, intervals, and record requirements for monitoring and testing are established, as well as guidelines for the evaluation of results.

This Appendix may be applied to safety valves, safety relief valves, pilot-operated pressure relief valves, power-actuated pressure relief valves, non-reclosing pressure relief devices and vacuum relief devices, including all accessories and appurtenances.

Mandatory Appendix II, "Check Valve Condition Monitoring Program" Provides an alternative to the testing or examination requirements of ISTC-3510 through ISTC-5221.

The pw-pose of this program is both to improve valve performance and to optimize testing, exan1ination, and preventive maintenance activities in order to maintain the continued acceptable performance of select groups of check valves.

Revision Date: 12/10/2014 Page 6 Attachment to ULNRC-06166

Callaway Energy Center 2.0 INSERVICE TESTING PLAN FOR PUMPS 2.1 Pump Inservice Testing Plan Description Inservice Testing Program Revision 32 This plan establishes the test intervals and parameters to be measured to meet the requirements of ASME OM Code IST A and ISTB as amended by specific relief requests contained in Attachment 3.

2.2 Pump Plan Table Description The pumps included in the Callaway Energy Center IST Plan are listed in Attachment I 0. The information contained in these tables identifies those pumps to be tested to the requirements of ASME OM Code, the testing parameters and frequencies, and associated relief requests. The headings for the pump tables are delineated below.

Pump Location Safety Class Pump Type Pump Driver Nominal Speed P&ID P&ID Coor.

Revision Date: 12/10/2014 Unique pump identification number.

ASME Code classification of the pump.

I ASME Code Class I 2

ASME Code Class 2 3

ASME Code Class 3 NC Non-Code, Safety Related Pun1p type.

Centrifugal Vertical Pump driver type.

Motor Turbine Motor driven Steam turbine driven Pump speed for variable speed pumps only.

Drawing number of the pump.

The P&ID Coordinate location of the pump.

Page 7 Attachment to ULNRC-06166

Revision Date: 12/10/2014 Callaway Energy Center Inservice Testing Program Revision 32 Category Test Type Test Freq.

Relief Request Tech. Pos.

Pump group as defined in ISTB-2000.

Group A Pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations.

Group B Pumps in standby systems that are not operated routinely except for testing.

Measured pump test parameters.

N Speed DP Differential Pressure Q

Flow Rate V

Vibration a-Denotes a Group A Pump Test b - Denotes a Group B Pump Test c - Denotes a Comprehensive Pump Test Frequency of the specified inservice test.

M3 Quarterly (92 Days)

Y2 Biennially (2 Years)

The applicable relief requests for the pump.

A technical position number is listed where the requirements of the code are not easily interpreted and clarifying infonnation ts needed. The technical position is used to document how Code requirements are being implemented at the plant.

Attachment 8

contains an index of all the Technical Positions included in Attachment 9.

Page 8 Attachment to ULNRC-06166

Callaway Energy Center 3.0 INSERVICE TESTING PLAN FOR VALVES 3.1 Valve Inservice Testing Plan Description lnservice Testing Program Revision 32 This plan establishes the test intervals and parameters to be measured to meet the requirements of IST A, ISTC, Appendix I, and Appendix II with the limitations imposed by 10CFR50.55a(b)(3).

Where the frequency requirements for valve testing have been detem1ined to be impracticable, Cold Shutdown or Refuel Outage Justifications have been identified and written. These justifications are provided in Attachments 5 and 7 respectively.

3.2 Valve Plan Table Description The valves included in the Callaway Energy Center IST Plan are listed in Attachment 11.

The information contained in these tables identify those valves to be tested to the requiren1ents of IST A, ISTC, Appendix I, and Appendix II, the test parameters and frequencies, and any associated relief requests. The headings for the valve tables are delineated below.

Valve Location P&ID P&ID Coor.

Safety Class Cat.

Size Revision Date: 12/10/2014 Unique valve identification number.

Drawing number of the valve.

The P&ID Coordinate location ofthe valve.

ASME Code classification of the valve.

1 ASME Code Class 1 2

ASME Code Class 2 3

ASME Code Class 3 NC Non-Code, Safety Related The ASME OM Code category (or categories) as defined in ISTC-1300.

A Seat Leakage Limited.

B Seat Leakage Not Reg u ired.

C Self-Actuating Valves.

AC Both Categories A and C.

BC Both Categories Band C.

The nominal pipe size of the valve, in inches.

Page 9 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Valve Type Act. Type Active/Passive Normal Position Revision 32 The valve body style abbreviation.

BF Butterfly Valve CK Check Valve DI Diaphragm Valve GB Globe Valve GT Gate Valve PLG Plug Valve RV Relief Valve sv Solenoid Valve 3W 3-Way Valve The valve actuator type abbreviation.

AO Air Operator HO Hydraulic Operator MA Manual MO Motor Operator SA Self-Actuating so Solenoid Operator Active or Passive function determination for the valve in accordance with IST A-2000.

A Active p

Passive The normal position abbreviation, identifying the valve's position during normal power operation.

If the system does not operate during power operation, then the normal position is the position of the valve when the system is not operating.

C Closed 0

Open LC Locked Closed LO Locked Open DE De-energized (solenoid valves)

E Energized (solenoid valves)

SYS System Condition Dependent Revision Date: 12/10/2014 Page 10 Attachment to ULNRC-06166

Revision Date: 12/10/2014 Callaway Energy Center lnservice Testing Program Revision 32 Safety Position Test Type The safety function position(s).

For valves that perform safety functions in the open and closed positions more than one safety function position may be specified.

C Closed 0

Open DE De-energized (solenoid valves)

E Energized (solenoid valves)

DE/E De-energized and Energized 0/C Open and Closed The test type abbreviation.

AT-01 Seat Leakage Rate Test (Appendix J)

AT-02 Seat Leakage Rate Test (PlY)

AT-03 Seat Leakage Rate Test (Other)

BTC Exercise Test Closed BTO cc co FC FO LT PIT RT Exercise Test Open Exercise Test Closed-Check Valve( I)

Exercise Test 0 pen-Check Valve( I)

Fail Safe Test Closed Fail Safe Test Open Leakage Test (other than Appendix J or PlY)

Position Indication Test Relief Valve Test (1)

Three letter designations may be used for check valve condition monitoring tests to differentiate between the various methods of exercising check valves. The letter following "CC" or "CO",

should be "A" for acoustics, "0" for disassembly and examination, "F" for flow indication, "L" for leakage rate indication, "M" for magnetics, "R" for radiography, "T" for temperature, or "U" for ultrasonics.

Page 11 Attachment to ULNRC-06166

Test Freq.

Relief Request Deferred Just.

Tech. Pos.

Revision Date: 12/10/2014 Callaway Energy Center lnservice Testing Program Revision 32 The test frequency abbreviation.

App-J CM cs M3 OP RR YX Appendix J Condition Monitoring<!)

Cold Shutdown Quarterly Operating Activities<2)

Refueling Outage X Years (X = I, 2,..., 1 0)

( 1) Frequency is as indicated in respect to the Condition Monitoring Plan for that valve group.

(2) Satisfied in accordance with IST Program Technical

Position, TP-0 1, "Bi-directional Testing of Check Valves".

The applicable relief request for the valve.

Deferred Test Justification.

This section refers to Cold Shutdown Justifications and Refuel Outage Justifications.

A Cold Shutdown Justification number is listed when the testing frequency coincides with Cold Shutdowns instead of being performed quarterly.

Cold Shutdown Justification numbers for valves are prefixed with "CSJ". Attachment 4 contains an index of all the Cold Shutdown Justifications included in Attachment 5.

A Refueling Justification number is listed when the testing frequency coincides with Refueling Justification instead of being performed quarterly or during Cold Shutdowns.

Refueling Justification numbers for valves are prefixed with "RJ".

Attachment 6 contains an index of all the Refueling Justifications included in Attachment 7.

A technical position number is listed when the requirements of the code are not easily interpreted and clarifying information is needed.

The technical position is used to document how Code requirements are being implemented at the plant. Attachment 8 contains an index of all the Technical Positions included in Attachment 9.

Page 12 Attachment to ULNRC-06166

Callaway Energy Center 4.0 ATTACHMENTS -

System and P&ID Listing -

Pump Relief Request Index -

Pump Relief Requests -

Cold Shutdown Justification Index -

Cold Shutdown Justifications -

Refuel Outage Justification Index Attaclunent 7-Refuel Outage Justifications -

Technical Position Index -

Technical Positions 0 -

Inservice Testing Pump Table 1 -

Inservice Testing Valve Table Revision Date: 12/10/2014 Inservice Testing Program Revision 32 Page 12a Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 1 System and P&ID Listing System System Name AB Main Steam AE Feedwater AL Auxiliary Feedwater lnservice Testing Program Revision 32 P&ID M-22AB01-02 M-22AE02 M-22AL01 AP Condensate Storage and M-22AP01 BB Reactor Coolant M-22BB01-04 M-22BGO 1-05 M-22BL01 BG Chemical and Volume Control BL BM BN EC EF EG Reactor Makeup Water Steam Generator Blowdown M-22BM01 Borated Refueling Water M-22BN01 Fuel Pool Cooling and M-22EC01,02 Essential Service Water Con1ponent Cooling Water M-22EF01,02,M-U2EF01 M-22EG01,02,03 EJ Residual Heat Removal M-22EJ01 EM High Pressure Coolant M-22EM01,02 EN Containment Spray M-22ENO 1 EP Accumulator Safety Injection M-22EP01 FC Auxiliary Feedwater Pump M-22FC01,02 GK Control Building HVAC M-22GK01,03 GS Containment Hydrogen M-22GSO 1 GT HB HD JE KA KB KC KJ LF SJ Revision Date: 12/10/2014 Containment Purge Liquid Radwaste Deconta1nination Emergency Fuel Oil Compressed Air Breathing Air for Tasks Fire Protection Standby Diesel Generator Rx Bldg Floor/Equip Drains Nuclear Smnpling System M-22GT01 M-22HB01 M-22HD01 M-22JE01 M-22KAO 1,02,05 M-22KB01 M-22KC02 M-22KJ01-06 M-22LF03, 09 M-22SJ01,04 Page 13 Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 2 Pump Relief Request Index Relief Request Description Number lnservice Testing Program Revision 32 PR -0 1 RHR Pump Discharge Pressure Gauge Range Requirements PR-02 Centrifugal Charging Pump Suction Pressure Gauge Range Requirements PR-03 Boric Acid Transfer Pump Flow Measurement PR-04 IST Exam Intervals and Grace PR-06 Variance about the Reference Values Revision Date: 12/10/2014 Page 14 Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 3 PUMP RELIEF REQUESTS Revision Date: 12/10/2014 lnservice Testing Program Revision 32 Page 15 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-01 RHR Pump Discharge Pressure Gauge Range Requirements

1.

ASME Code Components Affected Pump Description Code OM Code Number Class Category PEJOIA Residual Heat Removal Pump A 2

GpA PEJOIB Residual Heat Removal Pump B 2

GpA

2.

Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3.

Applicable Code Requirement

This request applies to the instrumentation requirements of the ASME OM Code.

ISTB-351 O(b )(I)

4.

Reason for Request

Range of Analog Instnnnents - The full scale range of each analog instrument shall be not greater than three times the reference value.

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), an alternative is proposed to the instrumentation requirements of the ASME OM Code. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for Group A testing for RHR pumps.

The range of the installed analog discharge pressure gauge for the RHR pumps is 0

- 700 psig. Because the reference values for pump discharge pressure during Inservice Testing are between 200 psig and 300 psig, the instrument range exceeds the requirement of ISTB-351 O(b )(I).

Pump discharge pressure indication is used along with pump suction pressure Revision Date: 12/10/2014 Page 16 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-01 RHR Pump Discharge Pressure Gauge Range Requirements (Continued) indication to determine pump differential pressure.

Discharge pressure reference values for the RHR pumps during Inservice Testing are between 200 psig and 300 ps1g.

Based on ISTB-351 O(b )(I), this would require as a maximum, a gauge with a range of 0 to 600 psig (3 X 200 psig) to bound the lowest reference value for discharge pressure. Applying the accuracy requirement of +/- 2o/o for the Group A test, the resulting inaccuracies due to discharge pressure effects would be +/- 12.0 psig (0.02 X 600 psig).

5.

Proposed Alternative and Basis for Use As an alternative, for the Group A test, Callaway Energy Center will use the installed discharge pressure analog gauge (0 to 700 psig) calibrated to less than or equal to +/- 1. 7 % such that the inaccuracies due to pressure will be less than that required by the Code (+/- 12.0 psig). The error associated with the discharge gage would then be no greater than +/- 11.9 psi (700 *.01 7). Use of the installed pressure gauge calibrated in this manner is equivalent in terms of measuring discharge pressure to less than +/- 2%.

Using the provisions of this relief request as an alternative to the specific requirements of ISTB-351 O(b )(1) identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

6.

Duration of Proposed Alternative The proposed alternative will be utilized for the entire Fourth 120 month Interval beginning December 20,2014.

7.

Precedent This relief request was previously approved for the 3rd 120 Month Interval at Callaway Energy Center as Relief Request PR-01.

Revision Date: 12/10/2014 Page 17 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-02 Centrifugal Charging Pump Suction Pressure Gauge Range Requirements

1.

ASME Code Components Affected Pump Description Code OM Code Number Class Category PBG05A Centrifugal Charging Pump A 2

GpB PBG05B Centrifugal Charging Pump B 2

GpB

2.

Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3.

Applicable Code Requirement

This request applies to the instrumentation requirements of the ASME OM Code.

ISTB-351 O(b )(I)

4.

Reason for Request

Range of Analog Instruments-The full scale range of each analog instrument shall be not greater than three times the reference value.

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), an alternative is proposed to the instrumentation requirements of the ASME OM Code. The basis of the relief request is that the proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for Group 8 testing for centrifugal charging pumps.

The range of the installed suction pressure gauges for the centrifugal charging pumps is 0 -

150 psig. Because the reference values for suction pressure during Inservice Testing are between 30 psig and 40 psig, the instrument range exceeds the requirement of ISTB-351 O(b)(I ).

Pump suction pressure indication is used along with pump discharge pressure indication to Revision Date: 12/10/2014 Page 18 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-02 Centrifugal Charging Pump Suction Pressure Gauge Range Requirements (Continued) determine pump differential pressure.

Suction pressure reference values for the centrifugal charging pumps during lnservice Testing are between 30 psig and 40 psig.

Based on ISTB-351 O(b )(I), this would require as a maximum, a gauge with a range of 0 to 90 psig (3 X 30 psig) to bound the lowest reference value for pressure. Applying the accuracy requirement of +/- 2% for the quarterly Group B pump test, the resulting inaccuracies due to suction pressure effects would be+/- 1.8 psig (0.02 X 90 psig).

5.

Proposed Alternative and Basis for Use As an alte1native, for the Group B quarterly test, Callaway Energy Center will use the installed suction pressure gauge (0 to 150 psig) calibrated to less than or equal to +/- 1.2

% such that the inaccuracies due to suction pressure will be less than that required by the Code (+/- 1.8 psig). The en-or associated with the suction gauge would then be no worse than+/- 1.8 psi (150 *.012). Use of the installed suction pressure gauge calibrated to less than +/- 2 % is equivalent in terms Code compliance for the measurement of suction pressure.

Using the provisions of this relief request as an alternative to the specific requiren1ents of ISTB-3510(b)(l) identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

6.

Duration of Proposed Alternative The proposed alternative will be utilized for the entire Fourth 120 month Interval beginning December 20, 2014.

7.

Precedent This relief request was previously approved for the 3rd 120 Month Interval at Callaway Energy Center as relief request PR-02.

Revision Date: 12/10/2014 Page 19 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-03 Boric Acid Transfer Pump Flow Measurement

1.

ASME Code Components Affected Pump Description Code OM Code Number Class Category PBG02A Boric Acid Transfer Pump A 3

GpA PBG02B Boric Acid Transfer Pump B 3

GpA

2.

Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3.

Applicable Code Requirement

This request applies to the Group A Test Procedure instrumentation requirements of the ASME OM Code.

lSTB-5121 (c)

ISTB-3000-1

4.

Reason for Request

Group A Test procedure -

"Where it is not practical to vary system resistance, flow rate and pressure shall be determined and compared to their respective reference values".

Table - Inservice Test Parameters Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), an alternative is proposed to the testing requirements of the ASME OM Code. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for Group A testing for Boric Acid Transfer pumps.

The normal test loop for the subject pumps consists of suction from the applicable Boric Acid Tank and discharge through a Mini-Flow Recirc line back to the Boric Acid tank; however, Revision Date: 12/10/2014 Page 20 Attachment to ULNRC-06166

Callaway Energy Center 10 CFR 50.55a Relief Request Number PR-03 Boric Acid Transfer Pump Flow Measurement (Continued) lnservice Testing Program Revision 32 flow measuring instrumentation is not installed in this flow path. The Mini-Flow Recirc line contains a locked throttle valve set to allow for the minimum pump recirculation flow (approximately 15gpm). The throttled position of this valve is important to provide for the minimum recirculation flow to protect the pump while minimizing the diversion of flow through the primary discharge path to the Charging system to allow for Immediate Boration in emergency conditions. Unlocking and adjustment of the throttle valve on a quarterly basis for Inservice Testing would create the potential for mis-positioning of the throttle valve and thus an adverse effect on system capability. Based on this, the Mini-Flow Recirc line will be considered a fixed resistance flow path.

An alternate test circuit is available in which flow rate may be measured, however this flow path requires injection of highly concentrated boric acid solution into the reactor coolant system. During the quarterly Group A test at normal power operations, this test is highly impractical since severe power level fluctuations would be created which could cause a trip of the reactor. Performing this test at cold shutdown intervals would also result in excessive boration of the reactor coolant system resulting in potential difficulties and delays in restarting the plant.

5.

Proposed Alternative and Basis for Use As an alternative to measuring differential pressure and flow during the Group A quarterly test, only the differential pressure will be measured and compared to its reference value.

Additionally, vibration measurements are also recorded and compared to their reference values.

The Group A test will be performed using the Recirc flow path shown on, with the throttle valve remaining in its locked position. The reference value is approximately 112 psig at an estimated flow rate of 15 gpm. Because the system resistance is fixed and flow can be assumed to be constant, pump degradation may be detected by comparing successive measurements of pump differential pressure. Based on this, it is not warranted to install additional instrumentation to provide for flow measurement.

During the comprehensive inservice test when flow may be measured, full-spectrum vibration analysis will be performed which is beyond the vibration analysis required by the Code. The vibration measurements will be recorded and compared to their reference values. Thus, when performing the comprehensive pump test, all required parameters will be measured and compared to their reference values. The performance of full spectrum analysis, in addition to continued quarterly and comprehensive testing, will ensure that an accurate assessment of pump health and operational readiness is determined. This alternative provides an acceptable level of quality and safety.

Revision Date: 12/10/2014 Page 21 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-03 Boric Acid Transfer Pump Flow Measurement (Continued)

6.

Duration of Proposed Alternative The proposed alternative will be utilized for the entire Fourth 120 month Interval beginning December 20, 2014.

7.

Precedent This relief request was previously approved for the 3rd 120 Month Interval at Callaway Energy Center as Relief Request PR -03.

Boric Acid Transfer Pump Test Diagram Boric Acid Tank Boric Acid Transfer Pump A(B)

Revision Date: 12/10/2014 L.O.

Locked Throttled Minimum Flow Recirc Line BGV209(21 0)

BGV155(167)

BGV 148( 166)

BGV147(165)

From other Boric Acid Transfer Pump A(B)

Charging Pump Suction Page 22 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-04 1ST Exam Intervals and Grace

1.

ASME Code Components Affected Pumps and Valves contained within the lnservice Testing Program scope.

2.

Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3.

Applicable Code Requirement

This request applies to the following frequency requirements of the ASME OM Code.

ISTA-3120(a)-

"The frequency for the inservice testing shall be in accordance with the requirements of Section 1ST."

ISTB-3400-Frequency of lnservice Tests ISTC-351 0-Exercising Test Frequency ISTC-3540-Manual Valves ISTC-3630(a)-

Frequency ISTC-3700-Position Verification Testing ISTC-5221 (c)(3)-

"At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8years."

Appendix I, 1-1320-Test Frequencies, Class 1 Pressure Relief Valves Appendix I, 1-1330-Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Appendix I, 1-1340-Test Frequencies-Class 1 Pressure Relief Devices That Are Used for Thermal Relief Application Appendix I, 1-1350-Test Frequencies-Class 2 and 3 Pressure Relief Valves Appendix I, I -1360-Test Frequencies-Class 2 and 3 Nonreclosing Pressure Relief Devices Revision Date: 12/10/2014 Page 23 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-04 Appendix I, 1-1370-Appendix I, I -1380-Appendix I, 1-1390-Appendix II, ll-4000(a)(l )-

Appendix II, ll-4000(b)(l)(e)-

4.

Reason for Request

1ST Exam Intervals and Grace (Continued)

Test Frequencies-Class 2 and 3 Primary Containment Vacuum Relief Valves Test Frequencies-Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Test Frequencies-Class 1 Pressure Relief Devices That Are Used for Thermal Relief Application Performance Improvement Activities Interval Optimization of Condition Monitoring Activities Interval Pursuant to I 0 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section IST establishes the inservice test frequency for all components within the scope of the Code.

The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in the Table 3.2 of NUREG 1482, Revision 1) and Owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TS) Surveillance Requirements (SRs). The TS typically allow for a less than or equal to 25o/o extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (SR 3.0.2).

However, regulatory issues have been raised concerning the applicability of the TS "Grace Period" to ASME OM Code required inservice test frequencies irrespective of allowances provided under TS Administrative Controls (i.e.,

TS 5.5.6, "lnservice Testing Program," invokes SR 3.0.2 for various OM Code frequencies).

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability.

Therefore, to avoid this conflict, the surveillance test should be performed as soon as it is practicable.

The NRC recognized this potential issue in the TS by allowing a frequency tolerance as described in TS SR 3.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility. Thus, just as with TS required surveillance testing, some tolerance is needed to allow extending OM Code testing intervals.

Revision Date: 12/10/2014 Page 24 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 10 CFR SO.SSa Relief Request Number PR-04 1ST Exam Intervals and Grace (Continued)

Interval extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Such extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.

5.

Proposed Alternative and Basis for Use ASME OM Code establishes component test frequencies that are based either on elapsed time periods (e.g., quarterly, 2 years, etc.) or on the occurrence of plant conditions or events (e.g.,

cold shutdown, refueling outage, upon detection of a sample failure, following maintenance, etc.).

a. Components whose test frequencies are based on elapsed time periods shall undergo Inservice Testing at frequencies as specified in the Callaway Technical Specifications (TS 5.5.8) and shown in the following table.

Specified Time Period Between Frequency

!rests Weekly At least once per 7 days Monthly At least once per 31 days Quarterly At least once per 92 days Semiannually At least once per 184 days Every 9 months At least once per 276 days Yearly or Annually At least once per 366 days Biennially or every 2 years IAt least once per 731 days

b. The specified time period between tests may be extended as follows:

i. For periods specified as less than 2 years, the period may be extended by up to 25% for any given test. This is consistent with Callaway TS Section 5.5.6, "lnservice Testing Program."

ii.

For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test.

c. Components whose test frequencies are based on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a Revision Date: 12/10/2014 Page 25 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-04 1ST Exam Intervals and Grace (Continued) sample failure, following maintenance, etc.) may not have their period between tests extended except as allowed by the ASME OM Code.

d. Period extensions may not be applied to the test frequency requirements specified in Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-water Reactor Nuclear Power Plants, as Subsection ISTD contains its own rules for period extensions.

e. Period extensions of 25% may also be applied to accelerated test frequencies (e.g., pumps in Alert Range) and other less than two year test frequencies not specified in the table above.

This relief is requested citing the guidance found in ASME approved Code Case OMN-20.

6.

Duration of Proposed Alternative The proposed alternative will be utilized for the entire Fourth 120 month Interval beginning December 20, 2014.

7.

Precedent A similar relief request (RV-01) has been approved for the Quad Cities Nuclear Power Station in NRC Safety Evaluation dated February 14,2013.

8.

References Letter from Joel S. Wiebe (U.S. NRC) to Mr. Michael J. Pacilio (Exelon Generation Co.),

'"Quad Cities Nuclear Power Station, Units 1 And 2 - Safety Evaluation In Support Of Request For Relief Associated With The Fifth 10 Year Interval Inservice Testing Program," dated February 14, 2013 NRC Regulatory Issue Summary 2012 "NRC STAFF POSITION ON APPLYING SURVEILLANCE REQUIREMENTS 3.0.2 AND 3.0.3 TO ADMINISTRATIVE CONTROLS PROGRAM TESTS ASME OM Code Case OMN "Inservice Test Frequency" Callaway TS Section 5.5.6- "lnservice Testing Program" Call a way TS SR 3.0.2-Specified Frequency (25%Grace Period)

Revision Date: 12/10/2014 Page 26 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 10 CFR 50.55a Relief Request Number PR-06 Variance about the Reference Values

1.

ASME Code Components Affected All Pumps listed in Attachment 1

2.

Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3.

Applicable Code Requirement

ISTB-5121, "Group A Test Procedure" ISTB-5121(b) states that "The resistance of the system shall be varied until the flow rate equals the reference point".

ISTB-5122, "Group 8 Test Procedure" ISTB-5122( c) states that "System resistance may be varied as necessary to achieve the reference point".

ISTB-5123, "Comprehensive Test Procedure" ISTB-5123(b) states that "For centrifugal and vertical line shaft pumps, the resistance of the system shall be varied until the flow rate equals the reference point".

I STB-5221, "Group A Test Procedure" I STB-5221 (b) states that "The resistance of the system shall be varied until the flow rate equals the reference point".

ISTB-5222, "Group B Test Procedure" ISTB-5222(c) states that "System resistance may be varied as necessary to achieve the reference point".

ISTB-5223, "Comprehensive Test Procedure" ISTB-5l23(b) states that "For centrifugal and vertical line shaft pumps, the resistance of the system shall be varied until the flow rate equals the reference point".

4.

Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), an alternative is proposed to the pump testing reference value requirements of the ASME OM Code. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety.

Specifically, this alternative is requested for all inservice testing of 1ST Program pumps as listed in Attachment 1.

For pump testing, there is difficulty adjusting system throttle valves with sufficient precision to achieve exact flow reference values during subsequent 1ST exams. Section ISTB of the ASME OM Code does not allow for variance from a fixed reference value for pump testing.

However, NUREG-1482, Revision 1, Section 5.3, acknowledges that certain pump system Revision Date: 12/10/2014 Page 27 Attachment to ULNRC-06166

Callaway Energy Center 10 CFR 50.55a Relief Request Number PR-06 Variance about the Reference Values (Continued) lnservice Testing Program Revision 32 designs do not allow for the licensee to set the flow at an exact value because of limitations in the instruments and controls for maintaining steady flow.

ASME OM Code Case OMN-21 provides guidance for adjusting reference flow/.1.P to within a specified tolerance during Inservice Testing. The Code Case states "It is the opinion of the Committee that when it is impractical to operate a pump at a specified reference point and adjust the resistance of the system to a specified reference point for either flow rate, differential pressure or discharge pressure, the pump may be operated as close as practical to the specified reference point with the following requirements. The Owner shall adjust the system resistance to as close as practical to the specified reference point where the variance from the reference point does not exceed+ 2% or-1% of the reference point when the reference point is flow rate, or+ 1% or-2o/o of the reference point when the reference point is differential pressure or discharge pressure.

5.

Proposed Alternative and Basis for Use Callaway seeks to perform future lnservice Pump testing m a manner consistent with the requirements as stated in ASME OM Code Case OMN-21. Specifically, testing of all pumps identified in Attachment.] will be performed such that flow rate is adjusted as close as practical to the reference value and within proceduralized limits of+2o/o I -1% ofthe reference value.

Callaway plant operators will still strive to achieve the exact test flow reference values during testing.

Typical test guidance will be to adjust flow to the specific reference value with additional guidance that if the reference value cannot be achieved with reasonable eff011 the test will be considered valid if the steady state flow rate is within the proceduralized limits of

+2% I -1% of the reference value.

Using the provisions of this request as an alternative to the specific requirements of ISTB-5121, ISTB-5122, ISTB-5123, ISTB-5221, ISTB-5222 and ISTB-5223 as described above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

6.

Duration of Proposed Alternative The proposed alternative will be utilized for the entire Fourth 120 month Interval beginning December 20, 2014.

7.

Precedent None

8.

References

1. ASME Code Case OMN-21, ""Alternate Requirements for Adjusting Hydraulic Parameters to Specified Reference Points" Revision Date: 12/10/2014 Page 28 Attachment to ULNRC-06166

Callaway Energy Center 10 CFR 50.55a Relief Request Number PR-06 Variance about the Reference Values (Continued)

PR-06 Attachment 1 lnservice Testing Program Revision 32 Callaway Inservice Testing Program Pumps covered by PR-06 Pump Number Description Pump Type Code OM Code Class Category MOTOR DRIVEN AUXILIARY PALOIA/B FEEDW A TER PUMPS Centrifugal 3

Group A eves BORIC ACID PBG02A/B TRANSFER PUMPS Centrifugal 3

Group A ESSENTIAL SERVICE WATER Vertical PEFOIA/8 PUMPS Line Shaft Group A

.)

COMPONENT COOLING PEGO 1 A/8/C/D WATER PUMPS Centrifugal Group A

.)

RESIDUAL HEAT REMOVAL PEJOIA/B PUMPS Centrifugal 2

Group A TURBINE DRIVEN AUXILIARY FEEDWATER PAL02 PUMP Centrifugal 3

Group B CENTRIFUGAL CHARGING PBG05A/8 PUMPS Centrifugal 2

Group B PEMOIA/B SAFETY INJECTION PUMPS Centrifugal 2

Group B CONTAINMENT SPRAY PENOIA/8 PUMPS Centrifugal 2

Group B Revision Date: 12/10/2014 Page 29 Attachment to ULNRC-06166

Cold Shutdown Justification No.

CSJ-01 CSJ-02 CSJ-03 CSJ-04 CSJ-05 CSJ-06 CSJ-07 CSJ-08 CSJ-09 CSJ-1 0 CSJ-11 CSJ-12 CSJ-13 CSJ-14 CSJ-15 CSJ-16 CSJ-17 CSJ-18 CSJ-19 CSJ-20 CSJ-21 CSJ-22 CSJ-23 CSJ-24 CSJ-25 CSJ-26 CSJ-27 CSJ-28 Callaway Energy Center ATTACHMENT 4 COLD SHUTDOWN JUSTIFICATION INDEX Description Main Steam Isolation Valves (ABHV0011,14,17,20)

Inservice Testing Program Revision 32 Steam Generator Power Operated ReliefValves (ABPV0001,2,3,4, ABV0345,346,34 7,348,349,350,351,352)

SG Feedwater Supply Isolation Valves (AEFV0039,40,41,42)

Auxiliary Feedwater Pump Discharge Check Valves (ALFV0030, 42)

Auxiliary Feedwater Pump Discharge Check Valves (ALV0054)

Reactor Vessel Head Vent Valves (BBHV800 1 A,B, 8002A,B)

Pressurizer Power Operated Relief Valves (BBPCV0455A,0456A)

Hot Leg to RHR Pump Suction Isolation Valves (BBPV8702A,B)

Charging to Regen Heat Exchanger Isolation Valve (BGHV81 05,6)

CVCS Letdown Isolation Valves (BGHV8152,8160)

VCT Outlet Isolation Valves (BGLCV0112B,C)

Letdown to Regen Heat Exchanger Level Ctrl Valves (BGLCV0459, 460)

Boric Acid to Charging Pumps Suction Check Valves (BGVOI47,165,174)

Safety Injection Pumps Minimum Flow Isolation Valve (BNHV8813)

RHR Heat Exchanger Outlet Check Valves (EJ8730A,B)

RHR Pump Suction Isolation Valves (EJHV870 1 A,B)

RHR to RCS Hot Leg Recirculation Isolation Valves (EJHV8716A,B)

RHR to SIICVCS Pumps Supply Isolation Valves (EJHV8804A,B)

RHR Injection Supply Isolation Valves (EJHV8809A,B)

Containment Sump to RHR Suction Isolation Valves (EJHV8811 A,B)

RHR Train A/8 Hot Leg Recirculation Isolation Valve (EJHV8840)

SI Pump Discharge to RCS Cold Leg Isolation Valve (EMHV8835)

Containment Recirc Sump to CS Pump Isolation Valves (ENHV0001, 7)

SI Accumulator Tank Outlet Isolation Valves (EPHV8808A,D)

SI Accumulator Tank Vent Isolation Valves (EPHV8950A,B,C,D,E,F)

Reactor Bui I ding Supply Flow Control Valve (KAFV0029)

SG Main Feedwater Control Valves (AEFCV051 0/520/530/540)

RCP Seal Water Return Valves (BGHV8100/8112)

Revision Date: 12/10/2014 Page 30 Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 5 COLD SHUTDOWN JUSTIFICATIONS Revision Date: 12/10/2014 Inservice Testing Program Revision 32 Page 31 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-01 Valve Number System Class ABHVOOll AB 2

ABHV0014 AB 2

ABHV0017 AB 2

ABHV0020 AB 2

Function lnservice Testing Program Revision 32 Category B

B B

B These normally open system medium-operated valves must close automatically to isolate the Steam Generator (S/G) from the non-safety related portion of the Main Steam header. The valves are required to close in the event of a Main Steam Line Break or Steam Generator Tube Rupture.

Energy for closing the valve is provided by the process fluid (main steam), which is admitted to the volume above the actuator piston (upper piston chamber) to close the valve. The valve actuator utilizes six solenoid valves, three solenoids per actuation train, to perform its design safety function.

These valves are open during normal operation to provide a flow path from the S/G to the main steam system and related loads. The open function does not suppo11 safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves closed during normal power operations.

Closing these valves for testing during normal power operations would interrupt steam flow from the steam generator to the main steam/turbine systems and result in a severe transient and a possible reactor scram. Testing by isolating each main steam header is possible but would require a power reduction which is unacceptable from an operational viewpoint. Partial stroke exercising these valves is also impracticable due to the risk of a valve full closure, and subsequent transient, while the unit is generating power.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the main steam system is not required to be operational.

Revision Date: 12/10/2014 Page 32 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 Cold Shutdown Justification CSJ-02 Valve Number System Class Category ABV0345 AB NC c

ABV0346 AB NC c

ABV0347 AB NC c

ABV0348 AB NC c

ABV0349 AB NC c

ABV0350 AB NC c

ABV0351 AB NC c

ABV0352 AB NC c

ABPVOOOl AB 2

B ABPV0002 AB 2

B ABPV0003 AB 2

B ABPV0004 AB 2

B Function Air-operated Power Operated Relief Valves (PORV) ABPVOOOl/2/3/4 are normally closed to isolate the main steam system from atmosphere. During accidents requiring the use of the AFW Turbine, these valves must also remain closed to prevent diverting steam from the AFW Turbine. These valves fail closed on a loss of electrical power or pneumatic supply. These valves must open to allow main steam to be directed to the atmosphere in order to remove decay heat from the Reactor Coolant System when the Main Steam lines or the turbine bypass system is not available. These valves open automatically based on pressure to remove decay heat and reduce S/G pressure.

Check valves ABV0345/34 7/349/351 must open to provide a flow path of safety related nitrogen supply from the accumulator to the actuator of the associated Steam Generator PORV during accident conditions.

Check valves ABV0346/348/350/352 must close to prevent backflow from the nitrogen auxiliary (non safety-related) gas supply to the associated Steam Generator PORV actuator thereby ensuring the PORV actuator can open to remove heat from the reactor coolant system during accident conditions.

Revision Date: 12/10/2014 Page 33 Attachment to ULNRC-06166

Callaway Energy Center Inservice Testing Program Revision 32 Justification Cold Shutdown Justification CSJ-02 (Continued)

It is impracticable to routinely exercise ABPVOOO I /2/3/4 open or closed during normal power operations.

Exercising these valves during normal power operations to perform testing would cause a decrease in pressure in the respective main steatn header resulting in a power transient which is unacceptable from an operational viewpoint.

Alternative Test Air operated valves ABPVOOOl/2/3/4 will be exercised open and closed and fail safe tested during cold shutdowns per ISTC-35I 0.

Check valves ABV0345/34 7 /349/35I will be exercised open and closed when ABPVOOO I /2/3/4 are exercised at cold shutdowns.

Check valves ABV0346/348/350/352 will be exercised in their non-safety open direction when ABPVOOOI/2/3/4 are exercised at cold shutdowns. NOTE: ABV0346/348/350/352 will be exercised in their safety close direction every quarter and therefore the close test is not pat1 of this justification.

Revision Date: 12/10/2014 Page 34 Attachment to ULNRC-06166

Valve Number AEFV0039 AEFV0040 AEFV0041 AEFV0042 Function Callaway Energy Center Cold Shutdown Justification CSJ-03 System Class AE 2

AE 2

AE 2

AE 2

lnservice Testing Program Revision 32 Category B

B B

B These normally open system medium operated valves must close automatically on a Feedwater Isolation Signal (FWIS) during accident conditions requiring feedwater isolation. Energy for closing the valve is provided by the process fluid (feedwater), which is adtnitted to the volume above the actuator piston (upper piston chamber) to close the valve. The valve actuator utilizes six solenoid valves, three solenoids per actuation train, to perform its design safety function.

These valves are normally open to provide feedwater flow from the feedwater system to the stean1 generator during normal power operation. This function is not required for safe shutdown or accident tnitigation since the supply of normal feed water is not safety related.

Justification It is impracticable to exercise these valves closed during normal power operations.

Exercising these valves close during normal power operations requires isolating normal feedwater flow to the steam generator which would result in a severe transient in the steam generator and subsequent reactor trip. Partial stroke exercising these valves is also impracticable since even a part-stroke exercise increases the risk of a valve closure when the unit is generating power.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the steam generators and feedwater system are not required to be in service.

Revision Date: 12/10/2014 Page 35 Attachment to ULNRC-06166

Valve Number ALFV0030 ALFV0042 Function Callaway Energy Center Cold Shutdown Justification CSJ-04 System Class AL 2

AL 2

lnservice Testing Program Revision 32 Category c

c These check valves are required to open to provide a flow path from Auxiliary Feedwater pump discharge to the Steam Generators for emergency cool down of the RCS. The auxiliary feed water pun1p flow will maintain sufficient water level in the steam generators to ensure adequate heat transfer and continuation of the decay heat removal process.

These check valves 1nust close to prevent the back flow of the other auxiliary feed water pumps to flow through the associated non-operating pump.

Justification It is impracticable to exercise these valves open or closed during normal power operations since exercising these valves would result in undesirable cold water flow to the steam generators.

Exercising these valves open during no1111al power operations requires injection of cold water into the steam generators to verify the open full flow position of the valves. This type of test places the plant in an undesirable condition since flow through these valves would unnecessarily thermally shock the steam generator feed water nozzles. Since the closure testing of these valves can only be performed during the open testing, is also impracticable to test these valves closed during normal power operations.

Alternative Test These valves will be exercised open and closed during cold shutdowns.

Revision Date: 12/10/2014 Page 36 Attachment to ULNRC-06166

Valve Number ALV0054 Function Callaway Energy Center Cold Shutdown Justification CSJ-05 System Class AL 2

lnservice Testing Program Revision 32 Category c

This check valve is required to open to provide a flow path from the Turbine Driven Auxiliary Feedwater pump discharge to the Steam Generators for emergency cool down of the RCS. The auxiliary feedwater pump flow will maintain sufficient water level in the steam generators to ensure adequate heat transfer and continuation of the decay heat removal process.

This check valve must close to prevent the back flow from the other auxiliary feedwater pumps through the associated non-operating pmnp.

Justification It is impracticable to exercise this valve open or closed during normal power operations since exercising this valve would result in establishing cold water flow to the stean1 generators.

Exercising this valve open during norn1al power operations requires injection of cold water into the steam generators to verify the open full flow position of the valve. This type of test places the plant in an undesirable condition since flow through this valve would u1mecessarily thermally shock the steam generator feed water nozzles. Since the closure testing of this valve can only be performed during the open testing, is also impracticable to test this valve closed during normal power operations.

Alternative Test This valve will be exercised open and closed during cold shutdowns.

Revision Date: 12/10/2014 Page 37 Attachment to ULNRC-06166

Scope Valve Number BBHV8001A BBHV8001B BBHV8002A BBHV8002B Function Callaway Energy Center Cold Shutdown Justification CSJ-06 System Class BB 2

BB 2

BB 2

BB 2

Inservice Testing Program Revision 32 Category B

B B

B These normally closed solenoid operated valves must open to vent the reactor vessel head during post accident conditions.

The valves must be closed to maintain the reactor coolant pressure boundary and isolate RCS pressure from the contain1nent atmosphere. These valves fail closed upon loss of power.

Justification It is impracticable to exercise these valves open and closed during normal power operations.

Exercising these valves open and closed during no1mal power operations would require venting of the reactor coolant system directly to containment. During normal power operations this test could result in a potential Loss of Coolant Accident since only one valve would remain to establish the reactor coolant system boundary. Additionally, containment entry is required to install the necessary vent test rig to perform this test. This would result in an increase in personnel radiation exposure.

Alternative Test These valves will be exercised open and closed and fail safe tested during cold shutdowns when the reactor coolant system is depressurized and radiation levels permit entry into containment.

Revision Date: 12/10/2014 Page 38 Attachment to ULNRC-06166

Valve Number BBPCV0455A BBPCV0456A Function Callaway Energy Center Cold Shutdown Justification CSJ-07 System Class BB 1

BB 1

lnservice Testing Program Revision 32 Category B

B These normally closed solenoid operated valves must open to provide a flow path from the pressurizer to the pressurizer relief tank to reduce reactor coolant system pressure during low temperature operation. The two pressurizer power operated relief valves (PORV) are supplied with actuation logic to ensure that a redundant and independent RCS pressure control back -up feature is provided for the operator during low temperature operations.

These valves must close to maintain the reactor coolant system pressure and prevent loss ofRCS inventory via the pressurizer relief tank. The valves close automatically when pressurizer pressure is below 2185 psig. Additionally, these valves fail closed upon loss of electrical power.

Justification It is impracticable to exercise these valves open and closed during normal power operations since exercising these valves would cause an RCS pressure transient and subsequent reactor trip.

Exercising these valves open and closed during normal power operations would cause a rapid depressurization of the reactor coolant system which would cause a pressure transient and subsequent trip of the reactor. Additionally, exercising this valve each quarter at power would eventually damage the valve seat.

Alternative Test These valves will be exercised open and closed and fail safe tested during cold shutdowns when the reactor coolant system is depressurized.

Revision Date: 12/10/2014 Page 39 Attachment to ULNRC-06166

Valve Number BBPV8702A BBPV8702B Function Callaway Energy Center Cold Shutdown Justification CSJ-08 System Class BB 1

BB 1

lnservice Testing Program Revision 32 Category A

A These normally closed motor operated valves must close or remain closed to isolate the reactor coolant system from the lower pressure residual heat removal system. The valves are considered pressure isolation valves, required to maintain the RCS pressure boundary. The valves are interlocked shut such that they cannot be opened if reactor coolant system pressure is greater than 3 60 psi g.

This valve opens to provide a flow path from the RCS hot leg to the RHR pump suction during normal unit cooldown. This function is not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves open and closed during normal power operations since exercising these valves would place the plant in an undesirable configuration.

Exercising these valves open and closed during normal power operations would require overriding the logic which maintains the valves in their closed safety position when the reactor coolant system is greater than 360 psig. In addition, opening these valves during normal power operations would over pressurize and potentially damage the lower pressure RHR system.

Alternative Test These valves will be exercised tested during cold shutdowns when the reactor coolant system is depressurized.

Revision Date: 12/10/2014 Page 40 Attachment to ULNRC-06166

Valve Number BGHV8105 BGHV8106 Function Callaway Energy Center Cold Shutdown Justification CSJ-09 System Class BG 2

BG 2

Inservice Testing Program Revision 32 Category A

B These normally open motor operated valves must close automatically upon receipt of a safety injection signal to isolate the normal charging return flow path during the injection mode of ECCS. Closure of these valves ensures adequate injection flow to the reactor coolant system cold legs during all modes of ECCS operation. These valves may also be closed by remote manual operation to isolate containment fron1 the charging system. Valve BGHV81 05 is also considered a containment isolation valve for penetration P-80.

These valves are open during normal operation to provide a flow path from the charging pun1ps, through the regenerative heat exchanger tubes to recover heat from the letdown flow, then to the reactor coolant system. This function is not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves closed (full or patiial) during normal power operations since exercising these valves places the plant in an undesirable condition.

Exercising these valves closed during normal power operations places the plant in an undesirable configuration since closure of the valves interrupts charging flow to the reactor coolant system.

Interruption of charging flow to the reactor coolant system may result in a loss of pressurizer level control and subsequent reactor trip.

Alternative Test These valves will be exercised tested during cold shutdowns when the chemical and volume control system is not required to be in service.

Revision Date: 12/10/2014 Page 41 Attachment to ULNRC-06166

Valve Number BGHV8152 BGHV8160 Function Callaway Energy Center Cold Shutdown Justification CSJ-10 System Class BG 2

BG 2

lnservice Testing Program Revision 32 Category A

A These normally open air operated valves must close upon receipt of a Phase A containment isolation signal to isolate containment from the chemical and volume control system. The valves are considered containment isolation valves for penetration P-23. These valves also fail closed on loss of air or electrical power.

The valves are normally open to provide a letdown flow path from the letdown orifice header to the letdown heat exchanger. This function is not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves closed (full or pat1ial) during normal power operations since exercising these valves places the plant in an undesirable condition.

Exercising these valves closed during normal power operations places the plant in an undesirable configuration since failure may cause a loss of pressurizer level control and subsequent reactor trip.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the reactor coolant system is depressurized.

Revision Date: 12/10/2014 Page 42 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-11 Valve System Class Number BGLCV0112B BG 2

BGLCV0112C BG 2

Function lnservice Testing Program Revision 32 Category B

B These normally open motor operated valves must close automatically upon receipt of a safety injection signal to isolate the volume control tank from the charging pump suction. Closure of these valves is required to ensure a flow path from the refueling water storage tank to the charging pumps during the injection mode of ECCS. The valves will also close automatically upon receipt of a volun1e control tank low water level signal.

The valves are normally open to provide a suction path from the volume control tank to the charging pumps during normal power operations to maintain and control reactor coolant inventory. This function is not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves closed (full or patiial) during normal power operations since exercising these valves places the plant in an undesirable condition.

Exercising these valves closed during normal power operations places the plant in an undesirable configuration since closure of these valves isolates the normal suction of the charging pumps.

Alternate charging suction paths would increase the reactor coolant system boron inventory and may result in a reactor trip.

Alternative Test These valves will be exercised closed during cold shutdowns when the chemical and volume control system is not required to be in service.

Revision Date: 12/10/2014 Page 43 Attachment to ULNRC-06166

Valve Number BGLCV0459 BGLCV0460 Function Callaway Energy Center Cold Shutdown Justification CSJ-12 System Class BG 1

BG 1

lnservice Testing Program Revision 32 Category B

B These normally open air operated valves must close automatically upon receipt of a pressurizer low level signal to isolate the letdown line and regenerative heat exchanger from the reactor coolant system thus preventing further potential loss of reactor coolant. The valves are also interlocked such that they cannot be opened if any orifice valves (BGHV8149A,B,C) are open.

These valves also fail closed upon loss of air or electrical power.

The valves are opened to provide a letdown flow path from the reactor coolant system to the regenerative heat exchanger during normal power operation. This function is not required for safe shutdown or accident mitigation.

Justification It is ilnpracticable to exercise these valves closed (full or partial) during normal power operations since closure would isolate the normal letdown flowpath which places the plant in an undesirable condition.

Exercising these valves closed during normal power operations places the plant in an undesirable configuration since normal letdown from the reactor coolant system would be isolated. Closure of these valves at power may cause a voiding effect which could lead to water hammer and subsequent equipment damage. Additionally, closure of these valves during normal power operation could adversely affect pressurizer level control and result in a trip of the reactor.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the normal reactor coolant system letdown flowpath is not required.

Revision Date: 12/10/2014 Page 44 Attachment to ULNRC-06166

Valve Number BGV0147 BGV0165 BGV0174 Function Callaway Energy Center Cold Shutdown Justification CSJ-13 System Class BG 3

BG 3

BG 3

lnservice Testing Program Revision 32 Category c

c c

These check valves n1ust open to provide a flow path from the discharge of the boric acid transfer pumps to the charging pump suction header when emergency boration is required.

Valves BGVO 14 7, 0165 1nust close to prevent backflow through an idle pun1p while the other pump is operating for emergency boration. Closure of this valve ensures adequate flow of boric acid to the charging ptunp suction header, which is ultimately delivered to the reactor coolant system during emergency boration operations.

Valve BGV0174 must close to prevent the flow of RHR Heat Exchanger discharge or RWST supply to the charging pun1p suction header from being diverted from the suction of the charging pumps. The closing of this valve will ensure that these other charging pump suction sources will be delivered to the charging pumps, which is ultimately delivered to the reactor coolant system during an accident.

Justification Exercising these valves open during normal power operations requires injection of a substantial amount of boron into the reactor coolant system to verify full flow. Boration of the reactor coolant system to perform this test would cause a power transient due to the negative reactivity addition and would result in reactor power fluctuations and subsequent reactor trip.

Alternative Test These valves will be exercised open during cold shutdowns when the chemical and volume control and reactor coolant systems are not required. Also, BGV0174 will be exercised close during cold shutdowns. BGV0147 and BGV0165 are exercised closed during normal operations of (the opposite train) boric acid transfer pumps.

Revision Date: 12/10/2014 Page 45 Attachment to ULNRC-06166

Valve Number BNHV8813 Function Callaway Energy Center Cold Shutdown Justification CSJ-14 System Class BN 2

Inservice Testing Program Revision 32 Category B

This normally open motor operated valve must close to isolate the RWST from the safety injection pump discharge piping during switchover from injection mode to recirculation mode of emergency core cooling system (ECCS). The valve is closed by remote manual operation. The valve does not receive any automatic actuation signals and is maintained in the open position with power removed during normal operations.

This valve is normally open to provide a minimum flow path to recirculate flow to the R WST in the event that -the pumps are started with the RCS pressure above pump shutoff head.

Additionally, this valve pen11its pump testing during normal plant operation. These functions are not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise this valve closed (full or partial) during normal power operations since closure of this valve would place the plant in an undesirable configuration.

Exercising this valve closed during normal power operations places the plant in an undesirable configuration since both trains of safety injection pumps would be inoperable. Additionally, failure of the valve in the closed position would damage the safety injection pumps due to overheating, in the event of a safety injection signal with the reactor coolant pressure above that of the safety injection pump discharge pressure.

Alternative Test This valve will be exercised closed during cold shutdowns when the safety injection pumps are not required to be in service.

Revision Date: 12/10/2014 Page 46 Attachment to ULNRC-06166

Valve Number EJ8730A EJ8730B Function Callaway Energy Center Cold Shutdown Justification CSJ-15 System Class EJ 2

EJ 2

Inservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the Residual Heat Removal (RHR)

Pump to the Reactor Coolant (RCS) System. The valves are located on the discharge header for the associated RHR Pump. The valve isolates one train of RHR and must open to allow flow during the Injection and Recirculation phases of ECCS.

These valves must close to prevent diverting Residual Heat Removal flow when the associated pump is secured but the opposite train pump is running. The RHR System is designed to be a redundant (two train) system. Therefore, one train of RHR could be required in an accident while the other train is secured or inoperable. In that case this valve would be required to close to prevent diverting flow from the operating train.

Justification Exercising these valves open during normal power operations would require injection of cold water by the residual heat removal pumps into the RCS hot legs. Since the residual heat removal pump cannot overcome the reactor coolant system pressure during normal power operations, this testing cannot be performed.

Alternative Test These valves will be exercised open during cold shutdowns. The valve closure test is performed quarterly by verification of differential pressure across the closed valve.

Revision Date: 12/10/2014 Page 47 Attachment to ULNRC-06166

Valve Number EJHV8701A EJHV8701B Function Callaway Energy Center Cold Shutdown Justification CSJ-16 System Class EJ 1

EJ 1

Inservice Testing Program Revision 32 Category A

A These normally closed motor operated valves must close to isolate containment and the Reactor Coolant System from the RHR System. Closure of these valves is by remote manual operation, and they do not receive an automatic signal to close. The valves are considered containment isolation valves for Penetration P-79/P-52. The valves are also considered a pressure isolation valves (PlY) and n1ust close to isolate the RCS from the RHR System.

These valves open to provide a flow path from the Reactor Coolant System (RCS) to the Residual Heat Removal (RHR) Pump suction when RCS cooling is required during shutdowns.

This is not an IST safety function. The RHR system is used to remove heat from the RCS when RCS temperature is less than 350F. This valve is interlocked to prevent opening when RCS pressure is greater than 3 60 psi g.

Justification It is impracticable to open these valves during norn1al power operations since it places the plant in an undesirable configuration.

Exercising these valves during normal power operations would require defeating the safety interlock which 1naintains the valves closed when reactor coolant pressure is greater than 360 psig. Additionally, opening these valves at power would cause the reactor coolant system to overpressurize the lower pressure residual heat removal system.

Alternative Test These valves will be exercise tested closed during cold shutdowns when the reactor coolant system is depressurized below 360 psig.

Revision Date: 12/10/2014 Page 48 Attachment to ULNRC-06166

Valve Number EJHV8716A EJHV8716B Function Callaway Energy Center Cold Shutdown Justification CSJ-17 System Class EJ 2

EJ 2

Inservice Testing Program Revision 32 Category B

B These normally open motor operated valves must open to provide a flow path from the Residual Heat Removal (RHR) pump to the Reactor Coolant System (RCS) cold legs during ECCS Injection. The system is designed such that either RHR pump may inject into all four of the cold legs. Therefore these valves are maintained open during modes 1 through 3. The valves must also open to provide a flow path from the RHR pump to the RCS hot legs during ECCS hot leg recirculation mode. These valves do not receive any automatic actuation signals and are operated by remote manual operation. [FSAR Table 6.3-3]

These valves must close to prevent diversion of flow away fro111 the RCS and the Safety Injection/Charging Pumps during ECCS Cold Leg Recirculation. The RHR System includes two redundant trains. However, the trains are crossconnected on the discharge of the RHR pumps, and these valves isolate one train from the cross-connect pipe. To prevent certain failures from affecting both trains, these valves must close.

Justification It is impracticable to exercise these valves open or closed (full or pm1ial) during normal power operations since closing either valve places the plant in an undesirable configuration.

Exercising the valves during normal power operations places the plant in an undesirable configuration since closure of either valve isolates the respective RHR pump from two RCS cold legs. In this configuration, both trains of Emergency Core Cooling System (ECCS) are inoperable.

Alternative Test These valves will be exercised open and closed during cold shutdowns.

Revision Date: 12/10/2014 Page 49 Attachment to ULNRC-06166

Valve Number EJHV8804A EJHV8804B Function Callaway Energy Center Cold Shutdown Justification CSJ-18 System Class EJ 2

EJ 2

lnservice Testing Program Revision 32 Category B

B These normally closed motor operated valves must open to provide a flow path from the Residual Heat Removal (RHR) System to the suction of the Centrifugal Charging Ptnnps (EJHV8804A) and Safety Injection Pumps (EJHV8804B). The valves are required to open to supply the high head pumps with recirculated cooling water. The valves do not receive any auton1atic actuation signals and are opened by the operator during recirculation switchover.

EJHV8804A must remain closed during the Injection mode of ECCS to isolate the RHR System from the suction of the Centrifugal Charging Pumps. EJHV8804B 1nust remain closed during the Injection mode of ECCS to isolate the RHR System from the suction of the Safety Injection Pumps.

These closure functions ensure sufficient flow for RHR Injection. EJHV8804B is interlocked such that it cannot be opened unless the Safety Injection Pump minimum flow line is isolated (EMHV8814A/B closed) and the RHR Suction valve from the RCS (EJHV8701A/B) is closed.

Justification It is impracticable to exercise these valves open during normal power operations since exercising valves places the plant in an undesirable configuration.

Exercising these valves open during normal power operations would require defeating the ECCS interlocks which would render both trains of safety injection inoperable.

Alternative Test These valves will be exercised open during cold shutdowns.

Revision Date: 12/10/2014 Page SO Attachment to ULNRC-06166

Valve Number EJHV8809A EJHV8809B Function Callaway Energy Center Cold Shutdown Justification CSJ-19 System Class EJ 2

EJ 2

lnservice Testing Program Revision 32 Category B

B These normally open motor operated valves must remain open to provide a flow path from the Residual Heat Removal (RHR) Pumps to the Reactor Coolant System cold legs during ECCS injection and cold leg recirculation. The valves are maintained open with power removed during Modes 1-3 to ensure a flow path to the RCS cold legs from the RHR System.

The valves must close to isolate the Reactor Coolant System cold legs from the RHR System during hot leg recirculation. These valves do not receive any automatic isolation signals and are closed by the operator during switchover from cold leg recirculation to hot leg recirculation. The valves are also considered containment isolation valves required to close to isolate penetration P-27 /82. The valves may be closed by the remote manual operator action for containment isolation purposes.

Justification It is impracticable to exercise these valves closed (full or partial) during normal power operations since closure of this valve would place the plant in an undesirable configuration.

Exercising the valves closed during normal power operations places the plant in an undesirable configuration since closure of these valves requires restoration of power to the valves and placing the RHR portion of ECCS in an inoperable status.

Alternative Test These valves will be exercised closed during cold shutdowns.

Revision Date: 12/10/2014 Page 51 Attachment to ULNRC-06166

Valve Number EJHV8811A EJHV8811B Function Callaway Energy Center Cold Shutdown Justification CSJ-20 System Class EJ 2

EJ 2

Inservice Testing Program Revision 32 Category B

B These normally closed motor operated valves must open to provide a flow path from the Containment Recirculation Sump to the suction of the Residual Heat Removal (RHR) Pump when the Emergency Core Cooling (ECCS) System shifts from Injection to Recirculation modes.

The valves open automatically on a Refueling Water Storage Tank (RWST) low-low 1 signal coincident with a Safety Injection signal (SIS). [FSAR Table 6.3-3] This function supports safe shutdown and accident mitigation by providing a recirculation flow path from the Containment Sump when the RWST is exhausted following the Injection mode.

The valves are considered Contai1m1ent Isolation valves for Penetration P-14115 and may be closed by remote manual operation to isolate the Containment Recirculation Sump and Containment from the Residual Heat Removal System. These valves do not receive an automatic Containment Isolation signal since it must remain open during the Recirculation mode of ECCS.

During normal operations the valves are interlocked and cannot be opened unless the RHR suction valves from both the RWST and RCS are closed.

Justification It is impracticable to exercise these valves open or closed (full or partial) during normal power operations since opening the valves places the plant in an undesirable configuration.

Exercising the valves open and closed during normal power operations places the plant in an undesirable configuration since opening these valves requires defeating the interlocks on the RHR suction isolation valves from the R WST and RCS. This test would require placing both trains of RHR in an inoperable status.

Alternative Test These valves will be exercised open and closed during cold shutdowns when RHR 1s not required and the suction isolation valves from the RWST and RCS may be opened.

Revision Date: 12/10/2014 Page 52 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-21 Valve Number System Class EJHV8840 EJ 2

Function Inservice Testing Program Revision 32 Category B

This normally closed motor operated valve must open to provide a flow path from the Residual Heat Removal (RHR) pumps to the Reactor Coolant System (RCS) Hot Legs during the Hot Leg Recirculation mode of ECCS. This valve is opened by the operator during switchover from Cold Leg Recirculation to Hot Leg Recirculation. This valve does not receive any automatic signals and is opened by remote manual operator action when the Recirculation Phase of ECCS IS initiated. This function supports safe shutdown and accident mitigation.

This valve must close to isolate the RCS Hot Legs from the RHR system during Injection and Cold Leg Recirculation modes of ECCS. The valve is maintained in the closed position with power locked out to prevent inadvertent operation during normal power operations. The valve is also a Containment Isolation valve for Penetration P-21 and n1ay be closed by remote manual operation to isolate Containment from the RHR system. The valve does not receive a Containment Isolation Signal since it must open during Hot Leg Recirculation.

Justification It is in1practicable to exercise this valve open (full or partial) during normal power operations since opening this valve places the plant in an undesirable configuration.

Exercising the valve open during non11al power operations places the plant in an undesirable configuration since opening this valve requires restoration of power to the valve and placing the RHR portion of ECCS in an inoperable status.

Alternative Test These valves will be exercised open during cold shutdowns.

Revision Date: 12/10/2014 Page 53 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-22 Valve Number System Class EMHV8835 EM 2

Function Inservice Testing Program Revision 32 Category B

This normally open motor operated valve must open to provide a flow path from the safety injection pumps to the reactor coolant system cold legs during injection and cold leg recirculation modes of ECCS. This valve is maintained in the open position and blocked from inadvertent operation by having its power removed during normal plant operation.

This valve n1ust close to isolate the reactor coolant system cold legs from the safety injection system during hot leg recirculation. This valve is closed by the operator during switchover from cold leg recirculation to hot leg recirculation and does not receive any automatic isolation signals. Once closed, this valve is not required to reposition to support any accident analysis events. Therefore, the open function is considered passive.

This valve is considered a containn1ent isolation valve for penetration P-49 and may be closed by remote manual operation to isolate containment from the safety injection system. This valve does not receive an auton1atic containment isolation signal since it n1ust remain open during safety injection and cold leg recirculation 1nodes of operation.

Justification It is impractical to exercise this valve closed (full or partial) during normal power operations since closing this valve places the plant in an undesirable configuration.

Exercising the valve during normal power operations places the plant in an undesirable configuration since closure of this valve isolates the cold leg injection path to the RCS. In this configuration, the cold leg injection path of Emergency Core Cooling System (ECCS) is inoperable.

Alternative Test This valve will be exercised closed during cold shutdowns when the safety injection to the cold legs of the RCS is not required to be in service.

Revision Date: 12/10/2014 Page 54 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-23 Valve Number System Class ENHVOOOl EN 2

ENHV0007 EN 2

Function lnservice Testing Program Revision 32 Category B

B These normally closed motor operated valves must open to provide a suction flow path from the containment recirculation sump to the respective containment spray pump when the containn1ent spray pump suction is switched to the containment recirculation sump. These valves do not receive any automatic actuation signals and are opened ren1ote manually by the operator during switchover to recirculation phase when the low-low-2 level in the RWST is reached.

These valves must remain closed to isolate contairu11ent from the contairunent spray system. The valves receive a confirmatory Phase A containn1ent isolation signal (CIS-A) to close within 30 seconds. These valves are considered containment isolation valves for Penetration P-13 (ENHV0007) and P-16 (ENHV0001).

Justification Exercising the valves open during normal power operations places the plant in an undesirable configuration since opening the valve would run the risk of draining the contairunent spray pmnps suction headers into the contairunent sump which would cause severe damage to the pumps and render them inoperable. The R WST would be required to be isolated during this testing to prevent flooding of containment should the single check valve fail to close. Current procedure requires the containment spray suction header to be drained prior to exercising these valves for testing purposes. Due to the amount of time for system draining/filling/venting to perfmm this test along with the increased risk associated with having the RWST isolated, this testing is considered impracticable to perform during power operations.

Alternative Test These valves will be exercised open and closed during cold shutdowns when the containment spray suction piping is not required to be inservice and the RWST is isolated from the containment spray suction piping.

Revision Date: 12/10/2014 Page 55 Attachment to ULNRC-06166

Valve Number EPHV8808A EPHV8808D Function Callaway Energy Center Cold Shutdown Justification CSJ-24 System Class EP 2

EP 2

Inservice Testing Program Revision 32 Category B

B These normally open motor operated valves must retnain open to provide a flow path from the safety injection tank accumulator to the reactor coolant system cold leg during accident conditions whenever the reactor coolant system pressure decreases below 600 psia. During normal operation, these valves are maintained in the open position with their power removed to prevent inadvertent operation. The valves receive a confirn1atory signal to open on a safety injection signal and are interlocked such that they cannot be closed with an SIS present. The valves are not required to reposition to support any accident analysis events. Therefore, the open function for these valves is considered passive.

These valves must close prior to reducing RCS pressure below 1000 psig to avoid a loss of accumulator water inventory to the reactor coolant systen1 during safe shutdown (hot standby to cold shutdown). Additionally, the valves are closed during normal plant shutdown after the RCS has been depressurized below I 000 psig to prevent a loss of accumulator water inventory to the reactor coolant systen1. The power to the valves is disconnected after they are closed to prevent inadvertent operation. During notmal plant startup, the valve is returned to the open position and power is disconnected before the RCS pressure exceeds I 000 psi g.

Justification It is impracticable to exercise these valves closed during normal power operation since closing this valve during normal power operations places the plant in an undesirable configuration.

Exercising these valves closed during normal plant operations requires the safety injection accumulator to be isolated. Isolating the safety injection accumulator during normal power operations places the plant in an undesirable plant configuration rendering the respective safety injection accumulator tanks inoperable.

Alternative Test These valves will be exercised closed during cold shutdowns when the safety injection accumulators are not required to be in service.

Revision Date: 12/10/2014 Page 56 Attachment to ULNRC-06166

Scope Valve Number EPHV8950A EPHV8950B EPHV8950C EPHV8950D EPHV8950E EPHV8950F Function Callaway Energy Center Cold Shutdown Justification CSJ-25 System Class EP 2

EP 2

EP 2

EP 2

EP 2

EP 2

lnservice Testing Program Revision 32 Category B

B B

B B

B These normally closed solenoid operated valves must open to depressurize the safety injection accumulator tank during emergency cold shutdown conditions in the event that the outlet valves 8808A-D cannot be closed, to prevent the loss of accumulator water to the RCS.

These valves are normally closed to isolate the safety injection accumulator tank vent to containment atmosphere, thereby providing sufficient pressure in the accmnulator for injection purposes. This function is not required for safe shutdown or accident mitigation since the accumulator level and pressure is continuously monitored and alarmed in the control room. If excessive leakage is detected, the operator is required to take actions to n1aintain the plant operation within the requirements of Technical Specifications or bring the plant to a safe shutdown condition.

Justification It is impracticable to exercise these valves open (partial or full) during normal power operations since exercising these valves place the plant in an undesirable configuration.

Exercising these valves open during notmal power operations would place the plant in an undesirable configuration rendering the respective safety injection accumulator inoperable. The Technical Specification action statement may not allow adequate time to test the valves and restore the accumulator. Additionally, should one of the valves fail to close, insufficient time is allowed to repair/replace/retest prior to shutting down the plant.

Alternative Test These valves will be exercised open during cold shutdowns when the safety injection accumulators are not required to be in service.

Revision Date: 12/10/2014 Page 57 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-26 Valve Number System Class KAFV0029 KA 2

Function Inservice Testing Program Revision 32 Category A

This normally open air operated valve must close to isolate Containment from the non-safety related Instrument Air (KA) System. This valve is a containment isolation valve for Penetration P-30. The valve receives a Phase A Containment Isolation Signal to close automatically within 5 seconds.

This valve is open during normal operation to supply Instrument Air to the Reactor Building primarily for use in operating various valves. However, supplying Instrument Air to the Reactor Building does not support safe shutdown or accident mitigation.

Justification Exercising this valve closed during normal power operations would interrupt the instrument air supply to valves and equipment necessary for normal system control and operation. Closure of the valve could affect the nmmalletdown flow path and isolation of the pressurizer spray feature.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the instrument air syste1n is not required by in1portant plant components.

Revision Date: 12/10/2014 Page 58 Attachment to ULNRC-06166

Callaway Energy Center Cold Shutdown Justification CSJ-27 Valve Number System Class AEFCV0510 AE NC AEFCV0520 AE NC AEFCV0530 AE NC AEFCV0540 AE NC Function lnservice Testing Program Revision 32 Category B

B B

B These normally open air-operated valves control Main Feedwater flowrate during normal operations. In the event of a FW pipe rupture inside contairunent remote manual closure of these valves will provide a diverse backup to the Main Feedwater Isolation Valves to limit the quantity of high energy fluid that enters the containment tlu*ough a broken loop.

Justification It is impracticable to exercise these valves closed during normal power operations since exercising these valves may result in a plant transient and subsequent reactor trip.

Exercising these valves closed during normal power operations requires isolating nonnal feedwater flow to the steam generator. This testing n1ay result in a severe transient in the steam generator and subsequent reactor trip. Partial stroke exercising these valves is also impracticable since even a part-stroke exercise increases the risk of a valve closure when the unit is generating power.

Alternative Test These valves will be exercised closed and fail safe tested during cold shutdowns when the steam generators and feedwater system are not required to be in service.

Revision Date: 12/10/2014 Page 59 Attachment to ULNRC-06166

Valve Number BGHV8100 BGHV8112 Function Callaway Energy Center Cold Shutdown Justification CSJ-28 System Class BG 2

BG 2

Inservice Testing Program Revision 32 Category A

A Valves BGHV81 00/8112 are normally open motor operated valves which must close automatically upon receipt of a Phase A Containment Isolation signal to isolate containment from the reactor coolant pump seal water return line. These valves are considered a containment isolation valves for penetration P-24. The valves are open to provide a return flow path from the reactor coolant pump seals to the seal water heat exchanger during normal power operations.

This function is not required for safe shutdown or accident mitigation since the reactor coolant pump seal water return along with the reactor coolant pumps are not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves during normal power operations. Interruption of RCP seal water return flow during pump operation would damage the reactor coolant pump seals and ultimately the pump.

Alternative Test These valves will be exercised closed during cold shutdowns when the reactor coolant pumps and seal water are not required to be in service.

Revision Date: 12/10/2014 Page 60 Attachment to ULNRC-06166

Refuel Outage Justification No.

RJ-01 RJ-02 RJ-03 RJ-04 RJ-05 RJ-06 RJ-07 RJ-08 RJ-09 RJ-10 RJ-11 RJ-12 RJ-13 RJ-14 RJ-15 RJ-16 Callaway Energy Center Inservice Testing Program Revision 32 ATTACHMENT 6 REFUEL OUTAGE JUSTIFICATION INDEX Description SG Feedwater Supply Check Valves (AEV0120,121,122,123)

Normal/Alternate Charging to RCS Check Valves (BB8378A,B,8379A,B)

RCP Thermal Barrier Cooling Water Valves (BBHV0013,14,15,16)

PORV Block Valve Exercising (BBHV8000A,B)

RCP Seal Water Supply Isolation Valves (BBHV8351A,B,C,D)

CCW to RCP Thermal Barrier Supply Check Valves (BBVO 122, 152, 182,212,474,4 76,479,480)

VCT to NCP/CCP Header Check (BG8440)

Charging Pump Discharge Check Valves (BG8481A,B)

RWST to Charging Pump Suction Check Valves (BG8546A,B)

Deleted RWST to RHR Pun1p Suction Check Valves (EJ8958A,B)

Charging to RCS Cold Leg (Boron Injection) Check Valve (EM8815)

Safety Injection Pump Discharge Check Valves (EM8922A,B)

R WST to Safety Injection Pump Suction Check Valves (EM8926A,B)

SI Pump to Accumulator Fill Line Check Valve (EMV0006)

Shutdown Purge Isolation Dampers (GTHZ0006,7,8,9)

Revision Date: 12/10/2014 Page 61 Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 7 REFUEL OUTAGE JUSTIFICATIONS Revision Date: 12/10/2014 lnservice Testing Program Revision 32 Page 62 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-01 Valve Number System Class AEV0120 AE 2

AEV0121 AE 2

AEV0122 AE 2

AEV0123 AE 2

Function Inservice Testing Program Revision 32 Category c

c c

c These check valves must open to provide a flow path from the auxiliary feedwater pump to the steam generator during accident conditions requiring auxiliary feedwater system initiation. The valves are open during normal power operation to provide the normal feedwater system flow to the steam generator.

These valves close to prevent reverse flow through the associated feedwater line and to prevent blowdown of the associated Steam Generator in the event of a secondary pipe break upstream of this valve but downstremn of the Feed water Isolation valve.

Justification It is impracticable to exercise these valves closed during normal power operations since it would require isolating feedwater to the steam generator, resulting in a severe transient in the steam generator and possible reactor trip.

Exercising these valves closed requires the use of a special backleakage test rig and constant SteaiTI Generator level and temperature. Such testing would be challenging to Operations during a typical Cold Shutdown scenario.

Alternative Test These valves will be exercised closed during refueling outages when the feedwater system is not required to be operational.

Revision Date: 12/10/2014 Page 63 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-02 Valve Number System Class BB8378A BB 1

BB8378B BB 1

BB8379A BB 1

BB8379B BB 1

Function lnservice Testing Program Revision 32 Category c

c c

c These check valves must close to isolate the reactor coolant system from the charging system in the event of a pipe break in the eves system.

Valves BB83 78A,B open to provide a flow path for normal charging water flow from the charging pumps to the ReS. Valves BB8379A,B open to provide a flow path for alternate charging flow from the charging pun1ps to the ReS. The normal charging flow path maintains the required water inventory in the ReS during normal operation, power changes, startup, and shutdown. The alternate charging provides backup to the normal charging flow path. These open functions are not required for safe shutdown or accident mitigation since neither the normal charging or alternate charging flow paths are required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these check valves closed during normal power operations or cold shutdown since intenupting charging flow to the ReS places the plant in an undesirable configuration. Access to these valves requires entry behind the reactor bioshield wall inside containment, which is not practicable from a radiation exposure standpoint during normal plant operations and is not practical during cold shutdowns when the area is highly radioactive and the valve body is insulated at a temperature that exceeds non-intrusive equipment adhesive ratings.

Alternative Test These valves will be exercised closed during refueling outages when the charging system is not required and radiation levels permit entry into containment.

Revision Date: 12/10/2014 Page 64 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-03 Valve Number System Class BBHV0013 BB 3

BBHV0014 BB 3

BBHV0015 BB 3

BBHV0016 BB 3

Function lnservice Testing Program Revision 32 Category B

B B

B These valves must close to isolate the RCS from the component cooling water system in the event of a cooling coil tube leak. In the event of a leak in the thermal barrier, the valves close automatically upon receipt of a high flow signal in the component cooling water return line.

These normally open motor operated valves provide a cooling water return flow path from the RCP thermal barrier cooling coil to the component cooling water system. This function prevents RCP pump damage and degradation of the pump seals that could result due to blockage of RCP cooling water. This function is not required for safe shutdown or accident mitigation since the reactor coolant pumps are not relied upon for safe shutdown.

Justification It is impracticable to exercise these valves closed during nmmal power operations or during cold shutdowns.

Exercising these valves closed, or partially closed during normal power operations would interrupt flow to the reactor coolant pump thermal barriers which could lead to damage of the pump seals and pump radial bearing which would ultimately damage the pump. It is also impractical to exercise these valves during Cold Shutdown periods due to the need to secure RCPs for the test. This would be a challenge to Operations while trying to maintain cooldown rates and RCS inventory.

Alternative Test These valves will be exercised closed during refueling outages when the reactor coolant pumps are not required to be in service.

Revision Date: 12/10/2014 Page 65 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-04 Valve Number System Class BBHV8000A BB 1

BBHV8000B BB 1

Function lnservice Testing Program Revision 32 Category B

B These normally open motor operated valves must open to provide a flow path from the pressurizer to the pressurizer relief tank when the power operated relief valve (PORV) is required to be open for reactor coolant system depressurization.

This valve must close to isolate the reactor coolant system pressurizer in the event the pressurizer power operated relief valve (PORV) develops excessive seat leakage or if it fails to close.

Additionally, this valve must close by operator action to isolate the reactor coolant system in the event of a spurious PORV actuation signal or during an inadvertent ECCS system initiation.

Justification It is impracticable to exercise these valves during normal power operations or cold shutdown when the PORV is inoperable due to excessive seat leakage. Opening the valve may result in inadvertent depressurization of the RCS.

When these valves are closed to isolate an inoperable PORV (due to excessive leakage) the valve is administratively maintained closed with power to it. If required to open to perfotm its intended safety function, the valve is opened by the operator. Opening of this valve at any other time while the PORV is inoperable due to excessive seat leakage could result in an uncontrolled RCS discharge to the pressurizer relief tank, a loss of pressurizer pressure control, and a potential inadvertent depressurization of the RCS.

Callaway Energy Center Technical Specifications 3.4.11 requires that if the block valve is closed to isolate a single PORV due to excessive leakage, that power be n1aintained to the block valve.

This condition may not exceed the next refueling outage.

Additionally, these valves may not be partial stroke exercised since they are not provided with this feature.

Alternative Test These valves will be exercised open and closed quarterly when they are not required to be closed to isolate an inoperable leaking PORV. When these valves are required to be closed to isolate a leaking PORV they will be exercised open and closed during refueling outages when the RCS is depressurized.

Revision Date: 12/10/2014 Page 66 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-05 Valve Number System Class BBHV8351A BB 2

BBHV8351B BB 2

BBHV8351C BB 2

BBHV8351D BB 2

Function lnservice Testing Program Revision 32 Category A

A A

A These normally open motor operated valves must open to provide a flow path from eves charging pumps to the ReP seals for emergency boration. A portion of the charging flow is directed to the RCPs through the seal water filter to borate the reactor coolant system to achieve and maintain a safe shutdown [FSAR 9.3.4].

Additionally, the valves open to provide a flow path for RCP seal injection water from eves charging pumps via the RCP seals. This function prevents RCP pump damage and degradation of the pump seals that could result because a blockage of ReP cooling water.

These valves must close to isolate containment from the eves system. The valves are closed by remote-manual control. These valves are required to provide containment isolation for penetration P-22 (8351 B) I -39 (8351 C) I -40 (8351 D) I -41 (8351 A).

Justification It is impracticable to exercise these valves during normal power operations since interrupting RCP seal water return flow would damage the reactor coolant pump seals. Interruption of reactor coolant pump seal injection flow when the reactor coolant pumps are in operation would damage the pump seal and ultimately the pump.

It is also impractical to exercise these valves during Cold Shutdown periods due to the need to secure RCPs for the test. This would be a challenge to Operations while trying to maintain cooldown rates and RCS inventory.

Alternative Test These valves will be exercised during refueling outages when the reactor coolant pumps and seal water is not required to be in service.

Revision Date: 12/10/2014 Page 67 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-06 Valve Number System Class BBV0122 BB 3

BBV0152 BB 3

BBV0182 BB 3

BBV0212 BB 3

BBV0474 BB 3

BBV0476 BB 3

BBV0479 BB 3

BBV0480 BB 3

Function Inservice Testing Program Revision 32 Category c

c c

c c

c c

c These check valves must close to isolate the RCS from the component cooling water system in the event of a cooling coil tube leak.

These valves open to provide a cooling water supply flow path from the component cooling water system to the RCP thennal barrier cooling coil. This function prevents RCP pump damage and degradation of the pump seals that could result due to blockage of RCP cooling water. This function is not required for safe shutdown or accident mitigation since the reactor coolant pumps are not relied upon for safe shutdown.

Justification It is impracticable to exercise these check valves closed during normal power operations since interrupting thermal barrier cooling coil flow would damage the reactor coolant pump seals.

Testing these check valves in the safety close direction requires isolating cooling water to the Reactor Coolant Pumps (RCP) Thermal Barrier Cooling Coils and Motor Coolers. This function is required when the RCP are operating. Loss of RCP seal injection without Thermal Barrier Coolant would cause catastrophic RCP seal failure and a subsequent Small Break Loss of Coolant Accident. Loss of RCP motor cooling would result in catastrophic motor failure which would cause a loss of forced RCS flow. The cooling water to the RCPs is provided by a common header, therefore testing cannot be performed until all four RCPs are secured, which does not occur except during reactor refueling outages.

Alternative Test These valves will be exercised closed during refueling outages when the reactor coolant pumps are not required to be in service.

Revision Date: 12/10/2014 Page 68 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-07 Valve Number System Class BG8440 BG 2

Function lnservice Testing Program Revision 32 Category c

This valve must open during the injection mode of ECCS to provide a minimum flow recirculation flow path through the seal water heat exchanger to protect the charging pumps while they are in recirculation operation. This mode will occur when the R WST is still the suction source and a safety injection signal is present.

Additionally, this check valve opens to provide a flow path from the volume control tank to the charging pump suction during normal plant operations. This function is not required for safe shutdown or accident mitigation.

This valve must close to prevent backflow and isolate the seal water heat exchanger piping during recirculation modes ofECCS. Valves BGLCV112B/C close to isolate the volume control tank and check valves BG8546A/B close to isolate the refueling water storage tank during hot and cold recirculation 1nodes of ECCS while the charging pumps are supplied by the residual heat removal pumps. BG8440 must close to prevent diversion of the residual heat reinoval flow and potential actuation of the seal water heat exchanger relief valve BG8123.

Justification It is impracticable to exercise this check closed during normal power operations or during cold shutdowns. Exercising the valve requires the performance of a leakage or reverse flow test to verify the closed position.

To perform a leakage test or reverse flow test during normal operations or during cold shutdowns requires temporary test equipment to be installed to establish a differential pressure across the valve to verify closure. This test is impracticable to be performed during normal power operations or cold shutdowns since the charging and residual heat removal systems would be required to be drained/vented and out of service to perform the leakage test.

Alternative Test This valve will be exercised closed during refueling outages when the BG and EJ systems are not required to be in service. The open direction of this valve is verified using normal system flow during normal power operations.

Revision Date: 12/10/2014 Page 69 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-08 Valve Number System Class BG8481A BG 2

BG8481B BG 2

Function Inservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the charging pu1np to the reactor coolant system cold legs during injection and recirculation modes of ECCS operation.

The valves must close to prevent backflow through an idle pump during ECCS injection and recirculation modes of operation. Closure of this valve ensures adequate flow to the reactor coolant system in the event of a failure of the respective charging pump to start.

Justification It is impracticable to exercise these check valves open during normal power operations or cold shutdowns.

Exercising these valves open requires injection of borated water into the reactor coolant system.

Performance of this test during nonnal plant operations would cause an increase in the reactor coolant boron inventory resulting in a reactivity transient and potential reactor trip.

Performance of this test contains a prerequisite that the reactor vessel head be removed in order to prevent the possibility of a cold overpressurization of the reactor coolant system.

This condition is only present during refueling outage periods.

Alternative Test These valves will be exercised opened and closed during refueling outages when the reactor coolant system is not required to be in service.

Revision Date: 12/10/2014 Page 70 Attachment to ULNRC-06166

Valve Number BG8546A BG8546B Function Callaway Energy Center Refuel Outage Justification RJ-09 System Class BG 2

BG 2

lnservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the refueling water storage tank to the charging pump suction. Opening of this valve is required to ensure a flow path from the refueling water storage tank to the charging pumps during the injection mode of ECCS. The valves must also open to provide a flow path from the refueling water storage tank to the charging pumps for automatic makeup to the reactor coolant system in the event of a minor leak.

The valves must close to prevent back flow of the residual heat removal pumps discharge to the refueling water storage tank during the recirculation phase of ECCS operation. Closure of this valve ensures an adequate suction source for the charging and safety injection pumps.

Justification It is impracticable to exercise these check valves open during normal power operations or cold shutdowns.

Exercising these valves open requires injection of borated water into the reactor coolant system.

Performance of this test during normal plant operations would cause an increase in the reactor coolant boron inventory resulting in a reactivity transient and potential reactor trip.

Performance of this test contains a prerequisite that the reactor vessel head be removed in order to prevent the possibility of a cold overpressurization of the reactor coolant system.

This condition is only present during refueling outage periods.

Alternative Test These valves will be exercised opened and closed during refueling outages when the reactor coolant system is not required to be in service.

Revision Date: 12/10/2014 Page 71 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-11 Valve Number System Class EJ8958A EJ 2

EJ8958B EJ 2

Function Inservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the Refueling Water Storage Tank (RWST) to the Residual Heat Removal Pump (RHR) suction during ECCS Injection following a LOCA.

These valves must close during switchover to the Containment Sump during recirculation to prevent reverse flow from the Containment Sump to the R WST thereby ensuring a suction source for the RHR Pump.

Justification It is impracticable to exercise these valves open or closed during normal power operations or cold shutdowns since exercising the valves requires injection into the RCS.

Exercising these valves open during normal power operations would require injection by the RHR pump into the RCS to verify full flow. Since the RHR pump cannot overcome the reactor coolant system pressure during normal power operations, this testing cannot be performed.

These valves cannot be exercised during cold shutdowns because a prerequisite for the test procedure is to have the reactor vessel head removed. This is to provide sufficient expansion volume required for the injection test.

Alternative Test These valves will be exercised open and closed during refueling outages when the reactor coolant system is depressurized and injection is possible.

Revision Date: 12/10/2014 Page 72 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-12 Valve Number System Class EM8815 EM 1

Function Inservice Testing Program Revision 32 Category A/C This check valve must open to provide a flow path from the centrifugal charging pumps to the reactor coolant system cold legs during injection and recirculation modes of ECCS.

This check valve must close to isolate containment from the chemical and volume control system. The valve is considered a containment isolation valve for penetration P-88. This valve is also considered a Pressure Isolation Valve and must close to isolate the reactor coolant system fron1 the chemical and volume control system.

Justification It is impracticable to exercise this valve open or closed during normal power operations or cold shutdowns since exercising the valves requires injection into the RCS.

Exercising these valves open during notmal power operations or cold shutdowns would require injection by the charging pumps into the RCS to verify full flow. This test cannot be performed during power operations since injection of borated water into the RCS cold legs would result in a decrease in reactor power resulting in a power transient and subsequent reactor trip.

Additionally, injection during power operations would thermally shock the reactor coolant system piping.

These valves cannot be exercised during cold shutdowns because a prerequisite for the test procedure is to have the reactor vessel head removed. This provides sufficient expansion volume for the testing to prevent low temperature overpressurization of the reactor coolant system.

Alternative Test This valve will be exercised open and closed during refueling outages when the reactor coolant system is depressurized and injection by the charging pumps into the RCS is possible.

Revision Date: 12/10/2014 Page 73 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-13 Valve Number System Class EM8922A EM 2

EM8922B EM 2

Function Inservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the safety injection pump to the reactor coolant system during ECCS injection and recirculation modes of operation.

The valves must close to prevent backflow through an idle pump during ECCS injection and recirculation n1odes of operation. Closure of this valve ensures adequate flow to the reactor coolant systen1 in the event of a failure of the respective safety injection pump to start.

Justification It is impracticable to exercise these valves open or closed during no1mal power operations or cold shutdowns since exercising the valves requires injection into the RCS.

Exercising these valves open during normal power operations or cold shutdowns would require injection by the safety injection pumps into the RCS to verify full flow. This test cannot be performed during power operations since the safety injection pump cannot overcome reactor coolant system pressure.

These valves cannot be exercised during cold shutdowns because a prerequisite for the test procedure is to have the reactor vessel head removed. This provides sufficient expansion volume for the testing to prevent low temperature overpressurization of the reactor coolant system.

Alternative Test These valves will be exercised open and closed during refueling outages when the reactor coolant system is depressurized and injection by the safety injection pumps into the RCS IS possible.

Revision Date: 12/10/2014 Page 74 Attachment to ULNRC-06166

Valve Number EM8926A EM8926B Function Callaway Energy Center Refuel Outage Justification RJ-14 System Class EM 2

EM 2

Inservice Testing Program Revision 32 Category c

c These check valves must open to provide a flow path from the RWST to the safety injection pumps during the ECCS injection mode.

This valve must close to isolate the RWST from the safety injection pump suction piping during cold and hot leg recirculation modes of ECCS. This isolation provides a suction source from the RHR pump discharge to the safety injection pumps.

Justification It is impracticable to exercise this valve open or closed during normal power operations or cold shutdowns since exercising the valves requires injection into the RCS.

Exercising these valves open during notmal power operations or cold shutdowns would require injection by the charging pumps into the RCS to verify full flow. This test cannot be performed during power operations since the safety injection pump cam1ot overcome reactor coolant system pressure.

These valves crumot be exercised during cold shutdowns because a prerequisite for the test procedure is to have the reactor vessel head removed. This provides sufficient expansion volume for the testing to prevent low temperature overpressurization of the reactor coolant system.

Alternative Test These valves will be exercised open and closed during refueling outages when the reactor coolant system is depressurized and injection by the safety injection pumps into the RCS IS possible.

Revision Date: 12/10/2014 Page 75 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-15 Valve Number System Class EMV0006 EM 2

Function Inservice Testing Program Revision 32 Category A/C This check valve must close to isolate containment from the safety injection system. This valve is considered a containment isolation valve for penetration P-58.

This valve does not have a safety function in the open direction since it opens only to facilitate maintenance and testing. This valve opens to fill the safety injection accumulators with borated water or adjust level during normal power operations or shutdown. This function is not required for safe shutdown or accident mitigation since the accumulator pressure and level is continuously monitored to assure they can perfonn their function.

Justification It is in1practicable to exercise this check valve closed during normal power operations or cold shutdowns since closure testing imposes an increase in personnel radiation exposure and may delay plant statiup.

To verify closure of this valve requires a backflow/leakage test. This testing requires entry into containment for test alignment and performance. During normal power operations and during cold shutdown periods this testing would result in an increase in personnel radiation exposure.

This testing cannot be performed during cold shutdowns due to the high potential for delaying plant statiup due to the significant amount of piping required to be filled and vented.

Additionally, during cold shutdowns, a failure of this valve to close could result in a rapid depressurization of the SI accumulator rendering it inoperable.

Alternative Test These valves will be exercised closed during refueling outages when the safety injection accumulators and fill lines are not required to be in service.

Revision Date: 12/10/2014 Page 76 Attachment to ULNRC-06166

Callaway Energy Center Refuel Outage Justification RJ-16 Valve Number System Class GTHZ0006 GT 2

GTHZ0007 GT 2

GTHZ0008 GT 2

GTHZ0009 GT 2

Function Inservice Testing Program Revision 32 Category A

A A

A These normally closed 36 inch air operated valves must close to isolate containment from the containment purge system. This valve closes automatically upon receipt of a containn1ent purge isolation signal (CPIS). The CPIS is initiated by receipt of an SIS or by indication of high radioactivity levels in the purge exhaust system process effluents by one of the purge exhaust radiation n1onitors. These valves are required to provide contaimnent isolation for penetration V

-161. The valves fail closed upon loss of pnetnnatic supply or electrical power.

These valves are opened by remote manual operation to provide a flow path to/from the containment shutdown purge supply air unit to the containment atmosphere for containn1ent purge during reactor outages. This function is not required for safe shutdown or accident mitigation.

Justification It is impracticable to exercise these valves closed during normal power operations or during cold shutdowns since exercising these valves requires thetn to be opened or partially opened prior to the closure test. Opening these valves would allow the containment to be vented to attnosphere, placing the plant in an undesirable configuration. These valves are administratively maintained in the closed position during Modes 1,2 3 and 4. Opening these valves is not permitted during those operating modes due to the size of the potential containment breach they would represent.

Alternative Test These valves will be exercised closed and fail safe tested during refueling outages when the containment boundary is not required.

Revision Date: 12/10/2014 Page 77 Attachment to ULNRC-06166

Technical Position No.

TP-01 TP-02 TP-03 TP-04 TP-05 TP-06 TP-07 TP-08 TP-09 TP-10 TP-11 TP-12 TP-13 Callaway Energy Center ATTACHMENT 8 TECHNICAL POSITION INDEX Description Bi-directional Testing of Check Valves lnservice Testing Program Revision 32 Testing of Power Operated Valves with Both Active and Passive Safety Functions Passive Valves Without Test Requirements Fail Safe Testing of Valves Classification of Skid-Mounted Con1ponents EMHV8924 PIT Method Method for Establishing Acceptance Criteria for Power-Operated Valves Check Valve Condition Monitoring Check Valves in Regular Use Categorization of IST Pumps (Group A or B)

Non-Intrusive Check Valve Testing Reserved Test Frequency for Class 3 Vacuum ReliefValves, EGV0305 and EGV0306 Revision Date: 12/10/2014 Page 78 Attachment to ULNRC-06166

Callaway Energy Center ATTACHMENT 9 TECHNICAL POSITIONS Revision Date: 12/10/2014 lnservice Testing Program Revision 32 Page 79 Attachment to ULNRC-06166

Callaway Energy Center lnservice Testing Program Revision 32 Technical Position TP-01 Bi-directional Testing of Check Valves with Non-Safety Positions Purpose The purpose of this Technical Position is to establish the station position for the non-safety direction exercise testing of check valves by normal plant operations.

Applicability This Technical Position is applicable to testing of the non-safety function (direction) of check valves which are included in the Inservice Testing Program. This position applies to those check valves required to be tested in accordance with Subsection ISTC (ASME OM Code 2004 Edition through 2006 Addenda) and Mandatory Appendix II-Condition Monitoring (ASME OM Code 2004 Edition through 2006 Addenda). This Technical Position does not apply to testing of the safety function (direction) of check valves included in the Inservice Testing Program.

Background

The ASME OM Code 2004 through 2006 Addenda section ISTC-3550, "Valves in Regular Use",

states:

"Valves that operate in the course of plant operation at a frequency that would satisfy the exercising requirements of this Subsection need not be additionally exercised, provided that the observations otherwise required for testing are made and analyzed during such operation and recorded in the plant record at intervals no greater than specified in ISTC-3510."

Section ISTC-351 0 requires that check valves shall be exercised nominally every 3 months with exceptions (for extended periods) referenced.

Section ISTC-5221 (a)(2) states:

"Check valves that have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled [to] either the full open position or to the position required to perforn1 its intended function(s) (see ISTC-11 00),

and verify closure."

Section ISTC-5221(a)(3) states:

"Check valves that have a safety function in only the close direction shall be exercised by initiating flow and observing that the obturator has traveled [to] at least the partially open position,3 and verify that on cessation or reversal of flow, the obturator has traveled to the seat."

,aThe partially open position should correspond to the normal or expected system flow."

Revision Date: 12/10/2014 Page 80 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-01 (Continued) lnservice Testing Program Revision 32 Bi-directional Testing of Check Valves with Non-Safety Positions Normal or expected system flow may vary with plant configuration and alignment; however, the open "safety function" of a check valve typically requires a specified design accident flow rate.

Since Callaway Plant Operations staff is trained in recognizing normal plant conditions, Operator judgment is acceptable in determining the check valve non-safety opening direction by obtaining normal or expected flow rates for the plant operating condition.

In summary, check valve non-safety function direction is satisfactorily demonstrated by verifying closure or passing normal or expected flow as applicable.

Position Callaway Energy Center will verify the non-safety position of check valves included in the Inservice Testing Program using the plant surveillance progran1. In lieu of a dedicated surveillance to perform the non-safety direction testing, the following alternate verifications may be perfonned as follows:

1.

An appropriate means shall be determined which establishes the method for determining the open/closed non-safety function of the check valve during norn1al operations. The position determination may be by direct indicator, or by other positive tneans such as changes in system pressure, flow rate, level, temperature, seat leakage, etc. This determination shall be documented in the respective Condition Monitoring Plan for the specific check valve group. For check valves included in the Inservice Testing Program and not included in the Condition Monitoring Plan, this determination shall be docmnented in the IST Bases Document for the specific check valve group.

2.

Observation and analysis of plant processes that a check valve is satisfying its' non-safety direction function may be used. As an example, a check valve that has a safety function only in the closed direction and normally provides a flow path to maintain plant operations. If the check valve is not sufficiently open to pass flow, an alarm or indication would identify a problem to the operator. The operator would respond to take appropriate actions. Abnormal plant conditions or indications which would identify a check valve n1alfunction would be documented using the Corrective Action Program.

3.

Observation and analysis of plant logs and other records satisfied by Operator or Engineering reviews may be an acceptable method for verifying a check valve's non-safety direction during nmmal plant operations.

The open/closed non-safety fu*nction shall be recorded at a frequency required by ISTC-3510, non1inally every 3 1nonths, with exceptions as provided, in plant records such as Callaway Revision Date: 12/10/2014 Page 81 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-01 (Continued) lnservice Testing Program Revision 32 Bi-directional Testing of Check Valves with Non-Safety Positions Energy Center Operating Logs, Electronic Rounds, chart recorders, automated data loggers, etc.

Records as indicated above in 1 through 3 are satisfactory for the non-safety direction testing.

Any issues regarding check valve operability are addressed using the Corrective Action Program.

Justification This Technical Position requires that the method of determining the non-safety position be established and documented in either the Condition Monitoring Plan or theIST Bases Document.

The plant systems and operator actions provide for the observations and analysis that the valve is satisfying its non-safety function. Additionally, the recording of parameters which demonstrate valve position is satisfied at a frequency in accordance with ISTC-351 0. These actions collectively demonstrate the non-safety position of Inservice Testing Program check valves in regular use as required by ISTC-3550.

Revision Date: 12/10/2014 Page 82 Attachment to ULNRC-06166

Purpose Callaway Energy Center Technical Position TP-02 Testing of Power Operated Valves with Both Active and Passive Safety Functions lnservice Testing Program Revision 32 The purpose of this Technical Position is to establish the testing requirements for power operated valves which have both an active and passive safety function.

Applicability This Technical Position is applicable to power operated valves which have an active safety function in one direction while performing a passive safety function in the other direction.

Background

TheIST Progran1 requires valves to be exercised to the position(s) required to fulfill their safety function(s). In addition, valves with remote position indication shall have their position indication verified. The Code does not restrict position indication testing to active valves.

Position Several valves included in the plant are designed to perfo1m passive safety functions during accident conditions, and then based on plant accident response, are designed to change positions to perform another (active) function. Once in their final position, there exist no conditions (for cettain valves) in which they would be required to be returned to their original passive position.

These valves are typically emergency core cooling system valves, which require changing position during different phases of the accident. After the original passive safety function (e.g.

provide flow path) is performed, the valves are repositioned to perform the active safety function (e.g. provide containtnent isolation or to allow injection from another water source). The valves are not required to return to their original position.

Power operated valves with passive functions in one direction and active in the other, will be stroke timed in only their active position. If these valves have remote position indication, the position indication verification will include verification of both positions.

Justification Code Interpretation 0 1-02 (response to inquiry 0 MI 07) addressed this issue.

Question: If a valve has safety functions in both the open and closed positions and is maintained in one of these positions, but is only required to move from the initial position to the other and is not required to return to the initial position, is stroke timing in both directions required?

Reply: No Revision Date: 12/10/2014 Page 83 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-03 Passive Valves without Test Requirements Purpose lnservice Testing Program Revision 32 The purpose of this Technical Position is to establish the station position for valves which perform a passive safety function; however, no testing in accordance with ISTC is required.

Applicability This Technical Position is applicable to valves which perform a passive function in accordance with IST A-2000 and do not have inservice testing requirements per Table ISTC-3500-1. This position is typical of Category B, passive valves which do not have position indication.

"An exan1ple is a manual valve which must remain in its normal position during an accident, to perform its intended function."

Typically, n1anual valves which perform a passive safety function are locked in their safety position and ad1ninistratively controlled by Callaway Plant procedures. These valves would be considered passive. If they do not have remote position indicating systems and are categorized as B, they would not be subjected to any test requirements in accordance with Table ISTC-3500-1.

Background

NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants" states In Section 2.4.2:

"A valve need not be considered active if it is only temporarily removed from service or from its safety position, such as manually opening a smnple valve for a short tin1e to take a sample, while maintaining administrative control over the valve. If the plant is in an operating mode that does not require a passive valve to be maintained in its "passive" (safety) position, the position of the valve may be changed without imposing IST

. requirements on the valve. By contrast, if a valve is routinely repositioned during power operations (or has an active safety function), it is an active valve. If a valve is repositioned to create a new alignment (e.g., as a corrective action for a condition of another valve in the line), an evaluation (considering the impact on the 1ST program) 1nay be required to ensure operational readiness before positioning the valve in a new position, as determined on a case-by-case basis."

Position The Callaway Energy Center Inservice Testing Program Valve Tables will not list valves which meet all of the following criteria.

Revision Date: 12/10/2014 Page 84 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-03 (Continued)

Passive Valves without Test Requirements lnservice Testing Program Revision 32 The valve is categorized B (seat leakage in the closed position is inconsequential for fulfillment of the valves' required function(s)) in accordance with ISTC-1300.

The valve is considered passive (valve maintains obturator position and is not required to change obturator position to accomplish the required function(s)) in accordance with IST A-2000.

The valve does not have a remote position indicating system which detects and indicates valve position.

The Callaway Energy Center Inservice Testing Program Basis will list such ASME Class valves and include a statement justifying their designation as Passive.

Justification Valves which 1neet this position will not be listed in the Callaway Energy Center Inservice Testing Progran1 Valve Tables; however, the basis for categorization and consideration of active/passive functions shall be documented in theIST Program Basis Document.

Revision Date: 12/10/2014 Page 85 Attachment to ULNRC-06166

Purpose Callaway Energy Center Technical Position TP-04 Fail Safe Testing of Valves lnservice Testing Program Revision 32 The purpose of this Technical Position is to establish the station position for fail safe testing of valves in conjunction with stroke time exercising or position indication testing.

Applicability This Technical Position is applicable to valves with fail safe actuators required to be tested in accordance with ISTC-3560.

Background

The ASME OM Code 2004 through 2006 Addenda section ISTC-3560 requires; "Valves with fail-safe actuators shall be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510."

Section ISTC-351 0 states; "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months... "

Position In cases where norn1al valve operator action moves the valve to the open or closed position by de-energizing the operator electrically, by venting air/system medium, or both, the exercise test will satisfy the fail safe test requirements and an additional test stroke specifically for fail safe testing will not be performed.

Callaway Energy Center will also use remote position indication as applicable to velify proper fail safe operation, provided that the indication system for the valve is peliodically velified in accordance with ISTC-3700.

Justification Callaway Energy Center Inservice Testing Program valves that fail open or closed upon loss of actuator power use the fail safe mechanism to stroke the valve to its safety position. For example, considering an air operated valve that fails closed. Such valves may use air to open the valve against spring force. When the actuator control switch is placed in the closed position for an exercise test, air is vented from the diaphragm and the spring moves the obturator to the closed position. This constitutes an adequate verification of the fail-safe operational readiness of the valve.

Revision Date: 12/10/2014 Page 86 Attachment to ULNRC-06166

Purpose Callaway Energy Center Technical Position TP-05 Classification of Skid Mounted Components Inservice Testing Program Revision 32 The purpose of this technical position is to clarify requirements for classification of various skid mounted con1ponents, and to clarify the testing requirements of these components.

Applicability Various pumps and valves that are procured as part of larger component subassemblies and which are typically not designed to meet the testing requirements for ASME Code Classes 1, 2, and 3 con1ponents.

Background

The ASME Code allows classification of some components as skid mounted when their satisfactory operation is demonstrated by the satisfactory performance of the associated major cmnponents. Testing of the major component is sufficient to satisfy lnservice Testing requiren1ents for skid mounted components. In section 3.4 of NUREG 1482 Rev. 2, the NRC supports the designation of components as skid mounted:

"The staff has determined that the testing of the major con1ponent is an acceptable n1eans for verifying the operational readiness of the skid-mounted and component subassemblies if the licensee discusses this approach in theIST program document."

and

"'This is acceptable for both Code class components and non-Code class components tested and tracked by the IST Program."

In the 1996 addenda to the ASME OM Code (endorsed by 1 OCFR50.55(a) in October 2000), the term skid-mounted was clarified by the addition of IST A paragraph 1. 7:

IST A 1. 7 Definitions Skid mounted components and component sub-assemblies - components integral to or that support operation of major components, even though these components may not be located directly on the skid. In general, these components are supplied by the manufacturer of the major component. Examples include: diesel skid-mounted fuel oil pumps and valves, steam admission and trip throttle valves for high-pressure coolant injection or auxiliary feedwater turbine-driven pmnps, and solenoid-operated valve provided to control the air-operated valve.

This definition is further clarified as stated in the 2004 Edition IST A-2000 DEFINITIONS:

Revision Date: 12/10/2014 Page 87 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-05 (Continued)

Classification of Skid Mounted Components lnservice Testing Program Revision 32 Skid mounted pumps and valves; pumps and valves integral to or that support operation of major components, even though these pumps and valves may not be located directly on the skid. In general, these pumps and valves are supplied by the manufacturer of the major component. Examples include:

(a) diesel fuel oil pumps and valves; (b) steam admission and trip throttle valves for high-pressure coolant injection turbine-driven pumps; (c) steam admission and trip throttle valves for auxiliary feed water turbine driven pumps; (d) solenoid-operated valves provided to control an air-operated valve.

Additionally the Subsections pertaining to pumps (ISTB) and valves (ISTC) includes exclusions/exemptions for skid mounted c01nponents; ISTB-1200( c) Exclusions "Skid-1nounted pumps that are tested as part of the major component and are justified by the Owner to be adequately tested."

ISTC-1200 Exemptions "Skid-mounted valves are excluded from this Subsection, provided they are tested as part of the 1najor component and are justified by the Owner to be adequately tested."

Position The 2004 ASME OM Code definition of skid mounted should be used for classification of components in the Callaway Nuclear Plant Inservice Testing Program. In addition, for a component to be considered skid mounted:

The 1najor component associated with the skid mounted component must be surveillance tested at a frequency sufficient to meet ASME Code test frequency for the skid mounted component.

Satisfactory operation of the skid mounted component must be demonstrated by satisfactory operation of the major component.

Revision Date: 12/10/2014 Page 88 Attachment to ULNRC-06166

Callaway Energy Center Technical Position TP-05 (Continued)

Classification of Skid Mounted Components Inservice Testing Program Revision 32 The 1ST Bases Document should describe the bases for classifying a component as skid mounted and the 1ST Program Plan should reference this technical position for the component.

Justification Classification of components as skid mounted elitninates the need for testing of sub components that are redundant with testing of major cotnponents provided testing of the major components demonstrates satisfactory operation of the "skid tnounted" components.

Revision Date: 12/10/2014 Page 89 Attachment to ULNRC-06166