Text

Response to Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test
	ML15163A166
Person / Time
Site:	Indian Point
Issue date:	06/08/2015
From:	Coyle L; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-068, TAC MF3369
	Download: ML15163A166 (319)
	v • d • e

Enterav Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB

'w Entergy P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-068 June 8, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Response to Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test (TAC NO. MF3369)

Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

REFERENCES:

1. NRC Letter to Entergy, Request for Additional Information Regarding the Proposed License Amendment to Permanently Extend the Containment Type A Leak Rate Test Frequency to 15 years (TAC NO. MF5382),

dated April 28, 2015

2. Entergy Letter NL-14-128 to NRC Regarding Proposed License Amendment Regarding Extending the Containment Type A Leak Rate Testing Frequency to 15 years, dated December 9, 2014 (ML14353A015)

Dear Sir or Madam:

Entergy Nuclear Operations, Inc., (Entergy) is hereby providing the attached response to the NRC request for additional information, Reference 1, associated with the proposed changes to the Indian Point 2 Technical Specifications (TS) in Reference 2. The responses to the request for additional information are provided in Attachment 1.

No new Regulatory Commitment is made in this submittal.

A copy of this response and the associated Attachments is being submitted to the designated New York State official in accordance with 10 CFR 50.91.

ccIz

NL-15-068 Docket No. 50-247 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 2015.

Sincerely, LC/sp

Attachment:

Response to Request for Additional Information Regarding the Extension of the Containment Type A Leak Rate Testing Frequency to 15 years

Enclosure:

Documents Provided in Support of The Response to Request for Additional Information Regarding the Extension of the Containment Type A Leak Rate Testing Frequency to 15 years cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT TO NL-15-068 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EXTENSION OF THE CONTAINMENT TYPE A LEAK RATE TESTING FREQUENCY TO 15 YEARS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

NL-15-068 Docket No. 50-247 Attachment Page 1 of 8 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EXTENSION OF THE CONTAINMENT TYPE A LEAK RATE TESTING FREQUENCY TO 15 Years In order for the NRC staff to complete their review of the Entergy request for Technical Specification Amendment to extend the Containment Type A leak test, the NRC Containment and Ventilation Branch (SCVB) has requested additional information. These requests and Entergy's responses follow:

SCVB RAI-1 License Amendment Request (LAR) Section 4.3.1 "Integrated Leak Rate Test (ILRT) Test Results" (pages 5&6 of 19, Attachment 1, Reference 1) details all test pressures in the absolute pressure scale of "psia" [pounds per square inch absolute]. Without providing the corresponding atmospheric pressure for each test pressure, the U.S. Nuclear Regulatory Commission (NRC) staff cannot confirm that the "calculated peak containment internal pressure for the Design-Basis-Loss-Of-Coolant accident, Pa, ... " of 47 psig [pounds per square inch gauge] was satisfied during ILRT test performance (Reference Indian Point Nuclear Generating Unit No. 2 (IP2) Technical Specification (TS) 5.5.14.b), consistent with the direction of Nuclear Energy Institute (NEI), Revision 2-A (Reference

2) and the test methodology of American National Standards Institute/American Nuclear Society (ANSI/ANS) 56.8-2002 (Reference 3).

For example an excerpt from Section 4.3.1 reads:

"The last two tests were:

1. The last ILRT in April 2006 had a measured containment leak rate (Ltm) at the test pressure of 60.5 psia was 0.0636 % containment air weight / day with a 95% confidence level."

Since Pa equals 47 psig, a test pressure of 60.5 psia prompts concern that the test pressure was not greater than Pa.

The staff requests that the licensee provide the corresponding recorded atmospheric pressures from each of the five ILRT test results recorded in Section 4.3.1

Response

The minimum allowable containment pressure during a Type A test is established in paragraph 3.2.12 of ANSI/ANS-56.8-2002 "Containment System Leakage Testing Requirements," which states that "The Type A test pressure shall not be less than 0.96 Pa for the duration of the Type A test". For the IP2 containment the Pa is 47 psig resulting in a minimum allowed containment pressure during the Type A test of 45.12 psig.

The IP2 Integrated Leak Rate Test procedure 2-PT-10YO01 used for the 2006 ILRT states that the lowest pressure reading during the ILRT was 60.5 psig when the outside atmospheric pressure was 14.848 psig yielding a minimum test pressure of 45.652 psig. Since the minimum test pressure of 45.652 psig was greater than the minimum required pressure of 45.12 psig, the requirements of ANSI/ANS-56.8-2002 were satisfied.

NL-15-068 Docket No. 50-247 Attachment Page 2 of 8 The five tests identified in NL-14-128, Section 4.3.1 are the ILRTs performed in August 1979, September 1984, December 1987, June 1991 and April 2006. The lowest recorded test pressures and the highest atmospheric pressures are recorded below. No recorded atmospheric pressures are available from the August 1979 test.

Year Lowest Containment Highest Atmospheric Pressure Differential Pressure (psia) Pressure (psia) 1979 No data 1984 65.285 14.904 50.381 1987 62.913 14.7" 48.213 1991 61.562 14.7" 46.862

The atmospheric pressure was not measured but assumed to be 14.7 psia.

SCVB RAI-2 The last sentence of page 6 of 19, Attachment 1 (Reference 1) from LAR Section 4.3.2 "Type B and C testing" reads "Notes are provided for test failures." However, no notes in Table 4.3-2 or subsequent pages of the LAR were provided that detail: (a) which Type B and Type C local leak rate tests (LLRTs) failed; (b) what corrective actions were performed; and (c) what historical test failures have been repetitive from the total population of Type B penetrations and Type C isolation valves.

The staff requests that the licensee provide this missing information.

Response

The LLRT failures, corrective actions and historical test failures as repetitive from the total population of Type B penetrations and Type C isolation valves follow:

During the 2R21 refueling outage in 2014 the leak rate through PRT Nitrogen Supply Line Check Valve 518 (3/4") was 1387.5 cc/min which exceeded the acceptance criterion of 300 cc/min. The acceptance criterion is an administrative limit and a higher value can be accepted without repair on an individual case basis when the overall containment leakage remains within the 10CFR50, Appendix J limit. This failure was documented in the IPEC Corrective Action program. Since an evaluation demonstrated that this leak rate did not adversely impact the ability of the containment to perform its design function (i.e. meet the leak rate limits of 10CFR50, Appendix J), this valve was accepted and a repair has been scheduled for the 2016 2R22 refueling outage. This was not a repetitive failure since this valve had not previously exceeded its leak rate limit.

Also during the 2R21 refueling outage, the leak rate through RCDT Nitrogen Supply Line CIV 1616 (1") was 21,000 cc/min, which exceeded the acceptance criteria of 400 cc/min. This failure to meet the acceptance criteria was accepted because the overall leakage remained within the 10CFR50, Appendix J limit even though a repair was ineffective. This was documented in the IPEC Corrective Action program. An evaluation of this valve indicated that this was a repetitive failure.

During 2R20, the prior outage in 2012, valve 1616 failed the leak rate test with a leakage rate of 6,000 cc/min. This failure to meet the acceptance criterion was accepted since the overall containment leakage was below the allowable limit and a repair was scheduled for 2R21 in 2014.

NL-15-068 Docket No. 50-247 Attachment Page 3 of 8 The repair in 2R21 changed the valve design from a hard seat to a soft seat valve, however, the post work test indicated that the leak rate remained elevated. An investigation indicated that the likely cause of the excessive leakage during the 2R21 post work test was damage to the valve internals caused by the welding process during the repair. Since the higher leak rate did not adversely impact the ability of the containment to perform its design function (i.e. meet the leak rate limits of 10CFR50, Appendix J), valve 1616 was accepted and corrective actions have been implemented to ensure that the repair currently scheduled for the 2016 refueling outage 2R22 will not result in similar damage.

SCVB RAI-3 The staff notes that the use of NEI TR 94-01, Rev 2-A (Reference 2) is acceptable for referencing by licensees proposing to amend their Technical Specifications (TSs) to permanently extend the ILRT surveillance interval to 15 years, provided six specific conditions are satisfied.

Condition 1 from Section 4.1 of NEI TR 94-01, Revision 2-A reads:

For calculating the Type A leakage rate, the licensee should use the definition in the NEI TR 94-01, Rev 2-A, in lieu of that in ANSI/ANS-56.8-2002. (Refer to SE Section 3.1.1.1).

Section 5.0 of the SE for NEI 94-01, Revision 2-A reads:

The performance leakage rate is calculated as the sum of the Type A upper confidence limit (UCL) and as-left minimum pathway leakage rate (MNPLR) leakage rate for all Type B and Type C pathways that were in service, isolated, or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to performing the Type A test. In addition, leakage pathways that were isolated during performance of the test because of excessive leakage must be factored into the performance determination. The performance criterion for Type A tests is a performance leak rate of less than 1.OLa.

Section 3.2.9 "Type A test performance criterion" of ANSI/ANS-56.8-2002 (Reference 3) defines the "performance leakage rate" and reads in part:

"The performance criterion for a Type A test is met if the performance leakage rate is less than La. The performance leakage rate is equal to the sum of the measured Type A test UCL and the total as-left MNPLR of all Type B or Type C pathways isolated during performance of the Type A test. , Page 4 of 19 of Entergy's LAR (Reference 1) for IP2 Compliance with Condition 1 reads:

Implementation of NEI 94-01 Rev 2-A will require use of the definition of "performance leakage rate" defined in Section 5.0 for calculating the Type A leakage rate when performing Type A tests.

The NRC staff notes that the "As found Leakage" is on a continuous trend towards eclipsing the

NL-15-068 Docket No. 50-247 Attachment Page 4 of 8 IP2 TS 5.5.14.d.1 leakage rate acceptance criteria of less than or equal to (<) 0.75La (i.e. 0.075 percent containment weight per day) as reflected in SCVB RAI-4 (below). The staff needs to develop a better understanding of why this phenomenon is occurring to make its regulatory decision. The staff notes that IP2's statement of compliance indicates future tense (i.e. "will require"). To make its regulatory decision, the staff needs to understand whether IP2's Type A ILRT plant test procedures currently reflect NEI 94-01, Revision 2-A's definition of "performance leakage rate". If the IRLT test procedures currently reflect the requisite definition, the staff requests historical information as to when the requisite NEI 94-01, Revision 2-A definition was adopted into IRLT test procedures. In addition the staff requests that Entergy Nuclear Operations, Inc. (Entergy) provide a copy of the current IP2 IRLT test procedures, plant drawings, etc. (or procedural excerpts from these documents) to aid the staff in understanding why this phenomenon is occurring.

Response

The IP2 ILRT is performed under procedure 2-PT-10Y001, "Integrated Leak rate Test". The current revision of this procedure is revision 2, dated 8/22/06. Since an ILRT has not been performed since 2006, this procedure has not been updated since 2006.

Revision 2-A of NEI Topical Report 94-01 was approved by the NRC based on a Safety Evaluation Report dated June 26, 2008 and then issued for use by NEI in a letter dated November 19, 2008.

Since this topical report was issued after the IP2 ILRT procedure was last revised, the current version of 2-PT-10YO01 does not include the requirements of NEI 94-01, Revision 2-A. Therefore, Entergy will revise 2-PT-1 OY001 prior to the next ILRT and will include the NEI 94-01, Revision 2-A requirements as provided in the NRC safety evaluation dated June 25, 2008. A copy of the current version of 2-PT-1OY001 is attached to this RAI response for information.

The definition of performance leakage rate in NEI Topical Report 94-01, Revision 2A, is more detailed than that of ANSI/ANS-56.8-2002 as shown by the quoted portions of those documents in the above question. Performance leakage as defined in 2-PT-1 OY001 is "Sum of above report Lam & UCL "AS LEFT" and as-left minimum pathway leakage rate of any pathway isolated during ILRT due to excessive Leakage." The "UCL" is the upper confidence leakage rate and "Lam" is the measured leakage rate. Therefore, there are few practical effects that result from revising the definition of performance leakage rate since the definitions are substantially similar.

The response to RAI-4 below discusses the projected ILRT leakage rate at the end of the 15 year interval based on the previous ILRT results.

SCVB RAI-4 LAR Section 4.3.1 "ILRT Test Results" (pages 5 & 6 of 19, Attachment 1, Reference 1) summarizes the IP2 Type A ILRT test results since August, 1979. These test results are summarized in the following Table:

NL-15-068 Docket No. 50-247 Attachment Page 5 of 8 June, 1991 0.0478 61.7 December, 1987 0.0342 62.9 September, 1984 0.0320 65.6 August, 1979 0.0260 62.7 The staff notes that the historical trend indicates that consistently, for all five historical ILRTs, the "As found Leakage" is on a continuous trend towards eclipsing the IP2 TS 5.5.14.d.1 leakage rate acceptance criteria of < 0.75La (i.e. 0.075% Containment weight per day).

Given the above ILRT results trend, the NRC staff requests that:

(1) The licensee explain why this phenomenon is occurring at IP2. More importantly, what is IP2's long term corrective action plan to arrest or reverse this trend?

Response

Entergy does not believe that the IP2 Type A ILRT test results since August 1979 indicate that the IP2 containment is degrading or constitutes an adverse trend requiring corrective action. Past ILRT tests performed across the industry have shown that the "as found leakages" measured during ILRTs can vary from performance to performance (as demonstrated, for example, by the Indian Point 3 historical test results). An ILRT is performed to test the containment boundary as well as leakage from Type B penetrations and Type C penetrations. The "as found" ILRT is the leakage from the Containment and the Type B and C penetrations tested as part of the ILRT as well as the leakage through the Type B and C penetrations not tested as part of the ILRT. The Type B and C tests results can vary from ILRT to ILRT depending on the systems that are vented, drained, and open to atmosphere for the ILRT. The leakage from the Type B and C components cannot be used for trending of results since the ILRT does not pinpoint the source of leakage. In addition, visual inspections of the internal and the external containment surfaces will continue to be performed as required by the ASME Section Xl Code. These visual inspections are capable of identifying any potential degradation if any were to occur prior to the next ILRT.

All of the IP2 ILRT "as found" test results have met the 10 CFR 50 Appendix J criterion of 1.OLa. This demonstrates that the overall containment leakage (Type A, Type B and Type C) has been maintained at leakage rates less than the assumed leakage rate in the plant accident analysis. The "as left" criterion for the containment leakage (Type A, Type B and Type C) is 0.75La, a lower value that assures that that there is margin for potential degradation that could increase the containment leakage rate before the next ILRT is performed. Such degradation historically has occurred primarily in Type B and C penetrations, which is why these penetrations are tested at a greater frequency than the ILRT.

Even if the past ILRT results are extrapolated through 2021, this would still not exceed the "as found" acceptance criteria of 1.01La. Furthermore, the IP2 Containment Leakage Rate Testing Program would require the "as left" criteria to be met prior to plant restart. Note that the approved program also provides for the case where an unacceptable (i.e., "as found" leakage >1.OLa) ILRT were to be performed. NEI 94-01, Revision 2-A states: "If the

NL-15-068 Docket No. 50-247 Attachment Page 6 of 8 Type A performance leakage rate is not acceptable, the performance criterion is not met, and a determination should be performed to identify the cause of unacceptable performance and determine appropriate corrective actions. Once completed, acceptable performance should be reestablished by demonstrating an acceptable performance leakage rate during a subsequent Type A test before resuming operation and by performing another successful Type A test within 48 months following the unsuccessful Type A test."

As noted above, Entergy does not believe that the IP2 containment is degrading or that the IP2 Type A ILRT test results since August 1979 constitute an adverse trend requiring corrective action. Therefore, Entergy is not planning to implement any further corrective actions because the Type A, B and C leakage rates continue to meet the 10CFR50, Appendix J limits. If the limits are not met, the program requires corrective actions and more frequent Type A, Type B or Type C testing.

(2) Entergy should include in its response a discussion of any IP2 containment modifications (major or minor) that may have affected containment integrity since August, 1979.

Response

There have been no modifications to the IP2 containment since 1979 that are considered major (I.e., of the type that would require separate testing per Appendix J,Section IV).

Some minor modifications have been made to the containment structure since 1979, such as isolating portions of the weld channel system, replacement of liner insulation panels to support liner inspections, and repairing delamination on the outside wall of the containment inside the electrical penetration tunnel. None of these minor modifications or maintenance activities would adversely affect the leak integrity of containment.

(3) For each ILRT, the licensee provide the individual cumulative MNPLR leakage rate for all Type B and Type C pathway test values that constitute a part of the total performance leakage rate (i.e. "As found Leakage") values identified in the table above.

Response

The following is the MNPLR leakage rate information available for each of the ILRT tests (additional details on As Found leakage are attached):

a) 2006 ILRT WCPS* Zone 1 - 18,689.02 cc/min WCPS Zone 2 - 19,255.36 cc/min Containment Spray Header - 69 cc/min Containment Spray Header - 139 cc/min Purge Supply - 2,574.23 cc/min Purge Exhaust - 5,502.82 cc/min Pressure Relief - 364.5 cc/min Total MNPLR added = 46,593.93 cc/min

NL-15-068 Docket No. 50-247 Attachment Page 7 of 8 WCPS- Weld Channel Pressurization System b) 1991 ILRT Total MNPLR added = 0 cc/min c) 1987 ILRT Penetration U-U and V-V - 42.28 cc/min Other penetrations Isolated during ILRT - 851.81 cc/min Total MNPLR added = 894.09 cc/min d) 1984 ILRT 80' Airlock - 16,194.66 cc/min 22 Fan Cooler Unit - 60.76 cc/min Air Ejector Discharge - 25.86 cc/min Penetration U-U - 59.32 cc/min Penetration V-V - 49.88 cc/min Total MNPLR added = 16,390.48 cc/min (4) Additional information about how IP2 plant programs satisfy the guidance of Regulatory Position 3 "Element 3: Define Implementation and Monitoring Program" of RG 1.174, Revision 2 (Reference 4)

Response: Position 3, Element 3 of RG 1.174 states, in part that "The licensee should propose monitoring program(s) that include a means to adequately track the performance of equipment that, when degraded, can affect the conclusions of the licensee's engineering evaluation and integrated decision making that support the change to the LB. The program should be capable of trending equipment performance after a change has been implemented to demonstrate that performance is consistent with the assumptions in the traditional engineering and probabilistic analyses conducted to justify the change".

The overall containment leakage includes leakage through containment penetrations and through containment isolation valves (CIVs) (i.e. Type B and C testing). The Type B and C leak rate testing is a quality program implemented per the requirements of IP2 Technical Specification section 5.5.14. This program ensures that Type B and C leak rates are measured on a periodic basis and the results are trended to ensure that degradation is identified and corrected prior to exceeding the corresponding regulatory limits. This program ensures that the requirements of position 3, element 3 of RG 1.174 are satisfied for the containment leak rate test.

REFERENCES:

1. Letter NL-14-128, dated December 9, 2014, from Lawrence Coyle, Entergy Nuclear Operations to U.S. Nuclear Regulatory Commission regarding the Proposed License

NL-15-068 Docket No. 50-247 Attachment Page 8 of 8 Amendment Regarding Extending the Containment Type A Leak Rate Testing Frequency to 15 Years, (ADAMS Accession No. ML14353A015)

2. NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," October 2008 (ADAMS Accession No. ML100620847)

3. ANSI/ANS-56.8-2002, Reaffirmed August 9, 2011, "Containment System Leakage Testing Requirements"

4. Regulatory Guide (RG) 1.174, Revision 2, dated May, 2011, "An Approach For Using Probabilistic Risk Assessment on Plant-Specific Changes To The Licensing Basis" (ADAMS Accession No. ML100910006).

ENCLOSURE TO NL-15-068 DOCUMENTS PROVIDED IN SUPPORT OF THE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EXTENSION OF THE CONTAINMENT TYPE A LEAK RATE TESTING FREQUENCY TO 15 YEARS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

MATERIALS FOR REQUEST FOR INFORMATION SCVB RAI-3

1. 2PT-1 0Y001 Integrated Leak Rate Test

Procedure Use Is: Control Copy:

SEntergy Nuclear Northeast RI Continuous Effective Date: 8/o76/ 66&'

0 Reference o Information Page 1 of 208 Approved By:

Procedure Sponsor, RPC T

Team 2A Procedure Owner PARTIAL REVISION

REVISION

SUMMARY

(Page 1 of 1) 1.0 REASON FOR REVISION 1.1 Incorporate comments from Lessons Learned, CRs, Feedbacks and TPC.

2.0

SUMMARY

OF CHANGES 2.1 Added step 3.38 and step to Attachment 2 per Feedback IP2-7306.

2.2 Added step 3.58 per Feedback IP2-7372.

2.3 Deleted previous Revision 1 step 3.65.5 to eliminate confusion as pressurization step immediately follows. Guidance for installing test gauges in Attachment 17.

No Rev bar.

2.4 Added step 4.7.4 and substeps per feedbacks IP2-7304, IP2-7390.

2.5 Attachment 3B, Page 5 of 13, MOV-958 Location:

Revised from "80' PAB SENTRY PANEL" to "98' PAB MCC ROOM".

Incorporates Advance TPC / DRN 06-01920.

2.6 Attachment 3E, Page 1 of 4, 21, 22 & 23 B/U Heater Group Test L/U's:

Revised from "Pullout" to "Off'. Incorporates Advance TPC / DRN 06-01920.

2.7 Attachment 13, Page 10 of 12, MOV-958 Location:

Revised from "80' PAB SENTRY PANEL" to "98' PAB MCC ROOM".

Incorporates Advance TPC / DRN 06-01920.

2.8 Attachment 17 Step 2.2: Added guidance to install test gauges at WCP-1 18 and WCP-1 19 for the 1170's AND open valves to place gauges in service.

(CR-IP2-2006-02049 CA# 00006) 2.9 Attachment 17: Revised to enhance documentation of gauge data, installation and removal of all test gauges used for contingency purposes.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 3 of 208 TABLE OF CONTENTS Section Title Page 1.0 P UR P O S E ................................................................................................... 5 2.0 PRECAUTIONS AND LIMITATIONS ............................................................. 5 3.0 P R E R EQ UIS ITES ......................................................................................... 9 4 .0 P R O C E DUR E .............................................................................................. 24 4 .1 Initial C onditions ............................................................................. 24 4.2 Pressurization of Vapor Containment .............................................. 24 4.3 Stabilization Phase .......................................................................... 28 4.4 Hold Test P hase .............................................................................. 31 4 .5 V erification Test ............................................................................. 37 4 .6 D epressurization ............................................................................. 40 4 .7 R esto ration ...................................................................................... 43 4.8 Final ILRT Results ......................................................................... 45 5.0 C O MME NT S ................................................................................................. 46 6.0 ACCEPTANCE CRITERIA ........................................................................... 49 7.0 TEST ACCEPTANCE .................................................................................. 49 8.0 EV A LU A T IO N .............................................................................................. 50 9.0 R E F E R E NC E S ............................................................................................ 51 10.0 RECORDS AND DOCUMENTATION .......................................................... 52 ATTACHMENT 1 TEST SUPERVISOR'S LOG ........................................................ 53 ATTACHMENT 2 CONTAINMENT PREPARATION CHECKLIST ........................... 54 ATTACHMENT 3 ILRT VALVE LINEUP INSTRUCTIONS ....................................... 58 ATTACHMENT 3A ILRT VALVE LINEUPS PRIOR TO PRESSURIZATION ............ 62 ATTACHMENT 3B ILRT VALVE LINEUPS PRIOR TO STABILIZATION ................. 76 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS ............................................. 89 ATTACHMENT 3D SUPPLEMENTARY ILRT VALVE LINEUPS ................................ 100 ATTACHMENT3E BREAKER LIST ........................................................................... 101

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 4 of 208 ATTACHMENT 3F LEAK DETECTION DEVICE TRACKING SHEET ........................ 105 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT ........................................... 106 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT115 ATTACHMENT 6 CONTAINMENT BUILDING LEAK RATE TEST SYSTEM LEAK RATE T E S T ING ................................................................................................... 13 4 ATTACHMENT 7 TEST EXCEPTIONS LOG .............................................................. 137 ATTACHMENT 8 VALVE LINEUP ALTERATION LOG .............................................. 138 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

............... 139 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION ..................... 154 ATTACHM ENT 11 CO NTING ENCIES ......................................................................... 160 ATTACHMENT 12 ILRT VERIFICATION TEST AND FLOW DATA ............. 176 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN ......... 179 ATTACHMENT 14 CONTROL ROOM LOG ............................................................... 191 ATTACHMENT 15 ILRT RESULTS

SUMMARY

......................................................... 193 ATTACHMENT 16 COMPUTER PRINTOUTS AND ATTACHMENTS ....................... 201 ATTACHMENT 17 GAUGE INSTALLATION / REMOVAL SHEET ............................. 202 ATTACHMENT 18 TEST GAUGE PRESSURE READINGS ...................................... 207 ATTACHMENT 19 VC AOV FAILURE POSITION LIST ............................................. 208

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 5 of 208 1.0 PURPOSE 1.1 This procedure establishes the requirements to assure that leakage through the primary reactor containment, and systems and components penetrating the primary containment does not exceed the allowable leakage rate values as specified in accordance with Technical Specification 5.5.14, Containment Leakage Rate Testing Program.

1.2 The requirements of 10CFR50.59 apply to this procedure.

2.0 PRECAUTIONS AND LIMITATIONS 2.1 Precautions and Limitations 2.1.1 Section 4.0 SHALL be performed WHEN the Reactor is in MODE 5.

2.1.2 READ the entire procedure prior to performing this test. A special evolution briefing SHALL be conducted as a Prerequisite PRIOR to actual test commencement. Brief in accordance with OAP-030 Infrequently Performed Tests and Evolutions SHALL be performed.

2.1.3 For performance of this critical infrequently performed test, the Manager, Site Operations, or his designee, has overall responsibility for the oversight of this test, including briefing the operating and test personnel with management expectations prior to performance of the infrequently performed test.

2.1.4 Communications between the Test Command Center and the Control Room SHALL be available at all times during the test. (The test, for this purpose, SHALL be considered to start when the personnel air lock is secured.)

2.1.5 Work activities near the Containment Building area while this test is being conducted will be stopped for the duration of the test. Access to roped off areas during the test will be approved by the Shift Manager.

2.1.6 Valve positions are to be controlled by this procedure and applicable operating procedures.

2.1.7 During pressurization of the containment, periodic surveillance of the containment and penetrations should be maintained. Any unusual conditions noted SHALL be immediately reported to the ILRT Test Supervisor. A determination of the condition will then be made.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 6 of 208 2.1.8 The ILRT Test Supervisor SHALL verify PRIOR to the test that there is NO significant fire hazard in containment. To compensate for the smoke detectors whose alarms may be inadvertently actuated during this test, additional heat detectors will be installed at locations determined by the Fire Protection Engineer.

2.1.9 Containment Building pressure is to be raised OR lowered only at the direction of the ILRT Test Supervisor.

2.1.10 Test pressure during the Stabilization and ILRT Phases must equal or exceed 0.96Pa (45.12 psig), but must NOT exceed Pd (52.0 psig).

Pressure may drop below this limit during the Verification Test Phase.

2.1.11 Containment Building will be pressurized, and stabilized at a pressure below 47.0 psig (+0, -1.0). Pressurization may proceed within the reasonable limits of the equipment, but pressurization and depressurization should be controlled to < 10 psi per hour for pressurization and < 15 psi per hour for depressurization.

2.1.12 NO leakage path SHALL be isolated without the approval of the ILRT Test Supervisor. Refer to Attachment 11, Contingencies for guidance handling leaks. PRIOR to OR during the test, any leaks which are repaired OR valve lineups which are altered SHALL be listed in Attachment 7, Test Exceptions Log. Any leakage penalties for the above will be documented on Attachment 9, Containment Penetration Summary.

2.1.13 Approved hearing protection is required in certain areas (adjacent to the air compressors, air charging piping, pressurization lines, and depressurization lines) during Pressurization AND Depressurization operations.

2.1.14 During pressurization for the ILRT the outer 80' and 95' airlock doors are left OPEN. IF leakage checks of the inner doors indicates excessive leakage into the airlocks it is permissible to accelerate airlock pressurization by closing the outer doors and pressurizing the airlock with air as directed in 2-PT-2Y016A, 80' Containment Air Lock Test and 2-PT-2Y016B, 95' Containment Airlock Test to within 0.5 psig below the planned final test pressure, accounting for gauge accuracy.

IF pressurization of the airlock is chosen, THEN snoop the outer doors and outboard boundary components. IF tight, THEN isolate and remove air source once pressure has been reached. IF excessive leakage is observed, THEN proceed per the guidance in step 2.1.21.

No:2-PT-1OY001 Rev:02 INTEGRATED LEAK RATE TEST Page 7 of 208 2.1.15 UNEXPECTED RESPONSE:

ILRT is a complex evolution involving temporary test equipment and several plant systems. Unexpected responses/alarms/plant indications can include sensor failure OR erratic behavior; fire/smoke alarms, misleading indications of excessive leakage; loss of or erratic level indication; unplanned rapid depressurization through a failed component, OR failure to pressurize due to valve/flange alignment problems.

IF any of these conditions are encountered during the test, THEN establish the Safe Condition for the test mode and assess plant/test conditions. (Step 2.1.16).

2.1.16 SAFE CONDITIONS & TEST ABORT CRITERIA:

Operations, ILRT Test Supervisor, OR ILRT Test Coordinator may decide to abort ILRT IF plant conditions, test conditions OR test results warrant. Attachment 11, Contingencies addresses actions for various phases of the test, safe conditions for each, and appropriate abort plans.

2.1.17 Deviations from this test direction that can have an influence on the test results, SHALL be handled in accordance with the Corrective Action Program.

2.1.18 Individual steps may be omitted OR performed out of order at discretion of ILRT Test Supervisor, marked N/A, and explained in Attachment 7, Test Exception Log.

2.1.19 At the direction of the Test Supervisor, valve alignment may be performed out of order. Any deviation SHALL be documented on Attachment 8, Valve Lineup Alteration Log.

2.1.20 Preparation for ILRT begins PRIOR to the plant entering Mode 5.

Containment Integrity SHALL be maintained in Modes 1, 2, 3 and 4 in accordance with the applicable portions of Technical Specification 3.6.

2.1.21 EXCESSIVE LEAKAGE:

Leakage discovered during leak searches or routine operations while containment is at pressure must be reported to ILRT Test Supervisor for evaluation, AND unless leakage is a personnel safety hazard, it must NOT be adjusted OR isolated without specific direction from ILRT Test Supervisor. ANY adjustment to a leaking containment boundary may result in test failure. Therefore, when leakage is identified, ILRT Test Supervisor will consider the options listed on Attachment 11, Contingencies.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 8 of 208 2.1.22 NO data point is to be rejected on a purely statistical basis.

Apparent outliers will be investigated for physical or measurement system problems. Individual sensor performance graphs and sensor deviation/failure criteria, provided by ILRT computer program, will be used to evaluate sensor performance and to provide basis for sensor deletion. Raw data for deleted sensors will continue to be recorded IF possible, but NOT used, throughout the test.

2.1.23 Temperature limits for Vapor Containment atmosphere SHALL NOT be exceeded. Limits are > 50°F and < 130 0 F.

2.1.24 Test Tags may be used on plant equipment. These tags are used to indicate that a component has been aligned to a certain configuration in support of ILRT.

2.1.25 Containment entry is permissible per OAP-007, Containment Entry, Egress, and Inspection.

2.1.25.1 IF a containment entry is required PRIOR to 12 psig, THEN an EMT SHALL be available.

NO personnel SHALL be allowed to enter containment above 12 psig without permission of the General Manager Plant Operation.

IF entries at pressure are required, THEN Safety SHALL be called to ensure compliance with requirements of OSHA regulations (29CFR1926).

2.1.26 IF the RCS is NOT full with "Loops Filled" as defined by Tech Specs, THEN a check for Reactor Vessel Head voiding must be performed on a periodic basis. {Reference 9.2.7) 2.2 General Information 2.2.1 Personnel performing this test SHALL read it in its entirety prior to the start of testing.

2.2.2 Personnel performing this test SHALL complete Sections 3.0, 4.0, 5.0, 6.0, 7.0 and 8.0, as applicable.

2.2.3 Any discrepancies found SHALL be identified in Section 5.0 Comments.

2.2.4 An upper case "V" used as a column header in lineup tables or beneath an initial line for a step denotes the requirement for verification by a second individual. This verification may be performed concurrently OR independently at the discretion of the SM/Designee.

2.2.5 Test instruments may be installed OR removed out of the sequence specified in the test and in parallel with other test preparation or completion steps.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 9 of 208 Initials 3.0 PREREQUISITES 3.1 Equipment required for test is addressed in Attachment 5, ILRT Measurement System Installation and Checkout.

For installed instrumentation used in determination of Acceptance Criteria, VERIFY NO overdue calibration PMs OR surveillances exist AND document this in Section 5.0, Comments.

3.2 OBTAIN a calibrated pressure device to measure outside ambient pressure which reads out in PSIA.

3.3 Reason for Test - CHECK applicable listing:

D] Normal Surveillance WR #

Il Post Maintenance Test WR #

WR #

WR#

[--] Increased Test Frequency WR #

FI Other NOTE The following tasks should be performed in support of the ILRT PRIOR to entering MODE 5 from power operation (sequence non-critical). Maintain Containment Integrity per step 2.1.20 PRELIMINARY STEPS 3.4 Manager, Site Operations OR his designee SHALL complete briefing per step 2.1.2 3.5 SM authorization to begin test preparation activities.

/

Shift Manager / Date

No:2-PT-1 OY001 Rev:02 INTEGRATED LEAK RATE TEST Page 10 of 208 Initials 3.6 An organization chart describing Testing Organization, including names, phone numbers and email addresses of personnel supporting preparation, implementation, and restoration activities has been developed and communicated to project team supporting ILRT.

3.7 A "Test Command Center" has been designated for control of testing activities during implementation of Section 4.0 activities. Phone numbers for the Test Command Center have been communicated to CCR, Plant Management and Outage Management.

3.8 As part of ILRT, Test Supervisor(s) SHALL maintain a log per Attachment 1, Test Supervisor's Log. The Log SHALL be initiated upon commencement of performance of this procedure. The Log SHALL be used to document those activities NOT documented on existing data sheets/attachments and should include shift turnovers, ILRT instrumentation/computer failures, compressor failures, fuel oil orders and deliveries, recommendations for procedure enhancements, and any significant events.

3.9 Rented portions of ILRT Pressurization System have been received AND installed per Attachment 4, Containment Building Pressurization /

Depressurization System Installation and Checkout at Test Supervisor's direction.

3.10 Termination of ILRT sensor instrument strings outside containment have been completed per Attachment 5, ILRT Measurement System Installation and Checkout. Circuit terminations have been "rung out" OR otherwise verified to be correct.

3.11 With permission of Manager, Site Operations OR his designee, Sensors may be installed inside containment per direction of the ILRT Test Supervisor/ILRT Consultant. (N/A step IF NOT applicable) 3.12 Setup of ILRT Measurement System outside containment is complete with exception of leak checks/valve alignments of pressure sensing line and superimposed leak lines (flow sensing line).

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 11 of 208 Initials NOTE The following tasks should be performed in support of ILRT AFTER entering MODE 5 from power operation (sequence non-critical) UNLESS specifically approved by the SM.

INSTRUMENTATION & CONTROLS PREREQUISITES 3.13 To prevent actuation of a Containment Spray signal, place associated Bistable trip switches in "TRIP" position. This will prevent associated relays from energizing, while allowing operators to maintain indication of VC pressure on supervisory panel. Reference Attachment 2, Containment Preparation Checklist.

3.14 Plant instrumentation required for conduct of ILRT (e.g. tank/sump level instrumentation) listed in Attachment 14, Control Room Log is calibrated per calibration program AND is available for ILRT.

3.15 Prepare VC instrumentation and equipment for ILRT by completing items listed on Attachment 2, Containment Preparation Checklist.

3.16 Termination of ILRT sensor instrument strings inside containment have been completed per Attachment 5, ILRT Measurement System Installation and Checkout. Circuit terminations have been "rung out" or otherwise verified to be correct.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 12 of 208 Initials MECHANICAL PREREQUISITES 3.17 The following Temporary Alterations have been performed in accordance with Attachments listed:

3.17.1 Department support of penetration preparations described in Attachments 3 and 4. (e.g. flange removal, temporary pipe hookup, etc.)

3.17.2 Temporary pressurization header has been installed and rented pressurization equipment attached per Work Order instructions and Attachment 4, Containment Building Pressurization /

Depressurization System Installation and Checkout.

3.18 Plant mechanical equipment protection activities inside containment per Attachment 2, Containment Preparation Checklist are complete.

ELECTRICAL PREREQUISITES 3.19 Plant electrical equipment protection activities inside the containment per Attachment 2, Containment Preparation Checklist are complete.

3.20 Temporary power and lighting requirements at temporary portions of Pressurization System per Attachment 4, Containment Building Pressurization I Depressurization System Installation and Checkout are met.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 13 of 208 Initials PROGRAMS & COMPONENTS PREPARATIONS 3.21 VERIFY all permits required for Data Collection and Pressurization Laydown area have been obtained and posted.

3.22 Temporary communications have been provided as determined by Test Coordinator. Record numbers on Attachment 1, Test Supervisor's Log.

3.23 Tables, chairs, work benches, table lamps, portable ventilation equipment, uninterruptible power supplies have been provided as determined by Test Coordinator.

3.24 Provide a listing of materials/equipment that should NOT be brought into OR left in VC to Containment Coordinator AND Outage Manager.

3.25 VERIFY installation and checkout portions of Attachment 4, Containment Building Pressurization/Depressurization System Installation and Checkout are complete and satisfactory, including check of air quality.

3.26 VERIFY that installation and calibration of instrumentation for ILRT is completed and properly documented in Attachment 5, ILRT Measurement System Installation and Checkout.

3.27 VERIFY "as-installed" certification of ILRT Data Management computer program is completed. Include certification package in Attachment 16, Computer Printouts and Attachments.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 14 of 208 Initials NOTE Completed portions of 2-PI-R002, Internal Containment Structural Visual Inspection and 2-PI-2Y001, External Containment Structural Visual Inspection may be used to meet this requirement OR portions of this requirement. IF the above tests have NOT been performed for a portion of containment structure, THEN a visual inspection as described in paragraph 3.2.1 of ANSI/ANS 56.8-1994 SHALL be performed AND results documented in 0, Containment Building Visual Inspection.

3.28 A general inspection of accessible interior AND exterior surfaces of containment structures and components has been performed. Any irregularities such as cracking, peeling, de-lamination, corrosion, and structural deterioration SHALL be recorded AND evaluated OR repaired as required, PRIOR to conduct of ILRT. Document results in Attachment 10, Containment Building Visual Inspection.

3.29 Establish controls (signs) limiting access to periphery of containment during test at RCA Access Points. Access should be limited to personnel authorized by the Test Coordinator. These areas do NOT include the Fuel Storage Building and the Primary Auxiliary Building (except electrical penetration and piping penetration rooms).

3.30 Collect available local leak rate test results completed PRIOR to ILRT.

Record as-found AND as-left results in Attachment 9, Containment Penetration Summary for calculations.

NOTE The activity limit provided will be used at Step 4.6.1 to determine the use of the contingency depressurization method in Section 3.0.Attachment 11, Contingencies.

CHEMISTRY PREREQUISITES 3.31 PROVIDE an Iodine activity limit at which the High Containment Activity Vent Path would be used per Attachment 11 Section 3.0 RECORD value below.

Containment Vent Path Activity Limit:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 15 of 208 Initials ILRT CONSULTANTS PREREQUISITES 3.32 The test preparation portions of Attachment 5, ILRT Measurement System Installation and Checkout are complete:

3.32.1 ILRT Measurement System installed meets performance and quality specifications of Attachment 5, Section 5.0.

3.32.2 Calibration and pre-test check information has been entered into Attachment 5, ILRT Measurement System Installation and Checkout Section 4.0, reviewed and found acceptable. Copies of sensor calibration sheets have been included in Attachment 16, Computer Printouts and Attachments.

3.32.3 ILRT Measurement System cabling has been terminated per Section 5.0 of Attachment 5, ILRT Measurement System Installation and Checkout. Documentation of cable lead landings may be on form in Section 5.0 OR using standard plant form controlled through the Work Control process. IF a Work Order related form is used, THEN attach a copy to Attachment 16, Computer Printouts and Attachments of this procedure.

3.32.4 ILRT Measurement System dry-bulb and RH sensors have been placed in containment per Section 5.0 of Attachment 5, ILRT Measurement System Installation and Checkout.

3.32.5 ILRT Measurement System outside containment has been installed and functionally checked per Attachments 5, ILRT Measurement System Installation and Checkout AND Attachment 6, Containment Building Leak Rate Test System Leak Rate Testing.

3.33 ILRT software program has been installed and "As-installed" Certification Package is complete. Attach certification package to Attachment 16, Computer Printouts and Attachments.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 16 of 208 Initials 3.34 Beginning at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months PRIOR to scheduled start of pressurization, PERFORM a tour of containment once a shift to VERIFY containment readiness for testing. Walk-down should catalog remaining items to be removed from containment OR items that must be protected from test pressure. Provide a list of discrepancies to the Outage Manager AND the Containment Coordinator.

3.35 Provide a set of marked-up P&IDs to Work Control organization illustrating test valve lineups/boundaries. Review drawings with affected coordinators.

3.36 Review of all Work Orders, Clearances, and Temporary Alterations outstanding or planned for release during ILRT window (plus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) has been completed.

Review should identify existing and/or potential infringement on test boundaries, equipment operations/losses that could impact plant conditions/stability during ILRT, and focus on ensuring Work Control provisions and communication channels are adequate.

3.37 VERIFY that Compressors and associated air handling equipment are setup per Attachment 4, Containment Building Pressurization/Depressurization System Installation and Checkout.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 17 of 208 Initials OPERATIONS PREREQUISITES 3.38 Reactor Vessel Cooling Support Blocks temperature Indicators TI-1259, TI-1260, TI-1261 and TI-1262 were damaged during the last ILRT in 2006.

These gauges SHALL be removed PRIOR to the Pressurization Phase.

Attachment 2, Containment Preparation Checklist.

3.39 INSTALL test gauges to monitor potential leak paths as directed in Attachment 17, Gauge Installation / Removal Sheet.

3.40 Setup a Trend Report on plant computer to monitor levels in CCR Log, per Attachment 14, Control Room Log every 15 minutes during test.

SET Plant Computer to print reports on the hour.

3.41 Depressurize IVSWS Tank AND IVSWS gas header per 2-OSP-1 0.4.1, Support Procedure - Isolation Valve Seal Water System Operation.

3.42 Depressurize WCCPPS zones using single zone section of 2-SOP-10.5.1, Weld Channel and Containment Penetration Pressurization System Operation as directed by the Test Supervisor. Do NOT depressurize Zone 2 UNTIL directed.

3.43 Secure Radiation Monitors R-41/42 per 2-SOP-12.3.2, Digital Radiation Monitoring System Operation (Local or SRD).

3.44 VERIFY Pressurizer level between 75% and 80% PRIOR to performing ILRT to compensate for level changes during pressurization. Pressurizer level SHALL remain within indicating range during ILRT.

3.45 VERIFY PRT is drained below the sparging line (< 10%).

Use 2-SOP-1.6, Pressurizer Relief Tank Operations as necessary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 18 of 208 Initials 3.46 Plant stability is critical during the ILRT. Avoid any activities that changes VC volume during Stabilization, Hold Test and Verification Test Phases.

3.47 RCS temperature is being controlled via RHR to within +/- 1F of any temperature selected by CRS WHEN pressurization starts.

NOTES As a minimum, the following procedures should be used to secure systems PRIOR to isolating them in the following Attachments:

" 2-SOP-5.4.1, VC Pressure Reliefs.

" 2-SOP-10.5.1, Weld Channel And Containment Penetration Pressurization System Operation.

2-OSP-10.4.1, Support Procedure - Isolation Valve Seal Water System Operation.

2-SOP-10.3, Containment Cooling System Operation.

" 2-SOP-3.1, Charging, Seal Water and Letdown Control.

" 2-SOP-12.3.2, Digital Radiation Monitoring System Operation (Local or SRD).

The ILRT Test Supervisor may specify the use of NA in steps as well as partial sections. E, Breaker List SHALL be reviewed for applicability PRIOR to isolating equipment to prevent equipment damage.

3.48 PERFORM the following system alignments as soon as practical PRIOR to their related phases:

3.48.1 Attachment 3A, ILRT Valve Lineups Prior to Pressurization.

3.48.2 Attachment 3B, ILRT Valve Lineups Prior to Stabilization

[NOT required prior to starting compressors].

3.48.3 Attachment 3C, ILRT Special Valve Lineups.

3.48.4 Attachment 3D, Supplementary ILRT Valve Lineups.

3.48.5 Attachment 3E, Breaker List.

3.48.6 Attachment 6, Containment Building Leak Rate Test System Leak Rate Testing.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 19 of 208 Initials 3.49 PLACE Pesonnel & Equipment Hatch Solenoids in INCIDENT MODE on panel SM.

3.50 RECORD RHR Cooling Loop in operation:

FINAL PREPARATIONS 3.51 INSPECT 80' AND 95' air lock doors. Door seals AND mating surfaces SHALL be clean and free of discontinuities. CLOSE inner doors of 80' AND 95' air locks. Outer doors SHALL remain OPEN to prevent excessive equalization time IF there is a small leak into air lock.

3.52 Place Manual SI Defeat switches in "DEFEAT" position to prevent actuation of Phase "A" signal during containment pressurization.

3.53 All electrical equipment should be de-energized within containment, except for those services required. Refer to Attachment 3E, Breaker List.

3.54 VERIFY that a review of on-going work and clearances on or around VC with Outage Work Control organization has been completed by the Test Supervisor AND ILRT Consultant, and any potential interferences with the test or breaches of testing lineups have been resolved.

3.55 REVIEW Attachment 8, Valve Lineup Alteration Log.

VERIFY any lineup alterations have been satisfactorily resolved.

3.56 REVIEW Attachment 9, Containment Penetration Summary to verify actual penetration status entering ILRT is accurately reflected.

3.57 CONDUCT a phase-specific briefing for Control Room personnel PRIOR to commencement of Pressurization Phase.

No:2-PT-10Y01 Rev:02 INTEGRATED LEAK RATE TEST Page 20 of 208 Initials 3.58 One hour PRIOR to ILRT Pressurization AND every ten minutes thereafter, the following announcement SHALL be made twice over the plant paging system:

"ATTENTION ALL PERSONNEL IN THE UNIT 2 VAPOR CONTAINMENT.

ATTENTION ALL PERSONNEL IN THE UNIT 2 VAPOR CONTAINMENT.

THE ILRT PRESSURIZATION PHASE WILL COMMENCE IN MINUTES. ALL NON-ILRT PERSONNEL EXIT THE VAPOR CONTAINMENT AT THIS TIME.".

3.59 A final closeout inspection has been made by ILRT Test Supervisor OR Designee to ENSURE:

3.59.1 All containment temporary equipment that contains supplies of compressed gases has been removed OR vented.

3.59.2 NO significant fire hazards have been identified in containment.

3.59.3 Any water standing on Containment Building floors or low spots has been removed and areas left dry if practical.

3.60 All Containment sumps have been pumped down to their minimum on-scale level.

3.61 Align Leak Rate Test System air compressor discharge header for Pressurization per Section 4.0 of Attachment 4, Containment Building Pressurization/Depressurization System Installation and Checkout.

3.62 Pressurization may begin PRIOR to completion of valve alignments providing Test Supervisor has verified the following:

3.62.1 Component manipulations and/or visual verifications associated with components inside containment on Attachments 3A, 3D and 3E are complete AND the following on Attachment 3C as follows:

a Attachment 3C, System: N2 to Nuclear Equipment is complete.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 21 of 208 Initials

Attachment 3C, System: Instrument Air is complete.

o Attachment 3C, System: Reactor Coolant is complete.

3.62.2 Containment portions of Attachment 2, Containment Preparation Checklist are complete.

3.62.3 Installation of ILRT Measurement System inside VC is complete per Attachment 5, ILRT Measurement System Installation and Checkout.

3.62.4 Containment Inspection is complete in its entirety per Attachment 10, Containment Building Visual Inspection OR the intent of containment inspection requirements as stated in Containment Leakage Rate Testing Program have been met.

3.62.5 Test Supervisor has reviewed Attachment 8, Valve Lineup Alteration Log to ensure that all components inside containment are in their Test Position OR have been satisfactorily dispositioned.

3.62.6 Review of all outstanding Work Orders, Clearances and Temporary Alterations have been completed at least to the extent that Test Supervisor, Work Management or Operations interface are satisfied that NO obstacles to closing out of containment/performing the test exist.

3.62.7 Final walkdown/closeout inspection of containment has been satisfactorily completed. VERIFY ALL personnel have been evacuated from the Containment Building. Confer with Health Physics department that ALL personnel in the Containment Building have been evacuated.

3.63 ESTABLISH communications between Test Command Center, CCR, and air compressor operator(s).

No:2-PT-1 QYO0i Rev:02 INTEGRATED LEAK RATE TEST Page 22 of 208 Initials 3.64 VERIFY containment temporary power and lighting has been isolated.

(e.g. Duralines, etc.)

3.65 VERIFY ALL personnel are clear of the VC. EVACUATE ALL personnel from VC by making the following announcement twice:

"ATTENTION ALL PERSONNEL IN THE UNIT 2 VAPOR CONTAINMENT. ATTENTION ALL PERSONNEL IN THE UNIT 2 VAPOR CONTAINMENT. ILRT PREPARATIONS ARE COMPLETE. ALL PERSONNEL EXIT THE VAPOR CONTAINMENT AT THIS TIME."

3.66 PRIOR to VC pressurization, Operations sounds VC Evacuation alarm:

3.66.1 VC Evacuation Alarm sounded:

INITIALS / DATE / TIME

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 23 of 208 Initials 3.67 CLOSE OUT the Containment Building as follows:

3.67.1 Equipment Hatch for 95' Air Lock.

3.67.1.1 VERIFY VC Equipment Hatch is installed.

3.67.1.2 VERIFY VC Equipment Hatch's last test following installation was acceptable.

3.67.2 95' Air Lock.

3.67.2.1 VERIFY outer door OPEN.

3.67.2.2 CLOSE AND LOCK inner door of Airlock.

Use locking device that would allow VC egress IF available.

3.67.2.3 Pressurized to 47 psig or greater as indicated on PI-7478, following closure.

3.67.3 80' Airlock.

3.67.3.1 VERIFY outer door OPEN.

3.67.3.2 CLOSE AND LOCK inner door of Airlock.

Use locking device that would allow VC egress IF available.

3.67.3.3 Pressurized to 47 psig or greater as indicated on PI-7482, following closure.

3.67.4 ISOLATE AND depressurize Zone 2 Weld Channel using Attachment 3C, ILRT Special Valve Lineups.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 24 of 208 Initials 4.0 PROCEDURE 4.1 Initial Conditions 4.1.1 Plant is shutdown, in MODE 5.

4.1.2 OBTAIN permission from SM OR Designated Alternate to perform this test.

/

SM OR Designated Alternate Signature / Date 4.1.3 OAP-030 Infrequently Performed Tests and Evolutions briefing has been completed:

/

SM OR Designated Alternate Signature / Date 4.1.4 The Test Coordinator has verified all Prerequisites and Precautions and Limitations have been reviewed and/or satisfactorily completed.

/

Test Coordinator / Date 4.2 Pressurization of Vapor m Containment 4.2.1 Data Collection:

4.2.1.1 RECORD outside ambient pressure at the start of pressurization:

PSIA Gauge Serial No: Cal due date:

4.2.1.2 RECORD initial pressure on test gauges listed In Attachment 17, Guage Installation / Removal Sheet on Attachment 18, Test Gauge Pressure Readings.

RECORD pressures every thirty minutes until containment reaches 12 psig. WHEN > 12 psig, THEN RECORD at one hour intervals thereafter until end of pressurization AND stabilization OR as directed by the Test Supervisor.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 25 of 208 Initials 4.2.1.3 START recording containment atmospheric data at 15 minute intervals using the ILRT Measurement System.

4.2.1.4 VERIFY Trend Report on Plant Computer setup to monitor levels in Attachment 14, Control Room Log is running.

4.2.1.5 Record Initial Water Levels on Attachment 14, Control Room Log page 1 of 1.

4.2.2 ANNOUNCE the following 2 times over the plant page:

"ATTENTION ALL UNIT 2 PERSONNEL. ATTENTION ALL UNIT 2 PERSONNEL. VAPOR CONTAINMENT PRESSURIZATION IS ABOUT TO COMMENCE. ALL NON ESSENTIAL PERSONNEL STAND CLEAR OF ROPED OFF AREAS ASSOCIATED WITH THE INTEGRATED LEAK RATE TEST."

4.2.3 INITIATE Pressurization by OPENING pressurization isolation valves upstream of penetration "UU" and "V V".

CONTINUE to pressurize until containment air pressure reaches the criteria specified in Step 2.1.11 NOTE Test pressure SHALL NOT fall below 45.12 psig OR exceed 52 psig at anytime during ILRT. Test pressure may fall below 45.12 psig during Verification Test.

4.2.3.1 MAINTAIN moisture AND oil content as low as possible when pressurizing Vapor Containment Building.

4.2.3.2 Containment inlet air temperature should be monitored during Pressurization Phase of test to ensure containment weighted average temperature is above 50°F and below 130 0 F.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 26 of 208 Initials NOTE Report any apparent leakage to the ILRT Test Supervisor. Do NOT isolate OR adjust any leakage found during leak checks. Excessive leakage is to be dispositioned per step 2.1.21.

4.2.3.3 INSPECT containment boundary for leakage at containment pressures of approximately 20 psig AND 40 psig using Attachment 13, Containment Building Penetration Walkdown as a guideline.

4.2.4 NOTIFY chemistry to obtain an air sample (Iodine and Noble Gas) from containment PRIOR to the end of pressurization.

This sample will be used to prepare a release permit for depressurizing containment after ILRT.

4.2.5 WHEN equal to OR greater than 40 psig, THEN VERIFY adequate flow can be obtained through each verification test flowmeter AND CHECK connections for leakage.

4.2.6 WHEN desired pressure is achieved, THEN:

4.2.6.1 ISOLATE Containment by CLOSING the five (5) three-inch isolation valves on EACH of the penetration manifolds at U U and V V.

4.2.6.2 SHUTDOWN remaining compressors.

4.2.6.3 ISOLATE compressors at compressor outlets and yard manifold.

4.2.6.4 OPEN vent(s) on compressor manifold to vent pressurization lines.

4.2.6.5 WHEN lines are depressurized, THEN check vent for evidence of leakage past the penetration manifold isolations.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 27 of 208 Initials NOTE ILRT Data Management computer program may be placed in Stabilization Mode while administrative review of remaining sections of this step is completed.

4.2.7 IF pressurization was begun prior to completion of all valve alignments, THEN VERIFY the following:

4.2.7.1 Component manipulations/visual verifications associated with components outside containment in Attachment 3B, ILRT Valve Lineups Prior to Stabilization are complete.

4.2.7.2 ILRT Test Supervisor AND ILRT Consultant has reviewed Attachment 8, Valve Lineup Alteration Log to ensure that all components listed are in their "TEST L/U". Any unresolved component positions must be listed as Test Exceptions in Attachment 7, Test Exceptions Log AND the impact on penetration status listed in Attachment 9, Containment Penetration Summary SHALL be assessed.

4.2.8 RECORD the lowest reading ILRT pressure gauge on line 1.

RECORDthe outside atmospheric pressure on line 2.

Subtract line 2 from line 1. Enter the result on line 3.

VERIFY Line 3 value is greater than 45.12 psig.

1. Lowest Reading ILRT Pressure Gauge psia

2. Outside Atmospheric Pressure psia

_ _psig Line 1 Line 2 Line 3

3. Line 3 value > 45.12 psig

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 28 of 208 Initials 4.3 Stabilization Phase 4.3.1 Data Collection:

4.3.1.1 RECORD ambient pressure at the start of stabilization:

Psia Gauge Serial No.:

Cal due date:

4.3.1.2 RECORD the Start of the Stabilization Phase:

Time (24 hr clock)

Date / /

4.3.1.3 RECORD pressure readings from test gauges installed in Attachment 17, Gauge Installation /

Removal Sheet on Attachment 18, Test Gauge Pressure Readings every hour until the end of stabilization OR as directed by Test Supervisor.

4.3.1.4 CONTINUE recording containment atmospheric data at 15 minute intervals using ILRT Measurement System.

4.3.1.5 VERIFY Trend Report on Plant Computer setup to monitor levels in Attachment 14, Control Room Log is still running.

4.3.2 Allow containment atmosphere to stabilize for a minimum of four hours after time recorded in step 4.3.1.2, THEN record time AND date.

Time (24 hr clock) Date /

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 29 of 208 Initials NOTE Stabilization criteria for performing ILRTs under both the BN-TOP-1 and ANSI 56.8-1994 methodologies are included. Leakage stabilization criteria of ANSI 56.8-1994 is more difficult to meet. At least one method's criteria must be met in order to enter Hold Test Phase. Both criteria should be met before starting Type A Test in order to provide the most options during Hold Test Phase. Note that failing to meet a methodology's stabilization criteria may preclude its use as a means to perform ILRT.

4.3.3 PRIOR to start of Type A Test, VERIFY the following stabilization criteria for containment atmosphere are met. Stabilization occurs WHEN:

4.3.3.1 BN-TOP-1 a) Rate of change of average temperature is less than 1.0°F/Hour averaged over the last two hours. (BN-TOP-1 requirement).

OR b) Rate of change of temperature changes less than 0.5 0 F/Hour/Hour averaged over the last two hours. (BN-TOP-1 requirement).

c) BN-TOP-1 stabilization criteria met. Attach a screen-print from the Stabilization Phase screen of ILRT Data Management Program stating criteria has been met to Attachment 16, Computer Printouts and Attachments.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 30 of 208 Initials NOTE Llh = estimate of leakage rate, derived from least squares slope and intercept using mass data over the last hour (in % wt/day).

L2h = estimate of leakage rate, derived from least squares slope and intercept using mass data over the last two hours (in % wt/day).

4.3.3.2 ANSI/ANS 56.8-1994 a) Primary containment atmosphere is assumed to be stabilized for Type A test purposes when the following criteria are simultaneously met (ANSI 56.8-1994):

Criterion (1)

The absolute value of difference between L2h and Llh SHALL be less than or equal to 0.25La Llh = _ ; L2h =

__ (L2h) - __ (Llh) = _ <(0.025% wt/day)

Criterion (2)

Llh SHALL be greater than or equal to zero and SHALL be less than La, NOTE Per ANSI/ANS 56.8-1994, paragraph 5.6, IF one OR more leakage pathways require isolation, repair OR adjustment in order to meet criterion (2), criterion (1) need NOT be re-verified provided this criterion was met PRIOR to time of isolation, repair, or adjustment. The change in Llh should be demonstrated to be a direct result of this isolation, repair, or adjustment.

b) ANSI/ANS 56.8-1994 leakage stabilization criteria met. Attach a screen-print from Stabilization Phase screen of ILRT Data Management Program stating criteria has been met to Attachment 16, Computer Printouts and Attachments.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 31 of 208 Initials 4.3.4 ILRT Test Coordinator SHALL judge IF containment is stabilized AND declare the start of test based on a review of temperature vs. time, pressure vs. time graphs, available mass change and leakage data, as well as meeting criteria of steps 4.3.1 and 4.3.2 or 4.3.3. RECORD below the number of hours of stabilization, the time and date of the end of stabilization and the time and date of the start of the ILRT.

Stabilization Declared:

Time / Date Number of Hours for Stabilization:

Hours Start of ILRT:

Time / Date 4.4 Hold Test Phase NOTE Perform ILRT calculations in accordance with Section 4.4.3 for BN-TOP-1 test OR Section 4.4.4 for an ANSI/ANS 56.8-1994 test.

4.4.1 Data Collection:

4.4.1.1 RECORD ambient outside pressure at the start of the Hold Test:

PSIA Gauge Serial No: Cal due date:

4.4.1.2 IF there has been NO indication of rising pressure on any of the test gauges, THEN discontinue collecting pressure data on the test gauges on Attachment 18, Test Gauge Pressure Readings OR as directed by the Test Supervisor.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 32 of 208 Initials 4.4.1.3 CONTINUE recording containment atmospheric data at 15 minute intervals using ILRT Measurement System.

4.4.1.4 VERIFY Trend Report on Plant Computer is setup to monitor levels in Attachment 14, Control Room Log is running.

4.4.1.5 Record Initial Water Levels on Attachment 14, Control Room Log page 2 of 2.

4.4.1.6 Record end-of-test Water Levels on Attachment 14, Control Room Log page 2 of 2.

4.4.2 MONITOR performance of temperature, humidity, and pressure sensors during conduct of test. Delete any non-operable sensors from calculation AND modify weighing factors IF necessary.

Document reasons for sensor deletion and volume fraction reassignment in Attachment 1, Test Supervisor's Log.

4.4.3 BN-TOP-1 TEST In order to perform a BN-TOP-1 test, the following criteria SHALL be met. IF a BN-TOP-1 test is NOT performed, THEN place an N/A in space provided below:

BN-TOP-1 Test 4.4.3.1 After a minimum of six (6) hours of acceptable data is obtained, determine if "Preliminary as Left" leakage rate, including known B & C additions from Attachment 15 using Total Time 95% Upper Confidence Level (UCL) as reported by ILRT computer program is < 0.075% wt/day.

4.4.3.2 BN-TOP-1 based on total-time calculations indicates that the magnitude of the calculated leakage rate is tending to stabilize at a value less than 75% of the maximum allowable leakage rate.The magnitude of calculated leakage rate may be increasing slightly as it tends to stabilize. In this case, the average rate of increase of the calculated leakage rate SHALL be determined from accumulated data over the last five (5) hours or last twenty (20) data points, which ever provides more points. Using this average rate, the calculated leakage rate is then linearly extrapolated to the 24th hour data point. This extrapolated value of the calculated leakage rate must be less than 75% of the maximum allowable leakage rate.

No:2-PT-10QY001 Rev:02 RATE TEST INTEGRATED LEAK Page 33 of 208 Initials 4.4.3.3 The mean of measure leak rates based on Total Time Calculations over the last five (5) hours of test or last twenty (20) data points, whichever provides the most data, SHALL be less than 75% of the maximum allowable leak rate.

4.4.3.4 The end of test upper 95% confidence limit for calculated leak rate based on Total Time calculations, plus all known additions SHALL be less than 75% of maximum allowable leak rate.

4.4.3.5 Data SHALL be recorded at approximately equal intervals and in NO case at intervals greater than one (1) hour.

4.4.3.6 At least twenty (20) data points SHALL be provided for proper statistical analysis.

4.4.3.7 The minimum test duration is six (6) hours.

4.4.3.8 The following minimum number of sensors were working properly at end of test:

a) At least twenty (20) drybulb temperature sensors.

b) At least four (4) relative humidity sensors.

c) At least one (1) pressure gauge.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST NofP208 Page 34 of 208I Initials NOTE Known Type B and C penalties and leakage savings SHALL be taken into account AND added to the Upper Confidence Level (UCL) Leakage Rate. IF additional penalties may be required due to leakage paths isolated during the test, an adequate margin between the UCL Leakage Rate and the acceptance criteria should be maintained to accommodate the additional values. IF Step 4.4.3.9c) is below the Acceptance Criteria, the verification test may be started PRIOR to completing all of the calculations required by Attachment 15, ILRT Results Summary.

4.4.3.9 Calculate leakage rates via ILRT computer program.

Record ILRT leakage below:

a) Leakage Measured (Lam) wt%/day b) Leakage Measured at 95% UCL wt%/day c) Preliminary As-Left Leakage _ wt%/day

/

Test Engineer Verification / Date 4.4.4 ANSIIANS 56.8-1994 TEST PERFORM ILRT measurements using mass point data analysis method until data indicates the following criteria is met. IF an ANSI/ANS 56.8-1994 test is NOT performed, THEN place N/A in space provided below.

ANSI/ANS 56.8-1994 Test 4.4.4.1 End of test upper 95% confidence limit for calculated leak rate based on mass point data analysis, plus all known additions SHALL be less than 75% of maximum allowable leak rate.

4.4.4.2 Data SHALL be recorded at approximately equal intervals and in NO case at intervals greater than one (1) hour.

4.4.4.3 At least thirty (30) data points SHALL be provided for proper statistical analysis.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 35 of 208 Initials 4.4.4.4 Minimum test duration is eight (8) hours.

IF Termination Criteria are NOT met, THEN:

a) CONTINUE the test, until the criteria is met, OR b) Consider performing a BN-TOP-1 test.

c) Consider restarting Hold Test if adequate pressure and stable conditions exist.

d) IF test results appear unacceptable due to excessive leakage, THEN refer to Step 2.1.21.

4.4.4.5 At end of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , VERIFY the two termination limits of ANSI 56.8-1994 have been met as follows:

a) Limit on curvature met by meeting any one of three inequalities described by ANSI 56.8-1994, as calculated by ILRT computer program (FTEST<1 or CP>0 or Quad<1).

b) Limit on data scatter met (COD>1).

c) Limits on curvature and data scatter above 4.4.4.5a) and 4.4.4.5b) were met for at least the last hour or the last four consecutive data sets (whichever is longer).

d) ATTACH ILRT computer program printout stating Termination Criteria has been met AND Termination Criteria Report printout to Attachment 16, Computer Printouts and Attachments of this procedure.

4.4.4.6 The following minimum number of sensors were working properly at end of test:

a) At least one (1) pressure gauge.

b) At least ten (10) drybulb temperature sensors.

c) At least three (3) relative humidity sensors.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 36 of 208 Initials NOTE Known Type B and C penalties and leakage savings SHALL be taken into account AND added to the Upper Confidence Level (UCL) Leakage Rate. IF additional penalties may be required due to leakage paths isolated during the test, THEN an adequate margin between UCL Leakage Rate and acceptance criteria should be maintained to accommodate additional values. IF Step 4.4.4.7c) is below acceptance criteria, THEN verification test may be started PRIOR to completing all calculations required by 5, ILRT Results Summary.

4.4.4.7 Calculate leakage rates via ILRT computer program.

Record ILRT leakage below:

a) Leakage Measured (Lam) wt%/day b) Leakage Measured at 95% UCL __ . wt%/day c) Preliminary As-Left Leakage . wt%/day Test Engineer Verification/Date CAUTION Notify Health Physics Department and Operations at least two hours PRIOR to starting the Verification Test.

4.4.5 ENSURE release permit has been completed AND portable air monitoring equipment has been setup.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 37 of 208 Initials NOTE IF a preliminary assessment of test additions/corrections was made prior to ending the ILRT and these additions were determined to have minimal impact on test acceptability, Step 4.4.4.7 may be completed after the superimposed leak is imposed and the Verification Test has begun.

4.5 Verification Test 4.5.1 Data collection:

4.5.1.1 Record time and date for start of Verification Test:

Time (24 hr clock): Date:

4.5.1.2 Record Verification Test Phase Initial Water Levels on Attachment 14, Control Room Log page 2 of 2.

4.5.1.3 VERIFY Trend Report on Plant Computer is setup to monitor levels in Attachment 14, Control Room Log is still running.

4.5.1.4 START recording containment atmospheric data in Verification Test Mode of ILRT Data Management Program at 15 minute intervals using ILRT Measurement System.

4.5.1.5 CONTINUE data acquisition after completion of ILRT through completion of Verification Test.

4.5.2 ESTABLISH a flow (Lo) through Verification Test rotometer of approximately 7.0 scfm (acceptable band is 5.25 to 8.75 scfm).

RECORD rotometer readings at approximately equal intervals NOT to exceed one (1) hour in Attachment 12, ILRT Verification Test and Flow Data.

4.5.2.1 IF a rotometer is used to measure imposed leak, THEN correct its reading to actual conditions in Step A of Attachment 12, ILRT Verification Test and Flow Data.

Corrected Flow value: scfm 4.5.2.2 ENTER corrected flow value into ILRT computer program:

Value entered: scfm

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 38 of 208 Initials 4.5.3 CONTINUE the Verification Test until the following criteria are met:

4.5.3.1 IF ILRT was performed per BN-TOP-1, Rev.1 (N/A if ILRT per ANSI 56.8-1994),

THEN PERFORM the following:

a) IF a short duration test was performed, THEN allow leak to stabilize for a period NOT to exceed one (1) hour from end of ILRT. Data acquisition is to continue throughout stabilization period. IF a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months test OR an ILRT under ANSI 56.8-1994 was performed, THEN a leak stabilization period is NOT required.

b) Record time and date:

Time (24 hr clock): Date:

c) Verification Test SHALL continue for one half the duration of the ILRT per BN-TOP-1, Rev. 1.

RECORD duration:

DETERMINE duration in hours of Verification Test. Subtract step 4.5.1.1 from 4.5.3.1b):

= (A) (hrs) 4.5.3.1b) 4.5.1.1 OBTAIN duration of ILRT from Attachment 15, ILRT Results Summary step 1.2 ILRT Duration: (hrs)

Divide ILRT duration by 2.

+ 2 = (B) (hrs)

ILRT duration IF value of (A) [Verification Test Duration] is greater than or equal to (B) [112 ILRT duration], THEN Verification test time is sufficient.

(A) hrs. Ž-(B) hrs.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 39 of 208 Initials d) Composite Leakage Rate (L,), as measured by ILRT computer using Total Time data analysis technique results, SHALL satisfy the following (show calculations on Attachment 12):

(L, + Lam - 0.25 La)1- L, - (L, + Lam+ 0.25. La)

Lower Limit Lc Upper Limit 4.5.3.2 IF ILRT was performed per ANSI 56.8-1994 (N/A if ILRT per BN-TOP-1), THEN:

a) Verification Test SHALL continue for a minimum of four (4) hours. Record duration:

Verification Test Duration: (hrs) b) Composite Leakage Rate (Lc), as measured by ILRT computer using Mass Point data analysis technique results, SHALL satisfy the following (show calculations on Attachment 12):

(L, + Lam - 0.25 La) < Lc -5(Lo + Lam+ 0.25. La)

Lower Limit Lc Upper Limit c) Lc value was within criteria above for the final hour or last four data points (whichever is longer).

d) At least 15 data sets were included in Verification Test result.

4.5.4 IF calculation indicated that Integrated Leak Rate Test is substantiated by Verification Test, THEN record acceptance in Attachment 1, Test Supervisor's Log AND proceed to Step 4.6.

4.5.5 IF calculation indicates that Integrated Leak Rate Test is NOT substantiated by Verification Test, THEN PERFORM the following (N/A unused steps):

4.5.5.1 CONTINUE data acquisition until data stabilizes within acceptance criteria band (if appropriate).

4.5.5.2 RECHECK verification flow meters AND ILRT measurement system, raw data and leak rate calculations for errors.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 40 of 208 Initials 4.5.5.3 IF errors are found and corrected, THEN continue Verification Test data acquisition until requirements of 4.5.3.1 OR 4.5.3.2 are met.

4.5.5.4 IF NO errors can be found AND test pressure is still above Pa, THEN consider securing superimposed leak and re-measuring Lam (restart ILRT) per Section 4.4.

4.5.6 WHEN Verification Test acceptance criteria has been met, THEN PERFORM the following:

4.5.6.1 RECORD the time and date for the start of the Verification Test:

Time (24 hr clock): Date:

4.5.6.2 RECORD end of Verification Test Phase Water Levels on Attachment 14, Control Room Log page 2 of 2.

4.5.6.3 Trend Report on Plant Computer is setup to monitor levels in Attachment 14, Control Room Log can be discontinued.

4.5.6.4 SECURE imposed leak, L, by isolating the flowmeter.

NOTE Restoration of plant and containment from ILRT may begin at SM's / Test Supervisor's discretion (Attachment 3B, ILRT Valve Lineups Prior to Stabilization may provide a safe place to start).

NOTIFY Maintenance Support AND Compressor vendor that break-down and removal of pressurization system compressors may begin.

Wear appropriate hearing protection in all areas so designated.

4.6 Depressurization 4.6.1 IF Iodine levels from samples taken during pressurization OR during depressurization exceed the limit provided in Step 3.31, THEN NOTIFY Outage Management, Health Physics and use the High Containment Activity Vent Path contingency in Section 3.0 of Attachment 11, Contingencies.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 41 of 208 Initials 4.6.2 ANNOUNCE the following 2 times over the plant page.

"ATTENTION ALL UNIT 2 PERSONNEL. ATTENTION ALL UNIT 2 PERSONNEL. VAPOR CONTAINMENT DEPRESSURIZATION IS ABOUT TO COMMENCE. ALL NON ESSENTIAL PERSONNEL STAND CLEAR OF ROPED OFF AREAS ASSOCIATED WITH THE INTEGRATED LEAK RATE TEST."

4.6.3 WHEN permission is granted from the Test Coordinator, THEN SLOWLY OPEN depressurization path blowdown valves AND RELEASE air from containment, maintaining a maximum depressurization rate NOT to exceed 15 psi/hr as follows:

4.6.3.1 ENSURE flanges on top of both Yard manifolds are removed.

4.6.3.2 SLOWLY OPEN all Yard manifold pentration stops:

(&1) (if)

UU-6, UU Manifold Stop VV-6, V V Manifold Stop V

UU-7, UU Manifold Stop

V V-7, V V Manifold Stop

UU-8, UU Manifold Stop

V V-8, V V Manifold Stop

UU-9, UU Manifold Stop

V V-9, V V Manifold Stop 0 UU-10, UU Manifold Stop _

V V-10, V V Manifold Stop

No:2-PT-1OY001 Rev:02 INTEGRATED LEAK RATE TEST Page 42 of 208 Initials 4.6.3.3 SLOWLY THROTTLE all Penetration manifold stops one at time as necessary until fully OPEN OR 15 psi/hr depressurization rate has been achieved:

(VI) (V)

UU-1, UU Manifold Stop

V V-i, V V Manifold Stop

" UU-2, UU Manifold Stop " V V-2, V V Manifold Stop

UU-3, UU Manifold Stop

V V-3, V V Manifold Stop

UU-4, UU Manifold Stop

V V-4, V V Manifold Stop

" UU-5, UU Manifold Stop " V V-5, V V Manifold Stop 4.6.3.4 Throttle OPEN MV-X, Manifold vents as necessary until all fully OPEN OR 15 psi/hr depressurization rate has been achieved 4.6.4 WHEN primary depressurization path throttle valve is full OPEN, AND depressurization rate has fallen below 15 psi/hr, THEN OPEN secondary depressurization path throttle valve(s).

MAINTAIN a maximum depressurization rate NOT to exceed 15 psi/hr.

4.6.5 WHEN containment pressure is less than 2 psig, THEN containment atmosphere SHALL be sampled by Health Physics followed by containment entry and final walk through PRIOR to allowing personnel access.

4.6.6 IF the 80' OR 95' airlock doors were locked with a chain or physical block to the hand wheels, THEN ENSURE all locks or blocking devices are removed to allow passage from inside containment. {Reference 9.2.8)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 43 of 208 Initials 4.7 Restoration 4.7.1 INFORM SM VC depressurization is complete.

4.7.2 REMOVE all instrumentation specified under Attachment 17, Gauge Installation / Removal Sheet.

4.7.3 REMOVE instrumentation installed from Attachment 5, ILRT Measurement System Installation and Checkout.

4.7.4 PRIOR to restoring power to Reactor Coolant Drain Tank Pumps in Attachment 3E, PERFORM the following:

4.7.4.1 REMOVE cap on LT-1003.

4.7.4.2 OPEN WDS-7038.

4.7.4.3 WHEN vented, THEN SHUT WDS-7038.

4.7.4.4 RE-INSTALL cap on LT-1003.

4.7.4.5 IF RCDT level column and LI-1003 on the Waste Disposal Panel are NOT approximately equal, THEN vent and fill RCDT level column.

4.7.4.6 VENT RCDT pump casings by cracking OPEN each RCDT pump volute drain UNTIL only water escapes.

4.7.4.7 VENT RCDT pump casings by cracking OPEN each RCDT upper casing vent plugs UNTIL only water escapes.

4.7.4.8 OPERATE only one pump in AUTO during initial WDS operation by placing either 21 RCDT Pump 2R 22 RCDT Pump selector switch in VLV523 CLOSED RCDT AUTO LEVEL DEFEAT position.

4.7.4.9 IF RCDT pressure and Containment Vent Header pressure are NOT equalized, THEN REMOVE loop seal on RCDT pumps per 2-SOP-5.1.1, Liquid Waste Disposal System Operation.

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 44 of 208 Initials NOTE System restorations should be performed concurrently with the Attachments.

Refer to procedures identified in NOTE prior to step 3.48 as well as other applicable procedures.

4.7.5 RESTORE all valves and breakers to correct Post-Test position as outlined in Attachments 3A, 3B, 3C, 3D, 3E, 4, 6, 7 and 8 OR as required by CRS. IF CRS OR SM requires use of Check-Off List (COL), THEN document COLs used in Section 5.0 Comments. ATTACH all COLs to this procedure.

4.7.5.1 COMPLETE Attachment 2, Containment Preparation CheckList returning all equipment which could be damaged by high pressure to its pre-test condition OR as required by CRS OR SM.

4.7.6 PLACE Pesonnel & Equipment Hatch Solenoids in NORMAL MODE on panel SM.

4.7.7 INFORM the SM that the ILRT is completed.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 45 of 208 Initials 4.8 Final ILRT Results NOTE Only the "AS LEFT" leakage calculated in step 4.8.1.1 below must be met prior to entering a mode of operation that requires containment integrity. Unacceptable "AS FOUND" OR "PERFORMANCE" Leakage rates may be dispositioned per the Containment Leak Rate Testing Program (CLRTP), step 5.4 of Reference 9.2.6 and the CR process.

4.8.1 WHEN all local leakage rate additions AND corrections to ILRT are known, THEN CALCULATE Final ILRT leakage rates using Attachment 15, ILRT Results Summary as guidance.

4.8.1.1 "AS LEFT" Leakage:

Sum of above reported Lam & UCL "AS LEFT" (on Attachment 15, ILRT Results Summary) 4.8.1.2 "AS FOUND" Leakage:

Sum of above reported Lam & UCL "AS FOUND" (on Attachment 15, ILRT Results Summary) 4.8.1.3 PERORMANCE LEAKAGE:

Sum of above report Lam & UCL "AS LEFT" and as-left minimum pathway leakage rate of any pathway isolated during ILRT due to excessive leakage.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 46 of 208 5.0 COMMENTS

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 47 of 208 Comments continued:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 48 of 208 Test Performers:

Print Name: Initials: Signature/Date:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 49 of 208 6.0 ACCEPTANCE CRITERIA 6.1 Technical Specification & IST Requirements:

7.0 TEST ACCEPTANCE 7.1 Technical Specifications Acceptance Criteria 7.1.1 Based on recorded data, are all Acceptance Criteria of 6.1 satisfied.

YES NO 7.1.2 IF the required Acceptance Criteria is NOT met, THEN:

NOTIFY CRS/SM.

INITIATE a WRT AND a CR.

" TAKE action in accordance with LCO 3.6.1 7.2 IF NO is circled in Step 7.1.1, THEN LIST Corrective Actions taken AND comments:

Comments:

Reviewed By:

SM OR Designated Alternate / Date

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 50 of 208 8.0 EVALUATION 8.1 PROGRAMS AND COMPONENTS REVIEW Comments:

Reviewed By:

Programs and Components Review / Date

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 51 of 208

9.0 REFERENCES

9.1 Commitment Documents 9.1.1 Title 10, Code of Federal Regulations, Part 50, Appendix J, Option B 9.1.2 "Containment System Leakage Testing Requirements" American National Standard ANSI/ANS 56.8-1994.

9.1.3 NRC Commitment NL-02-075-CO1, Ensure abandoned portions of WCCPPS are subjected to VC atmospheric pressure during ILRT.

9.1.4 "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" NEI 94-01, July 26, 1995.

9.1.5 "Performance-Based Containment Leak-Test Program," USNRC Regulatory Guide 1.163, September 1995.

9.2 Development Documents 9.2.1 Bechtel report "Testing Criteria for Integrated Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants" BN-TOP-1, Rev. 1, November 1, 1972.

9.2.2 USNRC INE Notice 85-71.

9.2.3 Improved Technical Specifications, Section 3.6 9.2.4 "Testing Containment Systems used with Light-Water-Cooled Power Reactors" Frank Zapp, et al, ORNL - NSIC - 26 UC 80 Reactor Technology.

9.2.5 Containment Leakage Rate Testing Program, PFM109 Rev.7 9.2.6 Primary Containment Leakage Rate Testing (Appendix J), ENN-DC-334 9.2.7 LO-OEN-2005-00276-CA6 from Waterford condition report CR-WF3-2005-2461 concerning voiding in the Rx head during depressurization of the Vapor Containment.

9.2.8 CR IP3-2005-01165-CA10 regarding 95' Airlock door being operated at the end of the ILRT from inside the VC with the handwheels locked and chained outside.

9.2.9 3-PT-10YO01, Integrated Leak Rate Test.

9.2.10 CRs IP2-2006-03052, IP2-2006-02129, IP2-2006-02049, LO-OLI-2006-00092.

No:2-PT-1 QY0Q1 Rev:02 INTEGRATED LEAK RATE TEST Page 52 of 208 9.3 Interface Documents 9.3.1 ,OAP-007, Containment Entry and Egress.

9.3.2 OAP-030, Infrequently Performed Tests and Evolutions.

9.3.3 2-OSP-10.4.1, Support Procedure - Isolation Valve Seal Water System Operation.

9.3.4 2-PI-2Y001, External Containment Structural Visual Inspection.

9.3.5 2-PI-R002, Internal Containment Structural Visual Inspection.

9.3.6 2-PT-2Y016A, 80' Containment AirLock Test.

9.3.7 2-PT-2Y016B, 95' Containment AirLock Test.

9.3.8 2-SOP-1.1, Filling and Venting Reactor Coolant System.

9.3.9 2-SOP-1.6, Pressurizer Relief Tank Operations.

9.3.10 2-SOP-3.1, Charging, Seal Water and Letdown Control.

9.3.11 2-SOP-5.4.1, VC Pressure Reliefs.

9.3.12 2-SOP-10.3, Containment Cooling System Operation.

9.3.13 2-SOP-10.5.1, Weld Channel and Containment Penetration Pressurization System.

9.3.14 2-SOP-I11.1, Ventilation System Operation.

9.3.15 2-SOP-12.3.2, Digital Radiation Monitoring System Operation (Local or SRD).

10.0 RECORDS AND DOCUMENTATION 10.1 Records The following required records are generated by this procedure and SHALL be maintained in accordance with IPEC Records Retention Schedule:

10.1.1 WHEN completed, THEN this Performance Procedure becomes a Quality Record.

10.2 Documentation The following documentation resulting from this procedure are NOT required to be controlled and maintained in accordance with the IPEC Records Retention Schedule.

None.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 53 of 208 ATTACHMENT 1 TEST SUPERVISOR'S LOG (Page 1 of 1)

DATE:

TIME: REMARKS:

NOTE: (1): MAKE ADDITIONAL SHEETS AS REQUIRED

No:2-PT-i OYO01 Rev:02 INTEGRATED LEAK RATE TEST Page 54 of 208 ATTACHMENT 2 CONTAINMENT PREPARATION CHECKLIST (Page 1 of 4)

EQUIPMENT PROTECTIONIPREPARATION Any equipment which may be damaged when subjected to high pressure should be removed from containment or vented.

NOT included is any instrumentation associated with containment isolation or monitoring of accident conditions. Use blank lines to document any items removed or vented NOT already listed in this attachment. Removed equipment SHALL be properly stored.

N/A Requirements to "restore" components simply verified as having unobstructed vent holes.

OPERATIONS (REFUELING TEAM):

EQUIPMENT PROTECTION VERIFICATION SIGNATURE & DATE COMPLETED RESTORED Complete Refueling Head Procedure As required by procedure.

sections for ILRT Preparation.

Internals Lifting Rig Instrumentation; Remove from containment (if required).

load cell readout unit.

OPERATIONS EQUIPMENT PROTECTION VERIFICATION SIGNATURE & DATE COMPLETED RESTORED Rx Vessel Cooling Support Blocks Apply protection as required and remove guages Temperature Indicators T1-1259, from VC to prevent damage. Apply protection as TI-1 260, TI-1 261 and TI-1 262 required and restore gauges to VC when ILRT is completed.

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 55 of 208 ATTACHMENT 2 CONTAINMENT PREPARATION CHECKLIST (Page 2 of 4)

MECHANICAL MAINTENANCE:

VERIFICATION SIGNATURE & DATE EQUIPMENT PROTECTION COMPLETED RESTORED Polar crane hyd. reservoir, gear boxes Vent to containment (if required).

CO2 Bottles from Flux Drive units Remove from containment.

Nitrogen, argon oxygen/acetylene, Remove from containment.

(etc.) bottles Vent boxes, remove aerosol cans, tubes of lubricant.

891A, B, C, D Blocked OPEN.

Block OPEN Fan Cooler Motor Duct Access Fan Cooler Units Pae Plate.

Fan Cooler Units Block all plenum doors OPEN.

VENT 21 Recirc Pump Motor Equalizing Device 21 Recirculation Pump Motor (rubber flapper on bottom side of motor housing) by blocking OPEN (IF Required).

VENT 22 Recirc Pump Motor Equalizing Device 22 Recirculation Pump Motor (rubber flapper on bottom side of motor housing) by blocking OPEN (IF Required).

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INSTRUMENTATION & CONTROLS:

VERIFICATION SIGNATURE &

DATE PROTECTION EQUIPMENT COMPLETED RESTORED Manipulator Crane position readout Remove from containment (assist Refuel Team transducer units operators if required).

RE-2 (Containment Radiation Monitor) Remove G-M tubes.

RE-7 (In-Core Instrumentation Area Remove G-M tubes.

Radiation Monitors)

"Bistable trip" switches for SPRAY INIT.

On containment pressure. Location: Place both "bistable trip" switches in the TRIP position CCR, panel B-9 ch. 4, yellow, Loop 1 "Bistable trip" switches for SPRAY INIT.

On containment pressure. Location: Place both "bistable trip" switches in the TRIP position CCR, panel A-9 ch. 2, white, Loop 3 "Bistable trip" switches for SPRAY INIT.

On containment pressure. Location: Place both "bistable trip" switches in the TRIP position CCR, panel B-1 ch.3, blue, Loop 2

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OTHER WORK GROUPS:

EQUIPMENT PROTECTION VERIFICATION SIGNATURE & DATE COMPLETED RESTORED Nitrogen, argon oxygen/ acetylene, (etc.) Remove from containment.

bottles Fire extinguishers Remove from containment.

Wooden scaffolding Remove from containment.

Gang boxes Vent boxes, remove aerosol cans, tubes of lubricant.

Tool Room Remove air conditioners, ANY aerosol cans, paint/solvent cans, lubricants tubes, bottles.

Reactor Cavity Radiation Monitor Remove G-M tubes (if required).

Computer monitors, CCTV monitors, test Remove from containment.

equipment with tube-based displays

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CHECKLIST CONTENTS:

ATTACHMENT 3A: ILRT VALVE LINEUPS PRIOR TO PRESSURIZATION Checklist consists of penetration alignments that must be completed prior to start of pressurization either because they include components to check while access is available to containment, OR to avoid potential closure problems once pressurization has started. NO penetration containing liquid is vented OR drained by this procedure, AND lineups are NOT sequence critical.

ATTACHMENT 3B: ILRT VALVE LINEUPS PRIOR TO STABILIZATION Checklist consists of penetration alignments that may be completed after pressurization has started because they include NO components to position inside containment, or those components are remotely operated in closed systems NOT exposed to test pressure. A penalty addition is planned for all of these penetrations so closure method and closure sequence is NOT critical.

ATTACHMENT 3C: ILRT SPECIAL VALVE LINEUPS Checklist consists of penetration alignments that must be completed prior to the start of pressurization, and are considered to be sequence critical.

CHECKLIST COMPLETION:

CAUTION Unless otherwise instructed by the Shift Manager, [IFline will be opened / vented OR CIVs must be opened, do NOT perform the Penetration Line Up when containment integrity is required. Penetration lineups that do NOT entail opening lines, venting / draining systems may be performed anytime as directed by the Test Supervisor.

Issue the ILRT Valve Line up Checklists to Operations AND attach a copy of these instructions.

Tagouts will only be used when a system's piping is opened for the test (e.g. vented to atmosphere), or for personnel safety.

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Informational Tagging is used sparingly to save time, and minimize demand on resources. ILRT Tags are information tags placed on valves/components moved from their NORMAL position for the ILRT (i.e. if the "Test Position" is the same as the component's normal position, a tag may not hung).

NO liquid filled penetrations are being vented/drained as part of this line-up.

PERFORM Attachment 3C, ILRT Special Valve Lineups in the order written for systems to be vented/opened to simplify proper venting of the system.

Except in cases where a penetration will be vented, the lineup is organized (sorted) by location to facilitate its completion.

MOST penetrations in Attachment 3A, ILRT Valve Lineups Prior to Pressurization AND B, ILRT Valve Lineups Prior to Stabilization will NOT be vented.

Their line-ups may be performed in any order, provided all piping is depressurized.

GENERAL INSTRUCTIONS:

IF a Containment Isolation Valve (CIV) in Penetrations that will be vented/tested by the ILRT (See , Containment Penetration Summary) has NOT been closed via normal means, THEN stroke valve PRIOR to closure per the ILRT Valve L/U Attachments to demonstrate they were closed by their normal mode of force. RECORD any Containment Isolation Valve (CIV) closure NOT by normal means on Attachment 7, Test Exceptions Log.

Lineups in Attachments 3A and 3B are suggested lineups, intended to disposition a penetration for the ILRT. These lineups may be modified IF required with the concurrence of the ILRT Coordinator AND the Test Supervisor. Any variation from this lineup SHALL be documented in , Test Exceptions Log AND testing status of the penetration reviewed and updated (if changed) in Attachment 9, Containment Penetration Summary.

Modifications to component line-ups may be required during the preparations for the ILRT. , Valve Lineup Alteration Log will be used to track changes requested to a system/penetration lineup once signed off as completed for the ILRT. The component position MUST be returned to the "Test L/U Position" PRIOR to starting compressors OR stabilization as appropriate (reviews are cued by the procedure). Any temporary valve lineup alteration that can NOT be restored prior to the test must be accepted by the ILRT Test Coordinator AND be dispositioned as stated in the previous paragraph above via Attachments 7 and 9.

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ILRT "Test L/U Position" may be verified through review of administrative controls documents (e.g.

a completed Containment Integrity Checklist OR Equipment Tagout Log, Locked Valve Log, etc.)

at the sole discretion of the Test Supervisor. Components verified through review or acceptance of administrative controls will be denoted with a printed "A" for "Admin." in the initials column to facilitate identification of verifications performed in this manner.

Components that have their "Test L/U Position" different than their normal position for the ILRT SHALL be verified in the field. Component position may also be accepted IF the component is part of a Clearance that will remain in force throughout the ILRT window. In these cases the Test Supervisor will sign-on to the applicable Clearance.

ILRT TAG LOCATION (WHEN USED):

For all remotely operated valves, hang ILRT Tag on the control switch only.

For all manual valves, hang ILRT Tag on valve handwheel only IF tags are to be used.

FLANGES/PIPE CAPS:

The drain/vent flange and bolts may be left attached as long as flange is swung to the side. The bolts must be installed finger-tight so that flange can NOT block vent OR drain path during the ILRT.

At completion of each ILRT Valve Lineup Attachment, all drain hoses are to be removed.

Do NOT obstruct pipe vents/drains inside OR outside containment. This will invalidate the ILRT for this penetration.

DEFINITIONS:

ILRT Tag CLOSED Position the valve in the CLOSED position AND attach an ILRT Tag at the appropriate location.

ILRT Tag OPEN Position the valve in the OPEN position AND attach an ILRT Tag at the appropriate location.

V Independent OR Concurrent Verification.

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PENETRATION RESTORATION CHECKLIST INSTRUCTIONS:

Components NOT returned to their AS FOUND condition SHALL be authorized by either the Test Supervisor OR CRS. Documentation for the reason the component was NOT returned to the AS FOUND condition SHALL be annotated or attached to the applicable Attachment.

Re-issue the ILRT Valve Lineup Attachment Checklists to complete penetration restoration to Operations AND attach a copy of these instructions.

Except for portions of the valve lineup accomplished via clearance, the restoration may be signed off in any order. Restore vented/drained penetrations per Test Supervisor to prevent inadvertent release of fluids through the ILRT test boundary.

Instrument Air penetrations must be restored PRIOR to restoring any penetrations containing AOVs.

Dispose of all ILRT Information Tags, bags, etc. in the appropriate manner.

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SYSTEM: CHEMICAL & VOLUME CONTROL (9321-2736, 208168)

TEST INI AS II VALVE DESCRIPTION LOCATION AS FOUND IT INIT V IL/U LEFT 201 / 202 LETDOWN LINE ISOL VLVS CCR SNF CLOSE MOV-205 CHARGING LINE TO RCS CIV 98' PAB MCC ROOM SHUT MOV-226 CHARGING LINE TO RCS CIV 98' PAB MCC ROOM SHUT MOV-227 HCV-142 BYPASS 98' PAB MCC ROOM SHUT MOV-250A 21 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-4925 21 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-2508 22 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-4926 22 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-250C 23 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-4927 23 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-250D 24 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-4928 24 RCP SEAL INJECTION CIV 98' PAB MCC ROOM SHUT MOV-222 SEAL WATER RETURN ISOL VLV CCR SNF SHUT 272A 21 SEAL WTR HX INLET STOP 98' PAB SHUT 221B 21 SEAL WTR HX BYPASS STOP 98' PAB SHUT

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SYSTEM: POST ACCIDENT VC H2 CONCENTRATION SAMPLING (208 79)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V 98' PAB SOV-5018 CONTAINMENT AIR SAMPLE CH-1 CIV MCC SHUT MCC ROOM SOV-5019 CONTAINMENT AIR SAMPLE CH-1 CIV 98M MCC PAR ROOM SHUT 98' PA8 SOV-5020 CONTAINMENT AIR SAMPLE CH-2 CIV MCC ROOM SHUT SOV-5021 CONTAINMENT AIR SAMPLE CH-2 CIV 98' ROOM MCC PAR SHUT CHANNELl H2-02 ANALYZER 98' PAB RETURN STOP TO VC CIV MOC ROOM CONTAINMENT AIR SAMPLE RETURN 98' PAB SOV-5023 CH-1 CIV MCC ROOM SHUT SOV-5024 CHANNEL2 H2-02 ANALYZER 98' PAB RETURN STOP TO VC CIV MCC ROOM SHUT SOV-5025 CONTAINMENT AIR SAMPLE RETURN 98' PAB OPEN CH-2 CIV MCC ROOM 80' PAB CAP CAP DOWNSTREAM OF 5130 OLD SAMPLE OLD AM CELL REMOVED 80' PAB OE 5130 CHANNEL-2 CROSS TIE DRAIN STOP OLD SAMPLE CELL OPEN CAP CAP DOWNSTREAM OF 5131 80' PAB CELL OLD SAMPLE REMOVED 80' PAB OPEN 5131 CHANNEL-1 CROSS TIE DRAIN STOP OLD SAMPLE CELL CAP CAP DOWNSTREAM OF 5129 68' MEZZANINE REMOVED 5129 TEST CONNECTION UPSTREAM OF 68'MEZZANINE OPEN SOV-5024

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SYSTEM: WASTE DISPOSAL SYSTEM (9321-2719)

TEST VALVE DESCRIPTION LOCATION AS FOUND TS LUU INIT AS LEFT INIT V 1723/1728 CNTMT SUMP DISCH ISOL VALVES CCR SNF CLOSE 1702/1705 RCDT PUMP DISCH ISOL VALVES CCR SNF CLOSE 1788/1789 RCDT GAS ANAL ISOL VALVES CCR SNF CLOSE 1786/1787 CNTMT VENT HDR ]SOL VALVES CCR SNF CLOSE 1717 RCDT TO GAS ANALYZER SAMPLE STOP 46' VC OPEN 1713 RCDT MANUAL VENT STOP 46' VC OPEN 1711 REFUELING CANAL DRAIN STOP TO RCDT 46' VC OPEN 1708 REFUELING CANAL DRAIN STOP TO RCDT 46' VC OPEN 1716 RCDT N2 SUPPLY & VENT HEADER STOP 46' VC OPEN

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SYSTEM: MAIN STEAM (9321-2017 & 9321-2041)

TEST VALVE DESCRIPTION I LOCATION AS FOUND LES

/UU INIT AS LEFT INIT V MS-1-21 21 SG MAIN STEAM STOP VLV CCR SBF-1 SHUT MS-1-22 22 SG MAIN STEAM STOP VLV CCR SBF-1 SHUT MS-1-23 23 SG MAIN STEAM STOP VLV CCR SBF-1 SHUT MS-1-24 24 SG MAIN STEAM STOP VLV CCR SBF-1 SHUT MS-91D 24 SG MST-4 INLET ROOT STOP 65' ABFP BLDG SHUT MS-94D 24 SG MST-4 DRIP POT DRAIN STOP 65' ABFP BLDG SHUT MS-91A 21 SG MST-1 INLET ROOT STOP 65' ABFP BLDG SHUT MS-94A 21 SG MST-1 DRIP POT DRAIN STOP 65' ABFP BLDG SHUT MS-91B 22 SG MST 2 INLET ROOT STOP 65' ABFP BLDG SHUT MS-94B 22 SG MST-2 DRIP POT DRAIN STOP 65' ABFP BLDG SHUT MS-56D 24 SG MS-1-24 SAMPLE AND VENT ROOT STOP 65' ABFP BLDG SHUT MS-55D 24 MAIN STEAM ISOL VLV MS-1-24 BYPASS 65' ABFP BLDG SHUT MS-58D-1 24 SG MST-4 ROOT STOP 65' ABFP BLDG SHUT MS-58D-2 24 SG MST-18 ROOT STOP 65' ABFP BLDG SHUT MS-3D 24 SG PCV- 1137 INLET STOP 65' ABFP BLDG SHUT MS-42 23 SG TO 22 AFP TURBINE 65' ABFP BLDG SHUT MS-41 22 SG TO 22 AFP TURBINE 65' ABFP BLDG SHUT MS-3B 22 SG PCV-1 135 INLET STOP 65' ABFP BLDG SHUT MS-56B 22 SG MS-1-22 SAMPLE AND VENT ROOT STOP 65' ABFP BLDG SHUT

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SYSTEM: MAIN STEAM (9321-2017 & 9321-2041) (continued)

TEST VALVE DESCRIPTION LOCATION AS FOUND U INIT AS LEFT INIT V MS-55B 22 MAIN STEAM ISOL VLV MS-1-22 BYPASS STOP 65' ABFP BLDG SHUT MS-58B-1 22 SG MST-12 ROOT STOP 65' ABFP BLDG SHUT MS-58B-2 22 SG MST-10 ROOT STOP 65' ABFP BLDG SHUT MS-56C 23 SG MS-1-23 SAMPLE AND VENT ROOT STOP 77' ABFP BLDG SHUT MS-55C 23 MAIN STEAM ISOL VLV MS-1-23 BYPASS 77' ABFP BLDG SHUT MS-58C-1 23 SG MST-13 ROOT STOP 77' ABFP BLDG SHUT MS-58C-2 23 SG MST-14 ROOT STOP 77' ABFP BLDG SHUT MS-3C 23 SG PCV-1136 INLET 77' ABFP BLDG SHUT MS-91C 23 SG MST-3 INLET ROOT STOP 77' ABFP BLDG SHUT MS-94C 23 SG MST-3 DRIP POT DRAIN STOP 77' ABFP BLDG SHUT MS-3A 21 SG PCV-1134 INLET 77' ABFP BLDG SHUT MS-56A 21 SG MS-1-21 SAMPLE AND VENT ROOT STOP 77' ABFP BLDG SHUT MS-55A 21 MAIN STEAM ISOL VLV MS-1-21 BYPASS 77' ABFP BLDG SHUT MS-58A-1 21 SG MST-5 ROOT STOP 77' ABFP BLDG SHUT MS-58A-2 21 SG MST-6 ROOT STOP 77' ABFP BLDG SHUT This system is lined up prior to pressurization s to ensure S/G's are "bottled up" so pressure gauges might detect in-leakage during pressurization. This lineup is a candidate for early restoration (the beginning of depressurization).

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SYSTEM: SAFETY INJECTION (9321-2735 & 235296)

TEST VALVE DESCRIPTION LOCATION AS FOUND L/U INIT AS LEFT INIT V MOV-866A / 21 CNTMT SPRAY DISCH STOP VALVES CCR SBF-1 CLOSE MOV-866C MOV-866CD 22 CNTMT SPRAY DISCH STOP VALVES CCR SBF-1 CLOSE MOV-866D MOV-888A RHR HX OUTLET TO SI PUMPS CCR SBF-1 CLOSE MOV-888B MOV-885A CNTMT SUMP TO RHR PUMP SUCT CCR SBF-1 CLOSE MOV-885B CNTMT SUMP TO RHR PUMP SUCT CCR SBF-1 CLOSE MOV-1805 CNTMT SUMP DISCH TO RHR PUMP CCR SBF-1 OPEN SUCT MOV-851A 22 SI PUMP TIE VALVE TO DISCHARGE CCR SBF-2 CLOSE OF 21 SI PUMP MOV-851B 22 SI PUMP OFCS PMTIE VALVE TO DISCHARGE CR BBF-2 CLOSE OF 23 $1PUMP BLOCKED "891A ACCUM 21 N2 FILL LINE CCR SMF OPEN BLOCKED

891B ACCUM 22 N2 FILL LINE CCR SMF OPEN OPEN BLOCKED

891C ACCUM 23 N2 FILL LINE CCR SMF OPEN BLOCKED 891D ACCUM 24 N2 FILL LINE CCR SMF OPEN OPEN

891A through D SHALL be BLOCKED OPEN by Maintenance. 4313 will be OPEN and 4315 will be OPEN with the flange removed in Attachment 3C, ILRT Special Valve Lineups to provide SIS Accumulator protection.

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SYSTEM: SAFETY INJECTION (9321-2735 & 235296) (Contin ed)

TEST AS VALVE DESCRIPTION ILiu LOCATION AS FOUND INIT ET LEFT INIT V MOV-850A 21 SAFETY INJECTION PUMP DISCHARGE 98' ROMSHUT PAB MCC STOP ROOM MOV-850B 23 SAFETY INJECTION PUMP DISCHARGE 98' PAB MCC SHUT STOP ROOM MOV-869A 21 SPRAYSTOP HEADER PUMP DISCHARGE TO SPRAY 98' ROOM PAB MCC SHUT MOV-869B 22 SPRAYSTOP HEADER PUMP DISCHARGE TO SPRAY 98' ROOM PAB MCC SHUT 878A 21 CONTAINMENT SPRAY PUMP TEST LINE 68' PAR SHUT STOP 878B 22 CONTAINMENT SPRAY PUMP TEST LINE 68' PAB SHUT STOP 859A SI TEST LINE CIV 51' PIPE PEN SHUT 859C SI TEST LINE CIV 51' PIPE PEN SHUT

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SYSTEM: FUEL TRANSFER TUBE (208486)

VALVE DESCRIPTION LOCATION AS FOUND TEST UU INIT AS LEFT INIT V FLANGE FUEL TRANSFER TUBE VC INSTALLED FCCH-001 FUEL TRANSFER TUBE GATE VALVE FSB SHUT SYSTEM: CONDENSER AIR REMOVAL (9321-2025)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V SJAE BLOWER CONTROL SWITCH FOR SJAE BLOWER CCR SBF-2 PULLOUT PCV-1229 SJAE EFFLUENT ISOL VLV CCR SNF CLOSE PCV-1230 SJAE EFFLUENT ISOL VLV CCR SNF CLOSE VENT 3/4" BLOWER DOWNSTREAM CAP 36'TH REMOVED SYSTEM: STATION AIR (9321-2035)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V SA-24 STATION AIR TO CONTAINMENT ISOLATION 51' PIPE PEN SHUT SA-24-1 STATION AIR TO CONTAINMENT ISOLATION 51' PIPE PEN SHUT SA-24-2 STATION AIR TO CONTAINMENT ISOLATION 51' PIPE PEN SHUT SA-24-3 STATION AIR TO CONTAINMENT ISOLATION 51' PIPE PEN OPEN CAP VENT PIPE BETWEEN SA-24-2 AND SA-24-3 51' PIPE PEN REMOVED

SA-21-20 STATION AIR HOSE CONNECTION ISOLATION 68' VC OPEN

Ensure pipe is vented to VC atmosphere. Remove any fittings IF necessary.

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SYSTEM: POST ACCIDENT CONTAINMENT VENTING (208879)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V E-2 CB ATMOSPHERE TO PA VENT 98'MCO SHUT MCC ROOM SU E-1 IA TO CB PA VENT 98'PASHUT MCC ROOM E-3 PRI VENT ISO STOP 98PASHUT E-5 SECONDARY VENT ISO STOP 98' PAR HU MCC ROOM 98' PAB EA-1 A TO CB, PA VENT MCC ROOM SHUT CAP REMOVE CAP DOWNSTREAM OF 51' SGBD REMOVED E-8 (BETWEEN PI-1396 AND E-8) ROOM E-8 Pl- 1396 STOP 51'SGBD OPEN ROOM CAP REMOVE CAP DOWNSTREAM OF SGBD 51'ROOM REMOVED E-9 (BETWEEN P1-1397 AND E-9)

E-9 P1-1397 STOP 51'SGBD OPEN I ROOM

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SYSTEM: SAFE SHUTDOWN TRANSMITTERS (30 8762)

VALVE DESCRIPTION LOCATION AS FOUND TEST UU INIT AS LEFT INIT V IIP-540 LT-3101 OUTPUT STOP TO LI-3101 68'VC RACK 19A SHUT

& LT-3101-1 IIP-536 PT-3105 OUTPUT STOP TO PI-3105 68'VC RACK 19A SHUT

& PI-3105-1 IIP-518 LT-5001 OUTPUT STOP TO LI-5001 68' VC RACK 21A SHUT AND LI-5001-1 IIP-526 LT-5002 OUTPUT STOP TO LI-5002 68'VC RACK 21A SHUT AND LI-5002-1 CAP CAP DOWNSTREAM OF IIP-543 80' VC REMOVED IIP-543 LI-3101 BLOWDOWN STOP 80' VC OPEN CAP CAP DOWNSTREAM OF IIP-539 80' VC REMOVED IIP-539 PI-3105 BLOWDOWN STOP 80' VC OPEN CAP CAP DOWNSTREAM OF IIP-521 80' VC REMOVED IIP-521 SG 21 LI-5001 STOP 80' VC OPEN CAP CAP DOWNSTREAM OF IIP-529 80' VC REMOVED IIP-529 SG 22 LI-5002 STOP 80' VC OPEN IIP-542 LI-3101 STOP 80'VC OPEN IIP-538 PI-3105 STOP 80' VC OPEN IIP-520 SG 21 LI-5001 STOP 80' VC OPEN IIP-528 STEAM GENERATOR 22 LI-5002 80' VC OPEN STOP

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SYSTEM: SAFE SHUTDOWN TRANSMITTERS (308762) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V IIP-500 22SG LEVEL INDICATOR LI-5002-1 51' PIPE PEN SHUT CIV STOP IIP-501 22SG LEVEL INDICATOR LI-5002-1 51' PIPE PEN SHUT CIV STOP I[P-502 21SG LEVEL INDICATOR LI-5001-1 51' PIPE PEN SHUT CIV STOP IIP-503 21SG LEVEL INDICATOR LI-5002-1 51' PIPE PEN SHUT CIV STOP IIP-504 PRESSURIZER LI-3101-1 51' PIPE PEN SHUT IIP-505 PRESSURIZER LI-3101-1 51' PIPE PEN SHUT IIP-506 PRESSURIZER PI-3105-1 51' PIPE PEN SHUT IIP-507 PRESSURIZER PI-3105-1 51' PIPE PEN SHUT IIP-508 22SG LEVEL INDICATOR LI-5002-1 51'PIPE PEN SHUT TEST CONN STOP IIP-510 21SG LEVEL INDICATOR LI-5001-1 51' PIPE PEN SHUT TEST CONN STOP IIP-512 PRESSURIZER LI-3101-1 T.C. 51' PIPE PEN SHUT IIP-514 PRESSURIZER PI-3105-1 T.C. 51' PIPE PEN SHUT

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SYSTEM: SAFE SHUTDOWN TRANSMITTERS (30 762) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V CAP CAP DOWNSTREAM IIP-509 51' PIPE PEN REMOVED IIP-509 INDICATOR LI-5002-1 22SG LEVEL STOP 51' PIPE PEN OPEN TEST CONN CAP CAP DOWNSTREAM IIP-511 51' PIPE PEN REMOVED IIP-51 1 21SG LEVEL INDICATOR LI-5001-1 51'PIPE PEN OPEN TEST CONN STOP CAP CAP DOWNSTREAM IIP-513 51' PIPE PEN REMOVED IIP-513 PRESSURIZER LI-3101-1 T.C. 51' PIPE PEN OPEN CAP CAP DOWNSTREAM IIP-515 51' PIPE PEN REMOVED IIP-515 PRESSURIZER PI-3105-1 T.C. 51' PIPE PEN OPEN SYSTEM: CONTAINMENT VENTILATION PURGE / RELIEF (9321-4022, 242688 VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V PCV-1190 CONT BLDG(INSIDE ISOL VLVS RELIEF PRESSVC) 80' PAB CLOSED PCV-119111192 CONT BLDG PRESS RELIEF CCR SLF CLOSED ISOL VLVS (OUTSIDE VC)

IA-774 IATO PCV-1 190 STOP 46' VC SHUT VENT PCV-1 190 VOLUME FITTING VENT TANK BY DISCONNECTING 46' VC FITTING DISCONNECTED

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SYSTEM: AIRLOCK GAUGES (9321-7052)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V VC 95' WCPS-1193 P1-1352 HI SIDE STOP Ai L5, Air Lock SHUT WCPS-1194 PI-1352 LO SIDE STOP VC k SHUT Air Lock WCPS-1195 P1-1351 LO SIDE STOP VC Lock Air 95L SHUT INSTALL CAP CAP LINE DOWNSTREAM VC 95' INSTALLED OF WCPS-1 195 Air Lock P1-1351 CONTAINMENT PRESSURE VC 95 REMOVED Air Lock VC 95' P1-1352 HATCH PRESSURE Ai Lock Air Lo' REMOVED EQUIPMENT VC 95' PI-7477 HATCH/PERSONNEL LOCK REMOVED STUB PRESSURE. (CB INT) Air Lock INSTALL CAP CAP WAS LINE WERE PI-7477 REMOVED VCLock Air 95' INSTALLED VC 80' WCPS-1 197 P1-1346 HI SIDE STOP Ai Loc SHUT Air Lock WCPS-1198 P1-1346 LO SIDE STOP VCk SHUT SU Air Lock WCPS-1 199 P1-1345 LO SIDE STOP VCLock Air 80L SHUT CAP LINE DOWNSTREAM VCLock 80' INSTALLED ITL INSTALLCAP OFWCPS-1199 Air

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SYSTEM: AIRLOCK GAUGES (9321-7052) (Co tinued)

VALVE DESCRIPTION LOCATION AS FOUND TEST IJU INIT AS LEFT INIT V P1-1345 CONTAINMENT PRESSURE VC 80' REMOVED Air Lock 80'AIRLOCK PRESSURE VC 80s PI-1346 GAUGE Air Lock REMOVED PERSONNEL LOCK STUB VC 80' REMOVED PI-7481 PRESSURE Air Lock CAP LINE WERE PI-7481 VC 80' INSTALL CAP WAS REMOVED Air Lock SYSTEM: CONTAINMENT VENTILATION FAN COOLER UNIT EXHAUST (9321 4022)

VALVE DESCRIPTION LOCATION AS FOUND TEST IJU INIT AS LEFT INIT V FCV-21 21CRF NORMAL MODE CCR SBF-2 OPEN OUTLET FCV-22 22CRF NORMAL MODE CCR SBF-2 OPEN OUTLET FCV-23 23CRF NORMAL MODE CCR SBF-2 OPEN OUTLET FCV-24 24CRF OUTLETNORMAL MODE CCR SBF-2 OPEN FCV-25 25CRF NORMAL MODE CCR SBF-2 OPEN OUTLET SYSTEM: WELD CHANNEL & PENETRATION PRESSURIZATION (9321-2726)

AS VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT LF LEFT [NIT V PCV-1101-1321B PRESSURE SWITCH 1321 LOWER ROOT STOP 68' VC (RACK 16) SHUT PCV-1 101-1318B PRESSURE SWITCH 1318 LOWER ROOT STOP 68' VC (RACK 16) SHUT

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SYSTEM: WELD CHANNEL & PENETRATION PRESSURIZATION (9321-2726)

AS AS VALVE DESCRIPTION IFOUND LOCATION FU TEST LIU INIT LEF LEFT INIT V PCV-1110-1 ZONE 1 - N2 BACKUP SUPPLY REGULATOR INLET STOP PCV-1110-22 ZONE 1 REGULATOR [PCV-1193] INLET STOP 80' PAB SHUT PCV-1110-23 ZONE 1 REGULATOR [PCV-11931 OUTLET STOP 80' PAB SHUT PCV-1101-1 REGULATOR PCV-1193 BYPASS STOP 80' PAB SHUT CAP REMOVE CAP DOWNSTREAM OF WCP-99 80' PAB REMOVED WCP-99 TEST CONNECTION PAB ZONE NORMAL SUPPLY Ba'PAR OPEN PCV-1 110-9 WELD CHANNEL ZONE 3 - N2 B/U SUPPLY REGULATOR INLET STOP 80'PAB SHUT PCV-1110-26 ZONE 3 REGULATOR [PCV-1197] INLET STOP 80' PAB SHUT PCV- 1110-27 ZONE 3 REGULATOR [PCV-1 1971 OUTLET STOP 80' PAB SHUT PCV-1101-3 REGULATOR PCV-1197 BYPASS STOP 80' PAB SHUT CAP REMOVE CAP DOWNSTREAM OF WCP-107 80' PAB REMOVED WCP-107 WSP-PL7 TEST CONNECTION PAB ZONE 3 NORMAL SUPPLY 80' PAB OPEN

Secure zones using 2-SOP-10.5.1, Weld Channel and Containment Penetration Pressurization System Operation individual zone depressurization section.

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SYSTEM: WELD CHANNEL & PENETRATION PRESSURIZATION (9321-2726) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V WCPS ZONE 4 - N2 BACKUP SUPPLY REGULATOR 80' PAB SHUT PCV-1110-21 INLET STOP PCV-1110-28 ZONE 4 REGULATOR [PCV-1199] INLET STOP 80' PAB SHUT PCV-1110-29 ZONE 4 REGULATOR [PCV- 11991 OUTLET STOP 80' PAB SHUT PCV-1101-4 REGULATOR PCV-1199 BYPASS STOP 80' PAB SHUT CAP REMOVE CAP DOWNSTREAM OF WCP-1 11 80' PAB REMOVED WCPS ZONE 4 NORMAL SUPPLY TEST WCP-1 11 CNETOSOP80'STOP CONNECTION PAB OPEN PCV-1111-1 ZONE 3 SUPPLY TO RACKS 16 & 17 51' PIPE PEN OPEN (PENETRATfON "Y")

PCV-1111-2 ZONE 4 SUPPLY TO RACKS 14 & 18 51' PIPE PEN OPEN (PENETRATION "Y")

SOV-EW-1 POST ACCIDENT VC ISOLATION 98'PAB MCC SHUT ROOM SOV-EW-2 POST ACCIDENT VC ISOLATION 98'PAB MCC SHUT ROOM PCV-1 231 SJAE OUTLET HDR CONT ISOL VALVE WCCPPS 51' PIPE PEN SHUT STOP

- PCV-1233 SJAE SEAL AIR SUPPLY 51' PIPE PEN SHUT

PCV-1231 INSTALL a mechanical spider on relay 33-1X behind panel SN to actuate relay and maintain PCV-1231 CLOSED.

- PCV-1233 INSTALL a mechanical spider on relay 33-2X behind panel SN to actuate relay and maintain PCV-1233 CLOSED.

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SYSTEM: WELD CHANNEL & PENETRATION PRESSURIZATION (9321-2726 & 201128) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V PCV-1240, 1239, CNTMT RAD MON WCPS VALVES CCR SNF CLOSE 1238,1241 1 NOTES: Depressurize the following valve interspaces:

Post Accident Containment Air Sample (PCV-1236 & PCV-1237)

Condenser air removal (PCV-1229 & PCV-1230)

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SYSTEM: CONTAINMENT PRESSURE TRANSMITTERS (235296)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V CONTAINMENT PRESSURE 1814A INSTRUMENTS CHANNEL 1 CIV 51' PIPE PEN OPEN CONTAINMENT PRESSURE INSTRUMENTS CHANNEL 2 CIV CONTAINMENT PRESSURE 1814C INSTRUMENTS CHANNEL 3 CIV 51' PIPE PEN OPEN 5182 PT-3300 INLET ROOT STOP 51' PIPE PEN OPEN 6557 PI-948A ISOLATION 51' PIPE PEN OPEN 6558 PT-949A ISOLATION 51' PIPE PEN OPEN 4385 PT-3300 INLET STOP 51' PIPE PEN OPEN 5181 PT-3301 INLET ROOT STOP 51' PIPE PEN OPEN 6559 PT-948B ISOLATION 51' PIPE PEN OPEN 6560 PT-949B ISOLATION 51' PIPE PEN OPEN 4387 PT-3301 INLET STOP 51' PIPE PEN OPEN 6561 PT-948C ISOLATION 51' PIPE PEN OPEN 6562 PT-949C ISOLATION 51' PIPE PEN OPEN

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SYSTEM: PRIMARY SAMPLING (9321-2745 & 227178 for HRSS)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V 956ABCDEF RCS SAMPLES ISOL VALVES CCR SNF CLOSE 956A PRESSURIZER STM SPACE SAMPLE VC 80' PAB SHUT lS. VA0 VF SENTRY PANEL 956B 80 PAB PRESSURIZER STM SPACE SAMPLE SENTRY PANEL SHUT 956C PRESSURIZER LIQUID SPACE SAMPLE 80 PAB SENTRY PANEL SHUT VC ISO VALVE 956D PRESSURIZER LIQUID SPACE SAMPLE 80 PAB VC ISO VALVE SENTRY PANEL SHUT MOV-990A RECIRC PUMPS SAMPLE TO RCS 80' PAS SAMPLE HX SENTRY PANEL SHUT MOV-990B RECIRC PUMPS SAMPLE TO RCS 80' PAB SHUT RAMPI : -k SENTRY PANEL MOV-956E RCS HOT LEG SAMPLE CONTAINMENT 80' PAS SHUT ISOLATION SENTRY PANEL MOV-956F RCS HOT LEGS 1&3 SAMPLE LINE 80' PAB SHUT ISOLATION SENTRY PANEL 956GH ACCUM SAMPLE LINE ISOL VALVES CCR SNF CLOSE 956G ACCUM'S SAMPLE VC ISO VALVE SENTRY PANEL 80' PAN SU SHUT 80' PAS 956H ACCUM'S SAMPLE VC ISO VALVE SENTRY PANEL SHUT MOV-958 RHR SAMPLE ISOLATION STOP MCC98 RooPAB SHUT 80' PAD MOV-959 RHR SAMPLE TO RCS SAMPLE HX 80' PAN SENTRY PANEL SHUT 990D RHR SAMPLE ISOLATION 959 BYPASS 68' PAB MEZZANINE SHUT MOV-5132 HRSS SAMPLE RETURN TO 80' PAB SHUT CONTAINMENT SUMP LINE ISOLATION SENTRY PANEL HRSS SAMPLE RETURN TO 80' PAB MOV-4399 CONTAINMENT SUMP LINE ISOLATION SENTRY PANEL SHUT

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SYSTEM: ISOLATION VALVE SEAL WATER (9321-2746)*

VALVE DESCRIPTION LOCATION As TEST L/U INIT AS LEFT INIT V FOUND 1435 IVSW BACKUP N2 BOTTLE STOP 80' PAB SHUT 1436 IVSW BACKUP N2 BOTTLE STOP 80' PAB SHUT 1437 IVSW PRIMARY N2 BOTTLE SUPPLY HEADER STOP 80' PAB SHUT SOV-3505 MOV-990 A&B RECIRC PUMP DISCH SAMP LINE 80' PAB SENTRY PANEL SHUT 98E PAB SOV-3500 N2 SEAL LINE 10 TO 732 RHR LOOP OUT MCC ROOM SHUT 98' PAB SOV-3506 N2 SEAL LINE 9 TO MOV-744 RHR RETURN MCC ROOM SHUT N2 SEAL LINE 60 TO MOV-888A RHR LOOP TO SI 98' PAB SOV-3507 PUMP MCC ROOM N2 SEAL LINE 60 TO MOV 888B RHR LOOP TO SI 98' PAB SOV-3508 PUMP MCC ROOM SHUT 98' PAB SOV-3509 N2 SEAL LINE 294 TO MOV 958 RHR SAMP VALVE MCC ROOM SHUT N2 SEAL LINE 337 TO MOV 1870 & 743 RHR 98' PAB SOV-3510 MINIFLOWTEST VALVE MCC ROOM SHUT GAUGE P1-1089 GAUGE REMOVED 80' PAB REMOVED 1445 N2 HDR PRESS GAUGE P1-1089 STOP 80' PAB OPEN 1442 N2 PCV-1090 PRESSURE REG INLET STOP 80' PAB SHUT 1444 N2 PCV-1090 PRESSURE REGULATOR BYPASS STOP 80' PAB SHUT 1438 N2 PRESS REG PCV-1076 INLET STOP SEAL WTR TNK 98' PAB SHUT N2 PRESS REG PCV-1076 BYPASS STOP SEAL WTR 98' PAB SHUT TNK 1441 N2 PRESS REG PCV--1076A INLET STP SEAL WTR TNK 98' PAB SHUT

Depressurize IVSW Tank and IVSW gas header per 2-OSP-10.4.1, Support Procedure - Isolation Valve Seal Water System.

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SYSTEM: ISOLATION VALVE SEAL WATER (9321-2746) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V CAP CAP FOR 1462 REMOVED 98' PAB REMOVED 1462 LOCAL TNK GASEOUS SAMPLE STOP SEAL 98' PAB OPEN WTR TNK 98' PAB SHUT 1414 FLOW CONTAMINATED HDR 1413 OUTLET STOP CONTROL VLV 1411 FLOW CONTROL VLV 1410 OUTLET STOP 98'PAB SHUT CONTAMINATED HOR 1415 FLOW CONTROL VLV BYPASS STOP 98' PAB SHUT CONTAMINATED HDR PRIMARY WATER FILL STOP SEAL WATER 98'PAB SHUT TANK 1453 CITY WATER FILL STOP SEAL WATER TANK 98' PAB SHUT 5625 CLEAN HDR INLET STOP CLEAN HDR AUTO 98' PAB SHUT SEAL WTR HDR'S 1400 SUPPLY STOP MANUAL SEAL WTR HDR 98' PAB SHUT

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SYSTEM: SERVICE WATER (209762)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V FAN 21 COIL INBOARD INLET 98'PAB MOV-SWN-41-1A VALVE M ROOMSHUT FAN 21 COIL INBOARD 98'PAB MOV-SWN-44-1A DISCHARGE VALVE MCC ROOM SHUT 21CRF MOTOR COOLER 98'PAB MOV-SWN-71-1A DISCHARGE ISOLATION VLV MCC SHUT FROM FCU-21 FAN 22 COIL INBOARD INLET 98'PAB MOV-SWN-41-2A VALVE MC ROOMSHUT MOV-SWN-44-2A FAN 22 COIL VALVE DISCHARGE INBOARD 98'PAB SHUT MCC ROOM 22CRF MOTOR COOLER 98PAB MOV-SWN-71-2A DISCHARGE ISOLATION VLV MCC ROOM SHUT FROM FCU-22 FAN 23 COIL INBOARD INLET 98'PAB SHUT MOV-SWN-41-3A VALVE MCC ROOM MOV-SWN-44-3A FAN 23 COIL INBOARD 98'PAB DISCHARGE VALVE MCC ROOM SHUT 23CRF MOTOR COOLER 98'PAB SHUT MOV-SWN-71-3A DISCHARGE ISOLATION VLV MCC ROOM FROM FCU-23 MOV-SWN-41-4A FAN 24 COIL INBOARD INLET 98'PAB SHUT VALVE MCC ROOM MOV-SWN-44-4A FAN 24 COIL INBOARD 98'PAB SHUT DISCHARGE VALVE MCC ROOM

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SYSTEM: SERVICE WATER (209762) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V 24CRF MOTOR COOLER 98'PAB MOV-SWN-71-4A DISCHARGE ISOLATION VLV MCC ROOM SHUT FROM FCU-24 MOV-SWN-41-5A FAN 25 COIL INBOARD INLET 98'PAB SHUT VALVE MCC ROOM MOV-SWN-44-5A FAN 25 COIL INBOARD 98'PAB SHUT DISCHARGE VALVE MCC ROOM 25CRF MOTOR COOLER 98'PAB MOV-SWN-71-5A DISCHARGE ISOLATION VLV MCC ROOM SHUT FROM FCU-25 SWN-43-1 21 FCU SUPPLY DRAIN STOP 51' PIPE PEN SHUT SWN-638 FCU-21 INLET VENT STOP 51' PIPE PEN SHUT SWN-43-2 22 FCU SUPPLY DRAIN STOP 51' PIPE PEN SHUT SWN-641 FCU-22 INLET VENT STOP 51' PIPE PEN SHUT SWN-43-3 23 FCU SUPPLY DRAIN STOP 51' PIPE PEN SHUT SWN-639 FCU-23 INLET VENT STOP 51' PIPE PEN SHUT SWN-43-4 24 FCU SUPPLY DRAIN STOP 51' PIPE PEN SHUT SWN-640 FCU-24 INLET VENT STOP 51' PIPE PEN SHUT SWN-43-5 25 FCU SUPPLY DRAIN STOP 51' PIPE PEN SHUT SWN-642 FCU 25 INLET VENT STOP 51' PIPE PEN SHUT

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SYSTEM: STEAM GENERATOR BLOWDOWN 9321-2729, 9321-2723)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V PCV-1214 21 SG ISOL VLV 1 CCRSCF CLOSE PCV-1214A 21 SG ISOL VLV 2 CCR SCF CLOSE PCV-1215 22 SG ISOL VLV 1 CCR SCF CLOSE PCV-1215A 22 SG ISOL VLV 2 CCR SCF CLOSE PCV-1216 23 SG ISOL VLV 1 CCR SCF CLOSE PCV-1216A 23 SG ISOL VLV 2 CCR SCF CLOSE PCV-1217 24 SG ISOL VLV 1 CCR SCF CLOSE PCV-1217A 24 SG ISOL VLV 2 CCR SCF CLOSE SGN-5 S/G 22 HDR QUICK CLOSE N2 80' PAB SHUT SPARGING SGN-6 S/G 21 HDR QUICK CLOSE N2 80' PAB SHUT SPARGING SGN-7 S/G 23 HDR QUICK CLOSE N2 80' PAB SHUT SPARGING SGN-8 S/G 24 HDR QUICK CLOSE N2 80' PAB SHUT SPARGING

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SYSTEM: AUXILIARY COOLANT (9321-2720 & 227781)

TEST VALVE DESCRIPTION LOCATION AS FOUND INIT AS LEFT INIT V L/U MOV-769 ISOL VLV RCPS-CLG INLET PHASE B CCR SNF CLOSE MOV-797 MOV-7841 RCP BEARING DISCH ISOL LVL PHASE B CCR SNF CLOSE MOV-786 MOV-625 / ISOL VALVES RCP THERM BARRIER DISCH CCR SNF CLOSE MOV-789 PHASE B 791 1798 EX LETDOWN HX INLET CCW ISOL VALVES CCR SNF CLOSE 793/ 796 EX LETDOWN HX OUTLET CCW ISOL VALVES CCR SNF CLOSE 753H AUX CCW PUMPS TO RECIRC. PUMPS HOR STOP 51' PIPE PEN SHUT 753G RECIRC. PUMPS RETURN HDR STOP 51' PIPE PEN SHUT A-500 EXCESS LETDOWN HX CCW INLET VENT STOP 51' PIPE PEN SHUT A-501 EXCESS LETDOWN HX CCW OUTLET VENT STOP 51' PIPE PEN SHUT NOTE: Penetrations J-9 (Residual Heat Removal Return), Penetration K-10 (Residual Heat Removal Loop Out), KK-53 (Residual Heat Removal Heat Exchanger Cooling Water In), JJ-52 (Residual Heat Removal Cooling Water Return) are lined up for shutdown cooling per Operations department procedures.

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SYSTEM: BOILER FEEDWATER (9321-2019 and 9321-20 8)

VALVE DESCRIPTION LOCATION AS FOUND TEST INIT AS LEFT INIT V LIU BFD-1130 21 STEAM GENERATOR WET LAY UP 32'ABFP BLDG SHUT ISOLATION VALVE BFD-7 FCV-417 OUTLET STOP 43'ABFP BLDG SHUT FCV-405A AUX BFP 22 DISCH TO STM GEN 21 CCR SCF SHUT FCV-406A AUX BFP 21 DISCH TO STM GEN 21 CCR SCF SHUT BFD-1132 22 STEAM GENERATOR WET LAY UP 32' ABFP BLDG SHUT ISOLATION VALVE BFD-7-1 FCV-427 OUTLET STOP 43' ABFP BLDG SHUT FCV-405B AUX BFP-22 DISCH TO STM GEN 22 CCR SCF SHUT FCV-406B AUX BFP 21 DISCH TO STM GEN 22 CCR SCF SHUT BFD-1134 23 STEAM GENERATOR WET LAY UP 32' ABFP BLDG SHUT ISOLATION VALVE BFD-7-2 FCV-437 OUTLET STOP 43' ABFP BLDG SHUT FCV-405C AUX BFP-22 DISCH TO STM GEN 23 CCR SOF SHUT FCV-406C AUX BFP-23 DISCH TO STM GEN-23 CCR SCF SHUT BFD-1 136 24 STEAM GENERATOR WET LAY UP 32'ABFP BLDG SHUT ISOLATION VALVE BFD-7-3 FCV-447 OUTLET STOP 43' ABFP BLDG SHUT FCV-405D AUX BFP-22 DISCH TO STM GEN 24 CCR SCF SHUT FCV-406D AUX BFP-23 DISCH TO STM GEN-24 CCR SCF SHUT

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SYSTEM: PRIMARY MAKEUP WATER (9321-2724)

SYSTEM: AUXILIARY STEAM SUPPLY (9321-2027)

VALVE DESCRIPTION UH-43 AUX STEAM TO VC STOP AUX CONDENSATE FROM VC UH-44 STOP SYSTEM: CITY WATER (9321-2018)

VALVE DESCRIPTION MW-17 CITY WATER TO VC STOP MW-17-1 JCITYWATER TO VC STOP

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SYSTEM: N2 to NUCLEAR EQUIPMENT (9321-2719, 9321-2723, 9321-2738, 235306, 235296)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V 181i1A ACCUMULATOR (NORTH BANK) N2 SUPPLY ROOT STOP 80' PAB SHUT ACCUMULATOR N2 SUPPLY ROOT STOP 80' PAB SHUT (SOUTH BANK) 1809 SI ACCUMULATOR BACKUP N2 REGULATOR 80' PAR SHUT PCV-7726 OUTLET STOP 1655 N2 INLET STOP TO PCV-473 TO PRT 51' PIPE PEN SHUT 1659 N2 INLET STOP TO PCV-1014 TO RCOT 51' PIPE PEN SHUT 1699 SRST N2 TO BOTTOM INLET STOP 80'PAN SRST SHUT PANEL 1692 SRST N2 TO TOP INLET STOP 80'PAB SRST SHUT PANEL This system continued on the next page.

This nitrogen system lineup SHALL be completed PRIOR to pressurization.

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SYSTEM: N2 to NUCLEAR EQUIPMENT (9321-2719, 9321-2723, 9321-2738, 235306, 235296) (Continue VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V 4314 N2 SUPPLY HEADER VENT STOP 46'VC SHUT

FLANGE REMOVE FLANGE DOWNSTREAM OF 46'VC REMOVED 4315

4315 N2 SUPPLY HEADER VENT STOP 46' VC OPEN N2 TO SIS ACCUMULATORS 46' VC OPEN

'4313 ANDSUPPLY PORV ACCUMULATORS STOP 4109 N2 SUPPLY STOP TO PCV-455C AND 46'VC OPEN PCV-456

4117 N2 STOP TO PCV-455C ACCUM 95'VC OPEN

.FLANGE DOWNSTREAM OF 4118 95' VC REMOVED

4118 PCV-455C N2 ACCUM VENT STOP 95' VC OPEN CAP REMOVE CAP DOWNSTREAM OF 4120 95' VC REMOVED 4120 PCV-455C ACCUM DRAIN STOP 95' VC OPEN CAP REMOVE CAP DOWNSTREAM OF 4113 95' VC REMOVED 4113 PCV-456 ACCUM DRAIN STOP 95' VC OPEN

These valves will vent most of the nitrogen pressure in the VC and PAB. This will be part of the SIS Accumulator protection.

This system continued on the next page.

This nitrogen system lineup SHALL be completed PRIOR to pressurization.

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SYSTEM: N2 to NUCLEAR EQUIPMENT (9321-2719, 9321-2723, 9321-2738, 235306, 235296) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST UJU INIT AS LEFT INIT V PCV-863 ISOL VALVE ACCUMULATOR CGR SMF CLOSE NITROGEN SUPPLY LINE N-783 PI-942-2 STOP 80' PAB OPEN CAP REMOVE CAP DOWNSTREAM 80'PAB REMOVED OF N-784 N-784 PI-942-2 TEST STOP 80' PAB OPEN SOV-3416 NITROGEN SUPPLY TO RCDT 98' PASHUT MCC ROOM SOV-3417 NITROGEN SUPPLY TO RCDT 98' PABR SU IMCC ROOM 98' PAB SOV-3418 NITROGEN SUPPLY TO PRT M MCC ROOM MSHUT SU 98' PAB SOV-3419 NITROGEN SUPPLY TO PRT C MCC ROOM MSHUT SU SOV-3405 N2 PURGE VALVE FOR PRT 98' PAB SHUT MCC ROOM 98' PAB SOV-3406 N2 PURGE VALVE FOR RCDT MCC ROOM SHUT 4831 SOV-3406 BYPASS STOP 72' FAN HOUSE SHUT 4834 SOV-3405 BYPASS STOP 72' FAN HOUSE SHUT This system continued on the next page.

This nitrogen system lineup SHALL be completed PRIOR to pressurization.

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SYSTEM: N2 to NUCLEAR EQUIPMENT (9321-2719, 9321-2723, 9321-2738, 235306, 235296) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V 1610 RCDT NITROGEN ISO STOP 51' PIPE PEN OPEN 5491 RCDT NITROGEN TEST STOP 51' PIPE PEN SHUT 5458 NITROGEN STOP FROM VALVE SOV-3417 51' PIPE PEN OPEN RCDT NITROGEN SUPPLY LINE CIV 51'PIPE PEN SHUT BYPASS 5460 SOV-341613417 INLET STOP 51' PIPE PEN OPEN 1610-1 NITROGEN TEST VENT CONNECTION 51' PIPE PEN SHUT VENT BREAK SWAGELOCK CONNECTION 51'PIPE PEN DISCONNECTED DOWNSTREAM OF PCV-1014 550 NITROGEN ISOLATION VALVE TO PRT 51' PIPE PEN OPEN 4161 NITROGEN SUPPLY TO PRT TEST STOP 51' PIPE PEN SHUT 4137 SUPPLY PRT OUTLET 51'PIPE PEN OPEN NITROGEN FROM SOV-3418 ANDTOSOV-3419 4136 SUPPLY PRT BYPASS 51' PIPE PEN SHUT NITROGEN FROM SOV-3418 ANDTOSOV-3419 4135 NITROGEN SUPPLY TO PRT INLET TO 51'PIPE PEN OPEN SOV-3418 AND SOV-3419 CAP CAP FOR 4160 51' PIPE PEN REMOVED 4160 NITROGEN SUPPLY TO PRT TEST STOP 51' PIPE PEN OPEN This nitrogen system lineup SHALL be completed PRIOR to pressurization.

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SYSTEM: REACTOR COOLANT (9321-2738 & 9321-2719)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V PCV-455C PRESSURIZER PORV TRAIN-B CCR FBF BLOCKED OPEN MOV-535 PRESSURIZER RELIEF LINE TRAIN B CCR FBF OPEN BLOCK VALVE BLOCKED PCV-456 PRESSURIZER PORV TRAIN-A CCR FBF OPEN OPEN MOV-536 PRESSURIZER RELIEF LINE TRAIN A CCR FBF OPEN BLOCK VALVE 5481549 PRT GAS ANALYZER ISOL VLV CCR SNF SHUT SA-501 PRT EXHAUSTER SA INLET STOP 95' VC SHUT 500-1 PRT N2 TEST STOP 46' VC SHUT EDUCTOR EDUCTOR NEEDLE VALVE 95' VC OPEN 4401 PRESSURIZER RELIEF TANK INLET TO 95' VC OPEN EDUCTOR 528 PRT N2 INLET STOP 46' VC OPEN 4178 RCS DRAINDOWN LEVEL INDICATOR 95'VC OPEN TYGON HOSE UPPER STOP CAP CAP DOWNSTREAM OF RCS-6021 130' VC REMOVED RCS-6021 REACTOR COLD SHUTDOWN LEVEL 130' VC OPEN TEST VALVE 4" FLANGE 4" VACUUM FILL CONNECTION FLANGE 95' VC REMOVED 580A OLD DEADWEIGHT TESTER ISOLATION 51' PIPE PEN SHUT

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SYSTEM: RADIATION MONITORING AIR SAMPLE (238106 VALVE DESCRIPTION LOCATION AS FOUND TEST LJU INIT AS LEFT INIT V

°1A-1782 IA TO SOV-1536 51' PIPE PEN SHUT PETCOCK PCV-1236 REGULATOR PETCOCK 51' PIPE PEN OPEN 1A-1781 IA TO SOV-1537 51' PIPE PEN SHUT PETCOCK PCV-1237 REGULATOR PETCOCK 51' PIPE PEN OPEN RAS-522 R-41 SAMPLE INLET ROOT STOP 51' PIPE PEN OPEN RAS-521 R-41/R-42 INLET ROOT STOP 51' PIPE PEN SHUT RAS-523 R-41/42 SAMPLE OUT TO VC VENT STOP 51' PIPE PEN OPEN RAS-524 R-411R-42 OUTLET ROOT STOP 51' PIPE PEN SHUT CAP CAP FOR RAS-559 68' MEZZ REMOVED

.RAS-559 R-41142 SAMPLE OUT TO VC VENT STOP 68' MEZZ SHUT CAP CAP FOR RAS-558 68' MEZZ REMOVED

- RAS-558 R-41/42 SAMPLESTOP IN FROM VC VENT 68'MEZZ OPEN

- - PCV-1236, CNTMT RAD MON ISOL VALVES CCR SNF CLOSE 1237, 1234, 12351

RAS-559 to be used as Test Flow connection. See Attachment 6, Containment Building Leak Rate Test System Leak Rate Testing for further operation.

- These valves will be manipulated as a contingency IF test taps are required by ILRT coordinator OR Chemistry.

Inform Test Supervisor PRIOR to use.

- - ENSURE PCV-1236 and PCV-1237 remain CLOSED unless needed for contingency in ** above.

Inform Test Supervisor IF OPENED during test.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 95 of 208 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS (Page 7 of 11)

SYSTEM: INSTRUMENT AIR (242688 [inside VC], 9321-2036 [out ide VCJ)

VALVE DESCRIPTION LOCATION AS FOUND TEST L/U INIT AS LEFT INIT V

PCV-1228 INSTRUMENT AIR ISOL VLV CCR SNF CLOSE

1A-501 IA CONTAINMENT STOP 51' PIPE PEN SHUT

CAP REMOVE CAP DOWNSTREAM 51'PIPE PEN REMOVED OF IA-503

1A-503 IA TEST STOP 51' PIPE PEN OPEN

IA-502 IA TEST STOP 51' PIPE PEN SHUT

°IA-500 IA CONTAINMENT STOP 51' PIPE PEN OPEN

CAP REMOVE CAP DOWNSTREAM 46'VC REMOVED OF IA-1441 I.A. TO V.C. RING HEADER

1A-1441 TEST CONNECTION 46' VC OPEN ISOLATION

Refer to Attachment 19, VC AOV Failure Position List for valve failure positions.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 96 of 208 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS (Page 8 of 11)

SYSTEM: PENETRATION AND LINER WELD JOINT CHANNEL PRESSURIZATION SYSTEM (9321-2726)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V

PCV-1110-5 ZONE 2 N2 BACKUP SUPPLY 80 PAB SHUT REGULATOR INLET STOP

PCV-1 110-24 PCV-1 195 INLET STOP 80' PAB SHUT

PCV-1110-25 PCV-1195 OUTLET STOP 80' PAB SHUT "PCV-1101-2 PCV-1195 BYPASS STOP 80' PAB SHUT REMOVE CAP DOWNSTREAM 80' PAB REMOVED OF WCP-103

WCP-103 TEST CONNECTION 80'PAB OPEN NORMAL SUPPLY ZONE 2 Secure Zone 2 using 2-SOP-1 0.5.1, Weld Channel and Containment Penetration Pressurization System Operation Individual Zone Depressurization Section.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 97 of 208 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS (Page 9 of 11)

SYSTEM: PENETRATION AND LINER WELD JOINT CHANNEL PRESSURIZATION SYSTEM (9321-2726) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST UU INIT AS LEFT INIT V WCP-90 WCCPP SUPPLY TO 95' AIRLOCK 95' MOB SHUT ISOLATION WCCPP SUPPLY TO 80' AIRLOCK 80' PAB SHUT WCP-83 ISOLATION WCCPP SUPPLY ISOLATION TO VC 80' PURGE SHUT PCV-1110-3 PURGE SUPPLY VALVES ENCLOSURE

CAP CAP DOWNSTREAM OF WCP-1 19 80' PAB NA INCP-119 ZONE 2 NORMAL SUPPLY TEST 80' PAB NA CONNECTION STOP

CAP CAP DOWNSTREAM OF WCP-1 18 80' PAB NA

WCP-118 ZONE 2 NORMAL SUPPLY TEST 80' PAB NA CONNECTION STOP PCV-1 110-4 WCCPP SUPPLY ISOLATION TO VC 80' PURGE SHUT PURGE EXHAUST VALVES ENCLOSURE

Use vents as necessary to vent valve interspaces WHEN associated CIV's are shut AND WCCPP isolations are shut.

- WCP-1 19 and WCP-1 18 to be used in Attachment 17, Gauge Installation / Removal Sheet for test pressure taps.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 98 of 208 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS (Page 10 of 11)

SYSTEM: PENETRATION AND LINER WELD JOINT CHANNEL PRESSURIZATION SYSTEM (9321-2726) (Continued)

VALVE DESCRIPTION LOCATION AS FOUND TEST LIU INIT AS LEFT INIT V WCCPP SUPPLY ISOLATION TO PCV-1110-8 PRESSURE RELIEF LINE BETWEEN 51' PIPE PEN SHUT PCV-1190 AND PCV-1191 WCCPP SUPPLY ISOLATION TO PCV-1110-7 PRESSURE RELIEF LINE BETWEEN 51' PIPE PEN SHUT PCV-1191 AND PCV-1 192

CAP CAP DOWNSTREAM OF WCP-1 17 51' PIPE PEN INSTALLED WCP-117 TEST VALVECONNECTION ISOLATION 51' PIPE PEN SHUT

'CAP CAP DOWNSTREAM OF WCP-82 51' PIPE PEN INSTALLED

WCP-82 TEST CONNECTION STOP 51' PIPE PEN SHUT

Use vents as necessary to vent valve interspaces WHEN associated CIV's are shut AND WCCPP isolations are shut.

- WCP-1 19 and WCP-1 18 to be used in Attachment 17, Gauge Installation / Removal Sheet for test pressure taps.

No:2-1T-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 99 of 208 ATTACHMENT 3C ILRT SPECIAL VALVE LINEUPS (Page 11 of 11)

NOTES: Depressurize the following valve interspaces:

Containment Purge Supply (FCV-1170 & FCV-1171)

° Containment Purge Exhaust (FCV-1172 & FCV-1173)

Pressure Relief (PCV-1190 & PCV-1191; PCV-1191 & PCV-1192)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 100 of 208 ATTACHMENT 3D SUPPLEMENTARY ILRT VALVE LINEUPS (Page 1 of 1)

SYSTEM:

AS VALVE DESCRIPTION LOCATION FOUND TEST L/U INIT AS LEFT INIT V Use this form to document additional lineups. Make additional copies as needed.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 101 of 208 ATTACHMENT 3E BREAKER LIST (Page 1 of 4)

AS TEST L/U INIT AS LEFT INIT V FOUND CCR CONTROL SWITCHES 21 RCP PULLOUT 22 RCP PULLOUT 23 RCP PULLOUT 24 RCP PULLOUT 21 SAFETY INJECTION PUMP PULLOUT 22 SAFETY INJECTION PUMP 2A PULLOUT 22 SAFETY INJECTION PUMP 3A PULLOUT 23 SAFETY INJECTION PUMP PULLOUT 21 CONTAINMENT SPRAY PULLOUT 22 CONTAINMENT SPRAY PULLOUT 21 RECIRCULATION PUMP PULLOUT 22 RECIRCULATION PUMP PULLOUT 21 FAN COOLER UNIT PULLOUT 22 FAN COOLER UNIT PULLOUT 23 FAN COOLER UNIT PULLOUT 24 FAN COOLER UNIT PULLOUT 25 FAN COOLER UNIT PULLOUT PZR MODULATING HEATERS PULLOUT 21 BACKUP HEATER GROUP OFF 22 BACKUP HEATER GROUP OFF 23 BACKUP HEATER GROUP OFF 21 CHARGING PUMP PULLOUT 22 CHARGING PUMP PULLOUT 23 CHARGING PUMP PULLOUT

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 102 of 208 ATTACHMENT 3E BREAKER LIST (Page 2 of 4)

AS FOUND TEST L/U INIT AS LEFT INIT V 6900 VOLTS RCP #21 BUS 1 RACKED OUT RCP #22 BUS 4 RACKED OUT RCP #23 BUS 3 RACKED OUT RCP #24 BUS 2 RACKED OUT 480 VOLTS BUS 5A RACKED 21 SAFETY INJECTION PUMP RACKED OUT/TEST 21 CONTAINMENT SPRAY RACKED PUMP OUT/TEST RACKED 21 FAN COOLER UNIT OUT/TEST RACKED 23 BACKUP HEATERS OUT/TEST MCC 28 RACKED OUT/TEST 22 FAN COOLER UNIT RACKED OUT/TEST 480 VOLTS BUS 2A MCC 28A RACKED OUT/TEST RACKED 22 BACKUP HEATERS OUT/TEST 22 SAFETY INJECTION PUMP RACKED IN RACKED 23 FAN COOLER UNIT OUT/TEST

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 103 of 208 ATTACHMENT 3E BREAKER LIST (Page 3 of 4)

AS FOUND I TEST LIU INIT AS LEFT INIT V 480 VOLTS BUS 3A RACKED 24 FAN COOLER UNIT OUT/TEST RACKED 21 BACKUP HEATER GROUP OUTKES OUT/TEST RACKED 22 SAFETY INJECTION PUMP OUTKES OUT/TEST 480 VOLTS BUS 6A PZR MODULATING HEATERS RACKED OUT/TEST RACKED 23 SAFETY INJECTION PUMP OUT/TEST RACKED 25 FAN COOLER UNIT OUT/TEST 22 CONTAINMENT SPRAY RACKED PUMP OUT/TEST MCC 27 CB PRESS RELIEF FAN [3MR] OFF CB PURGE SUPPLY FAN [2E] OFF ACCUMULATOR TOPPING OFF PUMP [3E]

MCC 26A 21 AUX COMP COOLING OFF PUMP [6KR]

MCC 26B 22 AUX COMP COOLING OFF PUMP [5KR]

ELECTRICAL PENETRATION AREA DURALINE KNIFE SWITCHES EDX 27 OFF EDX 28 OFF EDX 29 OFF EDX 30 OFF EDX 31 OFF EDX 32 OFF

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 104 of 208 ATTACHMENT 3E BREAKER LIST (Page 4 of 4)

AS jTEST IAS LIGHTING FU FOUND LEU LIU INITIALS A LEFT INITIALS V

LP #215 OFF CKTS 1-14, 16-28, 30, 31, 33, 36

LP #216 CKTS 1-14, 16, 19, 21-24, 27, 29, OFF 30, 31, 33, 36

LP #217 MAIN DISCONNECT OFF

LP #218 MAIN DISCONNECT OFF

LP #221 MAIN DISCONNECT OFF

IF VC entry is required, THEN operate breaker(s) in accordance with OAP-007, Containment Entry and Egress.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 105 of 208 ATTACHMENT 3F LEAK DETECTION DEVICE TRACKING SHEET (Page 1 of 1)

Use this form to document additional lineups. Make additional copies as needed.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 106 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 1 of 9) 1.0 EQUIPMENT RECORD Much of the pressurization system equipment will be rented for the ILRT. The contract with the vendor provides for supplying 21,000 cfm capacity, and the necessary equipment to dry and cool the air. The exact number and types of components supplied by the vendor to meet these requirements may vary. The major components of the pressurization system are described below. Record actual equipment used:

No. Req'd No. Used Description Air Compressor - Portable Engine Driven Screw Type, Capacity of 1500 scfm, 100% oil free, 100 psi. Total capacity: 22,500 cfm.

Air Dryer - desiccant, -40OF dewpoint out, approx. capacity of 4 5,400 cfm. Individual capacities (and number provided) may vary to support total capacity.

3" bull hoses - 50' long - to inter-connect the compressors, after coolers, air dryers and supply manifolds 3" bull hoses - 25' long - to inter-connect the compressors, after As required coolers, air dryers and supply manifolds Connection manifolds - to connect air supply via 3" bull hoses 3 to containment/Leak rate system piping.

(6" 150 lb flange pattern line)

Miscellaneous:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 107 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATIONIDEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 2 of 9) 2.0 POWER REQUIREMENTS Temporary electrical power must be supplied to the pressurization system components.

The types, quantities and ultimate toad will vary based on the weather conditions expected during the test, test preparation periods and the actual equipment supplied by the vendor. The table below lists typical requirements. Mark the table up to reflect actual requirements as needed.

Load Component DescriptionlNeed Quantity Voltage (Amps) Total Amps Airng(nempsc Cmpresors; Air Compressors; engine block 2/unit x 15 120 vac 15 ea 15x2x15 = 450 heaters (temp. < 500 F)

Spare Compressor 2/unit x 1 120 vac 15 ea 30 Miscellaneous:

Security light strings 16 120 vac 15 240

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 108 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATIONIDEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 3 of 9) 3.0 PRESSURIZATION SYSTEM INSTALLATION

3.1 TIMELINE

Delivery, security inspection, transport into protected area, 1 day (Start of pressurization -3 days)

" Set-up and check out pressurization system, connect to plant piping, 1 day (Start of pressurization -2 days)

" Resolve any compressor or component performance issues, perform flush/checkout if NOT previously completed (Start of pressurization -1 days)

Compressor vendor Operator/mechanic support of pressurization (Start of pressurization -2 hrs + pressurization cycle, 8-12 hrs)

" Refuel Compressors (Start of pressurization + 6hrs). Refueling can be performed while operating. Top off at end of pressurization.

Vent manifold line and/or compressor bull hoses, release Vendor operator (End of Pressurization, beginning of Stabilization Phase)

" Plant personnel monitor pressurization line for leaks.

(Through Stabilization Phase)

" Breakdown pressurization equipment - air dryers, compressors, chiller (if used),

hose bibs to manifold (End of Verification Test). Schedule vendor pickup.

" Disconnect rented manifold from plant piping (End of Depressurization)

" Remove equipment from site, stage to parking lot, load onto vendor's flatbeds, ship (End of Depressurization + 1 day)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 109 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 4 of 9) 4.0 PRESSURIZATION SYSTEM CHECKOUTILINE FLUSH 4.1 TEST EQUIPMENT 4.1.1 Fine mesh cloth for cleanliness check may be used during blowing lines out prior to installation.

4.2 PROCEDURE Initials 4.2.1 Rented portions of Pressurization System are connected to each other per ILRT Test Supervisor's directions to the manifolds.

4.2.2 VERIFY air vendor has inspected lines for absence of foreign material, debris and oil.

4.2.3 CLOSE the following WCCPP valves:

PCV-1101-U U A, RACK 11 PIPING PENETRATION U U PI-1189-UU STOP

PCV-1101-U U B, RACK 11 PIPING PENETRATION U U AIR SUPPLY STOP

PCV-1101-V VA, RACK 11 PIPING PENETRATION V V PI-1189-V V STOP

PCV-1101-VV B, RACK 11 PIPING PENETRATION V V AIR SUPPLY STOP 4.2.4 DIRECT Maintenance Department to install penetration manifold(s) to penetration "U U" and "V V". ENSURE manifold penetration(s) have required isolation valves to accept ample 3" supply hoses. (Leave flanges ON inside the Containment Building).

4.2.5 VERIFY 3" valves upstream of penetration "U U" and "V V' have been bench tested for leak tightness OR PERFORM a leak test of each valve after installation.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 110 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 5 of 9)

Initials 4.2.6 DIRECT Maintenace Department to install 3" hoses from the manifold(s) in the yard to the 3" valves on the penetration manifold(s) in the pipe pen area at U U and V V. This will completely connect pressurization line from compressors to VC.

4.2.7 Label air hoses in PAB to respective 3" isolation valve on either end to facilitate repairs to hose leaks easier during pressurization.

4.2.8 PERFORM the following to verify pressurization line integrity:

4.2.8.1 ALIGN system piping to pressurize system from compressors to VC penetration flanges to allow leak checks.

CAUTION PRIOR to pressurizing supply lines, remove all personnel from area with signs posted and area roped off.

4.2.8.2 START one diesel air compressor.

4.2.8.3 SLOWLY RAISE pressure in system to 50 psig.

4.2.8.4 HOLD pressure for ten (10) minutes (or as required to complete walkdown/leak checks).

4.2.8.5 INSPECT each connection for leakage.

IF required, REPAIR any leakage AND retest.

4.2.8.6 WHEN pressurization system has been verified to be leak free, THEN DIRECT ILRT Vendor to DEPRESSURIZE lines through available vent paths.

4.2.8.7 SECURE the compressors used for leak check.

No:2-PT-10Y001 Rev:02 RATE TEST INTEGRATED LEAK Page 111 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATIONIDEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 6 of 9)

Initials 4.2.9. Place pressurization system in Pressurization System Standby lineup described in Table 1 of this Attachment.

4.2.9.1 START each individual compressor one at a time to verify operability. It is NOT necessary to load compressors.

4.2.9.2 SECURE the compressors.

4.2.9.3 FILL compressors with fuel as necessary to be prepared for the ILRT.

4.2.10 ENSURE the following isolation valves are CLOSED:

Valve Description Position Initials V U U-1 U U Penetration Stop CLOSED U U-2 U U Penetration Stop CLOSED U U-3 U U Penetration Stop CLOSED U U-4 U U Penetration Stop CLOSED U U-5 U U Penetration Stop CLOSED V V-1 V V Penetration Stop CLOSED V V-2 VV Penetration Stop CLOSED V V-3 VV Penetration Stop CLOSED V V-4 VV Penetration Stop CLOSED V V-5 VV Penetration Stop CLOSED 4.2.11 DIRECT Maintenance to slowly REMOVE flanges from containment side of penetrations "U U" and "V V".

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 112 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 7 of 9)

Initials 5.0 PRESSURIZATION SYSTEM OPERATION 5.1 During ILRT rented portions of pressurization system will be operated by vendor-supplied personnel. These personnel will take direction from the ILRT Test Supervisor OR his designee.

5.2 WHEN directed by ILRT Test Supervisor, OR his designee THEN lineup pressurization system to pressurize containment per "Pressurization of Vapor Containment" line of Table 1.

5.3 As VC pressure rises, SECURE compressors/pressurization system as directed by the ILRT Test Supervisor OR his designee.

5.4 FILL air compressors fuel tanks before return to vendor (compressors are to be returned with the same fuel level as received or there will be an additional refueling charge).

6.0 PRESSURIZATION SYSTEM RESTORATION 6.1 WHEN directed by ILRT Test Supervisor, THEN various components of pressurization system may be disconnected from each other, and from pressurization system manifold (e.g. dryers, compressors, aftercoolers, chiller, etc. as applicable).

6.2 Pressurization system manifold may NOT be removed until directed by ILRT Test Supervisor.

6.3 Rented portions of pressurization system will be disconnected, prepared for shipment and moved to a staging area outside Protected Area for pickup by vendor's freight carrier.

6.4 OPEN the following WCCPP valves:

" PCV-1 101-U U A, RACK 11 PIPING PENETRATION U U PI-1189-UU STOP

" PCV-1101-U U B, RACK 11 PIPING PENETRATION U U AIR SUPPLY STOP

" PCV-1101-VVA, RACK 11 PIPING PENETRATION V V PI-1 189-V V STOP

" PCV-1101-VV B, RACK 11 PIPING PENETRATION VVAIR SUPPLY STOP

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 113 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 8 of 9)

OPENED and CLOSED as directed by the ILRT Test Coordinator U,

E0 Ea) oo 0) m3. EW .>. . .

U) .0" l )-

U) 0 > 0c 0 TABLE110 00-_ c o > >> -o0 PRESSURIZATION .2 SYSTEM ALIGNMENT C - ý5Z > oLa .U E CO >

0 Pressurization System Standby OFF Installed Closed OFF Closed Closed Closed Closed Closed Pressurization of Vapor Containment ON Installed Open ON 0' 0. 0 C. C.

Containment at Pressure OFF Installed Closed OFF Closed Closed Closed 0/C* O/C*

During ILRT' OFF Installed Closed OFF Closed Open Closed O/C* O/C*

During Verification Test OFF Installed Closed OFF Closed Open Closed Closed Closed During Depressurization Removed Removed Open OFF Closed Throt Throt Closed Closed

__________________________________Open Open

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 114 of 208 ATTACHMENT 4 CONTAINMENT BUILDING PRESSURIZATION/DEPRESSURIZATION SYSTEM INSTALLATION AND CHECKOUT (Page 9 of 9)

FIGURE 1: PRESSURIZATION SYSTEM LAYOUT PLAN (TYPICAL) 4 4.

L I j 1 2F . 4I0

' I sw I r I li&

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 115 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 1 of 19) 1.0 SPECIAL EQUIPMENT ANDIOR INSTRUMENTATION REQUIREMENTS 1.1 The following instrumentation or equivalent are required for the Integrated Leak Rate Test and are recently calibrated (within 6 months of test or in accordance with the plant's Test Equipment program) and the calibration dates are properly documented in this Appendix.

1.1.1 Absolute Pressure Quantity 2 Manufacturer Paroscientific Inc.

Type Precision pressure gauge Model 760-100A with Direct Pressure Readout and RS-232 Range 0 to 100 psia Accuracy +/- 0.020% Full Scale (+ 0.02 psia)

Repeatability +/- 0.005% Full Scale (+ 0.005 psia)

Resolution 0.0001 psi 1.1.2 Drybulb Temperature Quantity 30 Manufacturer Graftel Type Model 9202 Thermistors Range 50 to 1501F Accuracy +- 2.0°F Repeatability +/- 0.01°F Resolution + / - 0.001°F

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 116 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 2 of 19) 1.1.3 Relative Humidity Quantity 10 Manufacturer Graftel Type Model 9203 Relative Humidity Sensors (Temperature compensated bulk polymer chip)

Range 10 - 90% RH Accuracy + /-3.5% RH Repeatability + /-0.10% RH 1.1.4 Verification Flow Quantity 2 (1 primary, 1 backup)

Manufacturer Brooks Type Mechanical tube and float Range 1 to 10 scfm Accuracy +/- 2% full scale Repeatability +/ - 0.2% full scale

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 117 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 3 of 19) 1.1.5 Ambient Pressure Quantity 1 Manufacturer Bell & Howell (or equivalent)

Type CEC-402 (Strain Gauge)

Range 0 to 25 psia Accuracy +/- 0.25% full scale Repeatability + / - 0.1% full scale 2.0 GENERAL 2.1 Sensors should be located in the middle of the air volume they are monitoring, away from structural steel and other heat sources or sinks wherever possible, to minimize thermal lag.

Drybulb Temperature Sensors = 30 Dewcells or Humidity Sensors = 10 Precision Pressure Sensors = 2 Flow Meters = 1 with 1 backup Visalla hand held hygrometer = 1 Sensor locations are described in Section 6.0 of this Attachment.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 118 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 4 of 19) 3.0 SENSOR REJECTION INSTRUCTIONS NOTE Raw sensor data on functionally dependent parameters such as temperature, pressure and humidity should NOT be rejected solely based on statistical rejection techniques. Rather, sensor data may be rejected and NOT used in final calculation of air mass provided a good physical reason exists, such as loss of instrument power or erratic signal.

3.1 IF a sensor is rejected during the Type A test, THEN:

3.1.1 Which Sensor(s) rejected and cause SHALL be recorded in log of events.

3.1.2 The sensor's volume fraction SHALL be re-assigned the other sensors using volume fractions provided in the Sensor Failure Analysis, Table 1 3.1.3 All data points for Type A test, including those taken prior to rejection of sensor(s), SHALL be re-calculated with the sensor's input deleted. Use Single Failure Recommendations in Instrumentation Recommendations for Integrated Leak Rate Testing.

3.1.4 IF practical, THEN data from rejected sensor(s) should continue to be recorded for duration of both Type A test AND Verification Test.

3.1.5 IF a sensor is rejected during verification test, Type A test leakage rate, Verification Test leakage rate, and verification leakage rate limits SHALL be recalculated.

3.1.6 A sensor SHALL NOT be removed solely because its removal improves leakage rate result.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 119 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 5 of 19) 4.0 CALIBRATION INFORMATION 4.1 Test instrumentation have been calibrated within six months of start of ILRT, or at interval specified by applicable Test Equipment QA program. Calibration SHALL be traceable to NIST 4.2 A calibration check has been completed at ambient conditions within 1 month of start of ILRT. Calibration of Field Standards SHALL be traceable to NIST.

4.3 Test instrumentation is installed at locations provided.

4.4 Volume Weighting Fractions provided have been properly input into ILRT Software Plant Verified Calibration Instrument S/N Calibration By/Date Sensor Standard Sensor Difference Acceptance Check inatr Address Date By/Date Positioned Reading Reading Criteria Verified Designator Calibration By/Date TEl + 2.0°F TE2 + 2.0°F TE3 + 2.0°F TE4 + 2.0°F TE5 + 2.0°F

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 120 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 6 of 19)

Plant Verified Calibration nsren AdrSsN S/N Daibateo Calibration By/Date Sensor Standard Sensor Difference Acceptance Check Designtr Address Date Calibration Positioned Reading Reading Criteria Verified By/Date TE6 + 2.0oF TE7 + 2.0oF TE8 + 2.0°F TE9 + 2.0OF TEl0 + 2.0oF TEll + 2.0OF TEl2 + 2.0OF TEl3 + 2.0OF TE 14 + 2.00 F TEl5 + 2.0OF

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 121 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 7 of 19)

Plant Verified Calibration Instrument S/N Calibration By/Date Sensor Standard Sensor Acceptance Check Designator Date Calibration Positioned Reading Reading Criteria Verified DsgaoCairtoBy/Date TEl6 + 2.0°F TE17 + 2.0°F TE18 + 2.0 0 F TEl9 + 2.0°F TE20 + 2.0°F TE21 + 2.0°F TE22 + 2.0°F TE23 + 2.0°F TE24 + 2.0°F TE25 + 2.0°F

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 122 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 8 of 19)

Plant Verified Calibration Instrument S/N Calibration Sensor Standard Sensor Acceptance Check DesignatorAddress Date Calibration Positioned Reading Reading Criteria Verified DeintrClbainBy/Date TE26 + 2.0°F TE27 + 2.0°F TE28 + 2.0°F TE29 + 2.0°F TE30 + 2.0°F HE1 + 5%RH HE2 + 5%RH HE3 + 5%RH HE4 + 5%RH HE5 + 5%RH

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 123 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 9 of 19)

Plant Verified Calibration Instrument Addremnt SsN S/N Daibateo Calibration By/Date Veriied Sensor Standard Sensor Dfeec Acceptance Check DesignatorAddress Date Calibration Positioned Reading Reading Criteria Verified DesignatorCalibration By/Date HE6 + 5%RH HE7 + 5%RH HE8 + 5%RH HE9 + 5%RH HE10 + 5%RH PT-1 PT-2 FT-1 FT-2

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 124 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 10 of 19)

NOTES

" ALL sensing line tubing (pressure and flow) should be pressurized to test pressure and snooped for leaks. This can be done during pressurization if sensing line can be isolated for repairs.

" The acceptance criteria for the calibration check for the pressure gauges is a limitation on the variance between the two corrected (if applicable) gauge readings when compared against each other. The check can be performed at atmospheric pressure or test pressure. A comparison is made because most plants do NOT possess field standards of equivalent or better accuracy to use during a calibration check due to the extremely high accuracy of the ILRT gauges.

Per ANSI 56.8-1994, para. 4.2.1, Pretest checks are NOT required for mechanical flow rate device (e.g., rotameters),

however they are highly recommended. Flow meter calibration checks are also a simple comparison, typically against a known valve position. The calibration check should be proceeded by a line "flush" with air to verify N.OQparticulates or moisture exists in the sensing line. The calibration check should be performed at a flow rate equivalent to Lo to verify that tubing size is adequate to pass the desired flow rate with existing bends, valves, and pressure drops.

No:2-PT-10YO01 Rev:.02 INTEGRATED LEAK RATE TEST Page 125 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 11 of 19) 5.0 INSTRUMEN' ION: SENSOR STRING TERMINATION RECORD STRING # UU I oIIur VVIMI Terminal #

.#/ INSTALLED REMOVED INIT/DATE INIT/DATE INSIDE WIRE #/

Terminal # Eli INSTALLED INIT/DATE REMOVEDI NIT/DATE

1 IN i STRING # OUTSIDE WIRE #/ INSTALLED REMOVED INSIDE WIRE #/ INSTALLED REMOVEDI Terminal # INIT/DATE INIT/DATE Terminal # INIT/DATE NIT/DATE

1 OUT Pigtail leads sh; be labeled to match amphenol pinout.

No:2-PT-1OYO01 Rev:02 INTEGRATED LEAK RATE TEST Page 126 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 12 of 19) 5.0 INSTRUMENTATION INSTALLATION: SENSOR STRING TERMINATION RECORD S OUTSIDE WIRE #/ INSTALLED REMOVED INSIDE WIRE #/ INSTALLED REMOVEDI Terminal # INIT/DATE INIT/DATE Terminal # INIT/DATE NIT/DATE

2 IN ga S OUTSIDE WIRE#/ INSTALLED REMOVED INSIDE WIRE #/ INSTALLED REMOVEDI

2ROUT#Terminal # INIT/DATE INIT/DATE Terminal # INIT/DATE NIT/DATE Pigtail leads should be labeled to match amphenol pinout.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 127 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 13 of 19) 5.0 INSTRUMENTATION INSTALLATION: SENSOR STRING TERMINATION RECORD

. OUTSIDE WIRE #/ INSTALLED REMOVED INSIDE WIRE #/ INSTALLED REMOVEDI Terminal # INIT/DATE INIT/DATE Terminal # IN IT/DATE NIT/DATE

3 IN STRING # OUTSIDE WIRE#/ INSTALLED REMOVED INSIDE WIRE #/ INSTALLED REMOVEDI Terminal # INIT/DATE INIT/DATE Terminal # INIT/DATE NIT/DATE

3 OUT Pigtail leads should be labeled to match amphenol pinout.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 128 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 14 of 19)

Pigtail leads should be labeled to match amphenol pinout.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 129 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 15 of 19)

I leads should be labeled to match amphenol pinout.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 130 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 16 of 19) 6.0 INSTRUMENT LOCATIONS 6.1 Instrument locations are approximate and may be changed at Test Supervisor discretion. New locations will be recorded below, evaluated and the evaluation documented in Attachment 7, Test Exceptions Log.

6.2 Since temperature stratifies by elevation, azimuth and radius are NOT critical dimensions. Sensors should be placed away from heat sources and heat sinks such as concrete walls and steel I-beams.

6.3 Additional variations are permitted if existing location is in a high radiation field, inaccessible location, or near a heat sink or heat source.

SENSOR LOCATIONS AND VOLUME FRACTIONS TEST PLND INSTL'D PLND INSTL'D PLND INSTL'D ORIGINAL AS TESTED SENSOR SIN EQUIPMENT ELEV. ELEV. AZ. AZ. RADIUS RADIUS VWF VWF TEl 210' 0 8' 0.032220 TE2 190' 2700 19' 0.032220 TE3 210' 900 8' 0.032220 TE4 175' 900 27' 0.038390 TE5 210' 1800 8' 0.032220 TE6 175' 2700 27' 0.038390 TE7 190' 1800 19' 0.032220 TE8 160' 2700 37' 0.038390 TE9 210' 2700 8' 0.032220

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 131 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 17 of 19) 6.0 INSTRUMENT LOCATIONS SENSOR LOCATIONS AND VOLUME FRACTIONS TEST PLND INSTL'D PLND INSTL'D PLND INSTL'D ORIGINAL AS TESTED SENSOR SIN EQUIPMENT ELEV. ELEV. AZ. AZ. RADIUS RADIUS VWF VWF TEl0 190' 00 19' 0.032220 TEl 1 160' 90° 37' 0.038390 TE12 160' 900 19' 0.032220 TE13 175' 1800 27' 0.038390 TE14 160' 1800 37' 0.038390 TEl5 120' 2700 50' 0.042503 TE16 120' 00 50' 0.042503 TE17 160' 00 37' 0.038390 TE18 120' 900 50' 0.042503 TE19 98' 1800 55' 0.019671 TE20 120' 1800 50' 0.042503 TE21 98' 0o 55' 0.019671 TE22 98' 2700 55' 0.019671 TE23 98' 2160 50' 0.019671 TE24 98' 1440 50' 0.019671 TE25 98' 90o 50' 0.019671

No:.2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 132 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 18 of 19) 6.0 INSTRUMENT LOCATIONS SENSOR LOCATIONS AND VOLUME FRACTIONS TEST PLND INSTL'D PLND INSTL'D PLND INSTL'D ORIGINAL AS TESTED SENSOR SIN EQUIPMENT ELEV. ELEV. AZ. AZ. RADIUS RADIUS VWF VWF TE26 71' 72° 50, 0.037095 TE27 71' 1441 50' 0.037095 TE28 71' 2160 50' 0.037094 TE29 71' 2880 50' 0.037094 TE30 71' 0° 50' 0.037094 VWF TOTAL: 1.00

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 133 of 208 ATTACHMENT 5 ILRT MEASUREMENT SYSTEM INSTALLATION AND CHECKOUT (Page 19 of 19) 6.0 INSTRUMENT LOCATIONS SENSOR LOCATIONS AND VOLUME FRACTIONS TEST PLND INSTL'D PLND INSTL'D PLND INSTL'D ORIGINAL AS TESTED SENSOR SIN EQUIPMENT ELEV. ELEV. AZ. AZ. RADIUS RADIUS VWF VWF HEl 210' 00 8' 0.090490 HE2 210' 900 8' 0.090490 HE3 175' 2700 27' 0.090490 HE4 190' 1800 19' 0.090490 HE5 120' 2700 50' 0.119204 HE6 160' 0o 37' 0.119204 HE7 120' 900 50' 0.119204 HE8 71' 720 50' 0.093476 HE9 71' 2160 50' 0.093476 HE10 71' 0. 50' 0.093476

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 134 of 208 ATTACHMENT 6 CONTAINMENT BUILDING LEAK RATE TEST SYSTEM LEAK RATE TESTING (Page 1 of 3) 1.0 TEST SAMPLE LINES NOTE IF installing test sensing & flow lines during Pre-Outage THEN ENSURE Electrical Penetration door is NOT blocked open until Unit is in MODE 4 OR below.

1.1 REMOVE cap from valve 5128, Test Connection Downstream SOV-5024 (PACAS) on 68' Mezzanine.

1.2 INSTALL test sensing line (3/8" or better) from 5128 to the ILRT Vendor control station in the Electrical Penetration area.

1.3 INSTALL test valve at Elec Pen end of test sensing line.

1.4 INSTALL test flow line (1/2" or better) from RAS-559, VC AIR SAMPLE FLOW OUT FROM VC, (68' Mezzanine) to the ILRT Vendor control station in the Electrical Penetration area.

Split line to accommodate Vendor Flow Verification Test and Chemistry Dept Sample.

1.5 INSTALL two test valves at Elec Pen end of test flow lines.

1.6 At the ILRT control station, pressurize the two (2) sensing lines to 50 psig, +5 psig, -0 psig. INSPECT all connections for leakage on each sensing line and repair any indications.

Retest, IF required. VERIFY by initialing below.

Sensing Line I Initials / Date Flow Verification Line / Initials /Date

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 135 of 208 ATTACHMENT 6 CONTAINMENT BUILDING LEAK RATE TEST SYSTEM LEAK RATE TESTING (Page 2 of 3) 1.7 ALIGN the following instrumentation valves at the direction of the ILRT consultant.

0 5128, TEST CONNECTION DOWNSTREAM SOV-5024 (PACAS).

RAS-529, VC AIR SAMPLE FLOW OUT FROM VC.

LRT-1, ILRT Sensing Line Isolation.

LRT-2, ILRT Flow Line Isolation.

1.8 ALIGN CHEM-1, ILRT Chem Sample Isolation as directed by Chemistry to permit Containment sampling 2.0 RESTORATION 2.1 ENSURE the following valves are CLOSED:

5128, Test Connection Downstream SOV-5024 (PACAS).

V 0 RAS-529, VC Air Sample Flow Out From VC V

0 LRT-1, ILRT Sensing Line Isolation.

V 0 LRT-2 ILRT Flow Line Isolation.

V CHEM-1, ILRT Chem Sample Isolation.

V

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 136 of 208 ATTACHMENT 6 CONTAINMENT BUILDING LEAK RATE TEST SYSTEM LEAK RATE TESTING (Page 3 of 3) 2.2 REMOVE test sensing & flow lines from valves 5128 and RAS-559.

V 2.3 REPLACE cap at 5128.

V 2.4 ENSURE Electrical Penetration door is NOT blocked open for ILRT purposes.

V

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 137 of 208 ATTACHMENT 7 TEST EXCEPTIONS LOG (Page 1 of 1)

TEST EXCEPTION LOG PAGE OF Date/Time Proc. Initials Description / Resolution Step 4 4 4 4 4 4 I.

i 4 i 4 4 4 4 .4 4 4 .4 4 4 + 4 4 4- 4 4 + 4

+ +/-- +/-

4- +

4- L -I-

-I- +

Make additional copies as necessary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 138 of 208 ATTACHMENT 8 VALVE LINEUP ALTERATION LOG (Page 1 of 1)

INSIDERESTORED TO INSIDE RE-POSITIONED BY TEST TOU COMPONENT (Indiv. Comp.) CNTMNT? TEST LIU (Name I Extension) ICOMMENTS I DISPOSITION YES/NO (initials / Date)

This form is used to provide a mechanism to track temporary modifications to "completed" valve lineups/component status necessitated by ongoing outage activities during ILRT preparation. The form is used because many lineups/components are positioned via administrative procedure, SOP or other means, without tags. The ILRT Test Supervisor may elect to leave certain components in the requested position after reviewing them for potential impact on the ILRT.

Make additional copies of this form as necessary.

No:2-PT-1 QYO0i Rev:02 INTEGRATED LEAK RATE TEST Page 139 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 1 of 15)

PENETRATION STATUS DURING ILRT PnPenalty Addity Last Test As-Left As-Found Lekg Leavige Peno Line # Component Description [FSAR Fig #] [Drawing] App J N.Prgrm? Addition? (IF Dae MNPLR MNPLR Son Laavigs yes = value) Date 80 f 80 Airloc80 0 Airlock .6La-B Tested by Lock ILRT 95 It 95' Airlock 95' Airlock .6La-B Tested by Lock ILRT LL 369 PT- 948B/949B Containment Pressure Transmitter .6La-B Tested by ILRT 0 370 PT-948CI949C Containment Pressure Transmitter .6La-B ILRT by Tested RR 368 PT- 948,g949A Containment Pressure Transmitter .6La-B Tested by ILRT UU SPARE Gasketed Spare Pentrations (ILRT) .6La-B Take Penalty W SPARE Gasketed Spare Pentrations (ILRT) .6La-B Take Penalty Rack #11 Rack # 11 .6La-B Vented Rack #14118 Weld Channels: Dome, Bottom .6La-B Vented Rack #16 Fuel transfer tube double gasketed seal .6La-B Vented

INTEGRATED LEAK RATE TEST I No:2-PT-10YO01 Rev:02 I Page 140 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 2 of 15)

PENETRATION STATUS DURING ILRT Pen. Line # Component Description [FSAR Fig N] [Drawing] App J Peaatgy Addition(

Penalty Last Test As-Left

~As- Leag No. Prgrm? yes = value) Date MNPLR MNPLR Savings Rack #16 Equipment hatch double gasketed seal .6La-B Vented Rack #12 Rack #12 Electrical Penetrations .6La-B Vented Rack #13 Rack #13 Electrical Penetrations .6La-B Vented Rack #10/15 WCCPP pressurization air [43 [ 9321-2726] ZONE 2 .6La-B Vented PT-3300 Containment Pressure Transmitter .6La-B Tested by ILRT PT-3301 Containment Pressure Transmitter .6La-B Tested by ILRT Electrical Penetrations [ - ((9321-2726] .6La-B Tested by ILRT

No:2-PT-1 QYQO0 Rev:02 INTEGRATED LEAK RATE TEST Page 141 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 3 of 15)

PENETRATION STATUS DURING ILRT Pen, Line # Component Description (FSAR Fig #] [Drawing] App J mnalty(IF Addition? LastTest As-Left As-FoundP No. Prgrm? yes = value) Date MNPLR MNPLR Savings 80 ft 85C 80 Ft Airlock Isolation Spring Loaded Check Valves .6La-C Tested by Lock ILRT 80 ft 850 80 Ft Airlock Isolation Spring Loaded Check Valves .6La-C Tested by Lock ILRT 80 t6La-C t 85A 80 Ft Airlock Inner Door Equalizing Valve Tested by Lock ILRT 80Lo 858 80 Ft Airlock Inner Door Equalizing Valve .6La-C Tested by Lock ILRT 95 ft 95C 95 Ft Airlock Isolation Spring Loaded Check Valves .6La-C Tested by Lock ILRT Lock 95D 95 Ft Airlock Isolation Spring Loaded Check Valves .61a-C ILRT g5 ft * -C Tested by 95 ft 95A 95 Ft Airlock Inner Door Equalizing Valve .6La-C Tested by Lock ILRT 95 ft 95B 95 Ft Airlock Inner Door Equalizing Valve .6La-C Tested by Lock ILRT EE 49 FCV-1 170/1171 VC Purge Air Supply Isolation .6La-C Tested by ILRT FF 50 FCV-1172/1173 VC Purge Exhaust .6La-C Tested by ILRT GG 51 867AN878A Containment Spray Header CIV .6La-C Take Penalty

No:2-PT-10YO0I Rev:02 INTEGRATED LEAK RATE TEST Page 142 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 4 of 15)

PENETRATION STATUS DURING ILRT PenaltyAs-Pen. Line # Component Description [FSAR Fig #] [Drawing] App J Penalty Last Test As-Left As- Leakage No. Prgrrn? Addition?lue Date MNPLR MNPLR Savings yes = value)

LL 608 SOV-501815019 FCU Hydrogen Sampling [ 57] [ 208479 ] .61-C Tested by I ILRT LL 629 E-1, E-2. E-3, E-5 Post Accident Venting System [ 65 ] [ 208879 I .6La-C Tested ILRT by o 572 SOV-5024 FCU Hydrogen Sampling 157 ] [ 208479) .6La-C Tested by ILRT O 605 SOV-5020/5021 FCU Hydrogen Sampling [57 ][ 208479] .6La-C Tested by ILRT P 15 867B Containment Spray Pump Header CIV( 14)) 9321-2735] .6La-C Take Penalty PP 58 PCV-1 190/1191/1192 Pressure Relief Isolation .6La-C Tested by ILRT R 28 PCV-1229/1230 Air from SJAE to CB ] 34] [9321-2025] .6La-C Tested by ILRT R 557 SOV-5022/5023 FCU Hydrogen Sampling [57 ] [ 208479 .6La-C Tested by Hydroge SILRT 606 SOV-5018/5019 FCU Hydrogen Sampling [57)) 208479] .6La-C Tested by HydrogenILRT

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 143 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 5 of 15)

PENETRATION STATUS DURING ILRT Penalty A Lt As- akage

n. Line # Component Description (FSAR Fig 9] [Drawing] App J Addition? Last Test As-Left Found avings No. Prgrm? yes = value) Date MNPLR MNPLR RR 65 PCV-123411235 Radiation Monitor Sample [32 ]9321-2726J .6La-C Take Penalty RR 66 PCV-1236/1237 Radiation Monitor Sample (33] [9321-27261 .6La-C Tested by ILRT RR 68 863/4312 N2 Supply to PORV and SI Accumulators [17][ 235296! .6La-C Tested ILRT by Tested by "T 607 SOV-5018/5019 FCU Hydrogen Sampling (57 [208479 6La-C ILRT V 67 SOV-3416/SOV-3417 N to RC Tested by

/1616/5459 CDT[19[9321-2719 .6La- ILRT Y 32 SOV-34161SOV-3419 N to P 2 9321-2738 ] .6La-C Tested by

/518/4136 % Ro ILRT Y 39 IA-39/PCV-1228 Instrument Air to VC [64 )19321-2036) .6La-C Take Penalty Tested by Z 630 SOV-5020/5021 FCU Hydrogen Sampling [ 57] [208479 ] .6La-C ILRT IIP-500 through IIP-507 Safe Shutdown Transmitters .61-a-C Tested by ILRT

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 144 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 6 of 15)

PENETRATION STATUS DURING ILRT Pen.

Line # Component Description [FSAR Fig #] [Drawing]

App J Penalty Addition? (IF Last Test As-Left j As-Found Leakage No. Prgrm?

yes = value) Date MNPLj MNPLR o avings AA 45 PCV-1215/1215A 32 SIG Blowdown Upstream Containment Isolation IVSW NO BB 46 PCV-1214/1214A 31 SIG Blowdown Upstream Containment Isolation IVSW NO CC 47 PCV-1216/1216A 33 SIG Blowdown Upstream Containment Isolation IVSW NO DO 48 PCV-1217/1217A 34 SG BSlowdown Upstream Containment Isolation IVSW NO GG 51 869A Containment Spray Pump Header VC Isolation IVSW NO J 9 7411744 RHR Pumps Discharge Header Stop IVSW NO N 13 769/797 CCW to RCS Pump Seals and Motor Cooling [ 221 1227781 1 IVSW NO NN 56 850A/851A Safety Injection Pump Discharge Stop IVSW NO 0 14a MOV-789iFCV-625 CCW RCP Cooling from Seals to CCW Pumps [ 241 [ 227781 ] IVSW NO P 15 8698 Containment Spray Pump to Header [14][ 9321-27353 IVSW NO

No:2-PT-10YOO1 Rev:02 INTEGRATED LEAK RATE TEST Page 145 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 7 of 15)

PENETRATION STATUS DURING ILRT Penalty As- Leakage Pen. AppJ Line 0 Component Description [FSAR Fig #] [Drawing] Addition? (IF Last Test As-Left Found No. Prgrm? Date MNPLR MNPLR Savings yes = value)

Q 16 850B/851B SI Discharge [ 15 1(9321-2735] IVSW NO R 17 222 Seal Water Return from RCP [ 111] 9321-2736 ] IVSW NO R 18 793/796 CCW from Excess Letdown HX to CCW Pumps [30)) 227781 ] IVSW NO R 19 20512261227 Charging Water from Charging Pumps [ 9 9321-2736 IVSW NO RR 788 5132/4399 High Rad Sample Sys Return to Cntmnt Sump lsot [31a] [227178] NISW NO S 20 UH-43 Aux Steam Suppty to VC ( 45 ][ 9321-2027] IVSW NO T 21 UH-44 Aus Steam Cond Retumr 46 )[ 9321-2027] IVSW NO U 22 791r798 CCW to Excess Letdown Heat Exchanger [ 29 [ 227781] IVSW NO V 23 178611787 RC0T to Waste Gas Header [ 191[ 9321-2719] IVSW NO V 24 5481549 PRT Gas Analyzer Containment Isolation IVSW NO

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 146 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 8 of 15)

PENETRATION STATUS DURING ILRT Penalty L s Leakage Pen. App J No.

Line # Component Description [FSAR Fig #] [Drawing]

Prgrm?

Addition? (IF LastMtTest As-LRe A.nL yes -value) I a I MNP IMNPLR Savings V 30 1788/1789 RCDT Gas Analyzer Sample Isolation IVSW NO W 25 956A/956B Pressurizer Steam Sample Isolation IVSW NO W 26 956C1956D Pressurizer Liquid Sample Isolation IVSW NO W 59 956E/956F Hot Leg Loop 1&3 Sample Isolation IVSW NO RR 69 956Gt956H Accumulators Sample Isolation IVSW NO X 27 201/202 Reactor Coolant System Letdown [8] [9321-2736] IVSW NO Y 31 859A/859C Test Line from RC Cold Leg to RWST [161] 9321-2735[ ISW NO y 33 519/552 Primary Water Containment Isolation IVSW NO V 34 SA-24-1/SA-24 Station Air Supply to VC [411 [ 9321-20351 IVSW NO S 35 MW--17/MW-1 7.1 City Water Header to CB 47 ][9321-2018 IVSW NO V 338 172311728 Containment Sump Pumps Isolation I/SW NO

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 147 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 9 of 15)

PENETRATION STATUS DURING ILRT Penalty As-Pen. AppJ FtoIF.d Leakage No.

Line # Component Description [FSAR Fig#] (Drawing] Prgrm?

Addition? (IF ILaste T Pt MnPa Saags yes = value) P MNPLR Savings Z 40 170211705 RCDT Pumps Discharge Containment Isolation IVSW NO Z 41 250A/4925 Seal Water Injection to RCP [10 i[ 9321-2736 1 IVSW NO Z 42 2508/4926 Seal Water Injection to RCP [10] [ 9321-2736 1 IVSW NO Z 43 250C/4927 Seal Water Injection to RCP [101 [9321-2736 ] IVSW NO Z 44 2501/4927 Seal Water Injection to RCP [10 19321-2736] IVSW NO 1J 52 760A/822A, 760B1822B CCW Return RHR HX 126] [ 227781] NO NO K 10 732/743 RHR from RC hot leg [6] 1251783 ]NO NO K 294 9581959/990D RHR Loop Sample [5 ] [ 9321-27451 NO NO

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 148 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 10 of 15)

PENETRATION STATUS DURING ILRT Pen. App J Addition? (IF Last Test As-Left Found Leakage Line # Component Description IFSAR Fig #] [Drawing) yes Avalue) Date MNPLR MNPLR Savings No. Prgfn?

La Iia SWN-41-1A/ NO SWN-42-1/SWN-43-1 Service Water Supply to FCU 21 (3911 209762 NO Lb jib SWN-43-1N NO SWN-42-3/SWN-43-3 Service Water Supply to FCU 23 [ 39 ] 209762 j NO 11c SWN-43-4A/

Lc SWN-42-4/SWN-43-4 Service Water Supply to FCU 24 [39 ) ( 209762 ] NO NO Ld Ilb SWN-43-2A/

SWN-42-2/SWN-43.2 Service Water Supply to FCU 22 [ 39 11209762 1 NO NO Ile SWN-43-5A/

Le SWN-42-5/SWN-43-5 Service Water Supply to FCU 25 (39 ([209762 1 NO NO LL 54 753H CCW/Aux CCW to Recirculation Pumps Supply Header Stop NO NO 12277811 LL 55 753G Recirculation Pumps CCW Return Header Stop Valve [2277811 NO NO LL 369 1814B Containment Pressurization Sensing Instrumentation Stop NO NO Ma 12a SWN-44-3A/SWN-51-3A Service Water from FCU 23 to River [40]1209762 NO NO

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 149 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 11 of 15)

PENETRATION STATUS DURING ILRT Penalty Ls-TLeAkage Pen. App J Addition? (IF eo oLuntTestLeAakLeag No.

Line # Component Description [FSAR Fig #] [Drawing]

PrgrIn? yes - value) PLRI MNPLR Savings Mb 12b SWN-44-1A/SWN-51-1A Service Water from FCU 21 to River[ 40 [209762 NO NO MC 12c SWN-44-4A/SWN-51-4A Service Water from FCU 24 to River [401209762 NO NO Md t2d SWN-44-2A/SWN-51-2A Service Water from FCU 22 to River [401209762 NO NO Me 12e SWN-44-5ASWN-51-5A Service Water from FCU 25 to River [40 ]J 209762 NO NO O 370 1814C Containment Pressurization Sensing Instrumentation Stop NO NO 00 57 885A/885B Containment Sump Recirc Line 17 1[ 9321-2735 1 NO NO 00 60 888A/888B Low Head to High Head Safety Injection Recirc. Stop NO NO RR 368 1814A Containment Pressurization Sensing Instrumental Stop NO NO

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 150 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 12 of 15)

PENETRATION STATUS DURING ILRT Pen. App J Penalty As-Found Leakage Line # Component Description [FSAR Fig #] (Drawing] Addition? (IF Last Test As-Left No. Prgrm? Date MNPLR MNPLR Savings yes = value)

SS 495 SWN-71-4A Service Water Motor Cooler Return FCU 24 ] 40a ] ( 209762] NO NO SS 496 SWN-71-3A Service Water Motor Cooler Return FCU 23 40a] 209762] NO NO SS 497 SWN-71-1A Service Water Motor Cooler Return FCU 21 [40a ((209762] NO NO SS 498 SWN-71-2A Service Water Motor Cooler Return FCU 22[ 40a ((209762] NO NO SS 499 SWN-71-5A Service Water Motor Cooler Return FCU 251 40a ] [209762 NO NO TT 595 990A1990B Recirculation Pump Sample Isolation NO NO y 36 PCV-t 111-.1 WCCPP pressurization air [ 43 [9321-2726 NO NO Y 37 PCV-1111-2 WCCPP pressurization air (43 [9321-2726 NO NO 1870 RHR LoopMini Flow Test Line Stop NO NO

No:2-PT-1 QYGOl Rev:02 INTEGRATED LEAK RATE TEST Page 151 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 13 of 15)

PENETRATION STATUS DURING ILRT Penalty As d-Pen. App J Line # Component Description [FSAR Fig #] [Drawing] Addition? (IF Last Test As-Left Foun Leakage No. Prgrm? Date MNPLR MNPLR ISavings yes ==value)

E 6 FCV-417, FCV-417L Main Feed Line 36 f9321-2019

] ] Type A NO F 5 FCV-427, FCV-427L Main Feed Line [ 36 1 [ 9321-2019] Type A NO G 8 FCV-447, FCV-447L Main Feed Line (361 9321-2019 1 Type A NO H 7 FCV-437, FCV-437L Main Feed Line [36 1 9321-2019] Type A NO K 337 RHR Miniflow [5] [251783] Type A NO KK 53 CCW HX CCW Supply [25 [2277811 TypeA NO LL LL-LIS-1311 Reactor Vessel Level Inst [-] [208798 Type A NO LL LL-LIS-1312 Reactor Vessel Level Inst [ -1[208798] Type A NO 0 14 784 CCW RCP Cooling from Seals to CCW Pumps [231227781] Type A NO

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 152 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 14 of 15)

PENETRATION STATUS DURING ILRT Penalty As Pen. App J Last Test As-Left As-F Leakage Line # Component Description [FSAR Fig #] [Drawing] Addition? (IF No. Prgrrn? Date MNPLR NPLR Savings yes = value)

RR 474 580A Old Dead Weight Tester Penetration [ 44 1[9321-27381 Type A NO RR 529 PIS-403 Instrument PE-403 f -] [ 9321-2738] Type A NO RR LL-LIS-1321 Reactor Vessel Level Inst 1-] [208798] Type A NO RR LL-LIS-1322 Reactor Vessel Level Inst [- [208798] Type A NO W 364 Spare [ 38 9321-2714] Type A NO W 365 PIS-402 PE-402[ -)[9321-2738] Type A NO W 366 Spare [38 ](932t-2714] Type A NO W 367 Spare ] 38 1 [ 9321-2714] Type A NO Z IA Steam Generator Level (70119321-20191 Type A NO Z 1B Steam Generator Level 1701 19321-2019] Type A NO

No:2-PT-1 OYOO1 Rev:02 INTEGRATED LEAK RATE TEST Page 153 of 208 ATTACHMENT 9 CONTAINMENT PENETRATION

SUMMARY

(Page 15 of 15)

Or-MIT0ATU'nfI CTAT~iz lHOIKIr-i( 11 OT Description [FSAR Fig #] (Drawing) App J Penalty PenatioyI Pen. Line # Component PNo Ino[Prgrn? App rm Addition? (IF yes - value)

Z 2A Pressurizer Level ( 70 19321-2738] Type A NO Z 3A Pressurizer Pressure [ 70 ] 9321-27381 Type A NO TOTALS:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 154 of 208 Initials ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 1 of 6) 1.0 CONTAINMENT VISUAL INSPECTION 1.1 10CFR50, Appendix J and Regulatory Guide 1.163 require a visual inspection of accessible areas of the internal and external surfaces of the vapor containment building. This inspection requirement may be met in part OR its entirety by completing 2-PI-R002, Internal Containment Structural Visual Inspection and 2-PT-2Y001, External Containment Structural Visual Inspection OR by walking down the Containment per the instructions in this Attachment.

N/A any Section below that is met by accepting a satisfactorily completed 2-PI-R002 OR 2-PT-2Y001 inspection result.

2.0 EXTERIOR INSPECTION 2.1 INSPECT all pipe and electrical penetration areas, 80' and 95' Airlocks (outside),

and all other accessible exterior surfaces for the following that might cause loss of Containment's function:

0 cracks 0 distortions S loss of material 0 any other unusual conditions 2.2 Using the following tables, RECORD the results of the inspection, making note of all abnormal findings, deteriorations, and WRT #Wsfor corrective action:

ALL PIPE AND ELECTRICAL PENETRATION AREAS 11 ABNORMALITIES 1.

2.

3.

4.

5.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 155 of 208 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 2 of 6)

EXTERIOR INSPECTION (continued) Initials 80' AND 95' AIRLOCKS (OUTSIDE)

ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

ALL OTHER ACCESSIBLE EXTERIOR SURFACES ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 156 of 208 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 3 of 6)

Initials 3.0 INTERIOR INSPECTION 3.1 INSPECT all pipe and electrical penetration areas, 80' and 95' Airlocks (inside), all other accessible interior surfaces, liner insulation, and Reactor Sump Pit area for the following that might cause loss of Containment's function:

" Cracks

Distortions

" Loss of material

" Any other unusual conditions 3.2 Using the following tables, RECORD the results of this inspection, making note of all abnormal findings, deteriorations, and WRT #'s for corrective action:

ALL PIPE AND ELECTRICAL PENETRATION AREAS ABNORMALITIES T WRT #

1.

2.

3.

4.

5.

6.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 157 of 208 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 4 of 6)

INTERIOR INSPECTION (continued) Initials 80' AND 95' AIRLOCKS (INSIDE)

ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

ALL OTHER ACCESSIBLE INTERIOR SURFACES ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 158 of 208 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 5 of 6)

INTERIOR INSPECTION (continued) Initials INSPECT THE LINER INSULATION ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

CAUTION Watch Health Physics Tech SHALL be informed PRIOR to inspecting the Reactor Sump.

REACTOR SUMP PIT AREA ABNORMALITIES WRT #

1.

2.

3.

4.

5.

6.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 159 of 208 ATTACHMENT 10 CONTAINMENT BUILDING VISUAL INSPECTION (Page 6 of 6)

COMMENTS:

TEST PERFORMERS:

Print Name: Initials: SignaturelDate:

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 160 of 208 ATTACHMENT 11 CONTINGENCIES (Page 1 of 16) 1.0 TEST ABORT TEST PHASE SAFE CONDITION ABORT PLANS Preparation Stop in progress alignments. Place components in a safe condition as directed by CRS, SM, Test Supervisor. Document all manipulations on Attachment 8, Valve Lineup Alteration Log.

Pressurization - Close pressurization valve(s). From SAFE condition:

SUnload and stop compressors. - Proceed to Procedure Section 4.6, Depressurization Phase.

" Release plant systems under Test organization control (tags).

" Depressurize plant per procedure and any specific directions from operations/management.

" Unless otherwise directed, continue collecting data during depressurization Stabilization

Stop leak survey activities.

-Assess plant activities which may be in progress (sampling, stopping sump Same as above draining, etc.).

- Continue data acquisition.

Hold Test (ILRT)

Inherently stable, NO active manipulation of plant equipment. Same as above

Stop leak survey activities.

- Continue data acquisition.

Verification Test - Only activity is imposition of a known leak from containment. Same as above

- Continue data acquisition.

- If requested, stop imposed leak flow.

Depressurization - Isolate depressurization path until

Continue with depressurization when otherwise notified. so directed.

- Update Test Supervisor/Ops on current - Alter depressurization path as pressures/conditions in containment. directed by SM if required.

I Monitor depressurization rate closely.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 161 of 208 ATTACHMENT 11 CONTINGENCIES (Page 2 of 16) 2.0 EXCESSIVE LEAKAGE TEST PHASE LEAK SCENARIO RESPONSE Pressurization 1. Containment

VERIFY LLRT procedure tests leaking barrier Boundary, Locally in Post-Accident direction AND that a LLRT NOTE: Leak Rate Testable. will measure observed leakage.

Pressurization does NOT have to be IF penalty addition is already being applied for stopped during barrier, THEN take steps to isolate leakage.

leakage evaluation - IF a penalty addition was NOT planned AND unless Shift/Test leakage can be measured later with a LLRT, Management so THEN isolate penetration.

orders.

Continue pressurization to test pressure.

Record/explain action in Attachment 1, Test Supervisor's Log AND Attachment 7, Test Exceptions Log, THEN modify penetration's test status in Attachment 9, Containment Penetration Summary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 162 of 208 ATTACHMENT 11 CONTINGENCIES (Page 3 of 16) 2.0 EXCESSIVE LEAKAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Pressurization 2. Containment

Evaluate whether the leak can be later Boundary, NOT measured with an Appendix J leak test. IF Continued: Locally Leak Rate YES, THEN proceed as described in Leak Testable. Scenario 1 response.

- IF leakage can NOT be determined later with a local leakage rate style test, THEN evaluate whether leak can be isolated at test pressure.

IF leakage can be isolated with containment at pressure, THEN continue pressurization to final test pressure AND measure leakage in Stabilization Mode.

- IF leakage can NOT be isolated once containment exceeds 12 psi, THEN STOP pressurization AND evaluate options (e.g.

entry to close additional valves, correct a lineup, etc.).

IF necessary, THEN notify SM, ILRT Test Management AND request permission to depressurize to < 12 psi to effect repairs.

Record/explain action in Attachment 1, Test Supervisor's Log; AND Attachment 7, Test Exceptions Log, THEN modify penetration's test status as reflected in Attachment 9, Containment Penetration Summary if appropriate.

Pressurization 3. Test Boundary - IF observed leakage is from a line or component that is a Test Boundary, NOT a Continued: containment boundary as determined by ILRT Test Supervisor (e.g. such as a flange on the pressurization line), THEN take steps to isolate or correct leakage.

- Continue pressurization.

- Record/explain action in Attachment 1, Test Supervisor's Log.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 163 of 208 ATTACHMENT 11 CONTINGENCIES (Page 4 of 16) 2.0 EXCESSIVE LEAKAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Stabilization 4. Containment

Continue collecting data if leakage shows Boundary, Locally downward trend that can be projected to drop Leak Rate Testable below acceptance criteria - take NO action.

NOTE: - IF leakage does NOT appear to be trending It is NOT unusual to into an acceptable range, THEN apply Leak experience what Scenario 1 response.

appears to be high

VERIFY containment pressure > 96% Pa.

leakage early in -RESET Stabilization phase start time in ILRT stabilization processes suchdue to as in- computer (i.e. regenerate arrays from data gassesand void point directly AFTER Corrective Action was gassing an odtaken).

equalization. It is imperative that NO action be taken until a full evaluation of a problem is complete.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 164 of 208 ATTACHMENT 11 CONTINGENCIES (Page 5 of 16) 2.0 EXCESSIVE LEAKAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Stabilization 5. Containment

Continue collecting data if leakage shows Boundary, NOT downward trend that can be projected to drop Continued. Locally Leak Rate below acceptance criteria - take NO action.

Testable - EVALUATE whether leak can be measured later with an Appendix J leak test. IF YES, THEN proceed as described in Leak Scenario 1.

IF leakage can NOT be determined later with a local leakage rate style test, THEN evaluate whether leak can be isolated at test pressure.

- IF leakage can be isolated with containment at pressure, THEN remain in Stabilization Mode long enough to measure leakage, THEN isolate leak.

VERIFY containment pressure > 96% Pa.

- RESET array start time and quantify change once leak is isolated.

IF the leakage can NOT be isolated at test pressure, THEN quantify leakage using ILRT computer. Notify SM, ILRT Test Management AND request permission to depressurize to

< 12 psi to effect repairs.

- Record/explain the action in Attachment 1, Test Supervisor's Log AND Attachment 7, Test Exceptions Log. Modify penetration's test status in Attachment 9, Containment Penetration Summary.

Stabilization 6. Test Boundary

IF observed leakage is from a line or component that is a Test Boundary, NOT a containment Continued boundary as determined by the ILRT Test Supervisor (e.g. such as a flange on the pressurization line), THEN take steps to isolate or correct leakage.

- VERIFY containment pressure ->96% Pa.

- RESTART data collection in Stabilization mode, continue test.

- Record/explain action in Attachment 1, Test Supervisor's Log.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 165 of 208 ATTACHMENT 11 CONTINGENCIES (Page 6 of 16) 2.0 EXCESSIVE LEAKAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Hold Test (ILRT) 7. Containment - Continue collecting data if leakage shows a Boundary, Locally downward trend that can be projected to drop Leak Rate Testable below acceptance criteria - take NO action.

- IF leakage is excessive and does NOT appear to be trending downward, THEN apply Leak Scenario 4 response.

- VERIFY containment pressure a 96% Pa.

- RESET Test phase start time in ILRT computer (i.e. regenerate arrays from data point directly AFTER Corrective Action was taken).

NOTE: 8. Containment - Continue collecting data if leakage shows a Typically excessive Boundary, NOT downward trend that can be projected to drop leakage will be Locally Leak Rate below acceptance criteria - take NO action.

detected and Testable

EVALUATE whether leak can be measured later addressed during with an Appendix J leak test. IF YES, THEN stabilization. proceed as described in Leak Scenario I response.

- IF leakage can NOT be determined later with a local leakage rate style test, THEN evaluate whether leak can be isolated at test pressure.

- IF leakage can be isolated with containment at pressure, THEN remain in Test Mode long enough to measure leakage, then isolate the leak.

- VERIFY containment pressure > 96% Pa.

- RESET Test mode start and quantify change once leak is isolated (e.g. final measured leakage -

measured leakage observed prior to action).

IF leakage can NOT be isolated at test pressure, THEN quantify leakage using ILRT computer, notify SM, ILRT Test Management and request permission to depressurize to < 12 psi to effect repairs.

- Record/explain action in Attachment 1, Test Supervisor's Log AND Attachment 7, Test Exceptions Log. Modify penetration's test status in Attachment 9, Containment Penetration Summary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 166 of 208 ATTACHMENT 11 CONTINGENCIES (Page 7 of 16) 2.0 EXCESSIVE LEAKAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Hold Test (ILRT) 9. Test Boundary

IF observed leakage is from a line or Continued. component that is a Test Boundary, NOT a containment boundary as determined by the ILRT Test Supervisor (e.g. such as a flange on the pressurization line), THEN take steps to isolate OR correct leakage.

- Verify containment pressure >- 96% Pa.

Restart data collection in Test mode, continue test.

Record/explain action in Attachment 1, Test Supervisor's Log.

Verification Test 10. Containment - Apply Leak Scenario 7 response.

Boundary, Locally

Verify containment pressure ->96% Pa.

(Leakage out of Leak Rate acceptance band Testable - Restart data collection in Test mode, HIGH) complete another ILRT, then verify that test result.

- Record/explain action in Attachment 1, Test Supervisor's Log AND Attachment 7, Test Exceptions Log. Modify penetration's test status in Attachment 9, Containment Penetration Summary.

NOTE: 11. Containment

Apply Leak Scenario 8 response.

Leakage should have Boundary, NT Verify containment pressure _>96% Pa.

been identified earlier Locally Leak Rate in the test. Changes Testable

Restart data collection in Test mode, in leakage at this complete another ILRT, THEN VERIFY that point are typically due test result.

to plant system/lineup - Record/explain action in Attachment 1, Test changes Supervisor's Log AND Attachment 7, Test Exceptions Log. Modify penetration's test status in Attachment 9, Containment Penetration Summary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 167 of 208 ATTACHMENT 11 CONTINGENCIES (Page 8 of 16) 2.0 EXCESSIVE LEA KAGE (Continued)

TEST PHASE LEAK SCENARIO RESPONSE Verification Test 12. Test Boundary

Apply Leak Scenario 9 response.

Continued

Verify containment pressure ->96% Pa.

Restart data collection in Test mode, complete another ILRT, then verify that test result.

Record/explain action in Attachment 1, Test Supervisor's Log AND Attachment 7, Test Exceptions Log. Modify penetration's test status in Attachment 9, Containment Penetration Summary.

Depressurization 13. ANY - IF ILRT, Verification Test passed, and leakage is from a Test Boundary, THEN NO IMPACT to ILRT results.

" IF leakage is through a containment boundary, THEN ILRT Supervisor, ILRT Management and Plant Management will evaluate leak path.

IF directed by Test Supervisor, THEN ISOLATE leak path.

IF leakage path can NOT be isolated and it represents a safety hazard, THEN it may be prudent to secure depressurization while additional boundaries/safety precautions are established.

Continue depressurization to atmospheric.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 168 of 208 ATTACHMENT 11 CONTINGENCIES (Page 9 of 16)

Initials 3.0 HIGH CONTAINMENT ACTIVITY VENT PATH 3.1 VERIFY the following valves on the penetration manifold are CLOSED:

Valve Description Location Position Initials U U-1 UU Penetration Stop 51' PIPE PEN CLOSED U U-2 UU Penetration Stop 51' PIPE PEN CLOSED U U-3 UU Penetration Stop 51' PIPE PEN CLOSED U U-4 UU Penetration Stop 51' PIPE PEN CLOSED U U-5 UU Penetration Stop 51' PIPE PEN CLOSED V V-1 V V Penetration Stop 51' PIPE PEN CLOSED V V-2 V V Penetration Stop 51' PIPE PEN CLOSED V V-3 V V Penetration Stop 51' PIPE PEN CLOSED V V-4 V V Penetration Stop 51' PIPE PEN CLOSED V V-5 V V Penetration Stop 51' PIPE PEN CLOSED U U-6 U U Manifold Stop YARD CLOSED U U-7 U U Manifold Stop YARD CLOSED U U-8 U U Manifold Stop YARD CLOSED U U-9 U U Manifold Stop YARD CLOSED U U-10 U U Manifold Stop YARD CLOSED V V-6 V V Manifold Stop YARD CLOSED V V-7 V V Manifold Stop YARD CLOSED V V-8 V V Manifold Stop YARD CLOSED V V-9 V V Manifold Stop YARD CLOSED V V-10 V V Manifold Stop YARD CLOSED 3.2 DISCONNECT all 3" air hoses at the Yard Manifold end.

3.3 CLOSE Fan House Roll-Up Door #220.

3.4 BLOCK OPEN VC Exhaust Plenum door. (72' Fan House) 3.5 ROUTE open end of 3" air hoses to the VC Purge Exhaust Plenum.

No:2-PT-1OYOO1 Rev:02 INTEGRATED LEAK RATE TEST Page 169 of 208 ATTACHMENT 11 CONTINGENCIES (Page 10 of 16)

Initials 3.6 START both PAB Exhaust Fans per 2-SOP-11.1, Ventilation System Operation. Do NOT start the PAB Supply Fan.

3.7 WHEN permission from HP is received, THEN SLOWLY OPEN depressurization path blowdown valves and release air from containment. Maintain maximum depressurization rate tess than 15 psi/hr AND PAB at a negative pressure as follows:

Valve Description Position Initials U U-1 U U Penetration Stop OPEN U U-2 U U Penetration Stop OPEN U U-3 U U Penetration Stop OPEN U U-4 U U Penetration Stop OPEN U U-5 U U Penetration Stop OPEN V V-1 V V Penetration Stop OPEN V V-2 V V Penetration Stop OPEN V V-3 V V Penetration Stop OPEN V V-4 V V Penetration Stop OPEN V V-5 V V Penetration Stop OPEN 3.7.1 ENSURE PAB pressure remains negative.

3.7.2 GO TO step 4.6.5 in the main body of this procedure.

No:2-PT-10YO01 Rev:02 INTE GRATED LEAK RATE TEST Page 170 of 208 ATTACHMENT 11 CONTINGENCIES (Page 11 of 16)

Initials 4.0 RCS FILLING OR BORATION CAUTION

" USE OF THIS SECTION MAY VOID THE ILRT DATA.

" ENSURE ADEQUATE RCS VENT PATH ESTABLISHED PRIOR TO RUNNING SI OR CHARGING PUMPS.

NOTE This section provides direction for the following while considering any abnormal plant configurations due to ILRT lineups:

Restores each of the three available boration paths.

Provides a method of makeup from the RWST via valve 882.

" Provides some added guidance if loss of RHR occurs and steam generators are needed.

The SI system, via 22 SI Pump is the only available path without the need for field operations.

IF time permits, the preferred method for RCS addition is Charging.

The designated boration paths listed have been evaluated for the duration of the ILRT:

o CHARGING using the BAST - Most control, Field operations required.

o CHARGING using the RWST - Controllable, Field operations required.

o 22 SI PUMP using the RWST - Least controllable, ONLY CCR operations needed.

4.1 IF RCS conditions warrant make up OR boration AND time permits field operations, THEN restore Charging as follows:

4.1.1 DISPATCH an operator to OPEN the following valves:

205, CHARGING LINE STOP.

226, CHARGING LINE STOP.

No:2-PT-1OY001 Rev:02 INTEGRATED LEAK RATE TEST Page 171 of 208 ATTACHMENT 11 CONTINGENCIES (Page 12 of 16)

Initials 4.1.2 ALIGN a Charging Pump suction path:

4.1.2.1 To align CHARGING with BAST:

IF plant conditions are such that VCT overpressure alone will produce adequate charging flow, THEN adjust HCV-142 as necessary.

IF desired, THEN start charging pump(s) using 2-SOP-3.1, Charging Seal Water and Letdown Control, Section 4.2.2, NORMAL CHARGING PUMP STARTUP AND operate system as required.

OR 4.1.2.2 To align CHARGING with RWST:

a) START Charging Pump(s) using 2-SOP-3.1, Charging Seal Water and Letdown Control, Section 4.2.2, NORMAL CHARGING PUMP STARTUP.

b) OPEN LCV-112B, Emergency RWST Make-up Stop.

c) CLOSE LCV -112C, VCT Outlet stop.

d) PLACE RCS Make-up Control to stop.

e) OPERATE system as required.

4.2 IF RCS conditions warrant make up or boration AND time does NOT permit field operations, THEN fill using the RWST through 22 Safety Injection Pump as follows:

4.2.1 VERIFY the follwing valves are OPEN:

0 1810, Refueling Water to SI Pumps Suction. (SBF-1) 0 887A, 22 SI Pump Suction. (SBF-2)

887B, 22 SI Pump Suction. (SBF-2)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 172 of 208 ATTACHMENT 11 CONTINGENCIES (Page 13 of 16)

Initials CAUTION To prevent possible pump runout conditions, do NOT run 22 SI Pump with both 851A and 851B open.

4.2.2 OPEN only ONE of the following valves:

0 851A, 22 SI Pump Tie Valve to Discharge of 21 SI Pump. (SBF-2)

OR

851 B, 22 SI Pump Tie Valve to Discharge of 21 S3 Pump. (SBF-2) 4.2.3 ESTABLISH the desired fill rate by OPENING / CLOSING the appropriate combination of SI Cold Leg Branch stops:

4.2.3.1 IF 851A is OPEN, THEN:

" 856A, Loop 21 Cold Leg SI Line. (SBF-2)

" 856E, Loop 23 Cold Leg SI Line. (SBF-2) 4.2.3.2 IF 851B is OPEN, THEN

" 856C, Loop 24 Cold Leg SI Line (SBF-2)

" 856D, Loop 22 Cold Leg SI Line (SBF-2)

No:2-PT-1 QY001 Rev:02 INTEGRATED LEAK RATE TEST Page 173 of 208 ATTACHMENT 11 CONTINGENCIES (Page 14 of 16)

Initials NOTE 22 SI Pump 2A Breaker is Racked In as the dedicated power source to restore a boration path from the CCR. (i.e. 22 SIP from 2A is the preferred Pump and Breaker) 4.2.4 IF directed by CRS, THEN START 22 Safety Injection Pump.

4.2.4.1 IF 22 Safety Injection Pump can NOT be started from Bus 2A, THEN PERFORM the following:

" ESTABLISH conditions to START 22 SIP from Bus 3A.

OR

" ESTABLISH conditions AND START 21 OR 23 SI Pump.

4.2.5 WHEN filling the RCS through Safety Injection System is no longer necessary, THEN PERFORM the following:

4.2.5.1 ENSURE Safety Injection Pump is secured.

4.2.5.2 CLOSE the following valves as applicable:

856A

856C

856D e 856E

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 174 of 208 ATTACHMENT 11 CONTINGENCIES (Page 15 of 16)

Initials 4.2.5.3 ALIGN the following valves as directed by the CRS:

851A

851B

887A

887B

1810 NOTE This method will only be feasible IF the RCS is depressurized and the RCS physical level is below the RWST level.

4.3 IF desired to provide RCS make up or boration using the RWST through valve 882 AND conditions exist between the RWST and RCS that flow would be induced, THEN PERFORM the following:

4.3.1 ENERGIZE AND OPEN valve 882, RHR Pump Suction From the RWST.

4.3.2 MONITOR RCS level rise and RWST level reduction.

4.3.3 MONITOR RHR flow AND adjust IF necessary.

4.3.4 WHEN desired RCS level is reached OR IF directed by the CRS, THEN terminate makeup by CLOSING AND DE-ENERGIZING valve 882, RHR Pump Suction From the RWST.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 175 of 208 ATTACHMENT 11 CONTINGENCIES (Page 16 of 16)

Initials 4.4 IF RHR cooling is lost AND conditions warrant using the Steam Generators for RCS cooling, PERFORM The following:

4.4.1 IF necessary to create an INTACT RCS, THEN CLOSE the following:

" MOV-535, Pressurizer Relief Line Train B Block Valve

MOV-536, Pressurizer Relief Line Train A Block Valve 4.4.2 ENSURE the desired Atmospheric Dump Inlet Stop(s) are OPEN.

MS-3A

MS-3B_

MS-3C

MS-3D 4.4.3 GO TO 2-AOP-RHR-1, Loss of RHR.

5.0 UNEXPECTED ALARMS I INDICATIONS / CONDITIONS 5.1 Any unexpected alarms, indications OR conditions SHALL discussed with the ILRT supervisor and other departments / individuals as germane to the condition AND addressed as determined appropriate to the situation.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 176 of 208 ATTACHMENT 12 ILRT VERIFICATION TEST AND FLOW DATA (Page 1 of 3)

START TIME END TIME (Page of START DATE END DATE

AMBIENT CORRECTED TIME SERIAL # TEMPERATURE PRESSURE FLOW INITIALS 4

i I

4 *

Ambient pressure reading is only required once - at the beginning of the Verification Phase.

The goal is to set and maintain 8 scfm for an imposed leak. Readings are taken at 15 minute intervals to match the data scan intervals on the ILRT computer.

The Verification Test typically lasts only 4 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Make additional copies of this sheet as necessary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 177 of 208 ATTACHMENT 12 ILRT VERIFICATION TEST AND FLOW DATA (Page 2 of 3)

CALCULATE L, AS FOLLOWS:

A. IF a rotometer is used to measure the imposed leak, THEN correct its reading to actual conditions as follows:

Fc=Fr Pm Tc Pc Tm Where Fc corrected flow.

Fr reading from rotometer (IF107304 or IFI07305).

Pm back pressure at rotometer during test (IP107313).

Tm = temperature of flow through rotometer during verification test (IT107314).

Pc = pressure that rotometer calibration was performed at (from cal. sheet).

Tc = temperature rotometer calibration was performed at (from cal.

sheet).

Instrument Used: (Serial #)

Pm = psia Tm = OR Pc = psia Tc = OR Fr = SCFM B. Enter the corrected flow reading into the ILRT computer program. It will establish the acceptance criteria for the Verification Test results.

Fc value entered: scfm

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 178 of 208 ATTACHMENT 12 ILRT VERIFICATION TEST AND FLOW DATA (Page 3 of 3)

NOTE The ILRT Inc Data Management program automatically calculates Lo, in % wt/day based on an input of atmospheric pressure on corrected flow (Fc). The following steps are performed solely to verify that the proper data was input into the computer program, and that the Upper and Lower Limits the computer displays are correct.

C. Calculate the L, value imposed in weight % day using the following formula:

1. Fc (in SCF/m) x 0.07517 Ibs/SCF x 1440 min/day = Lo in lbs/day.

2. Fc (in Ibm/day): -I

3. L. (in lbs/day)/Wt of Containment Air Mass at End of ILRT x 100 = Lo (in %

wts/day).

4. Mass value used: Ibm

5. Lo = %wt/day D. The Composite Leakage Rate (Lc), as measured by the ILRT Measurement System and calculated using the same analysis technique used to calculate the ILRT acceptance criteria, SHALL satisfy the following:

(Lo + Lam - 0.25 La) -<Lc0 - (Lo + Lam+ 0.25. La)

Lower Limit Lc Upper Limit Where:

Lo = %wt/day (value from Section C step 5 above)

Lam =- %wt/day (from Step 4.4.3.9a)

No:2-PT-1OYO01 Rev:02 INTEGRATED LEAK RATE TEST Page 179 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 1 of 12)

RISK COMPONENT AREA Section 5 Below VLO 201 51' PIPE PEN red sample red sapelve valves CCR SNF VLO 202 51' PIPE PEN Section 5 Below CCR SNF red sample valves MOV-205 51'PIPE PEN Section 2 by red 98' PAB VLO MCC ROOM valves 1229/1230 Section 2 in 98' PAB MOV-226 51' PIPE PEN archway2 ROOM VLO archway MCC ROOM Section 2 in 98' PAB MOV-227 51' PIPE PEN archway2 ROOM VLO archway MCC ROOM Section 3 center 98' PAB VLO MOV-250A 51' PIPE PEN un S lines MCC ROO under SGBD lines MCC ROOM VLO MOV-4925 51' PIPE PEN VLO MOV-250B 51' PIPE PEN VLO MOV-4926 51' PIPE PEN VLO MOV-250C 51' PIPE PEN XII n hAnI-AQ')7 rl' DJDr- DI-ki I . . I.. under SGBD line,, I Section 3 center VLO MOV-250D 51' PIPE PEN un S cener under SGBD line,,

Section 3 center VLO IV O,)V-4.*Z0 D I Wrl'r- rt:-1

No:2-PT- 10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 180 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 2 of 12)

RISK COMPONENT AREA FIELDATTACH CHECK FOR: SYSTEM LOCATION LOCATION POSITION VLO MOV-222 51' PIPE PEN Section 5 by red valves CCRSNF SHUT 3A Bonnet, Packing CVCS (9321-2736) 1229/1330 Leakage, water Sea Reur 98'CPABHX 98' PAB SHUT 3A Bonnet, Packing CVCS (9321-2736)

VLO 272A 98' PAB 'HX CellP Leakage, water Sea Reur H8 Cell 98' PAB SHUT 3A Bonnet, Packing OVOS (9321-2736)

VLO 221 98 PAB Seal Return HX Cel Leakage, water MED PCV-1234 51' PIPE PEN Section 1 in corner by CCR SHUT 3C Packing Leakage PACAS (238106)

Rack 11 MED PCV-1235 51' PIPE PEN Section 1 in corner by OCR SHUT 3C Packing Leakage PACAS (238106)

Rack 11 CCR SU 3_PinLeae AA _280 MED PCV-1236 51' PIPE PEN Section 1 in corner by CCR SHUT 3C Packing Leakage PACAS (238106)

Rack 11 MED PCV-1237 51' PIPE PEN Section 1 in corner by CCR SHUT 3C Packing. Leakage PACAS (238106)

Rack 11 HI RAS-558 68' MEZZ In corner at top of stairs 68' MEZZ OPEN 3C Air coming from PACAS (238106) vent at Pa I

No:2-PT-1 QYQOl Rev:02 INTEGRATED LEAK RATE TEST Page 181 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 3 of 12)

RISK COMPONENT AREA FIELD CONTROL TEST ATTACH CHECK FOR: SYSTEM LOCATION LOCATION POSITION 98' PAB MED SOV-5018 68' MEZZ Across from phone MCC ROOM SHUT 3A Packing Leakage PAH2S (208479) 98' PAB MED SOV-5019 68' MEZZ Across from phone MOO ROOM SHUT 3A Packing Leakage PAH2S (208479)

HI 5131 80PLC Back left corner PAB OPEN 3A Air coming from PAH2S (208479)

SAMPLE CELL SAMPLE CELL vent at Pa MED SOV-5020 68' MEZZ Across from phone 98'MCO SHUT 3A Packing Leakage PAH2S (208479)

MOO ROOM SU A PcigLaae PHS(049 MED SOV-5021 68' MEZZ Across from phone 98' PAB SHUT 3A Packing Leakage PAH2S (208479)

MOO ROOM SU A PcigLaae PHS(049 80' PAB 80' PAB OPEN 3A Air coming from PAH2S (208479)

HI 5130 SAMPLE CELL Backleftcorner SAMPLE CELL vent at Pa 98' PAB MED SOV-5022 68' MEZZ Across from phone MOO ROOM SHUT 3A Packing Leakage PAH2S (208479) 98' PAB MED SOV-5023 68' MEZZ Across form phone MOO ROOM SHUT 3A Packing Leakage PAH2S (208479)

HI 5129 68' MEZZ Across from phone 68' MEZZ OPEN 3A Air coming from PAH2S (208479) vent at Pa 98' PAB MED SOV-5024 68' MEZZ Across from phone MCC ROOM I SHUT 3A Packing Leakage PAH2S (208479)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 182 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 4 of 12)

RISK COMPONENT AREA FIELD CONTROL TEST ATTACH CHECK FOR: SYSTEM LOCATION LOCATION POSITION MED 1728 51' PIPE PEN Section1 below I I190's CCR SNF SHUT 3A SeatWDS Leakage piping into WDS (9321-2719)

MED 1723 51' PIPE PEN Sectionw1' CCR SNF SHUT 3A Seat Leakage into below 1190's WDS piping WDS (9321-2719)

LO 1702 51' PIPE PEN Section 3 CCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

_________Right side of ladderI LO 1705 51' PIPE PEN RightSection side of 3ladder OCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

MED 1788 51' PIPE PEN Section 5 CCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

Above letdown pen I MED 1789 51' PIPE PEN Section 5 CCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

Above letdown pen ______

LO 1786 51' PIPE PEN Section 5 CCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

Above letdown pen ____ I______

LO 1787 51' PIPE PEN Section 5 OCR SNF SHUT 3A Packing Leakage WDS (9321-2719)

Above letdown pen CUInLag W (

VLO 859A 51' PIPE PEN Section 1 Bonnet, Packing SI (9321-2735)

By Alt Seal Inj Filter 51' PIPE PEN SHUT 3A Leakage, water VLO 8590 51' PIPE PEN Section 1 Bonnet, Packing S (9321-2735)

VLO_ 859C_ _1'_PIPEPN By Alt Seal Inj Filter 51' PIPE PEN SHUT 3A Leakage, water

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 183 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 5 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LO LOCATION LOCTION LOCATION POST POSITION ATTACH CHECK FOR: SYSTEM VLO MOV-850A 59' PAB SI Pump Cell 98' PAB SHUT 3A Bonnet, Packing SI (9321-2735)

MCC ROOM SHUT Leakage, water VLO MOV-850B 59' PAB SI Pump Cell 98' PAB SHUT 3A Bonnet, Packing SI (9321-2735)

MCC ROOM Leakage, water VLO MOV-851A 59' PAB SI Pump Cell CCR SBF-2 SHUT 3A Bonnet, Packing SI (9321-2735)

Leakage, water VLO MOV-851B 59' PAB SI Pump Cell CCR SBF-2 SHUT 3A Bonnet, Packing SI (9321-2735)

Leakage, water MOV-869A 68'MEZZ Section 1 98' PAB SHUT 3A Bonnet, Packing SI (9321-2735)

VLO MO-8 6'MEOverhead MCC ROOM Leakage, water VLO MOV-869B 68'MEZZ Section 1 98' PAB SHUT 3A Bonnet, Packing SI (9321-2735)

Overhead MCC ROOM Leakage, water VLO MOV-866A 68'PAB 21CSPUMP OCR SBF-1 SHUT 3A Bonnet, Packing SI (9321-2735)

VLO_____ __OV-866A__ 68'____PAB_ 2_SUP__B- SH 3A__ _ Leakage, water VLO MOV-866B 68' PAB 21 CS PUMP CCR SBF-1 SHUT 3A Bonnet, Packing SI (9321-2735)

___________ __________ _________ ________ Leakage,_waler___________

VLO 878A 68' PAB By Spray Pumps 68' PAB SHUT 3A Bonnet Packing SI (9321-2735) water nLeakage, VLO 878B 68' PAB By Spray Pumps 68' PAB SHUT 3A Bonnet, Packing SI (9321-2735)

________________ ______________ _________________ ______ Leakage,_water

No:2-PT-"1 YQ0l Rev:*02 INTEGRATED LEAK RATE TEST Page 184 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 6 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LO LOCATION LOCTION LOCATION POST POSITION ATTACH CHECK FOR: SYSTEM VLO MOV-866C 68' PAB 22 CS PUMP CCR SBF-1 SHUT 3A Leakage, water SI (9321-2735)

VLO MOV-866D 68'PAB 22 CS PUMP CCR SBF-1 SHUT 3A Bonnet, Packing SI (9321-2735)

V MS 6 6 APRB Leakage, water VLO MOV-888A 51' PIPE PEN' LightHPBlue valve by camera CCR SBF-1 SHUT 3A Bonnet, Leakage,Packing SI (9321-2735) water VLO MOV-888B 51' PIPE PEN' Light Blue valve by CCR SBF-1 SHUT 3A onnet, Packing SI (9321-2735)

HP camera Leakage, water VLO MOV-885A 35' PAB SWC Right at bottom CCR SBF-1 SHUT 3A Bonnet, Packing Leakage, water SI (9321-2735)

VLO MOV-885B 35' PAB SWC Right at bottom CCR SBF-1 SHUT 3A Bonnet, Packing SI (9321-2735)

_________________________ _________Leakage, water VHI 863 80' PAB By doors to CCR SHUT 3C Packing Leakage N2 (9321-2723)

Fan House LO 1809 80 PAB By doors to 80' PAB SHUT 3C Packing Leakage N2 (9321-2723)

Fan House VHI N-784 80' PAB By doors to 80'PAB OPEN 3C Air coming from N2 (9321-2723)

Fan House vent at Pa Bank isolation in Test Boundary; LO 1811-A 80' PAB overhead 80' PAB SHUT 3C Seat Leakage of N2 (9321-2723) overhead_ system pressure Bank isolation in Test Boundary; LO 1811-B 80' PAB overhead 80' PAB SHUT 30 Seat Leakage of N2 (9321-2723) 1 ov d 1 1 system pressure

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 185 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 7 of 12)

RISK COMPONENT AREA FIELDATTACH CHECK FOR: SYSTEM LOCATION LOCATION POSITION Section 2 Section 2 Test Boundary; LO 1655 51' PIPE PEN 3/4Wblue valve v/" blue valve SHUT 3C Seat Leakage of N2 (9321-2723)

__ system pressure MED SOV-3418 51 PIPE PEN Section1 98' PAB SHUT 3C N2 (9321-2738)

MED___ OBy Alt Seal Inj Filter MCC ROOM Section'1 98' PAB SHUT 3C N2 (9321-2738)

MED SOV-3419 51' PIPE PEN By Alt Seal Inj Filter MCC ROOM MED136 51' IPEPEN Sectioni MED 4136 51'PIPE PEN At Seal Inj Filter 51' PIPE PEN SHUT 3C Packing Leakage N2 (9321-2738)

ByAtSeation1 Airiomngero HI 4160 51' PIPE PEN Sectioni 51' PIPE PEN OPEN 3C Air cming from By Alt Seal Inj Filter vent at Pa 1659 51'PIPE PEN Section 2 Section 2 SHUT 3C Packing Leakage N2 (9321-2719),

LO 165 5' IP PN " blue valve 1W blue valve (9321-2723) 51'PIPE PEN Section 5 98' PAB N2 (9321-2738),

Above FCU, column MCC ROOM (9321-2723)

Section 5 98' PAB N2 (9321-2738),

MED SOV-3417 51'PIPE PEN Above FCU, column MCC ROOM SHUT 3C (9321-2723)

MED 4591' IPE EN ectin~Section Section 5 Seiove F 5

, SN2 MED 5459 (9321-2738),

51'PIPE PEN Above FCU, column Above FCU, SHUT 3C Packing Leakage (9321-2723) column Air coming from N2 (9321-2719),

VHI VENT 51 PIPE PEN AT PCV-1014 AT PCV-1014 OPEN 3C break in Swagelok (9321-2723) 1__________at Pa LO 548 51' PIPE PEN

____________ ~~aboveSection letdown 5 CCR SNF SHUT pen_______________________

3C Packing Leakage RCS (9321-2738)

LO 549 51' PIPE PEN Section 5 OCR SNF SHUT 3C Packing Leakage RCS (9321-2738) above letdown pen CCRISNF _SHUT 3C PackingLeakage RCS_(9321-2738)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 186 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 8 of 12)

RISK COMPONENT AREA FIELD CONTROL TEST ATTACH CHECK FOR: SYSTEM LOCATION LOCATION POSITION Seal lnj 1Filter LO 519 51' PIPE PEN 3B Packing Leakage RCS (9321-2738)

NearSection CCR SAF SHUT 1052 51 PIP PEN Section 1 LO 552 51'PIPE PEN ear Seal inj Filter CCR SAF SHUT 3B Packing Leakage RCS (9321-2738)

LO SA-24 51' PIPE PEN Section 11Section Secton Near Seal I Inj SHUT 3C Packing Leakage SA (9321-2035)

Near Seal Inj Filter Filter ESection 1 Section 1 LO SA-24-1 51' PIPE PEN Sein Near Seal Inj SHUT 3C Packing Leakage SA (9321-2035)

Near Seal Inj Filter Filter Section I ~ Section 1Aicongfm VLO VENT 51' PIPE PEN Near Section 1 Near Seal Inj OPEN 3C Air coming from SA (9321-2035)

Seal lnj Filter Near Filter vent at Pa HI PCV-1228 51' PIPE PEN Section 1 CCR SNF SHUT 3C Packing Leakage ]A (9321-2036)

Below 1190's Section 1 Section 1 Test Boundary:

LO IA-501 51' PIPE PEN Below 1190's Below 1190's SHUT 3C Seat Leakage of IA (9321-2036) system pressure VHI IA-503 51' PIPE PEN Section 1 Section 1 OPEN 3C Air coming from IA(9321-2036)

Below 1190's Below 1190's vent at Pa VHI FCV-1171 80' PAB 1170's Room OCR SLF SHUT 30 Packing Leakage, VENTILATION Outside by 80' Airlock seat leakage (9321-4022) 1170's Room 1VENTILATION MED PCV-1110-3 80' PAB Outside by 80' Airlock Outside by 80' SHUT 3C Packing Leakage (9321-4022)

Airlock CC LF SU C Packing Leakage, VENTILATION VHI VH C-13 FCV-1173 8'PB 80' PAB 1170'sFRoom 1170's SHRoom Outside by 80' Airlock seat leakage (9321-4022) 1170's Room 1VENTILATION MED PCV-1110-4 80' PAB Outside by 80' Airlock Outside by 80' SHUT 3C Packing Leakage (9321-4022)

Airlock I-

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 187 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 9 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LOCATION LOCATION POSITION ATTACH CHECK FOR: SYSTEM MED PCV-1 191 51'PIPE PEN COR SLF SHUT 3A Packing Leakage, VENTILATION ByV alseat leakage (9321-4022)

PCV-1192 51' PIPE PEN CCR SLF SHUT 3A Packing Leakage, VENTILATION MED By VC wall seat leakage (9321-4022)

Section 1 SectionPacking Leakage VENTILATION By VC wall On VC wall leakage (9321-4022)

Section 1 Section 1 SHUT 3A Packing Leakage VENTILATION LD PCV-1 110-8 51' PIPE PEN By VC wall On VC wall (9321-4022)

SeSection5ctNonS SAMPLAIONG MOV-956A 51' PIPE PEN boeVCn O5CCR SNF SHUT 38 Packing Leakage (9321-7402)

VLO Section 5 NSSS SAMPLING VLO MOV-956A 51' PIPE PEN Above 888's CCR SNF SHUT 3B Packing Leakage (9321-2745)

VLO MV956C 51' PIPE PEN Above 888's CCR SNF SHUT 3B watkn erkg (9321-2745)

Section 5 NSSS SAMPLING Section 5 Packing Leakage, NSSS SAMPLING VL 5D 5'IEPN Above 888's CCSF SU Bwater (9321-2745)

VLO MOV-990A 68'MEZZ Acorss from phone 80'SENTRY SHUT 3B Packing Leakage, NSSS SAMPLING PANEL water (9321-2745)

VLO MOV-990B 68' MEZZ Across from phone 80' SENTRY SHUT 3B Packing Leakage, NSSS SAMPLING PANEL water (9321-2745)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 188 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 10 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LO LOCATION LOCTRON LOCATION POST POSITION ATTACH CHECK FOR: SYSTEM VLO 956E 68'MEZZ Across from phone CCR SNF SHUT 3B Packing NSSS SAMPLING Leakage, water (9321-2745)

VLO 956F 68'MEZZ Across from phone CCR SNF SHUT 3B Packing NSSS SAMPLING Leakage, water (9321-2745)

Ars from RakSection 1 CR SN SHUT 38 Packing NSSS SAMPLING Across from Rack 11 P Leakage, water (9321-2745)

VLO 956H 51' PIPE PEN SectionCCR SNF SHUT 3B Across from Rack 11 Leakage, water (9321-2745)

VLO MOV-958 51 PIPE PEN Section 5 98' PAB Packing NSSS SAMPLING Under EL-51 MCC ROOM Leakage, water (9321-2745)

VLO MOV-959 68'MEZZ Across from phone 80' PAB SHUT 3B Packing NSSS SAMPLING SENTRY PANEL Leakage, water (9321-2745)

VLO 9900 68'MEZZ Across from phone 68'MEZZ SHUT 3B Packing NSSS SAMPLING VL_9DEAcossfrmpon 68_SHUT 3 Leakage, water (9321-2745)

HI PCV-1229 51' PIPE PEN Section 5 CCR SNF SHUT 3A Packing COND AIR REMOVAL Big Red Valve Leakage (9321-2025)

HI PCV-1230 51' PIPE PEN Section CCR SNF SHUT 3A Packing COND AIR REMOVAL Big Red Valve Leakage (9321-2025)

HI VENT 36'9"TH 20 ft downstream 20 ft downstream OPEN 3A Air coming from COND AIR REMOVAL of Blower of Blower vent at Pa (9321-2025)

Section 3 98'PAB Packing HI E-2 51' PIPE PEN Right Off Ladder MCCROOM SHUT 3A Leakage PACV (208879) on Left MCCIROOM SHUT 3A Ieakage

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 189 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 11 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LOCATION LOCATION POSITION ATTACH CHECK FOR: SYSTEM Section 3 98' PAB HI E-1 51' PIPE PEN Right Off Ladder MCC ROOM SHUT 3A Packing Leakage PACV (208879) on Left Section 3 98' PAB HI E-3 51' PIPE PEN Right Off Ladder MCC ROOM SHUT 3A Packing Leakage PACV (208879) on Left Section 3 98'PAB HI E-5 51' PIPE PEN Right Off Ladder MCC ROOM SHUT 3A Packing Leakage PACV (208879) on Left Section 3 98'PAB HI EA-1 51' PIPE PEN 6" prior to ladder on MCC ROOM SHUT 3A Packing Leakage PACV (208879)

Left 51' SGBD 51' SGBD Aicongfm VHI E-8 ROOM 51'SGBD Room Room OPEN 3A ircoming from PACV (208879)

ROOMRoomvent at Pa VHI E-9 51'SGBD 51'SGBD Room 51'Room SGBD OPEN 3A Air vent coming PACV (208879)

ROOM at Pafrom VLO 4399 51'PIPE PEN Section Understairs 1 Mezz from 80' PAB Sentry Panel SHUT 38 Packing Leakage Samp (227178)

VLO 5132 51' PIPE PEN Section 1 80' PAB SHUT 31 Packing Leakage Samp (227178)

Understairs from Mezz Sentry Panel Section 3 Aux Stm and Cond LO UH-43 51' PIPE PEN Across from ladder 51' PIPE PEN SHUT 38 Packing Leakage (9321-2027)

LO UH-44 51' PIPE PEN Section Across 3 from ladder 51' PIPE PEN Aux(9321-2027)

Stm and Cond SHUT 38 Packing Leakage HI IIP-500 51' PIPE PEN Section 3 Against Wall (Fire VC Blanket) 51 PIPE PEN 51_PPEPESU SHUT 3A 3A Packing Leakage PackingLeakage SSD Xmtr (308762)

SSDXmtr_(308762)

HI IIP-501 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PIPEPEN _SHUT 3A PcigLkeSt_386

No:2-PT-10YOO1 Rev:02 INTEGRATED LEAK RATE TEST Page 190 of 208 ATTACHMENT 13 CONTAINMENT BUILDING PENETRATION WALKDOWN (Page 12 of 12)

FIELD CONTROL TEST RISK COMPONENT AREA LOCATION LOCATION POSITION ATTACH CHECK FOR: SYSTEM HI IIP-502 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A Packingg Leakage 550 Xmtr (308762)

Wall (Fire Blanket) 5 I ETP k S t0 HI IIP-503 51' PIPE PEN Section 3 AgainstVC 51' PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket)____________________

HI IIP-504 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A 3A Packing Leakage PackingLeakage SSD Xmtr (308762)

SSDXmtr_(308762)

Wall (Fire Blanket) 51'_PIPE _EN_SHUT HI IIP-505 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket)_________________

HI IIP-506 51' PIPE PEN Scin3AantV 3 Against V SSection 51' PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PiPE SHU_3 _EN Pakigeaag____mt __0862 HI IIP-507 51' PIPE PEN Section 3 Against VC 51' PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PIPE SHU_3 _EN Pakigekae__Dtr(3872 HI IIP-508 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket) 51_iPEN SU 3A PakigeaagSD _mt_(0862 HI IIP-510 51' PIPE PEN Section 3 Against VC 51'PIPE PEN SHUT 3A Packing Leakage 550 Xmtr (308762)

Wall (Fire Blanket) 51_IPEN SU 3A _PackigLeakag SSDXmtr_(308762)

HI IIP-512 51' PIPE PEN Section 3 Against Wall (Fire VC Blanket) 51'PIPE 51_IPEN PEN SHUT SU 3A 3A Packing Leakage PakngakgSD SSD Xmtr (308762)

_mr _3872 HI IIP-514 51' PIPE PEN Section 3 Against VC 51' PIPE PEN SHUT 3A Packing Leakage SSD Xmtr (308762)

Wall (Fire Blanket) _____ _______________

VHI IIP-509 51'PIPE PEN Section 3 Against VC 51' PIPE PEN OPEN 3A Air coming from SSD Xmtr (308762)

VI_-0_51PP PN Wall (Fire Blanket) vent at Pa VHI IIP-511 51' PIPE PEN Section 3 Against VC 51' PIPE PEN OPEN 3A Air coming from SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PIPE PEN _OPEN 3A vent at Pa VHI IIP-513 51' PIPE PEN Section 3 Against VC 51' PIPE PEN OPEN 3A Air coming from SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PIPE PEN _OPEN 3A vent at Pa VHI IIP515 51' PIPE PEN Section 3 Against VC 51'PIPE PEN OPEN 3A Air coming from SSD Xmtr (308762)

Wall (Fire Blanket) 51'_PIPE PEN _OPEN 3A vent at Pa

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 191 of 208 ATTACHMENT 14 CONTROL ROOM LOG (Page 1 of 2)

HOURLY READINGS:

RECORD the following readings to provide potential correlations between any leakage change and changes in the containment net free volume. Manually recording these readings is NOT required IF a Trend Report is established on the Plant Computer. IF manual readings are taken, THEN RECORD hourly. ATTACH Trend Report printouts to Attachment 16, Computer Printouts and Attachments.

Rx Sump Containment Recirc PRT PZR I RCDT Level Sump Sump Level MLMS Level Level Initial Value TIME I I I I 4.

.4 * + 4 .4-I 4 -+ -4 F +

1 4 -4 F +

I I I I F 4 Make additional copies if necessary.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 192 of 208 ATTACHMENT 14 CONTROL ROOM LOG (Page 2 of 2)

START AND END OF ILRT HOLD READINGS:

The following readings are required at the start and end of the ILRT Hold Test, and will be used in Attachment 15, ILRT Results Summary to correct the ILRT results for any influence volume changes may have had on the leakage rate.

TANK/VOLUME LEVEL CHANGE START END DESCRIPTION CHANGE (Gallons)

RX SUMP LEVEL (FT):

CONTAINMENT SUMP (FT):

RECIRC SUMP (FT):

PRT LEVEL (%):

PZR (%) I MLMS (FT IN):

RCDT (%):

TOTAL CHANGE (TG):

START AND END OF VERIFICATION TEST READINGS:

The following readings are required at the start and end of the Verification Test, and will be used to correct the Verification Test results for any influence volume changes may have had on the leakage rate.

TANK/VOLUME START END LEVEL CHANGE DESCRIPTION CHANGE (Gallons)

RX SUMP LEVEL (FT):

CONTAINMENT SUMP (FT):

RECIRC SUMP (FT):

PRT LEVEL (%):

PZR (%) MLMS (FT IN):

RCDT (%):

TOTAL CHANGE (TG):

Conversion Factors:

1 inch change in RX SUMP level = gallons 1 inch change in CONTAINMENT SUMP level = gallons 1 inch change in RECIRC SUMP level = gallons 1% change in PRT level = gallons 1% change in PRESSURIZER level = gallons 1 inch change in MLMS = gallons 1% change in RCDT level = gallons

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 193 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 1 of 8) 1.0 VOLUME CHANGE CORRECTIONS 1.1 QUANTIFY VOLUME CHANGES:

1.1.1 Data comes from Attachment 14, Control Room Log. Maintain the correct sign convention throughout this calculation, as we are correcting for the net change in free volume (i.e. some levels may go up, others may go down). A reduction in tank level is NEGATIVE, conversely a rise in a tank or sump level is POSITIVE. Ultimately, the changes will be converted to a

%wt/day correction.

1.1.2 NET LEVEL DECREASE: IF the net change was negative, the containment net free volume increased, causing the pressure to drop and the leakage to look larger than it should have. In this case a SUBTRACTION is allowed from the ILRT leakage rate results.

1.1.3 NET LEVEL INCREASE: Conversely, if the net level change was positive, the containment net free volume decreased, masking the actual leakage and an ADDITION is required.

Net volume change from Attachment 14 in gallons: GALLONS 1.2 CONVERT GALLONS TO FT 3 CHANGES:

Record ILRT duration (hours) = (t) Duration = hrs Calculate net volume change in ft 3/day:

dV = (TG/t) (24 hrs/day) (lft3 / 7.48 gal.)

Where: dV = net containment volume change TG = sum of level changes in gallons (from table above) t = test duration in hours dV = (_ gallons/ hours) (24) (0.13367 ft3 / gallon) dV = ft3 / day

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 194 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 2 of 8) 1.3 CALCULATE NET FREE VOLUME CHANGE IMPACT IN %WT/DAY:

LV = (dV* Pt* C

100)/(R* T* W)

Where: LV is the volume change in %wtlday dV is the net volume change in ft3 / day from Step 1.2 Pt is the average containment pressure during the ILRT in psia 2 2 C is the conversion factor, 144 in / ft R is the gas constant for air = 53.35 ft Ibf / Ibm OR T is the average containment temperature in OR W is the average weight of the containment air in Ibm (use intercept of least squares fit line)

LV=(_

__= *144

100) / (53.35" ___ *_

Step B Pt T W LV = %wt/day

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 195 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 3 of 8)

NOTE Reference Step 1.1.1 of this Attachment for guidance pertaining to sign convention and addition/subtraction requirements.

2.0 PRELIMINARY TYPE B & C PENALTY ADDITIONS 2.1 Total of as-left MNPLR for penalty additions from Attachment 9, Containment Penetration Summary:

Total Penalty Addition (sccm):

2.2 Convert the MNPLR Penalty Addition to Ibm/day:

Penalty Addition = ( sccm)(lscf/28,317scc)(0.07517 Ibm/scf)(1440 min/day)

Penalty Addition (in Ibm/day) =

2.3 Convert the Ibm/day Penalty Addition to %wtlday value:

Penalty Addition (in Ibm/day) = ( Ibm/day

100) / initial containment Step 2.2 air mass (Ibm)

Penalty Addition (%wt/day) =

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 196 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 4 of 8) 3.0 PRELIMINARY LEAKAGE SAVINGS CALCULATION 3.1 Total of leakage savings for as-found ILRT calculation from Attachment 9, Containment Penetration Summary:

Leakage Savings Addition (sccm):

3.2 Convert the Leakage Savings Addition to Ibm/day:

Leakage Savings Addition = (. sccm)(lscf/28,317scc)(0.07517 lbm/sco(1440 min/day)

Leakage Savings Addition (in Ibm/day) =

3.3 Convert the Ibm/day Leakage Savings Addition to %wt/day value:

Leakage Savings Addition (in Ibm/day) = ( Ibm/day

100)/ initial containment Step 3.2 air mass (Ibm)

Leakage Savings Addition (%wt/day) =

(This calculation will need to be repeated, COPY this page as necessary)

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 197 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 5 of 8) 4.0 FINAL TYPE B & C PENALTY ADDITIONS 4.1 The ILRT is being performed at the beginning of the outage. The preliminary ILRT results will be based on existing local leakage rate results, some of which may be replaced with tests performed after the ILRT. When all local leakage rate testing is completed, enter the results on Attachment 9, Containment Penetration Summary and calculate the total of as-left MNPLR for penalty additions:

Total Penalty Addition (sccm):

4.2 Convert the MNPLR Penalty Addition to Ibm/day:

Penalty Addition = ( sccm)(1scf/28,317scc)(0.07517 Ibm/scf)(1440 min/day Penalty Addition (in Ibm/day) =

4.3 Convert the Ibm/day Penalty Addition to %wt/day value:

Penalty Addition (in Ibm/day) = ( Ibm/day

100) / initial containment Step 4.2 air mass (Ibm)

Penalty Addition (%wt/day) =

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 198 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 6 of 8) 5.0 FINAL LEAKAGE SAVINGS CALCULATION 5.1 The ILRT is being performed at the beginning of the outage. The preliminary ILRT results will be based on existing local leakage rate results, some of which may be replaced with tests performed after the ILRT. If maintenance is perfomed on components NOT exposed to the ILRT test pressure, any leakage savings must be included in the Final As-Found ILRT results. When all local leakage rate testing is completed, enter the results on Attachment 9, Containment Penetration Summary and calculate the total leakage savings for as-found ILRT calculation from Attachment 9, Containment Penetration Summary:

Leakage Savings Addition (sccm):

5.2 Convert the Leakage Savings Addition to Ibm/day:

Leakage Savings Addition = ( sccm)(1scf/28,317scc)(0.07517 lbm/scf)(1440 min/day)

Leakage Savings Addition (in Ibm/day) =

5.3 Convert the Ibm/day Leakage Savings Addition to %wt/day value:

Leakage Savings Addition (in Ibm/day) = ( Ibm/day

100)/ initial containment Step 5.2 air mass (Ibm)

Leakage Savings Addition (%wtlday) =

(This calculation may need to be repeated COPY this page as necessary)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 199 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 7 of 8) 6.0 PRELIMINARY AS-LEFT ILRT RESULTS:

CHECK box for results used to accept ILRT 6.1 MEASURED MASS POINT (ANSI 56.8-11994)

TOTAL TIME (BN-TOP-1) 1-z LEAKAGE: N/A 6.2 REGRESSION LINE LEAKAGE Lam:

6.3 LEAKAGE AT 95%UCL:

6.4 MNPLR Penalty Additions (from 2.3) 6.5 Volume Change Lul Correction (from 1.3) 6.6 PRELIMINARY AS-LEFT ILRT Result:

7.0 PRELIMINARY AS-FOUND ILRT RESULTS USE results used to accept ILRT 7.1 AS-LEFT ILRT MASS POINT (ANSI 56.8-1994) LI TOTAL TIME (BN-TOP-1)

LII RESULT (from 6.6): N/A 7.2 LEAKAGE SAVINGS (from 3.3):

7.3 PRELIMINARY AS-FOUND ILRT Result:

LIIIIII IZZ

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 200 of 208 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 8 of 8) 8.0 FINAL AS-LEFT ILRT RESULTS CHECK box for results used to accept ILRT MASS POINT TOTAL TIME (ANSI 56.8-1994) (BN-TOP-1) 8.1 MEASURED LEAKAGE: N/A 8.2 REGRESSION LINE LEAKAGE Lam:

8.3 LEAKAGE AT 95%UCL:

8.4 MNPLR Penalty Additions (from 4.3) 8.5 Volume Change Correction (from 1.3) 8.6 FINAL AS-LEFT ILRT Result:(<75%L.)

9.0 FINAL AS-FOUND ILRT RESULTS USE results used to accept ILRT MASS POINT (ANSI 56.8-1994) DTOTAL TIME (BN-TOP-1) 9.1 AS-LEFT ILRT RESULT (from 8.6): N/A 9.2 LEAKAGE SAVINGS (from 5.3):

9.3 FINAL AS-FOUND ILRT Result:

L IZI

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 201 of 208 ATTACHMENT 16 COMPUTER PRINTOUTS AND ATTACHMENTS (Page 1 of 1)

The purpose of this Attachment is to provide a single location in the procedure for collecting computer printouts from the plant computer trend report, the ILRT data management computer and other sources.

LIST OF PRINTOUTS AND ADDITIONAL ATTACHMENTS:

0 0

Make additional copies if needed.

No:2-PT-10YO01 Rev;02 INTEGRATED LEAK RATE TEST Page 202 of 208 ATTACHMENT 17 GAUGE INSTALLATION I REMOVAL SHEET (Page 1 of 5)

Test gauges are used in various locations to monitor pressure in various spaces/voids as an early indication of leakage from containment, or to indicate leakage between boundaries. The ILRT Test Supervisor may direct installation of additional test gauges when troubleshooting potential leakage paths. Use this attachment to document Cal Due data, installation and removal of these test gauges.

1.0 DOCUMENT GAUGE DATA:

GAUGE CAL RANGE INSTALLED REMOVED V SERIAL# DUE (1) LOCATION/PURPOSE (Initials/Date) (Initials/Date) 0-60 psig Monitor SIG #21 for in-leakage at valve 0-60 psig Monitor SIG #22 for in-leakage at valve 0-60 psig Monitor S/G #23 for in-leakage at valve 0-60 psig Monitor S/G #24 for in-leakage at valve Monitor space between PCV-1 170 & 1171 0-60 psig at WCP-1 19 Monitor space between PCV-1 172 & 1173 0-60 psig at WCP-1 18.

(1) A different gauge range may be used at the discretion of the Test Supervisor.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 203 of 208 ATTACHMENT 17 GAUGE INSTALLATION I REMOVAL SHEET (Page 2 of 5) 2.0 INSTALL GAUGES:

2.1 To INSTALL Steam Generator pressure gauges perform the following:

INIT 21 Steam Generator

1. CLOSE MS-74A, Test PI Stop on Stm Line 21.

2. REMOVE downstream plug.

3. INSTALL test gauge downstream of MS-74A.

4. OPEN MS-74A.

22 Steam Generator

1. CLOSE MS-74B, Test PI Stop on Stm Line 22.

2. REMOVE downstream plug.

3. INSTALL test gauge downstream of MS-74B.

4. OPEN MS-74B.

23 Steam Generator

1. CLOSE MS-74C, Test P1 Stop on Stm Line 23.

2. REMOVE downstream plug.

3. INSTALL test gauge downstream of MS-74C.

4. OPEN MS-74C.

24 Steam Generator

1. CLOSE MS-74D, Test PI Stop on Stm Line 24.

2. REMOVE downstream plug.

3. INSTALL test gauge downstream of MS-74D

4. OPEN MS-74D.

No:2-PT-10Y001 Rev:02 INTEGRATED LEAK RATE TEST Page 204 of 208 ATTACHMENT 17 GAUGE INSTALLATION / REMOVAL SHEET (Page 3 of 5) 2.2 To INSTALL 1170's pressure gauges perform the following:

INIT Space Between PCV-1170 & 1171 at WCP-119

1. REMOVE cap from test connection WCP-1 19.

2. INSTALL test gauge on test tap at WCP-1 19.

3. OPEN WCP-119.

Space Between PCV-1172 & 1173 at WCP-118

1. REMOVE cap from test connection WCP-1 18.

2. INSTALL test gauge on test tap at WCP-1 18.

3. OPEN WCP-118.

2.3 IF Pressure Gages are directed to be installed to troubleshoot leakage, THEN the following guidance should be used for installation.

Troubleshoot Gauge Installation

1. CLOSE root stop OR gauge isolation.

2. REMOVE any installed instrumentation.

3. INSTALL gauge as directed by Test Supervisor.

4. OPEN valve closed in step 1.

5. RECORD gauge info on data on Gauge Data table.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 205 of 208 ATTACHMENT 17 GAUGE INSTALLATION I REMOVAL SHEET (Page 4 of 5) 3.0 REMOVE GAUGES:

3.1 To REMOVE Steam Generator pressure gauges PERFORM the following:

INIT 21 Steam Generator

1. CLOSE MS-74A, Test PI Stop on Stm Line 21 _(V)

2. REMOVE test gauge downstream of MS-74A.

3. REINSTALL plug. _(V) 22 Steam Generator

1. CLOSE MS-74B, Test PI Stop on Stm Line 22.

_(V)

2. REMOVE test gauge downstream of MS-74B.

3. REINSTALL plug.

23 Steam Generator

_(V)

1. CLOSE MS-74C, Test PI Stop on Stm Line 23.

2. REMOVE test gauge downstream of MS-74C.

_(V)

3. REINSTALL plug.

24 Steam Generator

_ (V)

1. CLOSE MS-74D, Test PI Stop on Stm Line 24.

_(V)

2. REMOVE test gauge downstream of MS-74D.

3. REINSTALL plug.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 206 of 208 ATTACHMENT 17 GAUGE INSTALLATION / REMOVAL SHEET (Page 5 of 5) 3.2 To REMOVE 1170's pressure gauges perform the following:

INIT Space Between PCV-1170 & 1171 at WCP-119

1. CLOSE WCP-119.

2. REMOVE test gauge downstream of WCP-119.

3. REINSTALL cap.

Space Between PCV-1172 & 1173 at WCP-118

1. CLOSE WCP-118.

2. REMOVE test gauge downstream of WCP-1 18. .(V)

3. REINSTALL cap. (V) 3.3 IF Pressure Gages are directed to be installed to troubleshoot leakage, THEN the following guidance should be used for installation.

Troubleshoot Gauge Removal

1. CLOSE root stop OR gauge isolation. .(V)

2. REMOVE any installed instrumentation. -(v)

3. INSTALL instrumentation removed during installation. .(V)

4. IF required, THEN OPEN valve closed in step 1. __ _C)

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 207 of 208 ATTACHMENT 18 TEST GAUGE PRESSURE READINGS (Page 1 of 1)

TIME 21 SIG 22 SIG 23 SIG 24 SIG 1170/71 1172173 Initial value Copy as needed for additional sheets.

No:2-PT-10YO01 Rev:02 INTEGRATED LEAK RATE TEST Page 208 of 208 ATTACHMENT 19 VC AOV FAILURE POSITION LIST (Page 1 of 1)

VALVE DESCRIPTION FAIL POSITION Valves Expected to Remain AS IS PCV-455A, B Pressurizer Spray Valve LCV-459 Letdown Isolation Valve RHR Loop Bypass to Demin Flow Control HCV-133Vav Valve 246 RCP #1 Seal Bypass 213 Excess Letdown Stop Valve HCV-123 Excess Letdown Flow Control Valve 212 Auxiliary Spray 891s*, 896s, 890s SI Accumulator Valves FAILS CLOSED 839A-H SI Test Valves HCV-943 Accumulator Vent FCV-1170, 1172 Inside VC Purge & Exhaust Valves PCV-1 190 Pressure Relief Valve 516 PRT Vent to Vent Header 523 Pressurizer Relief Tank Drain 560 Primary Water Isolation to PRT 1609 RCDT to VC Sump Drain 215 Excess Letdown Diversion Valve FAILS TO VCT

-*FCV-21, 22, 23, 24, 25 CNTMT Recirc Fan Norm Outlets FAILS OPEN Valves Expected to REPOSITION 200A, B, C Letdown Control Valves 955C-F, 951,953 Accumulator and RCS PZR Samples FAILS CLOSED 553A, B, C, D Primary Water To RCP Standpipes 204A, B Alternate & Normal Charging Isolations 261A, B, C, D RCP Seal Return Isolation FAILS OPEN 544 Flange Seal Leak Detector Isolation

891A through D will be blocked OPEN for SIS Accumulator protection.

- CRF Normal Outlets will be positioned to OPEN per Attachment 3A.

MATERIALS FOR REQUEST FOR INFORMATION SCVB RAI-4

1. ILRT 1984-As found Type B and C

2. ILRT 1987 - As found total

3. ILRT 1991 -As found total

4. ILRT 2006 - As found Information

9.0 Comments

(Include any MWR Numbers with descriptions, if issued).

LYS iA466 b&o /x d' SAt"It!,- /4-dZ- '

=0 0 1- C1

~

A-A ~ ~ A il 4--1&- d~~o 24%6~ ~

If If 9, A r- U" ^I

-*V v' /% L

__ _ __ _ __ CFM -14 I $c,-FA, IPA__

eo' ^ 1 9J. Lok V-A ___ 96o62,6

__ .16 ______

22 '44v c-~/e- c,'-1r _____ 06__V6 10oo5o006zf ft -c eL ejg ,Sb2 0/// _ __ _ _ __

U- "-fOOZI.., -i~ -o *,aO~4j

? ,o~

0.N 7___ __^__ __ _ /,/I ,/ o etcr. CIZ'4 a, If Z7i~-z------..~ 1 7. nft 7~~~~,vL~~r .Jh 'ts 746#1*-

vr --I', P.?S'Y?

9 vb I eds- 6 E.-,514 e-eA PT-3Y1-29

12.0 Equipment Operability and Acceptance Criteria C~'3' Operability Criteria The Integrated Leak Rate Test shall be considered satisfactory if as recorded in the Test Results the "As Found" condition meets the criteria required in the test results.

The following is to be completed by the Senior Watch Supervisor:

12.1 Based on a review of the Test Results, are the Operability Criteria satisfied? b\*

YES 12.2 If the Operability Criteria are not satisfied:

a) Take the required Technical Specification action.

b) An'SOR shall be prepared. SOR # A/or vQI/TriV) 12.3 Comments: Y/'1/4OXr-* 4- A/v C- *J R 0.

S'eniorfJtch Supervisor / Date 12.4 If Operability Criteria are not satisfied, COE Review required.

Rý! v i ew- / Date RETURN COMPLETED TEST TO THE TEST ENGINEER A cg47 Wer 45~ ,J/1 0J 6wi E&4s6A D.) Ad Itl~-l , f&?I~-9AmIcij

8.3 Post-Test Conditions (Order of accomplishment to be determined by ILRT Project Manager).

3.3.1 Disconnect and remove air compressors.

8.3.2 Drain aftercoolersi and refigerant dry,'ers and lay-up per the manufacturer's recommendations.

8.3.3 Close all the valves in the pressurization system arid instrumentation system.

8.3.4 Disconnect and store all components of th~e pressurization and instrumentation sy.stem foa, future testing. Take alI necessary prezauzions for ;a'il-rJp instrumentation and equipment for use on the ne.ýt ILLT.

8.3.s De-energize all test electrical circuits.

8.3.8 Remove RHDs and RTDs. Service the units for ions te'rrr storage and put them in storage. Disconnect rTD and RH-electrica: leads at penetrations HS, and HL8. Reemov.

and store temporary wiring, RTD and RHD extensions cables inside and outside containment.

38.3.7 Remove the instrument sensing isciation valves, lhe sensing I Ines from penetration Z.

8.3.8 Remove the containment pressurizea-on isclatior vas and elbow from peretrations UU and VL). 1 ind fIarnge the penetrations inside and outside of containment.

6.3.9 Local leak test penetrations UU and (N usin5 Test Procedure No. PT-V28. Results of this test must be added to the "As Found" and "As Left" ILPT leak -ate.

3.3.10 Local leak test sensor lines at penetration Z using test procedure PT-R27, data sheet 23. Results of this test must be added to "As Found" and "As Left" !LRT leak rate.

B.3.11 Perform "As Fcund" and "As Left" local leak rate tests on any leakage paths that were isolated during the ILRT. Results of both tests must be added to the ILRT.

PT-3YI Page 2?9 of 270

8.3.12 Local leak test all systems that were configured with artificial leakage barriers (Precaution 4.11). Results of these tests must be added to the ILRT leak rate.

8.3.13 Close all vents inside containment that were opened to simulate potential post accident conditions. Record that vents are closed in the appropriate column of Attachment I.

8.3.14 Restore the equipment and instrumentation protected in Attachment 1 to their original condition and record same.

8.3.15 Remove portable Copus blowers and electrical lines, and store for next ILRT.

8.3.16 Remove temporary communications set up used for the test.

8.3.17 Inspect for and remove any oil that may Have been deposited inside containment by the compressors) record findings in Comments Section.

8.3.18 Restore UCCPPS to normal operating condition.

8.3.19 Review Attachment I to verify that all items listed Have been restored to normal.

8.3.20 Remove the blocks from the automatic high and high-high pressure signals as per Attachment 6 and log in the SRO log.

Removed BY:(1 iD/ Date Verified By OA:* j'.j Signature / Date Steps 8.3.12 thru 8.3.20 Accepted BY: ý 5 4

/ihnature I/ Oate PT-3Y1 Page 30 of 270

Q7 10.0 TEST RESULTS 10.1 Record the "As Found" value, in the table below:

ICRITERIA I REOUWRED I ACTUAL 110.1.1 "As Found" ILRT 1<0.075 wto/dayl QO_.3Ll~(8.2.18) I leakage rate at I (.7SLa)* I _faOboZo6(8.3.9) I the 957* upper I_+_ ( (8.3.10)l confidence level I I +ooooH5 (8.3.11)1 I + ~O (8.3.12)l TOTAL:

Must include ILRT results throuqh izer, etratior,- described in the "As Found" condition. (Steps 8.3.9 thr-u E.3.i2).

10.? Any actual value in tie Taible above that is not tound satisfactory sial I be brou-,_kt to tke attentiorn of i-,e dLtW Senior Watch Supervisor immediately. Record below that the GEWE was notif ied.

SUS NctiTied Test Perfcrmed P>:

SRO Informed of Field Uork arnd Calculation _

Completion: Completion: 227 SRO IDate 11.1 The test is complete and the Test Results Se-ctionr is czocp!eted accurately. If any error is found in tine Test Results Section t.,at would cause a Required Value not to be satisi ied> ti-,eS`SU shall be notified immediately. Complete Step 12.1 of Th2 Operability,' Criteria and initiate an SOP for any Required Values in the Test Re ults Section that are not satisfied.

Co n Gn+-up I r or- Des i grie. /Date 0 PT-3YI

f. I Page 32 of 270

Date: Monday, 1 JuLy 1991 12:i9pm ET To: BAR.A, CONRAD.V, QUIRK.J

. From: BAR.A

Subject:

ILRT F'ressure Gauge Line Leak I was infirmed that ILRT F'ress.Gauge Line Local Leakage test indicates 220 cc/min. This is very smaLL Leak. that cannot affect the results of A-type

containment test performed on 6-23-91 for the following reasons:

o The pressure Line Leakage is accounted by the A-test results and musi not he added the ILfRT test b leakage.

o The A-type containment leak test caLcuLations are based on containment-pressure change rather then on the accuracy of the absoLute pressure measured by the gauge. Therefore any pressure drop in the Line does rot affect the test result.

o The ILRT test accuracy was successfuLLy verified by the CLRT,. This fact

confirms the above statements.

Based on the above Pressure Line Maximum Local Leakage Rate of 10 cc/min can be changed to actuaL measured Leak rate or deLeted as' a reqjuirement for the test in the ILR'r procedure.

A.Bar L

PT-3Y1 Rev. 6 4.0 T= RTSULIS 4.1 Record the value, in the table below:

CRITERIA - As Left R-XIRFD ACIUML 4.1.1 = leakage 0.075 wt%/day.0q7V11 (3.2.18) f5 e g,"e rate at the 95% or 0.75 La + 0.0 (3.3.9) upper confidence + 6,0 (3.3.10 Z

level + 0,0 (3.3.11)

+ 0,0 (3.3.12)

TOTAL: O,_0 _779_

Shall include = results throuh penetrations described in the "As Found" corxnition. (Steps 3.3.9 TH* 3.3.12).

4.2 ANY actual value in the Table above that is NOT found satisfactory shall be brouht to the attention of the duty

/

Senior Watch Supervisor IMMEDIATELY. Record below that the SWS was notified.

SWS Notified 4.3 Test Performed By:

Signa!/Dt 4.4 SRO Informed of Field Work ard Calculation Completion:

SRO /Date 5.0 SUPERVISOR REVIEW:

5.1 The test is complete and the Test Results Section is completed accurately. IF ANY error is found in the Test Results Section that would cause a Required Value NOT to be satisfied, the SWS shall be notified IMMEDIATELY. Complete Step 6.2 of the Operability Criteria AND initiate an SOR for ANY Required Values in the Test Results Sect 7h*

atFre9 satisfied. 1 spaq// -71 p7 Cogni.isor or Designee /Date Page 23 of 25

No:2-PT-10YO01 Rev-0l INTEGRATED LEAK RATE TEST Page 44 of 206 0 Initials 4.8 Final ILRT Results NOTE Only the "AS LEFT" leakage calculated in step 4.8.1.1 below must be met prior to entering a mode of operation that requires containment integrity. Unacceptable "AS FOUND" OR "PERFORMANCE" Leakage rates may be dispositioned per the Containment Leak Rate Testing Program (CLRTP), step 5.4 of Reference 9.2.6 and the CR process.

4.8.1 WHEN all local leakage rate additions AND corrections to ILRT are known, THEN CALCULATE Final ILRT leakage rates using Attachment 15, ILRT Results Summary as guidance.

4.8.1.1 "AS LEFT" Leakage:

Sum of above reported Lam & UCL "AS LEFT" 0,o~ jo4 (on Attachment 15, ILRT Results Summary) (,16, 4.8.1.2 "AS FOUND" Leakage:

Sum of above reported Lam & UCL "AS FOUND" 6.o634 (on Attachment 15, ILRT Results Summary) CJ 4.8.1.3 PERORMANCE LEAKAGE:

Sum of above report Lam & UCL "AS LEFT" and as-left minimum pathway leakage rate of any pathway isolated during ILRT due to excessive 0 . 04 9q leakage. f,.

(0

No:2-PT-1OYOO Rev.:01 INTEGRATED LEAK RATE TEST 0 Page 45 of 206 5.0 COMMENTS IV/- I~tf5 5Aý4 AL~t 10 Wot/r Otvffl ecLV- J,;L%/ 12 )5 rjN.,?r-TAINr4m ~

Ar0) 2C aW to Att 3,0 Tn fJA ~T

()PACyiWc, W14 ro Fj-Di Z-2-I & z, C %/ i12- 3j ru,

-1 esi, TY5 Ib"~

-666 0 -Se ct vr7 . it-7b 46/' 1171 < U-72 ?e455\jj(eto ,JrIW 7411. toT 5-Lt~b -+I> AM4 gi-c 17 Vk ic po.rt1 Per~ro

~~ C R~5 drf'cijos AlokQ 0 - x~ ',5N1sr II4 T.

PIC 5 bTFory (i I Att- tL~ed,5yit ~~; Tke-t.4t low&J~i Nroil"'5 LvýJt piR ICAlý 01Au 'PC5 AIVP ACI2T A(vJ)t J4 Ut

()

No:2-PT-10Y001 Rev:01 INTEGRATED LEAK RATE TEST Page 46 of 206 Comments continued:

('5 Wcb 1 d-Lwcp-ltIf A~t'rllfo 4L<ýo 71 * (* rA-,rfi,l.,<3 V,.t,J Oo(kt,,CJ4ý of e 1 /,,-COV/4N, i' AtT 3C-be ~it, 5 tPIAt01t f AAI v Pro~Yt~ Cjo~t OLur.

irqJ(T0 K4j vWrf( tVr~t r~ of V14r t~hlw-00Rj l 5D..".4 Clvrj& 15

-,Jo doq&4o ptw 3i/-Iol -t 4-I* 51,,.t- *,-PTO *7 - o005, 2f F-46.F3 of. 5,

e I L&T VtJ r c.-

(,*..2 /'A-*-i; Y/.x P,,,.,,,, SL,. r t-tf , .o IL7 K7-*JC-5"

, A, (o C'o L .2-ff, C. i.-r',,.,',-CI*.ri. f*F9-?;,l 0 .

Lev~td IjL'cd~aic'"/ 4/e O' O -- J"~

Ia, $,'ed4/' /o I,, .,J*utc.le'lJ ,4{oi.

an , ) O5 I\Ikk i"tFcr- ogA5A, Od5.

o© INTEGRATED LEAK RATE TEST No:2-PT-IOYOO Page 46 of 206 Revl01 Comments continued:

0@

N

No:2-PT-1I)YOO1 Rev:01 INTEGRATED LEAK RATE TEST C©.0 Page 47 of 206 Test Performers:

Print Name: Initials: Signature/Date:

"r a Da44, fo.,h,:C(A, 11-4(

/*

k0ou Rer in6 zIz 2 xc~ QCtuC-

-0

%f

No:2-PT-10YO01 Rev:01 INTEGRATED LEAK RATE TEST

Print Name: SignpjurelDate:

,w:.* sI**.

FR~- RCA.L2L. 1<

K90 O~

wS 0 _____

II

No:2-PT-10YOO Rev:01

( INTEGRATED LEAK RATE TEST Page 48 of 206 6.0 ACCEPTANCE CRITERIA 6.1 Technical Specification & IST Requirements:

7.0 TEST ACCEPTANCE 7.1 Technical Specifications Acceptance Criteria 7.1.1 Based on recorded data, are all Acceptance Criteria of 6.1 satisfed.

S NO 7.1.2 IF the required Acceptance Criteria is NOT met, THEN:

" NOTIFY CRS/SM.

INITIATE a WRT AND a CR.

" TAKE action in accordance with LCO 3.6.1 7.2 IF NO is circled in Step 7.1.1, THEN LIST Corrective Actions taken AND comments:

Comments: ,, C9- "T_?2- A*

T6Oo-OŽ113 l . .*

Reviewed By:

SM OR Designated Alternate / Date

No:2-PT-10YO01 Rev:O1 0 INTEGRATED LEAK RATE TEST Page 49 of 206 8.0 EVALUATION 8.1 PROGRAMS AND COMPONENTS REVIEW Comments: 'A6YAf/A(//1 ,j4 Reviewed By:

"L Prarams andComponents Review / Date 2.~.**>~

C-) The ILRT was performed in 2R117 with leakage within specification as documented in the test. The test was a challenge for the facility in several ways from a project management point of view: the setup area in the transformer yard was not available which resulted in staging in the FSB/MO building yard, this staging required manufacture of special containment penetration manifolds and use of a very large number of small 3" hoses, the hose arrangement partially blocked normal building access/egress and, due to an important temporary power supply installed across the center of the FSB/MO building yard, the removal of air compressors was delayed resulting in project cost overrun. The resistance offered by the long lengths of numerous 3" hoses was able to be overcome during pressurization but greatly increased the time required for depressurization.

During the ILRT, difficulties were encountered in temperature stabilization and Weld Channel System leakage. The temperature control problems were the result of tidal changes which cascaded through Service Water, Component Cooling and Residual Heat Removal. Although these changes were expected based on the experience at IP3 in 2005 ILRT, we were unable to completely control the reactions to these temperature changes.

This was a major concern for meeting stability criteria and proved a significant handicap when troubleshooting leakage rates.

A problem arose generally in the WCPS which resulted in closing all four WCPS Zones.

For Zones 3 and 4, the containment isolation valves WCP-I IlI-I and WCP-lI 111-2 were closed due to leakage from the distribution system in containment. These valves are exempt from Type C testing similar to CCW valves which are the boundary for a closed system outside containment. This was an unexpected event since the pre-outage values

'! Wfor the two Zones were low. It was later demonstrated that the leakage increased from less than 2 scfrn to approximately 8 scfm in the few days between plant shutdown and the start of the ILRT. These Zones were left depressurized upstream resulting in the ILRT pressure challenging the containment welds directly. (See condition reports IP2 2006 2049 and 2062 for documentation of isolated Zones 3 and 4.) Thus, the leakage for Zones 3 and 4 as well as the WCP-I 11I-I and WCP-I 111-2 were included in the ILRT leakage results (i.e. part of 95% UCL Leakage). The isolation of Zones I and 2 resulted in the inclusion and resolution of large leakage penalties. I have attached a complete discussion of the penalty resolution issue in Attachment 16 for condition report IP2 2006 02113. The net result for Zones I and 2 was that the actual leakage for those Zones is very small. If Zones I and 2 had not been isolated, or if the precise containment leakage for the these Zones had been obtained prior to the test, then the ILRT Preliminary Results would not have included the large penalty and condition report IP2 2006 02113 would not have been required.

Finally, the results of all Type B&C tests performed in 2R117 were tabulated. These results were used for the final As Found and As Left leakage values. I have included tables for these values in Attachment 16.

As Bergren June 1, 2006

(O No:2-PT-10YO01 Rev:01 INTEGRATED LEAK RATE TEST Page 192 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page l of 8) 1.0 VOLUME CHANGE CORRECTIONS 1.1 QUANTIFY VOLUME CHANGES:

1.1.1 Data comes from Attachment 14, Control Room Log. Maintain the correct sign convention throughout this calculation, as we are correcting for the net change in free volume (I.e. some levels may go up, others may go down). A reduction in tank level is NEGATIVE, conversely a rise in a tank or sump level is POSITIVE. Ultimately, the changes will be converted to a

%wt/day correction.

1.1.2 NET LEVEL DECREASE: IF the net change was negative, the containment net free volume increased, causing the pressure to drop and the leakage to look larger than it should have. In this case a C,'. SUBTRACTION is allowed from the ILRT leakage rate results.

1.1.3 NET LEVEL INCREASE: Conversely, if the net level change was positive, the conlainment net free volume decreased, masking the actual leakage and an ADDITION is required.

Net volume change from Attachment 14 in gallons: 5' *3 GALLONS 1.2 CONVERT GALLONS TO FT3 CHANGES:

Record ILRT duration (hours) = (t) Duration II/ 7.5 hrs Calculate net volume change in ft3/day:

dV = (TG/t) (24 hrs/day) (lft3 / 7.48 gal.)

Where: dV = net containment volume change TG = sum of level changes in gallons (from table above) t = test duration in hours 0 3 dV = (.ý..I3allons/ji.L"hours) (24) (0.13367 ft / gallon) dV= s'. 0o0" 1/day

No:2-PT-10YO01 Re

INTEGRATED LEAK RATE TEST W Page 193 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 2 of 8) 1.3 CALCULATE NET FREE VOLUME CHANGE IMPACT IN %WTIDAY:

LV = (dV

Pt

C - 100) / (R

T - W)

Where: LV is the volume change in %wt/day dV is the net volume change in ft3 / day from Step 1.2 Pt is the average containment pressure during the ILRT In psia 2

C is the conversion factor. 144 in / f1t R is the gas constant for air = 53.35 ft Ibf / Ibm 1R T is the average containment temperature in OR W is the average weight of the containment air in Ibm (use intercept of least squares fit line)

LV = (_Is, 05'*6/0, (2z

144

100) 1 (53.35

S"'93. I. 7V.2? /3)

Step B Pt T W LV = 0.0o00 %wt/day

- (pou,*,,ioD UP F,6, F- ooo0-q -

0

No:2-PT-1 OYOOI Rev:01 INTEGRATED LEAK RATE TEST

~Page 194 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 3 of 8)

NOTE Reference Step 1.1.1 of this Attachment for guidance pertaining to sign convention and addition/subtraction requirements.

2.0 PRELIMINARY TYPE B & C PENALTY ADDITIONS 2.1 Total of as-left MNPLR for penalty additions from Attachment 9. Containment Penetration Summary:

Total Penalty Addition (sccm): 122C. 3 2.2 Convert the MNPLR Penalty Addition to Ibm/day:

/L2Z.3 Penalty Addition = (__sccm)(1scf/28,317scc)(0.07517 Ibm/scf)(1440 min/day)

Penalty Q.;*i.., Addition (in Ibm/day) - * ', '~

2.3 Convert the Ibm/day Penalty Addition to %wt/day value:

Penalty Addition (in Ibm/day) = C1 'Ibm/day

100) / 7'2 73 . initial containment Step 2.2 air mass (ibm)

Penalty Addition (%wt/day) = o. 00 9 '

0 ATTACHMENT 16 ILRT RESULTS

SUMMARY

(Page 4 of 8) 3.0 P ELIMINARY LEAKAGE SAVINGS CALCULATION 3.1 Total of leakage savings for as-found ILRT calculation from Attachment 9, ontainment Penetration Summary:

0O Lea ge Savings Addition (sccm):

3.2 Conve the Leakage Savings Addition to Ibm/day:

Leakage vings Addition = sccm)(lscf/28,317scc)(0.07517 Ibm/scf)(1440 min/day)

Leakage Savin s Addition (in Ibm )=

3.3 Convert the Ibm/day eakage Savings Addition to %wt/day value:

Leakage Savings Addition (in Ibm/day) 100)

"Ibm/day* initial contain ment Ste 3.2 air mass (lbm Leakage Savings Addition (%wtlday) =

(This calculation will need to be repeate , COPY this page as necessary)

A',, 0 0

No:2-PT-10YO01 Rev:01 INTEGRATED LEAK RATE TEST Page 196 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 5 of 8) 4.0 FINAL TYPE B & C PENALTY ADDITIONS 4.1 The ILRT is being performed at the beginning of the outage. The preliminary ILRT results will be based on existing local leakage rate results, some of which may be replaced with tests performed after the ILRT. When all local leakage rate testing is 0O completed, enter the results on Attachment 9, Containment Penetration Summary and calculate the total of as-left MNPLR for penalty additions:

Total Penalty Addition (sccm): 76,t.-',-

4.2 Convert the MNPLR Penalty Addition to Ibm/day:

Penalty Addition = ý(! sccm)(lscf/28,317scc)(0.07517 Ibmlscf)(1440 min/day Penalty Addition (in Ibm/day) = a,?.

4.3 Convert the Ibm/day Penalty Addition to %wt/day value:

Penalty Addition (in Ibm/day) = ( *'ýy Ibm/day

100)/ 2*Z 7-3 initial containment Step 4.2 air mass (Ibm)

Penalty Addition (%wt/day) = 0. ;o, 0

No:2-PT-10Y001 Rev:01

( INTEGRATED LEAK RATE TEST Page 197 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 6 of 8) 5.0 FINAL LEAKAGE SAVINGS CALCULATION 5.1 The ILRT is being performed at the beginning of the outage. The preliminary ILRT results will be based on existing local leakage rate results, some of which may be replaced with tests performed after the ILRT. If maintenance is perfomed on components NOT exposed to the ILRT test pressure, any leakage savings must be included in the Final As-Found ILRT results. When all local leakage rate testing is completed, enter the results on Attachment 9, Containment Penetration Summary and calculate the total leakage savings for as-found ILRT calculation from Attachment 9, Containment Penetration Summary:

Leakage Savings Addition (sccm)" /l-7 5.2 Convert the Leakage Savings Addition to Ibm/day:

Leakage Savings (ThO Addition = (/L7"f sccm)(1scfi28,317scc)(0.07517 lbm/scf)(1440 min/day)

Leakage Savings Addition (in Ibm/day) z . 3* L) 5.3 Convert the Ibm/day Leakage Savings Addition to %wt/day value:

Leakage Savings Addition (in Ibm/day) q.'3V'I lbm/day - 100) 1 7Y, 7 initial containment Step 5.2 air mass (Ibm)

Leakage Savings Addition (%wtlday) = . 0Vb*

(This calculation may need to be repeated COPY this page as necessary) 0

INTEGRATED LEAK RATE TEST ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 7 of 8) 6.0 PRELIMINARY AS-LEFT ILRT RESULTS:

CHECK box for results used to accept ILRT MASS POINT F (ANSI 56.8-11994) (BN-TOP-1) J 6.1 MEASURED LEAKAGE: N/A 6.2 REGRESSION LINE A/Aj1 LEAKAGE Lam: 9, &".

6.3 LEAKAGE AT 95%UCL e. e*7 ,vffi' 6.4 MNPLR Penalty Additions (from 2.3) , 00 f IA/fr 6.5 Volume Change Correction (from 1.3) (9, '4 0 6 6.6 PRELIMINARY AS-LEFT ILRT Result: .

7.0 PRELIMINARY AS-FOUND ILRT RESULTS USE results used to accept ILRT 7.1 AS-LEFT ILRT MASS POINT (ANSI 56.8-1994)

LETOTAL TIME (BN-TOP-1)

[Ti RESULT (from 6.6): NIA 7.2 LEAKAGE SAVINGS (from 3.3):

7.3 PRELIMINARY AS-LIIKJ FOUND ILRT Result:

0 INTEGRATED LEAK RATE TEST No:2-PT-10YO01 Rev:01 Page 199 of 206 ATTACHMENT 15 ILRT RESULTS

SUMMARY

(Page 8 of 8) 8.0 FINAL AS-LEFT ILRT RESULTS CHECK box for results used to accept ILRT MASS POINT TOTAL TIME (ANSI 56.8-1994) (BN-TOP.1) 8.1 MEASURED LEAKAGE: N/A A/A 8.2 REGRESSION LINE LEAKAGE Lam: 6.0 ý;-c gAI 8.3 LEAKAGE AT 95%UCL: 0. os5-7 8.4 MNPLR Penalty Additions (from 4.3) ()Q0 3_7'/

8.5 Volume Change Correction (from 1.3) 0 ,0 0 0! ,Al/

0* 8.6 FINAL AS-LEFT ILRT Result:(<75%La) 0.0 0 9.0 FINAL AS-FOUND ILRT RESULTS USE results used to accept ILRT 9.1 AS-LEFT ILRT MASS POINT (ANSI 56.8-1994)

EL TOTAL TIME (BN-TOP-1)

AJ/A RESULT (from 8.6): NIA 9.2 LEAKAGE SAVINGS

0. 060oo f,/A (from 5.3):

9.3 FINAL AS-FOUND ILRT Result:

CR IP2 2006 02113 PENALTY RESOLUTION INCLUDES THE FOLLOWING DOCUMENTS:

- CR IP2 2006 02113 (6 Pgs)

- ILRT INC. PRELIMINARY TEST REPORT (3 Pgs)

- 217 ILRT PENALTY RESOLUTION (Recovery Plan) (4 Pgs)

- ZONE I WORK ORDER IP2 06 18693 (14 Pgs)

- ZONE 2 WORK ORDER IP2 06 18694 (17 Pgs)

C.

I I ' Entefgy I CONDITION REPORT ICR-IP2-2006-02113 I

.S* : Originator: Bergren,Christopher J Originator Phone: 7216 q gioator Group: P&C Eng Codes Staff Operability Required: Y Reportability Required: N Supervisor Name: Azevedo,Neison F Discovered Date: 04/24/2006 13:13 Initiated Date: 04/24/2006 13:37 Condition

Description:

The Integrated Leak Rate Test had actual test results of 0.0587 %wt/day which is meets the acceptance criteria of <0.075

%wt/day. However, certain known leakage paths were isolated for the test. When this is done, penalties are taken based on the known leakage amounts. For this test, when the known leakage amounts are added, the total leakage is administratively changed to 0.0799 %wt/day which is not acceptable for Mode change for startup. These known leakages must be reduced by a minimum of 10,136.7 sccm prior to startup. This is not an issue at this time because the value of 0.075 %wt/day is applicable to the design basis leakage at accident conditions (above cold shutdown).

Immediate Action

Description:

Notified plant management and the shift manager.

Suggested Action

Description:

This is a mode hold item for cold shudown.

REFERENCE ITEMS:

Type Code Description TSN 2-PT-10YO01 TRENDING (For Reference Purposes Only):

Trend Type Trend Code EL ESPC KEYWORDS KW-OUTAGE LESSONS LEARNED WE ESPC KEYWORDS KW-LEAKS-AIR REPORT WEIGHT I I

SI

Entergy OPERABILITY CR-!P2-2006-02113 C Operability Version: I Operability Code: EQUIPMENT INOPERABLE Immediate Report Code: NOT REPORTABLE Performed By: Kich,Frank M 04/24/2006 20:12 Approved By: McCarthy,Brian P 04/24/2006 21:10 Operability

Description:

Due to failure of the ILRT the containment is inoperable when in modes 1,2,3,4. Until repairs are completed on leaking components the plant cannot enter Mode 4. Discussed with Licensing and there is no immediate reportability required per LI-108.

Approval Comments:

Approved C,I

Entergy I REPORTABILITY ICR-IP2-2006-02113 -]

( ReportabUlty Version: I I Report Number:

!ID Report Code: NOT REPORTABLE Boilerplate Code:

Performed By : Janickijohn W 04/25/2006 11:06 Reportability

Description:

Appropriate corrective actions initiated to resolve the reasons for the surveillance failures which are to be completed prior to mode change. This aspect of VC integrity not required in the current mode. Also, the test results are bounded by the accident analysis and as such there is no past operability concern (results were only .75 of La). Not reportable per IP-SM-LI-108.

( A>-

L-

Entegy. CORRECTIVE ACTION CR-IP2-2006-02113 C CA Number: I e

Group p iI Name I Assigned By: Operations Watch Staff Brooks,Kevin L Assigned To: P&C Eng Component Mgmt Tesoriero.Michael V Subassigned To: P&C Eng Codes Staff BergrenChristopher J Originated By: Brooks,Kevin L 4/24/2006 14:44:18 Performed By: Tesoriero,Michael V 5/9/2006 03:10:43 Subperformed By: Bergren,Christopher 1 5/8/2006 15:07:25 Approved By:

Closed By: Brooks,Kevin L 5/9/2006 05:31:04 Current Due Date: 05/10/2006 Initial Due Date: 05/10/2006 CA Type: ACTION Plant Constraint: MODE 4/HOT SHUTDOWN CA

Description:

NOTE MODE 4 HOLD: document required cornective actions complete prior to mode 4

Response

See sub-response. The ILRT has passed satisfactorily with the penalties reduced to acceptable levels. There is no longer a mode 4 issue with the ILRT. MVT

>~

(s~i

Entergy CORRECTIVE ACTION CR-IP2-2006-02113 e following corrective actions were completed.

The combination of Zone I and Zone 2 Weld Channel System leakage was tested using local leak rate test methods and equipment under work orders IP2-06-18693 and IP2-06-18694 respectively. The tests demonstrated that the actual penetration leakage was reduced from the value reported in the previous 2-PT-RI I Sensitive Leak Rate for Zones I and 2.

This is a substantial reduction in the overall penetration penalty and is well in excess of the 14000 cc/min reduction required for meeting the Technical Specification requirement of leakage less than or equal to 75% La. Therefore, the ILRT is satisfactory and there is no further Mode Change Hold attributable to penalty values at this time.

Data:

The vendor, ILRT Inc, was supplied with the following pre-ILRT values for those penetrations which could not be tested by the ILRT or were isolated during the ILRT:

WCPS Zone I (From 2-PT-RI I performed 12/05) - 18689.02 cc/min WCPS Zone 2 (From 2-PT-RI I performed 12/05) - 19255.36 ccmin Containment Spray Header - 69 cc/min Containment Spray Header - 139 cc/min Purge Supply - 2574.23 cc/min Purge Exhaust - 5502.82 cc/min Pressure Relief- 364.5 cc/min Sum Total = 46593.93 cc/min.

Reduction of this Sum Total necessary for meeting the criteria of less than or equal to 75% La = 14000 cc/min.

Note that the original value of 10136.7 cc/min was revised upward to 14000 cc/min based on determining that the changes in j ressurizer level observed during the test did not represent liquid leaving containment.

The test 2-PT-RI I is normally conducted by reading Zone flow from installed instrumentation and is conservative with respect to actual leakage through the penetrations. Zone I and Zone 2 were tested at the racks with the Zone depressurized upstream. The results of the test were as follows Zone I - 1417.5 cc/min Zone 2 - 1292.7 cc/min The Zone 2 value includes a 1000 cc/min penalty for penetrations UU and VV which were tagged out at the time of the work order testing. This tag out was performed in such a way that the particular WCPS penetrations UU and VV were left pressurized with an indicated pressure value which did not change over a period of at least seven days even though the upstream Zone was depressurized. From this it was concluded that the penetration does not leak; however, because the penetration was tagged out, a penalty of 1000 cc/min was conservatively assumed to apply.

The difference between the Zone leakage from 2-PT-RI 1 and the work step lists is 37944.38 cc/min - 2710.2 cc/min 35234.18 cc/min.

The new Sum Total is 46593.93 - 35234.18 = 11359.75. Note that exact values will change slightly based on final valve testing which is currently scheduled. Careful monitoring will prevent exceeding 75% La based on those outstanding tests.

Based on these values the ILRT leakage is less than 75% La and, therefore, there is no Mode Change Hold due to ILRT associated penalties in 2R117 at this time.

See attached completed work order steplists.

Closure Comments:

agree and close tachments:

Subresp Description

__-" Zone 2 Work Order

I' Ente I CORRECTIVE ACTION ICR-IP2-2006-02113 Attachments:

Zone I Work Order

ILRT Inc.

c.;: -29 Talisman Te.

Oswego, NY ]3126 http://www.URT~com (315) 402-5599 April 15, 2006 11-PTR-2006002 GCVW-L060415A Mr. Christopher Bergren Entergy Nuclear Northeast Indian Point Unit 2 Broadway & Bleakley Ayes.

Buchanan NY 10511

Subject:

Preliminary Test Report, 2006 ILRT

Dear Chris:

The ILRT (including Verification Test) at the Indian Point Power Station, Unit 2 was completed at 10:00 on April 24, 2006. The preliminary leakage rate results based solely on computer results were acceptable. However, the ILRT results must be corrected for:

9 volume changes

penetrations not aligned during the test during test preparations

and penetrations isolated during the test itself These alignment corrections are known as "B&C Penalties", and are made using "As Leftr minimum pathway local leakage rate results in most cases. These additions are currently not known due to local leakage rate testing and repairs that will have to occur during the 2R1 7 outage. Based on currently known data (outdated LLRT results that were scheduled to be performed after the ILRT totaling - 46,593 sccm or 0.0227%wt/day) the Preliminary As Left ILRT results do NOT appear to be acceptable, however, sufficient margin exists between the computer reported results and the technical specification acceptance criteria to allow reporting an acceptable Final As Left ILRT Result at the end of the outage. Please note that the penalty additions may change based on post-test "as-left" LLRT results. The computer test results (sans additions) are shown in the table below:

Analysis Technique Test Result Acceptance Criteria Mass Point 0.0563 %wt/day 5 75%La = 0.075%wt/day (Calculated Leakage)

Mass Point 0.0587 %wt/day 5 75%L. = 0.075%wt/day (Leakage at 95%UCL) 0 it, I VC. AAo( , 0,ý 113

i'i ILRT Inc.

m 'k cW 29 Talisman Te.

Oswego, NY 13126 http://www.ELRT~com (315) 402-5599 As the ILRT was performed per ANSI 56.8-1994, the official test results are those obtained using the Mass Point data analysis technique. With known additions, (penalties, level corrections) the Preliminary "As Left" ILRT leakage results were unacceptable at -0.0799 %wt/da¥. The results will be improved by further local leakage rate testing results.

After Entergy Management permission was obtained, the ILRT computer reported leakage was then validated by the successful completion of the verification test required by 10 CFR 50 App J using the Mass Point data analysis technique. An imposed leakage of 7.0 scfm (6.9 scfm after correction back to calibrated conditions) was set. The imposed leakage equated to 0.0954 %wt/day. The results are listed below:

Acceptance Criteria Analysis Technique Verification Results Lam + Lo + 25%La 0.1767 %wt/day (Upper Limit)

Mass Point (L,) 0. 1313 % wt/day Lam + Lo - 25%La

0. 1267 %wt/day (Lower Limit)

A copy of the complete set of the individual data sets for the test and verification phases as well as parameter graphs will be provided in the final test report. The draft of the final test report will be submitted within four weeks after receipt of local leakage rate data for penetrations not included in the ILRT, and a copy of the executed procedure, (including all appendices and attachments).

Dr. Howard T. Hill, Mr. Robert M. Carey, Mr. George C. Van Wert and Mr. Jenme Cornell provided consulting services and performed the ILRT's data reduction and calculation tasks. If you have any questions concerning the interpretation of the ILRT Data, please contact me at 315-402-5599 or Robert Carey at 813-571-9981. ILRT Inc appreciates the opportunity to work with FENOC, and looks forward to doing so again.

Sincerely yours, ILRT Inc Robert M. Care, Vice President p

0 NOTES: NOTES: NOTES:

1. Many of the leakage additions used to calculate 1. The WCCPP reading prior to opening the 1. To fail the Performance Criteria the excessive the 0.0227% wt/day value are over four years Purge valves to support outage activities (and leakage of the isolated paths had to be from old, and were simply used as placeholders. The Radon concerns) would provide a better components NOT included in the Type B or C outdated LLRTs were already scheduled for (though conservative) "as found" evaluation of program, or that are not testable. ALL 2R 17 the 1170 valves initial condition. pathways isolated during this ILRT are

2. The -0.0015% wt/day value was an assumption 2. An as found LLRT prior to any repairs is still currentJy monitored with Appendix J tests based on data available at the time. RCDT desirable to correlate the leakage during the except WCCPP Zones 3 & 4 which meet levels were unreliable and Sump levels were not ILRT with the LLRT result. IF the valves have separate testing criteria included in the plant's functional during the test. The dropping Pzr. been cycled before the LLRT can be Technical Specifications (Section 3.6. 10) level made the leakage appear larger than it accomplished, the LLRT will probably not 2. The volume change corrections were actually was, and a subtraction for its impact reflect the valves' leakage during the ILRT. ultimately determined to be zero.

would have been allowed IF the lost water volume had ended up outside the containment.

Measurements after access was restored indicated the RCDT overflowed and ended up in the trenches of the 46' elevation because the sump had been blocked for mod work. A calculation by Dr. Howard Hill of ILRT Inc accounted for the lost Pzr. volume within the containment, so no subtraction is allowed.

3. The ILRT procedure, 2-PT-10YO01, steps 4.4.4.1 and 4.4.4.7 require that prior to terminating the test, the leakage rate from the computer be adjusted with 'all known additions".

The 0.0587%wt/day leakage at the 95%UCL was acceptable alone, but would not be result in an acceptable ILRT when all known additions were made. Entergy Outage Management was informed of the fact, and the fact that the numbers ultimately added would be "as left"

(*fter repairs/adjustments). Entergy management approved ending (he test at 11.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months with a Preliminary As Left value of 0.0799% wt/day.

4. The -0.0015% volume change corrections were revised to zero once access to the VC confirmed lost PZR inventory remained within the containment. REVISED preliminary As Left is now 0.0814%wtlday. To attain a FINAL As Left result of 0.070%wtiday an improvement of 23,500 sccm (through repairs or updated, lower LLRT values).

LOWER-TIER APPARENT CAUSE Sheet I of 3 Condition Report Number: Assigned Department:

CR-IP2-2006-02113 Programs & Components Engineering PROBLEM STATEMENT: (The WHAT) (see Procedure step 5.4[2](a))

The Integrated Leak Rate Test (2-PT-1i Y001) performed in 2R17 had actual test results of 0.0587 %wt/day which meets the acceptance criteria of <0.075 %wt/day. However, certain suspected leakage paths were isolated as procedurally controlled contingency actions during the test. When this was done, penalties were taken based on previously recorded Type B and Type C leakage results for those isolated portions. When these penalty amounts were added to the actual leakage, the total leakage was administratively changed to 0.0799 %wt/day which exceeded the acceptance criteria. These known leakages had to be reduced prior to startup to meet the 0.075 %wt/day requirement.

EXPLANATION OF PROBLEM: (The HOW) (see Procedure step 5.4[2](b))

The penalty addition process is part of the ILRT procedure. The process uses leakages from the most recent Type B and Type C testing results for any containment penetration which can not be tested by the ILRT or is isolated during the ILRT. Several penetrations were isolated during the ILRT due to suspected leakage. Weld Channel System (WCPS) Zones 1 and 2 were among those isolated. Therefore, the last Type B testing results for those Zones were added to the ILRT.

Type B testing for Zones 1 and 2 was last performed in test 2-PT-R1 1 in December, 2005 with a combined documented leakage of approximately 38,000 cc/min. Penalty addition from these zones was sufficient in themselves to exceed the acceptance criteria as stated in the condition report. Although the penalty addition was procedurally controlled, a condition report was deemed appropriate to ensure that the technique was identified to outage management as a restraint to mode change pending resolution.

The test 2-PT-R1 1 has a comparatively large acceptance criteria of 0.2 %wt/day and is performed in a manner which provides information about the total WOPS leakage rather than exact values for each individual system rack or penetration. The result is that the reported system leakage is in excess of actual leakage at each welded penetration sleeve. A plan was immediately implemented to test and identify the actual penetration leakage for the two zones.

The intent of the plan was to replace the overly conservative values taken in 2-PT-R1 1 with actual penetration leakage. This plan was successful as documented in CA 00001 of this condition report (See attached Recovery Plan). The resulting actual values replaced the values from 2-PT-R1 1 resulting in a satisfactory preliminary ILRT result.

The identified problem is the use of overly conservative leakage values for WCPS Zones 1 and 2 as penalties in the 2R17 ILRT. The use of the overly conservative values resulted in a temporary mode restraint that could potentially have been avoided.

One method of avoiding the use of the penalty would have been to un-isolate WCPS Zone 1 and Zone 2 prior to the end of the ILRT. This action was rejected durinq the test because the

LOWER-TIER APPARENT CAUSE Sheet 2 of 3 actual leakage was not known and there was a desire to limit entering and exiting contingency actions since the containment air mass takes time to react to each specific change. This could have added substantially to test time.

A better method would have been to know the actual penetration leakage before the test so that, when the penalties were added, the result would not have exceeded the acceptance criteria. An action to verify actual leakage might still have been implemented but the mode restraint would not have been required.

When testing for system leakage in 2-PT-R1 1, Zones 1 and 2 are evaluated for contribution to Type B leakage because those zones protect containment penetrations. The test is conducted by excluding leakage from Type C sources (such as containment purge or pressure relief valves) since those sources have their own tests and penalties. The remaining leakage is totaled against the overall technical specification limit of 0.06 wt%/day. This leakage is evaluated on the basis of system usage rather than by performing a local leak rate test at the rack penetrations. A similar method applies to Zones 3 and 4 in that a system leakage is obtained in 2-PT-R1 1 rather than a rack-specific leakage. Zones 3 and 4, exclusive of the specific tests (such as fuel transfer tube and post accident containment venting), are used to provide a cover gas to liner welds in the containment structure. Based on suspected leakage, Zones 3 and 4 were isolated by closure of valves PCV-1 111-1 and PCV-1 111-2 against ILRT pressure. The ILRT pressurized and tested the liner welds directly and that leakage is included in the actual test result of 0.0587 wt%/day. Zones 3 and 4, after exclusion of specific tests mentioned above are not applicable to Type B or Type C testing and are not counted against the 0.06 wt%/day limit. Therefore, the existing methodology of 2-PT-R1 1 results in two test result values. The total of all four zones is tested against the criteria of 0.2 wt%/day and the portions of Zones 1 and 2 which do not have a specific Type C test are added to the running total for 0.06 wt%/day. These values are system-oriented and overly conservative when applied to specific penetration leakage.

Therefore, the values used for the Zones 1 and 2 penalties were overly conservative because they include system leakage in excess of actual leakage through the containment penetrations.

APPARENT/CONTRIBUTING CAUSE(S): (The WHY) (see Procedure step 5.4[2](c))

Why were overly conservative values from 2-PT-R 11 used as penalties in the ILRT?

Because no specific racks or penetration testing was done before the ILRT.

Why was no specific rack or penetration testing done before the ILRT?

Because the effect of adding the overly conservative value was not anticipated.

Therefore, the apparent cause of this condition was the failure to anticipate the result of a contingency action.

The cause could be removed by revising 2-PT-R1 1 to provide a method to obtain specific rack or penetration test results for those portions of the test used as Type B test results.

LOWER-TIER APPARENT CAUSE Sheet 3 of 3 EXTENT OF CONDITION: (see Procedure step 5.412](d))

The use of penalties to formulate preliminary results is not normally used in surveillance testing and is unique to the ILRT procedure. Therefore, based on review of a sample of completed 2R17 surveillance tests, there are no other procedures to which the use of penalties applies.

CORRECTIVE ACTION(S): (see Procedure step 5.4[2](e))

1. Revise 2-PT-R1 1 to include a method to obtain rack or penetration specific values for those portions of Zones 1 and 2 which are applicable to Type B testing.

ISSUE / PROBELM SOLUTION I RESOLUTION I ACTION / COMPLETED

[note any Work Orders, MODs, other]

Example: Cords are currently a trip Example: Cords were removed or raised out of the pathway.

hazard.

PROPOSED/ASSIGNED CORRECTIVE ACTIONS ITEM # ISSUE/CAUSE SOLUTION I RESOLUTION TYPE Assigned Due Date PCRS

[note any Work Orders, MODs, CA Department CA#

other]

The previous work packages Electrical conduit will be run and CA Maintenance 0/0/0 00 Ex: did not specify guidance for outlets installed per work order (AC-1) placement of electrical number XXXXXX. On 1/1/01 the extension cords. CRG approved closure to this WO#.

AC-1 Overly conservative Revise 2-PT-R1 1 to CA Operations 9/14/06 04 values were placed include a methodology Procedure into the test to provided by IST Group address potential Engineer to determine Zone 1 and 2 leak best leak rates for these rates, rather than zones so that actual performing actual values are obtained for leak rate testing for ILRT(vice penalty these zones, estimates) to support more accurate test result conclusions.

EVALUATOR (Print Name) Date report completed Phone Extension of Investigator Chris Bergren 5/16/06 271-7216

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 PAGE 1 of 11 I11111111111111111l111111 II 05/02/2006 16:07 Problem / Work Requested:

Problem / Work Requested:

INVESTIGATE / TROUBLESHOOT AIR LEAKAGE FROM WELD CHANNEL ZONE 2 Location: WCPS-ZONE-2 Loc.Descrip: WELD CHANNEL PRESSURIZATION ZONE 2 Building / Elevation:' N/A Equipment: OTHR2008-002

Description:

Model # UNK- Serial # UNK Reported By: AMIHALI Date: 04/27/2006 Planner: SBYRNE Supervisor: <none> Loop: <none>

Priority: 8 System: WCPS QA Class: A Work Typ e : P OTHER EQ: N Outage ID: 17E Week/Mode: MODE4 Status: INPROG Project No: <none>

Response Dep:MFIN Change of Scope YES / NO (circle one):

Release for Work Supervisor to verify WO in progress : Date:

LCO / AOT #:

Tagout# (s)C Work Complete /closeout .

Suoervisor./ Lead: Date:

Retest Reqd? Yes / No In Scope of Work Signature/Date WRT Loc: No tag hung Work Accepted (WCC) Yes / No New WO Niumbef:

Signature/Date STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 PAGE 2 ofll 1111l1111111111111ll 111ilH 1111l1l 1111111111111ll1l11 05/02/2006 16:07 Work Order Hierarchy WO# Description Parent WO IP2-06-18694 Investigate / troubleshoot air IP2-06-19352 leakage from Weld Channel Zone Controlled Documents and Records Document Description Revision

References:

Z95X Per CR 2006-02113 This is a mode hold item for cold shudown.

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center 1P2 Information Copy - Rev 0 PAGE 3 of 1l WORK ORDER # 1P2-06-18694 05/02/2006 16:07 Plant Impact Matrix PIMX Desc.:

OPS Impact Summary:

Prepared By:

Prepared Date:

Independent Review:

2nd SRO:

LCO/AOT/TRM/ODCM:

LCO 2nd SRO:

LCO(Admin)

Reference:

LCO(Admin)Ref Duration:

LCO Ref Duration 2nd SRO:

Equipment to Protect:

Equip to Protect IR:

Special Entergy Power Mktg Notify:

Special Entergy Notify IR:

OPS Proc Refs:

OPS Proc IR:

OD/TFC/TPC/Caution Tag:

OD/TFC IR:

Precautions or Removal Plan:

Prec or Remove IR:

Contingency Plans Required:

Cont Plans Req IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 4 of 11 WORK ORDER # IP2-06-18694 05/02/2006 16:07 CCR Brief Required:

CCR Brief IR:

On-Line Risks:

Instrument Bus Spike:

Instrument Bus IR:

Proximity Risk:

Proximity Risk IR:

Reactor Trip:

Reactor Trip IR:

Feedwater Transient:

Feedwater Trans IR:

Loss of Offsite Power:

Loss of Offsite IR:

Reactivity:

Reactivity IR:

On-Line PRA:

On-Line PRA IR:

ShutDown Risks:

Decay Heat Removal:

Decay Heat IR:

RCS Inventory:

RCS Inventory IR:

Power Availability:

Power Availability IR:

Reactivity:

Reactivity IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 5 ofl WORK ORDER # IP2-06-18694 05/02/2006 16:07 11l I lll11111111111111 HEil 111111f11111 11111lIl11111111111111 iNi RCS/VC Integrity:

RCS/VC IR:

SFP,Rad Mon,HVAC:

SFP,Rad Mon,HVAC IR:

ShutDown PRA:

ShutDown PRA IR:

CCR Impact:

CCR Impact IR:

Activity Location:

Activity Location IR:

Estimated Alarm Severity(#per Hour):

Estimated Alarm IR:

Estimated # of Personnel in CCR:

Estimated # of Personnel IR:

Restoration Plan Required:

Restoration Plan IR:

Unnecessary Entry into LCO:

Challenge to VC Integrity:

Chem/Rad Release/Spill:

Loss of Configuration Ctrl:

New Sys Components from DCP:

OPS Proc Refs and Verify Rev:

OPS Proc Refs IR:

PWT Printed:

PWT Correct for Plant Cond:

PWT Correct Plant Cond IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 1III1III1111ll11111III111llll PAGE 6 of 1i 05/02/2006 16:07 Is LCO Info in LCO DB:

Is LCO Info in LCO DB IR:

Tag-Out Review Complete:

Tag-Out Review Complete IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 PAGE 7 ofll IIM1111M111 IIIII111111 III1111I11 1IIIIII111111II 11111111 I11111I111I11105/02/2006 16:07 Job Details Job Plan: <none> Work Class: <none> IST Related: <none>

Rep Task ID: <none> Task Type: <none> SectionXI/Qual Grp:*

PWT: Y Defic Type: <none> Risk Significant: <none>

PCRS #: 2006-2113 Engineer: <none> Maint Rule:

Department Billed: V32 GL Account: NEV32-7A000-IP2-CROT-F3PC5MTCRO-095 Permits and Support Job Plan # <none>

Notifications RWP: <none> -

Safety Group: <none> -

Radwaste: <none> -

Fire Protection: <none> -

Quality Control: <none> -

Other Notifications: <none> -

Health Physics: <none> -

Requirements Fall Protection: <none> -

FME Clean Level: <none> -

Cleanliness: <none> -

Support Chemistry. Department: <none>.-

Crane / Forklift Required: <none> -

Scaffold Required: <none> -

Temporary Power Required: <none> -

Security Coordination: <none> -

Cutting, Burning, Welding permit: <none> -

Insulation Removal Required: <none> -

Other Support Required: <none> -

Precautions / Hazards Flammable / Explosion Concerns: <none> -

Heat Stress Requirements: <none> -

Hazardous Chemical: <none> -

Asbestos: <none> -

Lead Abatement: <none> -

Electrical High Voltage: <none> -

Respiratory Requirements: <none> -

Confined Space Permit: <none> -

Other Precautions / Hazards: <none> -

Work Instructions STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 PAGE 8 of 11 1ll11l11l1r1l11111I111I111 05/02/2006 16:07 Actions Taken 4/28/06 - 17E Mode4 per scope #366- Bengis as sysadm As-Found Condition:

^i (_A_ c r-JIc,~~ L ~~

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center 1P2 Information Copy - Rev 0 PAGE 9 of 11 WORK ORDER # IP2-06-18694 05/02/2006 16:07 1111111111111 111111111 111111111111 11111111111111111 i11111 l11t Parts Used Class Stock Number Green Tag Number M & TE Calibration / Due Date Step Used 2-

/Yh~7 STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center 1P2 Information Copy - Rev 0 PAGE 10 of l WORK ORDER # 1P2-06-18694 05/02/2006 16:07 NO Planned Materials STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18694 PAGE 11 ofl1 IHE 11111 I1111III1 1M11111I1111111111 11II1 111 I111 1ll 1l111 111 05/02/2006 16:07 PWT Plans PWT PreImplementation Review Issued By:

WILL BE TESTED UNDER 2-PT-RII ==> IP2-06-19352 PWT Completion Review WE: SAT UNSAT /

SM: SAT UNSAT /

OPS PPMIS ENTRY /

TEST ENG: SAT UNSAT /

STOP THINK ACT REVIEW Set Your Teammates Up For Success

WORK STEP LISTs OASL 15.86 Rev. 0 ATTACHMENT I S WORK STEP LIST

( Page 1 of 2 )

WSL Number:

( Use "year / Month / day / time" as the number - Example 01040712:31 )

Date: / /. Page 1 of System / Component affected: -iJA' Id C L avi-,A (

Purpose of Step list: _. r r A% LLRT -fI bx(o C1~ah. I 1~57 References used in step list development: 93 ) I - F- - (.2 fc:~,o~. /O~57f

_l L Prepared By: 14. aI,-/

Reviewed By: >KZ2zc&~-)

Approved By:

OM/AOM /GSM Rad Engineer (Required IF there is a potential for a Radiological problem.)

SNOTE It MAY be acceptable to perform some steps concurrently OR NOT in the sequence presented provided the SM approval is obtained.

Prerequisites:

1. Briefing held outlining Precautions, Limitations, Safety concerns, Scope of work etc..

S1 2. Verification that equipment status is as expected prior to performance of Work Step List.-

Page 2 of 3

1.6 Leakage Test for WCPS Rack #15 PERFORM Pre-Test lineup per Attachment 2 Section B, WCPS Q0 Rack #15 Test Valve Lineup.

NOTE WCPS Zone 2 is isolated and depressurized to preclude possible inleakage through PS-PCV-1 110-10, PS-PCV-1 110-11 and PS-PCV-1 110-15 during test.

WCPS Zone 2 air receiver may remain pressurized during this test.

NOTE Test pressure must be applied to maintain a minimum of 53 psig across zone being tested.

PERFORM setup for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

If Rack #15 is depressurized, repressurize using bypass on Leak Rate Test Rig or equivalent as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: ?( II'*i -/,4-Slowly REMOVE test connection cap for gauge isolated.

CONNECT test rig outlet to test connection.

Open gauge isolation valve. ,-

Increase Rack #15 pressure to 49 psig using bypass on Leak Rate Test Rig or equivalent.

If Rack #15 is pressurized to greater than 49 psig, then: REDUCE Rack #15 pressure to less than 49 psig as follows:

CLOSE a penetration gauge isolation valve. _

RECORD number of penetration gauge valve closed in Step above Valve No: K -"J "

Slowly REMOVE test connection cap for gauge isolated.

Slowly OPEN gauge isolation valve to reduce Rack #15 pressure to less than 49 psig, THEN:

CLOSE gauge isolation valve.

CONNECT test rig outlet to test connection.

OPEN gauge isolation valve. .. J20 OPERATE applicable leak rate test rig per O-OSP-IST-O01, Leak Rate Test Rig Operation to maintain 53 psid across Zone 2 Rack #15.

WHEN pressure and flow stabilize, THEN RECORD data below as required: ýp WCCPPS Rack #15 TIME PRESSURE TEMP FLOW READING (minutes) (psig) (OF) (sccm) 5 1(.3 10 _¢b r-15 READIN AVERAGE IVýLa

/4/

IF desired to identify leaking penetration(s), perform Attachment 1.

CLOSE gauge isolation valve on Rack #15.

Ž6 CLOSE test rig inlet valve.

DEPRESSURIZE test rig through test rig vent.

IF Volumetrics Leak Rate Monitor was used, THEN CALCULATE average flow from data table and RECORD below:

Indicated Average Flow: I C.a'-_ cc%

x IF B&C Test Rig was used, THEN PERFORM leakrate calculations per O-OSP-IST-001, Leak Rate Test Rig Operation. ATTACH completed calculation sheet to test package. /

Calculated leakrate: sccm 7/

PERFORM restoration for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

Install test connection cap.

fV Ifdesired to depressurize Rack #15, Then REDUCE Rack #15 pressure as follows or equivalent:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: - - -

2+/-

Slowly REMOVE test connection cap for gauge isolated.

Slowly OPEN gauge isolation valve to depressurize Rack #15. 4@

After depressurize complete, INSTALL test connection cap.

PERFORM Restoration lineup per Attachment 2 Section 8, Rack #15 Post Test Valve Lineup.

1.7 Leakage Test for WCPS Rack #10 PERFORM Pre-Test lineup per Attachment 2 Section C, WCPS Rack #10 Test Valve Lineup.

NOTE WCPS Zone 2 is isolated and depressurized to preclude possible inleakage through PS-PCV-1 110-10, PS-PCV-1 110-11 and PS-PCV-1 110-15 during test.

WCPS Zone 2 air receiver may remain pressurized during this test.

NOTE Test pressure must be applied to maintain a minimum of 53 psig across zone being tested.

PERFORM setup for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

If Rack #10 is depressurized, repressurize using bypass on Leak Rate Test Rig or equivalent as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: 0'C-IILi-i'.hJ Slowly REMOVE test connection cap for gauge isolated.

CONNECT test rig outlet to test connection.

Open gauge isolation valve.

Increase Rack #10 pressure to 49 psig using bypass on Leak Rate Test Rig or equivalent.

If Rack #10 is pressurized to greater than 49 psig, then: REDUCE Rack #10 pressure to less than 49 psig as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: ___ -_

_________J N _

Slowly REMOVE test connection cap for gauge isolated.

Slowly OPEN gauge isolation valve to reduce Rack #10 pressure to less than 49 psig, THEN:

CLOSE gauge isolation valve.

CONNECT test rig outlet to test connection. AL-"

OPEN gauge isolation valve.

OPERATE applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation to maintain 53 psid across Zone 2 Rack #10.

WHEN pressure and flow stabilize, THEN RECORD data below as required:

WCPS Rack #10 TIME PRESSURE TEMP

FLOW READING (minutes) (psig) (OF) (sccrn) 15 . L AVERAGE q y READING -____ __

IF desired to identify leaking penetration(s), perform Attachment 1.

CLOSE gauge isolation valve on Rack #10.

CLOSE test rig inlet valve.

XD DEPRESSURIZE test rig through test rig vent.

IF Volumetrics Leak Rate Monitor was used, THEN CALCULATE average flow from data table and RECORD below:

Indicated Average Flow: _ _ _ __ _

sccm IF B&C Test Rig was used, THEN PERFORM leakrate calculations per 0-OSP-IST-001, Leak Rate Test Rig Operation. ATTACH completed calculation sheet to test packa e.

Calculated leakrate: sccm

PERFORM restoration for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

Install test connection cap.

IV CLOSE a penetration gauge isolation valve. W RECORD number of penetration gauge valve closed in Step above Valve No: VC-J- IIol /

-0*1-Slowly REMOVE test connection cap for gauge isolated.

Slowly OPEN gauge isolation valve to depressurize Rack #10.

Al-After depressurize complete, INSTALL test connection cap.

PERFORM Restoration lineup per Attachment 2 Section C, Rack #10 Post Test Valve Lineup.

1.8 Leakage Test for WCPS Rack #11 PERFORM Pre-Test lineup per Attachment 2 Section D, WCPS Rack #11 Test Valve Lineup.

NOTE WCPS Zone 2 is isolated and depressurized to preclude possible inleakage through PS-PCV-1 110-10, PS-PCV-1 110-11 and PS-PCV-1 110-15 during test.

WCPS Zone 2 air receiver may remain pressurized during this test.

NOTE Test pressure must be applied to maintain a minimum of 53 psig across zone being tested.

PERFORM setup for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

If Rack #11 is depressurized, repressurize using bypass on Leak Rate Test Rig or equivalent as follows:

CLOSE a penetration gauge isolation valve.

1-I RECORD number of penetration gauge valve closed in Step above Valve No: -! I/(i-'--"t-Slowly REMOVE test connection cap for gauge isolated.

CONNECT test rig outlet to test connection.

Increase Rack #11 pressure to 49 psig using bypass on Leak Rate Test Rig or equivalent.

Open guage isolation valve.

If Rack #11 is pressurized to greater than 49 psig, then: REDUCE Rack #11 pressure to less than 49 psig as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step .

above Valve No: .CU J(J*A-Slowly REMOVE test connection cap for gauge isolated. ___-_

Slowly OPEN gauge isolation valve to reduce Rack #11 pressure to less than 49 psig, THEN:

CLOSE gauge isolation valve.

CONNECT test rig outlet to test connection. __"

OPEN gauge isolation valve.

OPERATE applicable leak rate test rig per O-OSP-IST-001, Leak Rate Test Rig Operation to maintain 53 psid across Zone 2 Rack #11.

WHEN pressure and flow stabilize, THEN RECORD data below as required:

WCPS Rack #11 TIME PRESSURE TEMP

FLOW READING (minutes) (psig) (OF) (sccm) 10AEA 15 69~ ~

READING ~ 42 IF desired to identify leaking penetration(s), perform Attachment 1.

CLOSE gauge isolation valve on Rack #11.

':ýyl CLOSE test rig inlet valve.

DEPRESSURIZE test rig through test rig vent.

IF Volumetrics Leak Rate Monitor was used, THEN CALCULATE average flow from data table and RECORD below:

Indicated Average Flow: sccm IF B&C Test Rig was used, THEN PERFORM leakrate calculations per 0-OSP-IST-001, Leak Rate Test Rig Operation. ATTACH completed calculation sheet to test packaqe.

Calculated leakrate: 1ý14 sccm

ATTACHMENT 1 LEAKAGE IDENTIFICATION Identify individual leaking penetration(s) by closing penetration isolation valve and subtracting from previously recorded total.

Rack/Isolation VIv Rack Total (A) New total with Leakage of valve closed (B) Isolated Line (A-B) 4 -4 4 4 4 4 4 4

ATTACHMENT 2 SECTION A WCPS TEST TEST VALVE LINEUP (Page 1 of 1)

PRE-TEST POST-TEST VALVE DESCRIPTION AS TEST L/U INIT NORM LIU AS LEFT INIT IV FOUND O PCV-1110-15 WCPS Supply to Rack #15 Isolation CLOSED PCV-1 110-11 WCPS Supply to Rack #11 Isolation CLOSED OPEN /

PCV-1110-10 WCPS Supply to Rack #10 Isolation _OPEN_

_CLOSED Pcv- 1101VVE PTO ')

01v/JU-e Pcv- 1) o I UL) 13

ATTACHMENT 2, WCCPPS RACKS #15, #10 & #11 TEST VALVE LINEUP SECTION B, Rack #15 _

VALVE DESCRIPTION PRE-TEST POST-TEST AS TEST L/U INIT NORM AS INIT INDEP FOUND LIU LEFT VERIF Penetration WCPS Rack #15 Penetration Supply All Valves All Valves .1I Supply Isolation Isolations -.* Open Open ",F4w Valves u Y0m Gauge Isolation WCPS Rack #15 Gauge Isolations All Valves All Valves Valves Open Open

........ _SECTION C, Rack #10 ___

VALVE DESCRIPTION PRE-TEST POST-TEST AS TEST LJU INIT NORM AS INIT INDEP FOUND LJU LEFT VERIF Penetration WCPS Rack #10 Penetration Supply e1( All Valves All Valves ccl y Supply Isolation Isolations Open Open Valves __ __

Gauge Isolation WCPS Rack #10 Gauge Isolations afl All Valves All Valves 60V Valves ___________ pný Open I____

ATTACHMENT 2, WCCPPS RACKS #15, #10 & #11 TEST VALVE LINEUP SECTION D, Rack #11 STEP 4.4.2 STEP 4.4.15 PRE-TEST POST-TEST VALVE DESCRIPTION AS TEST LIU INIT NORM AS INIT INDEP FOUND L/U LEFT VERIF Penetration WCPS Rack #11 Penetration Supply All Valves All Valves Supply Isolation Isolations Open Openi Valves _ 0)____ Open Gauge Isolation WCPS Rack #11 Gauge Isolations All Valves All Valves Valves Open Open IAStvt) OQ Q04 \\

) VIC

Attachment Header Document Name:

untitled Document Location ISubresponse Description Attach

Title:

Pone 1 Wo.r Order

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18693 PAGE 1 of 10 111il11l 1111 1111111 l 1III1 HE1111111111 11111l I11II11M 11II 11l1 G4/30/20C6 09:49 Problem / Work Requested:

INVESTIGATE / TROUBLESHOOT AIR LEAKAGE FROM WELD CHANNEL ZONE 1 Location: WCPS-ZONE-1 Loc.Descrip: WELD CHANNEL PRESSURIZATION ZONE 1 Building / Elevation: N/A Equipment: OTHR2008-001

Description:

Model # UNK- Serial # UNK Reported By: AMIHALI Date: 04/26/2006 Planner: SBYRNE Supervisor: <none> Loop: <none>

Priority: 8 System: WCPS QA Class: A Work Typ e : P OTHER EQ: N Outage ID: 17E Week/Mode: MODE4 Status: INPROG Project No: <none>

Response Dep:MFIN Change of Scope YES / NO (circle one):

Release for Work Supervisor to verify WO in progress : Date:

LCO / AOT #:

Tagout#(s):

Work Complete / Closeout Supervisor / Lead: Date:

Retest Reqd? Yes / No In Scone of Work Signature./Dat-e WRT Lcc: No tag hung Work Accepted (WCC) Yes / No New WO Number:

S1Enature' rDate STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 2 of 10 WORK ORDER # IP2-06-18693 04/30/2006 09:49 1111111111111 Hil11111i11111 i 111111iiii11111i11111 tili iltli iiHi1lill Work Order Hierarchy WO# Description Parent WO This Workorder Has NO Hierarchial Family Controlled Documents and Records Document Description Revision

References:

As per CR 2006-02113 This is a mode hold item for cold shudown.

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 AAG1 3 of10 WORK ORDER # IP2-06-18693 fl~

HHE 11111111111111fi1

~~~~11111111 Il~t 1111 111W ll 04/30/2006 09:49 Plant Impact Matrix PIMX Desc.:

OPS Impact Summary:

Prepared By:

Prepared Date:

Independent Review:

2nd SRO:

LCO/AOT/TRM/ODCM:

LCO 2nd SRO:

LCO(Admin)

Reference:

LCO(Admin)Ref Duration:

LCO Ref Duration 2nd SRO:

Equipment to Protect:

Equip to Protect IR:

Special Entergy Power Mktg Notify:

Special Entergy Notify IR:

OPS Proc Refs:

OPS Proc IR:

OD/TFC/TPC/Caution Tag:

OD/TFC IR:

Precautions or Removal Plan:

Prec or Remove IR:

Contingency Plans Required:

Cont Plans Req IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAG_ 4 of 10 WORK ORDER # IP2-06"18693 04/13/2006 09:49 CCR Brief Required:

CCR Brief IR:

On-Line Risks:

Instrument Bus Spike:

Instrument Bus IR:

Proximity Risk:

Proximity Risk IR:

Reactor Trip:

Reactor Trip IR:

Feedwater Transient:

Feedwater Trans IR:

Loss of Offaite Power:

Loss of Offsite IR:

Reactivity:

Reactivity IR:

On-Line PRA:

On-Line PRA IR:

ShutDown Risks:

Decay Heat Removal:

Decay Heat IR:

RCS Inventory:

RCS Inventory IR:

Power Availability:

Power Availability IR:

Reactivity:

Reactivity IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 5 of10 WORK ORDER # IP2-06-18693 04/30/2006 09:49 RCS/VC Integrity:

RCS/VC IR:

SFP,Rad Mon,HVAC:

SFP,Rad Mon,HVAC IR:

ShutDown PRA:

ShutDown PRA IR:

CCR Impact:

CCR Impact IR:

Activity Location:

Activity Location IR:

Estimated Alarm Severity(#per Hour):

Estimated Alarm IR:

Estimated # of Personnel in CCR:

Estimated # of Personnel IR:

Restoration Plan Required:

Restoration Plan IR:

Unnecessary Entry into LCO:

Challenge to VC Integrity:

Chem/Rad Release/Spill:

Loss of Configuration Ctrl:

New Sys Components from DCP:

OPS Proc Refs and Verify Rev:

OPS Proc Refs IR:

PWT Printed:

PWT Correct for Plant Cond:

PWT Correct Plant Cond IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 6 of 10 WORK ORDER # IP2-06-18693 1111111l1111111111111111 l111111111l111l11 il111l111l111l111104/30/2006 C9:49 Is LCO Info in LCO DB:

Is LCO Info in LCO DB IR:

Tag-Out Review Complete:

Tag-Out Review Complete IR:

STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 WORK ORDER # IP2-06-18693 PAGE 7 of 10 11111ll 1111111111 HEl lllIIIIl 111I1II111 IIII III1II f11 l I1111111II04/30/2006 09:49 Job Details Job Plan: <none> Work Class: <none> IST Related: <none>

Rep Task ID: <none> Task Type: <none> SectionXI/Qual Grp:*

PWT: <none> Defic Type: <none> Risk Significant: <none>

PCRS #: 2006-2113 Engineer: <none> Maint Rule:

Department Billed: V32 GL Account: NEV32-7A000-IP2-CROT-F3PC5MTCRO-095 Permits and Support Job Plan # <none>

Notifications RWP: <none> -

Safety Group: <none> -

Radwaste: <none> -

Fire Protection: <none> -

Quality Control: <none> -

Other Notifications: <none> -

Health Physics: <none> -

Recluirements Fall Protection: <none> -

FME Clean Level: <none> -

Cleanliness: <none> -

Support

... Chemistry Department: <none>,-

Crane / Forklift Required: <none> -

Scaffold Required: <none> -

Temporary Power Required: <none> -

Security Coordination: <none> -

Cutting, Burning, Welding permit: <none> -

Insulation Removal Required: <none> -

Other Support Required: <none> -

Precautions / Hazards Flammable / Explosion Concerns: <none> -

Heat Stress Requirements: <none> -

Hazardous Chemical: <none> -

Asbestos: <none> -

Lead Abatement: <none> -

Electrical High Voltage: <none> -

Respiratory Requirements: <none> -

Confined Space Permit: <none> -

Other Precautions / Hazards: <none> -

Work Instructions STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 8 of 10 WORK ORDER # IP2-06-18693 04/30/2006 09:49 11I 11I 1111111 HIE 1I1111111IIII 11l1l 11i11111111111l I1lnl I11lll 1l11111 Actions Taken 4/28/06 - 17E Mode4 per scope #366- Bengis as sysadm Found zone 1 secured. Placed zone 1 in service as per 2-sop 10.5.1. Allowed system to stabilize at pressure. Systematically did drop test on all points on racks 12 & 13. Found the following penterations leaking RACK 12 H-25 & H-28 ( very minor pressure drops on both)

RACK 13 H-20 & H63 1-20 had signifgant pressure drops, H-63 H

had lesser pressure drop)

Need to go into VC to snoop the four penetrations for external leakage Poplees/Mahalic 4/28/06 As-Found Condition:

kJc&LL0t (g4t-( JVtjrA4 4. rjgt A

~J~ALt*A rja- L-

\J(4t.X ,.xojL- LAP9& c r .A TPL ~-/

N~r~A4 'V Oq~w -304 STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 9 of 10 WORK ORDER # IP2-06-18693 04/30/2006 09:49 1I i III111111 IIIl HEI 11111 11111 li1111111111 111111 III lHA III Parts Used Class Stock Number Green Tag Number M & TE Calibration / Due Date Step Used STOP THINK ACT REVIEW Set Your Teammates Up For Success

Indian Point Energy Center IP2 Information Copy - Rev 0 PAGE 10 of 10 WORK ORDER # 1P2-06-18693 04/30/20G.6 09:49 NO Planned Materials STOP THINK ACT REVIEW Set Your Teammates Up For Success

WORK STEP LISTS OASL 15.86 Rev. 0 S ATTACHMENT I WORK STEP LIS

( Page 1 of 2)

WSL Number: 33/ - Z (Use "year I Month / day I time" as the number - Example 01040712:31 )

Date: / / 3:, /6 6 - Page 1 of_-3 System / Component affected: Vt/l d - k \cai (I Z .,-e (

Purpose of Step list: . T /h -L 1T o- L,. l c, 1 ,, t.

References used in step list development: -o a Prepared By: / ..

Reviewed By: £ /~\ -' /

Approved By:.- OM "

/AO M / GSM Rad Engineer:

(Required IF there is a potential for a Radiological problem.)

NOTE it MAY be acceptable to pserformsome steps concurrently OR NOT in the sequence .

presented provided the SM approval is obtained.

Prerequisites:

1. Briefing held outlining Precautions, Limitations, Safety concerns, Scope of work etc..

2. Verification that equipment status is as expected prior to performance of Work Step List.

Page 2 of 3

1.1 Precautions And Limitations To prevent injury to personnel and/or damage to equipment, care SHALL be exercised when venting lines Test pressure must be applied to maintain a minimum of 53 psid across zones being tested.

1.2 General Information Personnel directing this test SHALL read it in its entirety prior to performing test. Personnel otherwise involved SHALL read applicable sections.

Any discrepancies found SHALL be identified in Comments section Nitrogen or air may be used as a test medium.

Test apparatus and system boundaries SHALL be checked for leakage with Snoop or equivalent while pressurizing system. Tightening fittings, valve packing, etc.

as required is allowable. Leakage from components other than penetrations being tested will result in erroneous data.

Pressure test gauges SHALL be a 1/4% gauge calibrated to +/-1/4%. Gauge ranges may vary from those specified in Step 1.3 provided range on gauge does NOT exceed three times expected value.

1.3 Equipment required for test:

EQUIPMENT SERIAL # CAL DUE INITIALS I I I DATE 0-100 PSIG TEST GAUGE AAA..

B&C RIG THERMOMETER IVA JA.

B& C LOW w VA, #

TEST RIG MEDIUM A-r FLOWMETERS HIGH * /,L VOLUMETRICS LEAK RATE MONITOR cs.u* f--3-- .h b7 IF Volumetrics Leak Rate Monitor is used, THEN MARK N/A.

- IF B&C Test Rig is used, THEN MARK N/A.

PERFORM Pre-Test lineup per Section A, Test Valve Setup of Attachment 1, WCCPPS Racks #12 & 13 Test Valve Lineups.

U

NOTE WCCPPS Zone 1 is isolated and depressurized to preclude possible inleakage through PS-PCV-1 110-12 and PS-PCV-1 110-13 during performance of test.

WCCPPS Zone 1 air receiver may remain pressurized during this test.

DEPRESSURIZE WCCPPS Zone I per SOP-10.5.1, Weld Channel and Containment Penetration Pressurization System /

Operation.

PERFORM setup for applicable leak rate test rig per 0-OSP-IST-001, Leak Rate Test Rig Operation.

Leakage Test for WCCPPS Rack #12 PERFORM Pre-Test lineup per Section B, Rack #12, of Attachment 1, WCCPPS Racks #12 & 13 Test Valve Lineups.

REDUCE Rack #12 pressure to less than 49 psig as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: (:d -lp,o - .I 1

Slowly REMOVE test connection cap for gauge isolated. T7 Slowly OPEN gauge isolation valve to reduce Rack #12 pressure to less than 49 psig.

V>f WHEN Rack #12 pressure is less than 49 psig, THEN:

CLOSE gauge isolation valve.

CONNECT test rig outlet to test connection.

OPEN gauge isolation valve.

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OPERATE applicable leak rate test rig per O-OSP-IST-001, Leak Rate Test Rig Operation.

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WHEN pressure and flow stabilize, THEN RECORD data below as required:

WCCPPS Rack #12 TIME PRESSURE TEMP* 1FLOW READING (minutes) (psig) (OF) (sccm) 15 AVERAGE READING p...

If desired to identify leaking penetration(s), perform Attachment 2 ,/

CLOSE gauge isolation valve on Rack #12.

CLOSE test rig inlet valve.

DEPRESSURIZE test rig through test rig vent.

IF Volumetrics Leak Rate Monitor was used, THEN CALCULATE average flow from data table and RECORD below: I Indicated Average FIow: fsccm IF B&C Test Rig was used, THEN:

PERFORM leakrate calculations per 0-OSP-IST*"

001, Leak Rate Test Rig Operation.

0" (!

RECORD calculated leakrate from 0-OSP-IST-001, Leak Rate Test Rig Operation:

Calculated leakrate: sccm .*

ATTACH completed calculation sheet to test package.

DISCONNECT test rig from Rack #12 test connection.

REPLACE the test connection cap IV PERFORM Post-Test lineup per Section B, Rack #12, of , WCCPPS Racks #12 & 13 Test Valve Lineup.

~7 AG

Leakage Test for WCCPPS Rack #13 PERFORM Pre-Test lineup per Section B, Rack #13, of Attachment 1, WCCPPS Racks #12 & 13 Test Valve Lineups.

REDUCE Rack #13 pressure to less than 49 psig as follows:

CLOSE a penetration gauge isolation valve.

RECORD number of penetration gauge valve closed in Step above Valve No: V)C, 7 - (CV-//gj - /-

Slowly REMOVE test connection cap for gauge isolated. L -

Slowly OPEN gauge isolation valve to reduce Rack #13 pressure to less than 49 psig.

WHEN Rack #13 pressure is less than 49 psig, THEN:

CLOSE gauge isolation valve.

CONNECT test rig outlet to test connection.

OPEN gauge isolation valve. __

OPERATE applicable leak rate test rig per O-OSP-IST-O01, Leak Rate Test Rig Operation.

WHEN pressure and flow stabilize, THEN RECORD data below as required:

WCCPPS Rack #13 TIME PRESSURE TEMP

FLOW READING (minutes) (psig) (OF) (sccm) 10 L3,__

_5 15 AVERAGE "o READING 07

If desired to identify leaking penetration(s), perform CLOSE gauge isolation valve on Rack #13.

CLOSE test rig inlet valve. '1 DEPRESSURIZE test rig through test rig vent.

IF Volumetrics Leak Rate Monitor was used, THEN CALCULATE average flow from data table and RECORD below:

Indicated Average Flow: I O *. "Ssccm IF B&C Test Rig was used, THEN:

PERFORM leakrate calculations per 0-OSP-IST-001, Leak Rate Test Rig Operation.

RECORD calculated leakrate from 0-OSP-IST-001, Leak Rate Test Rig Operation:

I;!

Calculated leakrate: sccm ATTACH completed calculation sheet to test package.

DISCONNECT test rig from Rack #13 test connection.

~4~2 REPLACE the test connection cap IV PERFORM Post-Test lineup per Section B, Rack #13, of , WCCPPS Racks #12 & 13 Test Valve Lineup.

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ATTACHMENT 1, WCCPPS RACKS #12 & 13 TEST VALVE LINEUPS (Page 1 of 1)

SECTION A, Test Setup VALVE DESCRIPTION PRE-TEST POST-TEST AS FOUND TEST LIU INIT NORM LIU AS LEFT INIT IV PS-PCV-1110-12 WCCPPS Supply to Rack #123.solation CLOSED OPEN PS-PCV-1110-13 WCCPPS Supply to Rack #13.Isolation OS- CLOSED OPEN SECTION B, Rack #12 VALVE DESCRIPTION PRE-TEST POST-TEST AS FOUND TEST LU INIT NORM JU AS LEFT INIT IV Penetration Sup WCCPPS Rack #12 Penetration Supply ALL VALVES n ALL VALVES Isol Valves Isolations OPEN,/ OPEN C -

Gauge Isol Vlvs WCCPPS Rack #12 Gauge Isolations ALL VALVES ALL VALVES 0..

__________________ OnI OPEN- OPEN SECTION C, Rack #13 VALVE DESCRIPTION PRE-TEST POST-TEST AS FOUND TEST L/U INIT NORM LJU AS LEFT INIT IV Penetration Sup WCCPPS Rack #13 Penetration Supply ALL VALVES ALL VALVES Isol Valves Isolations 0 pe r.J OPEN OPEN O .

Gauge Isol Vlvs WCCPPS Rack #13 Gauge Isolations I ALL VALVES ALL VALVES

_ ____jjOPEN OPEN )_ I _

jGjP

Attachment 2 To identify leaking penetration(s) close penetration isolation valve in sequence, as desired. Record below.

Penetration Supply Isolation Valve New Flow Rate Closed (sccm)

___ __ [1-2A _ __ 77'Wccccv ý V7~.W~14? 5"D

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Attachment 2 To identify leaking penetration(s) close penetration isolation valve in sequence, as desired. Record below.

Penetration Supply Isolation Valve New Flow Rate Opened (sccm)

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3

Entergy CORRECTIVE ACTION CR-IP2-2006-02113 CA Number: 2 Group I Name Assigned By: CRG/CARB/OSRC ReynoldsJoseph A Assigned To: P&C Eng Codes Mgmt AzevedoNelson F Subassigned To : P&C Eng Codes Staff Bergren,Christopher J Originated By: Reynolds.Joseph A 4/24/2006 20:59:35 Performed By: Azevedo,Nelson F 5/22/2006 05:16:31 Subperformed By: Bergren.Christopher J 5/18/2006 12:28:54 Approved By:

Closed By: Reynolds,Joseph A 5/22/2006 06:44:40 Current Due Date: 05/23/2006 Initial Due Date: 05/23/2006 CA Type: DISP- ACE/LT CA Priority:

Plant Constraint: #NONE CA

Description:

Please perform Lower-tier apparent cause evaluation of this ILRT unacceptable leakage issue and assign further corrective actions as required. Note a corrective action was assigned to CA&A to document the CARB presentation of your evaluation.

Response

See sub response below.

Subresponse :

See attached report. CA 00004 issued after acceptance by Operations Procedure Group.

Closure Comments:

Per CA&A review, noted the response addressed all expected discussion points and was therefore accepted pending CARB review. CA# 3 assigned to document the results of the CARB review, therefore this CA completed and closed.

Attachments:

Subresponse Description ILRT Penalty B Report

Attachment Header Document Name:

iuntitled Document Location ISubresponse Description Attach

Title:

JILRT Penalty B Report

LOWER-TIER APPARENT CAUSE Sheet I of 3 Condition Report Number: Assigned Department:

CR-IP2-2006-02113 Programs & Components Engineering PROBLEM STATEMENT: (The WHAT) (see Procedure step 5.4[2](a))

The Integrated Leak Rate Test (2-PT-1i Y001) performed in 2R17 had actual test results of 0.0587 %wt/day which meets the acceptance criteria of <0.075 %wt/day. However, certain suspected leakage paths were isolated as procedurally controlled contingency actions during the test. When this was done, penalties were taken based on previously recorded Type B and Type C leakage results for those isolated portions. When these penalty amounts were added to the actual leakage, the total leakage was administratively changed to 0.0799 %wt/day which exceeded the acceptance criteria. These known leakages had to be reduced prior to startup to meet the 0.075 %wt/day requirement.

EXPLANATION OF PROBLEM: (The HOW) (see Procedure step 5.4[2](b))

The penalty addition process is part of the ILRT procedure. The process uses leakages from the most recent Type B and Type C testing results for any containment penetration which can not be tested by the ILRT or is isolated during the ILRT. Several penetrations were isolated during the ILRT due to suspected leakage. Weld Channel System (WOPS) Zones 1 and 2 were among those isolated. Therefore, the last Type B testing results for those Zones were added to the ILRT.

Type B testing for Zones 1 and 2 was last performed in test 2-PT-R1 1 in December, 2005 with a combined documented leakage of approximately 38,000 cc/min. Penalty addition from these zones was sufficient in themselves to exceed the acceptance criteria as stated in the condition report. Although the penalty addition was procedurally controlled, a condition report was deemed appropriate to ensure that the technique was identified to outage management as a restraint to mode change pending resolution.

The test 2-PT-R1 1 has a comparatively large acceptance criteria of 0.2 %wt/day and is performed in a manner which provides information about the total WCPS leakage rather than exact values for each individual system rack or penetration. The result is that the reported system leakage is in excess of actual leakage at each welded penetration sleeve. A plan was immediately implemented to test and identify the actual penetration leakage for the two zones.

The intent of the plan was to replace the overly conservative values taken in 2-PT-R1 1 with actual penetration leakage. This plan was successful as documented in CA 00001 of this condition report (See attached Recovery Plan). The resulting actual values replaced the values from 2-PT-R1 1 resulting in a satisfactory preliminary ILRT result.

The identified problem is the use of overly conservative leakage values for WCPS Zones 1 and 2 as penalties in the 2R17 ILRT. The use of the overly conservative values resulted in a temporary mode restraint that could potentially have been avoided.

One method of avoiding the use of the penalty would have been to un-isolate WCPS Zone 1 and Zone 2 prior to the end of the ILRT. This action was rejected during the test because the

LOWER-TIER APPARENT CAUSE Sheet 2 of 3 actual leakage was not known and there was a desire to limit entering and exiting contingency actions since the containment air mass takes time to react to each specific change. This could have added substantially to test time.

A better method would have been to know the actual penetration leakage before the test so that, when the penalties were added, the result would not have exceeded the acceptance criteria. An action to verify actual leakage might still have been implemented but the mode restraint would not have been required.

When testing for system leakage in 2-PT-R1 1, Zones 1 and 2 are evaluated for contribution to Type B leakage because those zones protect containment penetrations. The test is conducted by excluding leakage from Type C sources (such as containment purge or pressure relief valves) since those sources have their own tests and penalties. The remaining leakage is totaled against the overall technical specification limit of 0.06 wt%/day. This leakage is evaluated on the basis of system usage rather than by performing a local leak rate test at the rack penetrations. A similar method applies to Zones 3 and 4 in that a system leakage is obtained in 2-PT-R1 1 rather than a rack-specific leakage. Zones 3 and 4, exclusive of the specific tests (such as fuel transfer tube and post accident containment venting), are used to provide a cover gas to liner welds in the containment structure. Based on suspected leakage, Zones 3 and 4 were isolated by closure of valves PCV-1111-1 and PCV-1111-2 against ILRT pressure. The ILRT pressurized and tested the liner welds directly and that leakage is included in the actual test result of 0.0587 wt%/day. Zones 3 and 4, after exclusion of specific tests mentioned above are not applicable to Type B or Type C testing and are not counted against the 0.06 wt%/day limit. Therefore, the existing methodology of 2-PT-R1 1 results in two test result values. The total of all four zones is tested against the criteria of 0.2 wt%/day and the portions of Zones 1 and 2 which do not have a specific Type C test are added to the running total for 0.06 wt%/day. These values are system-oriented and overly conservative when applied to specific penetration leakage.

Therefore, the values used for the Zones 1 and 2 penalties were overly conservative because they include system leakage in excess of actual leakage through the containment penetrations.

APPARENT/CONTRIBUTING CAUSE(S): (The WHY) (see Procedure step 5.4[2](c))

Why were overly conservative values from 2-PT-R1 1 used as penalties in the ILRT?

Because no specific racks or penetration testing was done before the ILRT.

Why was no specific rack or penetration testing done before the ILRT?

Because the effect of adding the overly conservative value was not anticipated.

Therefore, the apparent cause of this condition was the failure to anticipate the result of a contingency action.

The cause could be removed by revising 2-PT-R1 1 to provide a method to obtain specific rack or penetration test results for those portions of the test used as Type B test results.

LOWER-TIER APPARENT CAUSE Sheet 3 of 3 EXTENT OF CONDITION: (see Procedure step 5.4[2](d))

The use of penalties to formulate preliminary results is not normally used in surveillance testing and is unique to the ILRT procedure. Therefore, based on review of a sample of completed 2R17 surveillance tests, there are no other procedures to which the use of penalties applies.

CORRECTIVE ACTION(S): (see Procedure step 5.4[2](e))

1. Revise 2-PT-R1 1 to include a method to obtain rack or penetration specific values for those portions of Zones 1 and 2 which are applicable to Type B testing.

ISSUE / PROBELM SOLUTION / RESOLUTION / ACTION / COMPLETED

[note any Work Orders, MODs, other]

Example: Cords are currentlya trip Example: Cords were removed or raisedout of the pathway.

hazard.

PROPOSED/ASSIGNED CORRECTIVE ACTIONS ITEM # ISSUE/CAUSE SOLUTION / RESOLUTION TYPE Assigned Due Date PCRS

[note any Work Orders, MODs, CA Department CA#

other]

The previous work packages Electricalconduit will be run and CA Maintenance 0/0/0 00 Ex: did not specify guidance for outlets installedper work order (AC-1) placement of electrical number XXXXXX. On 1/1/01 the extension cords. CRG approved closure to this WO#.

AC-1 Overly conservative Revise 2-PT-R1 1 to CA Operations 9/14/06 04 values were placed include a methodology Procedure into the test to provided by IST Group address potential Engineer to determine Zone 1 and 2 leak best leak rates for these rates, rather than zones so that actual performing actual values are obtained for leak rate testing for ILRT(vice penalty these zones. estimates) to support more accurate test result conclusions.

EVALUATOR (Print Name) Date report completed Phone Extension of Investigator Chris Bergren 5/16/06 271-7216

Entergy I CA DUE DATE EXTENSION CR-IP2-2006-02113 Corrective Action : CR-IP2-2006-02113 CA-00002 Version: 1 Approved: W Requested Duedate: 05/23/2006 Previous Duedate: 05/17/2006 Requested By: Azevedo,Nelson F 05/12/2006 Approved By: LewandowskiPaul R 05/12/2006 Request

Description:

Please extend the due date to 5/23/06 to allow for additional review of the ILRT data which has been collected since this CR was first initiated. This extension has no impact on industrial or nuclear safety because all ILRT related issues have been resolved and the next ILRT will not occur for another 10 years. Supervisor concurrence has been obtained for this extension.

Approved

Description:

Per CA&A review, the request does not pose a safety hazard, interim controls are not required, the requestor is Supervisor/Superintendent level, and the extension does not exceed the 30-day limit. Therefore, the extension is approved.

Entergy CORRECTIVE ACTION CR-IP2-2006-02113 CA Number: 3 Group I Name I Assigned By: CA&A Staff ReynoldsJoseph A Assigned To: CA&A Staff Turnicki,Michael L Subassigned To :

Originated By: Reynolds,Joseph A 4/24/2006 21:00:56 Performed By: Schmnidt,George P 5/31/2006 09:43:27 Subperformed By:

Approved By:

Closed By: Schrnidt,.George P 5/31/2006 09:43:27 Current Due Date: 06/07/2006 Initial Due Date: 06/07/2006 CA Type: CARB REVIEW CA Priority:

Plant Constraint: #NONE CA

Description:

Document the results of the apparent cause (LT) presentation to the CARB.

Response

The CAT B / ACE report was presented to and accepted by the CARB on 5/30/2006 AS-IS.

This completes this assigned action, therefore this action is closed.

Subresponse :

Closure Comments:

Entergy CORRECTIVE ACTION CR-IP2-2006-02113 CA Number: 4 Group Name Assigned By: P&C Eng Codes Staff Bergren,Christopher J Assigned To: Operations Procedure Mgmt MillerMark J Subassigned To : Operations Procedure Staff Lane,.Betty J Originated By: Bergren,Christopher J 5/18/2006 12:22:24 Performed By: Miller,Mark J 9/12/2006 14:48:08 Subperformed By: Lane.Betty J 9/12/2006 14:35:14 Approved By:

Closed By: Miller,Mark J 9/12/2006 14:48:08 Current Due Date: 09/14/2006 Initial Due Date: 09/14/2006 CA Type: ACTION CA Priority:

Plant Constraint: HNONE CA

Description:

Revise 2-PT-Ri I to include a methodology provided by IST Engineer to determine best leak rates for these zones so that actual values are obtained for ILRT(vice penalty estimates) to support more accurate test result conclusions.

Response

Changes verified.

Subresponse:

Incorporated Eng. feedback Closure Comments:

Entergy CORRECTIVE ACTION I CR-IP2-2006-02113 CA Number: 5 Group I Name I Assigned By: CA&A Staff Reynolds,Joseph A Assigned To: P&C Eng Codes Mgrnt AzevedoNelson F Subassigned To :

Originated By: Schrnidt,George P 9/13/2006 10:04:49 Performed By: Azevedo,Nelson F 9/13/2006 10:29:43 Subperformed By:

Approved By:

Closed By: Reynolds,Joseph A 9/13/2006 15:31:43 Current Due Date: 09/26/2006 Initial Due Date: 09/26/2006 CA Type: CR CLOSURE REVIEW CA Priority:

Plant Constraint: #NONE CA

Description:

CAT-B, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND Approve OR Disapprove CLOSURE IN ACCORDANCE WITH EN-LI-102, SECTION 5.9.

Response

This CR is ready for closure.

Subresponse:

Closure Comments:

Per CA&A review, noted the CR owner recommended and approved the CR for closure.

v t e Letter Sequence Response to RAI
TAC:MF3369, Change in Technical Specifications End States - WCAP-16294 (Approved, Closed)
Initiation Request, Request Acceptance... Administration Withholding Request Acceptance Questions 18 March 2014 Answers 2 April 2014 8 June 2015 29 June 2015 Results Approval Other: ML14107A043, ML15160A406, ML15331A233, NL-14-001, Proposed License Amendment for Alternate Repair Criteria for Steam Generator Tube Inspection and Repair, NL-14-128, Proposed License Amendment Regarding Extending the Containment Type a Leak Rate Testing Frequency to 15 Years
MONTHYEAR2014-04-15 [Table View]

NL-15-068, Response to Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test

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