ML17299A391

Forwards Previous & Addl Relief Requests from Requirements of ASME Boiler & Pressure Vessel Code,Section Xi,Per 10CFR50.55(g)(5)(iii).Some Previously Submitted Relief Requests Revised as Annotated

ML17299A391
Person / Time
Site:	Palo Verde
Issue date:	06/28/1985
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Knighton G Office of Nuclear Reactor Regulation
References
ANPP-32925-EEVB, TAC-64953, TAC-64954, TAC-64955, NUDOCS 8507020506
Download: ML17299A391 (112)

Text

>>e~ "a, REGULAT NFORMATION DISTRIBUTION EM (RIDS)

ACCESSION NBR:8507020S06 DOC ~ DATE'5/06/28 NOTARIZED; NO

DOCKET FACIL:STN"50;528 Palo Verde Nuclear Stationi Unit li Arizona Publ,i 05000528 STN;50 529 Palo Verde Nuclear Station~

Unit 2i Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Statiogi Unit 3i Arizona Publi 05000530 AUTH INANE, AUTHOR AFFILIATION VAN BRUNTiE,E, Ar izona Public Service-Co.

RECIP ~ NAME RECIPIENT AFFILIATION KNIGHTONg G + li, L>>icensing Branch 3

SUBJECT:

Forwards preVious 8

addi>> relief requests from requirements of ASME Boiler 8 Pressure Vessel Code~Sect<on XIiper 10CFR50

~ 55(g)(5)(iii).Some, previously submitted relief requests revised as annotated.

DISTRIBUTION CODEi A047D COPIES RECEI/ED:LTR, ENCL 'IZE':

'l 5C, TITLE':

OR Submittal: Inservice'nspection/Testing NOTES:Standardized plant.

OL: 12/31/84 Standardized plant ~

Standardized plant.

05000528 05000529 05000530

~

RECIPIENT ID CODE/NAME>>

NRR LB3 BC 01-INTERNAL; ACRS 16 EI 0/HPS3 ed/~T.

04 COPIES LTTR ENCL 7

7 10 10 1

0 1

1 1

1 RECIPIENT IO CODE/NAME AOM/LFMB NRR/OE/MEB 1S NRR/OL/TAPMG RGNS

, COPIES LTTR ENCL" 0

1 1

1 EXTERNAL'4 24X NRC PDR 02 1

1 1-1 LPOR i>>IS I C 03 05 TOTAL NUMBER OF COPIES REQUIRED:

L'TTR 28 FNCL 26

~ f"

$ g lI f

7

~

l

~

~ ~

%flan

>>) )w (A f

~

f "C.'

Arizona Nuclear Power Project P.o. BOX 52034 4

PHOENIX, ARIZONA85072-2034 Director of Nuclear Reactor"Regulation Attention:

Mr. George W. Knighton, Chief Licensing Branch No.

3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555 June 28, 1985 ANPP-32925-EEVB/BJA

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3

PVNGS ASME Section XI Pump and Valve Testing Program Docket Nos.

STN 50-528(License No. NPF-41)/529/530 File:

85-056-026 G.1.01.10

References:

(1)

Letter from E. E.

Van Brunt, Jr.,

ANPP, to G.

W. Knighton, NRC, dated August 21, 1984 (ANPP-30290).

Subject:

PVNGS ASME Section XI Pump and Valve Testing Program.

(2)

Letter from E. E.

Van Brunt, Jr.,

ANPP, to T. Novak,

NRC, dated October 1, 1982 (ANPP-21932).

Subject:

PVNGS ASME Section XI Pump and'alve Testing Program.

(3)

Letter from E. E.

Van, Brunt, Jr.,

ANPP, to R. L. Tedesco, NRC, dated April 21, 1982 (ANPP-20680).

Subject:

PVNGS ASME Section XI Pump and Valve Testing Program.

Dear Mr. Knighton:

The above referenced letters were previous submittals of relief requests from the requirements of the ASME Boil'er and Pressure Vessel

Code,Section XI.

The attachment to this letter contains all of the previously submitted relief requests as well as some additional relief requests which have been identified since the last submittal. It should be noted that some of the previously submitted relief requests have been revised in this submittal.

These revisions are annotated with a vertical revision bar adjacent to the revised portions.

The attached relief requests are being submitted in accordance with the requirements of 10CFR50.55a(g)(5)(iii).

If you have any questions on this matter, please contact Mr. W. F. Quinn of my staff.

Very truly yours, pppjpppppp Bppb28 PDR ADPCK 05000PDR E, E. Van Brunt, Jr.

Executive Vice President Project Director EEVB/BJA/slh Attachments cc:

E. A. Licitra A. C. Gehr R. P.

Zimmerman J.

Page (all w/a)

S.i yS

ATTACHMENT 1 PUMP RELIEF REQUESTS

l I

PUMP RELIEF REQUEST NO.

1 SYSTEM Safety Related COMPONENT:

All pumps listed in the program.

CLASS:

263 FUNCTION:

To provide pumped liquid to safety related systems.

TEST REQUIREMENTS:

To measure bearing temperature.

BASIS FOR RELIEF:

,Industry data has shown that bearing temperature changes due to degrading bearings only occurs after major degradation has occurred at the pump.

Prior to this, the vibration measurement would provide the necessary information to warn the operator of an impending malfunction. Therefore, this parameter will not be measured, since its information is after the fact.

ALTERNATE TESTING:

None.

1, e

PUMP RELIEF RE UEST NO.

2 SYSTEM:

Diesel Generator Fuel Oil Transfer System COMPONENTS:

DFA-P01 and DFB-P01 P&ID & COORDINATES:

13-M-DFP-001 9 B-6 and B-2 CLASS:

FUNCTION:

To provide fuel oil to the standby diesel generators.

Measure displacement vibration amplitude of pump.

BASIS FOR RELIEF:

These pumps are immersable centrifugal sump pumps located in the emergency fuel oil storage tanks, therefore, are inaccessible for this type of testing.

ALTERNATE TESTING:

No alternate testing for this parameter is practical, however, all other parameters will be tested per Section XI requirements to show pump integrity.

PUMP RELIEF RE UEST NO.

3 SYSTEM:

Diesel Generator System COMPONENTS:

DGA"P02,DGB-P02,DGA-P03,DGB-P03,DGA-POS,DGB-POS P&ID AND COORDINATES:

13-M-DGP-00l: sht.

4 Q F7, F3; sht.

3 9 C7, C3; sht.

7 6 D7, D3.

An inservice test shall be conducted with the pump operating at nominal motor nameplate speed.

The resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the reference value.

The test parameters shall then be measured and observed and compared to the corresponding reference values.

BASIS FOR RELIEF:

These pumps are supplied as an integral part of the Diesel Generator skid package.

The operational readiness of these pumps will be ascertained by assuring the capacity of the pumps to fulfilltheir func'tion during the monthly diesel generator Technical Specification surveillance test.

ALTERNATE TESTING:

Operate the pumps monthly when the Diesel Generator is functionally tested in accordance with Technical Specifications 3/4.8.1.

4IO

PUMP RELIEF RE UEST N0.4 SYSTEMS:

Chemical and Volume Control, Safety Injection COMPONENTS:

CHA-P01, CHB-P01, CHE-P01, SIA-P05, and SIB-P05 P&ID Ec COORDINATES:

13-M-CHP-002 8 83, D3, and ('3 13-M-SIP-001 8 C14 and D14 CLASS:

FUNCTION:

CHA-P01, CHB-POl, and CHE-P01 are the three charging pumps.

SIA-P05 and SIB-P05 are the containment spray chemcial addition pumps (SCAP).

The charging pumps provide makeup to the reactor coolant system for chemistry and volume control.

In addition they provide auxiliary spray to the pressurizer during the final stages of shutdown.

The SCAP inject a controlled amount of hydrazine into the containment spray flow to remove radioactive elemental iodine from the containment atmosphere.

The inlet pressure and differential pressure shall be measured or observed and recorded.

BASIS FOR RELIEF:

These pumps are of positive displacement design and as such are designed to deliver constant capacity irrespective of inlet pressure or differential pressure across the pump.

The parameters important to monitoring pump degradation are discharge pressure and flow rate.

Measuring inlet pressure and differential pressure provides no meaningful information.

ALTERNATE TESTING:

No alternate testing fox these parameters is meaningful,

however, discharge pressure will be measured and recorded and all other parameters will be tested per Section XI requirements to show pump integrity.

4

PUMP RELIEF RE VEST NO.

5 SYSTEM:

Safety Related COMPONENT:

All pumps listed in the program CLASS:

2 & 3 FUNCTION:

To provide pumped liquid to safety related systems TEST RE UIREMENTS:

Measure displacement vibration amplitude of pump.

BASIS FOR RELIEF:

Standard industry practice is to use vibration velocity as a basis for the establishment of vibration standards for machinery operating at speeds from 600 to 12,000 rpm. Vibration velocity is used because vibration velocity is independent of frequency in this rpm. range, yielding a simple measure of the severity of vibration, see Ref. l.

AITERNATE TESTING:

Measure vibration velocity of the pump.

Allowable ranges for vibration velocity will be:

Acceptable

< 0.3 in /sec, alert 0.3 in /sec to 0.6 in /sec, Required Action > 0.6 in/sec, see Ref. 2.

Reference 1:

Shock and Vibration Handbook, second Edition

1976, C. K; Harris and C. E. Crede, Page 19-2.

eference 2:

The Practical Vibration Primer, C. Jackson, 1981 Page 43, Figure 8.1

1 I

I

PUMP RELIEF RE UEST NO. 6 SYSTEM:

Auxiliary Feedwater System (AF)

COMPONENT:

AFN-P01, AFA-P01, AFB-POI PAID COORDINATE:

13-M-AFP-001 9 H8, D8, B8 CLASS:

FUNCTION AFN-POl, AFA-POl, and AFB-P01 are the non-esential Auxiliary-Feedwater

Pump, the steam driven Aux Feedwater Pump and the motor driven Aux Feedwater Pump, respectively, and supply make-up water to the Steam Generator during start-up/shutdown conditions and subsequent to receipt of an AFAS (aux feed actuation signal).

Note AFN-P01 does not receive an AFAS.

TEST RE UIREMENT:

IVP-3100 requires that either the pump differ-ential pressure or flow rate be set and the other pump criteria (differential pressure or flow rate) be measured.

BASIS FOR RELIEF:

The hydraulic circuits for the ASME Section XI test for these pumps is via minimum flow recir-culation loop.

Minimum flow orifices installed in the line contr'ol constant flow.

High velocity fluid through the orifice ensures that they do not become plugged and orifice erosion would be detected as pump degradation and investigated accordingly.

ALTERNATE TESTING:

None; flow is constant but not measured.

I

PUMP RELIEF REQUEST NO.

7 SYSXSM:

Essential Chill Water (EC)

COMPONENT:

ECA-P01$

ECB-P01 P&ID COORDINATES:

13-M-ECP-001 8 B8$

B4 CLASS:

TEST REQUIREMENTS:

IWP-3100 requires that either the differential pressure or flow be measured (or set) and the other parameter (differential pressure or flow) be measured for degradation.

BASIS FOR RELIEF:

IWP-3112 permits establishment of different sets of reference values.

The Essential Chill water system has installed temperature control valves.

The control valves do not permit establishment of a single flow rate since the system will self-adjust to system loading conditions.

The acceptance criteria established is a band of values (as per IWP-3112) which compares a range of flow rates with a range of differential pressures.

The, acceptance band parallels the pump's characteristic curve.

Alert range bands and unacceptable pump performance bands were set correspondingly.

For any given flow rate, the acceptable differential pressure is equal to or conservativ relative to ASME ZI (ie 0.93 to 1.02 dPr) based on the pump's characteristic curve.

An example band is attached.

ALTERNATE TESTING:

None; testing performed as scheduled.

I i

r

o CCIliRGLILED DQCUNRMtl' o\\,

o PALO VERDE NUCLEAR GENERATING STATION MANUAL ESSENTIAL CHILLED WATER PUHP OPERABILITY 4.0o5 l

o PROCEDURE NO.

41ST-1EC02 REVISION cA-Wa I

g.assume, VK i

APPENDIX C Page 1 of 2 Page 13 of 14 I

ol. i F.I. o.M...C.<P.ue',

I o

'gtPfl" '

~o o:)

o, ie'r ~

S Pg

~

o

~'

~ o

'C

'lB

~ ~'g CC g~

RI

~ oc J(0 I

9f 2

~ :

~

~

o I

1

~ c J

I o

I I

I l

1 I

I

~

I I

l T; i

gb I

z5 o

I o

I y

~

I I

)

)

~

~

i I

7

(

II I

X

VALVE RELIEF RE UEST NO.

1 SYSTEM:

Chemical and Volume Control (CH)

COMPONENTS:

CH-UV-515, CH-UV-516, CH-UV-520, CH-UV-523, CH-UV-500 PAID COORDINATES:

13-M-dHP-001 8

H15, H15, E5, F13 13-M-CHP-002 8

F6 CATEGORY:

B,A,B,A,B CLASS:

CH-UV-515 and CH-UV-516 are Class 1, all others are Class 2

FUNCTION:

Valves are contained'n the normal letdown/volume control make-up loop TEST REQUIREMENTS:

Full Stroke exercise test once every three months or p'art stroke every three months and full stroke during cold shutdown.

BASIS FOR RELIEF:

Disrupting normal flow paths in order to full or partial stroke these valves could cause unwarranted transients in the RCS volume/boron concentration.

ALTERNATE TESTING:

Full stroke test these valves dur'ing cold shutdown.

l t

l 1

VALVE RELIEF REQUEST NO.

2 SYSTEM:

Essential Cooling Water (EW)

COMPONENTS:

EW-UV-65 and EW-UV-145 P&ID COORDINATES:

13-M-EWP-001 9 C8 and C4 CATEGORY:

CLASS:

FUNCTION:

Valves open to provide Nuclear Cooling (NC) water system with Essential Cooling Water (EW) in the event that the Nuclear Cooling water system is inoperable.

TEST REQUIREMENTS:

Full stroke exercise test every three months or part stroke exercise every three months and full stroke test during cold shutdown.

BASIS FOR RELIEF:

Full stroking or part stroking these valves during operation will produce high pressure in the Nuclear Cooling Water system.

"This could lead to the system becoming inoperable and necessitate shutdown of the reactor coolant pumps.

ALTERNATE TESTING:

Perform full stroke testing during cold shutdown.

E%

gl I

VALVE RELIEF REQUEST NO.

3 SYSTSM:

Safety Injection and Shutdown Cooling (SI)

COMPONENTS:

SI-V205 and SI-V206 PAID COORDINATES:

13-M-SIP-001 8 G14 and A14 CATEGORY:

CLASS:

FUNCTION:

These valves open to provide flow to the High Pressure Safety Injection pumps (HPSI), Low Pressure Safety Injection (LPSI) and Containment Spray (CS) pumps from the recirculation sump.

TEST REQUIREMENTS:

Full stroke exercise every three months or part stroke e'very three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

The recirculation sump is normally dry therefore full stroking cannot be established.

ALTERNATE TESTING:

Perform a partial stroke exercise test only every three months.

l

'l I

VALVE RELIEF REQUEST NO. 4 SYSTEM:

Safety Injection and Shutdown Cooling Systems COMPONENTS:

SIE-Vi14, SIE-V124, SIE-V134, SIE-V144 PAID COORDINATES:

13-M-SIP-002 Q F13, Fll, F6, and F4 CATEGORY:

C CLASS:

FUNCTION:

Valves open to provide flow paths from the low pressure safety injection headers to the Primary Coolant System.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

Flow cannot be established to full stroke exercise these valves during operation due to the pressure in the Primary Coolant System. Partial'troke exercising of these valves would require entry into the containment Radiological Controlled Area which is contrary to ALARA precepts.

ALTERNATE TESTING:

Full stroke exercise during cold shutdown.

I I

f

VALVE RELIEF REQUEST NO.

5 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENT:

SI-V164 and SI-V165 P&ID COORDINATES:

13-M-QIP-002 9 F9 and F5 CATEGORY:

AC CLASS:

FUNCTION:

Valves open to provide flow from Containment Spray pump to the discharge spray nozzles.

TEST REQUIREMENT:

Full stroke exercise every three months or part stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

Flow cannot be established without discharging water into containment.

Partial stroking during operation is prohibited by ALARA concerns as the valves and test connections are in containment.

ALTERNATE TESTING:

Perform partial stroke testing during refueling using test connections.

I l

VALVE RELIEF REQUEST NO;-

6 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENTS:

SI-V215, SI-V225, SI-V235, SI-V245 P&ID COORDINATES:

13-M-SIP-002 Q A15, A12, A7 and A5 CATEGORY:

AC CLASS:

FUNCTION:

To prevent backflow of Primary Coolant into the Safety Injection Tanks while providing a flow path for Safety Injection water into the RCS loops.

TEST REQUIREMENT:

Full stroke exercising every three months or part, stroke exercise every three months and full stroke test during cold shutdown.

BASIS FOR RELIEF:

Full stroke testing to stroke, these valves is not practical during any plant mode other than when the reactor vessel head is removed,'fuel is off-loaded, and the core barrel is removed.

Part stroke testing is feasible during hot shutdown.

Plant design conditions allows part stroke testing with a maximum of 35gpm through the valve.

ALTERNATE TESTING:

Part stroke exercise in Mode 3 after each refueling outage when the Safety Injection Tank. pressure. is

'bove 600 psig.

Additionally, disassemble valves and verify freedom of movement of disc motion on a 10 year year basis such that one valve is inspected every 10 years.

1 i

1

VALVE RELIEF RE VEST NO ~

7 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENTS:

SI-V113, SI-V123, SI-V133, SI-V143, SI-7404, SI-V405 P&ID COORDINATES:

13-M-SIP-002 8 F14, Fll, F7, F4 13-M-SIP-001 8 F50 B5 CATEGORY:

CLASS:

FUNCTION:

Valves open to provide, high pressure safety injection flow to the reactor coolant system.

I Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

These valves can only be full stroke exercised by initiation of flow through the valves and into the Reactor Coolant system.

Safety Injection pump head is insufficient to establish flow through the valves against Reactor Coolant System pressure.

Additionally, when the Reactor Coolant System pressure is

low, over pressurization of the RCS is possible if the Vessel head is installed.

(hallenging the Low Temperature Over Pressure protection (LTOP) system is unwarranted.

Partial stroke exercising of these valves would require the establishment of a flow path through valves addressed by Technical Specification Surveillance Requirement 4.4.5.2.2d and subsequent containment Radiological Controlled Area entry would be necessary by personnel, in order to meet this Tech.

Spec.

requirement.

Containment entry by personnel to satisfy T.S.

3/4.4.5.2.2d

'on a

quarterly basis during normal operations is an ALARA and radiation protection concern.

ALTERNATE TESTING:

The valves will be full stroked during refueling (Mode 6) when the vessel head is not installed.

r

'I I

'VALVE'RELIEF REQUEST'NO' SYSZSM:

Main Steam (SG)

COMPONENTS:

SG-UV-130, SG-UV-135, SG-UV-172, SG-UV-175 P&ID COORDINATES:

13-M-EGP-002 8 G12, C12, G12, and C12.

CATEGORY:

B CLASS:

FUNCTION:

Downcomer feedwater isolation valves TEST REQUIREMENT:

Full stroke test every three months or partial stroke. test every three months and full stroke test at cold shutdown.

BASIS FOR RELIEF:

Full stroke testing of these valves during power operation would isolate up to 15% of the normal feedwater flow to the steam generators and could cause an unwarranted plant transient and plant trip.

Partial stroking is not possible as the valves are not jog capable.

ALTERNATE TESTING:

Full stroke testing at cold shutdown.

5 L'

t VALVE RELIEF REQUEST NO.

9 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENTS:

SI-V217, SX-V227, SI-V237, SI-V247, SI-V540 SI-V541, SI-V542, SI-V543 P&ID COORDINATES:

13-M-SIP-002 9

B14, Bll, B6, B3, C14, Cll, C6, C3 CATEGORY:

AC CLASS:

FUNCTION:

Valves open to provide a flow path from Safety. Injection and Shutdown Cooling to the Primary Loop.

Valves close to prevent pressurization of SI piping from RCS loop..

TEST 'REQUIREMENT:

Full stroke open every three months or part stroke open every three months and full stroke open at cold shutdown.

BASIS FOR RELIEF:

These valves can only be stroked open by initiation of flow through the valves and into the RCS.

Safety Injection pump head is not sufficient to exercise these valves due to pressure of the RCS.

ALTERNATE TESTING:

t Full stroke exercise these valves during cold shutdown utilizing shutdown cooling.

VALVE RELIEF REQUEST NO.

10 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENT:

SI-V522, SI-V523, SI-V532, SI-V533 P&ID COORDINATES:

13-M-PIP-002 8

C3, F2, C10, F10 CATEGORY:

AC CLASS:

FUNCTION:

Valves open to provide a long term recirculation flow path for the High Pressure Safety Injection (HPSI) system to the shutdown cooling lines TEST REQUIREMENT:

Full stroke exercise test every three months or part stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

These valves can only be full stroke exercised by initiation of flow through the valves and into the RCS.

Safety Injection pump head is not sufficient to full stroke exercise these valves due to RCS pressure.

SI-V522 and SI-V532 cannot be part stroked during operation due to RCS pressure.

SI-V523 and SI-V533 cannot be part stroked during operation due to ALARA concerns as these valves and their test connections are in the containment building.

ALTERNATE TESTING:

Full stroke exercise test these valves during the refueling mode (Mode 6) when the reactor vessel head is removed using the Safety Injection system.

VALVE RELIEF REQUEST NO.'ll DELETE RELIEF REQUEST SUPERCEDED BY VRR NO. 41

& 42

t t

VALVE'RELIEF'EQUEST NO.

12 SYSTEM:

Chemical and Volume Control (CH)

COMPONENT:

CH-V431, CH-HV-203, CH-HV-205 P&ID COORDINATES:

13-M-CHP-001 9

Gll, H12, G12 CATEGORY:

C, B, B

CLASS:

FUNCTION:

Valves open to provide a flow path for Auxiliary Spray to the pressurizer.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise during cold shutdown.

BASIS FOR RELIEF:

Exercising these valves is not possible during power operation.

Their function is to protect the charging system from Reactor Coolant System pressure during normal operations and to provide auxiliary spray <<

cool/depressurize the pressurizer when the Reactor Coolant pumps are not operating.

Partial stroking is not possible since CH-HV-203 and CH-HV-205 are solenoid valves and control flow to CH-V431.

Stroking these valves during operation introduces unwarranted transients in RCS pressure and unwarranted thermal cycling of the pressurizer spray nozzle (reference Tech Specs 5.7.1).

ALTERNATE TESTING:

Full Stroke test during cold shutdown.

VALVE RELIEF REQUEST NO.

13 SYST EH:

Chemical and Volume Control (CH)

COMPONENTS:

CH-V787$ CH-V802, CH-V807, CH-V812, CH-V866 CH-V867, CH-V868, CH-V869, CH-V835, CH-HV-255 P6ID COORDINATES:

13-M-CHP-001 Q Hl, Gl, Fl, El, Hl, Gl, Fl, El G3, G4 CATEGORY:

CH-HV-255 is Category A

CH-V835 is Category AC All others are Category C

CLASS:

CH-V835 and CH-HV-255 are Class 2

All others are Class 1

FUNCTION:

Valves are open to provide a flow path for seal injection to the reactor coolant pumps.

Full stroke exercise every three months or partial stroke every three months and full stroke test at cold shutdown.

BASIS FOR RELIEF:

These valves are open during normal operation to provide seal injection to the reactor coolant pumps.

Stroking these valves closed would require discontinuing seal injection to the pumps and compromising reactor coolant pump seal integrity.

CH-HV-255 is.not jog capable so CH-HV-255 and all of the check valves down stream cannot be part stroked.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

It

VALVE RELIEF'REQUEST NO.

14 SYSTEM:

Chemical and Volume Control (CH)

COMPONENTS:

CH-HV-524, CH-VM70, CH-V433, CH-V429 P&ID COORDINATES:

13-M-CHP-001 8 D16, F15, G9, D16 CATEGORY:

A, AC, C, C

CLASS:

2, 2, 1, 2

FUNCTION:

Valves open to provide a flow path for the charging flow to the Reactor Coolant System and the pressurizer auxiliary spray.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

These valves are open during normal operation to maintain reactor coolant system chemistry, purity, and maintain RCS volume.

Stroking these valves closed during normal operation could upset the'hemical balance and cause unwarranted transients.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

VALVE RELIEF RE EST NO. 15 SYSTEM:

Nuclear Cooling Water (NC)

COMPONENTS:

NC-V118, NC-UV-401, NC-UV-402, NC-UV-403 PE(ID COORDINATES:

13-M-NCP-003 8 E6, E7, F7, F6 CATEGORY:

AC, A, A, A GLIBS:

FUNCTION:

Valves open to provide a flow path for nuclear cooling water supply/return to the reactor coolant pump lube oil coolers, reactor coolant pump seal coolers, and CEDM air coolers.

Full stroke test every three months or partial stroke test

'every three months and full stroke test at cold shutdown.

BASIS FOR RELIEF:

, These valves are open 'during normal operation to allow a supply of nuclear cooling water to the reactor coolant pump coolers.

Stroking these valves could cause overheating of the reactor coolant pump motor air coolers, lube oil coolers and compromise the integrity of the reactor coolant pump seals.

Stroking these valves could also cause overheating of the CEDM's and cause CEA's to drop into the core.

Partial stroking is not possible since the valves are not jog capable.

ALTERNATE TESTING:

Full stroke test these valves during cold shutdown.

J h

I i

r

'I

VALVE RELIEF"REQUEST NO16 SYSTEM:

Main Steam (SG)

COMPONENTS:

SG-V003, SG-V005, SG-V006, SG-V007-SG-V642, SG-V652, SG-V653, SG-V693 P &ID COORDINATES:

13-M-SGP-002, 9

E-10, A-10, A-10, E-10 G-ll, G-10, C-10, C-ll CATEGORY:

CLASS:

FUNCTION:

The normal function of the valves is 'to open and provide a flow path for feedwater flow to" the steam generators.

The safety function is to close.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

These valves are in the feedwater inlet lines to each steam generator and are open during power operations.

Full stroke or partial stroke testing of these valves during operation would requi're securing feedwater flow to the steam generator and cause a reactor trip.

Per Technical Specifications, Main Steam System is required to be operable prior to entering Mode 4.

These valves require Steam Generator pressure to back pressure test the valves for closing.

Adequate pressure in Steam Generator does not exist until in Mode 3.

ALTERNATE TESTING:

Test valves in Mode 3 when sufficient pressure is available for stroking valves to the closed position.

I

'll t

VALVE'RELIEF 'RE VEST'NO; '17 SYSTEM:

Chemical and Volume Control (CH)

COMPONENTS:

CH-V190 P&ID COORDINATES:

13-M-OHP-002 8

AS CATEGORY:

CLASS:

FUNCTION:

Valve opens with differential pressur'e to provide gravity flow from Refueling Water Tank (RWT) to the suction of the charging'pumps.

'EST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and fu3.3. stroke exercise at cold shutdown.

BASIS FOR RELIEF:

The gravity feed suc'tion path. is isolated during normal operation.

Stroking this valve during operation would disrupt normal letdown and charging and cause unwarranted plant transient (boration).

ALTERNATE TESTING:

Full Stroke test during cold shutdown

I

VALVE RELIEF REQUEST NO.

18 SXSZEM:

Chemical and Volume Control (CH)

COMPONENTS:

CH-UV-505 and CH-UV-506 P&ID COORDINATES:

13-M-8HP-002 9 G13 and G14 CATEGORY:

A, A CLASS:

XUNCTION:

Valves provide containment isolation on Reactor Coolant seal water bleed off lines.

TEST REQUIREMENTS:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

These valves are open during normal operation to provide seal water bleed-off from the reactor coolant pumps.

Stroking these valves would require dis'contin-uing seal injection to the pumps and compromise Reactor Coolant pump seal integrity.

Partial stroking is not possible since the valves are not jog capable.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

VALVE RELIEF'REQUEST NO.

19 RELIEF REQUEST DELETED SUPERCEDED BY VRR NO. 38

OO I

VALVE RELIEF REQUEST NO. 20 SYSTEM:

Main Steam (SG)

COMPONENTS:

SG-HV-178, SG-HV-179, SG-HV-184, SG-HV-185 PAID COORDINATES:

13-M-SGP-001 9 E14, A14, F14, C14 CATEGORY:

B CLASS:

FUNCTION:

Main Steam atmospheric dump valves for plant cooldown during off-normal or emergency conditions.

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

ALTERNATE TESTING:

Stroking the atmospheric dump valves during normal operations could initiate an unwarranted transient and/or uncontrolled Primary side/Secondary side cooldown.

Full stroke test during cold shutdown.

OO II g

VALVE RELIEF REQUEST NO. 21 DELETE RELIEF REQUEST SUPERCEDED BX VRR N0,41

II f

VALVE RELIEF REQUEST'NO.

22 DELETE RELIEF REQUEST

VALVE RELIEF RE UEST NO.

23 SYSTEM'ontainment Purge (CP)

COMPONENTS:

CP-UV-2A, CP-UV-2B, CP-UV-3A, CP-UV-3B P&ID COORDINATES:

13-M-CPP-001 9 D6, D3, D5, D2 CATEGORY:

A CLASS:

FUNCTION:

These valves are 42" containment purge supply and exhaust isolation valves TEST REQUIREMENT:

Full stroke test every three months or partial stroke test every three months and full stroke test during cold shutdown.

BASIS FOR RELIEF:

PVNGS Technical Specifications (3.6.1.7a) requires each 42" containment purge supply and exhaust isolation valve to be sealed closed during operation.

ALTERNATIVE TESTING:

Full stroke test these valves during cold shutdown.

f I

VALVE RELIEF REQUEST NO.

24 SYSTEM:

Reactor Coolant (RC)

COMPONENTS:

RC-HV-430, RC-HV-431, RC-HV-432, RC-HV-433 RC-HV-446, RC-HV-447, RC-HV-448, RC-HV-449 RC-HV-450, RC-HV-451, RC-HV-452, RC-HV-453 P&ID COORDINATES:

13-M-RCP-002 9 Dll, Hll, H4, D4, B12s E12s E4s B4 B10, E10, E3, B3 CATEGORY:

CLASS:

FUNCTION:

Reactor Coolant Pump Seal System High Pressure Cooler and Controlled Leak-off isolation valves TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown BASIS FOR RELIEF:

Stroking of these valves during normal operation would disrupt the normal flow in the reactor coolant pump seal injection system and thereby compromise reactor coolant pump seal integrity.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

'I

VALVE RELIEF REQUEST NO. 25 DELETE RELIEF REQUEST

" VALUE RELIEF REQUEST NO.

26 DELETE RELIEF REQUEST

0~

VALVE RELIEF REQUEST

'NO.

27

~ DELETE RELIEF REQUEST

VALVE RELIEF REQUEST NO.

28 SYSTEM:

Safety Injection and Shutdown Cooling System (SI)

COMPONENTS:

SIB-UV-614, SIB-UV-624, SIA,-UV-634, SIA-UV-644 P6ID COORDINATES:

13-M-SIP-002 9 A14, A12, A7 and A4 CATEGORY:

CLASS:

FUNCTION'afety Injection Tank paths from the Safety Coolant System during to isolate the Safety and refuel'ing.

Isolation Valves provide flow Injection Tanks to the Primary operation. The valves are closed Injection Tanks in cold shutdown TEST REOUIREMENTS:

Full stroke test:every three 'months, or partial stroke exercise every three months and full stroke test".during cold shutdown.

BASIS FOR RELIEF:

Full or partial stroke testing of these valves during operation is contrary to the safety function of these valves.

The PVNGS Technical Specifications require the isolation valves to be key-locked open and power to the valve removed to ensure an unobstructed flow path.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

0 I

VALVE RELIEF REQUEST NO.

29 SYSTEM:

Safety Injection and Shutdown Cooling (SI)

COMPONENTS:

SI-UV-651, SI-UV-652, SI-UV-653, SI-UV-654 SI-UV-655, SI-UV-656 P&ID COORDINATES:

13-M-SIP-002 8 C3$ C10, E3, E10i G3, G10 CATEGORY:

SI-UV-655 and SI-UV-656 are Category B

All others are Category A

CLASS:

SI-UV-655 and SI-UV-656 are Class 2

SI-UV-651, SI-UV-652, SI-UV-653, SI-UV-654 are class 1.

FUNCTION:

Shutdown Cooling Isolation Valve TEST REQUIREMENT:

Full stroke test every three months or partial stroke every three months and full stroke test during cold shutdown.

BASIS FOR RELIEF:

These valves are provided with interlocks which prevent them from being opened if the pressurizer pressure is in excess of 400 psig.

ALTERNATE TESTING:

Full stroke test during'old shutdown

VALVE RELIEF'RE UEST NO.

3O SYSTEM:

Instrument Air (IA)

COHPONENT:

PGID COORDINATE:

13-M-IAP-003 Q G-6 CATEGORY:

A CLASS:

FUNCTION:

Instrument Air Containment Isolation Valve TEST REQUIREMENT:

Full Stroke test during normal operation every three months or partial stroke every three months and full stroke during cold shutdown BASIS FOR RELIEF:

Stroking this valve during normal operation would isolate Letdown from Reactor Coolant system which can

,cause unwarranted transients in the RCS volume and the charging piping temperature.

ALTERNATE TESTING:

Full stroke test during cold shutdown.

)

VALVE'RELIEF'REQUEST NO.'31 SYSTEM:

Essential Chilled Water (EC)

COMPONENTS:

EC-V037, EC-V038, EC-V042, EC-V043 EC-V059, EC-V060, EC-V063, EC-V064 P&ID COORDINATES:

13-M-ECP-001 8 D7, D7, C7, C7 D3, D3, C3, C3 CATEGORY:

CLASS:

FUNCTION:

. To provide isolation between,.'Essential Chill water expansion tank and Demineralized water or Nitrogen systems.

TEST REQUIREMENT:

Frill stroke exercise every three months or part stroke every three months and fullstroke exercise at cold shutdown.

BASIS FOR RELIEF:

Plant Design condition does not provide the means for test each valve individually, i.e., valves are in series.

ALTERNATE TESTING:

Test the series of two valves's a un'it for backG.ow prevention.

Note:

This reque'st for relief 'is needed only for the fuel cycle as test connections will be added during the first refueling outage.

VALVE RELIEF'REQUEST"NO:'32 SYSYEM:

Essential Cooling Water (EW)

COMPONENTS:

EW-V029, EW-V077 EW-V018, EW-Vl03 P&ID COORDINATES:

13-M-EWP-001 Q H-3, H-3 H-7$ H-7 CATEGORY:

CLASS:

FUNCTION:

- To provide isolation between Essential 'Cooling Water Surge tank and Demineralized water system Fu11 stroke exercise every three months or partial stroke exercise every three months and full'stroke exercise at cold shutdown.

BASIS FOR'RELIEF:

Plant Design does not allow a method for back pressure

.testing each valve individually ALTERNATE TESTING:

Disassemble the valves,. check valve seat and disk visible score marks. manually stroke the disc and observe the valve disk stroke back to the shut position.

Note:

Relief is requested only for the first fuel cycle.

Test connections will be added during the first refueling outage to permit individual testing.

VALVE RELIEF REQUEST NO'"33 SYSTEM:

Diesel Generator (DG)

COMPONENTS:

DG-V002$ DG-V003 DG-VOll, DG-V012 P6ID COORDINATES:

13-M-DGP-OOl, Sht 1 8 F7, F7 F37 F3 CATEGORY:

CLASS:

FUNCTION:

To provide isolation between Demineralizer Water system and Diesel Generator Jacket Water Cooler Tank.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown..

BASIS FOR RELIEF:

Plant. design does not provide. the means for testing each valve individually.

Valves are in series.

ALTERNATE TESTING:

Test the series of two valves as a unit for backflow prevention.

Note:

The request for relief is needed until the end of the first fuel cycle.

Test connections will be added during the first refueling outage.

t

~ '

VALVE RELIEF'RE UEST NO. 34 SYSTEM:

Main Steam (SG)

COMPONENTS:

SG-UV-134A, SG-UV-138A P&ID COORDINATES:

13-M-gGP-001 Q E14, C14 CATEGORY:

B CLASS:

FUNCTION:

The above valves are used for isolation of the Auxiliary Feedwater Turbine warm-up line TEST REQUIREMENT:

Perform Valve position indication verification per IWV-3300 once every two years; perform stroke time test once every three months per IWT-3412.

BASIS FOR RELIEF:

Technical Specifications 4.7.1.2d does not require the Turbine driven Auxiliary Feedwater pump to be tested (operable) until Mode 3.

Also, steam is required to obtain physical'vidence that valve is open/closed.

ALTERNATE TESTING:

Test position verification of the above valves in conjunction with the operability testing of the turbine driven Auxiliary Feedwater pump in Mode 3.

Stroke time testing will be performed prior to entry to Mode.4, as per ASME Section XI.

C

VALVE RELIEF RE VEST NO ~ 35 SYSYSM:

Main Steam (SG)

COMPONENTS:

SG-UV-1133, SG-UV-1134, SG-UV-1135A, SG-UV-1135B SG-UV-113 6A, SG-UV-113 6B P&ID COORDINATES:

13-M-SGP&01 8 E14, C14, Hll, Fll, Dll, Bll CATEGORY:

CLASS:

2'UNCTION:The above valves provide steam trap isolation for the main steam lines.

Perform valve position verification per IWV-3300 once every two years.

Perform stroke time testing every three months.

BASIS FOR RELIEF The valves cannot be tested for position verification

" without steam in the

line, since there are Y no 'solation valves between the solenoid valves and the 28" main steam line.

Steam needs to be in the 28" line in order to obtain physical evidence that the valve is open/closed.

Technical Specification Table 3.6.1 requires that these valves be operable prior to entry into Mode 4.

Sufficient steam does not exist until Mode 3.

ALTERNATE TESTING:

Perform valve position verification in Mode 3

when there is sufficient steam available in the line for flow/position verification.

Perform full stroke exercise and stroke time testing every three months as per Technical Specification 4.7.1.5.1.

't

VALVE RELIEF REQUEST NO. 36 SYSTEM:

COMPONENTS:

Reactor Coolant System (RC)

RC-HV-101, RC-HV-102, RC-HV-103, RC-HV-105, RC-HV-106, RC-HV-108, RC-HV-109 PAID COORDINATES:

13-M-RCP-001, G-15, P-15, G-14,G-13 CATEGORY:

C1ASS:

FUNCTION:

l and 2

.High point vent for reactor vessel and pressurizer for venting noncondensibles from Reactor Coolant System.

TESTING REQUIREMENT:

Full stroke test every three months or partial stroke test every three months and full stroke test during cold shutdown.

BASIS POR RELIEP:

Valves are part of reactor coolant. pressure boundary and form part. of the. double isolation valve required by 10CFR50.2v.

Valves are solenoid valves and cannot be part stroked.

Full stroke testing of these valves violates reactor coolant pressure boundary.

Valve malfunction eg stuck open valve during Mode 1 increases the probability of a LOCA.

Additionally,, stroking of RC-HV-106 (vent to containment) would release reactor coolant; this constitutes an ALARA and radiation protection concern.

ALTERNATE TESTING:

Pull stroke test valves during refueling outage.,

~0 II

VALVE RELIEF REQUEST NO. 37 SYSYSM:

Safety Related Valves COMPONENTS:

Various P&ID COORDINATES:

Various CATEGORY:

A and B

CLASS:

1,2, and 3

FUNCTION:

Power Operated valves shall be full stroke exercised within the time interval required by IWV-3413 and corrective action shall be taken if valve stroke exceed code limi.'ts per XWV-3417.

TESTING REQUIREMENT:

Corrective action per HPl-3417 shall be taken for any valve whose stroke time increases by 50% or more for valves with stroke times less than or equal to 10 seconds.

BASIS FOR RELIEF:

Valve stroke times (actual) of less than 2 seconds need not comply with the 50% increase rule for valves with required stroke times of 5 to 10 seconds.

Very short stroke times may vary slightly due simply to measurement technique and are not statistically significant, e.g. for valves with stroke times of 1.0 secs, an increase to 1.50 seconds is not signi icant when compared to an acceptance criteria of 5 to 10 secs.

ALTERNATE TESTING:

None; valves tested as scheduled.

Valves with stroke times of less than 2 seconds shall be placed in the alert range and the frequency increased per DlV-3417 when the actual stroke time exceeds 2,5 seconds.

VALVE RELIEF REQUEST NO.

38 SYSTEM:

Safety Related Valves COMPONENTS:

Containment Isolation Valves (See Tech Specs 3/4.6.3, Table 3.6-1, Sections A, B, C, D, E, F, G)

PAID COORDINATES:

Various (See FSAR 6.2.4 and Figure 6.2.4-1 sheets 1 to 10).

CATEGORY:

A or AC CLASS:

FUNCTION:

Containment Isolation Valve TESTING RE UIREMENT:

Valves are required to be leak tested p'er IHV-3420/3422 on a two year frequency.

BASIS FOR RELIEF:

ALTERNATE TESTING:

Valves'requiring testing per

10CFR50, Appendix J are tested on a 24 month frequency.

These valves need not be further tested per ASME XI.

This basis is in agreement with NRC draft Reg Guide on Inservice Testing of Valves, issued November 1981.

None; valves tested per 10CFR50, Appendix J and Tech Spec 3/4.6.1, & 3/4.6.3; Note that relief is not requested for any valve identified in Tech Spec 3/4.4.5.2.2

( Reactor Coolant system operational leakage).

These latter valves will be tested per TS 3/4.4.5.2.2.

t

~ v'

t.

C

~

~

VALVE RELIEF REQUEST'NQ 39 SYSTEM:

Safety Related Valves COMPONENTS:

Various PAID COORDINATES:

Various CATEGORY:

A$ B, C

CLASS:

1, 2, 3

FUNCTION:

Safety Related TESTING REQUIREMENT:

Perform testing required by ASME Section ZI, Subsection IWV on a quarterly basis and every two

years, as required.

BASIS FOR RELIEF:

t

1. Check Valves (Category C) whose normal function is to open and whose safety function is to close generally require considerable amounts of maintenance support to test each valve by depressurizing upstream of the check valve.

This involves breaching the pressure boundary at a vent or drain, hooking up hoses, draining the system or pressurizing downstream of the valve and monitoring for a pressure decay.

Subsequent to criticality, high radiation zones in excess of 1 R/hr will exist in many areas where testing is performed.

2. Power Operated valves require position verification at least every two years.

These valves may require field support to verify valve postion., Radiation fields may be in excess of 1 R/hr.

ALTERNATE TESTING:

l. All Check Valves with flow through the valve will tested as scheduled.

2. All check valves which require reverse flow checking and which are in radiation fields in excess of 1 R/hr will be check during refueling 'outages.

3. Motor operated and Air operated valves with evidence of stem movement observable in the field will be tested as scheduled every two years.

4. Solenoid valves which can be tested from the control room and other objective evidence of valve position.is obtain-able (eg flow indication) will,be tested as scheduled.

5. Solenoid valves for which indirect evidence is not obtainab3 and where the radiation field is 1 R/hr or greater will be tested every other refueling outage-

r

~

~V

3 p

~

'VALVE RELIEF RE VEST NO;39 (continued)

ALTERNATE TESTING:

(continued)

6. Other Power operated valves for which indirect evidence is not obtainable and require field support in radiation fields of 1 R/hr or greater vill be tested every other refueling outage.

SO lt~

I f

)

0 I

E VALVE RELIEP REQUEST NO.'40 SYSTEM:

Auxiliary Peedwater (AP)

COMPONENTS:

P&ID COORDINATES:

AP-V137, AP-V138 13-M-APP-001 8 D6$

C6 CATEGORY:

CLASS:

FUNCTION:

Discharge check valves on essential steam driven auxiliary feedwater pump and on essential motor driven auxiliary feedwater pump.

TESTING REQUIREMENT:

Full" stroke exercise every three months or partial stroke exercise every three months and full stroke at cold shutdown.

BASIS POR RELIEF:

Stroking these valves during power'peration woul'd result in injection of cold auxiliary feedwater into a not steam generator.

In addition to causing an

'nwarranted plant transient, this could reduce the quality of the steam exiting the steam generator.

ALTERNATE'TESTING:

Partial stroke test; on minimum recirculation flow,

.every 31 days on a STAGGERED BASIS, per technical Specification 4.7.1.2a.

Full stroke after each refueling out'age on a STAGGERED BASIS per Technical specification 4.7.1.2c

s r

VALVE'RELIEF RE VEST NO. 41 SYSYEH:

Auxiliary Feedwater System (AF)

COMPONENTS:

AF-V015, AF-V024 P&ID COORDINATES:

13-M-AFP-001 8 D55 C5 CATEGORY:

CLASS:

FUNCTION:

Provide flow path to each steam generator from essential auxiliary feedwater pumps.

TEST REQUIREMENTS:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise every cold shutdown.

BASES FOR RELIEF:

Stroking these valves during operation (full or partial stroking) is not possible without injecting cold water into the steam generator, This causes unwarranted thermal transients in the steam generator.

ALTERNATE TESTING:

Full flow stroke test valves during refueling on a staggered basis in accordance with and concurrent with full flow testing required by Technical Specification 4.7.1.2c.

Note:

Testing of AF-V015 may be delayed to Mode 3 in that steam is required to operate the turbine driven auxiliary feedwater pump.

~ +~

r g

~

"VALVE RELIEF'REQUEST NO; 42 SYSTEM

~

• Auxiliary Feedwater Svstem (AF)

COMPONENTS:

AF-V079, AF-V080 PAID COORDINATES:

13-M-ALP-001 9 D2, B2 CATEGORY:

C CLASS:

FUNCTION:

Provide flow path for auxiliary feedwater (essential) to each steam generator.

TEST REQUIREMENT:

Full stroke exercise every three months or partial stroke exercise every three months and full stroke exercise

,I at cold shutdown.

BASIS FOR RELIEF:

Stroking this valve during power operation would result in the iniection of cold aux..feedwater intq a hot steam genera'tor.

In addition to possibly causing an unwarranted transient, this reduces the quality of the steam exiting the steam generator.

ALTERNATE TESTING:

The valves will be full stroke tested during the flow test required by PVNGS Technical Specification 4.7.1.2c.

r

~*sg>

J

-'VALVE RELIEF REQUEST NO. 43 SYSTEM:

Auxiliary Feedwater System (AF)

COMPONENT:

AF-V005, AF-V009 PAID COORDINATES:

13-M-AFP-001 9 E7,C7 CATEGORY:

CLASS:

3 FUNCTION:

Provide alternate suction flow paths from the Reactor Makeup Water Tank (RMWT) for Auxiliary Feedwater pumps AFA-P01 and AFB-POl which normally take suction from the Condensate Storage Tank (CST).

TEST REQUIREMENT:

Full stroke exercise.every three months or partial stroke exercise every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF:

Full stroke exercising of these valves would inject radioactive water from the RKA into the Secondary System which adversely affects ALARA by increasing the contamination level of the Secondary System and potentially extending the Radiological Controlled Area boundaries.

ALTERNATE TESTING:

Partial stroke exercise every three months using test connections.

~ c>+

%~'

'S>

~'4 e~~

VALVE RELIEF REQUEST NO. 44 SYSTEM:

Safety Related Check Valves COMPONENTS:

Various PAID COORDINATES:

Various CATEGORY:

CLASS:

1, 2, 3

TESTING REQUIREMENT:

IWV-3521: Check valves shall be exercised at least once every three months, except as provided by D&-3522.

BASIS FOR RELIEF:

The additional exercising of check valves which are stroke exercised during the course of plant operation in order to satisfy the exercising requirement results in unneces-

,sary wear to components,and equipment.,The stroke exercising of check valves during the normal course of plant operation may satisfy the exercising requirement, and should not require additional, redundant, testing.

This reque'st for relief corresponds in concept to IWV-3414 for power operated valves in regular use.

P ALTERNATE TESTING:

No additional testing is required for check valves which are exercised in the course of plant operations at a frequency satisfying IWl-3521, provided the observations otherwise required by IWV-3520 are made and analyzed during such operation and are recorded in the plant record.

h Ql ~