ML17303A549

Forwards Response to NRC 870330 Request for Addl Info Re Inservice Testing Program for Pumps & Valves,Per 870527 & 28 Meetings.Util Will Submit Rev to Pump & Inservice Testing Program within Approx 9 Months Following Receipt of NRC SER

ML17303A549
Person / Time
Site:	Palo Verde
Issue date:	09/10/1987
From:	Haynes J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
161-00496-JGH-B, 161-496-JGH-B, TAC-64953, TAC-64954, TAC-64955, TAC-649555, NUDOCS 8709170200
Download: ML17303A549 (208)

Text

REQULAT INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR: 8709170200 DOC. DATE: 87/09/10 NOTARIZED: NO DOCKET 0 FACIL: STN-50-528 Palo Verde Nuclear Stations Unit ii Arizona Publi 05000528 STN-50-529'alo Verde Nuclear Stations Unit 2i Ari zona Pub 1 i 05000529 STN-50-530 Palo Verde Nuclear Stations Unit 3i Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION HAYNES'.~~ Arizona Nuclear Power Prospect (formerly Arizona Public Serv RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

Forwards response to 870330 request for addi info re

~6'~

SUBJECT:

NRC inservice testing program For pumps Zc valvesi per 870527 5 28 meeting. Util will submit rev to pump 8c inservice testing program within approx 9 months following receipt of NRC SER.

DISTRIBUTION CODE: A047D COPIES RECEIVED: LTR l ENCL + SIZE:

TITLE: OR Submittal: Inservice Inspection/Testing NOTES: Standardized plant. 05000528 Standardized plant. 05000529 Standardi zed p lant. 05000530 I

REC P IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 5 5 LICITRAiE 1 1 DAVIS' 1 1 INTERNAL: ACRS 10 10 AEQD/DOA 1 AEOD/DSP/TPAB 1 ARM/DAF/LFMB 1 0 NRR/DEST/MEB 1 1 NRR/DEBT/MTB 1 N /ILRB 1 1 0('C /HDS 1 1 0 RE( F LE 01 1 1 RES/DE/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES:

li TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 28

4 1

Arizona Nuclear Power Project P.O. BOX 52034 ~ PHOENIX, ARIZONA85072-2034 161-00496-JGH/MA September 10, 1987 U. S. Nuclear Regulatory Commission >

Washington, D. C. 20555 ATTN: Document Control Desk

References:

(1) Letter from E. A. Licitra, NRC, to E. E. Van Brunt, Jr.,

ANPP, dated March 30, 1987.

Subject:

ASME Section XI Pump and Valve Inservice Testing Program-Palo Verde, Units 1, 2 and 3.

(2) Meeting between ANPP and'RC Staff on May 27 and 28, 1987 at the Palo Verde Site.

Subject:

Meeting to Discuss Palo Verde Inservice Testing Program for Pumps and Valves.

Dear Sirs:

Sub)ect: Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos: STN 50-528 (License NPF-41)

STN 50-529 (License NPF-51)

STN 50-530 (License NPF-65)

PVNGS Inservice Testing Program File: 87-A-056-026 By Reference (1), the NRC Staff requested additional information on the PVNGS Inservice Testing Program for pumps and valves. Subsequent to this request, a meeting was held between ANPP and the NRC Staff to discuss ANPP's draft re-sponses to the NRC request. The attachments to this letter provide ANPP's formal response to the NRC request for information. The attachments are arranged in the following order:

Attachment 1 - Responses to NRC Questions Attachment 2 Pump and Valve Relief Requests Attachment 3 Cold 'Shutdown Justifications Attachment 4 - Check'Valve Reliability Analysis ANPP will submit a formal revision to the PVNGS Pump and Valve Inservice Testing Program within approximately nine (9) months following receipt of the NRC SER on the program. The date of implementation of the testing program changes will be specified in the formal program revision submittal, but is expected to be the date of transmittal of the program revision to the NRC.

87o9lioioo 8709~<<~~8 ADOCK 0500 PDR PDR P

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Document Control Desk 161-00496 Page 2 September 10, 1987 If you have any additional questions on this matter, please contact Mr. W. F. quinn of my staff.

Very truly yours, J. G. Haynes Vice President Nuclear Production JGH/BJA/mes Attachments cc: 0. M. De Michele (all w/attachments)

E. E. Van Brunt, Jr.

J. B. Martin J. R. Ball G. W. Knighton E. A. Licitra A. C. Gehr

g ATTACHMENT 1 RESPONSES TO NRC QUESTIONS

t 0 PALO VERDE NUCLEAR GENERATING STATION, UNITS IST PROGRAMS (REVISION 0) REVIEW 1, 2, AND 3 REQUEST FOR ADDITIONAL INFORMATION The following information is submitted in response to the Nuclear Regulatory Commission's (NRC) request for additional information concerning the PVNGS Pump and Valve Program. The request for information was supplemented by a meeting be-tween the NRC, the NRC's consultant (EGRG) and Arizona Nuclear Power Project (ANPP) personnel. The meeting occurred on May 27 R 28, 1987. The format of the response is to repeat the NRC's request for information followed by the ANPP response.

I. VALVE TESTING PROGRAM A. General Comments and uestions

1. The NRC position for inservice testing of valves identified to be tested during cold shutdown is that testing shall commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching the cold shutdown condition, rather than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> specified in the Palo Verde IST Program.

Response: The PVNGS Program will be revised to indicate valve testing during cold shutdown (Mode 5) will be initiated within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving cold shutdown condition.

2. Are all valves that are Appendix J, Type C, leak rate tested included in the IST program and categorized A or A/C?

Response: In summary, all valves contained in the Type C program. will be included in the IST Program and categorized as either A or AC.

However, manual Type C valves and valves CH-HV-524, SI-PSV-179, SI-PSV-189, R SI-PSV-474 are not currently in the IST Program, although they are included in the Type C test program per Appendix J. The PVNGS program will be revised to include the above listed valves, except for CH-HV-524. Valve CH-HV-524 has been locked open due to single failure criteria, and is currently being de-leted from the Type C program. Valve SI-UV-708 is also currently in the Type C program, but a design change capped off the line just downstream of this valve. Valve SI-UV-708 is in the process of being deleted from the Type C program, and will be deleted from the IST program.

3. The NRC has concluded that the applicable leak test procedures and re-quirements for containment isolation valves are determined by 10 CFR50 Appendix J, however, the applicant must comply with the Analysis of Leakage Rates and Corrective Action requirements of Section XI, ~

paragraphs IWV-3426 and 3427 (see valve relief request number 41).

Response: Valve Relief Request No. 41 will be amended to indicate that Relief is not sought for IWV-3426 and IWV-3427. PVNGS will comply with IWV-3426 and IWV-3427 as will be noted in the revised IST program.

4. The note on Page 7, Section 2.3.K states that testing of specific valves during cold shutdown is not required if plant operating conditions will not permit the testing of those valves. It is the staff position that specific requests for relief should be provided for any valves that fall into this category.

Response: Note on Page 7, Section 2.3.K will be deleted.

5. Are there any valves in the air/nitrogen supply to the HSIV's and main feedwater isolation valves whose failure. could prevent these isolation valves from performing their safety related functions?

Response: No, there are no valves in the air/nitrogen supply to the HSIV's and Main Feedwater Isolation Valves (FWIV's) whose failure would prevent these isolation valves from performing their safety function.

6. A general relief from Code requirements cannot be granted for as yet unspecified valves (Refer to Valve Relief Request No. 42). If a problem does arise with testing any particular valves, then a specific request for relief should be submitted for those valves -giving the detailed justification which should include the radiation field intensity, the time required to perform the testing, and any other pertinent information that should be considered when evaluating the request.

Response: Specific relief will be generated when required. As of the present date, no relief has been taken per this request. URR f42 will be deleted in the next revision of the program.

7. The NRC staff position is that relief may be obtained from the trending requirements of Section XI [Paragraph IWV-3417(a)] for rapid acting valves, however, in order to obtain this relief the licensee is required to assign a maximum limiting stroke time of 2 seconds to those valves and perform corrective action as required by IWV-3417(b) if the measured stroke times exceed the 2 second limit. Valve Relief Request No. 40 is not in compliance with this staff position.

Response: VRR b40 will be deleted. Trending of valves will be performed in accordance with new VRR 844.

3. Provide a more specific technical justification for not full-stroke exercising valves AFA-V015 and AFB-V024 during cold shutdown.

Response: Valve Relief Request ¹2 has been deleted and replaced with Cold Shutdown Justification CSJ-2.

4. Provide a more specific technical justification for not full-stroke exercising valves AFA-V079 and AFB-V080 during cold shutdown.

Response: Valve Relief Request ¹3 has been deleted and replaced with Cold Shutdown Justification CSJ-3.

5. Provide a more specific technical justification for not full-stroke exercising valves AFA-U007, AFB-U022, AFA-U137 and AFB-V138 quarterly.

Response: Valve Relief Request ¹1 has been deleted and replaced with Cold Shutdown Justification CSJ-l.

C. Chemical And Volume Control S stem

'(

1. 'eview the safety function of valves CH-V154 and V155 (figure CHP-002:

B-13) and CH-HV524 (figure CHP-001; E-15) to determine be included in the IST program.

if they should Response: Valves CH-V154 and CH-V155 are downstream of Boric Acid make-up pumps (BNP's). BNP's are not ASHE XI Pumps (not class 1E).

Therefore, valves downstream of a non-1E powered pump need not be tested. BAMP's are not credited in any safety analysis.

CH-HV-524 is a passive valve (locked open) and is therefore not within the scope of the ASHE XI.

2. Review the safety function of valve PCN-V215 to determine if it should be included in the IST program.

Response: PCN-V215 is in the IST Program per an NRC commitment. Reference letter, ANPP-31548, dated 12-20-84. .PCN-V215 is the isolation between the charging pump suction from the spent fuel pool.

3. Does valve CHE-PDV-240 have a required fail-safe position?

.Response: Yes, CH-PDV-240 fails closed. Additionally, it was noted during the meeting that VRR ¹5 needed to be deleted and issued as a cold shutdown justification for valve CH-UU-501. See CSJ-5. Valves CH-239 and 240 will be tested quarterly per the code requirements.

4. Does valve CHN-V118 perform any safety function in the closed position?

If so, how is this valve verified closed?

Response: Valve CH-V118 does not perform any safety function in the closed position. CH-V118 was installed as an operating convenience valve.

The valve was designed to ensure blended make-up is directed to charging pumps. If CH-V118 fails open, CH-UV-501 can be closed

'he as needed.

5. Provide a more specific technical justification for not full-stroke exercising valves CHA-V177, V190, HV536 and CHN-UV514 during cold shutdown.

Response: CH-HV-536, CH-UV-514, CH-V177 and CH-V190 can be tested at cold shutdown. VRR g4 will be deleted and replaced with a cold shut-down justification. See CSJ-4.

4

6. What'alternate methods have been considered to verify that valves CHB-V305 and CHA-V306 full-stroke open?

K Response: Valves CHB-V305 and CHA-V306 can be full-stroke exercised, but only during filling of the Reactor Vessel Cavity at VRR-6.

Refueling'ee

7. Provide the PAID that shows valve CHE-HV239.

Response: 13-M-CHP-001 (G-ll) provided during meeting.

8. Provide a more specific technical justification for not. full-stroke exercising valve CHE-V440 during cold shutdown.

1 Response: CHE-V440 is in a flow path which is not normally used and is iso-lated with a manual valve. The valve will be tested per code when the associated boration flow path is required to be operable.

VRR //8 will be deleted. Valves will be tested per IMV-3416.

9. Is RCS charging expected to be stopped during each cold shutdown to allow testing of valve CHN-UV501?

Response: Yes, CHN-UV-501 will be tested on a cold shutdown frequency.

VRR 85 will be deleted and replaced with .a cold shutdown justifi-cation. See CSJ;5.

10. How is valve CHE-V435 verified to full-stroke open quarterly?

Response: CH-PDV-240 is closed directing all charging flow through the bypass line where V435 is installed. V435 is a spring loaded check valve.

ll. How is valve CHN-V835 verified to full-stroke closed during cold shutdown'?

Response: The Reactor Coolant Pump Seal Injection lines are isolated via manual valves. The system is then pressurized via CH-V833 (demin source) and leakage from CH-V834 is verified to stop.

12. Provide a more specific technical justification for not full-stroke exercising valves CHB-UV-515, CHA-UV-516 and CHB-UV-523 during cold shutdown.

Response: The affected valves are full stroked during cold shutdown. See Cold Shutdown Justification CSJ-8. VRR k'10 will be deleted and replaced with CSJ-8.

13. Mhy was the exercise test for valve CHN-V494 deleted from the IST Program?

Response: This valve was considered to be a passive valve as its only safety function was containment isolation. However, the program will be revised to show a full stroke exercise at cold shutdown per CSJ-32.

D. Containment Pur e S stem

l. Are valves CPA-UV4A, UV4B, CPB-UV5A and UV5B full-stroke exercised quarterly?

Response: Valves are full stroked quarterly as noted in the program.

E. Condensate Transfer S stem

1. Provide a more technical justification for not full-stroke exercising valves CTA-V016 and CTB-V020 quarterly.

Response: Valves will be full stroke exercised quarterly, when required to be operable.

2. Review the safety function of valves CT-V037 and V038 (figure CTP-001; C-4 and B-4) to determine if they should be included in the IST Program.

Response: Valves will be added to IST Program and full stroke exercised quarterly. t

I

F. Diesel Generator S stem

1. Review the safety function of valves DGA-V002, V003, V006 and DGB-V011, V012 and Y015 to determine if they should be included in the XST Program.

Response: The function of the valves has been reviewed. These valves have no safety function and will be deleted from the XST Program.

2. Provide PAID's Ol-M-DGP-OOl, sheets 6 and 8.

Response: PAID's provided during the meeting.

Essential Chilled Water S stem

1. Review the safety function of valves ECA-V041 and ECB-V072 to determine if theyJ should be included in the XST Program.

Response: The function of these valves has- been reviewed. These valves are the check valves which open to provide make-up to the essential chilled water expansion tanks. These valves do not have a safety function and will be deleted from the XST Program.

2. Do valves EC-TV29 and TV30 (figure ECP-001; E-7 and E-3) have a required fail-safe position?

Response: No, these valves do not,have a required fail safe position. These valves are not in the Section XX Program.

H. Essential Coolin Water S stem

1. Review the safety function of valves EWA-V018, EWB-Y029, V077, EWA-Y079, EWB-V080 and EWA-V103 to determine if they should be included in the IST Program.

Response: The function of these valves has been reviewed. These valves are the check valves which open to provide makeup to the essential cooling water expansion tanks. These valves do not have a safety function and will be deleted from the IST Program.

2. Provide a more specific technical justification for not full-stroke exercising valves EWA-UV65 and UV145 quarterly.

Response: Due to the pressure differential between these two systems (NC/EW),

it is not possible to control surge tank pressure and level in the nuclear cooling water system when cross connected. The NC system would have to be shutdown for the duration of the valve e stroke test and that is not possible on line because NC system supplies RCP motor cooling and letdown heat exchanger cooling water.

.See Cold Shutdown Justification CSJ-12, which replaces VRR 818.

I. HVAC Containment Buildin S stem

1. Nhat is the basis for assigning a maximum stroke time of one second to valves HCB-UV44, HCA-UV45, UV46 and HCB-UV47.(See Relief Request No.

40).

Response: FSAR Table 6.2.4-2.

J. Containment H dro en Control S stem

1. Do valves HPA-V002 and HPB-V004 perform any safety function in the open position?

Response: Yes, these valves must open to return hydrogen recombiner flow to containment and they will be added to the IST program.

2. What is" the basis for assigning a maximum stroke time of one second to valves HPA-HV7A, HV7B, HPB-HV8A and HV8B? (See Relief Request No. 40).

Response: FSAR Table 6.2.4-2.

K. Instrument and Service Air S stem

1. Provide a more specific techical justification for not full-stroke exercising valve IAE-UV2 quarterly.

Response: Stroking this valve renders all air operated valves inside contain-ment inoperable for the durati,on of the test. The valve is solenoid operated and cannot be part stroked. Valve will be full-stroked during cold shutdown. Stroking this valve shut will affect all air operated valves in containment which include pressurizer spray, numerous CH valves (CIV's) etc. VRR //20 will be deleted and replaced with Cold Shutdown Justification CSJ-14.

L. Hain Steam S stem

1. How are valves SGA-V043, V044, SGE-V887 and V888 verified to full-stroke open quarterly during plant operation? Do these valves perform any safety function in the closed position?

Response: The ASHE Section XI Program contains a typographical error with respect to valves SGA-V043, V044, SGE-V887 and V888. These valves are only part stroked on line. These valves are tested concurrent with mini-flow testing of pump AFA-P01 (Turbine driven essential Aux. feedwater pump). These steam check valves are full stroke tested concurrent with the full flow injection test of AFA-POl pursuant to Tech. Spec. 4.7.1.2c.

These valves have no safety function in the closed direction.

During operation of the essential feedwater pump pursuant to a AFAS (Aux. Feed Actuation Signal), both A and B Train Steam supplies are feeding the steam driven Aux. Feedwater pumps, although one train is sufficient. The safety function of the valves is to open and supply steam to the turbine.

See Cold Shutdown Justification CSJ-28.

2. Review the safety functions of the following valves to determine if they should be included in the IST Program.

Location Valve fi ure SGP-001 PV306A A-11 V350 A-10 PV306B A-13 V360 A-12 PV313B G-13 V339 G-12 PV313A H-12 V334 H-ll V346 G-12 V348 G-12 V357 A-12 V358 A-12 Response: These valves are Instrument Air and Nitrogen Supply to the Atmospheric Dump Valve Actuators. They provide System Control functions. These valves need not be individually identified in the IST Program. They will be individually verified to operate when the main steam atmospheric dump valves are full stroke exercised during cold shutdown using only the nitrogen accumulator supply. See cold shutdown justification CSJ-18 which replaces VRR ¹26.

3. Provide a more specific technical justification for not full-stroke exercising valves SGB-HV178, SGA-HV179, HV184 and SGB-HV185 quarterly.

Response: See Cold Shutdown Justification CSJ-18 which replaces VRR ¹26.

4. Provide a more specific technical justification for not full-stroke exercising valves SGA-UV134A and UV138A quarterly.

Response: VRR ¹25 has been revised.

5. Provide the technical justification for not full-stroke exercising valves SGE-UV170, UV171, UV180 and UV181 quarterly.

Response: See Cold Shutdown Justification CSJ-25.

6. Are valves SGA-UV1133, UV1134, SGB-UV1135A, UV1135B, UV1136A and UV1136B full-stroke exercised quarterly in accordance with the requirements of Section XI? If so, what is the purpose of Relief Request No. 27?

Response: The purpose of VRR //27 (as well as VRR 825) is to permit entry into Mode 4 without testing position indication of these solenoid valves. VRR 827 has been augmented and revised, accordingly.

7. Do valves SGE-V642, V652, V653 and V693 perform any safety function in the open position? How is each of these valves verified to close during cold shutdown testing?

Response: These valves provide protection of the feedwater lines from back-flow from the auxiliary feedwater system and ensure that auxiliary feedwater flow is directed into the steam generator. Only one valve per line is required to perform this function. All four valves will be retained in the IST program but the valves in each line will be tested in series as a unit.

These valves provide no safety function in the open direction.

8. Mhat is the basis for assigning a maximum stroke time of one second to valves SGB-HV200 and HV201? (See Relief Request No. 40).

Response: FSAR Table 6.2.4-2.

9. Provide the technical justification for not full-stroke exercising valves SGB-UV132, UV137,'GA-UV174 and UV177 quarterly.

Response: These valves are feedwater isolation valves. These valves are part stroke exercised quarterly and full stroke exercised during cold shutdown as permitted by code. It is not feasible to isolate feedwater flow to an operating steam generator. Reactor/Turbine trip will result. See Cold Shutdown Justification CSJ-26.

10. Review the safety functions of valves SG-V002, V008, V431 and V432 (figure SGP-002, F-15 and B-15) to determine if they should be included in the IST Program.

Response: These valves are non-seismic and., not quality related. They are in the "N" Aux Feed Pump supply to the feedwater system and are not within the scope of IMV-1100. Valves need not be included in the IST Program.

11. Do valves SG-FV1113 and FV1123 (figure SGP-002; H-14 and D-14) have a required fail-safe position?

Response: These valves are not in the Section XI IST Program. The valves are flow control valves and are exempt per IVV-1200. (The valves fail locked). Additionally, valves are non-g, non-seismic 8 are not with the scope of IMV-1100. Valves need not be included in the IST Program. These valves do not have a required fail safe position.

N. Safet In ection and Shutdown Coolin S stem

1. How are valves SIA-V120 and SIB-V130 full-stroke exercised quarterly?

Response: Flow from the plant* demin water system via valves SI-V885, SI-V254 to valves SI-V551 and SI-V554 respectively. Flow is measured with an ultrasonic flow device.

2. How are valves SIB-V484 and SIA-V485 full-stroked exercised quarterly?

Response: Valves are tested under conditions of shutdown cooling when the Containment Spray Pumps are functioning as Residual Heat Removal pumps. See Cold Shutdown Justification CSJ-30.

3. What are the consequences of valves SIB-UV659 or SIA-UV660 failing closed during their quarterly testing?

'I Response: The respective Safety Injection train would be inoperative due to lack of minimum flow capabilities. See Cold Shutdown Justification CSJ-20.

4. What alternate methods have been considered for full-stroke exercising valves SIA-V205 and SIB-V206 during cold shutdowns or refueling outages?

e Response: The is only viable alternate method of full stroking these valves disassembly and these valves will be disassembled per Valve Relief Request No. 32.

These valves are check valves in the containment recirculation sumps (return lines to ESF pumps). The sumps are always dry.

5. How are valves SIA-V434 and SIB-V446 full-stroke exercised quarterly?

Response: These valves can be part stroke exercised on line and full stroke exercised during cold shutdown. See Cold Shutdown Justification CSJ-29.

6. Is valve SI-V463 (figure SIP-001; D-8)'ppendix J, Type C, leak rate tested?

Response: Valve SI-V463 is Appendix J, Type C leak tested. It is a manual isolation valve and will be added to the program as noted in General questions A-2 and A-3 above.

7. Provide a more specific technical justification for not full-stroke exercising valves SIA-V164 and SIB-V165 during cold shutdowns. What alternate methods have been considered for full-stroke exercising these valves?

Response: Valves are the last isolation valve in containment spray supply lines to the spray nozzles. The only method of full stroke testing would be to spray down containment, and that is not a viable option.

These valves will be disassembled and freedom of movement verified every 5 years in connection with air/smoke test per Tech Spec 3/4.2c and as per VRR 831.

8. The NRC staff has approved valve sample disassembly/inspection for full-stroke exercising check valves on a refueling outage frequency. Provide a more specific technical justification for not full-stroke exercising valves SIE-V215, V225, V235 and V245 during refueling outages.

Response: Valves are Safety Injection Tank Discharge check valves. Full stroke testing would require injection into the RCS at high flow rates. This is possible only during refueling with the Reactor head removed. Blowing the Nitrogen blanket gas into the Vessel will create extensive turbulence (crud burst 8 airborne contamination). Disassembly is the ~onl viable method of verification of freedom of movement. See VRR 433.

9. How are valves SIE-V217, V227, V237 and V247 verified to full-stroke open utilizing RCS shutdown cooling?

Response: See Valve Relief Request No. 34.

10. Provide a more specific technical justification for not full-stroke exer-cising valves SIA-V522, V523, SIB-V532 and V533 during cold shutdowns.

Response: The valves are part of Long Term Recirculation lines. This portion of the SI system is fed by the HPSI pumps. If the flowrates through these valves are 40 gpm or greater and the Reactor Head is in place, the low temperature overpressure protection (LTOP) relief valves may lift. The RCS is generally maintained at solid conditions during mode 5 and there is no place to remove the excess injected water. Overpressurization will result and the potential for Pres-surized Thermal Shock is high. See Valve Relief Request No. 35.

11. Are the following valves Appendix J, Type C, leak rate tested?

SIB-UV615 SIB-UV616 SIA-UV617 SIB-UV625 SIB-UV626 SIA-UV627 SIA-UV635 SIB-UV636 SIA-UV637 SIA-UV645 SIB-UV646 SIA-UV647

a Response: No, these valves are Safety Injection, Injection Valves. Their function is to allow flow into the containment building (R.C.S.)

during accident situations, and are exempt from Appendix J, leak test.

12. What are the consequences of valves SIB-HV690 and SIA-HU691 failing open during their quarterly testing?

Response: See Cold Shutdown Justification CSJ-27.

13. How is full-stroke exercising verified for each of valves SIE-V540, V541, V542 and V543?

Response: By verifying shutdown cooling flow rate through each valve.

14. Provide a more specific technical justification for not full-stroke exercising valves SIA-HV605, HV606, HV-607, HV-608, SIB-HV-613, HV-633 and HV-643 during cold shutdown.

Response: Valves will be full stroked during cold shutdown and valve relief request f37 will be deleted and replaced with Cold Shutdown Justification CSJ-22.

II. PUMP TESTING PROGRAM

1. What alternative tests have been considered to detect any mechanical degra-dation of the diesel generator fuel oil transfer pumps'?

Response: Pump Relief Request /f3 has been revised to provide additional basis for testing the DF pumps solely for flow rate and differential pressure.

2. How is the operational readiness of the diesel generator jacket water cooling pump, lube oil pump, and fuel oil booster pump ascertained during the monthly diesel generator technical specification surveillance test?

Response: The operational readiness of these pumps is ascertained by the evalu-ation of pertinent system parameters recorded from various locations and. time intervals during the monthly Diesel Generator Surveillance test. These parameters include the following:

SYSTEMS PARAMETER Jacket Water Jacket water temperature and pressure, Jacket water coolant temperature and pressure, Jacket water surge tank level, Jacket water pump vibration.

Lube Oil Lube oil temperature and pressure, Lube oil cooler temperature and pressure, Lube oil sump level, Lube oil pump vibration.

Fuel Oil Fuel oil pressure and Fuel oil Day tank level, Fuel oil pump vibration.

Please note that the above pumps were designed as non-ASME, and will be deleted from the IST Program, as will the associated PRR 84.

3. Concerning Pump Relief Request 41;Section XI, Paragraph IWP-3100 requires that both pump differential pressure and flow rate to be measured.

Response: Pump Relief Request 81 and f/6 will be revised. Pump flow for HPSI, LPSI, and Containment Spray, and for Auxiliary Feedwater will be measured using ultrasonic flow meters. The Relief Request will be changed to Request Relief from the 2X Accuracy required per the Section XI code.

Currently available on site, ANPP has controlotron flow instrumen-tation. That instrumentation can only be calibrated to +&% and the present Relief Requests will be modified to Request Relief to use the +AX Accuracy equipment.

The only functions of this flow instrumentation will be to satisfy code requirements and to verify that the installed flow orifice is not degraded.

Degradation of the pumps could'e observed in numerous parameters but typically would be determined by changes in pump pressure and/or flowrate. Pump flow is not varied for there tests, but rather is constant as a result of the fixed resistance of the miniflow line.

Changes in flow would be evident with the measurement tolerance of

+5X.

Due to the pump tests being performed at the miniflow recirculation point on the pump curve, changes in pump pressure would be more in-dicative of pump degradation. Therefore, pump pressure will be measured in accordance with the requirements whereas pump flow will be measured to +5X.

4. Review the safety functions of the boric acid makeup pumps to determine if they should be included in the IST Program.

Response: DP-ll00 states that only pumps that are provided with an emergency power source are included in the Section XI Program. Boric Acid Makeup Pumps (BAMPS) do not have an emergency power source (non-class 1E). Additionally, FSAR 3.9;6.1 and Table 3.9-21 do not 0 5.

list the BAMPS as Active Pumps.

Review the safety functions of the fuel pool cooling pumps to determine if they should be included in the IST Program.

Response: Fuel pool cooling pumps are not included in the IST Program.

These pumps are not active as per FSAR 3.9.6.1 and Table 3.9-21.

The PC Pumps were discussed with NRR during the Unit 1 pre-licensing review, and NRC agreed at that time that the PC Pumps would not be included in the pump program (Ref. ANPP-31548 HFQ/TFQ, dated December 20, 1984).

6. Table IWP-3100-1 requires the measurement of pump flow rate; why is this parameter listed as being observed in the pump listing.

Response: Pump flow rate (for charging pumps) is measured and recorded in cur-rent Section XI, Pump Procedures. The Palo Verde Pump and Valve Program will be revised, to correct the Pump listings.

7. Concerning Pump Relief Request g6, lack of proper flow measurement instru-mentation does not negate the Code Requirement that flow be measured.

Response: See response to question Number 3.

ATTACHMENT 2 PUMP AND VALVE RELIEF REQUESTS

II l

PROGRAM: UNIT:

REV:

PUMP RELIEF RE VEST NO. 1 SYSTEM: Auxiliary Feedwater System (AF)

COMPONENTS: AFN-P01, AFA-P01, AFB-P01 PRID 8 COORDINATES: 13-M-AFP-001 9 H8, D8, B8 CLASS:

FUNCTION: AFN-P01, AFA-POl, and, AFB-P01 are the nonessential Auxiliary Feedwater Pump, the steam driven Aux Feedwater Pump and motor driven Aux Feedwater Pump, respectively, and supply make-up water to the Steam Generator during startup/shutdown conditions and subsequent to receipt of an AFAS (aux feed actuation signal). Note AFN-POl does not receive an AFAS.

IWP-4110-1 required flow to be measured with an instru-ment with an accuracy of +2X of fullscale.

Currently, ANPP has ultrasonic equipment with an accuracy of +5X of fullscale.

BASIS FOR RELIEF: The hydraulic circuits for the ASME Section XI test for these pumps is via minimum flow recirculation loop.

Minimum flow orifices installed in the line control constant flow. High velocity fluid through the orifice ensures that they do not become plugged. Since the only real function of flow measurement in this situation is to check the flow orifice condition, accuracy of

+5X is sufficient.

ALTERNATE TESTING: None, flow is constant and measured.

PROGRAl'1: UNIT:

Rev.:

PUMP RELIEF RE UEST NO 2 SYSTEMS: Chemical and Volume Control, Safety Injection COMPONENTS: CHA-P01, CHB-P01, 'CHE-P01, SIA-P05, and SIB-P05 P&ID COORDINATES: 13-M-CHP-002 9 B3, D3, and G3 13-M-SIP-001 9 C14 and D14 CLASS:

FUNCTION: CHA-P01, CHB-P01, and CHE-P01 are the three charging pumps. SIA-P05 and SIB-P05 are the containment spray chemical 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 for these parameters is meaningful. However, discharge pressure will be set and recorded and flow rate will be measured & recorded as per Section XI. Flow Rate will be trended.

CI PROGRAM: UNIT:

REV:

PUMP RELIEF RE VEST NO. 3 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.

TEST RH UIRMKZS: Measure displacement vibration amplitude of pump.

BASIS FOR RELIEF: These pumps are submersible centrifugal pumps located at the bottom of the Diesel Fuel Oil Storage Tanks under >10 feet of diesel fuel. Access to these pumps is not possible without completely draining the fuel tank. The discharge piping and electrical cable is connected to the pump at the top of the tank. Any vi-bration readings taken at the flange where the piping is connected would be meaningless due to the dampening effect of the fuel oil and the tank itself.

ALTERNATE TESTING: None, however, all other parameters required by the Section XI code will be measured and pump performance will be evaluated.

PROGRAM: UNIT:

REV:

PUMP RELIEF R UEST NO. 4 SYSTEM: Diesel Generator System COMPONENTS DGA-P02, DGB-P02, DGA-P03, DGB-P03, DGB-P05, DGB-P05 PUMP RELIEF REQUEST HAS BEEN DELETED

PROGRA."l: UNIT:

Rev.:

PUHP RELIEF REQUEST NO. 5 SYSTEM: Safety Injection System (SI)

COHPONENT: SIA-P01, SIB-P01 P&ID COORDINATES: 13"H-SIP-001 I B-lls G-11 CLASS:

FUNCTION SIA-P01 and SIB-P01 are Low Pressure. Safety Injection Pumps (LPSI). They function to inject borated water into the core post accident (Emergency Core Cooling) and also serve function as shutdown cooling pumps.

ASHE Section XI, IWP-4120 requires that each instrument used shall be three times the reference value'r less.

BASIS FOR RELIEF: The discharge pressure of the LPSI pump ranges from 220 to 240 psig under minimum recirculation flow. Under conditions of shutdown cooling, the discharge pressure under full flow conditions ranges from 300 psig .to 480 psig. The discharge Pressure Indicator for the LPSI pump (SIA-PI-306 and SIB-PI-307) range from 0 " 750 psig. Loop accuracy is nominally 1.14", compared to Code requirement of 2.07 per IWP-4110-1. It is necessary for the pressure indicator to provide information for both ASHE XI and normal plant operation. Indicator range is 3.4 times discharge pressure vice 3.0 times value as per Code. Installation of temporary discharge pressure gauge is impractical due to ALARA considerations ie LPSI discharge piping 2R/hr. Based on increased accuracy, ALARA considerations and Code intent to use installed instrumentation, PI"306 and 307 should be used. Additionally, IWA-5263 utilizes pressure gauges with a range of 4.0 times the pressure value.

ALTERNATE TESTING: None, testing to be performed as scheduled.

/J

PROGRAM: UNIT:

REV:

PUMP RELIEF R UEST NO. 6 SYSTEM: Safety Injection System (SI)

COMPONENTS: SIA-P01, SIB-P01 SIA-P02, SIB-P02 SIA-P03, SIB-P03 PAID 5 COORDINATES: 13-M-SIP-001 9 'B-11, G-11, A-11, E-11, C-11, H-11 CLASS:

FUNCTION: SIA-P01 and SIB-P01 are Low Pressure Safety Injection Pumps and also serve as Shutdown Cooling Pumps. SIA-P02 and SIB-P02 are High Pressure Safety Injection Pumps.

SIA-P03 and SIB-P03 are Containment Spray Pumps. These pumps provide Emergency Core Cooling functions (P01 and P02), residual heat removal function (POl) contain-ment heat removal function (P03).

TEST R UIREMENTS: IMP-4110-1 required flow measurement equipment with, an accuracy of +2X of fullscale.

Currently, ANPP has ultrasonic equipment with an accuracy of +5X of fullscale.

BASIS FOR RELIEF: The hydraulic circuits for the ASME Section XI test for these pumps is via minimum flow recirculation loops.

Minimum flow orifices installed in the lines control constant flow. High velocity fluid through the orifice ensures'hat they do not become plugged. Since the only real function of flow measurement in this situation is to check the flow orifice conditions, +5X accuracy is sufficient.

ALTERNATE TESTING: None, flow is constant and measured.

VALVE RELIEF REQUESTS l

I

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 1 SYSTEM Auxiliary Feedwater (AF)

COMPONENTS: AFA-V007, AFB-V022, AFA-V137, AFB-V138 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹1

PROGRAM: UNIT:

REV VALVE RELIEF RE UEST NO. 2 SYSTEM: Auxiliary Feedwater (AF)

COMPONENTS: AFA-V015, AFB-V024 SUPERCEDED BY COLD SfHJTDOW JUSTIFICATION g2

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 3 SYSTEM: Auxiliary Feedwater (AF)

COMPONENTS: AFA-V079, AFB-V080 SUPERCEDED BY COLD SIHJTDOMN JUSTIFICATION 83

PROGRAM: UNIT:

REV VALVE RELIEF RE VEST NO. 4 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHA-V177, CHA-V190, CHE-HV536, CHN-UV514 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹4

PROGRAM: UNIT:

REV:

VALVE RELIEF RE VEST NO. 5 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHN-UV-501 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION g5

VALVE RELIEF RE VEST NO. 6 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHB-V305, CHA-306 PAID 8 COORDINATES: 13-M-CHP-002 9 C-l5 CATEGORY:

CLASS:

FUNCTION: Valves are discharge check valves from the Refueling Water Tank (RWT) to the suction of Low Pressure Safety Injection (LPSI) pump, High Pressure Safety Injection (HPSI) pump, and Containment Spray Pump. Valves open to pass borated water to ECCS pumps.

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

BASIS FOR RELIEF: Valves can be part stroke during operation in support of quarterly testing of LPSI, HPSI and Containment Spray surveillance testing. However, valves require excess of normal shutdown cooling flow, in order

'n to full stroke valves open. Flow rates of this magni-tude are not practical during operations or cold shut-down ALTERNATE TESTING: Part stroke valves every quarter and full stroke during refueling (cavity fill).

e

PROGRAM: UNIT REV:

VALVE RELIEF RE UEST NO. 7 SYSTEM: Chemical and Volume Control (CH)

COi%%NENTS: CHE-V431, CHB-HV-203, CHA-HV-205 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹6

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 8 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHE-V440 VALVE RELIEF REQUEST DELETED

PROGRAM: UNIT:

REV:

VALVE RELIEF 'EST NO. 9 SYSTEM: Chemical and Volume Control (CH)

COMPONENT: CHB-UV-505 and CHA-UV-506 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION P7

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 10 SYSTEM: Chemical and Volume Control (CH)

CWPONMS: CHB-UV-515, CHA-UV-516, CHB-UV-523 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹8

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 11 SYSTEM: Chemical and Volume Control System CONPONENTS: CHB-HV-530 and CHA-HV-531 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 89

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 12 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHN-V-835, CHE-HV-255 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹10

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 13 SYSTEM: Containment Purge (CP)

COMPONENTS: CPA-UV-2A, CPA-UV-2B, CPB-UV-3A, CPB-UV-3B SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹ll

PROGRAM: UNIT:

REV VALVE RELIEF RE UEST NO. 14 SYSTEM: Condensate Transfer (CT)

COMPONENTS: CTA-V016, CTB-V020 VALVE RELIEF REQUEST DEU."TED

PROGRAM: UNIT REV:

e VALVE RELIEF RE UEST NO. 15 SYSTEM: Diesel Generator (DG)

COMPONENTS: DGA-V002, DGA-V003 DGB-V011, DGB-V012 VALVE RELIEF REQUEST DELETED

PROGRAM: UNIT:

REV:

VALVE RELIEF RE VEST NO. 16 SYSTEM: Diesel Generator (DG)

COMPONENTS: DGA-UV-3, DGB-UV-4, DGA-UV-5, DGB-UV-6, DGA-UV-7 DGB-UV-8, DGA-UV-9, DGB-UV-10, DGA-UV-ll, DGB-UV-12 DGA-UV-15, DGB-UV-16 P&ID 8 COORDINATES: 13-M-CHP-001, sh 5 9 F-7, F-3, D-7, D-3, F-6, F-2 13-M-DGP-001, sh 8 9 F<<6, F-3, F-6, F-3 13-M-DGP-001, sh 6 9 D-6, D-2 CATEGORY:

CLASS: Non-Classed FUNCTION: Valves UV-3, UV-4, UV-5, UV-6, UV-7, UV-8, UV-15 and UV-16 are part of the Diesel Generator Air Starter System. Valves DG-UV-'9, UV-10, UV-11, and UV-12 are part of the Diesel Generator Control Air System to the Fuel Control Linkage.

TEST RE UIR1MÃZS: Full stroke exercise and time test every three months or part stroke test every three months and full stroke test at cold shutdown.

BASIS FOR RELIEF: The valves are totally enclosed solenoid valves and it is not possible to observe any stem movement.

Additionally there are no remote indicator lights.

There is no practical way to stroke time the valve since there is no obtainable evidence of valve move-ment.

Valves were purchased as part of Diesel Generator skid.

Valves UV-3, UV-5, UV-7, and UV-15 are controlled from a single handswitch. Valves UV-4, UV-6, UV-8 and UV-16 are controlled from a single handswitch. Valves UV-9 and UV-11 are controlled from a single handswitch.

Valves UV-10, UV-12 are controlled from a single hand-switch. Independent operation of individual valves is not possible without rendering other valves inoper-able.

Technical Specifications 3/4.8.1.1.2a(4) requires monthly starting of Diesel Generator. The Diesel must start and attain speed, frequency and voltage within 10 seconds. Valve malfunction or degradation of operation will reduce D/G starting capacity and D/G will be inoperable.

ALTERNATE TESTING: Test valves concurrent with monthly Diesel Generator start test.

PROGRAM: UNIT REV:

VALVE RELIEF RE UEST NO. 17 SYSTEM: Essential Cooling frater (EM)

COMPONENTS: EJB-V029, ENB-V077 ECA-V018, ERA-V103 VALVE RELIEF REQUEST DELETE)

PROGRAM: UNIT:

REV:

VALVE RELIEF RH UHST NO. 18 SYSTEM: Essential Cooling Mater (EM)

COMPONENTS: SPA-UV-65, and ERA-UV-145 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 812

PROGRAM: UNIT:

REV.

VALVE RELIEF R UEST NO. 19 SYSTEM: Service Gas, Instrument Air, Chilled Water System COMPONENTS: GAE-V-Oll, GAE-V-015, IAE-V-021 and WCE-V-039 SUPERCEDED BY COLD SISTDOWN JUSTIFICATION ¹13

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 20 SYSTEM: Instrument Air (IA)

COMPONENTS: IAE-UV-2 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 814

PROGRAM: UNXT REV VALVE RELIEF RE UEST NO. 21 SYSTEM: Nuclear Cooling Water (NC)

COMPONENTS: NCE-V118, NCB-UV-401, NCA-UV-402, NCB-UV-403 SUPERCEDED BY COLD SHUTDOWN JUSTXFXCATXON ¹15

PROGRAM: UNIT:

REV:

VALVE RELIEF VEST NO. 22 SYSTEM: Reactor Coolant System (RC)

COMPONENTS RCA-HV-101, RCB-HV-102, RCA-HV-103, RCB-HV-105 RCA-HV-106, RCB-HV-lOS, RCB-HV-109 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 816

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 23 SYSTEM: Main Steam (SG)

COMPONENTS: SGE-V003, SGE-V005, SGE-V006, SGE-V007 SGE-V642, SGE-V652, SGE-V653, SGE-V693 PAID 5 COORDINATES: 13-M-SGP-002, 9 E-10, A-10, A-10, E-10 G-11, G-10, C-10, C-11 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 'IREMENT: 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 operations would require 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 pres-sure in Steam Generator does not exist until in Mode 3.

ALTERNATE TESTING: Test valves in Mode 3 when sufficient pressure is avail-able for stroking valves to the closed position at cold shutdown. Valves SGE-V642 and SGE-652 shall be tested in series, as. a unit. Valves SGE-V653 and SGE-V693 shall be testing in series, as a unit.

PROGRAM: UNIT REV VALVE RELIEF RE UEST NO; 24 SYSTEM: Hain Steam (SG)

COMPONENTS: SGB-UV-130, SGB-UV-135, SGA-UV-172, SGA-UV-175 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION gl7

PROGRAM: UNIT:

REV:

VALVE RELIEF R UEST NO. 25 SYSTEM: Hain Steam (SG)

COMPONENTS: SGA-UV-134A$ SGA-UV-138A P8ID 8 COORDINATES: 13-M-SGP-001 9 E14, C14 CATEGORY:

CLASS:

FUNCTION: The above valves are used for isolation of the Auxiliary Feedwater turbine warm-up line.

TEST R UIREMENT: Perform Valve position indication verification per IMV-3300 once every two years perform stroke time test once every three months per IMV-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 evidence that valve is open/closed.

Relief is needed to test (or test after maintenance),

for valve position indication only, Mode 3 after cold shutdown. This is when steam is available.

ALTERNATE TESTING: Test position verification of the above hermetically sealed 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 ASHE Section XI.

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 26 SYSTEM: Main Steam (SG)

COMPONENTS: SGB-HV-178, SGA-HV-179, SGA-HV-184, SGB-HV-185 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION f18

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 27 SYSTEM: Main Steam (SG)

COMPONENTS: SGA-UV-1133, SGA-UV-1134, SGB-UV-1135A, SGB-UV-1135B SGB-UV-1136A, SGB-UV-1136B PAID 8 COORDINATES: 13-M-SGP-001 9 E14, C14, H11, F11, D11, B11 CATEGORY:

CLASS:

FUNCTION: The above valves provide steam trap isolation for the main steam lines.

TEST R UIREMENT: 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 no isolation valves between the hermetically sealed 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. These valves are tested per Section XI requirements. The purpose of this Relief Request is to allow Plant Mode Change prior to position verification testing. Testing is required prior to entry into Mode

4. Testing is required every two years or post-maintenance.

ALTERNATE TESTING: Perform valve position verification in Mode 3 at the conclusion of refueling 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 4.0.5.

PROGRAM: UNIT:

REV:

VALVE RELIEF RH UHST NO. 28 SYSTEM: Safety Injection and Shutdown Cooling (SI)

COMPONENTS: SIE-V113, SIE-V123, SIE-V133, SIE-V143, SIA-VI404, SIB-V405 P8ID R COORDINATES: 13-M-SIP-002 9 F14, F12, F7, F4 13-M-SIP-001 8 F6, B4 CATEGORY:

CLASS:

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

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 initia-tion of flow through the valves and into the Reactor Coolant system. Safety Injection pump head is insuf-ficient to establish flow through the valves against Reactor Coolant System pressure. Additionally, when the Reactor Coolant System pressure is low, over pres-surization of the RCS is possible if the Vessel head is installed. Testing would challenge the Low Temper-ature Over-Pressure protection (LTOP) system, and could damage equipment due to over-pressure and would violate Tech. Spec. pressure/temperature limits. Partial stroke exercising of these valves would require the establish-ment 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 during normal operations is an ALARA and radi-ation protection concern.

ALTERNATE TESTING: The valves will be full stroked during refueling (Mode

6) when the vessel head is not installed.

PROGRAM: UNIT:

REV VALVE RELIEF RE UEST NO. 29 SYSTEM: Safety Injection and Shutdown Cooling (SI)

COMPONENTS: SIE-V114, SIE-V124, SIE-V134, SIE-V144 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹19

0 PROGRAM: UNIT:

REV:

VALVE RELIEF RE VEST NO. 30 SYSTEM: Safety Injection (SI)

COMPONENTS SIA-V157, SXB-V158, SIA-V201, SXB-V200 P&ID & COORDINATES: 13-M-SIP-001 9 G-13, C-13, F-12, B-12 CATEGORY:

CLASS:

FUNCTION: Valves SXA-V157 and SIB-V158 open to provide a flow path from the Refueling Water Tank (RWT) to the Contain-ment Spray Pumps. Valves SXA-V201 and SIB-V200 open to provide a flow path from the RWT to the Low Pressure Safety Injection Pumps (LPSI).

TEST UIREMENT: 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 be partial stroked during operation.

The valves cannot be full stroked during operation or during cold shutdown. During operation, the only recir-culation line (2" with an orfice) and a maxi-recircu-lation line (6"). Neither line has the capacity to handle full stroke exercise flows. During cold shut-down, these valves are closed and are not part of the shutdown cooling lineup, i.e., the shutdown cooling lines taps into the LPSI and containment spray suction lines down stream from these valves. These valves can be full stroked at refueling as part of filling of the reactor refueling pool from the RWT.

ALTERNATE TESTING Testing to be performed as partial stroking during normal operations and full stroke testing during re-fueling.

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 31 SYSTEM: Safety Injection and Shutdown Cooling l,SI)

COMPONENTS: SIA-V164 and SIB-V165 PAID 5 COORDINATES: 13-M-SIP-002 9 F8 and F6 CATEGORY: AC CLASS FUNCTION: Valves open to provide flow from Containment Spray pump to the discharge spray nozzles.

TEST RE UIREMENT: 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, i.e., spray initiation 9 >3500 gpm per valve. Partial stroking during operation is prohibited by ALARA concerns as the valves and test connections are in containment. Valves are never in regular service; the internals are immersed in demineralized water.

ALTERNATE TESTING: 1. Perform air/smoke testing 5 years per T. S.

3/4.6.2e.

2. Disassemble both valves during refueling outages in which air/smoke test is performed.

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 32 SYSTEM: Safety Injection and Shutdown Cooling (SX)

COMPONENTS: SIA-V205 and SIB-V206 PAID 4 COORDINATES: 13-M-SIP-001 9 G14 and A14 CATEGORY:

CLASS:

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

TEST RE UIR1KENT: Full stroke exercise every three months or part stroke every three months and full stroke exercise at cold shutdown.

BASIS FOR RELIEF: The recirculation sump is normally dry, therefore full stroking during operation is impractical. Partial stroking during operation is also impractical.

ALTERNATE TESTING: Disassemble/Verify valve full stroke capability of one valve every fourth refueling.

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 33 SYSTEM Safety Injection and Shutdown Cooling (SI)

COMPONENTS: SIE-V215, SIE-V225, SIE-V235, SIE-V245 PAID 5 COORDINATES: 13-M-SIP-002 9 A15, 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 Tank (SIT) water into the RCS loops.

TEST ~

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

MSIS FOR RELIEF: Full stroke testing 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 35 gpm through the valve. Full stroke testing would require a full blowdown of SIT. This is not feasible and would create a significant crud burst, and airborne contamination.

ALTERNATE TESTING: Part stroke exercise in Mode 3 after each refueling outage when the Safety Injection Tank pressure is above 600 psig. Additionally, disassemble valves and verify freedom of movement of disc motion on a refueling basis, such that one valve is inspected every second refueling outage.

PROGRAM: UNIT:

REV VALVE RELIEF RE VEST NO. 34 SYSTEM: Safety Injection and Shutdown Cooling (SI)

COMPONENTS: SIE-V217, SIE-V227, SIE-V237, SIE-V247 P8ID R COORDINATES: 13-M-SIP-002 9 A13, A10, A6, A4, C14, Cll, C6, C4 CATEGORY: AC 1

CLASS'UNCTION:

Valves open to provide a flow path from Safety Injection and Shutdown Cooling to the Primary Loop. Category "AC" valves close to prevent pressurization of SI piping from RCS loop pressure.

TEST RE UI1UÃENT: 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. Low Pressure Safety Injection pump head is not sufficient to exercise these valves due to pressure of the RCS.

Discharge of Safety Injection Tank through the valves would create significant crud burst, airborne contami-nation and could uplift core if vessel head and UGS is not in place or Fuel is not loaded.

ALTERNATE TESTING: Disassemble (1) valve each refueling outage to verify freedom of disc movement, or use ultrasonic methods to verify valve full stroke on a refueling basis.

Currently under ANPP review is the movats checkmate system to be used for check valve full stroke determin-ation as an option in lieu of valve disassembly.

NOTE: Valves SIE-V540, V541, V542 and V543 are now covered under CSJ-31.

PROGRAM: UNIT:

REV:

VALVE RELIEF UEST NO. 35 SYSTEM: Safety Injection and Shutdown Cooling (SI)

COMPONENTS: SIA-V522, SIA-V523, SIB-V532, SIB-V533 P8ID 5 COORDINATES: 13-M-SIP-002 9 C2, F2, F2, C10, F9 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 RE UIREMHNT: 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 stroked 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 oper-ation 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. Full stroke exercising during cold shutdown would challenge the Low Temperature Over Pressure (LTOP) relief valves, could damage equipment and would violate RCS Temperature/Pressure limits.

ALTERNATE TESTING: Full stroke exercise test these valves during the re-fueling mode (Mode 6) when the reactor vessel head is removed using the Safety Injection System.

h PROGRAM: UNIT:

REV:

VALVE RELIEF RE VEST NO. 36 SYSTEM: Safety Injection and Shutdown Cooling COMPONENTS: SIA-HV-604, SIB-HV-609, SIC-HV-321, SID-HV-331 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 821

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO. 37 SYSTEM: Safety Injection (SI)

COMPONENTS: SIA-HV-605, SIA-HV-606, SIA-HV-607, SIA-HV-608 SIB-HV-613, SIB-HV-623, SIB-HV-633, SIB-HV-643 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION f22

PROGRAM: UNIT:

REV:

VALVE RELIEF RE VEST NO. 38 SYSTEM: Safety Injection and Shutdown Cooling (SI)

I COMPONENTS: SIB-UV-614, SIB-UV-624, SIA-UV-634, SIA-UV-644 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION 823

PROGRAM: UNIT REV:

VALVE RELIEF RE VEST NO. 39 SYSTEM: Safety Inspection and Shutdown Cooling (SI)

COMPONENTS: SIA-UV-651, SIB-UV-652, SIA-UV-653, SIB-UV-654 SIA-UV-655, SIB-UV-656 SUPERCEDED BY COLD SHUTDOWN JUSTIFICATION ¹24

i PROGRhH: UNIT REV:

VALVE RELIEF UEST NO. 40 SYSTEM: Safety Related Valves COMPONENTS Various VALVE RELIEF REQUEST DELETED.

PROGRAM: UNIT:

REV:

VALVE RELIEF RE UEST NO 41 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 6.24-1 sheets 1 to 10)

CATl?GORY: A or AC CLASS:

FUNCTION: Containment Isolation Valve Valves are required to be leak tested per IVV-3421, IWl-3422, IVV-3423, IMV-3424, and IVV-3425 on a two year frequency.

BASIS FOR RELIEF: Valves requiring testing per 10CFR50, Appendix J are tested on a 24 month frequency. These valves need not be further tested per ASHE XI. This basis is in agree-ment with NRC draft Reg. Guide on Inservice Testing of Valves, issued November, 1981.

ALTERNATE TESTING: None; valves tested per 10CFR50, Appendix J and Tech.

Spec. 3/4.6.1 8 3/4.6.3. Note that relief is not re-quested for any valve identified in Tech. Spec.

3/4.4.5.2.2 (Reactor Coolant System Operation Leakage).

These latter valves will be tested per Tech. Spec.

3/4.4.5.2.2. PVNGS will comply with the Valve Test requirements of IHV-3426 and Il<V-3427.

PROGRAM: UNIT:

REV VALVE RELIEF UEST NO. 42 SYSTEM: Safety Related Valves COMPONENTS: Various VALVE RELIEF REQUEST DEU'.TED

PROGRAM: UNIT:

REV VALVE RELIEF RE VEST NO. 43 SYSTEM: Safety Related Check Valves COMPONENTS: Various VALVE RELIEF REQUEST D1KEI.'ED

PROGRAM UNIT:

REV:

VALVE RELIEF UEST NO. 44 SYSTEM: Safety Related Power Operated Valves C(h%'ONENTS: Various PAID 5 COORDINATES: Various CATEGORY: A and B CLASS: 1, 2, and 3 TEST RE UIREMENT: IVV-3417(a) requires that valves which exhibit an in-crease of 25% in stroke time (for valves with actual stroke times of greater than 10 secs) or 50X in stroke time (for valves with stroke times of less than or equal to 10 secs) shall have their frequency of testing in-creased to monthly until corrective action is taken, at which time the original test frequency shall be resumed.

BASIS FOR RELIEF: Using a fixed reference value, provides a more logical and stringent basis for determining increased test frequencies. Adhering to the Code as stated above, a valve's stroke time could increase during each test and still be considered acceptable, while in fact, the valve could be failing or, at least, worthy of being tested at an increased frequency. Using a fixed ref-erence value as a standard would give rise to an in-creased test frequency much sooner than the standard set forth in the Code.

ALTERNATE TESTING: If a fixed reference value is exceeded by either:

1) 251 or more for those reference values greater than 10 seconds, or

2) 50K or more for those reference values less than or equal to 10 seconds.

The frequency of testing shall be increased to'once a month until the condition is corrected.

ATTACHMENT 3 COLD SHUTDOWN JUSTIFICATIONS

COLD SIKTDOWN JUSTIFICATION ¹1 SYSTEM: Auxiliary Feedwater (AF)

COMPONENTS: AFA-V007, AFB-V022, AFA-V137, AFB-V138 PAID 8 COORDINATES: 13-M-AFP-001 9 D7, C7, D6, C6 CATEGORY:

CLASS:

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

BASIS FOR COLD Stroking these valves during power operation would SHUTDOWN TESTING: result in the injecting of cold auxiliary feedwater into a hot steam generator. This will damage the feedwater piping and/or steam generator via thermal shock/fatigue. Additionally, the injection of cold auxiliary feedwater would upset the steam generator pressures and levels and could lead to a reactor trip and/or Main Steam Isolation Signal (MSIS).

Valves will be full stroke exercised during cold shutdowns.

NOTE: During Preoperational testing, excessive vibration problems with the AF Pumps and associated AF piping, necessitated a design change to block off the full flow recirculation lines with a specticle blind. Full flow recirculation is no longer a possible test.

I t

COLD SHUTDOWN JUSTIFICATION 02 SYSTEM: Auxiliary Feedwater (AF)

COMPONENTS: AFA-V015, AFB-V024 P&ID & COORDINATES: 13-M-AFP-001 9 D5, C5 CATEGORY:

n CLASS:

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

BASIS FOR COLD -Stroking these valves during power operation would SHUTDOWN TESTING: result in the injection of cold auxiliary feedwater into a hot steam generator. This will damage the feedwater piping and/or steam generator via thermal shock/fatigue. Additionally, the injection of cold auxiliary feedwater would upset the steam generator pressures and levels and could lead to a reactor trip and/or Main Steam Isolation Signal (MSIS).

Valves will be full stroke exercised during cold shutdown.

COLD SHUTDOWN JUSTIFICATION ¹3 SYSTEM: Auxiliary Feedwater (AF)

COMPONENTS: AFA-V079, AFB-V080 FRID R COORDINATES: 13-M-AFP-001 9 D2, B2 CATEGORY:

CLASS FUNCTION: Provide flow path auxiliary feedwater (essential) to each steam generator. ~

BASIS FOR COLD Stroking these valves during power operation should SHUTDOWN TESTING: result in the injection of cold auxiliary feedwater into a hot steam generator. This will damage the feedwater piping and/or steam generator via thermal shock/fatigue. Additionally, the injection of cold auxiliary feedwater would upset the steam generator pressures and levels and could lead to a reactor trip and/or Main Steam Isolation Signal (MSIS).

Valves will be full stroke exercised during cold shutdown.

COLD SIHJTDOWN JUSTIFICATION 4'4 SYSTEM Chemical and Volume Control (CH)

COMPONENTS: CHA-V177, CHA-V190, CHE-HV536, CHN-UV514 PAID 8 COORDINATES: 13-M-CHP-002 9 B8, A8, A14, B10 CATEGORY: C, C, B, B CLASS: 2 2 2 3 FUNCTION: Valve opens during emergency boration to provide flow from Refueling Water Tank (RWT) to the suction of the charging pumps via gravity feed or Boric Acid Make-up Pumps.

BASIS FOR COLD These valves are normally closed during operation SHUTDOWN TESTING: isolating the emergency boration path. Stroking these valves during operation would cause excessive boration due to the high Boron concentration in the Refueling Water Tank. This could increase boron level beyond shutdown margin requirements and would cause a reactor shutdown.

Full stroke test check valves during cold shutdown and per Technical Specification 3/4.1.2.2b. Full stroke test power operated valves during cold shutdown.

COLD SIIUTDOWN JUSTIFICATION ¹5 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS: CHN-UV-501 PAID 8 COORDINATES: 13-M-CHP-002 9 C-7 CATEGORY:

CLASS:

FUNCTION: CHN-UV-501 is Volume Control Tank (VCT) Discharge Isolation Valve. UV-501 closes on low VCT level to protect charging pumps from loss of NPSH.

BASIS FOR COLD SHUTDOWN TESTING Disrupting the normal charging system flow path would be required to stroke this valve. This would cause transients in the RCS, volume. Closing this valve also will result in the loss of NPSH to the charging pumps and would cause damage to the charging pumps.

Loss of charging flow would thermally cycle and damage the Regenerative Heat Exchanger.

Valve to be full stroke exercised and stroke time tested during cold shutdown.

1 COLD S1iUTDOWN JUSTIFICATION II6 SYSTEM: Chemical and Volume Control (CH}

COMPONENTS CHE-V431, CHB-HV-203, CHA-HV-205 PAID 8 COORDINATES: 13-M-CHP-001 6 H9, H10, Gll CATEGORY: C, B, B CLASS:

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

BASIS FOR COLD Their function is to protect the charging system SHUTDOWN TESTING: from Reactor Coolant System pressure during normal operations and to provide auxiliary spray to cool/depressurize the pressurizer <<hen the Reactor Coolant pumps are not operating. Partial stroking is not possible since CHB-HV-203 and CHA-HV-205 are solenoid valves and control flow to CHE-V431.

Stroking these valves during operation introduces transients in RCS pressure and thermal cycling/fatigue of the pressurizer spray nozzle (reference Tech.

Specs. 5.7-1}. Exercising these valves during power operation would lead to a reactor trip due to RCS pressure changes.

Full stroke exercise test during cold shutdown for CHE-V431 and full stroke exercise and stroke time test for CHB-HV-203 and CHA-HV-205.

COLD SHUTDOW JUSTIFICATION 87 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS CHB-UV-505 and CHA-UV-506 PAID 8 COORDINATES: 13-M-CHP-002 9 G13 and G14 CATEGORY: A, A CLASS:

FUNC170N: Valves provide containment isolation on Reactor Coolant seal water bleed off line.

BASIS FOR COLD These valves are open during normal operation to SHUTDOMN TESTING: provide seal water bleed-off from the reactor coolant pumps. Stroking these valves would require dis-continuing seal injection to the pumps. Partial stroking is not possible since the valves are not jog capable. Stroking these valves on line would damage Reactor Coolant pump seals and could lead to a Reactor Shutdown.

Full stroke test during cold shutdown.

COLD SHUTDOWN JUSTIFICATION 88 SYS1BI: Chemical and Volume Control (CH)

COMPONENTS CHB-UV-515, CHA-UV-516, CHB-UV-523 P&ID & COORDINATES: 13-H-CHP-001 9 H15, H15, F13 CATEGORY: B, A, A CLASS: CHB-UV-515 and CHA-UV-516 are Class 1, all others are Class 2.

FUNCTION: Valves are contained in the normal letdown/volume contro1 make-up loop.

BASIS FOR COLD Disrupting normal letdown flow. in order to full SHUTDOW TESTING: stroke these valves could cause transients in the RCS volume/boron concentration. Valves do not have part stroke capabilities. Stroking these valves would cause pressurizer level transients and could cause a reactor shutdown. Additionally, disrupting Wl 'ull charging letdown flow will thermally cycle letdown nozzles on .the RCS piping and the Regenerative Heat Exchanger.

stroke test these valves during cold shutdown.

COLD SHUTDOWN JUSTIFICATION 89 SYSTEM: Chemical and Volume Control System COMPONENTS: CHB-HV530, and CHA-HV531 PAID 5 COORDINATES: 13-M-CHP-002 9 C15, and C14 CATEGORY:

CLASS:

FUNCTION: Safety Injection Pump to Refueling Water Tank Suction Isolation Valves.

BASIS FOR COLD Stroking these valves during operation would SHUTDOWN TESTING: violate PVNGS Technical Specifications, Limiting Conditions for Operation, requiring two independent flow paths capable fo taking suction from the Refueling Water Tank on a safety injection actuation signal. Valve is normally open. If valve failed in closed position, this would render one ~corn lets safety injection train (eg HPSI, LPSI and Containment Spray Pump') in-operable. This is an unsafe mode of operation.

Full stroke test at cold shutdown.

COLD SHUTDOWN JUSTIFICATION 410 SYSTEM: Chemical and Volume Control (CH)

COMPONENTS CHN-V835, CHE-HV-255 PAID 4 COORDINATES: 13-M-CHP-001 9 G3, GA CATEGORY: CHE-HV-255 is Category A CHN-V835 is Category AC CLASS FUNCTION: Valves are open to provide a flow path for seal injection to the reactor coolant pumps.

BASIS FOR COLD These valves are open during normal operation to SHUTDOWN TESTING: provide seal injection to the reactor coolant pumps.

Stroking these valves closed would require dis-continuing seal injection to the pumps and causing reactor coolant pump seal damage. CHE-HV-255 is not jog capable so CHE-HV-255 and the check valve down stream cannot be part stroked. Damaging the seals would necessitate a reactor shutdown and containment entry.

Full stroke test during cold shutdown.

COLD S1IUTDOWN JUSTIFICATION Ill SYSTEM: Containment Purge (CP)

COMPONENTS CPA-UV-2A, CPA-UV-2B, CPB-UV-3A, CPB-UV-3B P&ID & COORDINATES: 13-H-CPP-001 9 D6; D5, D2 CATEGORY:

CLASS:

FUNCTION: These valves are 42" containment purge supply and exhaust isolation valves.

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

Stroking these valves during operation would be a violation of Technical Specification. Failure of these valves in the open position would compromise containment integrity and would violate Tech. Spec.

3/4.6.1.7.

m" Full stroke test these valves during cold shutdo~.

COLD SHUTDOWN JUSTIFICATION 812 SYSTEM: Essential Cooling Mater (EW)

CONPONENTS EMA-UV-65 and EMA-UV-145 PAID 5 COORDINATES: 13-M-EVP-001 9 C8 and C4 CATEGORY:

CLASS FUNCTION: Valves open to provide Nuclear Cooling (NC) water system with Essential Cooling Mater (EM) in the event that the Nuclear Cooling Mater System is inoperable.

BASIS FOR COLD Pull stroke exercising these valves during operation SHUTDOMN TESTING: will produce high pressure in the Nuclear Cooling (NC) water system due to the pressure differential between the NC system and the Essential Cooling Mater (EM) system. This will cause the NC surge tank pressure relief valve (PSV) to lift. This will result in the loss of level control of both the NC and the E'M system. The EM system is required to be operable above Hode 4. In order to preclude loss of EM system function, the NC system would have to be shutdown to perform the test. However, 'the NC system supplies cooling water to the Reactor Coolant Pump seals. Loss of NC would require tripping all four RCP's and this would cause a reactor trip.

Full stroke test during cold shutdown.

COLD SHUTDOWN JUSTIFICATION 813 SYSTEM: Service Gas, Instrument Air, Chill Water System COMPONENTS GAE-V011, GAE-V015, IAE-V021 and WCE-V039 P&ID 8 COORDINATES: 13-M-GAP-001 9 D6, F2 13-M-IAP-003 9 G5 and 13-M-WCP-001 9 G7 CATEGORY: AC CLASS:

FUNCTION: In board containment isolation valves.

BASIS FOR COLD Valves must be tested in a manner that proves that SISTDOWN TESTING: the disk is'on its seat. A containment entry would be required to perform this test and the associated system would have to be shutdown for test duration.

Containment entry during normal operation to perform this test is not warranted due to ALARA.

Valves will be tested during cold shutdown.

COLD S1$ TDOWN JUSTIFICATION 814 SYSTEM: Instrument Air (IA)

C0%%NENTS: IAE-UV-2 P&ID R COORDINATES: 13-H-IAP-003 9 G7 CATEGORY:

CLASS:

FUNCTION: Instrument Air Containment Isolation Valve BASIS FOR COLD Closing this valve during operation isolates all SHUTDOWN TESTING: instrument air inside containment. All Air Operation Valves (AOV) inside containment could not be operated.

CH, SI and WC valves would be affected. Also letdown would be isolated from the RCS. This would cause transients in the RCS volume and charging piping temperature leads to fatigue. Valve is solenoid operated and cannot be part stroked. RCS Transients could lead to a reactor shutdown.

Full stroke test during cold shutdown.

COLD SHUTDOWN JUSTIFICATION //15 SYSTEM: Nuclear Cooling 1<ater (NC)

COMPONENTS NCE-V118, NCB-UV-401, NCA-UV-402, NCB-UV-403 PRID 5 COORDINATES: 13-M-IAP-003 9 E6, E7, F7,"F6 CATEGORY: AC, A, A, A CLASS:

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 Control Element Drive Mechanism (CEDM) air coolers.

BASIS FOR COLD These valves are open during normal operation to SHUTDOMN TESTING: allow a supply of nuclear cooling water to the reactor coolant pump coolers. Stroking these valves would 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 would also cause overheating of the CEDM's and cause Containment Element Assemblies (CEAs) to drop into the core. Partial stroking is not possible since the valves are not jog c'apable.

Stroking these valves could trip the reactor and damage the Reactor Coolant Pumps and CEDMs.

Full stroke test these valves during cold shutdown.

COLD SHUTDOWN JUSTIFICATION $ 16 SYSTEM: Reactor Coolant System (RC)

COMFONENTS: RCA-HV-101, RCB-HV-102, RCA-HV-103, RCB-HV-105 RCA-HV-106, RCB-HV-108, RCB-HV-109 PAID R COORDINATES: 13-M-RCP-001, G-15, F-15, G-14, G-13 CATEGORY:

CLIISS: 1 and 2 FUNCTION: High point vent for reactor vessel and pressurizer for venting noncondensibles from Reactor Coolant System.

BASIS FOR COLD Valves are part of reactor coolant pressure boundary SHUTDOWN TESTING: 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 cool'ant pressure boundary. Valve malfunction (e.g., 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 to containment atmosphere.

This constitutes an ALARA and radiation protection concern. Stroking these valves would lead to possible equipment damage and personnel safety hazards. Tech.

Spec. 4.4.10 requires these valves to be closed during operation. Failure of one of these valves in the open position would require a reactor shutdown.

mm Full stroke test valves during cold shutdown.

'I COLD StHJTDOWN JUSTIFICATION 817 SYSTEM: Main Steam (SG)

COMSNENTS SGB-UV-130, SGB-UV-135, SGA-UV-172, SGA-UV-175 PAID 8 COORDINATES: 13-M-SGP-002 9 G12, C12, G12 and C12.

CATEGORY:

CLASS:

FUNCTION: Downcomer feedwater isolation valves.

BASIS FOR COLD These valves are normally open during operation.

S11UTDOWN TESTING: Full stroke testing of these valves during power operation would isolate up to '15K of the normal feedwater flow to the steam generators and would cause a plant transient and reactor trip. Partial stroking is not possible as the valves are not jog capable.

RE UIRED TESTING Full stroke testing 6t cold shutdown.

COLD SIHJTDSBf JUSTIFICATION 818 SYSTEM: Main Steam (SG)

COMPONENTS: SGB-HV-178, SGA-HV-179, SGA-HV-184, SGB-HV-185 PAID 5 COORDINATES: 13-M-SGP-001 Q E14, A14, F14, C14 CATEGORY:

CLhSS:

FUNCTION: Main Steam atmospheric dump valves for plant cool-down during off-normal or emergency conditions.

BASIS FOR COLD Opening these valves releases Main Steam directly SHUTDOWN TESTING: to the atmosphere. Stroking the atmospheric dump valves during operation would initiate a plant transient, and uncontrolled primary/secondary cooldown, and an excessive steam flow rate. Changes in steam generator levels and pressures and RCS pressures and temperatures would lead to a plant trip. Additionally, opening the ADV's is a personnel hazard and may release radioactive material to the environment if there is any history of primary/second-ary leakage.

Full stroke test during cold shutdown.

COLD S1IUTDOWN JUSTIFICATION II19 SYSTEN: Safety Injection and Shutdown Cooling (SI)

COMPONENTS. SIE-V114, SIE-V124, SXE-V134, SXE-V144 PRID 5 COORDINATES: 13-M-SXP-002 9 F13, Fll, F6 and F4 CATEGORY:

CLASS:

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

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

Full stroke exercise during cold shutdown.

I~

COLD SIHJTDOWN JUSTIFICATION ¹20 SYSTSS: Safety Xnjection (SI)

CRPONENTS- SIA='UV-'660 and SIB-UV-659 P&ID & COORDINATES: 13-HSXP-001 9 E-7 and A-6 CATEGORY: B CLASS:

FUNCTXON Safety Xnjection Pump Combined Recirculation.

BASIS FOR COLD These valves provide recirculation flow path to the SHUTDOMN TESTING: Refueling Mater Tank from HPSX, LPSX, and containment spray pumps. If one of these valves were to fail during their quarterly test, a complete Safety Injection train would be rendered inoperable.

(No recirculation flow path). This would require plant shutdown until the problem could be corrected.

Valves are solenoid operated and cannot be part stroked.

Full stroke and time test at cold shutdown.

COLD SlHJTDOWN JUSTIFICATION ¹21 SYSTEM: Safety Injection and Shutdown Cooling COMPONENTS: SIA-HV-604, SIB-HV-609, SIC-HV-321, SID-HV-331 PAID 5 COORDINATES: 13-M-SIP-001 9 G3, C3 CATEGORY: SIC-HV-321 and SID-HV-331 are Category A.

SIA-HV-604 and SIB-HV-609 are Category B CLASS:

FUNCTION: Isolation Valves in the long term recirculation lines to the reactor coolant system hot legs.

e BASIS FOR COLD SHUTDOWN TESTING:

The PVNGS Technical Specifications valves be closed with power to the removed during normal operations.

valves during operation would be a Technical Specifications.

require these valve operators Stroking these violation of Ful" stroke test these valves during cold shutdown.

COLD SHUTDOWN JUSTIFICATION 022 SYSTEM: Safety Injection .(SI):..".:: -

~ .

COMPONENTS SIA-HV-605, SIA-HU-606, SIA-HV-607, SIA-HU-608 SIB-HV-613, SIB-HU-623, SIB-HU-633, SIB-HU-643 PAID 8 COORDINATES: 13-M-SIP-002 9 E-15, E-12, E-', E-4 9 E-15, E-12, E-7, E-4 CATEGORY:

CLASS.

FUNCTION: Safety Injection Tank Nitrogen Uent. Tanlc is vented during recovery phase of small break LOCA (such as Steam Generator Tube Rupture) to preclude inadvertant discharge of Tank into Reactor Vessel.

BASIS OF COLD Stroking these valves during operation would be a SJHJTDOWN TESTING: violation of Technical Specifications. Partial stroking is not possible as these valves are solenoid valves. Full stroking during operation is not practical since the valves are shut and power is removed during operation per Technical Specification 3.5.1e. Cycling the valve during operation would reduce the pressure in the Safety Injection Tank below Technical Specification Limits (600 psi).

This would render the Tank inoperable. Rendering each tank (ie 4 of 4) inoperable once each quarter is unwarranted. There are no block valves for the vents. If a valve were to fail open, the effected tanlc would be inoperable and could not be remedied without a shutdown and containment entry.

IS Full stroke exercise during cold shutdown.

COLD SHUTDOWN JUSTIFICATION 823 SYSTEM: Safety Injection and Shutdown Cooling System (SI)

COMPONENTS SXB-UV-614, SIB-UV-624, SIA-UV-634, SXA-UV-644 P8ID 8 COORDINATES: 13-M-SXP-002 9 A14, A12, A7 and A4 CATEGORY:

CLASS FUNCTION: Safety Injection Tank Isolation Valves provide flow paths from the Safety Injection Tanks to the Primary Coolant System during operation. The valves are closed to isolate the Safety Injection Tanks in cold shutdown and refueling.

BASIS FOR COLD Full or partial stroke testing of these valves during SHUTDOW TESTING: operation is contrary to the safety function of these valves. The PVNGS Technical Specifications require the isolation valves to be key-locked open and pow'er to the valve removed to ensure an unobstructed flow path. Stroking these valves during operation would be a violation of Technical Specification.

Full stroke test during cold shutdown.

COLD SIHJTDOWN JUSTIFICATION 824 SYSTEN: :Safety .I'njection and Shutdown"Cooling (SX)"

GNPONENTS ,SXA-UV-651, SIB-UV-652, SXA-UV-653, BIB-UV-'654 SIA-UV;655, SIB-UV-656 U

PAID 8 COORDINATES: 13-1'1-SIP-002 9 C3, C10, E3, E10, G3, G10 CATEGORY: SXA-UV-655 and SIB-UV-656 are Category B All others are Category A CLASS: SIA-UV-655 and SIB-UV-656 are Class 2 SIA-UV-651, SXB-UV-652, SIA-UV-653, SIB-UV-654 are Class 1 FUNCTXON: Shutdown Cooling Isolation Valve BASIS FOR COLD These valves are provided with interlocks which

'SHUTDOW TESTING: prevent them from being opened if the pressurizer pressure is in excess of 400 psig. The Class 1 valves provide pressure isolation function between Reactor Coolant System and Shutdown Cooling System as noted in Tech. Spec. 4,4.4.2.1. Opening of these valves would overpressurize their piping system.

Full stroke test during cold shutdown.

COLD SHUTDOWN JUSTIFICATION ¹25 SYSTPI: Main Steam (SG)

COMPONENTS: SGE-UV170, SGE-UV171, SGE-UV180, SGE-UV181 PAID 5 COORDINATES: 13-M-SGP-001 H-10, F-10, D>>10, 8-10 CATEGORY:

CLIISS:

FUNCTION: Main Steam Isolation Valves (MSIV)

BASIS FOR COLD SHUTDOWN TESTING: Valves are tested per code (part stroke test quarterly).

These valves cannot be full stroke tested during opera-tion. Closing an MSIV during operation would cause a turbine trip and would cause a reactor trip. Main steam safety valves would lift level would vary dramatically.

and secondary pressure/

RE UIRED TESTING: Full stroke and time test at cold shutdown.

COLD SHUTDOWN JUSTIFICATION f26 SYSTEM: Main Steam (SG)

COMPONENT: SGB-UV132, SGB-UV137, SGA-UV174, SGA-UV177 PAID 8 COORDINATES: 13-M-SGP-002 E-12, B-12, E-13, B-13 CATEGORY CLASS:

FUNCTION: Feedwater Isolation Valves (FWIV)

BASIS FOR COLD SHUTDOWN TESTING: These valves are tested per code (part stroke test quarterly). These valves cannot be full stroke tested during operation. Closing an FWIV would isolate feed flow to operating steam generators causing loss of secondary level control and a subsequent reactor trip.

RE UIRED TESTING: Full stroke and time test at cold shutdown.

COLD SHUTDOWN JUSTIFICATION 827 SYSTEM'afety Injection (SI)

COMPONENTS: SIA-HV691 5 SIB-HV690 PAID 5 COORDINATES 13-M-SIP-002 H-4, H-13 CATEGORY:

CLASS:

FUNCTION: Shutdown cooling warmup bypass valves allow for warmup of shutdown cooling heat exchanger and associated piping, prior to initiation of shutdown cooling.

BASIS FOR COLD SHUTDOWN TESTING: If the warmup bypass valves were to fail open during their quarterly testing (at power) and a small break LOCA were to occur, shutdown cooling would be required with the warmup bypass closed. Tech Spec 0'3.7.13 would be violated and the unit would have to be shut-down. If the valve failed closed, the shutdown heat exchanger and associated piping could be thermally shocked.

RE UIRED TESTING: Full stroke test during cold shutdown.

COLD SIIUTDOWN JUSTIFICATION ¹28 SYSTEM: Main Steam (SG)

COMPONENTS:

SGA-V043, SGA-V044, SGE-V887, SGE-V888 PAID R COORDINATES: 13 M SGP 001 E 12~ C 12~ D 12 D 12 CATEGORY:

CLASS'UNCTION:

Valves open to provide main steam supply to steam driven auxiliary feedwater pump.

CRASIS FOR COLD SHUTDOWN TESTING: Valves will be part stroke exercised during monthly pump test per T.S.4.7.1.2; Full stroke exercising of valves would require full flow injection of auxiliary feedwater into hot steam generator. Use of auxiliary feedwater during plant operation will damage feedwater piping and/or steam generators via thermal shock/fa-tigue. Additionally, the injection of cold auxiliary feedwater would upset the steam generator pressure and levels and could lead to a reactor trip and/o'r main steam isolation signal (MSIS).

RE UIRED TESTING: Full stroke exercise valves during cold shutdown when main steam pressure permits testing as noted in Tech Spec 4.7.1.2.

COLD SEJTDOWN JUSTIFICATION 829 SYSTSM: Safety Injection (SX)

C(NP0NENTS SXA-V434, SXB-V446 PAID 5 COORDINATES: 13-M-SXP-001, F-9, B-9" CATEGORY:

CLASS:

FtJNCZION: Valves open to provide low pressure ECCS flow to Reactor Coolant System. Valves also open to provide flow path for shutdown cooling.

BASIS FOR COLD SHUTDOWN TESTXNG: Valves will be part-stroke exercised during plant opera-tion. Flow rates needed to achieve full stroke exer-cise cannot be attained during plant operation. The only flow path capable of providing full flow exercising is into the reactor coolant system. During plant opera-tion, RCS pressure is significantly higher than shut-off head of Low Pressure Safety Injection (LPSX) pump.

LPSX pump cannot inject into RCS due to pressure in RCS.

RE UXRED TESTING: Full flow exercise during shutdown cooling when LPSI pump functions as the shutdown cooling pump.

COLD SIHJTDOWN JUSTIFICATION 830 SYSTEM: Safety Injection (SI)

COMPONENTS: SIB-V484, SIA-V485 P&ID & COORDINATES: 13-M-SIP-001, C-9, H-9 CATEGORY CLASS:

FUNCTION: Valves open to provide containment spray flow to Con-tainment Building. Valves also open to provide shutdown cooling flow when containment spray pump is used for shutdown cooling.

BASIS FOR COLD SHUTDOWN TESTING: Valves cannot be full stroked exercised during operation (in containment spray mode) without spraying down inside the Containment Building. Initiation of containment spray during operation will damage equipment by spraying water on electrical equipment and soaking equipment with boric acid. Operation of the containment spray pump as a shutdown cooling pump during plant operation is not possible since the discharge head of the pump is significantly below the Reactor Coolant system pressure.

RE UIRED TESTING: Full stroke exercise these valves during cold shutdown using the containment spray pump as a shutdown cooling pump.

COLD SISTDOWN JUSTIFICATION 831 SYSTEM: Safety Injection (SX)

COMPONENTS: SIE-V540, SIE-V541, SIE-V542, SIE-V543 I

PAID R COORDINATES: 13-M-SXP-002, C-13, C-11, C-6, C-4 CATEGORY: AC CLASS:

FUNCTION: Valves open to provide Safety Injection and shutdown cooling flow into the Reactor Coolant system.

BASIS FOR COLD SHUTDOWN TESTING: The injection flow rate of the Low Pressure Safety Injection (LPSI) pump and injection pressure of the LPSI, plus High Pressure Safety Injection (HPSI) pump combined, is not adequate to overcome Reactor Coolant pressure during normal operation. Flow rates cannot be attained and pressure is well below RCS pressure.

'IRED TESTING: Full stroke exercise these valves during cold shutdown when the SX system is aligned for shutdown cooling.

t COLD SHUTDOWN JUSTIFICATION 832 SYSTEM: Chemical and Volume Control (CH)

COMPONENT: CHN-V494 P8ID 8 COORDINATES: 13-M-CHP-003 E-14 CATEGORY: A/C CLASS:

FUNCTION: This valves only SAFETY Function is containment isolation.

BASIS FOR COLD Valve is inside containment. To full stroke this SHUTDOW TESTXNG: valve closed during operation would require a contain-ment entry. Containment Entry during operation is not warranted due to ALARA concerns and safety of plant personnel.

REVISED TESTING: Valve will be tested during cold shutdown.

i, ATTACHMENT 4 CHECK VALVE RELIABILITY ANALYSIS

Re 1 i ab i 1 it y Based Recomr>>end at ion For Check Valve Testing Frequencie gaol I. Intr oduct ion A lel iabi itV 1 study was pel med iri order to provide a l Bl iabi1 ity based reccmmendat ion for the frequency of check valve testirig ir> pVNBS ECCH arid AFN sy toms. It i not pr act,ical to ver ify design flaw thr'ough some <Jf these valves

<e. q. coritainment sump check valve, SIT check valves) and therefore there are some concern. that partial blockage of flow could occur ard riot be detected by the plant testing program. Iri respor>se to this concel ri the NRC has i-uggested that it (>>ay be ber>ef icial to pe>'for(>l addit iorial Sect iori XI check valve test ar>dlor irispect i oris.

The NPRDS data base provide.. data on a@proximately 5373 safety related check valve repre. Bnt inq an est imated i5 568 check valve yearof experience. 4)ithir> thi data base there are 6>'>8 doc>lr>lented tailur es of check valves. Or>1 y 5 of these 448 failures w(:uld poterit ial ly result iri i griificarit blockage of ECCS check valve flow. ( The majority of these fail ure r esulti rig only iri either ir>terr>al or extenrial leakage and having rio ignificant impact i: n the valves abi 1 i ty bo pass f 1 ow ir> the forwar d 1ir ect iori) .

Additionally, there is not a single documented rai lure of ari ECCB check valve of more than 2 iriches iri diameten to allow suf ficier t ECCS f'low in the for war d direct iori. 1her e is one documerited failure of a 2 irich contair>r>>er>t spray additive

<NaOh) valve to allow sufficient flow due to O'Lockage arid or>e docurnerited failure of a 3 irich diar>>eter baric acid Makeup va 1 ve due to blockage ~ Although both <<f thPse fai lures would have beeri detected during partial flc<w test irig of the af fecte(3 systems, it was conser vat ively assumed that these failunes would only be detected during ful 1 r" low test irig or fur iriq physical irispect ion. Ther e are also no documented failures of ECCS check valve. to allow suf f icierit flow due to bindirig of or inter fer ence wi th the check valve flapper, ol- due to other failures or check Ya 1 Ye 1rl'0 Pl 'na 1 se Thel B ar'B however>' doc( Lfllen t e(j fa 1 1 ut Bs o f AFN check valves due to this fai lure r>lode and tr>Q l'ot cause of thesP, f al lures was conservat i vely assumed to apply to ECCH check valves.

I I. Methodology ThP- apprOaCh take,> Within thiS ar>alyriiS WaS:

( 1 ) f To ig'~sess the rrequericy o chpck valve fai 1ur es which would decgi adP syst e>n 1<~~> f capac i t y but not be det Oct Bd by thiB pl'SPr< t pl arit test irig pl c gnam. l w>= pot er>t i al r>lode of f

pal t i a 1 >" low bl ockage were i d Brit i i Bd:

f blockage cif low by pneci pitat iori of bol'c acid; arid partial blocka> e of Flow by valve

iriterrials . Table ~ dc>curner<ts the result:s c<f.

this analysis . Valve failure rates were assessed by f irst ca 1 cul at ing a f a i 1 ur e rat e based c<n obsel ved l i4ustr y f-.-.< i 1 uv es arid secc rid by subj ect i ve1 y mod i fy i rig the fa i 1 ur e 1

rate based c<ri eai"h v~~3.ves suscept i bi 1 it y to such failure, (e. g. a irich valve with bor ic acid conceritr atic<ns riear the salubi1 ity 1 irnl t i s Avouch f>1c<l e 1 i kel y t o becc<rne bl c<cked then a 12 inch diameter valve with relatively 1c<w barari canceritr at iaris) .

Ta calculate the frequency c<f test equir ed ",

tc< reduce the check valve failures ideritified iri step (1) ta rnincr contributars ta system failure relative to failures c<f active carnpc<nent . The criteria imposed by this arialy. is was that check valve partial blockage fai lures shauld coritri bute less than teri pereerit to system failure rela ive 'to the failure of active carnpc<ner<ts within the af fected flow path. (Far the SIT discharge valves thi - was not pa sible since there are na active cornpc<rients within the flaw path therefore far thi particular flow path it

=

was judged that a partial blockage rate cf less thari 5. 8E-84 was acceptable) ~

III. Re ults/Conclusions ANPP ha ccrieluded that f'ul 1 flaw test irig c f certairi ECCB cheek valves (e. g. the cantainrnent suinp and SIT check va1ves > is not practical. For these check valves, additional cheek valve testing is recornrnended ta ensure that check valve par t ial blockage failures rernair< a rnir<or coritributor to systein failure r clat ive t;o active ccmponent faults. Therefc<r e, the fal lawing check valve tests are recornrnended in lieu af ful1 flc<w testing:

Valve Bro~u Reearniner<ded Addi t i c<ria1 I ~ 1@I<

Cant airiinerit Spray I sc 1 w- i->I >ys 1 ca 1 L y l nspect latiori Cheek Valves tc c<rie valve every spr ay header (S I-V164/ th ird refueling V1E5> aut age Cont a 1 nrner<t Sum p Check Phys i ca 1 1 y i'rispec 0 Valves (SI-V~85/SI-V>"&6) c:;ie valve evei y fc<urth refuel ing c<ut age ~

i V a '<<v <~Br a u Recarnrnended Addi t i ona 1 Test in/

BIT discharge Check Valve- Physically inspect

< S I - Vi~1 5/2""<<) / ~35/8 5 )

<<'r one va1 ve every second refueling out age>>

SI T and ECCH Comb ined Ul tr asonica1 ly ver-Cheek Valves (GI-VR}7, i y pr aper valve V227, VZv 7 r V2l>7 ) ape] at ion af at 1 east valve each efuelxng out agee Peniadie disassembly and physical inspection of the SIT and ECCG combined cheek valves <SI-V<<""17 seri es) i s not r eeornrnended.

Although . uch ir<<spection may mar gimbal ly improve the ability of'he plar<t to mitigate a lar ge LOCA event, such inspeetiorrs Would degl aae the abi 1 ity af the plarrt to rni i gate a la<<~s of residual heat r ernova1 event dur i kg shutdown. Sever al r"ecent "

tudies (e. g. NSAC-G6, Zion Re idual Heat Removal PRA) indicate that lass of decay heat ernoval events provide a gee (ter r isk than large LOCA events.

t TABLE 1 RELIABILITY BASED RECOMMENDATIONS FOR FREQUENCY OF CHEC)( VALVC TEST Requir'ed Additiona)

Testing to Ensure Reconuner>ded Addit ior>al Cheek Valve Est irnated Partial that Check Valve Part i a 1 Blockage Testing if Full Flow Test ing is Determir<ed Blockage Failure Remains a Minor rot to be Practical Cheek Valve Current Test Rate Contributor to Gr oup Progra<n ( Fra<n Table 2 System Failure Containment Spray Partial Stroke 8E-84/yr Test one valve Physical ly ir<spect one I..olation Valve to Tested every 18 every forth re- valve every third re-Spray Header months fuel ir<g outage. fue 1 ing outage.

Si-V164/SI-V165 (73ST XZZ86)

ESF Sump Check Partial Stroke 1. 9E-84/yr Verify operability Physically I r<spect one Valve Tested every 18 of ane valve every valve every fax th re-SI-V285/SI-V286 mor<ths forth refueling fueling outage.

(73ST-XZZ86) outage SIT Discharge Check Partial Strake 2. 9E-84/yr Since Safety Injec- Physically inspect one Valve" Tested Every 18 tion Tark is a valve every econd SI-V215/225/235/245 mar<the passive component< refueling outage.

Check Valve Failure is.a significant por t ion of system failure. However, a SIT partial block-age probability of 5E-84 per demand was judged accep-table. This re-quires that one valve be verified operable every 2nd refueling outage.

SIT and Tested to 4888 gprn 1. 9E-84/yr Verify operability Ver xfy proper valve ECCS Co<nbined Check (73ST-XZZ86) of or<e valve every operatior< every re-Valves refuel ing outage. fueling autage , by us in g u 1 t ras or< i e SI-V217/227/237/247 testing.

TABLE 2 ESTINATION OF CHEC}( VALVE FAILURE RATES AND BASIS Valve Blockage Valve Blockage Total Susceptibi)ity Rate Due To Susceptibi)ity Rate Due,To Fai) ur e Rate To Blockage/ Foreign Mater ial To Va)ye De format i onl Impacted By F'orei'gn 'Mater ial Deformat(on/ Binding Full Flow Test Binding Low Low C. S. Di schar ge (18" Diameter) 4.4E-85/yr (exposed to 6. 1E-85/yr 1 ) E-84/yr neglibile dif-

~

Va 1 ves (Cont a inment B)d g )

SI-V)64/165 .." (Infrequent Flow> fereritial pres-(Demin Water ) sul es)

Low Low FGF Sump Check" (24" Diametep) 1. 3E-84lyr (exposed to 6. 1E-85/yr 1.9E-84/yr Valves (Auxiliary Bldg) neg)igible dif-5 I-V285l286..

)

.(Stagnant f low) ferential pressures)

~

Low Nedium SIT Discharge (14" Di ameter) Ii. 4E-85/yr (exposed to 1.9E-84/yr 2. 3E-84/yr Valves (Cont a inment B 1 d g? medium differen-SI-V215/225/235 (Irifrequent f)ow) tial pressures

/245 (Bor ated Water) quickly applied)

SIT 8 ECCS Low Medium Comb)ried Check Valves (14" Diameter)

(Containment B)dg)

Neg1 i gib) e (exposed

)ar ge to differen-

i. 9E-84/yr 1', 9E-84/yr SI-V217/227/237 () 8 Month Flow) t i a) pressure

/247 slowly applied)

'I 4

'I ~