ML18095A805

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Forwards Rev to Inservice Testing Program & Relief Requests Re Qualifications of Test Supervisors,Auxiliary Feedwater Pumps 11,12 & 13 & Boric Acid Transfer Pumps 11 & 12
ML18095A805
Person / Time
Site: Salem  PSEG icon.png
Issue date: 03/14/1991
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N91015, NUDOCS 9103210155
Download: ML18095A805 (36)


Text

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  • Public Service Electric and Gas Company Stanley LaBruna Public Serv.ice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuclear Operations MAR 1 4 1991 NLR-N91015 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

ADDITIONAL INFORMATION REGARDING INSERVICE TESTING PROGRAM SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric & Gas Company (PSE&G) hereby submits, in the Attachment 1 and 2 to this letter, a revision to the Inservice Testing (IST) Program, submitted October 3, 1989 (ref. NLR-N89196). This request is submitted in accordance with Section 4.b.5 of Appendix A to Technical Specifications and Section XI of the ASME Boiler and Pressure Vessel Code. This letter supersedes PSE&G letter to NRC, dated February 28, 1990 (ref:NLR-N90041).

PSE&G asks that all relief requests submitted in Attachments 2 and 3 to this letter are processed for immediate implementation.

A description of the proposed changes is contained in Attachment 1. The revised pages and relief requests are contained in Attachment 2.

Attachment 3 contains a copy of the relief requests for valves not previously approved, to allow testing on a refueling cycle frequency. These relief requests were submitted in IST Program, dated November 3, 1989.

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  • MAR 1 4 1991 Document Control Desk 2 NLR-N91015 Should there be any questions with regard to this submittal, please do not hesitate to contact us.

Sincerely, Attachments C Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson

  • senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mr. Emanuel Mossa New Jersey Department of Labor and Industry PO Box 1503, Labor and Industry Building Trenton, NJ 08625

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NLR-N91015

. . .. . . ATTACHMENT 1

  • DEScRIPTION OF THE PROPOSED CHANGES
1. QUALIFICATIONS FOR TEST SUPERVISORS This relief request is to allow test supervisors for relief valve testing to be qualified to ANSI NlS.1-1971.
2. UNIT 1 AUXILIARY FEEDWATER PUMPS This change is to al*low for increased tolerance in the accuracy of the flow measuring devices.
3. UNIT 1 BORIC ACID TRANSFER PUMPS This change is to allow for increased tolerance.in the accuracy of the flow measuring devices. .- *
4. UNIT 1 .CHILLED WATER PUMPS This change is to allow for increased tolerance in the.

accuracy of the flow measuring devices.

5. UNIT 2 CHILLED WATER PUMPS This change is to allow for increased tolerance in the accuracy of the flow measuring devices.
6. UNIT 2 SERVICE WATER PUMP TESTING This change is to allow 3% accuracy for flow measuring devices during testing due to piping configurations.
7. RHR CONTAINMENT SUMP SUCTION VALVES (SJ44)

This change is to delete currently submitted relief request to test in Cold Shutdown as allowed by Code. Also, this relie*f request is to perform the Remote Position Verifi¢a1:ion Test on an every other refueling frequency.

Page 1 of 1

.NLR~N91015 ATTACHMENT 2 RELIEF REQUESTS Page 1.of 9

NLR-N91015 RELIEF REQUEST COMPONENT: Qualifications of Test Supervisors CATEGORY: "C" Relief Valves TEST REQUIREMENTS: current Maintenance Department procedures reference ASME Section XI, part IWV-3512.

This part of the Code requires testing of these valves per ASME Performance Test Code PTC 25.3. This Code states that a person who supervises the test shall have a formal education in thermodynamics and fluid mechanics. In addition, he shall have at least two years of practical experience in test supervision.

BASIS FOR RELIEF: The requirements of PTC 25.3 are primarily applicable to manufacturer's testing of new valves. The maintenance activity covered by our test procedures is lift set testing.

Only Section 4.09 of PTC 25.3 "Valve Operational Readiness Tests" applies to the testing performed by the Maintenance Department at Salem.

ALTERNATE TESTING: Maintenance test procedures will only reference Section 4.09 of PTC 25.3.

Maintenance supervisors will be qualified in accordance with ANSI 18.1-1971 as committed to in the UFSAR.

Page 2 of 9

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NLR-N91015 RELIEF REQUEST COMPONENT: 11, 12, and 13 AUXILIARY FEEDWATER PUMPS CLASS: 2 FUNCTION: The Auxiliary Feedwater Pumps serve as an emergency backup for supplying feedwater to the secondary side of the steam generators at times when the Main Feedwater System is not available.

TEST REQUIREMENTS": ASME Section XI, Article IWP-3000, requires measurement of inlet pressure, differential pressure, flow rate, vibration amplitude, and bearing temperature. Article IWP-4110 further requires the instrument accuracy for the flow measurement be + 2% of _full scale.

BASIS FOR RELIEF: At present, flow measurement for Auxiliary Feedwater Pumps is taken using an instrument*

which is calibrated to an accuracy of 1-4%.

The existing instrumentation is a Controlotron Clampitron Model 240. The instrument is obsolete and is due to be replaced with a Controlot_ron Clampi tron Model 990 flow instrument. This new flow instrumentation will be calibrated to 1%

accuracy. Calibration of the existing instrumentation is not possible due to parts availability.

Past pump data has been reviewed assuming the larger* tolerance. No operability concerns were noted. The design change process to upgrade the instrumentation is in progress.

When the new instrumentation is installed, the NRC will be notified that the relief request is no longer required. The new instrumentation will be installed by December 31, 1991.

ALTERNATE TESTING: Use the existing flow instrumentation until the more accurate flow instrumentation can be installed.

Page 3 of 9

NLR-N91015 RELIEF REQUEST COMPONENT: 11 and 12 BORIC ACID TRANSFER PUMPS CLASS: 2 FUNCTION: The Boric Acid Transfer Pwnps serve to control chemical shim for reactivity changes for normal operation. They are used for emergency boration reactivity control for emergency conditions.

TEST REQUIREMENTS: ASME Section XI, Article IWP-3000, requires measurement of inlet pressure, differential pressure, flow rate, vibration amplitude, and bearing temperature. Article IWP-4110 further requires the instrument accuracy for the flow measurement be + 2% of full scale.

BASIS FOR RELIEF: At present, flow measurement for the Boric Acid Transfer Pwnps is taken using an instrument which is calibrated to an accuracy .

of 1-3%. The existing instrumentation is a portable Controlotron Clampitron Model 990.

This instrument is due to be replaced with a permanently mounted Controlotron Clampitron Model. 990 flow instrument.. This new flow instrumentation will be calibrated to 1%

accuracy.

Past pump data has been reviewed assuming the larger tolerance. No operability concerns were noted. The design.change process to upgrade the instrumentation is in progress.

When the* new instrumentation is installed, the NRC will be notified that the relief request is no longer required. The new instrumentation will be installed by May 31, 1991.

ALTERNATE TESTING: Use the existing flow instrumentation until the more accurate flow instrumentation can be installed.

Pag~ 4 of 9

NLR-N91015 RELIEF REQUEST COMPONENT: 11 and 12 CHILLED WATER PUMPS CLASS: 2 FUNCTION: The Chilled Water Pumps provide Chilled Water to the Control Room Emergency Ventilation System during certain plant transients in order to maintain Control Room habitability.

TEST REQUIREMENTS: ASME Section XI, Article IWP-3000, requires measurement of inlet pressure, differential pressure, flow rate, vibration amplitude, and bearing temperature. Article IWP-4110 further requires the instrument accuracy for the flow measurement be + 2% of full scale.

BASIS FOR RELIEF: At present, flow measurement for the Chilled Water Pumps is taken using an instrument which is calibrated to an accuracy of 3%.

The existing instrumentation is a Fischer Porter Rotometer, which can only be calibrated to 3% accuracy. The test flow rate specified in the pump test procedure is the pump design flow. This flow is 18%

greater than the system design flow requirements. The additional 1% inaccuracy from the flow meter would reduce the excess flow margin to approximately 17%. The reduction in flow margin will not. impact the ability of the pumps to perform the required safety function.

Past pump data has been reviewed assuming the larger* tolerance. No operability concerns were noted.

ALTERNATE TESTING: Use the existing flow instrumentation.

Page. 5 of 9

NLR-N91015 RELIEF REQUEST COMPONENT: 21 and 22 CHILLED WATER PUMPS CLASS: 2 FUNCTION: The Chilled Water Pumps provide Chilled Water to the Control Room Emergency Ventilation System during certain plant transients in order to maintain Control Room habitability.

TEST REQUIREMENTS: ASME Section XI, Article IWP-3000, requires measurement of inlet pressure, differential pressure, flow rate, vibration amplitude, and bearing temperature. Article IWP-4110 further requires the instrument accuracy for the flow measurement be +/- 2% of full scale.

BASIS FOR RELIEF: At present, flow measurement for the Chilled Water Pumps is taken using an instrument which is calibrated to an accuracy of 3%.

The existing instrumentation is a Fischer Porter Rotometer, which can only be calibrated to 3% accuracy. The test flow rate specified in the pump test procedure is the pump design flow. This flow is 18%

greater than the system design flow requirements.- The additional 1% inaccuracy from the flow meter would reduce the excess flow margin to approximately 17%. The reduction in flow margin will not impact the ability of the pumps to perform the required safety function.

Past pump data has been reviewed assuming the larger tolerance. No operability concerns were noted.

ALTERNATE TESTING: Use the existing flow instrumentation.

Page. 6 of-9

NLR-N91015 RELIEF REQUEST COMPONENT: 21, 22, 23, 24, 25, and 26 SERVICE WATER PUMPS CLASS: 3 FUNCTION: These pumps will pump Delaware River water for cooling through coolers and heat exchangers in the Containment, Auxiliary, and Turbine Buildings.

TEST REQUIREMENTS: ASME Section XI, Article IWP-3000, requires measurement of inlet pressure, differential

  • pressure, flow rate, vibration amplitude, and bearing temperature. Article IWP-4110 further requires the instrument accuracy for the flow mea$urement be +/- 2% of full scale.

BASIS FOR RELIEF: At present, flow measurement for*the Service Water Pumps is taken using permanently mounted instruments calibrated to an accuracy of 1%. The instrument is a transit-time clamp-on ultrasonic flow meter, manufactured by the controlotron Corporation. This instrumentation is located in the Service Water Intake Structure. The piping configuration in the Unit 2 Intake Structure contains elevation changes, elbows, and changes in flow direction which do not allow for a profile to be established which permits accurate flow measurement~

Unit 2 Service Water System has a pipe tunnel with a favorable piping configuration with instrumentation with an accuracy rating of 3%. The most repeatable results of flow measurement can be obtained using instrumentation in the Unit 2 Pipe Tunnel.

Past pump data has been reviewed assuming the larger tolerance. No operability concerns were noted.

ALTERNATE-TESTING: Use flow instrumentation located in the Unit 2 Pipe Tunnel for IST testing of the Service Water Pumps in order to get more repeatable data. *

  • Pag~ 7 of 9

NLR-N91015 RELIEF REQUEST VALVE: 11SJ44 and 12SJ44 CATEGORY: B-CLASS: 3

. FUNCTION: Safety Injection System Containment Sump suction Isolation Valves TEST REQUIREMENTS: Observe the valve at least once every two years to verify that operation is accurately indicated by its ~emote position indication, in accordance with ASME Section XI, -paragraph IWV-3300.

BASIS FOR RELIEF: These valves are each located in separate

.*compartments in the Containment *.-- The compartments are accessible from outside the Containment through four foot diameter manway~ which must be unbolted and manually removed. These manways are sealed by gaskets on the flange surface to which they are bolted. The proper sealing of this surface is necessary to ensure Containment integrity.

If the valves are Remote Position verified every two ye~rs, it is possible that the hatch would have to be removed.for verification only. In order to minimize damage to flange surf~ces and gaskets, the-valves should be verified for remote position indication when other scheduled maintenance/

inspection activities are performed.

_ALTERNATE TESTING: Remote position indication will be verified once every other refueling concurrent with Environmental Qualification inspections.

Page_ 8 of 9

NLR-N91015 RELIEF REQUEST VALVE: 21SJ44 and 22SJ44 CATEGORY: B CLASS: 3 FUNCTION: Safety Injection System Containment Sump Suction Isolation Valves TEST REQUIREMENTS: Observe the valve at least once every two years to verify that operation is accurately indicated by its remote position indication, in accordance with ASME Section XI, paragraph IWV-3300.

BASIS FOR RELIEF: These valves are each located in separate compartments in the Containment.-* The*

compartments are accessible from outside the Containment through four foot diameter manways which must be unbolted and manually removed. These manways are sealed by gaskets on the flange surf ace to which they are bolted. The proper sealing of this surface is necessary to ensure Containment integrity.

If the valves are Remote Position verified every two years, it is possible that the hatch would have to be removed for verification only. In order to minimize damage to flange surfaces and gaskets, the valves should be verified for remote position indication when other scheduled maintenance/

inspection activities are perforined.

ALTERNATE TESTING: Remote position indication will be verified once every other refueling concurrent with Environmental Qualification inspections.

Page 9 of 9

NLR-N91015 ATTACHMENT 3 RELIEF REQUESTS VALVE TESTING ON A REFUELING CYCLE SALEM UNIT 1 Page 1 of 24

NLR-N91015 RELIEF REQUEST VALVE: ll-14CC128 (4 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: To prevent backflow from the Reactor Coolant Pump Thermal Barrier.

TEST REQUIREMENTS:. Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

  • BASIS FOR RELIEF: These valves cannot be exercised closed during Power Operations because Component Cooling flow to the .Reactor Coo1*ant Pump
  • Thermal Barrier would be lost.

ALTERNATE TESTING: These valves will b.e exercised to the closed position during Refueling after the Component Cooling System has been dechromated to minimize the health hazards.to the individuals performing the test and to protect the Reactor Coolant Pumps.

Page *2 of 24

NLR-N91015 RELIEF REQUEST VALVE: 1PR25 CATEGORY: A,C (check)

CLASS: 2 FUNCTION: ECCS Relief valve non-return check and Containment Isolation.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: Valve cannot be full flow tested in the forward direction due to the size of the test connection. This valve cannot be reverse flow tested during Power Operat~on because a blank flange must be installed which renders ECCS relief valves inoperable.

ALTERNATE TESTING: A partial exercise test will be performed in the forward direction due to the size of test connection. The valve will also be periodically disassembled to comply with item 2 of Generic Letter 89-04. Valve will be exercise tested in the reverse direction during Refueling local leak rate testing.

Page*3 of 24

NLR-N91015 RELIEF REQUEST VALVE: 1RC40, 41, 42, AND 43 (4 valves)

CATEGORY: B CLASS: 2 FUNCTION: To vent the Reactor Vessel Head.

TEST REQUIREMENTS:

A: Stroke time/exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3410.

B: Perform remote position indicator verification in accordance with the requirements of Section XI, paragraph IWV-3300.

BASIS FOR RELIEF:

A: A letter from Mr. Steve Varga (Operating Reactor Branch 1, Division of Licensing),

dated September 27, 1983 to Mr. R. A. Uderitz (Vice President Nuclear).* Technical Specification surveillance.requirements 4.4.12.1, 4.4.12.2, and 4.4.12.3.

B: Remote position verification cannot be performed due to no local valve position indication.

ALTERNATE TESTING:

A: These valves will be exercised during Refuelings in accordance with Technical Specification surveillance requirements 4.4.12.1, 4.4.12.2, and 4.4.12.3.

B: None Page-4 of 24

NLR-N91015 RELIEF REQUEST VALVE: 1SJ3 CATEGORY: c (check)

CLASS: 2 FUNCTION: To prevent backflow of the Volume Control System into the Refueling Water Storage Tank.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements

. of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: This valve cannot be exercised during Power Operation-because 2300 ppm boron would be injected into the Reactor Coolant System.

ALTERNATE TESTING: This valve will be full flow tested during Refueling and radiographed after full flow testing, once the Volume Control Tank has been pressurized, to verify the valve has

  • reseated.

Page -5 of 24 .

NLR-N91015 RELIEF REQUEST VALVE: 11 - 14SJ55 (4 valves)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backf low from the discharge of the RHR Pumps into the Accumulators.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: During Power Operation, the Reactor Coolant System pressure is greater than Accumulator pressure.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings~

Page *6 of 24

NLR-N91015 RELIEF REQUEST VALVE: 11 - 14SJ56 (4 vaives)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backf low from the Reactor Coolant System into the Accumulators and the RHR Pump discharge lines.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: Flow cannot be established during Power Operation because the RCS pressure is greater than both the RHR Pump shutoff ~ead and Accumulator pressure.

  • ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.
  • page*7 of 24

NLR-N91015 RELIEF REQUEST VALVE: 1SJ70 CATEGORY: c (check)

CLASS: 2 FUNCTION: To prevent backflow from the RHR Pump suction to the Refueling Water Storage Tank.

TEST REQUIREMENTS: Exercise valve at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: Valve can only be full stroke exercised during cavity fill. During Power Operation maximum RHR pump flow on recirculation is 500 gpm from discharge of pump ~o suction of pump. Flow through 1SJ70 would.be minimal.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.

Page-8 of 24

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NLR-N91015 RELIEF REQUEST VALVE: 11 - 14SJ139 (4 valves)

CATEGORY: C (check)

CLASS: 1 FUNCTION: To prevent backflow from the Reactor Coolant System hot legs into the Safety Injection Pumps.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: During Power Operation, testing is not possible, since Reactor Coolant system pressure is greater than Safety Injection Pump shutoff head.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.

Page-9 of 24

NLR-N91015 RELIEF REQUEST VALVE: 11 - 14SJ144 (4 valves)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backf low from the Reactor Coolant System cold legs into the Safety Injection Pump discharge lines. -

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520._

BASIS FOR RELIEF: During Power Operation, testing is not possible, since Reactor Coolant *system pressure is greater than Safety Injection Pump shutoff head.

  • ALTERNATE TESTING: These valves will be full stroke exercised during Refuel~ngs.

Page-10 of 24

NLR-N91015

.RELIEF REQUEST VALVE: 11 AND 13SW5 (2 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: Prevent backflow from the Turbine header to the Pump discharge header.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance witn the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: A method. of verifying these valves closed other than inspection is not available.

ALTERNATE TESTING: These valves will be inspected during Refuelings with one of the two valves being disassembled and inspected each Refueling.

Page*ll of 24

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NLR-N91015 RELIEF REQUEST VALVE: 12 AND 14SW5 (2 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: Prevent backflow from the Nuclear header to the Pump discharge header.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: These valves cannot be exercised open without subjecting the system to a significant

  • transient and erosion. An adequate means for testing the valve closed is not __available.

ALTERNATE TESTING: These valves will be part stroke exercised

  • every 90 days. One of these valves will be disassembled and inspected every Refueling.

Page*12 of 24

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NLR-N91015 SALEM UNIT 2

  • Page*13 of 24

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NLR-N91015 RELIEF REQUEST VALVE: 21-24CC128 (4 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: To prevent backf low from the Reactor Coolant Pump Thermal Barrier.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: These valves cannot be exercised closed during Power Operations because Compon*ent Cooling flow to the Reactor Coolant Pump Thermal Barrier would be lost.

ALTERNATE TESTING: These valves will be exercised to the closed position during Refueling after the Component Cooling System has been dechromated to minimize the he~lth hazards to the individuals performing the test and to protect the Reactor Coolant Pumps.

Page-14 of 24

NLR.:..N91015 RELIEF REQUEST VALVE: 2PR25 CATEGORY: *A,C (check)

CLASS: 2 FUNCTION: ECCS Relief valve non-return check and Containment Isolation.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: Valve cannot be full flow tested in the forward direction due to the size of the test connection. This valve cannot be reverse .

flow tested during Power Operat.ton because a blank flange must be installed which .renders ECCS relief valves inoperable.

ALTERNATE TESTING: A partial exercise test will be performed in the forward direction due to the size of test connection. The valve will also be periodically disassembled to comply with item 2 of Generic Letter 89-04. Valve will be exercise tested in the reverse direction during Refueling local leak rate testing.

Page*15 of 24

NLR-N91015 RELIEF REQUEST VALVE: 2RC40, 41, 42, AND 43 (4 valves)

CATEGORY: B CLASS: 2 FUNCTION: To vent.the Reactor Vessel Head.

TEST REQUIREMENTS:

A: Stroke time/exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3410.

B: Perform remote position indicator verification in accordance with the requirements of Section XI~ paragraph IWV-3300.

BASIS FOR RELIEF:

A: A letter from Mr. Steve Varga (Operating Reactor Branch 1, Division of Licensing), .*

dated Sept~mber 27, 1983to Mr. R. A. Uderitz (Vice President Nuclear) *.* Technical Specification surveillance requirements 4.4.12.1, 4.4.12.2, and 4.4.12.3.

B: Remote position verification cannot be performed due to no local valve position indication.

  • ALTERNATE TESTING:

A: These valves wiil be exercised during Refuelings in. accordance with Technical Specification. surveillance requirements 4.4.12.1, 4.4.12.2, and 4.4.12.3.

B: None Page*16 of 24

NLR-N91015 RELIEF REQUEST VALVE: 2SJ3 CATEGORY: c *(check)

CLASS: 2 FUNCTION: To prevent backflow of the Volume control System into the Refueling water Storage Tank.*

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

  • BASIS FOR RELIEF: This valve cannot be exercised during Power Operation because 2300 ppm boron would.be injected into the Reactor Coolant System.

ALTERNATE T~STING: This valve will be full flow tested during Refueling and radiographed after full flow testing, once the*Volume Control Tank has been.pressurized, to verify the valve has reseated.

  • page*17 of 24

NLR-N91015 RELIEF REQUEST VALVE: 21 - 24SJ55 (4 valves)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backflow from the discharge of the RHR Pumps into the Accumulators.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: During Power Operation, the Reactor Coolant system pressure is greater than Accumulator

.Pressure.

ALTERNATE TESTING: These valves will be full stroke.exercised during Refuelings.

  • Page*1a of 24

NLR-N91015 RELIEF REQUEST VALVE: 21 - 24SJ56 (4 vaives)

CATEGORY: c (check)

CLASS:* 1 FUNCTION: To prevent backflow from the Reactor Coolant system* into the Accumul.ators and the RHR Pump

  • discharge lines.

TEST REQUIREMENTS: Exercise valves at least once every three .

months, in accordance.with the requirements of Section XI, paragraph IWV-3520.

  • BASIS FOR RELIEF: Flow cannot be established during Power Operation because the RCS pressu*re is greater than both the RHR Pump shutoff head and Accumulator pressure.
  • ALTERNATE TES.TING: These valves will be full stroke exercised during Refuelings.
  • page-19 of 24

NLR-N91015 RELIEF REQUEST VALVE: 2SJ70 CATEGORY: c (check)

CLASS: 2 FUNCTION: To prevent backflow from the RHR Pump suction to the Refueling Water Storage Tank.

TEST REQUIREMENTS: Exercise valve at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: Valve can only be full stroke exercised during cavity fill. During Power Operation maximum RHR pump flow on recirculation is 500 gpm from discharge of pump to suction of pump. Flow through 2SJ70 would.be minimal.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.

Page-20 of 24

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NLR-N91015 RELIEF REQUEST VALVE: 21 - 24SJ139 (4 valves)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backflow from the Reactor Coolant System hot legs into the Safety Injection Pumps.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: During Power Operation, testing is not possible, since Reactor Coolant System pressure is greater than Safety Injection Pump shutoff head.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.

Page*21 of 24

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' ~- 11 )

NLR..,;N91015 RELIEF REQUEST VALVE: 21 - 24SJ144 (4 valves)

CATEGORY: c (check)

CLASS: 1 FUNCTION: To prevent backf low from the Reactor Coolant System cold legs into the Safety Injection Pump discharge lines.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph*IWV-3520.

BASIS FOR RELIEF: During Power Operation, testing is not possible, since Reactor Coolant System pressure is greater than Safety ,_Injection Pump shutoff head.

ALTERNATE TESTING: These valves will be full stroke exercised during Refuelings.

Page*22 of 24

NLR-N91015 RELIEF REQUEST VALVE: 21 AND 23SW5 (2 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: Prevent backflow from the Turbine header to the Pump discharge header.

TEST REQUI~MENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV~3520.

BASIS FOR RELIEF: A method of verifying these valves closed other than inspection is not av~ilable.

ALTERNATE TESTING: These valves will be inspected during Refuelings with one of the two valves being disassembled and inspected each Refueling .

Page-23 of 24

NLR-N91015 RELIEF REQUEST VALVE: 22 AND 24SW5 (2 valves)

CATEGORY: c (check)

CLASS: 3 FUNCTION: Prevent backflow from the Nuclear header to the Pump discharge header.

TEST REQUIREMENTS: Exercise valves at least once every three months, in accordance with the requirements of Section XI, paragraph IWV-3520.

BASIS FOR RELIEF: These valves cannot be exercised open without subjecting the system to a signi_ficant transient and erosion. An adequate means for testing the valve closed is not.available.

ALTERNATE TESTING: These valves will be part stroke exercised every 90 days. One of these valves will be _,_

disassembled and inspected every Refueling. **

Page *24 of 24