ML18200A080

Submittal of Fourth 10-Year Interval Inservice Testing (IST) Program Plan

ML18200A080
Person / Time
Site:	LaSalle
Issue date:	07/18/2018
From:	Trafton W J Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18200A230	List: ML18200A080 RA18-059, Inservice Testing Program Plan, Technical Position TP-05
References
RA18-059
Download: ML18200A080 (174)

Text

Exelon Generation. LaSalle County Station 2601 North 21S1 Road Marseilles, IL 61341 815-415-2000 Telephone www.exeloncorp

.com RA18-059 10 CFR 50.55a July 18, 2018 United States Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555

Subject:

LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50.374 Submittal of Fourth 10-Year Interval lnservice Testing (IST) Program Plan In accordance with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTA, "General Requirements," attached for your information is a copy of the Fourth 10-Year Interval lnservice Testing (IST) Program Plan for LaSalle County Station (LSCS), Units 1 and 2. The fourth interval of the LSCS, Units 1 and 2 IST Program Plan complies with the 2004 Edition through 2006 Addenda of the ASME OM Code. Should you have any questions concerning this letter, please contact Ms. Dwi Murray, Regulatory Assurance Manager, at (815) 415-2800.

Respectfully, Site Vice President LaSalle County Station

Attachment:

LaSalle County Station, Units 1 and 2, lnservice Testing Program Plan Fourth Year Interval, Revision O cc: Regional Administrator-NRC Region Ill NRC Senior Resident Inspector-LaSalle County Station APPROVALS:

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval LaSalle County Station Units 1 & 2 Inservice Testing Program Plan Fourth Ten-Year Interval Revision 0 Commercial Service Dates: Unit 1 -January 1, 1984 Unit 2-October 17, 1984 LaSalle County Station 2601N.21st Rd Marseilles, Illinois 61341 Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval REVISION LOG Effective Revision Description Prepared; Date Approved; Date Date IST Engr. Programs Program Manager Engineer Revision 0 -Original 10/12/17 Issue for Fourth Ten-J.P 10/2/17 See Cover Year IST Interval Revision Date: 1011212017 2 !ST-LAS-PLAN SECTION 1.0 1.1 1.2 2.0 2.1 2.2 3.0 3.1 3.2 4.0 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14.

15. 16. 17. !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval TABLE OF CONTENTS INTRODUCTION Purpose Scope INSERVICE TESTING PLAN FOR PUMPS Pump Inservice Testing Plan Description Pump Plan Table Description INSERVICE TESTING PLAN FOR VALVES Valve lnservice Testing Plan Description Valve Plan Table Description ATTACHMENTS System and P&ID Listing Pump Relief Request Index Pump Relief Requests Valve Relief Request Index Valve Relief Requests Cold Shutdown Justification Index Cold Shutdown Justifications Refuel Outage Justification Index Refuel Outage Justifications Check Valve Condition Monitoring Plan Basis Index Check Valve Condition Monitoring Plan Basis Station Technical Position Index Station Technical Positions lnservice Testing Pump Table Index Inservice Testing Pump Table lnservice Testing Valve Table Index Inservice Testing Valve Table Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval

1.0 INTRODUCTION

1.1 Purpose

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

• Shutdown the reactor to the safe shutdown condition,

• Maintaining the safe shutdown condition, or

• To mitigate the consequences of an accident.

The LaSalle County Station was designed and licensed to operate with the Cold Shutdown condition defined as the "safe" shutdown condition.

1.2 Scope

The IST program plan has been prepared to meet the requirements of the American Society of Mechanical Engineers (ASME) OM Code 2004 Edition through 2006 Addenda (ASME OM Code 2004/2006a).

Mandatory Appendix I of the ASME OM Code 2004 Edition through 2006 Addenda will be used for pressure relief device testing activities.

Mandatory Appendix II of the ASME OM Code 2004 Edition through 2006 Addenda (as modified by 10CFR50.55a(b)(3)(iv)(A), (B) and (C)) will be used for check valve condition monitoring activities.

Motor operated valve testing is based on the requirements of ASME Code Case OMN-1 for selected valves (as modified by 10CFR50.55a(b)(3)(ii) and Relief Request RV-01).

• ASME OM Code 2004/2006a, Subsection IST A, "General Requirements" ISTA contains the requirements directly applicable to inservice testing including the Owner's Responsibility and Records Requirements.

• ASME OM Code 2004/2006a, Subsection ISTB, "Inservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants" ISTB establishes the requirements for inservice testing of pumps in water reactor nuclear power plants. The pumps covered are those provided with an emergency power source that are required in shutting down of the reactor to a safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval o ASME OM Code 2004/2006a, Subsection ISTC, "Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants" ISTC establishes the requirements for inservice testing of valves in light-water reactor nuclear power plants. The valves covered include those which provide overpressure protection and are required to perform a specific function, either actively through the changing of valve obturator position or passively by effectively maintaining required obturator position in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

11 ASME OM Code 2004/2006a, Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants" Provides the requirements for performance testing and monitoring of nuclear plant pressure relief devices. Methods, intervals, and record requirements for monitoring and testing are established, as well as guidelines for the evaluation of results. The Appendix applies to safety valves, safety relief valves, operated pressure relief valves, power-actuated pressure relief valves, reclosing pressure relief devices and vacuum relief devices, including all accessories and appurtenances.

11 ASME OM Code 2004/2006a, Mandatory Appendix II, "Check Valve Condition Monitoring Program" Provides an alternative to the testing or examination requirements of ISTC-3510 through ISTC-5221.

The purpose of this program is both to improve valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of a select group of check valves. 11 ASME OM Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants" Provides an alternative to the valve testing requirements of subsection ISTC for certain electric motor operated valves. The purpose of these alternative requirements is to provide a program to both improve valve performance and to optimize testing and examination activities, thus eliminating unnecessary testing that provides minimal information about the MOV' s operational readiness.

Revision Date: 1011212017 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval The LaSalle County Nuclear Power Station Fourth Ten-Year Pump and Valve Inservice Testing Plan will be in effect as follows:

• Unit One: Start (1): October 12, 2017

• Unit Two: Start (1): October 12, 2017 End: October 11, 2027 End: October 11, 2027 ( 1) The start date for the Fourth Ten-Year IST Interval reflects a one ( 1) year extension of the Second Ten-Year IST Interval on Unit 1 and an extension of less than one (1) year of the Second Ten-Year IST Interval on Unit 2 as allowed by paragraph IW A-2430(d) of ASME Code Section XI (1989 Edition).

This extension is discussed in the letter dated October 16, 2006 from LaSalle County Station to the U.S. Nuclear Regulatory Commission (ref. Regulatory Assurance Letter RA06-063).

This extension shall not cause successive intervals to be altered by more than one ( 1) year from the original pattern of intervals.

Revision Date: 1011212017 3 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval 2.0 INSERVICE TESTING PLAN FOR PUMPS 2.1 Pump Inservice Testing Plan Description This testing program for pumps meets the requirements of the ASME OM Code 2004 edition through 2006a, Section ISTB "Inservice Testing of Pumps in Water Reactor Nuclear Power Plants". Where these requirements have been determined to be impractical, specific requests for relief were written and are included in Attachment

3. NRC Generic Letter 89-04 and NUREG 1482, Revision 2 have been used as guidance in the development of the IST Program. 2.2 Pump Plan Table Description The pumps included in the LaSalle County Nuclear Power Station IST Plan are listed in Attachment

15. The information contained in these tables identifies those pumps that are required to be tested to the requirements of Subsection ISTB of the ASME OM Code 2004 Edition through 2006 Addenda, along with their applicable tests, and test frequencies.

The Pump Plan Table is divided into sections based upon Plant System. The headings for the pump tables are delineated below. PumpEPN Pump Name P&ID Coor. IST Group Revision Date: 1011212017 The unique Equipment Part Number (EPN) for the pump. Each EPN is preceded with a Unit designator for the pump: 0 1 2 Common Unit Unit 1 Unit 2 The descriptive name for the pump. The Piping and Instrumentation Drawing on which the pump is represented.

The P&ID Coordinate location of the pump. Pump Group as defined in ISTB-2000 Group A GroupB NIA Continuous or routinely operated pumps Standby pumps not operated routinely Not Applicable (Skid-mounted)

IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval 2.2 Pump Plan Table Description (Cont'd) Safety Class The ASME Code classification of the pump. Pump Type Pump Driver Revision Date: 1011212017 1 2 3 NC NS Class 1 Class 2 Class 3 Non-Code, Safety Related Non-Safety Related The type of pump. C Centrifugal PD Positive Displacement VLS Ve1tical Line Shaft The type of pump driver. Motor Turbine Engine 2 Motor driven Steam turbine driven Combustion Engine IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 2.2 Pump Plan Table Description (Cont'd) Test Type Test Freq. Revision Date: 1011212017 Measured test parameters.

S(l) Pump Speed (Measured only for variable speed pumps). Differential Pressure as calculated by subtracting the suction from the discharge pressures or obtained by direct measurement.

DIS-Pco Discharge Pressure (Measured only for positive displacement pumps). y(l) SKID Flow Rate as measured using a rate or quantity meter installed in the pump test circuit. Vibration (Pump bearing).

Parameter(s) as determined by LaSalle County Station are verified through the testing of the item's parent/major component.

Cl) Following the specification of each 'Test Type', within parenthesis will be noted which of the following test criteria will be applied: a -Denotes a Group A Pump Test b Denotes a Group B Pump Test c -Denotes a Comprehensive Pump Test The frequency for performing the specified inservice test. M3 cs RF Y2 OP 3 Quarterly (92 Days) Cold Shutdown Refueling Two Years (Biennially)

Operating Parameter IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval 2.2 Pump Plan Table Description (Cont'd) Relief Request Deferred Just. Tech. Pos. Revision Date: 1011212017 A relief request number is listed when a specific Code requirement is determined to be impractical.

Reference either a Cold Shutdown or Refueling Justification Evaluation by its specific justification number. Reference a Technical Position by its specific number. A Technical Position is written to document how Code requirements are being implemented at the station when the requirement( s) of the Code are not easily interpreted.

4 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 3.0 INSERVICE TESTING PLAN FOR VALVES 3.1 Valve Inservice Testing Plan Description This testing program for valves meets the requirements of the ASME OM Code 2004 edition through 2006a, Section ISTC "Inservice Testing of Valves in Water Reactor Nuclear Power Plants"; Mandatory Appendix I "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants"; Mandatory Appendix II Check Valve Condition Monitoring Program" with the limitations imposed by 10 CPR 50.55a(b)(3)(iv)(A), (B) and (C); and ASME Code Case OMN-1 with the limitations imposed by 10 CPR 50.55a(b )(3)(ii).

Where these requirements are determined to be impractical, specific requests for relief have been written and are included in Attachment

4. Where the frequency requirements for valve testing have been determined to be impractical, Cold Shutdown or Refuel Outage Justifications have been identified and written. These justifications are provided in Attachments 7 and 9 respectively.

3.2 Valve

Plan Table Description The valves in Attachment 17 list all ASME Class 1, 2, 3 and NC Valves that have been scoped in the IST Program and have been assigned Valve Categories.

Valves exempt per ASME OM Code ISTC-1200 are not listed. The Valve Plan Table is divided into sections by Plant System. The following information is included for each valve: Valve EPN A unique identifier for the valve. Each EPN is preceded with a Unit designator for the valve: 0 1 2 Common Unit Unit 1 Unit 2 Valve Name The description of the valve. P&ID The Piping and Instrumentation Drawing (P&ID) number on which the valve appears. (If the valve appears on multiple P&IDs, the primary P&ID will be listed.) P&ID Coor. The drawing coordinate location on the P&ID for the valve. Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 3.2 Valve Plan Table Description (Cont'd) Code Class IST Category Valve Size Revision Date: 1011212017 The ASME Classification of the valve. 1 2 3 NC NS ASME Code Class 1 ASME Code Class 2 ASME Code Class 3 Non-Code, Safety Related Non-Safety Related The category(s) assigned to the valve based on the definitions per ASME OM Code ISTC-1300.

The following categories are defined in the Code: Category A -Valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their function(s).

Category B -Valves for which seat leakage in the closed position is inconsequential for fulfillment of their function(s).

Category C -Valves that are self-actuating in response to some system characteristic, such as pressure (relief valves) or flow direction (check valves) for fulfillment of their function(s).

Category D -Valves that are actuated by an energy source capable of only one operation, such as rupture disks or explosive-actuated valves. NIA-Valves that have been included into the IST Program as the result of a commitment.

More than one Category may be specified if more than one distinguishing Category characteristic is applicable.

The nominal size of the valve, in inches. 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 3.2 Valve Plan Table Description (Cont'd) Valve Type ACT. Type Active/Passive Revision Date: 1011212017 The valve body design as indicated by the following abbreviation.

3W 4W ANG BAL BTF CK DAM DIA GA GL PCV PLG PLT PPT RPD RV SCK SHR sv XFC 3-Way Valve 4-Way Valve Angle Ball Valve Butterfly Valve Check Valve Damper Diaphragm Valve Gate Valve Globe Valve Pressure Control Valve Plug Valve Pilot Valve Poppet Valve Rupture Disk Relief Valve Stop Check Valve Shear Valve/SQUIB Valve Safety Excess Flow Check Valve The actuator type abbreviation.

AO Air Operator EXP Explosive Actuator HO Hydraulic Operator M Manual MO Motor Operator SA Self-Actuating SAP Self-Actuated Pilot SO Solenoid Operator Active or Passive function determination for the valve in accordance with ISTA-2000.

A Active P Passive NIA Not Applicable (Non-Safety Related Valves) 3 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 3.2 Valve Plan Table Description (Cont'd) Normal Position Safety Position Revision Date: 1011212017 The normal position of the valve during normal power operation.

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

C Closed LC Locked Closed D De-energized (3-way and 4-way valves) E Energized (3-way and 4-way valves) 0 Open LO Locked Open SYS System Condition Dependent The valve's safety function position(s).

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

c D E DIE 0 O/C NIA 4 Closed De-energized (3-way and 4-way valves) Energized (3-way and 4-way valves) De-energized or Energized Open Open or Closed Valve has no Safety Related Position (Augmented)

IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval 3.2 Valve Plan Table Description (Cont'd) TestRqmt The test(s) that will be performed to fulfill the requirements of ASME OM Code ISTC. The definitions and abbreviations are identified below: cc co CP DT ET FS-C FS-0 LT-J LT-S ME OPR OMN-0 OMN-C PIT RVT ST-C SD SE ST-0 Exercised Closed-Check Valve 1 Exercise Open Check Valve 1 Partial Exercise Open-Check Valve 1 Rupture Disk I Explosive Valves Full Exercise without stroke timing Fail Safe Test Closed Fail Safe Test Open Leakage Rate Test (Appendix J) Leakage Rate Test (Seat, ISTC-3630)

Manual Exercise Operator Rounds (condition monitoring)

Open Test per OMN-1 Criteria Closed Test per OMN-1 Criteria Position Indication Test Relief Valve Test Stroke Time Closed Solenoid De-energize Solenoid Energize Stroke Time Open 1 Three letter designations are used for Check Valve Condition Monitoring tests to differentiate between the various methods of exercising check valves. The letter following "CC" or "CO", or "CP" is "A" for acoustics, "D" for disassembly and examination, "F" for flow indication, "M" for magnetic, "R" for radiography, "T" for break away torque, "U" for ultrasonic, or "X" for manual exercise.

Revision Date: 1011212017 5 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval 3.2 Valve Plan Table Description (Cont'd) Test Freq. Relief Request Deferred Just. The test frequency abbreviation.

AppJ CM cs M3 OP RR S2 SA Y2 Y5 YlO OMN Appendix J Condition Monitoring 1 Cold Shutdown Quarterly Operating Activities 2 Refuel Outage Explosive Charge Sample Check Valve Disassembly Sample 3 2 years 5 years 10 years Per the MOY Program, not to exceed 10 years The applicable Relief Request as it applies to the subject test. Deferred Test Justification.

This field provides reference to either an applicable Cold Shutdown Justification or Refuel Outage Justification.

A Cold Shutdown Justification is a document that provides a justification as allowed by ISTC-3510 to extend the applicable testing frequency to that which coincides with the plant's "Cold Shutdown" frequency.

A Cold Shutdown Justification is identified by its unique number identifier which has a "CS" prefix. Cold Shutdown Justifications are contained in Attachment 7 of this document.

A Refuel Outage Justification is a document that provides a justification as allowed by ISTC-3510 to extend the applicable testing frequency to that which coincides with the plant's "Refuel Outage" frequency.

A Refuel Outage Justification is identified by its unique number identifier that has a "RJ" prefix. Refueling Outage Justifications are contained in Attachment 9 of this document.

1 Frequency is as indicated in respective Condition Monitoring Plan for that valve group. 2 Satisfied i.a.w. Exelon IST Program Technical Position, TP-05, "Check Valves in Regular Use." 3 Used for check valve disassembly/inspection per ISTC requirements or to indicate Condition Monitoring frequency (refer to respective Condition Monitoring Plan for that valve group). Revision Date: 1011212017 6 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Tech. Pos. Revision Date: 1011212017 A Technical Position is a document that is used by the utility/Owner to clarify their interpretation of Code requirements when it is felt by the utility or Owner that either the requirements of the code are not easily interpreted or when they simply want to document how a Code requirement is being implemented at the station. Technical Positions are identified by their unique number identifier that contains a "TP" prefix. Technical Positions are contained in Attachment 13 of this document.

This column also identifies the applicable Check Valve Condition Monitoring Program group as contained in Attachment 11, where applicable.

7 IST-LAS-PLAN JST Program Plan LaSalle County Station Units I & 2, Fourth Interval 4.0 ATTACHMENTS:

Attachment 1 System and P&ID Listing Attachment 2 Pump Relief Request Index Attachment 3 Pump Relief Requests Attachment 4 Valve Relief Request Index Attachment 5 Valve Relief Requests Attachment 6 Cold Shutdown Justification Index Attachment 7 Cold Shutdown Justifications Attachment 8 Refuel Outage Justification Index Attachment 9 Refuel Outage Justifications Attachment 10 Check Valve Condition Monitoring Plan Basis Index Attachment 11 Check Valve Condition Monitoring Plan Basis Revision Date: 1011212017 Attachment 12 Station Technical Positions Index Attachment 13 Station Technical Positions Attachment 14 Inservice Testing Pump Table Index Attachment 15 Inservice Testing Pump Table IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Revision Date: 1011212017 Attachment 16 Inservice Testing Valve Table Index Attachment 17 Inservice Testing Valve Table 2 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 1 SYSTEM AND P&ID LISTING System System Name P&ID CM Containment Monitoring M-156-1,-2, -3,-4, M-158-1, -2,-3,-4 DG Diesel Generator M-83-1,-2,-3,-4 DO Diesel Fuel Oil M-85-1, M-132 FC Fuel Pool Cooling M-98-1, M-144-1 FW Feed water M-57-1, M-118-1 HG Containment Combustible Gas Control M-130-1, -2 HP High Pressure Core Spray M-95, M-141, M-2095-1, M-2141-1 IA Instrument Air M-81-2,M-81-17 IN Instrument Nitrogen M-66-1, -2, -3, -4, -7, -8 LP Low Pressure Core Spray M-94, M-140, M-2094-1, M-2140-1 MC Clean Condensate Storage M-75-2, -4 MS Main Steam M-55-1, -2, -3, -7, -8, M-116-1,-2,-3,-7,-8, M-2055-4, -5, -6, -7, M-2116-4, -5, -6, -7 NB Nuclear Boiler M-139-1, -2,-3,-4, -5 NR Neutron Monitoring M-774-1, -4 PC Primary Containment M-92-2,M-138-2 RD Control Rod Drive M-100-2, -3, -4, -5, M-146-2, -3, -4, -6 RE Reactor Building Equipment Drains & Floor M-91-3, -4, Drains M-137-3, -4 Revision Date: 1011212017 l IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval RH Residual Heat Removal M-96-1, -2, -3, -4, M-87-1, -2, -3, M-134-1, -2, -3, M-142-1, -2, -3, -4, M-2096-4, -5, M-2142-4, -5 RI Reactor Core Isolation Cooling M-101-1, -2, M-147-1, -2, M-2101-1, M-2147-1 RR Reactor Recirculation M-93-1, -2, -3, -4, -5, M-2093-1, -2, -3, -4, -8, M-2139-1, -2, -3, -4, -8 RT Reactor Water Cleanup M-97-1, M-143-1, M-2097-1, -2, M-2143-1, -2 SA Service Air M-82-3, -5 SC Standby Liquid Control M-99, M-145 VG Standby Gas Treatment M-89 VP Primary Containment Chilled Water M-86-1, M-133-1 VQ Primary Containment Purge M-92-1, -2,M-138-1,-2 VR Reactor Building Ventilation M-1455-1 M-1456-1 WR Reactor Building Closed Cooling Water M-90-2,M-136-2 Revision Date: 1011212017 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fou11h Interval ATTACHMENT 2 PUMP RELIEF REQUEST INDEX Designator Description Revision RP-01 Water Leg Pump Flow Test Rev.0 RP-02 Water Leg Pump Rev.0 Comprehensive Testing RP-03 Code Case OMN-21 Rev.0 RP-04 Code Case OMN-19 Rev.0 Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 3 PUMP RELIEF REQUESTS Revision Date: 1011212017 1 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Pump Relief Request

• RP-01 Water Leg Pump Flow Test (Rev. 0) (Page 1of3) Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Hardship without Compensating Increase in Level of Quality or Safety 1. ASME Code Component(s)

Affected Pump Description Class Category 1E22-C003 HPCS Water Leg Pump 2 Group A 1E21-C002 LPCS Water Leg Pump 2 Group A 1E12-C003 RHR Water Leg Pump 2 Group A 1E51-C003 RCIC Water Leg Pump 2 Group A 2E22-C003 HPCS Water Leg Pump 2 Group A 2E21-C002 LPCS Water Leg Pump 2 Group A 2E12-C003 RHR Water Leg Pump 2 Group A 2E51-C003 RCIC Water Leg Pump 2 Group A 2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda 3. Applicable Code Requirement Unit 1 1 1 1 2 2 2 2 ISTB-3000, General Testing Requirements, Table ISTB-3000-1, Inservice Test Parameters, specifies the parameters to be measured during inservice testing (i.e., Flow Rate, Q). ISTB-5121, Group A Test Procedure, paragraph ISTB-512l(c) states, "Where it is not practical to vary system resistance, flow rate and pressure shall be determined and compared to their respective reference values." 4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and Standards," Paragraph (z)(2), an alternative is proposed to the requirement to measure flow rate as defined in the ASME OM Code. The basis of the request is that the requirement to measure the flow rate provides a hardship without a compensating increase in the level of quality and safety. Specifically, this request is for the pumps listed in this relief request. Revision Date: 1011212017 1 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-01 Water Leg Pump Flow Test (Rev. 0) (Page 2 of3) The primary purpose of the pumps listed in this request is to maintain the High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS), Reactor Core Isolation Cooling (RCIC), and Residual Heat Removal (RHR) pump discharge lines filled to limit the potential for water hammer upon associated pump initiation.

Once the supported pump (e.g., HPCS, RHR, etc.) is in operation, the associated water leg pump serves no further safety related function.

The amount of flow delivered by each water leg pump is dependent upon each supported system's leakage rate. Each water leg pump is capable of delivering approximately 50 gallons per minute (gpm). None of the listed water leg pumps have instrumentation installed in the discharge line for measuring flow rates. While flow measurement instrumentation is provided downstream of the water leg pump's branch connection to its associated support system, during power operation, the water leg pump is unable to generate sufficient pressure to flow through the associated flow element into the reactor vessel. Additionally, the flow measurement instrumentation associated with these lines, which is designed to measure flow developed by the HPCS (0-8000 gpm), LPCS (0-10,000 gpm), RHR (0-10,000 gpm), or RCIC (0-700 gpm), is not capable of measuring such small flows developed by the water leg pump (i.e., approximately 50 gpm). The application of temporary flow instrumentation (ultrasonic) cannot be utilized as there is not a run of piping long enough to allow for an accurate measurement.

System modifications to provide for test measuring locations for flow instrumentation places undue burden on the licensee without demonstrating any increase in the level of plant safety. These pumps are in continuous operation and pump performance is continuously monitored by a low-pressure alarm on each HPCS, LPCS, RHR, and RCIC pump discharge header. 5. Proposed Alternative and Basis for Use LSCS will continue to monitor the subject pumps for degradation by measuring and recording pump inlet pressure, discharge pressure (from which differential pressure is calculated), and vibration.

These measurements are taken quarterly, during normal plant operation, when the supported system's pump is not in operation and RCS pressure is greater than the water leg pump's discharge pressure.

Measurement and trending of these parameters under these stated conditions will provide satisfactory indication of operational readiness as well as the ability to detect potential degradation.

In addition, the main emergency core cooling system (ECCS) pump headers, each has a low pressure sensor, which continuously monitors the operability of the respective water leg pump and alarms upon reaching its low set-point.

The LSCS Technical Specification (TS) surveillance requirements (i.e., TS 3.5.1.1, TS 3.5.2.3, and TS 3.5.3.1) also verify operability of the water leg pumps by verifying flow through a high point vent on a monthly basis. Revision Date: 1011212017 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-01 (Rev. 0) (Page 3 of3) Vibration measurements will continue to be obtained under normal operating conditions and evaluated in accordance with ISTB-512l(d) and ISTB-512l(e).

The differential pressure across the pump will also continue to be determined quarterly through plant procedures utilizing each pump's minimum flow line in accordance with ISTB-512l(c) and ISTB-512l(e).

Differential Pressure and vibration will continue to be trended. Vibration data will be indicative of levels trending toward unacceptable values and should allow time for LSCS to take adequate corrective actions before the pumps fail. In addition, LSCS verifies operability of these pumps through the continuous monitoring of the HPCS, LPCS, RHR, and RCIC pump discharge line pressures that are monitored in the control room by alarm. 6. Duration of Proposed Alternative 4th IST Interval, beginning October 12, 2017, through October 11, 2027 7. Precedents This relief request was previously approved for the third ten-year interval at LSCS Units 1 and 2 via Relief Request RP-01, as documented in the Safety Evaluation dated September 26, 2007 (ML072620373).

8. Approval This relief request was approved for the fourth ten-year interval at LSCS Units 1 and 2 via Relief Request RP-01, as documented in the Safety Evaluation dated February 22, 2017 (ML17024A265).

Revision Date: 1011212017 3 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-02 Water Leg Pump Comprehensive Test (Rev. 0) (Page 1of4) Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Hardship without Compensating Increase in Level of Quality or Safety 1. ASME Code Component(s)

Affected Pump Description Class Category 1E22-C003 HPCS Water Leg Pump 2 Group A 1E21-C002 LPCS Water Leg Pump 2 Group A 1E12-C003 RHR Water Leg Pump 2 Group A 1E51-C003 RCIC Water Leg Pump 2 Group A 2E22-C003 HPCS Water Leg Pump 2 Group A 2E21-C002 LPCS Water Leg Pump 2 Group A 2E12-C003 RHR Water Leg Pump 2 Group A 2E51-C003 RCIC Water Leg Pump 2 Group A 2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda 3. Applicable Code Requirement Unit 1 1 1 1 2 2 2 2 ISTB-3000, General Testing Requirements; Table ISTB-3000-1, Inservice Test Parameters, specifies the parameters to be measured during inservice testing (i.e., Flow Rate, Q). ISTB-3510, General, (a) Accuracy, states, in part, "Instrument accuracy shall be within the limits of Table ISTB-3510-1.

... " Table ISTB-3510-1, Required Instrument Accuracy, specifies the required instrument accuracies for the Comprehensive and Preservice Tests (% ), for various test parameters (i.e., Y2% for differential pressure).

ISTB-3300, Reference Values, paragraph (e) states, "Reference values shall be established in a region(s) ofrelatively stable pump flow." Subparagraph (e)(l) states, "Reference values shall be established within +/-20% of pump design flow rate for the comprehensive test." ISTB-5123, Comprehensive Test Procedure, paragraph (e) states, in part, "All deviations from the reference values shall be compared with the ranges of Table ISTB-5121-1..." Revision Date: 1011212017 4 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request

• RP-02 Water Leg Pump Comprehensive Test (Rev. 0) (Page 2 of 4) Table ISTB-5121-1, Centrifugal Pump Test Acceptance Criteria, specifies the centrifugal pump test acceptance criteria (e.g., acceptable, alert and required action ranges) for the various pump test parameters (i.e., flow rate, differential pressure and vibration) during the comprehensive pump test. 4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (z)(2), an alternative is proposed to the following requirements as defined in the ASME OM Code: 1) To measure flow, 2) for the instrument accuracy required in comprehensive tests, 3) to test within +/-20% of the pump design flow for comprehensive tests, and 4) the comprehensive pump test acceptance criteria.

The basis of the request is that these requirements present a hardship without a compensating increase in the level of quality and safety. Specifically, this request is for the pumps listed in this relief request. The primary purpose of the pumps listed in this request is to maintain the High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS), Reactor Core Isolation Cooling (RCIC), and Residual Heat Removal (RHR) pump discharge lines filled to limit the potential for water hammer upon associated pump initiation.

Once the supported pump (e.g., HPCS, RHR, etc.) is in operation, the associated water leg pump serves no further safety related function.

The amount of flow delivered by each water leg pump is dependent upon each supported system's leakage rate. Each water leg pump is capable of delivering approximately 50 gallons per minute (gpm). None of the listed water leg pumps have instrumentation installed in the discharge line for measuring flow rates. While flow measurement instrumentation is provided downstream of the water leg pump's branch connection to its associated support system, during power operation, the water leg pump is unable to generate sufficient pressure to flow through the associated flow element into the reactor vessel. Additionally, the flow measurement instrumentation associated with these lines, which is designed to measure flow developed by the HPCS (0-8000 gpm), LPCS (0-10,000 gpm), RHR (0-10,000 gpm), or RCIC (0-700 gpm), is not capable of measuring such small flows developed by a water leg pump (i.e., approximately 50 gpm). The application of temporary flow instrumentation (ultrasonic) cannot be utilized, as there is not a run of piping long enough to allow for an accurate measurement.

System modifications to provide for test measuring locations for flow instrumentation places undue burden on LSCS without demonstrating any increase in the level of plant safety. These pumps are in continuous operation and pump performance is continuously monitored by a low-pressure alarm on each HPCS, LPCS, RHR, and RCIC pump discharge header. Quarterly Group A testing, as modified by LSCS pump relief request RR-RP-01, will continue to be performed during the stipulated conditions that: 1) the RCS pressure is greater than the Revision Date: 1011212017 5 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-02 Water Leg Pump Comprehensive Test (Rev. 0) (Page 3 of 4) discharge pressure of the associated water leg pump, and 2) the supported system pump is not in operation during the testing of the associated water leg pump. Comprehensive pump testing requires that the pump parameters be measured while the pump is operating at a flow rate within 20% of the pumps design flow. These water leg pumps operate in a "keep ready" mode, maintaining the support system piping pressurized with water, which is dependent upon each individual system's leakage rate. The remaining differences between the comprehensive pump testing and Group A testing is the accuracy of the instruments used in measuring the differential pressure (Table ISTB-3510-1, 2% versus Yi%) as well as the acceptance criteria associated with the pump's differential pressure (Table ISTB-5121-1, 0.90 to 0.90 to with 0.93% alert limit). These water leg pumps are tested quarterly by isolating them from their support system piping and measuring their pressure and vibration parameters as they pump system fluid through a minimum flow orifice in the minimum flow line. As there is no flow measurement taken as a result of the system configuration, variation of the system resistance is not used. The utilization of more accurate test instrumentation and acceptance criteria under these conditions would result in a hardship without a compensating increase in the level of quality and safety. 5. Proposed Alternative and Basis for Use LSCS will continue to monitor the subject pumps for degradation by measuring and recording pump inlet pressure, discharge pressure, (from which differential pressure is calculated), and vibration.

The differential pressure and vibration data will be trended as directed by ISTB-5121, Group A Test Procedure, as amended by Relief Request RP-01. These measurements are taken quarterly, during normal plant operation, when the supported system's pump is not in operation and RCS pressure is greater than the water leg pump's discharge pressure.

Measurement and trending of these parameters under these stated conditions will provide satisfactory indication of operational readiness as well as the ability to detect potential degradation.

In addition, the main emergency core cooling system (ECCS) pump headers each have a low pressure sensor, which continuously monitors the operability of the respective water leg pump and alarms upon reaching its low set-point.

The LSCS Technical Specification (TS) surveillance requirements (i.e., TS 3.5.1.1, TS 3.5.2.3, and TS 3.5.3.1) also verify operability of the water leg pumps by verifying flow through a high point vent on a monthly basis. Vibration measurements will continue to be obtained under normal operating conditions and evaluated in accordance with ISTB-512l(d) and ISTB-512l(e), Group A testing. The differential pressure across the pump will also continue to be determined quarterly through plant procedures utilizing each pump's minimum flow line in accordance with ISTB-512l(c) and ISTB-5121(e).

Revision Date: 1011212017 6 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request

• RP-02 Water Leg Pump Comprehensive Test (Rev. 0) (Page 4 of 4) Differential Pressure and vibration will continue to be trended. In addition, LSCS verifies operability of these pumps through the continuous monitoring of the HPCS, LPCS, RHR, and RCIC pump discharge line pressures that are monitored in the control room by alarm. In conclusion, on the basis that complying with the specified requirements would result in undue hardship without a compensating increase in the level of quality and safety, and the proposed alternative continues to provide reasonable assurance of operational readiness of the water leg pumps, LSCS requests approval of the proposed alternative pursuant to 10 CFR 50.55a (z)(2). 6. Duration of Proposed Alternative 4th IST Interval, beginning October 12, 2017, and ending October 11, 2027 7. Precedent This relief request was previously approved for the third ten-year interval at LSCS Units 1 and 2 via Relief Request RP-02, as documented in the Safety Evaluation dated May 7, 2008 (ML080930122).

8. Approval This relief request was approved for the fourth ten-year interval at LSCS Units 1 and 2 via Relief Request RP-02, as documented in the Safety Evaluation dated February 22, 2017 (MLl 7047 A586). Revision Date: 1011212017 7 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request

• RP-03 Code Case OMN-21 (Rev. 0) (Page 1of4) Proposed Alternative in Accordance with 10 CFR 50.55a(z)(l)

1. ASME Code Component(s)

Affected Pump Description Pump Type Class Category ODGOIP Diesel Generator Centrifugal 3 Group A IDGOIP Cooling Water Pumps 2DGOIP 1FC03PA Fuel Pool Emergency Centrifugal 3 Group B 1FC03PB Make-Up Pumps 2FC03PA 2FC03PB 1E22-C001 High Pressure Core Vertical Line Shaft 2 GroupB 2E22-C001 Spray (HPCS) Pumps Centrifugal 1E22-C002 HPCS Diesel Generator Centrifugal 3 Group A 2E22-C002 Cooling Water Pumps 1E21-C001 Low Pressure Core Vertical Line Shaft 2 GroupB 2E21-C001 Spray Pumps Centrifugal 1E12-C002A Residual Heat Removal Vertical Line Shaft 2 Group A 1E12-C002B (RHR) Pumps Centrifugal 2E12-C002A 2E12-C002B 1E12-C002C RHR (LPCI) Pumps Vertical Line Shaft 2 Group B 2E12-C002C Centrifugal 1E12-C300A RHR Service Water Centrifugal 3 Group A 1E12-C300B Pumps 1El2-C300C 1E12-C300D 2E12-C300A

2E12-C300B 2E12-C300C 2E12-C300D 1E51-C001 Reactor Core Isolation Centrifugal 2 Group B 2E51-C001 Cooling Pumps Revision Date: 1011212017 8 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Pump Relief Request -RP-03 Code Case OMN-21 (Rev. 0) (Page 2 of 4) 2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda 3. Applicable Code Requirement ISTB-5121, Group A Test Procedure, paragraph ISTB-5121(b) states, in part, that "The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point. .. " ISTB-5122, Group B Test Procedure, paragraph ISTB-5122(c) states, "System resistance may be varied as necessary to achieve the reference point." ISTB-5123, Comprehensive Test Procedure, paragraph ISTB-5123(b) states, in part, that "The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point." ISTB-5221, Group A Test Procedure, paragraph ISTB-522l(b) states, in part, that "The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point." ISTB-5222, Group B Test Procedure, paragraph ISTB-5222( c) states "System resistance may be varied as necessary to achieve the reference point." ISTB-5223, Comprehensive Test Procedure, paragraph ISTB-5123(b) states, in part, that "The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point. .. " 4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (z)(l), an alternative is proposed to the pump testing reference value requirements of the ASME OM Code. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for all inservice testing of IST Program pumps for LSCS, Units 1 and 2, as listed in this request. Revision Date: 1011212017 9 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request

• RP-03 Code Case OMN-21 (Rev. 0) (Page 3 of 4) For pump testing, there is difficulty adjusting system throttle valves with sufficient precision to achieve exact flow reference values during subsequent IST tests. Section ISTB of the ASME OM Code does not allow for variance from a fixed reference value for pump testing. However, NUREG-1482, Revision 2, Section 5.3, acknowledges that certain pump system designs do not allow for the licensee to set the flow at an exact value because of limitations in the instruments and controls for maintaining steady flow. ASME OM Code Case OMN-21, "Alternative Requirements for Adjusting Hydraulic Parameters to Specified Reference Points," provides guidance for adjusting reference flow or differential pressure to within a specified tolerance during pump inservice testing. The Code Case states that: "It is the opinion of the Committee that when it is impractical to operate a pump at a specified reference point and adjust the resistance of the system to a specified reference point for either flow rate, differential pressure or discharge pressure, the pump may be operated as close as practical to the specified reference point with the following requirements.

The Owner shall adjust the system resistance to as close as practical to the specified reference point where the variance from the reference point does not exceed + 2% or -1 % of the reference point when the reference point is flow rate, or+ 1 % or -2% of the reference point when the reference point is differential pressure or discharge pressure." The NRC also discusses this ASME Code change in NUREG-1482, Revision 2, Section 5.3. 5. Proposed Alternative and Basis for Use LSCS seeks to perform future inservice pump testing in a manner consistent with the requirements as stated in ASME OM Code Case OMN-21. Specifically, testing of the pumps identified in this request will be performed such that the flow rate is adjusted as close as practical to the reference value and within proceduralized limits of +2% I -1 % of the reference flow rate or alternatively the differential pressure or discharge pressure is adjusted as close as practical to the reference value and within proceduralized limits of+ 1 % I -2% of the reference pressure or differential pressure.

LSCS plant operators will continue to strive to achieve the exact test reference values (flow or differential pressure) during testing. Typical test guidance will be to adjust the reference parameter (i.e., flow or differential pressure) to the specific reference value with additional guidance that if the reference value cannot be achieved with reasonable effort the test will be considered valid if the steady state flow rate is Revision Date: 1011212017 10 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request

• RP-03 Code Case OMN-21 (Rev. 0) (Page4 of 4) within the proceduralized limits of +2% I -1 % of the reference value or the steady state pressure or differential pressure is within the proceduralized limits of + 1 % I -2% of the reference value. Using the provisions of this request as an alternative to the specific requirements of ISTB-5121, ISTB-5122, ISTB-5123, ISTB-5221, ISTB-5222, and ISTB-5223 as described above, will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Based on the determination that the use of controlled reference value ranges provides an acceptable level of quality and safety, this proposed alternative is being requested pursuant to 10 CPR 50.55a(z)(l).

6. Duration of Proposed Alternative 4th IST Interval, beginning October 12, 2017, through October 11, 2027 7. Precedents

• Callaway Plant, Unit 1 -Relief Request PR-06, Alternative to ASME OM Code Requirements for IST for the Fomth Program Interval Safety Evaluation dated July 15, 2014 (ML14178A769)

• Wolf Creek Generating Station-Request for Relief 4PR-01 for the Fourth 10-Year Inservice Testing Program Interval-Safety Evaluation dated May 15, 2015 (ML15134A002)

8. Approval This relief request was approved for the fourth ten-year interval at LSCS Units 1 and 2 via Relief Request RP-03, as documented in the Safety Evaluation dated February 22, 2017 (MLl 7047 A586). Revision Date: 1011212017 11 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-04 Code Case OMN-19 (Rev. 0) (Page 1of4) Proposed Alternative in Accordance with 10 CFR 50.55a(z)(l)

1. ASME Code Component(s)

Affected Refer to Table RR-RP-04 2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda 3. Applicable Code Requirement ISTB-5123, Comprehensive Test Procedure, paragraph ISTB-5123(e), refers to Table ISTB-5121-1, Centrifugal Pump Test Acceptance Criteria, which specifies a multiplier of 1.03 times the established reference value for the measured hydraulic value of differential pressure or flow rate for the upper limits for "Acceptable Range" and "Required Action Range, High" criteria for the comprehensive pump test (CPT). ISTB-5223, Comprehensive Test Procedure, paragraph ISTB-5223(e), refers to Table ISTB-5221-1, Vertical Line Shaft Centrifugal Pump Test Acceptance Criteria, which specifies a multiplier of 1.03 times the reference value for the measured hydraulic value of differential pressure or flow rate for the upper limits for "Acceptable Range" and "Required Action Range, High" criteria for the CPT. 4. Reason for Request Pursuant to 10 CPR 50.55a, "Codes and standards," paragraph (z)(l), an alternative is proposed to the requirement for a multiplier of 1.03 times the reference value for the CPT' s upper "Acceptable Range" and "Required Action Range, High" criteria, referenced in Tables ISTB-5121-1 and ISTB-5221-1.

The proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for all inservice testing of IST Program pumps as listed in attached Table RR-PR-04, IST Program Pumps Affected by Alternative Request RR-RP-04.

Occasionally, LSCS has had some difficulty with implementing the high required action range limit of 1.03 above the established hydraulic parameter reference value due to normal data scatter. This could result in the plant entering (or remaining in) an applicable Technical Specification (TS) Limiting Condition for Operation (LCO) for reasons other than a pump degradation issue. Revision Date: 1011212017 12 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-04 Code Case OMN-19 (Rev. 0) (Page 2 of 4) Based on the similar difficulties experienced by other Owners, ASME OM Code Case (CC) OMN-19, Alternative Upper Limit for the Comprehensive Pump Test, was developed and has been published in the 2011 Addenda of the ASME OM Code. The ASME white paper for this code case discussed the impact of instrument inaccuracies, human factors involved with setting and measuring test parameters, readability of gauges, and other miscellaneous factors on the ability to meet the 1.03 acceptance criteria.

Industry operating experience is also discussed in this white paper. CC OMN-19 has not yet been approved for use in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code. 5. Proposed Alternative and Basis for Use LSCS proposes to use ASME OM CC OMN-19 as published in the 2011 Addenda of the ASME OM Code for the fourth ten-year interval IST Program. CC OMN-19 allows for the use of a multiplier of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's (CPT's) upper "Acceptable Range" criteria and "Required Action Range High" criteria referenced in the applicable test acceptance criteria tables ISTB-5121-1 and ISTB-5221-1.

The bases for the approval of CC OMN-19, as discussed in the ASME white paper, are summarized below: 1. Instrument inaccuracies of measured hydraulic values 2. Instrument inaccuracies of set value and its effect on measured value 3. Instrument inaccuracies and allowed tolerance for speed 4. Human factors involved with setting and measuring flow, DIP, and speed 5. Readability of gauges based on the smallest gauge increment, and 6. Miscellaneous factors The inaccuracies summarized above associated with obtaining the CPT hydraulic data may cause the measured value to exceed the existing Code-allowed CPT upper "Acceptable Range" criteria and/or the "Required Action Range, High" criteria of 103% (i.e., 1.03 multiplier).

The new upper limit of 106% (i.e., 1.06 multiplier), as approved in CC OMN-19, will eliminate declaring the pump inoperable and entering an unplanned TS LCO, or will eliminate the extension of an existing LCO. As a condition for using CC OMN-19, LSCS will implement a pump periodic verification test (PPVT) program to verify that a pump can meet the required differential (or discharge) pressure, as applicable, at its highest design basis accident Revision Date: 1011212017 13 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Pump Relief Request -RP-04 Code Case OMN-19 (Rev. 0) (Page 3 of 4) flow, as discussed in ASME Mandatory Appendix V, which was published in the 2012 Edition of the ASME OM Code. LSCS will not be required to perform a PPVT if the design basis accident flow rate in the LSCS safety analysis is bounded by the CPT or Group A test. Also, if the pump does not have a design basis accident flow rate, then a PPVT is not required.

Therefore, any IST pump that utilizes the 1.06 multiplier for the CPT will meet the condition described above. Using the upper limit of 1.06 times the reference value in lieu of the 1.03 multiplier for the CPT' s upper "Acceptable Range" and "Required Action Range, High" criteria referenced in the applicable ISTB test acceptance criteria tables will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Using the provisions of this request as an alternative to the specific requirements of tables ISTB-5121-1 and ISTB-5221-1, as described above, will continue to provide an acceptable level of quality and safety. Therefore, this proposed alternative is requested pursuant to 10 CPR 50.55a(z)(l).

6. Duration of Proposed Alternative 4th IST Interval, beginning October 12, 2017, through October 11, 2027 7. Precedents

• Cooper Nuclear Station Requests for Relief [RP-08], and Alternatives to ASME OM Code Requirements for Inservice Testing for the Fifth 10-Year Program Interval, dated February 12, 2016 (ML16014A174)

• Columbia Generating Station -Requests for Relief ... RP06, ... for the Fourth 10-Y ear Inservice Testing Interval, dated December 9, 2014 (ML14337A449) and Correction to Safety Evaluation Pages, dated February 9, 2015 (ML15030A232)

8. References

• ASME OM Code Case OMN-19, Alternative Upper Limit for the Comprehensive Pump Test

• RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 1, dated August 2014 (ML13340A034)

• ASME OM Code, 2012 Edition, Division 1, Mandatory Appendix V, Pump Periodic Verification Test Program, issued April 6, 2013 Revision Date: 1011212017 14 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth interval Pump Relief Request -RP-04 Code Case OMN-19 (Rev. 0) (Page 4 of 4)

• White Paper for ISTB Code Change, [Standards Committee Ballot 09-610, Record 09-657] Change C, A relaxation of the high required action range for the Comprehensive Pump Test Hydraulic Parameters ( 1.03 to 1.06), dated December 2007 9. Approval This relief request was approved for the fourth ten-year interval at LSCS Units 1 and 2 via Relief Request RP-04, as documented in the Safety Evaluation dated February 22, 2017 (MLl 7024A265).

Revision Date: 1011212017 15 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Table RR-RP-04, IST Program Pumps Affected by Alternative Request RR-RP-04 Pump UNID Description Pump Code ASME Design IST Pump (Units 1 & 2) Type Class OM Code Basis Comp. Periodic Category Accident Pump Verification Flow Test Test Rate Flow (PPVT) (gpm) Rate Required (gpm) (Yes/No) ODGOIP Diesel Centrifugal 3 Group A 1489 1775 No Generator Cooling Water Pumps lDGOlP Diesel Centrifugal 3 Group A 1053 1205 No Generator Cooling Water Pumps 2DG01P Diesel Centrifugal 3 Group A 1053 1190 No Generator Cooling Water Pumps 1FC03PA Fuel Pool Centrifugal 3 Group B 300 300 No 1FC03PB Emergency 2FC03PA Make-Up 2FC03PB Pumps 1E22-C001 High Vertical 2 Group B 6250 6300 No Pressure Line Shaft Core Spray Centrifugal (HPCS) Pumps 2E22-C001 High Vertical 2 Group B 6200 6200 No Pressure Line Shaft Core Spray Centrifugal (HPCS) Pumps 1E22-C002 HPCS Diesel Centrifugal 3 Group A 993 1010 No 2E22-C002 Generator Cooling Water Pumps Revision Date: 1011212017 16 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Table RR-RP-04, IST Program Pumps Affected by Alternative Request RR-RP-04 (Continued)

PumpUNID Description Pump Code ASME Design IST Pump (Units 1 & 2) Type Class OM Code Basis Comp. Periodic Category Accident Pump Verification Flow Test Test Rate Flow (PPVT) (gpm) Rate Required (gpm) (Yes/No) 1E21-C001 Low Pressure Vertical 2 Group B 6350 6350 No 2E21-C001 Core Spray Line Shaft Pumps Centrifugal 1E12-C002A Residual Vertical 2 Group A 7200 7200 No 1El2-C002B Heat Line Shaft 2El2-C002A Removal Centrifugal 2El2-C002B (RHR) Pumps 1E12-C002C RHR (LPCI) Vertical 2 Group B 7200 7200 No 2El2-C002C Pumps Line Shaft Centrifugal 1El2-C300A RHR Service Centrifugal 3 Group A 4185 4000 Yes 1El2-C300B Water Pumps 1El2-C300C 1El2-C300D 2El2-C300A 2E12-C300B 2E12-C300C 2E12-C300D 1E51-C001 Reactor Core Centrifugal 2 Group B 625 600* No 2E51-C001 Isolation Cooling Pumps * -The IST measured value of 600 gpm for the RCIC pumps is taken downstream of the unmeasured

(-25 gpm) flow to the RCIC lube oil cooler. The design requirement of 625 gpm includes that unmeasured value. Therefore, the test confirms that the 600 gpm that is the measured flow to the reactor is the maximum required flow after the pump has also provided the additional flow to the RCIC lube oil cooler. No additional Pump Periodic Verification Test is required for the RCIC pumps. Revision Date: 1011212017 17 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval ATTACHMENT 4 VALVE RELIEF REQUEST INDEX Designator Description Revision RV-01 Motor Operated Valves Rev.O Revision Date: 1011212017 18 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 5 VALVE RELIEF REQUESTS Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 1of8) Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety 1. ASME Code Component(s)

Affected All active ASME Class 1, 2, and 3 Motor Operated Valves (MOVs) scoped into the LSCS Inservice Testing (IST) Program subject to diagnostic testing per Generic Letter (GL) 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Operated Valves," and cannot be classified as Skid Mounted. Station Inservice Testing Program subject to diagnostic testing per Generic Letter (GL) 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Power-Operated Valves," and can not be classified as Skid Mounted. 2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda 3. Applicable Code Requirement ISTC-3100, Preservice Testing, paragraph (a) states "Any valve that has undergone maintenance that could affect its performance after the preservice test shall be tested in accordance with ISTC-3310." ISTC-3310, Effects of Valve Repair, Replacement, or Maintenance on Reference Values, states, in part, "When a valve or its control system has been replaced, repaired, or has undergone maintenance

... that could affect the valve's performance, a new reference value shall be determined or the previous value reconfirmed by an inservice test. .. " ISTC-3510, Exercising Test Frequency, states, in part, that "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months ... " ISTC-3520, Exercise Testing, ISTC-3521, Category A and Category B Valves, specifies that Category A and Category B valves shall be tested as provided in subparagraphs (a) through (h). ISTC-3521(a) through (h) specify that Category A and B MOVs shall be full-stroke exercised during operation at power to the position(s) required to fulfill its functions(s);

the MOVs shall be exercised during cold shutdowns if it is not practicable to exercise the valves at power; or that the MOV s shall be exercised during refueling outages if it is not practicable to exercise the valves during cold shutdowns.

Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Valve Relief Request -RV -01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 2 ofS) ISTC-3700, Position Verification Testing, states, in part, that "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated." ISTC-5120, Motor-Operated Valves, in paragraphs ISTC-5121, Valve Stroke Testing, ISTC-5122, Stroke Test Acceptance Criteria, and ISTC-5123, Stroke Test Corrective Action, specifies requirements for stroke time testing MOV s when exercised in accordance with ISTC-3510.

Code Case (CC) OMN-1, Section 3.3, Inservice Test, paragraph (b), states, in part, that "Inservice tests shall be conducted in the as-found condition." CC OMN-1, Section 3.4, Effect of MOV Replacement, Repair, or Maintenance, states, in part, that "Deviations between the previous and new inservice test values shall be identified and analyzed." CC OMN-1, Section 6.3, Evaluation of Data, states, in part, that "Evaluations shall determine the amount of degradation in functional margin that occurred over time." CC OMN-1, Section 6.4, Determination of MOV Functional Margin, requires testing or analytical methods to ensure adequate margin exists between valve-operating requirements and the available actuator output capability to satisfy the acceptance criteria for MOV operational readiness. (only requested for the Quarter-Turn MOVs specified,)

4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (z)(l), an alternative is proposed to the requirement to perform quarterly stroke time testing (ISTC-5120) and biennial position verification testing (ISTC-3700) as defined in the ASME OM Code. An additional alternative is proposed to the CC OMN-1 requirements in: 1) Section 3 .3(b) for testing in the as-found condition, 2) Section 3.4 to analyze deviations between previous and new inservice tests, 3) Section 6.3 to determine the amount of degradation in functional margin over time, and 4) Section 6.4 to determine the MOV functional margin for the specified quarter-turn valves. The basis of the request is that the alternative testing would provide an acceptable level of quality and safety. Specifically, this request is for all active ASME Class 1, 2, and 3 MOVs scoped into the LSCS IST Program subject to diagnostic testing per GL 96-05, and cannot be classified as Skid Mounted. Revision Date: 1011212017 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 3of8) 5. Proposed Alternative and Basis for Use 10 CFR 50.55a(a) states, in part, that Regulatory Guide (RG) 1.192, Revision 1, "Operating and Maintenance Code Case Acceptability, ASME OM Code," dated August 2014, has been approved for incorporation by reference by the Director of the Federal Register pursuant to 5 U.S.C. 552(a) and 1 CFR part 51. In RG 1.192, it states within Table 2, "Conditionally Acceptable OM Code Cases," that the alternative rules of ASME CC OMN-1, Alternative Rules for Preservice and Inservice Testing of Active Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants, 2006 Addenda, when applied in conjunction with the provisions for leakage rate testing in ISTC-3600, may be applied with the following provisions: ( 1) The adequacy of the diagnostic test interval for each MOV must be evaluated and adjusted as necessary, but not later than 5 years or three refueling outages (whichever is longer) from initial implementation of OMN-1. (2) When extending exercise test intervals for high risk MOVs beyond a quarterly frequency, licensees must ensure that the potential increase in core damage frequency (CDF) and risk associated with the extension is small and consistent with the intent of the Commission's Safety Goal Policy Statement.

When applying risk insights as part of the implementation of OMN-1, licensees must categorize MOV s according to their safety significance using the methodology described in Code Case OMN-3, "Requirements for Safety Significance Categorization of Components Using Risk Insights for Inservice Testing of LWR Power Plants," with the conditions discussed in RG 1.192 or use other MOV risk ranking methodologies accepted by the NRC on a plant-specific or industry-wide basis with the conditions in the applicable safety evaluations.

This conditional acceptance of CC OMN-1, per RG 1.192 is applicable in lieu of the provisions for stroke-time testing in subsection ISTC of the 1995 Edition up to and including the 2006 Addenda of the ASME OM Code. Compliance with RG 1.192 Conditions LSCS proposes to use the requirements of CC OMN-1 for MOV stroke time and position verification testing. The LSCS MOV testing program was developed utilizing GL 89-10, "Safety Related Motor Operated Valve Testing and Surveillance," and GL 96-05. The continued implementation of CC OMN-1 will continue to reconcile and consolidate testing within the IST program and eliminate unnecessary testing that provides minimal information about MOV operational readiness.

Revision Date: 1011212017 3 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 4of8) As part of the LSCS commitment on MOV Periodic Verification Testing made in response to GL 96-05, LSCS is participating in the Joint Owners' Group (JOG) Program for MOV Periodic Verification.

The JOG Program is described in Topical Report (TR) MPR-1807, Revision 2, and was accepted by the NRC in an October 1997 safety evaluation (SE) as an industry-wide response to GL 96-05 with certain conditions and limitations.

LSCS implementation and compliance with the above-identified provisions (Items 1, 2, and 3) of CC OMN-1 are detailed below: 1. LSCS MOV testing frequencies identified in the IST program do not exceed three refueling cycles (i.e., a nominal 6 years). Therefore, the expectation that the frequency of testing be evaluated and adjusted within five years or three refueling outages, whichever is longer, of CC OMN-1 implementation will be satisfied.

2. LSCS will exercise medium and low safety significance MOVs at least once every refueling cycle as required in CC OMN-1, Section 3.6.1. Initially, LSCS committed to continue to test high risk MOVs quarterly (where it is not practicable to exercise a valve during plant operations, the valve will be exercised in cold shutdown or refueling outages per CC OMN-1, Section 3.6.3). When extending the exercise test frequency intervals for high risk MOV s beyond a quarterly frequency, LSCS shall ensure that any potential increase in the CDF and risk associated with the extension is small and consistent with the intent of the Commissions Safety Goal Policy Statement.

Upon extension of these frequencies, the IST Program will be appropriately revised. 3. LSCS has performed differential pressure testing practicability reviews for GL 89-10 that evaluated the benefits of performing a particular test against the potential adverse effects placed on valves or systems caused by this testing. The evaluation included an assessment of potential component (valve or pump) damage or system availability concerns that may outweigh the benefits of dynamic testing for some MOVs. As a result, some MOVs are not subject to differential pressure testing, but are justified for design basis performance by analysis.

This alternate methodology to meet the condition specified in RG 1.192 has been previously accepted by the NRC in their approval of LSCS's CC OMN-1 Relief Request RV-02 for the third interval on September 26, 2007. Alternatives to CC OMN-1 With LSCS compliance with the above provisions as stipulated in RG 1.192, LSCS requests relief from the following OMN-1 sections and proposes the following alternatives.

• OMN-1, Section 3.3, Inservice Test, paragraph (b), requires inservice testing to be conducted in the as-found condition.

Revision Date: 1011212017 4 IST-LAS-PLAN JST Program Plan LaSalle County Station Units I & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 5 of8)

• OMN-1, Section 3.4, Effect of MOV Replacement, Repair, or Maintenance, requires deviations between the previous and new inservice tests values shall be identified and analyzed.

• OMN-1, Section 6.3, Evaluation of Data, requires evaluations to determine the amount of degradation in functional margin that occurred over time.

• OMN-1, Section 6.4, Determination of MOV Functional Margin, for the quarter-tum valves specified.

LSCS Alternative to CC OMN-1, Section 3.3(b) LSCS proposes not to perform as-found testing in all situations.

Not performing as-found testing is justified by the manner in which LSCS determines MOV functional margin and test interval.

Unlike the example for determining test interval given in CC OMN-1, Section 6.4.4, LSCS uses a process, which is less dependent on as-found testing. When pre-service testing is performed, a degradation factor is applied to extrapolate the appropriate test frequency based upon a calculated decline in functional margin over time. Random selections of valves are as-found tested and test results are used to validate degradation assumptions per JOG guidelines.

This sample as-found testing is applied to computational methods to ensure that the functional margin is adequate over the testing interval.

Therefore, LSCS requests relief from the requirement of CC OMN-1 Section 3.3(b) for always performing as-found testing. LSCS Alternative to CC OMN-1, Section 3.4 Section 3.4 requires identifying and analyzing deviations between previous and new test values. As described above, LCSC uses a process that is less dependent on as-found testing. Specifically, as-found testing is applied to computational methods to ensure that the functional margin is adequate over the testing interval.

Therefore, a specific analysis addressing the deviations between the previous and new tests is not required.

Therefore, LSCS requests relief from the requirement of CC OMN-1 Section 3.4 for always identifying and analyzing deviations between previous and new test values. LSCS Alternative to CC OMN-1, Section 6.3 Section 6.3 requires performing evaluations to determine the amount of degradation in functional margin over time. When pre-service testing is performed, a degradation factor is applied to extrapolate the appropriate test frequency based upon a calculated decline in functional margin over time. Random selections of valves are as-found tested and test results are used to validate degradation assumptions per JOG guidelines.

This sample as-found testing is applied to computational methods to ensure that the functional margin is adequate over the testing interval.

Therefore, LSCS requests relief from the requirement of CC OMN-1 Section 6.3 for performing evaluations to determine the amount of degradation in functional margin over time. LSCS Alternative to CC OMN-1, Section 6.4 Revision Date: 1011212017 5 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 6 of8) Section 6.4, Determination of MOV Functional Margin, requires, in part, that the Owner shall demonstrate that adequate margin exists between valve-operating requirements and the available actuator output capability to satisfy the acceptance criteria for MOV operational readiness.

LSCS has identified several quarter-tum MOV s that operate under low differential pressure conditions, such as air dampers and isolation valves. In closure of GL 89-10 at LSCS, these quai1er-and 6.3tum valves were accepted without diagnostic testing based on analytical methods. These valves operate under low differential pressure and have significant margin. These valves are as follows: 1(2)VG003 1(2)VG004 1(2)VQ037 1(2)VQ038 1(2)VP113A/B 1(2)VP114A/B Standby Gas Treatment Equipment Train Outlet Damper Standby Gas Treatment Equipment Train Inlet Damper Primary Containment Purge Air Filter Unit Upstream Isolation Valve Primary Containment Purge Air Filter Unit Downstream Isolation Valve Drywell Cooler Inlet Inboard Isolation Valve Drywell Cooler Outlet Inboard Isolation Valve These MOV s will continue to be stroke time and position verification tested in accordance with ASME OM Code subsection ISTC requirements.

These valves will also undergo actuator inspections and motor current signature traces from the motor control center to ensure proper operation.

The motor current signature traces provide the ability to detect degradation of the valve. These testing requirements will provide assurance that the valves will be capable of performing their safety functions.

Therefore, LSCS requests relief from the requirements of OMN-1 Section 6.4 for determination of the MOV functional margin for the quarter-tum MOV s identified above. Technical Positions The following positions describe how LSCS interprets and complies with the various CC OMN-1 requirements:

1. CC OMN-1, Section 3 .1, Design Basis Verification Test, allows the use of testing that was conducted prior to the implementation of CC OMN-1 if it meets the requirements of the code case. LSCS intends to utilize the testing performed under GL 89-10 to satisfy the requirement for a one-time test to verify the capacity of each MOV to meet its related design requirements.

2. CC OMN-1, Section 3.2, Preservice Test, requires that each MOV be tested during the preservice test period or before implementing inservice testing. LSCS intends to utilize the testing performed under GL 89-10 to satisfy the requirement.

LSCS will perform a new preservice test when an MOV undergoes maintenance or modification that could affect its performance.

3. CC OMN-1, Section 3.3, Inservice Test, paragraph (b), states, in part, that "Inservice tests shall be conducted in the as-found condition." Maintenance activities, such as stem lubrication, shall not be conducted if they might invalidate the inservice test results. At Revision Date: 1011212017 6 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Valve Relief Request -RV-01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 7of8) LSCS, the frequency of stem lubrication and periodic MOV verification testing differ considerably, and the times at which these activities are optimally performed do not coincide.

As part of the GL 96-05 program, as-found data has been collected for a sample population of MOV s under various lubrication conditions.

The results from this as-found data were used to create stem factor variability assumptions that are used to estimate the effect of stem lubrication on stem performance over the entire lubrication cycle. As described above, relief has been requested from CC OMN-1, Section 3.3(b) as it applies to inservice testing being conducted in the as-found condition.

With this relief, if testing were to occur directly following maintenance such as a stem lube, test results would not be invalidated as methods used to analyze the test results take into consideration testing under these circumstances.

Therefore, the intent of CC OMN-1, Section 3.3(b), that testing is performed under conditions that will not hinder the ability to determine applicable functional margins and determine operational readiness is maintained utilizing methods previously described.

4. CC OMN-1, Section 3.3(c) requires the IST Program to include a mix of static and dynamic MOV performance testing. LSCS will utilize the JOG program's mix of static and dynamic MOV performance testing to satisfy this requirement.

Additionally, LSCS will utilize the existing engineering standards, which are consistent with the JOG standards, to conduct evaluations to alter the mix of required MOV performance testing, when applicable, in order to meet this requirement.

5. CC OMN-1, Section 3.3.1, Inservice Test Interval, paragraph (b), requires MOV inservice testing to be conducted every two refueling cycles or three years (whichever is longer) until sufficient data exists, from an applicable MOV or MOV group, to justify a longer test interval.

LSCS has sufficient MOV testing data to justify its current testing frequencies, and therefore meets this requirement.

6. CC OMN-1, Section 6.4.4, Determination of MOV Test Interval, requires that calculations for determining MOV functional margin be evaluated to account for anticipated time related changes in performance (i.e., account for potential related degradation).

LSCS will utilize the JOG process for setting test frequencies, which is based on margin and safety significance to meet this requirement.

7. According to Table 2 of RG 1.192, the only testing that is described within ISTC that will need to continue to be performed with the adoption of CC OMN-1 is that of leakage testing as described by ISTC-3600.

Therefore, position verification testing as described in ISTC-3700 need not be performed per the frequency requirements of ISTC. However, LSCS will continue to perform position verification testing at a frequency consistent with JOG guidelines during MOV diagnostic testing. Revision Date: 1011212017 7 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Valve Relief Request -RV -01 Utilization of ASME Code Case OMN-1 (Rev. 0) (Page 8of8) 6. Duration of Proposed Alternative 4th IST Interval, beginning October 12, 2017, and ending October 11, 2027. 7. Precedents This relief request was previously approved for the third ten-year interval at LSCS Units 1 and 2 as Relief Request RV-02, as documented in the Safety Evaluation dated September 26, 2007 (ML072620373).

8. References

• Regulatory Guide 1.192, Operating and Maintenance Code Case Acceptability, ASME OM Code, Revision 1, dated August 2014

• Generic Letter 89-10, "Safety Related Motor Operated Valve Testing and Surveillance, dated June 28, 1989

• GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, dated September 18, 1996

• TR MPR-1807, Revision 2, Motor-Operated Valve Periodic Verification, dated July 1997

• NRC letter forwarding Safety Evaluation for JOG Program on MOV Periodic Verification described in JOG Topical Report MPR-1807 to respective Owners' Groups, dated October 30, 1997 9. Approval This relief request was approved for the fourth ten-year interval at LSCS Units 1 and 2 via Relief Request RV-01, as documented in the Safety Evaluation dated March 1, 2017 (MLl 7059C583).

Revision Date: 1011212017 8 IST-LAS-PLAN Cold Shutdown Justification No. CS-01 CS-02 CS-03 CS-04 CS-05 CS-06 CS-07 CS-08 CS-09 CS-10 CS-11 CS-12 CS-13 CS-14 CS-15 CS-16 CS-17 CS-18 CS-19 CS-20 CS-21 !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 6 COLD SHUTDOWN JUSTIFICATION INDEX Description Recirculation Flow Control Valves Reactor Water Cleanup Isolation Valves Inboard and Outboard MSIV s Drywell Instrument Valves IN Regulated Header Drywell Isolation Valves ADS N2 Supply to DW Isolation Valves Feedwater Check Valves Main Steam Relief Valve Vacuum Breakers Feedwater Outboard Testable Check Valves Shutdown Cooling Testable Check Valves SBLC System Injection Check Valves RCIC Turbine Exhaust Check Valves RCIC Injection Testable Check Valves ADS Accumulator Inlet Check Valves Reactor Recirc Loop Process Sampling Inbd Bypass Check Valve Inboard and Outboard Accumulator Check Valves HPCS, LPCS and RHR Injection Check Valves SRV Accumulator Inlet Check Valves Drywell Instrument Nitrogen TIP Indexer Purge Valves Drywell Cooler Inlet and Outlet Inboard Isolation Valves HCU Accumulator Charging Water Check Valves Revision Date: 1011212017 9 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 7 COLD SHUTDOWN .JUSTIFICATIONS Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown .Iustification

-CS-01 (Rev. 0) (Page 1of2) Valve Number System Class Category Unit 1B33-F338A RR 2 B 1 1B33-F338B RR 2 B 1 1B33-F340A RR 2 B 1 1B33-F340B RR 2 B 1 1B33-F342A RR 2 B 1 1B33-F342B RR 2 B 1 1B33-F344A RR 2 B 1 1B33-F344B RR 2 B 1 1B33-F339A RR 2 B 1 1B33-F339B RR 2 B 1 1B33-F341A RR 2 B 1 1B33-F341B RR 2 B 1 1B33-F343A RR 2 B 1 1B33-F343B RR 2 B 1 1B33-F345A RR 2 B 1 1B33-F345B RR 2 B 1 2B33-F338A RR 2 B 2 2B33-F338B RR 2 B 2 2B33-F340A RR 2 B 2 2B33-F340B RR 2 B 2 2B33-F342A RR 2 B 2 2B33-F342B RR 2 B 2 2B33-F344A RR 2 B 2 2B33-F344B RR 2 B 2 2B33-F339A RR 2 B 2 2B33-F339B RR 2 B 2 2B33-F341A RR 2 B 2 2B33-F341B RR 2 B 2 2B33-F343A RR 2 B 2 2B33-F345B RR 2 B 2 Function These valves are the inboard containment and outboard containment isolation for the Reactor Recirculation Pump hydraulic control lines. These valves are normally open during plant operation to allow hydraulic fluid from the flow control valve hydraulic power unit to position the reactor recirculation line flow control valve in response to electrical signals from the recirculation flow control system. These valves also have an automatic closure function (Group

2) to isolate primary containment to mitigate the consequences of an accident.

Revision Date: 1011212017 IST-LAS-PLAN J ustiflcation

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-01 (Rev. 0) (Page 2of2) It is impractical to full or part-stroke exercise these valves closed on a quarterly (nominal 92 days) basis during plant operation.

The reactor recirculation system provides forced circulation of water through the reactor core. The recirculation system in conjunction with the recirculation flow control system, provides a means of controlling reactor power over a limited range by adjusting the flow of coolant through the core. Between 65 -100% power, with the correct control rod pattern, a change in core flow will also result in a change in reactor power. Each reactor recirculation flow control valve is controlled by a remote hydraulic power unit (HPU) located outside primary containment.

The HPUs supply the high pressure fluid used to position the flow control valves. The individual hydraulic lines penetrate the primary containment and are each equipped with both an inboard and outboard isolation valve. Full-stroke closure testing of the subject valves to the closed position will cut off the hydraulic oil required to provide remote operating capability of the FCV. This could result in a loss of the ability of plant operators to appropriately respond to changing plant conditions that require the regulation of core flow and reactor power. Alternative Frequency These valves will be full-stroke exercised Closed during cold shutdown per ISTC-3521( c) and (f). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-01. Revision Date: 1011212017 2 IST-LAS-PLAN Valve Number 1G33-F001 1G33-F004 2G33-F001 2G33-F004 Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-02 (Rev.1) (Page 1of2) System RT RT RT RT Class 1 Category A 1 A 1 A 1 A Unit 1 1 2 2 These valves are the inboard containment and outboard containment isolation for the Reactor Water Clean Up System. These valves are have a function to be open during normal plant operation to provide a path for reactor coolant to flow to and from the reactor water cleanup system to maintain high water purity. This is not a safety function.

These valves have a safety function to close and limit leakage from the primary containment in the event of an accident.

1(2)G33-F001 and 1(2)G33-F004 automatically close as a result of a Group 5 isolation signal. 1(2)G33-F004 also automatically close as a result of a standby liquid control system actuation.

Justification These valves are tested per the requirements of OMN-1 as modified by LaSalle County Station Relief Request RV-01. Valves 1(2)G33-F001 are assigned a risk ranking of "Medium", whereas valves 1(2)G33-F004 are assigned a risk ranking of "High". A risk ranking of "High" corresponds to a quarterly test frequency.

It is impractical to full or part-stroke exercise these valves to the closed position on a quarterly (nominal 92 days) basis during plant operation.

As stated in section 5.4.8.2 of the UFSAR, the RWCU system continuously purifies reactor water. Closure of any of the subject valves would require that the entire RWCU system be shutdown.

Additionally, closure of either 1(2)G33-F001 or 1(2)G33-F004 during normal system operation will also automatically shutdown all of the cleanup recirculation pumps. This will cause an unnecessary thermal transient on the cleanup recirculation pumps and other system components possibly leading to their premature failure. Revision Date: 1011212017 3 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-02 (Rev. 1) (Page 2of2) System operation is generally maintained during power operation to maintain reactor water chemistry stable. As a condition of relief to implement Code Case OMN-1, LaSalle Station has committed to continue to exercise high risk MOVs quarterly (where practicable, otherwise in cold shutdown, or in refuel outages per OMN-1, Sections 3.6.3(b) and (c)). It is not practicable to full or part-stroke exercise the RWCU Isolation valves to the closed position nominally every 3 months per the requirements of OMN-1, Section 3.6.3(a) during normal plant operation.

Alternative Frequency These valves will be full-stroke exercised during cold shutdown per OMN-1 Section 3.6.3(b).

References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-02. Revision Date: 1011212017 4 IST-LAS-PLAN Valve Number 1B21-F022A 1B21-F022B 1B21-F022C 1B21-F022D 1B21-F028A 1B21-F028B 1B21-F028C 1B21-F028D 2B21-F022A 2B21-F022B 2B21-F022C

2B21-F022D 2B21-F028A 2B21-F028B 2B21-F028C 2B21-F028D Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-03 (Rev.1) (Page 1of2) System MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS Class 1 Category A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A 1 A Unit 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 These valves are the Main Steam inboard and outboard containment isolation valves. These valves are normally open and must be open to provide a steam flow path from the reactor, through the containment to the turbine and auxiliary loads to support plant operation.

This is not a safety related function.

The subject valves have a safety function to close on a Group 1 primary containment isolation signal (PCIS). Justification It is impractical to full stroke exercise or fail-safe test these valves to the closed position on a quarterly (nominal 92 days) basis during plant operation.

The MSIVs are partial stroked exercised on a quarterly basis in order to meet the MSIV scram functional test requirements identified in Technical Specification Requirement 3.3.1.1.9 and Technical Specification Table 3.3.1.1-1Item5.

Revision Date: 1011212017 5 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

• CS-03 (Rev.1) (Page 2of2) As identified in UFSAR section 5.4.5.4, the performance of a full-stroke exercise to the Closed position of individual MSN s can be performed during power operation if reactor power is reduced sufficiently to avoid a scram as a result of reactor overpressure or high flow through the stream line flow restrictors.

However, NUREG-1482, Rev. 2, "Guidelines for Inservice Testing at Nuclear Power Plants" identifies in section 2.4.5 that impractical conditions justifying test deferrals may include those situations that could result in an unnecessary plant shutdown, cause unnecessary challenges to safety systems, place undue stress on components, cause unnecessary cycling of equipment, or unnecessarily reduce the life expectancy of the plant systems and components.

Therefore, the full stroking of these MSN s is impractical during power operation.

Alternative Test These valves will be full-stroke exercise tested to the closed position and fail-safe tested during cold shutdowns per ISTC-3521(c) and (f). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-03. Revision Date: 1011212017 6 !ST-LAS-PLAN Valve Number 1IN074 1IN075 2IN074 2IN075 Function !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification

-CS-04 (Rev. 0) (Page 1 of2) System IN IN IN IN Class 2 Category A 2 A 2 A 2 A Unit 1 1 2 2 The subject valves are the Drywell Instrument Nitrogen Purge Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment penetrations M-60 (Unit 1) and M-54 (Unit 2) to mitigate the consequences of an accident.

1(2)IN074 and 1(2)IN075 automatically isolate on a Group 10 Containment Isolation signal. The subject valves have a non-safety related function to open to allow the Drywell Pneumatic System (IN) gases to flow to support the proper operation of pneumatically controlled or operated loads. Justification It is impractical to perform a full or part-stroke exercise of the subject valves during plant operation.

None of the subject valves have part-stroke closure capability.

The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads mainly in the drywell during plant operation.

The distribution of the compressed gas is via two headers. The regulated header supplies all of the system requirements in the drywell (MSNs, main steam safety relief valves (SRVs), reactor recirculation sample valves, recirculation pump seal water control valves and RHR, RCIC, HPCS and LPCS testable check valves) with the exception of the ADS valves. The ADS valve accumulators are supplied by the unregulated header. Additionally there are safety related nitrogen bottles connected to the unregulated header outside of containment which will makeup gas to the unregulated header when pressure drops below 160 psig. Revision Date: 1011212017 7 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-04 (Rev. 0) (Page 2 of2) It is impractical to perform a full-stroke exercise of 1(2)IN074 and 1(2)IN075 during power operation.

The closure of either of these valves would isolate the purge path for all of the IN system air dryers and the relief paths for numerous system relief valves to the drywell. There are two desiccant type air dryers for each compressor.

The dryers are used to ensure that the moisture content of the compressed gas will not adversely impact the operation of the components served (MSIVs, SRVs (including ADS valves), and etc.). Closure of either valve could adversely affect the moisture quality of the IN system air. Additionally, there are numerous IN system relief valves that use the dryer purge path as a relief path for IN system gas. Closure of either valve could prevent the relief valves from relieving system pressure as required to prevent overpressurization of the system or damage to system equipment.

Alternative Test These valves will be full-stroke exercised closed during cold shutdowns per ISTC-3521 ( c) and (f). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-04. Revision Date: 1011212017 8 IST-LAS-PLAN Valve Number 1IN017 2IN017 1IN075 2IN075 Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-05 (Rev. 0) (Page 1of2) System IN IN IN IN Class 2 Category A 2 A 2 A 2 A Unit 1 2 1 2 These valves are the Drywell Instrument Nitrogen Regulated Header Supply Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment penetration M-60 (Unit 1) and M-54 (Unit 2) to mitigate the consequences of an accident.

These valves automatically isolate on a Group 10 Containment Isolation signal. These valves have a non-safety related open function to provide a flow path for Nitrogen to the Main Steam Safety Relief Valve accumulators.

Justification The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads mainly in the drywell during plant operation.

The distribution of the compressed gas is via two headers. The regulated header supplies all of the system requirements in the drywell (MSIVs, main steam safety relief valves (SRV's), reactor recirculation sample valves, recirculation pump seal water control valves and RCIC testable check valves) with the exception of the ADS valves. The MSIVs are operated by air operated pistons to cause the valves to open or assist spring pressure in closing the valves. The flow of instrument air is controlled by solenoid operated pilot valves in the air supply line. The solenoids are energized to open the MSIV. If both solenoids are deenergized, the air will be vented from the operating piston and air pressure (with spring assist) will close the valve. It is impractical to perform a full-stroke exercise of 1(2)IN017 during power operation.

The closure of 1(2)IN017 would isolate the pneumatic supply to the inboard Main Steam Isolation Valves. Loss of pressure between the Inboard MSIV Accumulator Inlet check Valve and the MSIV with this valve closed will cause the MSIV to close and the reactor to SCRAM. Alternative Test These valves will be full-stroke exercised closed during cold shutdowns per ISTC-3521 ( c) and (f). Revision Date: 1011212017 9 IST-LAS-PLAN References

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-05 (Rev. 0) (Page 2 of 2) In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-05. Revision Date: 1011212017 10 !ST-LAS-PLAN Valve Number IINIOO 1IN101 2IN100 2IN101 Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-06 (Rev. 0) (Page 1of2) System IN IN IN IN Class 2 Category B 2 B 2 B 2 B Unit 1 1 2 2 These valves are the ADS Accumulator Unregulated N2 Header Drywell Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment penetration, (Unit 1, penetrations M-55 and M-60, Unit 2, Penetrations M-55 and M-61), to mitigate the consequences of an accident, post-LOCA.

These valves do not receive an automatic Containment Isolation signal but can be aligned post-LOCA by the control room if required.

These valves exist to satisfy the requirements of 10CFR50 Appendix A, GDC 57. The ADS valves are designed, analyzed and tested to perform their required safety functions on a total loss of pneumatic supply pressure by the pressure retained in the individual accumulators by their respective check valves. This backup pressure source provides the option of using the ADS valves for long term accident mitigation.

These valves have an open safety function to allow for the supply of instrument nitrogen from either the Instrument Nitrogen System or nitrogen bottle banks to allow for the operation of the ADS valves following an accident via continuous supply to the two groups of ADS accumulators.

[Ref. USAR Table 7.5-1, Note 6] Justification The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads mainly in the drywell during plant operation.

It is impractical to perform a partial stroke of these valves because they are solenoid valves and do not have the ability to partially stroke. It is also impractical to full-stroke exercise of these valves to the closed position during plant operation.

The closure of 1(2)IN100 or 1(2)IN101 would isolate the pneumatic supply to the individual ADS valve accumulators.

This may have adverse affect on the system capability to maintain the ADS valves in the open position.

Revision Date: 1011212017 11 IST-LAS-PLAN Alternative Test !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-06 (Rev. 0) (Page 2 of2) These valves will be full-stroke exercised closed during cold shutdowns per ISTC-3521(c) and (f). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-06. Revision Date: 1011212017 12 IST-LAS-PLAN Valve Number 1B21-F010A 1B21-F010B 2B21-F010A 2B21-F010B Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-07 (Rev. 0) (Page 1of2) System FW FW FW FW Class 1 1 1 1 Category NC NC NC NC Unit 1 1 2 2 These valves are the Feedwater Check Valves located inside Containment, which also function as Containment Isolation Valves. These valves have a safety function to close (self-actuation) to isolate the primary reactor containment (penetration M-5 and M-6 respectively).

Additionally, these valves have a safety function to close (self-actuation) to isolate the Reactor Coolant Pressure Boundary whenever normal feedwater flow becomes unavailable.

These valves have a non-safety function to open during normal plant operation to provide a path for feedwater flow to the reactor vessel to maintain the desired water level. Open functional testing to satisfy the bi-directional testing requirement of ISTC-522l(a) is satisfied through Operator observation performed upon transition from Cold Shutdown to power operation following the performance of a closed test. Justification It is not practical to full-stroke these valves to the closed position on a quarterly (nominally every 3 months) basis during plant operation.

The feedwater system serves as the main source of makeup water to the reactor vessel during plant operation.

Closure of either of the subject valves would induce a plant transient due to reduced feedwater flow to the reactor vessel, unnecessarily challenge the plant operators and could subsequently cause a plant scram. The only practical method to verify the full-stroke closure capability of these valves utilizing flow is by seat leakage testing. As described above, all of the subject check valves have a seat leakage limiting function as primary containment isolation valves. Therefore, these valves are individually leakage rate tested in accordance with the requirements of 10 CFR 50 Appendix J and Technical Specification Surveillance Requirement 3.6.1.1.1.

Revision Date: 1011212017 13 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown .Justification

-CS-07 (Rev. 0) (Page 2 of2) In order to manipulate the test connections and block valves to their proper position to perform a leakage rate test of the subject valves, an entry into the drywell is required.

This is not practical during plant operation or cold shutdowns when the atmosphere in containment is inerted. The drywell at LaSalle County Station is ine1ted during plant operation as required by Technical Specification 3.6.3.2 to protect against a bum or explosion of hydrogen gas generated by the reactor core metal-water reaction as a result of a loss of coolant accident.

Entry into the drywell during plant operation or cold shutdowns for the sole purpose of performing these leakage rate tests would require that the drywell be inerted. Section 3.1.1.3 of NUREG-1482, Rev. 1, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Alternative Test These valves will be full-stroke exercised closed during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522( c ). [Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-07. Revision Date: 1011212017 14 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification

-CS-08 (Rev. 0) (Page 1of3) Valve Number System Class Category Unit 1B21-F037Cl MS 3 c 1 1B21-F037C2 MS 3 c 1 1B21-F037Dl MS 3 c 1 1B21-F037D2 MS 3 c 1 1B21-F037El MS 3 c 1 1B21-F037E2 MS 3 c 1 1B21-F037Fl MS 3 c 1 1B21-F037F2 MS 3 c 1 1B21-F037Hl MS 3 c I 1B21-F037H2 MS 3 c 1 1B21-F037Kl MS 3 c 1 1B21-F037K2 MS 3 c 1 1B21-F037Ll MS 3 c 1 1B21-F037L2 MS 3 c 1 1B21-F037Ml MS 3 c 1 1B21-F037M2 MS 3 c 1 1B21-F037Pl MS 3 c 1 1B21-F037P2 MS 3 c 1 1B21-F037Rl MS 3 c 1 1B21-F037R2 MS 3 c 1 1B21-F037Sl MS 3 c 1 1B21-F037S2 MS 3 c 1 1B21-F037Ul MS 3 c 1 1B21-F037U2 MS 3 c 1 1B21-F037Vl MS 3 c 1 1B21-F037V2 MS 3 c 1 2B21-F037Cl MS 3 c 2 2B21-F037C2 MS 3 c 2 2B21-F037Dl MS 3 c 2 2B21-F037D2 MS 3 c 2 2B21-F037El MS 3 c 2 2B21-F037E2 MS 3 c 2 2B21-F037Fl MS 3 c 2 2B21-F037F2 MS 3 c 2 2B21-F037Hl MS 3 c 2 2B21-F037H2 MS 3 c 2 2B21-F037Kl MS 3 c 2 2B21-F037K2 MS 3 c 2 2B21-F037Ll MS 3 c 2 2B21-F037L2 MS 3 c 2 Revision Date: 1011212017 15 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-08 (Rev. 0) (continued)

Valve Number 2B21-F037Ml 2B21-F037M2 2B21-F037Pl 2B21-F037P2 2B21-F037Rl 2B21-F037R2 2B21-F037Sl 2B21-F037S2 2B21-F037Ul 2B21-F037U2 2B21-F037Vl 2B21-F037V2 Function (Page 2 of3) System MS MS MS MS MS MS MS MS MS MS MS MS Class 3 3 3 3 3 3 3 3 3 3 3 3 Category c c c c c c c c c c c c Unit 2 2 2 2 2 2 2 2 2 2 2 2 These valves are the Main Stearn Relief Valve Vacuum Breakers and have a safety function to open to alleviate any vacuum that could develop within the SRV discharge line following SRV actuation.

This prevents water from the suppression pool from being drawn into the affected discharge line, which could result in a serious water hammer condition upon subsequent re-actuation of the SRV. The subject valves also have a safety related close function to prevent discharge of the SRV from being directed into the drywell. These check valves are not "capacity certified" and are therefore only required to meet the requirements ofISTC-3522 as provided in Note 4 to Table ISTC-3500-1.

Justification It is impractical to perf01m a full stroke exercise of the subject valves during plant operation or during cold shutdowns when the drywell is inerted. The only practical method available to perform a full-stroke exercise of these valves is by manually exercising the valve disk to its full open and full closed position while visually verifying valve obturator (disk) position.

Access to the disk is gained from the intake port of the valve body. Revision Date: 1011212017 16 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification

-CS-08 (Rev. 0) (Page 3 of3) In order to perform this test, access to the drywell area is required.

Access to the drywell area is not practical during plant operation or cold shutdowns when the atmosphere in containment is inerted. The drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification 3.6.3.2 to protect against a bum or explosion of hydrogen gas generated by the reactor core metal-water reaction as a result of a loss of coolant accident.

Entry into the drywell during plant operation or cold shutdowns for the sole purpose of performing the exercise tests for the subject valves would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Alternative Test These valves will be manually full-stroke exercised open and closed during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-08. Revision Date: 1011212017 17 IST-LAS-PLAN Valve Number 1B21-F032A 1B21-F032B 2B21-F032A 2B21-F032B Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-09 (Rev. 0) (Page 1of2) System Class Category FW 1 AIC FW 1 AIC FW 1 AIC FW 1 AIC Unit 1 1 2 2 The subject valves are the Feedwater Line Outboard Testable Check Valves that also function as Containment Isolation Valves. These valves have a safety related function to close (Group 2 Primary Containment Isolation System -PCIS) to isolate the primary reactor containment (penetration M-5 and M-6). Additionally, these valves have a safety related function to close (self-actuation) to isolate the Reactor Coolant Pressure Boundary whenever normal feedwater flow becomes unavailable.

These valves are equipped with a spring to assist in the valve's closure during no flow conditions.

During normal operation, air is applied to the spring in order to compress the spring, preventing the spring from forcing the disk into the flow of feedwater.

Upon an isolation signal, air is applied to assist the spring in driving the disk into the valve's seat. Note that the strength of the air/spring combination is not sufficient to fully close the valve during feed flow. [Reference Ops. Feedwater Training Description]

These valves have a non-safety related function to be open during normal plant operation to provide a path for feedwater flow to the reactor vessel to maintain the desired water level. Justification It is not practical to full-stroke these valves to the closed position on a quarterly basis during plant operation.

The feedwater system serves as the main source of makeup water to the reactor vessel during plant operation.

Full closure of either of the subject valves would induce a plant transient due to reduced feedwater flow to the reactor vessel, unnecessarily challenge to the plant and could subsequently result in a plant scram. As identified in NUREG 1482, Rev. 2, section 4.1.5.4, if the closure of these valves on cessation or reversal of flow is required to accomplish a safety-related function, closure must be verified by reverse flow testing or such other positive means as acoustic monitoring or radiography.

Revision Date: 1011212017 18 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-09 (Rev. 0) (Page 2of2) The only practical method to verify the full-stroke closure capability of these valves utilizing flow is by seat leakage testing. As described above, all of the subject check valves have a seat leakage limiting function as primary containment isolation valves. Therefore, these valves are individually leakage rate tested in accordance with the requirements of 10 CPR 50 Appendix J and Technical Specification Surveillance Requirement 3.6.1.1.1.

In order to manipulate the test block valves to their proper position to perform a leakage rate test of the subject valves, an entry into the drywell is required.

This is not practical during plant operation or cold shutdowns when the atmosphere in containment is inerted. The drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification 3.6.3.2 to protect against a bum or explosion of hydrogen gas generated by the reactor core metal-water reaction as a result of a loss of coolant accident.

Entry into the drywell during plant operation or cold shutdowns for the sole purpose of performing these leakage rate tests would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Alternative Test These valves will be full-stroke exercised to the open and closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third IO-Year IST Interval, this Cold Shutdown Justification was identified as CS-09. Revision Date: 1011212017 19 IST-LAS-PLAN Valve Number 1E12-F050A 1E12-F050B 2E12-F050A 2E12-F050B Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-10 (Rev. 0) (Page 1of2) System RH RH RH RH Class 1 1 1 1 Category AJC AJC AJC AJC Unit 1 1 2 2 These valves are the RHR Shutdown Cooling Return Check Valves, which also function as Pressure Isolation Valves (PIV). These valves have a safety related function to close to protect the low pressure RHR piping and components from reactor coolant and are considered pressure isolation valves (PIV). These valves have a non-safety related function to open to allow for flow from the RHR system to the vessel during the normal shutdown cooling mode. These normally closed testable check valves serve as the first isolation valve in the event of a system line break. Justification It is not practical to perform a full-stroke exercise of these subject valves to the closed position during plant operation or cold shutdowns when the atmosphere in containment is inerted. The RHR Pump does not produce adequate head to flow into the vessel during power operation so these valves cannot physically be exercised during those conditions.

For conditions to exist that allow for these valves to be exercised, the plant must be in either Modes 4, 5 or defueled.

The only practical method to verify the full-stroke closure capability of these valves utilizing flow is by seat leakage testing. As described above, all of the subject check valves are PIV s that have a seat leakage limiting function as reactor coolant boundary pressure isolation valves. As a result, these valves are individually leakage rate tested in accordance with the requirements of Technical Specification Surveillance Requirement 3.4.6.1. Revision Date: 1011212017 20 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification-CS-10 (Rev. 0) (Page 2of2) In order to manipulate the necessary block and test connection valves to perform a leakage rate test entry into the dtywell is required.

This is not practical during plant operation or cold shutdowns when the atmosphere in containment is inerted. The drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification 3.6.3 .. Entry into the drywell during plant operation or cold shutdowns for the sole purpose of performing these leakage rate tests would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Alternative Test The subject valves shall be full-stroke exercised to the closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-10. Revision Date: 1011212017 21 IST-LAS-PLAN Valve Number 1C41-F006 1C41-F007 2C41-F006 2C41-F007 Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-11 (Rev. 0) (Page 1of2) System SC SC SC SC Class 1 1 1 1 Category c NC c NC Unit 1 1 2 2 These valves are the Stand By Liquid Control (SBLC) Injection Line Inboard and Outboard Check Valves. These valves have the safety related function to open to provide a flow path for the injection of the SBLC inventory of sodium pentaborate, a neutron absorber, into the reactor which will stop the nuclear chain reaction in response to an Anticipated Transient Without Scram (ATWS) event. These valves have a safety function to close to isolate containment penetration M-34 once either of the explosively actuated Squib Valves [i.e. 1(2)C41-F004A and B] is actuated.

Justification It is impractical to perform a full-stroke exercise of the subject valves to the open or closed position nominally every 3 months during plant operation.

In order to perform a full-stroke exercise of the subject valves to the open position, the SBLC system must inject fluid into the reactor vessel. This requires actuation of at least one of the explosively actuated injection (squib) valves. (Testing procedures allow for the injection of demineralized water in lieu of the injection of the sodium pentaborate solution).

These squib valves (1(2)C41-F004NB) are single use type valves that serve as a leakage seal between the SBLC and reactor coolant system and act as primary containment isolation valves. Once actuated, these valves's spent explosive charges and inlet chamber plug must be replaced which necessitates a system lineup that would render the SBLC system inoperable.

Technical Specification

3.1.7 requires

that the SBLC system be operable during Modes 1 and 2. The injection of the sodium pentaborate solution during plant operation would cause an unnecessary negative reactivity excursion of the reactor possibly causing a plant shutdown.

Injection of the sodium pentaborate solution during cold shutdowns would delay plant startup to restore the reactor coolant system water chemistry to the proper conditions.

Revision Date: 1011212017 22 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-11 (Rev. 0) (Page 2 of2) Testing is achieved through the injection of cold demineralized water in lieu of the sodium pentaborate solution.

Still, the injection of cold demineralized water during plant operation could cause a positive reactivity excursion of the reactor possibly causing a plant shutdown.

In both injection scenarios, the explosive activation of a squib valve would result in entry into TS 3.1.7 while in either Mode 1or2 in order to perform subcomponent replacement.

In order to perform a closure test of the subject valves, boundary valve 1(2)C41-F008 must be isolated.

This valve is located inside of the drywell. The drywell at LaSalle Country Station is inerted during plant operation as required by Technical Specification

3.6.3. Entry

into the drywell during plant operation or cold shutdowns when the atmosphere in containment is inerted for the sole purpose of isolating this valve to perform a closure test of the subject valves would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. The Cold Shutdown testing at a frequency corresponding to that of TSR 3.1.7.8 for the open exercise testing is justified by ISTC-3522(a), which states that open and close tests need only be performed at an interval when it is practicable to perform both tests. It is therefore impractical to perform a full stroke exercise test in either an open or closed direction during plant operation.

Alternative Test These valves will be full-stroke exercised to the open and closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages on a frequency that corresponds to 24 month staggered test frequency associated with TSR 3.1.7.8 per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-11. Revision Date: 1011212017 23 IST-LAS-PLAN Valve Number 1E51-F040 2E51-F040

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-12 (Rev. 0) (Page 1of1) System RI RI Class 2 2 Category A/C A/C Unit 1 2 These valves are now included in in the Check Valve Condition Monitoring Program, Condition Monitoring Plan 11. Revision Date: 1011212017 24 IST-LAS-PLAN Valve Number 1E51-F065 1E51-F066 2E51-F065 2E51-F066 Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-13 (Rev.1) (Page 1of2) System Class Category RI 1 AJC RI 1 AJC RI 1 AJC RI 1 AJC Unit 1 1 2 2 These valves are the RCIC Injection Inboard and Outboard Testable Check Valves. These valves have a safety related function to open to allow RCIC injection flow to enter the Reactor Vessel to mitigate the consequence of an accident.

These valves also have a safety related function to close to act as reactor coolant system pressure isolation valves. Justification The RCIC system is designed to assure adequate core cooling in the event of reactor isolation from its primary heat sink and the loss of feedwater flow to the reactor vessel without actuation of any of the Emergency Core Cooling System equipment.

RCIC is required to be operable whenever the plant is in Modes 1-3 when reactor pressure exceeds 150 psig in accordance with Technical Specification

3.5.3. These

valves are located in the main injection line to the reactor vessel. Closure verification of the subject valves can only be performed utilizing a leakage type test when the RCIC system is isolated and shutdown (inoperable).

In order to safely (from both the standpoint of equipment and personnel safety) perform this leakage test, the reactor must be shutdown and at atmospheric pressure, (i.e. Mode 4 or 5) and a blind flange installed in the main injection line between 1(2)E51-F066 and the reactor vessel (inside the drywell).

Additionally, performance of this test requires the installation of test equipment and the opening of various vent connections.

The drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification

3.6.3. Entry

into the drywell during plant operation or cold shutdowns for the sole purpose of performing a closure test of the subject valves would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Revision Date: 1011212017 25 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-13 (Rev. 1) (Page 2 of2) These valves are located in the main RCIC injection line to the reactor vessel downstream of the injection line isolation valve (i.e. 1(2)E51-F013).

In order to perform a full-stroke open exercise 1(2)E51-F065 and 1(2)E51-F066, the RCIC pump must be started, the RCIC injection isolation valve opened, resulting in flow to the reactor vessel. The injection of RCIC system flow into the reactor vessel during power operations would inject large amounts of relatively cold water into the reactor vessel which could cause a reactivity excursion, level control problems and possible subsequent reactor scram. While this test could be performed during Modes 2-3 conditions, per ISTC 3522(a) open and closed tests need only be performed at an interval when it is practicable to perform both tests. It is therefore impractical to perform a full-stroke exercise of these valves to either the open or closed position during plant conditions other than Modes 4, and 5 when the drywell is inerted. Alternative Test These valves will be full-stroke exercised to the open and closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-13. Revision Date: 1011212017 26 IST-LAS-PLAN Valve Number 1B21-F040C 1B21-F040D 1B21-F040E 1B21-F040R 1B21-F040S 1B21-F040U 1B21-F040V 2B21-F040C 2B21-F040D 2B21-F040E 2B21-F040R 2B21-F040S 2B21-F040U 2B21-F040V Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown .Justification-CS-14 (Rev. 0) (Page 1of3) System IN IN IN IN IN IN IN IN IN IN IN IN IN IN Class 2 2 2 2 2 2 2 2 2 2 2 2 2 2 Category AJC AJC AJC AJC AJC AJC AJC AJC AJC AJC AJC AJC AJC AJC Unit 1 1 1 1 1 1 1 2 2 2 2 2 2 2 These valves are the ADS Accumulator fillet Check Valves. These valves have a safety related function to close to permit the ADS valves to be operated in the event of a loss of the drywell pneumatic system gas supply. These valves also have a safety related function to open to allow pressurized gas to flow to the ADS valve accumulator from the safety related nitrogen bottle banks to support the operation of each valves respective ADS valve . .Justification The safety function of the SRV s is to prevent overpressurization of the reactor coolant system, which could lead to failure of the reactor coolant pressure boundary .* fu order to open exercise these valves to the position required to fulfill their safety function, the supported ADS valve's actuator must be stroked open, after which would necessitate the recharging of the associated ADS accumulator.

Opening an ADS/SRV when at full operating pressure would cause a significant challenge to the plants operation.

Such actions would result in a significant decrease in reactor pressure and result in a reduction in reactor water inventory, which could result in a plant scram. Even opening the ADS/SRV under Mode 4 conditions would result in needing to recharge the affected ADS accumulators, which would result in a delay to the resumption of power generation.

Revision Date: 1011212017 27 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification-CS-14 (Rev. 0) (Page 2 of3) Based upon the following, it is also impractical to exercise these check valves during power operation for the following reasons: The stroking of the ADS/SRV valves in place can lead to valve through seat leakage during plant operation, as based upon industry experience and experience at LaSalle. In previous operating cycles for Unit 1 and Unit 2, approximately 18% (i.e., 5 of 28) of the valves that were subjected to one open/close cycle developed leakage, whereas, approximately 57% (i.e., 12 of 21) of the valves that experienced more than one open/close cycle developed through seat leakage. The SRV and ADS valve leakage is directed to the pool of water in the primary containment suppression chamber causing a need to increase cooling to the pool or a plant shutdown to fix the leaking valve. Therefore, the operation of these ADS/SRVs for the sole purpose of performing an open exercise test of these check valves is not practical.

The decoupling of the ADS actuator from the SRV however would allow for actuation of the ADS without the actual opening of the SRV, thus removing the unnecessary introduction of actions that could result in potential through seat leakage of the SRV. However it must be recognized that the drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification 3.6.3. To decouple the ADS actuator from the SRV, a drywell entry would be required, which would necessitate de-inerting.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, inert and replace the lost nitrogen gas could delay the return to power. An alternative to the decoupling of the ADS from the SRV would involve the opening of vent valve down stream of the associated check valve, however access to that vent valve would also require entry into the drywell which would necessitate de-inerting.

It is therefore determined to be impractical to perform a full-stroke exercise of these valves to the open or closed position dming plant operation or during cold shutdowns while the drywell is in inerted conditions.

Alternative Test These valves will be full-stroke exercised to the open and closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] Revision Date: 1011212017 28 IST-LAS-PLAN References

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification-CS-14 (Rev. 0) (Page 3 of3) In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-14. Revision Date: 1011212017 29 IST-LAS-PLAN Valve Number 1B33-F395 2B33-F395

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-15 (Rev. 0) (Page 1of1) System RR RR Class 2 2 Category NC NC Unit 1 2 These valves are now included in in the Check Valve Condition Monitoring Program, Condition Monitoring Plan-07. Revision Date: 1011212017 30 IST-LAS-PLAN Valve Number 1B21-F024A 1B21-F024B 1B21-F024C 1B21-F024D 1B21-F029A 1B21-F029B 1B21-F029C 1B21-F029D 2B21-F024A 2B21-F024B 2B21-F024C 2B21-F024D 2B21-F029A 2B21-F029B 2B21-F029C 2B21-F029D Function !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification-CS-16 (Rev. 0) (Page 1 of2) System IN IN IN IN IA IA IA IA IN IN IN IN IA IA IA IA Class 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 Category NC NC NC NC NC NC NC NC NC NC NC NC NC NC NC NC Unit 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 This group of valves is made up of the Inboard and Outboard MSIV Accumulator Check Valves. These check valves have a safety function to close to isolate non-safety related instrument air or nitrogen from the gas stored in its supported safety related accumulators.

Accumulator pressure is required to ensure proper operation of the MSIV s to mitigate the consequences of an accident.

Justification The inboard MSIV accumulator check valves are located inside primary containment.

The only practical method to verify the full-stroke closure capability of these valves utilizing flow is by seat leakage testing. In order to manipulate the test connection valves and block valves to their proper position to perform a leakage rate test of the subject valves, entry into the drywell is required.

The drywell at LaSalle Country Station is inerted during plant operation as required by Technical Specification

3.6.3. Entry

into the drywell during plant operation or cold shutdowns for the sole purpose of performing these leakage rate tests would require that the drywell be inerted. Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-ine1t and replace the lost nitrogen gas could delay the return to power. Revision Date: 1011212017 31 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown Justification

-CS-16 (Rev. 0) (Page 2 of2) The only practical method of verifying the full-stroke closure capability of the outboard MSIV accumulator check valves is by seat leakage testing. This is impractical during plant operation because seat leakage testing would require isolation of the instrument air supply to at least two outboard MSIV accumulators.

This removes the fast-closure (3 to 5 second) capability of the MSIV s with the depressurized accumulators.

In addition, isolation of the air supply could potentially result in the closure of an MSIV at power potentially leading to a plant scram. Alternative Test These valves will be full-stroke exercised to the closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-16. Revision Date: 1011212017 32 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Valve Number 1E22-F005 1E21-F006 1E12-F041A 1E12-F041B 1E12-F041C 2E22-F005 2E21-F006 2E12-F041A 2E12-F041B 2E12-F041C Function Cold Shutdown Justification

-CS-17 (Rev. 1) (Page 1of3) System Class Category HP 1 A/C LP 1 A/C RH 1 A/C RH 1 A/C RH 1 A/C HP 1 AIC LP 1 A/C RH 1 A/C RH 1 A/C RH 1 A/C Unit 1 1 1 1 1 2 2 2 2 2 These valves are the HPCS, LPCS and RHR Injection Check Valves. These valves serve as Pressure Isolation Valves (PIV), which are safety related closed functions.

These valves also have a safety related open function to allow for injection from their associated system. This injection flow is necessary to provide sufficient cooling to the reactor core to prevent excessive fuel cladding temperature following a break in the nuclear system piping. Justification Open Testing The only methods available to verify a full-stroke open exercise of the valve is to either flow through the valve at a rate that meets or exceeds the required maximum accident condition flow or to use a mechanical exerciser.

If a mechanical exerciser is used, the force(s) or torque(s) required to move the obturator and fulfill its safety function(s) shall meet the acceptance criteria specified by the owner. It is not practical to provide any flow through the LPCI/RHR and LPCS valves to perform a full stroke exercise during plant operation.

The LPCI/RHR and LPCS pumps have insufficient head to flow to the reactor during normal power operations.

Additionally, the LPCI/RHR and LPCS injection isolation valves are interlocked to prevent their opening during plant operation when reactor coolant system pressure is > 500 psig. The reactor pressure interlock prevents the inadvertent opening of these valves during power operation to protect the lower design pressure rated LPCI/RHR and LPCS system piping located outside of the reactor containment from overpressurization.

Revision Date: 1011212017 33 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown .Justification

-CS-17 (Rev.1) (Page 2of3) It is not practical to manually exercise the LPCI/RHR and LPCS valves to their open position using a mechanical exerciser during plant operation because the valves are located in the drywell, which is inerted during plant operation.

It is not practical to pass any flow through the HPCS system to perform a full or stroke exercise of 1 (2)E22-F005 during plant operation.

HPCS is an emergency core cooling system that is designed to cool the reactor in the event of a coolant system pipe break. If the HPCS system were operated during plant operation, relatively cold water would be directly injected into the reactor at power. This could cause a reactor reactivity excursion and/or level transient that would unnecessarily challenge the plant and possibly result in a reactor scram. It is not practical to manually exercise the HPCS valves to their open position using a mechanical exerciser during plant operation because the valves are located in the drywell, which is inerted during plant operation.

Close Testing In order to full stroke close these valves, the valve must first be opened against RCS pressure.

During power operation, neither the LPCS nor the RHR systems are capable of developing sufficient pressure to open their subject valves against RCS pressure.

While the HPCS system is capable of injecting into the RCS during power operating conditions, doing so is undesirable as the introduction of cold water to the reactor would result in undesirable power fluctuations and possible reactor trip. In addition, the only practical method to verify the successful closure of these valves is through performing a seat leakage testing. As described above, all of the subject check valves serve as PIV s. Each PIV is assigned individual leakage rate criteria as described in Technical Specification Surveillance Requirement 3.4.6.1. In order to perform TSR 3.4.6.1, entry into the drywell is required in order to manipulate the test connection and block valves to their necessary positions.

This is not practical during plant operation or cold shutdowns when the atmosphere in containment is inerted. The drywell at LaSalle County Station is inerted during plant operation as required by Technical Specification

3.6.3. Entry

into the drywell during plant operation or cold shutdowns for the sole purpose of performing these leakage rate tests would require that the drywell be inerted. Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. Revision Date: 1011212017 34 IST-LAS-PLAN Alternative Test /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-17 (Rev. 1) (Page 3of3) These valves will be full-stroke exercised open and closed following each refueling outage or period of cold shutdown during which the drywell has been de-inerted for reasons other than Inservice Testing per ISTC-3522(b) and ISTC-3522(c).

Note, while it may not be necessary to de-inert the drywell to perform the open testing of these subject valves (if flowing through the valve at a rate that meets or exceeds the required maximum accident condition flow), per ISTC-3522, open and close tests need only be performed at an interval when it is practicable to perform both tests. As a result, the most restrictive criteria as provided above will be used. References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-17. Revision Date: 1011212017 35 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification-CS-18 (Rev. 0) (Page 1of2) Valve Number System Class Category Unit 1B21-F036C IN 3 AIC 1 1B21-F036D IN 3 AIC 1 1B21-F036E IN 3 AIC 1 1B21-F036F IN 3 AIC 1 1B21-F036H IN 3 AIC 1 1B21-F036K IN 3 AIC 1 1B21-F036L IN 3 AIC 1 1B21-F036M IN 3 AIC 1 1B21-F036P IN 3 AIC 1 1B21-F036R IN 3 AIC 1 1B21-F036S IN 3 AIC 1 1B21-F036U IN 3 AIC 1 1B21-F036V IN 3 AIC 1 2B21-F036C IN 3 AIC 2 2B21-F036D IN 3 AIC 2 2B21-F036E IN 3 AIC 2 2B21-F036F IN 3 AIC 2 2B21-F036H IN 3 AIC 2 2B21-F036K IN 3 AIC 2 2B21-F036L IN 3 AIC 2 2B21-F036M IN 3 AIC 2 2B21-F036P IN 3 AIC 2 2B21-F036R IN 3 AIC 2 2B21-F036S IN 3 AIC 2 2B21-F036U IN 3 AIC 2 2B21-F036V IN 3 AIC 2 Function These valves are the SRV Accumulator Inlet Check Valves. These valves have a safety related function to close to permit the SRV's to be operated in the "relief' mode in the event of a loss of the drywell pneumatic system gas supply. These valves have a non-safety related open function to provide a flow path from the Instrument Nitrogen Receiver IN02T to the Main Steam SRV Accumulator.

Justification The safety function of the SRVs is to prevent overpressurization of the reactor coolant system, which could lead to failure of the reactor coolant pressure boundary.

Revision Date: 1011212017 36 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-18 (Rev. 0) (Page 2 of2) The SRVs function as both Safety and Relief valves, with a subset of (7) of these SRV's providing a third function of being able to provide a depressurization function. (i.e. those equipped with ADS, valves C/D/E/R/S/UN).

For power operated relief operation, each valve is provided with a pressure sensing device that is programmed with various setpoints, depending upon plant operating parameters.

When the relief set pressure is reached, a solenoid valve actuates allowing air/nitrogen to provide the motive force through a pneumatic piston/cylinder and linkage assembly to open the subject SRV. Each SRV can also be operated independently in a Relief Mode from controls located in the main control room. Each SRV is provided with its own pneumatic accumulator and inlet check valve. These accumulators assure that the valve can be opened following failure of their non-safety related air supply. The accumulators, check valves and associated test connections are physically located inside of the drywell. The drywell at LaSalle Country Station is inerted during plant operation as required by Technical Specification

3.6.3. Entry

into the drywell during plant operation or cold shutdowns for the sole purpose of performing a closure test of the subject valves would require that the drywell be de-inerted.

Section 3.1.1.3 of NUREG-1482, Rev. 2, identifies that de-inerting during cold shutdowns for the sole purpose of performing these tests is impractical because the time and effort needed to de-inert, re-inert and replace the lost nitrogen gas could delay the return to power. ISTC requires that all check valves be exercise tested in both directions regardless of safety function.

Open and close tests need only be performed at a frequency when it is practical to perform both tests per ISTC-3522(a).

Therefore based upon the above justification, it is impractical to perfmm a full-stroke exercise of these valves to the closed position during plant operation or during cold shutdowns.

Alternative Test These valves will be full-stroke exercised to the open and closed position during cold shutdown if the drywell has been de-inerted for reasons other than Inservice Testing, or during refueling outages per ISTC-3522(b) and ISTC-3522(c).

[Reference Technical Position TP-12] References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as CS-18. Revision Date: 1011212017 37 IST-LAS-PLAN Valve Number 1IN031 2IN031 Function /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-19 (Rev. 0) (Page 1of2) System IN IN Class 2 Category A 2 A Unit 1 2 These valves are the Drywell Instrument Nitrogen Traversing Incore Probe (TIP) Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment penetration M-4 7 to mitigate the consequences of an accident.

These valves automatically isolate on a Group 2 Containment Isolation signal. These valves have a non-safety related open function to provide a flow path for Nitrogen to each TIP index mechanism and guide tube assembly.

These valves are the only Primary Containment Isolation Valves on the penetration, and are location outside the drywell. .Justification The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads mainly in the drywell during plant operation.

Each TIP index mechanism and guide tube assembly is continuously purged with dry nitrogen from the drywell pneumatic system. This prevents changes in the drywell atmospheric humidity from affecting the quality of the flux profile. In addition, each drive mechanism is purged with dry instrument air to aid in moisture removal. It is impractical to perform a partial stroke of these valves because they are solenoid valves and do not have the ability to partially stroke. It is also impractical to full-stroke exercise these valves to the closed position during plant operation because the testing would unnecessarily reduce the life expectancy of plant components (NUREG-1482 Revision 2 section 2.4.5). The closure of 1 (2)IN031 would isolate the pneumatic supply to the TIP drive mechanism, and this may have an adverse affect on drywell atmosphere humidity from destroying the Sermetel (graphite) coating of the guide tubes, which could render the TIP system inoperable.

The nitrogen purge also limits the amount of general corrosion on all interior surfaces, and thus further reduces the possibilities of component failure. Furthermore, failure of these valves in the non-conservative position (i.e., open position) during valve cycling would result in a loss of containment integrity (NUREG-1482 revision 2 section 3.1.1(1) and 3.1.1(2)).

Revision Date: 1011212017 38 IST-LAS-PLAN Alternative Test !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Cold Shutdown .Justification

-CS-19 (Rev. 0) (Page 2of2) These valves will be full-stroke exercised closed during cold shutdowns per ISTC-352l(c) and (f). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-19. Revision Date: 1011212017 39 !ST-LAS-PLAN Valve Number 1VP113A 1VP113B 1VP114A 1VP114B 2VP113A 2VP113B 2VP114A 2VP114B Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-20 (Rev. 0) (Page 1of2) System VP VP VP VP VP VP VP VP Class 2 Category A 2 A 2 A 2 A 2 A 2 A 2 A 2 A Unit 1 1 1 1 2 2 2 2 Valves 1(2)VP113A and 1(2)VP113B are the Drywell Cooler Inlet Inboard isolation valves and valves 1(2)VP114A and 1(2)VP114B are the Drywell Cooler Outlet Inboard isolation valves. These normally open motor operated valves must close automatically within 90 seconds upon receipt of a Group 2 isolation signal to isolate containment from the primary chilled water system. This is a safety related function.

This valve opens to provide a chilled water supply from the chilled water pump to the drywell. This function is not required for safe shutdown or accident mitigation.

Justification It is impractical to stroke time test these valves to the closed position on a quarterly (nominal 92 days) basis during plant operation.

Quarterly stroke time testing of these valves requires swapping of chiller divisions to ensure the opposite train of the system is in operation prior to stroke time testing the valves associated with the non-running division.

These valves are not typically closed during normal chiller division swaps. These valves are closed while swapping chiller divisions (on a quarterly frequency) for the sole purpose of stroke time testing the valves. Frequent starting/stopping of the drywell chiller divisions and cycling/timing of the valves discussed in this Cold Shutdown Justification creates additional wear on the safety related Primary Containment Cooling System (i.e., the VP System) and unnecessarily challenges the drywell cooling fans, chillers, and pumps. This places undue stress on the system, increases the probability of an equipment failure, and reduces the life expectancy of the system. Furthermore, a failure of the Primary Containment Cooling System (including the valves discussed in this Cold Shutdown Justification) may necessitate a Reactor shutdown and Containment/Drywell entry due to Technical Specification 3.6.1.5 drywell air temperature limitations.

Revision Date: 1011212017 40 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown .Justification

-CS-20 (Rev. 0) (Page 2of2) NUREG-1482, Rev. 2, "Guidelines for Inservice Testing at Nuclear Power Plants" identifies in section 2.4.5 that impractical conditions justifying test deferrals may include those situations that could result in an unnecessary plant shutdown, cause unnecessary challenges to safety systems, place undue stress on components, cause unnecessary cycling of equipment, or unnecessarily reduce the life expectancy of the plant systems and components.

Therefore, stroke time testing of the subject valves to the closed position on a quarterly (nominal 92 days) basis is impractical during power operation.

Alternative Test These valves will be stroke time tested to the closed position during cold shutdowns per ISTC-3521(c), ISTC-352l(f), and ISTC-3521(g).

References This Cold Shutdown Justification was created during LaSalle' s Third 10-Year IST Interval in response to NER NC-09-037 (Technical Specification Required Shutdown due to Inboard Isolation Valve Packing Leak at LaSalle Unit 2). Revision Date: 1011212017 41 IST-LAS-PLAN Description

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-21 (Rev. 0) (Page 1of2) It is not practicable to full-stroke close the HCU Accumulator Charging Water Check Valve nominally every 3 months per the requirements of ISTC-3522(b

). Affected Components EPN Class Cat. Description 1(2)Cll-D001-115 NC C HCU Accumulator Charging Water Check Valve Function There are 185 of each of the valves listed above, i.e., one for each of the 185 control rod drives. 1(2)Cll-D001-115 (HCU Accumulator Charging Water Check Valve) has a safety function to close to prevent a loss of accumulator pressure in the event that charging supply pressure is lost and to prevent diversion of accumulator discharge water during a scram. This valve has a function to open to allow charging water to pass from the control rod drive pumps to the hydraulic control units. Flow to the accumulators is required only during scram reset or system startup. This valve has no safety function to open. Justification LaSalle's reactor vessels are equipped with bottom-entry hydraulically driven control rod drive mechanisms with high pressure water providing the hydraulic power. Each control rod (185 total) is operated by a hydraulic control unit (HCU), which consists of valves and an accumulator.

The HCU is supplied charging and cooling water from the control rod drive pumps and the control rod operating cylinder exhausts to the scram discharge volume. Revision Date: 1011212017 42 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Cold Shutdown Justification

-CS-21 (Rev. 0) (Page 2 of2) Various valves in the control rod drive system perform an active function in scramming the control rods to rapidly shut down the reactor. Section 4.4.6 of NUREG-1482 (Rev.2) provides a discussion on the testing of individual scram valves for control rods in Boiling Water Reactors.

Section 4.4.6 of NUREG-1482 states in part "the control rod drive system valves that perform an active function in scramming the reactor are the scram discharge volume vent and drain valves, scram inlet and outlet valves, the scram discharge header check valves, the charging water header check valves and the cooling water header check valves". It is impractical to perform a full-stroke exercise of these valves to the closed position during plant operation.

Closure verification of this valve can only be performed by depressurizing the charging water header with the HCU pressurized.

An automatic scram is initiated when the charging water header pressure drops below 1157 psig for more than approximately 10 seconds. In earlier stages of the IST Program, these valves were tested in Refuel Outages only. The Justification had been that in order to perform a pressure decay test of the HCU accumulators to verify check valve closure, the control rod drive pumps had to be shutdown.

Since the control rod drive pumps had to be shutdown, the reactor recirculation pumps also had to be shutdown because reactor recirculation pump seal supply was isolated.

The shutdown of the reactor recirculation pumps would have increased the wear and stress on the pumps, increasing the number of cycles of plant equipment and possibly extend the length of the cold shutdown.

This position was similar to the NRC position identified in Section 3 .1.1.4 of NUREG-1482 regarding the stopping of reactor coolant pumps for cold shutdown valve testing. Due to process changes, the Surveillance for this testing, was changed, allowing a pressure decay test without shutting down the control rod drive pumps. The change involves the isolation of the charging water header from the pump discharge path, and pressure decay through a drain line on the charging water header. This change in procedure allows for closure testing of the HCU accumulator checks during cold shutdown periods. Alternative Frequency This valve will be full-stroke exercised closed during cold shutdown per ISTC-3522(b

). References In the LaSalle Third 10-Year IST Interval, this Cold Shutdown Justification was identified as CS-21. Revision Date: 1011212017 43 IST-LAS-PLAN Refueling Outage J ustiflcation No. RJ-01 RJ-02 RJ-03 RJ-04 RJ-05 RJ-06 RJ-07 /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 8 REFUEL OUTAGE JUSTIFICATION INDEX (Page 1 of 1) Description Drywell Nitrogen Valves Recirculation Pump Seal Flow Check Valves RVWLIS Instrument Panel Check Valves Drywell Instrument Check Valves Main Steam System Alternate Shutdown Cooling Valves RCIC System Check Valves Excess Flow Check Valves Revision Date: 1011212017 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 9 REFUEL OUTAGE JUSTIFICATIONS Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Valve Number lINOOlA lINOOlB 2IN001A 2IN001B Function Reactor Refueling .Justification -R.J-01 (Rev. 0) (Page 1 of2) System IN IN IN IN Class 2 2 2 2 Category A A A A Unit 1 1 2 2 These valves are the Drywell Instrument Nitrogen Suction Header Isolation Valves that also function as Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment (penetration M-62 on Unit 1 and penetration M-54 on Unit 2) to mitigate the consequences of an accident.

The subject valves automatically isolate on a Group 10 Containment Isolation signal. The subject valves have a non-safety function to open to allow the Drywell Pneumatic System (IN) gases to flow to support the proper operation of pneumatically controlled or operated loads located in the drywell. The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads located in the drywell during plant operation and during cold shutdowns.

The distribution of the compressed gas is via two headers. The regulated header supplies all of the system requirements in the drywell (MSIV s, main steam safety relief valves, reactor recirculation sample valves and the recirculation pump seal water control valves) with the exception of the ADS valves. The ADS valve accumulators are supplied by the unregulated header. Additionally there are safety related nitrogen bottles connected to the unregulated header outside of containment which will makeup gas to the unregulated header when pressure drops below 160 psig . .Justification In order to perform a closure test of either 1(2)IN001A or 1(2)IN001B, the compressors would have to be shutdown to avoid an automatic compressor trip or compressor damage. A shutdown of the compressors would cause the shutdown of the entire IN system and unnecessary cycling of plant equipment.

A backup gas supply from the instrument air system via 1(2)IN059 and 1(2)IN060 is available to provide backup air to operate the components such as the SRVs (non-ADS), MSIVs (inside the drywell) and the recirculation pump seal water control valves. However, use of this air supply line may cause dilution of the inerted containment atmosphere.

Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling Justification -RJ-01 (Rev. 0) (Page 2 of2) The drywell at LaSalle Country Station is inerted during plant operation as required by Technical Specification 3.6.3. It is also not practical to close these subject valves during cold shutdowns as the compressors typically remain in operation and potential dilution of the inerted containment atmosphere could result in an unnecessary delay in returning the plant to power operation in order to reestablish the required inert concentration. (Ref. NUREG 1482, Rev. 2, section 3.1.1.3).

It is therefore impractical to perform a full-stroke exercise of these subject valves during plant operation or cold shutdowns.

Alternative Test These valves will be full-stroke exercised closed during refueling outages per ISTC-3522( c ). References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-01. Revision Date: 1011212017 2 IST-LAS-PLAN Valve Number 1B33-F013A 1B33-F013B 1B33-F017A 1B33-F017B 2B33-F013A 2B33-F013B 2B33-F017A 2B33-F017B Function /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-02 (Rev. 0) (Page 1 of2) System Class Category RR 2 AIC RR 2 AIC RR 2 AIC RR 2 AIC RR 2 AIC RR 2 AIC RR 2 AIC RR 2 AIC Unit 1 1 1 1 2 2 2 2 These valves are the Reactor Recirculation Pump Seal Flow Check Valves, which also function as Containment Isolation Valves. These valves have a safety function to close to isolate the primary containment to mitigate the consequences of an accident.

These valves have a non-safety related function to open to allow CRD system water to pass to the reactor recirculation pump seal packages.

Justification It is impractical to pe1form a full-stroke exercise test of these valves during plant operation or during cold shutdowns.

These valves are in the reactor recirculation pump seal purge lines. The reactor recirculation pump seals are provided with water from the control rod drive pumps to prevent coolant flow from leaking along the reactor recirculation pump shaft out into the drywell. The seal purge provides a continuous flow of clean, cool water. It is highly desirable to maintain this flow at all times. If the seal purge flow is interrupted, a backflow of reactor coolant water may carry foreign material into the seal package, which could damage the seal surfaces and result in rapid seal wear. The seal purge line check valves are normally open dming plant operation to allow cooling flow to the reactor recirculation pump seals. During plant shutdown to Mode 4 this flow path is also maintained in order to support pump operations and seal health as described above. The only practical method of verifying the full-stroke closure capability of these valves is by seat leakage testing. It was determined in section 4.1.6 of NUREG-1482, Rev. 2, that the need to setup test equipment in order to perform a seat leakage rate test to verify valve closure is adequate justification to defer backflow testing of a check valve to a refueling outage. Revision Date: 1011212017 3 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification -RJ-02 (Rev. 0) (Page2 of2) The non-safety, bi-directional testing of these valves also requires evidence of the valves ability to travel from the closed position to an open position.

As described above, the ability to close this valve in preparation for an open test is not practical during conditions of Recirculation Pump operation or desired when RCS pressure have the potential of back flowing water containing pruticulate matter into the pump seals that could result in seal package degradation.

Alternative Test These valves will be full-stroke exercised closed during refueling outages per ISTC-3522(c). References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-02. Revision Date: 1011212017 4 IST-LAS-PLAN Valve Number 1Cll-F422B 1Cll-F422D lCl l-F422F 1Cll-F422G 1Cll-F423B lCl l-F423D lCl 1-F423F 1Cll-F423G 2Cll-F422B 2Cl l-F422D 2Cll-F422F 2Cl 1-F422G 2Cll-F423B 2Cl l-F423D 2Cll-F423F 2Cll-F423G Function !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

• R.J -03 (Rev. 0) (Page 1of2) System RD RD RD RD RD RD RD RD RD RD RD RD RD RD RD RD Class 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 Category NC NC NC NC NC NC NC NC NC NC NC NC NC NC NC NC Unit 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 These valves are the Reactor Vessel Water Level Indication System (RVWLIS) Reference Leg Continuous Backfill Panel Check Valves, which also function as Containment Isolation Valves. These valves have a safety related function to close and limit primary containment leakage in the event of an accident and to maintain the instrument reference legs full to ensure accurate reactor water level signals and indications.

These valves have a non-safety related function to open to allow a continuous flow of water from the control rod drive system into the reactor vessel level indicating system reference legs. This backfill water is provided to prevent non-condensable gases from separating in the reference legs, which could adversely affect the indication of reactor vessel level. Justification It is impractical to perform a full-stroke exercise of the subject valves to the closed position during plant operation or during cold shutdowns.

The only practical method to verify individual valve closure is by the performance of a local leakage test to the requirement of 10 CFR 50 Appendix J and Technical Requirements Manual Technical Surveillance Requirement 3.3.n.2. This leakage test requires isolation of the reference leg backfill flow and venting and draining of piping. The isolation and draining of these Revision Date: 1011212017 5 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-03 (Rev. 0) (Page 2of2) portions of the system is not practical during plant operation.

The reference leg backfill system is designed to provide a continuous flow of water to the reactor vessel level instrument reference legs to prevent the introduction and propagation of non-condensable gases in the reference legs. The isolation of backfill flow for LLRT testing could adversely affect accuracy of the indication of reactor vessel level indication.

Reactor vessel level indication is used as an input to numerous alarms and safety actuations (main turbine trip, reactor feed pump trip, HPCS actuation, PCIS, reactor recirculation trip, reactor scram and etc.). Seat leakage testing of the subject valves during cold shutdowns is also impractical.

As stated above, local leakage rate testing of the subject valves requires the isolation of the reference backfill lines, venting and draining of piping and the installation of test equipment.

It was determined in section 4.1.6 of NUREG-1482, Rev. 2, that the need to setup test equipment in order to perform a seat leakage rate test to verify valve closure is adequate justification to defer backflow testing of a check valve to a refueling outage. Bi-directional exercising requirements of ISTC-3522(a) are satisfied in the open direction during the fill and vent process of leak rate testing on a refuel outage frequency.

A refuel frequency for the open exercise testing is justified by ISTC-3522(a), which states that open and close tests need only be performed at an interval when it is practicable to pe1form both tests. Alternative Test These valves will be full-stroke exercised closed during refueling outages per ISTC-3522(c). References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-03. Revision Date: 1011212017 6 IST-LAS-PLAN Valve Number 1IN043 1IN044 2IN043 2IN044 Function !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling Justification

-RJ-04 (Rev. 0) (Page 1of2) System Class Category IN 3 c IN 3 c IN 3 c IN 3 c Unit 1 1 2 2 Valves 1(2)IN043 and 1(2)IN044 are the A and BADS Accumulator Unregulated Nitrogen Header Drywell Supply Check Valves and have the safety related function to close to prevent the safety related nitrogen supply gas from the nitrogen bottle bank from being lost through the non-safety related IN header. The nitrogen bottle banks are used only when the normally operating IN system is incapable of meeting the ADS valve accumulator pressure requirements.

These subject valves have a non-safety related function to open to allow the Drywell Pneumatic System (IN) gases to flow to support the proper operation of pneumatically controlled or operated loads located in the drywell . .Justification It is not practical to perform a full-stroke exercise of the subject valves during plant operation or during cold shutdowns.

The purpose of the IN system is to supply instrument quality compressed gas for the continuous operation of pneumatically controlled or operated loads located in the drywell during plant operation and during cold shutdowns.

The distribution of the compressed gas is via two headers. The regulated header supplies all of the system requirements in the drywell (MSIV s, main steam safety relief valves, reactor recirculation sample valves, recirculation pump seal water control valves and RHR, RCIC, Revision Date: 1011212017 7 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-04 (Rev. 0) (Page 2 of2) HPCS and LPCS testable check valves) with the exception of the ADS valves. The ADS valve accumulators are supplied by the unregulated header. Additionally there are safety related nitrogen bottles connected to the unregulated header outside of containment which will makeup gas to the unregulated header when pressure drops below 160 psig. The only practical method to perform a full-stroke closure exercise test of valves 1(2)1N043 and 1(2)IN044 is to perform a seat leakage type test. The ADS valves are required to be operable in Modes 1, 2 and 3 as required by Technical Specification 3.4.4. In order to manipulate the test connection valves and block valves to their proper position to perform a leakage rate test of these subject valves, the un-regulated gas supply to the ADS valves must be isolated.

In addition, in order to perform leakage rate testing of the subject valves, test equipment would have to be setup. In section 4.1.6 of NUREG-1482, Rev. 2, it was determined that the need to setup test equipment is adequate justification to defer backflow testing of a check valve to a refueling outage. Alternative Test These valves will be full-stroke exercised closed during refueling outages per ISTC-3522( c ). References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-04. Revision Date: 1011212017 8 IST-LAS-PLAN Valve Number 1B21-F020 1B21-F021 1B21-F070 1B21-F071 1B21-F072 1B21-F073 1B21-F418A 1B21-F418B 2B21-F020 2B21-F021 2B21-F070 2B21-F071

2B21-F072 2B21-F073 2B21-F418A 2B21-F418B Function !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling Justification

-RJ-05 (Rev. 0) (Page 1of2) System MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS Class NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS Category B B B B B B B B B B B B B B B B Unit 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 The valves are the Motor Operated valves in the Main Steam System. These valves have no safety function identified.

These valves are used to support the operation of the MSIV Alternate Leakage Treatment (ALT) path. Justification As a result of a response to an NRC comment (Comment 2.C of letter dated February 5, 1996; Responses to NRC Comments-MSIV-LCS) concerning the reliability of the alternate leakage path (including boundary valves), a commitment was made to include these subject valves in the IST program. While inclusion into the IST Program would typically prescribe that these valves be tested in accordance with ISTC-5100, and require that power operated valves be tested in accordance with the applicable requirements of ISTC-3000, which is nominally every 3 months, the commitment specifically states that these valves need only be full-stroke exercised once each refueling outage. Revision Date: 1011212017 9 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-R.J-05 (Rev. 0) (Page 2 of2) It should also be stated that per, Section 2.2.4 of NUREG-1482, Rev. 2, if a commitment is made to include a component in the IST program, the component is considered to be within the scope of the program. Alternative Test The subject valves shall be full-stroke exercised open and closed each refueling outage as identified in the above identified commitment.

References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-05. Revision Date: 1011212017 10 IST-LAS-PLAN Valve Number 1E51-F030 2E51-F030 Function /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-06 (Rev.1) (Page 1of2) System RI RI Class 2 Category c 2 c Unit 1 2 These valves are the RCIC Pump Suppression Pool Suction Check Valves. These valves have a safety related function to open to provide a suction flow path from the suppression pool to the RCIC pump. These valves also have a safety related function to close to prevent the backflow of water from the RCIC suction line into either the suppression pool or Cycled (CY) Condensate Storage Tank (CST) thereby maintaining the injection header filled and pressurized.

Justification In order to full open exercise these valves, a full-flow test of the RCIC Pump while taking suction from the Suppression Pool is required.

Quarterly full flow testing of the RCIC Pump is performed taking suction from the CST and discharging flow back to the CST via procedures LOS-RI-Q3 or LOS-RI-Q5.

In order to transfer suction to the Suppression Pool, a discharge flow path large enough must also be established to handle RCIC full flow back to the Suppression Pool. During Modes 1-3, this would require the installation of the blind side of a spectacle flange in the return line to the CY Tank in order to maintain Primary Containment integrity, opening locked closed, manually operated Containment Isolation Valves 1(2)E51-F362 and 1(2)E51-F363 and lifting a lead which removes the interlock which keeps 1(2)E51-F022 and 1(2)E51-F059 closed if 1(2)E51-F031 is open. Full open testing is performed during startup after refueling by lining up from the Suppression Pool through the full flow test line to the CY Tank. This transfer requires Chemistry Department approval.

It is therefore not practical to full stroke exercise this valve quarterly or during Cold Shutdowns.

Alternative Test These valves will be full-stroke exercised open during refueling outages per ISTC-3522( c ). Revision Date: 1011212017 11 IST-LAS-PLAN References

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-06 (Rev. 1) (Page 2 of 2) In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-06. Revision Date: 1011212017 12 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling .Iustification

-RJ:-07 (Rev. 1) (Page 1 of7) Valve Number System Class Category Unit 1B21-F325A MS 2 c 1 1B21-F325B MS 2 c 1 1B21-F325C MS 2 c 1 1B21-F325D MS 2 c 1 1B21-F326A MS 2 c 1 1B21-F326B MS 2 c 1 1B21-F326C MS 2 c 1 1B21-F326D MS 2 c 1 1B21-F327A MS 2 c 1 1B21-F327B MS 2 c 1 1B21-F327C MS 2 c 1 1B21-F327D MS 2 c 1 1B21-F328A MS 2 c 1 1B21-F328B MS 2 c 1 1B21-F328C MS 2 c 1 1B21-F328D MS 2 c 1 1B21-F344 NB 2 c 1 1B21-F346 NB 2 c 1 1B21-F348 NB 2 c 1 1B21-F350 NB 2 c 1 1B21-F353 NB 2 c 1 1B21-F355 NB 2 c 1 1B21-F357 NB 2 c 1 1B21-F359 NB 2 c 1 1B21-F361 NB 2 c 1 1B21-F363 NB 2 c 1 1B21-F370 NB 2 c 1 1B21-F372 NB 2 c 1 1B21-F374 NB 2 c 1 1B21-F376 NB 2 c 1 1B21-F378 NB 2 c 1 1B21-F413A RI 2 c 1 1B21-F413B RI 2 c 1 1B21-F415A RI 2 c 1 1B21-F415B RI 2 c 1 Revision Date: 1011212017 13 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling .Iustification

-RI-07 (Rev.1) (Page 2 of7) Valve Number System Class Category Unit 1B21-F437 NB 2 c 1 1B21-F439 NB 2 c 1 1B21-F441 NB 2 c 1 1B21-F443 NB 2 c 1 1B21-F445A NB 2 c 1 1B21-F445B NB 2 c 1 1B21-F447 NB 2 c 1 1B21-F449 NB 2 c 1 1B21-F451 NB 2 c 1 IB21-F453 NB 2 c I IB21-F455A NB 2 c 1 IB21-F455B NB 2 c 1 1B21-F457 NB 2 c 1 IB21-F459 NB 2 c 1 1B21-F461 NB 2 c 1 1B21-F463 NB 2 c 1 1B21-F465A NB 2 c 1 1B21-F465B NB 2 c 1 1B21-F467 NB 2 c 1 1B21-F469 NB 2 c 1 1B21-F471 NB 2 c 1 1B21-F473 NB 2 c 1 1B21-F475A NB 2 c 1 1B21-F475B NB 2 c 1 1B21-F570 NB 2 c 1 1B21-F571 NB 2 c 1 1B33-F301A RR 2 c 1 1B33-F301B RR 2 c 1 1B33-F305A RR 2 c 1 1B33-F305B RR 2 c 1 1B33-F305C RR 2 c 1 1B33-F305D RR 2 c 1 1B33-F307A RR 2 c 1 1B33-F307B RR 2 c 1 1B33-F307C RR 2 c 1 1B33-F307D RR 2 c 1 1B33-F311A RR 2 c 1 1B33-F311B RR 2 c 1 1B33-F311C RR 2 c 1 1B33-F311D RR 2 c 1 Revision Date: 1011212017 14 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling Justification

-R.I-07 (Rev.1) (Page 3 of7) Valve Number System Class Category Unit 1B33-F313A RR 2 c 1 1B33-F313B RR 2 c 1 1B33-F313C RR 2 c 1 1B33-F313D RR 2 c 1 1B33-F315A RR 2 c 1 1B33-F315B RR 2 c 1 1B33-F315C RR 2 c 1 1B33-F315D RR 2 c 1 1B33-F317A RR 2 c 1 1B33-F317B RR 2 c 1 1B33-F319A RR 2 c 1 1B33-F319B RR 2 c 1 1E12-F315 RH 2 c 1 1E12-F317 RH 2 c 1 1E12-F319 RH 2 c 1 1E12-F359A RH 2 c 1 1E12-F359B RH 2 c 1 1E12-F360A RH 2 c 1 1E12-F360B RH 2 c 1 1E21-F304 LP 2 c 1 1E22-F304 HP 2 c 1 1G33-F309 RT 2 c 1 1G33-F312A RT 2 c 1 1G33-F312B RT 2 c 1 2B21-F325A MS 2 c 2 2B21-F325B MS 2 c 2 2B21-F325C MS 2 c 2 2B21-F325D MS 2 c 2 2B21-F326A MS 2 c 2 2B21-F326B MS 2 c 2 2B21-F326C MS 2 c 2 2B21-F326D MS 2 c 2 2B21-F327A MS 2 c 2 2B21-F327B MS 2 c 2 2B21-F327C MS 2 c 2 2B21-F327D MS 2 c 2 2B21-F328A MS 2 c 2 2B21-F328B MS 2 c 2 2B21-F328C MS 2 c 2 2B21-F328D MS 2 c 2 Revision Date: 1011212017 15 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification-RI-07 (Rev.1) (Page4 of7) Valve Number System Class Category Unit 2B21-F344 NB 2 c 2 2B21-F346 NB 2 c 2 2B21-F348 NB 2 c 2 2B21-F350 NB 2 c 2 2B21-F353 NB 2 c 2 2B21-F355 NB 2 c 2 2B21-F357 NB 2 c 2 2B21-F359 NB 2 c 2 2B21-F361 NB 2 c 2 2B21-F363 NB 2 c 2 2B21-F370 NB 2 c 2 2B21-F372 NB 2 c 2 2B21-F374 NB 2 c 2 2B21-F376 NB 2 c 2 2B21-F378 NB 2 c 2 2B21-F413A RI 2 c 2 2B21-F413B RI 2 c 2 2B21-F415A RI 2 c 2 2B21-F415B RI 2 c 2 2B21-F437 NB 2 c 2 2B21-F439 NB 2 c 2 2B21-F441 NB 2 c 2 2B21-F443 NB 2 c 2 2B21-F445A NB 2 c 2 2B21-F445B NB 2 c 2 2B21-F447 NB 2 c 2 2B21-F449 NB 2 c 2 2B21-F451 NB 2 c 2 2B21-F453 NB 2 c 2 2B21-F455A NB 2 c 2 2B21-F455B NB 2 c 2 2B21-F457 NB 2 c 2 2B21-F459 NB 2 c 2 2B21-F461 NB 2 c 2 2B21-F463 NB 2 c 2 2B21-F465A NB 2 c 2 2B21-F465B NB 2 c 2 2B21-F467 NB 2 c 2 2B21-F469 NB 2 c 2 2B21-F471 NB 2 c 2 Revision Date: 1011212017 16 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling .Iustification

-RJ:-07 (Rev.1) (Page 5 of7) Valve Number System Class Category Unit 2B21-F473 NB 2 c 2 2B21-F475A NB 2 c 2 2B21-F475B NB 2 c 2 2B21-F570 NB 2 c 2 2B21-F571 NB 2 c 2 2B33-F301A RR 2 c 2 2B33-F301B RR 2 c 2 2B33-F305A RR 2 c 2 2B33-F305B RR 2 c 2 2B33-F305C RR 2 c 2 2B33-F305D RR 2 c 2 2B33-F307A RR 2 c 2 2B33-F307B RR 2 c 2 2B33-F307C RR 2 c 2 2B33-F307D RR 2 c 2 2B33-F311A RR 2 c 2 2B33-F311B RR 2 c 2 2B33-F311C RR 2 c 2 2B33-F311D RR 2 c 2 2B33-F313A RR 2 c 2 2B33-F313B RR 2 c 2 2B33-F313C RR 2 c 2 2B33-F313D RR 2 c 2 2B33-F315A RR 2 c 2 2B33-F315B RR 2 c 2 2B33-F315C RR 2 c 2 2B33-F315D RR 2 c 2 2B33-F317A RR 2 c 2 2B33-F317B RR 2 c 2 2B33-F319A RR 2 c 2 2B33-F319B RR 2 c 2 2E12-F315 RH 2 c 2 2E12-F317 RH 2 c 2 2E12-F319 RH 2 c 2 2E12-F359A RH 2 c 2 2El2-F359B RH 2 c 2 2E12-F360A RH 2 c 2 2E12-F360B RH 2 c 2 2E21-F304 LP 2 c 2 2E22-F304 HP 2 c 2 2G33-F309 RT 2 c 2 2G33-F312A RT 2 c 2 2G33-F312B RT 2 c 2 Revision Date: 1011212017 17 IST-LAS-PLAN Function /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Reactor Refueling Justification

-RJ-07 (Rev.1) (Page 6 of7) These valves are excess flow check valves that function to provide the process fluid to their support instrument.

These valves have a safety function to perform as Containment Isolation valves in that they act to minimize the loss of fluid through them following a break in the instrument line downstream from the valve. These valves have a non-safety related function to open to allow for continued operation of their supported downstream instrument.

Justification It is impractical to full-stroke exercise excess flow check valves to the closed position during plant operation or during cold shutdowns.

These valves are controlled leakage check valves, which are designed to automatically close in the event of a downstream line rupture. Upon closing, these valves are designed to allow a controlled leakage. Exercising these valves requires that the instrumentation tubing downstream of each EFCV be depressurized or drained (as applicable) and the closure function verified by change in the amount of flow and/or verification of an audible click when the poppet seats. Draining or depressurizing the downstream side of these valves will separate the subject instrument from its source. These instruments provide indication of a large number of essential plant operational parameters.

This instrumentation supplies input to a large number of reactor protection type actuations such as ECCS initiation, Primary Containment Isolation, Secondary Containment Isolation, etc. Isolation and testing of the subject valves during plant operation would render their respective instrumentation inoperable and could cause an unexpected plant transient, equipment actuations or a plant scram. Additionally, the performance of this closure test requires the installation of test equipment to monitor the expected change in flow when the valve moves to the check position.

It was determined in section 4.1.6 of NUREG-1482, Rev. 2, that the need to setup test equipment in order to verify valve closure is adequate justification to defer backflow testing of a check valve to a refueling outage. Revision Date: 1011212017 18 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Reactor Refueling Justification

-RJ-07 (Rev.1) (Page 7 of7) The non-safety, bi-directional testing of these valves also requires evidence of the valves ability to travel from the closed position to an open position.

As described above, the ability to close this valve in preparation for an open test is not practical until conditions allow for the closure of the valve. Therefore evidence of an open test cannot be collected until following the performance of a closed test, which is performed on a refueling frequency.

Alternative Test These valves will be full-stroke exercised closed during refueling outages per ISTC-3522(c). Evidence of the valves ability to open is satisfied with the return to service verification of the valves supported instrument function as described in Technical Position TP-10. References In the LaSalle Third 10-Year IST Interval, this Refueling Justification was identified as RJ-07. Revision Date: 1011212017 19 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 10 CHECK VALVE CONDITION MONITORING PLANS BASIS INDEX (Page 1 of 1) H2 Recombiner R Revision Date: 1011212017 1 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 11 CHECK VALVE CONDITION MONITORING PLANS BASIS Revision Date: 1011212017 1 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-01 (Rev. 1) (Page 1of3) Valve Number System Class Category Unit 1E12-F046A RH 2 c 1E12-F046B RH 2 c 2E12-F046A RH 2 c 2E12-F046B RH 2 c Function These check valves must open to provide a flow path for the RHR pumps when circulating on minimum flow to prevent overheating and potential damage. 1 1 2 2 These valves are located between their associated Containment Penetration and their associated minimum-flow recirculation isolation valve. Although from a practical perspective, these valves would close to function as Containment Isolation Valves in the event of an ECCS failure following an accident, they are not credited as CIV s because 10 CFR 50, Appendix A, General Design Criterion 56 does not permit the use of a simple check valve as the outer Containment Isolation Valve. The CIV function is satisfied by the minimum-flow recirculation isolation valves . .Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 1 OCFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-01 as maintained in the LaSalle Inservice Testing Program Bases Documents.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Revision Date: 1011212017 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-01 (Rev. 1) (Page 2 of3) Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-01 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-01: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

PARTIAL STROKE OPEN Partial stroke open is performed quarterly per LOS-RH-Ql by verification of flow noise through the valves upon pump start. DISASSEMBLY AND Disassembled and inspected the valve per LMP-RH-INSPECTION 04 every third outage. This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plan for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-01 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-01 documents the analysis and basis for the check valve condition monitoring program for these valves. Revision Date: 1011212017 2 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-01 (Rev.1) (Page 3 of3) d. LaSalle Check Valve Condition Monitoring Plan Group CM-01 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-01 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 3 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-02 (Rev. 1) (Page 1of3) Valve Number System Class Category IHG007 HG 2 c IHG016 HG 2 c 2HG007 HG 2 c 2HG016 HG 2 c Function Unit I I 2 2 These check valves must open to provide a flow path from its unit's drywell to either its unit's hydrogen recombiner or the opposite unit's recombiner to allow cross connecting.

One recombiner system is provided for each nuclear unit. Each recombiner has the capability of serving either containment; therefore, there is I 00% redundancy of all components and controls [UFSAR 6.2.5.2].

These valves are not required to close since the hydrogen recombiner upstream and downstream isolation valves are closed to prevent cross connecting both containments when the opposite unit's drywell is supplying the opposite unit's recombiner.

Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in IOCFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-02 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Revision Date: 1011212017 4 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-02 (Rev.1) (Page 2 of3) Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-02 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-02: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

DISASSEMBLY AND Disassembled and inspected the valve every third INSPECTION outage. This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

FULL STROKE OPEN Full stroke open performed every refueling outage in conjunction with the applicable recombiner' s functional test. In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-02 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-02 documents the analysis and basis for the check valve condition monitoring program for these valves. Revision Date: 1011212017 5 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-02 (Rev.1) (Page 3 of 3) d. LaSalle Check Valve Condition Monitoring Plan Group CM-02 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-02 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 6 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-03 (Rev. 0) Valve Number 2VG024A 2VG025A Function (Page 1of3) System VG VG Class 3 3 Category c c Unit 2 2 These check valves must close to prevent diversion of standby gas treatment system air flow to the service air system in the event of a break of the non-safety related service air system piping located upstream of the subject valve. These valves open to provide a flow path from the service air system to the standby gas treatment system. This function is not required for safe shutdown or accident mitigation.

Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-03 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

Revision Date: 1011212017 7 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-03 (Rev. 0) (Page 2 of3) CM-03 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-03: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

DISASSEMBLY AND Disassembled and inspected every 48 months, with INSPECTION an allowable 25% extension.

This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability ROUTINE OPERATOR Flow element 2FI-SA049 is located just upstream of ROUNDS these in-series check valve. During operating rounds, flow is verified through the flow element, further satisfying the open testing requirement for these valves. In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-03 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-03 documents the analysis and basis for the check valve condition monitoring program for these valves. Revision Date: 1011212017 8 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-03 (Rev. 0) (Page 3 of3) d. LaSalle Check Valve Condition Monitoring Plan Group CM-03 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-03 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 9 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-04 (Rev. 0) (Page 1of1) The valves in this Condition Monitoring Plan were "Abandoned-In-Place" in accordance with Engineering Change (EC) 358662 during the 2nd 10-Year IST Interval.

The Condition Monitoring Plan was retired shortly after the valves were "Abandoned-In-Place".

The list of valves included in the Plan prior to the Plan being retired are listed below and are included for historical purposes only. Valve Number 1HG017A 1HG017B 2HG017A 2HG017B Revision Date: 1011212017 System HG HG HG HG 10 Class 2 2 2 2 Category c c c c Unit 1 1 2 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-05 (Rev. 0) Valve Number 1E51-F021 2E51-F021 Function (Page 1of2) System RI RI Class 2 2 Category c c Unit 1 2 These check valves must open to provide a flow path from the RCIC pump to the suppression pool to prevent the RCIC pump from being damaged by overheating at reduced pump discharge flow [UFSAR 5.4.6, 7.4.1.2].

These valves close to isolate the suppression pool from the RCIC system. This function is not required for safe shutdown or accident mitigation since the downstream motor operated valve (E51-F019) is relied upon for isolation of the RCIC minimum flow line [UFSAR 7.4.1, Table 6.2-21]. J ustiflcation In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 1 OCFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-05 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-05 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Revision Date: 1011212017 11 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM -05 (Rev. 0) (Page2 of2) Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-05: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

PARTIAL STROKE OPEN Partial stroke open performed quarterly in conjunction with the applicable RCIC pump test. DISASSEMBLY AND Disassembled and inspected every third outage. INSPECTION This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-05 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-05 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-05 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-05 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 12 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-06 (Rev. 0) Valve Number 1E12-F089 2E12-F089 Function (Page 1of2) System RH RH Class 2 2 Category c c Unit 1 2 These valves must open to provide a flow path from the fuel pool emergency make-up pump to containment for containment flooding.

These valves close to prevent flow from the discharge of RHR Pump E12-C002B from being diverted when required to perform a safety-related function (i.e., LPCI, Suppression Pool Cooling, Containment Cooling) in the event of a loss of system integrity on the upstream side. Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-06 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-06 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Revision Date: 1011212017 13 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-06 (Rev. 0) (Page 2 of2) Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-06: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

DISASSEMBLY AND Disassembled and inspected the valve every third INSPECTION outage. This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-06 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-06 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-06 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-06 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 14 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-07 (Rev. 0) Valve Number 1B33-F395 2B33-F395 Function (Page 1 of2) System RR RR Class 2 2 Category NC NC Unit 1 2 These check valves are installed to relieve pressure that could develop from the thermal expansion of trapped fluid between containment isolation valves B33-F019 and B33-F020. These valves open to relieve overpressure and prevent piping rupture. These valves must close to isolate primary containment.

These valves are required to provide containment isolation for penetration M-36 [UFSAR Table 6.2-21]. Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-07 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities. The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-07 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Revision Date: 1011212017 15 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-07 (Rev. 0) (Page2 of2) Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with this valve group CM-07: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

OPEN AND CLOSE Verify the ability of the valve to physically Open EXERCISE and Close every third outage. LEAKRATE TESTING Leak rate on the Appendix J Program frequency.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-07 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-07 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-07 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-07 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 16 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-08 (Rev.1) (Page 1of3) Valve Number System Class Category ODG002 DG 3 c 1DG002 DG 3 c 1E22-F028 HP 3 c 2DG002 DG 3 c 2E22-F028 HP 3 c Function Unit Common 1 1 2 2 These check valves are the discharge pump check valves for the Division 1 and 2 DG Cooling Water Pumps and Division 3 HPCS DG Cooling Water Pumps. These valves must open to provide flow to their respective cooling loads. The cooling water flow removes heat to maintain the environmental qualification of and to prevent damage to the essential equipment and ensures a reliable onsite power source for Division 1, 2 and 3 loads. These check valves must close to prevent reverse rotation of the idle cooling water pump due to backflow from other operating cooling water pumps that share a common lake discharge path . .Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-08 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan Revision Date: 1011212017 17 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-08 (Rev.1) (Page 2 of3) documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-08 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-08: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

OPEN EXERCISE Exercise open performed quarterly in conjunction with the applicable pump test. DISASSEMBLY AND Disassembled and inspected every 4 years. This INSPECTION activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-08 documents the date and basis for inclusion of these valves in condition monitoring.

Revision Date: 1011212017 18 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-08 (Rev. 1) (Page 3 of3) c. LaSalle Check Valve Condition Monitoring Plan Group CM-08 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-08 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-08 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 19 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-09 (Rev. 0) Valve Number 1IN018 2IN018 Function (Page 1of3) System IN IN Class 2 2 Category NC NC Unit 1 2 These check valves must close to isolate containment from the Drywell Pneumatic system. These valves provides containment isolation for penetration M-60 (Unit 1) and M-54 (Unit 2) [UFSAR Table 6.2-21]. These valves are normally open to provide a flow path to the MSIVs and SRVs accumulators.

This function is not required for safe shutdown or accident mitigation since the drywell pneumatic supply is not safety related [UFSAR 9.3.1.3] . .Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-09 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-09 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Revision Date: 1011212017 20 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-09 (Rev. 0) (Page 2 of3) Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-09: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

OPEN EXERCISE Verify the ability of the valve to Open is accomplished quarterly in conjunction with the quarterly stroke testing of the Rx Recirc Loop Process Sampling Inboard Isolation Valves (B33-F019) and partial stroke test of the MS IVs, which results in the need to replenish nitrogen in the MSIV, which results in flow through these check valves. LEAKRATE TESTING Leak rate data trend on the Appendix J Program frequency.

This satisfies the closed bi-directional testing requirement of Mandatory Appendix II. In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-09 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-09 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-09 documents the failure and maintenance history patterns for the subject valves. Revision Date: 1011212017 21 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-09 (Rev. 0) (Page3 of3) e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-09 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 22 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-10 (Rev. 0) Valve Number IE51-F028 2E51-F028 Function (Page 1 of3) System RI RI Class 2 2 Category NC NC Unit 1 2 These valves are the RCIC Condenser Vacuum Pump Discharge Check Valves and must close to isolate containment from the RCIC system. These valves are considered containment isolation valves for Penetration M-81. [UFSAR Table 6.2-21] These valves open to provide a flow path for the RCIC turbine barometric condenser vacuum pump exhaust to the suppression pool. The RCIC barometric condenser operates to maintain a vacuum on the turbine seals to prevent steam leakage into the RCIC room. The RCIC barometric condenser, vacuum pump, and condensate pump are non-safety, non-code components.

Thus, this valve is not required to open for RCIC operability . .I ustification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 1 OCFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-10 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

Revision Date: 1011212017 23 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-10 (Rev. 0) (Page 2 of3) CM-10 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-10: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

OPEN EXERCISE Verify the ability of the valve to Open is accomplished quarterly in conjunction with the performance of the Condenser Vacuum Pump test. DISASSEMBLY AND Disassembled and inspected every other outage. INSPECTION This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

CLOSE EXERCISE Verify the ability of the valve to Close at the Appendix J testing frequency.

LEAK RATE TESTING Leak rate performed on the Appendix J Program frequency.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

Revision Date: 1011212017 24 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval b. LaSalle Check Valve Condition Monitoring Plan Group CM-10 documents the date and basis for inclusion of these valves in condition monitoring.

Revision Date: 1011212017 25 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-10 (Rev. 0) (Page 3 of3) c. LaSalle Check Valve Condition Monitoring Plan Group CM-10 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-10 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-10 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 26 IST-LAS-PLAN IST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-11 (Rev. 0) Valve Number 1E51-F040 2E51-F040 Function (Page 1 of2) System RI RI Class 2 2 Category Af C A/C Unit 1 2 These valves are the RCIC Turbine Exhaust Check Valves that must open to provide a flow path from the RCIC turbine exhaust to the suppression pool during RCIC operation

[UFSAR 5.4.6.3].

These valves must close to isolate containment from the RCIC system. These valves are considered a containment isolation valve for Penetration M-76. [UFSAR Table 6.2-21]. Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-11 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-11 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Revision Date: 1011212017 27 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-11 (Rev. 0) (Page 2 of2) Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-11: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

PARTIAL OPEN EXERCISE Verify the ability of the valve to Partially Open is accomplished quarterly in conjunction with the performance of the RCIC Pump test LOS-RI-Q3/5 CLOSE EXERCISE Verify the ability of the valve to Close at the Appendix J testing frequency.

LEAK RATE TESTING Leak rate on the Appendix J Program frequency.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-11 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-11 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-11 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-11 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 28 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-12 (Rev. 0) (Page 1of1) This Condition Monitoring Plan was discontinued during the 2nd 10-Year IST Interval and the valves returned to traditional ISTC testing. The list of valves included in the Plan prior to the Plan being discontinued are listed below and are included for historical purposes only. Valve Number 1C41-F006 1C41-F007 1C41-F006 1C41-F007 Revision Date: 1011212017 System SC SC SC SC 29 Class 1 1 1 1 Category AC AC AC AC Unit 1 1 2 2 IST-LAS-PLAN IST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-13 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 30 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-14 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 31 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-15 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 32 !ST-LAS-PLAN

/ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-16 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 33 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-17 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 34 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-18 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 35 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-19 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 36 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-20 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 37 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-21 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 38 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-22 (Rev. 0) (Page 1of1) Reserved for future use Revision Date: 1011212017 39 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-23 (Rev. 0) Valve Number 1E12-F046C 2E12-F046C Function (Page 1of3) System RH RH Class 2 2 Category c c Unit 1 2 These valves are the C RHR Pump Min Flow Line Check Valves that must open to provide a flow path for the C RHR pump when running on minimum flow to prevent overheating and potential damage. These valves are located between Containment Penetration M-84 (Train B & C) and the minimum-flow recirculation isolation valve (E12-F064).

Although from a practical perspective, these valves would function as a Containment Isolation Valves in the event of an ECCS failure following an accident, they are not credited as a CIV because 10 CFR 50, Appendix A, General Design Criterion 56 does not permit the use of a simple check valve as the outer Containment Isolation Valve. The CIV function is satisfied by the minimum-flow recirculation isolation valve (El2-F064). These valves must close to prevent reverse flow from the other RHR trains from being misdirected into the C RHR flow path when the C RHR pump is idle when E12-F064 is open. Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Revision Date: 1011212017 40 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-23 (Rev. 0) (Page 2 of3) Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-23 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies the attributes for trending.

CM-23 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-23: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

PARTIAL STROKE OPEN Partial stroke open performed quarterly in conjunction with the applicable RHR pump test. Verification of "flow noise" by observer.

DISASSEMBLY AND Disassembled and inspected the valve every third EXAMINATION outage. This activity will inspect for worn, loose, or deformed parts and verify the open and closed capability.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements ofISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: Revision Date: 1011212017 41 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-23 (Rev. 0) (Page3 of3) a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-23 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-23 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-23 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-23 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 42 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-24 (Rev. 0) (Page 1of2) Valve Number System Class Category 1E51-F082 RI 2 c 1E51-F084 RI 2 c 2E51-F082 RI 2 c 2E51-F084 RI 2 c Function Unit 1 1 2 2 These valves are the RCIC Turbine Exhaust Vacuum Breaker Downstream and Upstream Check Valves. These valves must open to provide a flow path from the suppression chamber to the RCIC system exhaust line to equalize pressure and prevent vacuum formation in the exhaust line [UFSAR 6.2.4.2.3].

These valves must close to the prevent flow of steam into the suppression chamber air space during turbine operation.

This function ensures that the RCIC steam exhaust is directed to and condensed in the suppression pool [UFSAR 6.2.4.2.3] . .Justification In accordance with ASME OM Code Appendix II, these valves are included in the station Check Valve Condition Monitoring Program. The following describes the basis for grouping the valves, failure analysis, maintenance and testing history, and planned condition monitoring activities.

This plan meets the requirements of Appendix II of the ASME OM Code 2004/2006a including the limitations set forth by the NRC in 10CFR50.55a.

The intended purpose of the condition monitoring activities for the subject valves is the optimization of testing, examination and preventive maintenance activities.

An analysis of the test and maintenance history has determined that the grouping of these valves is justified.

This group of check valves has the same design characteristics, is installed in the same application, and experience similar service conditions.

Analysis Reference For the Condition Monitoring analysis and justification details for this group of valves, refer to LaSalle Check Valve Condition Monitoring Plan Group CM-24 as maintained in the LaSalle Inservice Testing Program Bases Document.

This Condition Monitoring Plan documents the analysis performed that determined the groupings, specifies inservice tests, and lists any preventive maintenance activities.

The Condition Monitoring Plan then identifies the intervals associated with the designated activities and identifies Revision Date: 1011212017 43 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Check Valve Condition Monitoring Plan Basis CM-24 (Rev. 0) (Page 2 of2) the attributes for trending.

CM-24 also documents the maintenance history and industry review along with the failure modes expected for this valve group. Condition Monitoring Activities The information in this section satisfies the requirements of ASME OM Code 2004/2006a, Appendix II section II-4000(b

), Optimization of Condition Monitoring Activities.

The following details the condition monitoring activities and their implementation frequencies associated with valve group CM-24: ASSESSMENT TREND PARAMETER AND FREQUENCY TECHNIQUES:

OPEN EXERCISE Verify the ability of the valve to Open is accomplished on a two refueling outage frequency with the performance of LTS-100-20.

CLOSE EXERCISE Verify the ability of the valve to Open is accomplished on a two refueling outage frequency with the performance of LTS-100-20.

In accordance with ASME OM Code ISTC-5222 and 10CFR50.55a, if for any reason the condition monitoring plans for this group of valves is discontinued, then the requirements of ISTC-3510, ITSC-3520, ISTC-3540, and ISTC-5221 shall apply to the applicable valve(s).

Compliance This plan meets the documentation requirements of Appendix II of the ASME OM Code as follows: a. This Plan Basis documents the valves included in the group for Condition Monitoring.

b. LaSalle Check Valve Condition Monitoring Plan Group CM-24 documents the date and basis for inclusion of these valves in condition monitoring.

c. LaSalle Check Valve Condition Monitoring Plan Group CM-24 documents the analysis and basis for the check valve condition monitoring program for these valves. d. LaSalle Check Valve Condition Monitoring Plan Group CM-24 documents the failure and maintenance history patterns for the subject valves. e. This Plan Basis and LaSalle Check Valve Condition Monitoring Plan Group CM-24 document the condition monitoring activities, attributes and bases for the intervals for each of the valves included in this Plan Basis. Revision Date: 1011212017 44 IST-LAS-PLAN Technical Position No. TP-01 TP-02 TP-03 TP-04 TP-05 TP-06 TP-07 TP-08 TP-09 TP-10 TP-11 TP-12 TP-13 /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 12 STATION TECHNICAL POSITION INDEX Description Bi-directional Testing of Check Valves Passive Valves without Test Requirements Fail Safe Testing of Valves Manual Valve Exercise Frequency Check Valves in Regular Use Categorization of IST Pumps (Group A or B) Water Leg Pump Check Valves Thermal Relief Valves Classification of Skid-mounted Components Excess Flow Check Valve Testing Testing of Power Operated Valves with Both Active and Passive Safety Functions.

Cold Shutdown Testing Comprehensive Pump Testing Reference Point Determination Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval ATTACHMENT 13 STATION TECHNICAL POSITIONS Revision Date: 1011212017 IST-LAS-PLAN

/ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-01 (Rev. 0) (Page 1 of 3) Bi-directional Testing of Check Valves with Non-Safety Positions Purpose The purpose of this Technical Position is to establish the station pos1t1on for the verification of the non-safety direction exercise testing of check valves by normal plant operations.

Applicability This Technical Position is applicable to those valves that are included in the Inservice Testing Program whose open or close function is a non-safety function.

This position applies to those check valves required to be tested in accordance with Subsection ISTC (ASME OM Code 2004 Edition through 2006 Addenda) and Appendix II. This Technical Position does not apply to testing of the safety function (direction) of check valves included in the Inservice Testing Program. Background The ASME OM Code 2004 through 2006 Addenda section ISTC-3550, "Valves in Regular Use", states: "Valves that operate in the course of plant operation at a frequency that would satisfy the exercising requirements of this Subsection need not be additionally exercised, provided that the observations otherwise required for testing are made and analyzed during such operation and recorded in the plant record at intervals no greater than specified in ISTC-3510." Section ISTC-3510 requires that check valves shall be exercised nominally every 3 months with exceptions (for extended periods) referenced.

Section ISTC-3522(a) requires that each check valve exercise test shall include open and close tests. Section ISTC-5221(a)(2) states: "Check valves that have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled to either the full open position or to the position required to perform its intended function(s) (see ISTC-1100), and verify closure." Revision Date: 1011212017

!ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-01 (Rev. 0) (Page 2 of 3) Section ISTC-522l(a)(3) states: "Check valves that have a safety function in only the close direction shall be exercised by initiating flow and observing that the obturator has traveled [to] at least the partially open position, 3 and verify that on cessation or reversal of flow, the obturator has traveled to the seat." " 3 The partially open position should correspond to the normal or expected system flow." Appendix II Section II-4000 requires that valve obturator movement during applicable test or examination activities shall be sufficient to determine the bidirectional functionality of the moving parts. Normal and/or expected system flow may vary with plant configuration and alignment.

LaSalle Country Station Operations staff is trained in recognizing normal plant conditions.

For check valves that have a non-safety related function in the open position, Operator judgment has been deemed acceptable in determining whether or not the normal or expected flow rates for plant operation has been obtained.

For check valves that have a non-safety related function in the closed position, Operator judgment is also deemed acceptable in determining whether or not flow cessation has occurred resulting in obturator travel to the closed position.

Position LaSalle County Station will verify the non-safety position of check valves included in the Inservice Testing Program using the plant surveillance program. In lieu of a dedicated surveillance to perform the non-safety direction testing, the following alternate verifications may be performed as follows: 1. An appropriate means shall be determined which establishes the method for validating the open/closed non-safety function of the check valve during normal operations.

The validation may be by direct indicator, or by other positive means such as changes in system pressure, flow rate, level, temperature, seat leakage, etc. Revision Date: 1011212017 2 IST-LAS-PLAN

!ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Technical Position TP-01 (Rev. 0) (Page 3 of 3) 2. Verification that a check valve is satisfying its non-safety direction function may be accomplished by observation and/or analysis of plant activities.

For an example, consider a check valve that has a safety function only in the closed direction and normally provides a flow path to maintain plant operations.

If this check valve does not open to pass flow when required, an alarm or indication would identify a problem to the operator.

The operator would respond by taking the appropriate actions. An Issue Report would then be generated for the abnormal plant condition, which would identify the check valve failure. 3. Observation and analysis of plant logs and other records is an acceptable method for verifying a check valve's non-safety direction function verification during normal plant operations.

The performance of the open/closed non-safety function shall be recorded at a frequency required by ISTC-3510, nominally every 3 months, (with exceptions as allowed), in plant records such as the LaSalle County Station Operating Logs, Electronic Rounds, chart recorders, automated data loggers, surveillances, etc. Records as indicated above in 1 through 3 are satisfactory for the non-safety direction testing. An Issue Report shall be generated for any issues regarding check valve operability.

Justification This Technical Position establishes the acceptability of the methods used in determining the ability of a valve to satisfy its non-safety function.

Through normal plant system operation and Operator actions, a valve's non-safety function can be verified through either observation or analysis of plant records and logs. Additionally, the recording of parameters that demonstrate valve position will take place at a frequency to meet the frequency requirements of ISTC-3510.

These actions collectively demonstrate the safety position of Inservice Testing Program check valves in regular use as required by ISTC-3550.

History In the LaSalle Third 10-Year IST Interval, the Technical Position addressing testing of check valves with non-safety positions was Technical Position TP-01. Revision Date: 1011212017 3 IST-LAS-PLAN Purpose !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-02 (Rev. 0) (Page 1of2) Passive Valves Without Test Requirements The purpose of this Technical Position is to establish the station position for valves with passive safety functions.

Applicability This Technical Position is applicable to valves with a passive function in accordance with ISTA-2000 and do not have inservice testing requirements per Table ISTC-3500-1.

This position is typical of Category B, passive valves that do not have position indication.

An example is a manual valve that must remain in its normal position during an accident to perform its intended function.

Typically, manual valves that perform a safety function are maintained in their safety position and administratively controlled by LaSalle County Station procedures.

These valves would be considered passive. If they do not have remote position indicating systems and are categorized as B, they would not be subjected to any test requirements in accordance with Table ISTC-3500-1.

Position The LaSalle County Station Inservice Testing Program, Valve Tables -Attachment 17, will not list valves that meet the following criteria.

• The valve is Category B in accordance with ISTC-1300 (seat leakage in the closed position is inconsequential for fulfillment of the required function(s)).

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

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

Justification Valves that meet this position will not be listed in the LaSalle County Station Inservice Testing Program, Valve Tables -Attachment

17. Revision Date: 1011212017 4 IST-LAS-PLAN History !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-02 (Rev. 0) (Page 2of2) In the LaSalle Third 10-Year IST Interval, the Technical Position addressing testing of check valves with non-safety positions was Technical Position TP-02. Revision Date: 1011212017 5 IST-LAS-PLAN Purpose !ST Program Plan LaSalle County Station Units 1 & 2, Fourth Interval Technical Position TP-03 (Rev. 0) (Page 1of2) Fail Safe Testing of Valves The purpose of this Technical Position is to establish the station position for fail safe testing of valves in conjunction with stroke time exercising or position indication testing. Applicability This Technical Position is applicable to valves with fail-safe actuators requiring testing in accordance with ISTC-3560.

Background The ASME OM Code 2004 through 2006 Addenda section ISTC-3560 requires; "Valves with fail-safe actuators shall be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510." Section ISTC-3510 states; "Active Category A, Category B, and Category C check valves shall exercised nominally every 3 months ... " Position In cases where the valve operator moves the valve to the open or closed pos1t10n following de-energizing the operator electrically, by venting air, or both, the resultant valve exercise satisfies the fail safe test requirement and an additional test specifically for fail safe testing will not be performed.

Justification Fail Safe Testing ensures the ability of the fail safe mechanism of the valve to position the valve to the fail safe position.

Whether or not the actuation of this fail safe mechanism is due to Operator Action or failure of either the valve's air or electric power source, the resultant action of the valve will be the same. Therefore, credit for the verification of a valve's fail safe ability can be taken based on the successful performance of either stroke time exercising or position indication testing. Revision Date: 1011212017 6 !ST-LAS-PLAN History !ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-03 (Rev. 0) (Page 2 of 2) Fail Safe Testing of Valves In the LaSalle Third 10-Year IST Interval, the Technical Position addressing the fail safe testing of valves was Technical Position TP-03. Revision Date: 1011212017 7 !ST-LAS-PLAN

!ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-04 (Rev. 0) (Page 1 of 1) This Technical Position is intentionally left blank. Revision Date: 1011212017 8 IST-LAS-PLAN Purpose /ST Program Plan LaSalle County Station Units I & 2, Fourth Interval Technical Position TP-05 (Rev. 0) (Page 1 of 2) Check Valves in Regular Use The purpose of this Technical Position is to establish the station position for exercise testing of check valves that are in regular use during normal plant operations.

Applicability This Technical Position is applicable to check valves that are capable of being demonstrated to be open during routine operations.

Background The ASME OM Code 2004 through 2006 Addenda section ISTC-3550, "Valves in Regular Use", states: "Valves that operate in the course of plant operation at a frequency that would satisfy the exercising requirements of this Subsection need not be additionally exercised, provided that the observations otherwise required for testing are made and analyzed during such operation and recorded in the plant record at intervals no greater than specified in ISTC-3510." Section ISTC-3510 requires that check valves shall be exercised nominally every 3 months with exceptions (for extended periods) referenced.

Normal and/or expected system flow may vary with plant configuration and alignment.

Since the LaSalle County Station Operations staff is trained so as to be able to recognize normal plant conditions, Operator judgment has been deemed acceptable for the purpose of determining check valve open demonstration by observing either normal or expected flow rates for the plant operating condition.

Position LaSalle County Station will verify the open position of these subject check valves by observing plant logs, computer systems, strip chart recorders, etc., during normal plant operations.

The open/closed safety function shall be recorded at a frequency required by ISTC-3510, nominally every 3 months, (with exceptions as provided), in plant records such as LaSalle County Station Operating Logs, Electronic Rounds, chart recorders, automated data loggers, surveillances, etc. Revision Date: 1011212017 9 IST-LAS-PLAN