ML19257C509

Recommendations to NRC for SER of Indian Point Station,Unit 2:Inservice Testing Program, Informal Rept

ML19257C509
Person / Time
Site:	Indian Point
Issue date:	09/30/1979
From:	Randy Hall, Lettieri V, Restivo T BROOKHAVEN NATIONAL LABORATORY
To:	Cheng C Office of Nuclear Reactor Regulation
References
CON-FIN-A-3117 BNL-NUREG-26860, NUDOCS 8001290266
Download: ML19257C509 (72)

Text

IllTERii1 REPORT Accession !!o.

Contract Prog' ram or Project

Title:

Inservice Testing Program Subject of this Document: Indian Point Station - Unit 2 Type of Document: Informal Report Author (s): T. Restivo, V. Lettieri, and R.E. Hall Date of Document: September 1979 Responsible 11RC Individual Dr. Cy. Cheng and IIRC Office or Division: Division of Operating Reactors

~ U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

Brookhaven flational Laboratory Upton, NY 11973 Associated Universities, Inc.

for the U.S. Department of Energy ,

Prepared for 1840 24~l U.S. Iluclear Regulatory Comission Washington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 11RC FIM !!o. A- 3117 g{

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LIMITED DISTRIBUTION

-26860 .

L.NUREG ORMAL REPORT RECOMMEiiDATIONS TO THE NRC FOR THE SAFETY EVALUATION REPORT OF INDIAN POINT STATION - UNIT 2 INSERVICE TESTING PROGRAM T. RESTIV0, V. LETTIERI, AND R.E. HALL I

hiff DATE PUBLISHED - SEPTEMBER 1979 DEPARTMENT OF NUCLEAR ENERGY BROOKHAVEN NATIONAL LABORATORY UPTON NEW YORK 11973 Prepared for the U.S. Nuclear Regulatory Commission

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Office of Nuclear Reactor Regulation

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F dd5 ,. 1JuD]df]ldlh J b i) Il N O T I C E. This report was prep.ned as an an ount of work sponsored by the United States Government. Neither ihr United States nor the United States Nuclear Reculatory g% Commission, nor any of their cmployees, nor any of their contractors, sula ontractors, c their employ ces, nukes any warraniy, es.ptcss or implied, or assumes any Iccal liability or responsibility for the as curar y,(o.apletenew or usefulness of any inf >rma-tion, apparatut product or prorcss disclosed, or reprevnts that its use wouhl not infringe pris ately ow ned righis. D

BNL-NUREG-26860 INFORMAL REPORT LU11TED DISTRIBUTION Recommendations to the NRC for the Safety Evaluation Report of Indian Point Station - Unit 2 ^ Inservice Testing Program T. Restivo, V. Lettieri, and R.L. Hal l Engineering and Advanced Reactor Safety Division Department of Nuclear Energy Brookhaven National Laboratory Upton, New York 11973 September 1979 1

                                                          ,ec ,anica t MC Researc'1 and ..

Assistance Recort Prepared for U.S. Nuclear Regulatory Commission Washi ngton, D.C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3117 1840 244

NOTICE: This document contains preliminary information and was prepared primarily for interim use. Since it may be subject to revision or correction and does not represent a final report, it should not be cited as reference without the expressed consent of the author (s). . 1840 245

TABLE OF CONTENTS E x e c u t i v e S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1.0 Pump s , I n s e rv i c e Te s ti ng P rog ram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.0 Val ve s , I n serv i ce Te sti ng P rogram. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3.0 Col d Shutdown Te sti ng of Val ve s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 4.0 Program Breakdown................................................ 50 5.0 Mi sc el l a n e ou s C omme n ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3 Conclusion............................................................ 65 a h andTechnicai MRC5sResystance Report 1840 246 i

Brookhaven National Laboratory Recommendations to the NRC for the Safety Evaluation Report of Indian Point Station, Unit 2 Consolidated Edison Company of New York, Inc. Inservice Testing Program For the November 1,1977 - June 30,1979 Period , (Docket No. 50-247) (Submittal dated August,1977) Executive Summary Under contract to the Nuclear Regulatory Canmission (NRC), the Reactor Engineering Analysis Group of Brookhaven National Laboratory (BNL) has con-ducted a review of the following Indian Point, Unit 2, Inservice Testing Program submittals:

1. Inservice Inspection and Testing Program, Indian Point Nuclear Generating Unit No. 2, dated August 1977.

2. Inservice Inspection and Testing Program, Supplements Nos.1, 2, and 3, dated respectfully September 1977, October 1977, and February 1979.

The BNL review process culminated with the Safety Evaluation P,eview (SER) meeting held at the Indian Point, Unit 2, plant on March 7, 8, and 9,1979. Attendees were personnel from the plant, NRC, and BNL. Mr. T.J. Restivo (con-sultant to BNL) and Mr. V. Lettieri (BNL) represented BNL. The recommendations made in this report are based on evaluations which considered: Practi:ality within limitations of equipment design and geometry, requirements of Section XI of the 1974 Edition thru Summer of 1975 of the ASME Boiler and Pressure Vessel Code,10 CFR 50.55a(g), NRC Staff Guidance Letters (November 1976 and January 1978), and topics of numerous NRC Staff /BNL brief-ings. The licensee has requested that Code relief be granted for 15 pump test items and 48 valve items. Also that, Cold Shutdown Testing be approved for 32 valves. This report recommends that Code relief be granted for 11 of the 15 pump items and 26 of the 48 valve items. Also recanmended is that Cold Shutdown Testing be approved for all except ~ one of the valves against which this request was made. 1840 247 1

1.0 PUMPS - INSERVICE TESTING PROGRAM 1.1 General 1.1.1 Relief Request: (Reference, paragraph 2.1 - supplement .. Test the following pumps every two months instead of the Code required one month frequency. o Safety Injection Pumps o Residual Heat Removal Pumps o Containment Spray Pumps o Auxiliary Component Cooling Pumps o Auxiliary Boiler Feedwater Pumps Code Requirement: (IWP-3400). (a) An inservice test shall be run on eacn pump, nominally each month during normal plant operation. It is recommended that this test frequency be maintained during shutdown periods where this can reasonably be accomplished, al-though this is not mandatory. If it is not tested during plant shutdown, the pump shall be tested within one week af ter plant is returned to normal operation. (b) Pumps that are operated more frequently than every month need not be run or stopped for a sfe-cial test, provided the plant log shows each such pump was operated at least once every month at the reference conditions and the quan-tities specified were measured, observed, recorded, and analyzed. Licensee Basis for Relief Request: (All pumps except Component Cooling, Service water, and Recirculation Pumps). The nominal pump test frequency as specified in Subsection IWP requires pump testing once each month during normal plant operation. In a total of over 300 monthly tests completed during the last 5-1/2 years to satisfy Technical Specification requirements - approximately 25 tests per pump - the safety injection, residual heat removal, containment spray, auxiliary component cooling and motor driven auxiliary boiler feedwater pumps have demonstrated no significant change in operating characteristics. In light of this experience, exception is taken to pefonning monthly tests on these pumps with an alter-nate proposed two month test interval scheduled. Based on the pre-ceding test results, the two month test interval will not signifi-cantly alter the operational readiness of these components and will decrease pump wear-out over the plant life time. The interval between successive tests shall not exceed two months (+ 25%). Accordingly, during normal plant operation, each pump shall be tested at least six times per year at approximately equal inter-vals. Evaluation: The detennination of pump operating characteristic ~ changes is considered to be just one of the objectives of the Code. Other prime objectives are: Rotating the pumps periodically for bearing brinelling and lubrication reasons, and verifying peri-odically that the pumps will respond correctly to electrical ini-tiating signals. Rotation of the pumps on a periodic basis is 1840 248

believed to stem from Code committee members' investigations and/or exper f ence that showed that bearing brinelling and/or lubrication loss can result when pumps of these types are inactive over long periods. The Code committee's establishrent of the one month rota-tion frequency, is believed to be the result of a consensus of a body of experts at the time. A vast majority of the Licensees seem to support this conclusion by the fact that the one month test fre-quency is widely practiced. Periodic testing also provides a degree of assurance that the elec-trical circuitry has not been opened or reversed as a result of human errors made during performance of maintenance or other check-out procedures. The one month Code frequency is believed to be more conservative than the Licensee's proposed two month frequency with respect to these type problems, in that a problem can be dis-covered over a shorter period of plant operation. Therefore, it is recommended that this relief request be denied. 1.1.2 Relief Request: (Reference, paragraphs 2.3 and 3.3, supplement 3). Testing of the Recirculation Pumps will be performed during re-fueling shutdowns. Code Requirement: See Code Requirement Item 1.1.1. Licensee Basis for Relief Request: The Recirculation Pumps are located insice containment and are not accessible for testing dur-ing nonnal plant operation. Consequently, exception is taken to testing these pumps at the frequency specified by Subsection IWP. Testing of these pumps will be performed during reactor shutdowns for refueling. This is consistent with present technical specifi-cation requirements for recirculation pump surveillance testing. Evaluation: The Licensee has described the subject pumps as being located in a separate sump inside containment with no provisions for remote readout of pump parameters. The sump does not normally contain enough water to effect safe pump operation, in that the be-arings use the pumped fluid for lubrication / cooling. Also, the pump hydraulic circuit is designed only for miniflow testing. Testing the pumps monthly would require f : ling the pumps' sump each time with approximately 6000 gallons of water, and requiring that personnel enter containment to conduct the Code required pump tests. This relief request from testing at the Code frequency is based on radiation exposure, and large inventory rad-waste proces-sing requirements. The significance of at least spin testing the pumps at the Code ~ frequency has been discussed in the evaluation written against the Licensee's relief request to go to a two month test frequency (other pumps). Brinelling and proper pump response to the initiat-ing electrical signal are points that are felt to apply in this case. 3 1840 249

In light of this, it. is recommended that the Licensee be requested to review the pump configuration and ascertain if it is possible to incorporate modifications such as pump bearing water lube lines and remote readouts' that would allow spin testing the pump's Code fre-quency with the sump water inventory that is normally available, and monitoring the fact that pump rotation is in the proper direc-tion. The pump test circuit configuration was shown only to be a miniflow recirculation path. As such, no design flow type tests can be accomplished during the pumps' inservice life. Based on this, the subject of sump cleanliness should be considered. For-eign objects if present in the sump can affect the ability of the pumps to perform its safety function at design flows. Mini-f;ow spin tests would not necessarily reveal the existence of foreign objects that are capable of affecting the pumps' ability to perform its designed function. Therefore, it is also recommended that the Licensee be requested to consider this and show what provisions are used, such as periodic sump inspection, to preclude this possibil-ity. Monthly pump spin tests, periodic verification of pump inlet clearance, and full Code parameter tests at refueling outages should be the minimum test plan for these pumps. It is felt that such a plan would adequately satisfy the intent of the Code rela-tive to the recirculation pumps. Until such time that the Licensee re-reviews these pumps and re-sponds to the issues raised la the preceding paragraphs, it is re-commended that this remain an open item. 1.1.3 Relief Request: (Reference, paragraph 3.2, supplement 3). Refrain from continuing the miniflow recirculation testing of the Safe 2y Injection Pumps and Motor Driven Auxiliary Boiler Feedwater Pumps prior to startup during refueling outages and substituting full flow pump tests (present technical specification requirement). Code Requirement: An inservice test shall be run on each pump, nominally each manth during nomal plant operation. Each inservice test shall include measurement and observation of all quantities in Table IWP-3100-1 except bearing temperatures which shall be mea-sured during at least one inservice test each year. Licensee Basis for Relief Request: (Safety Injection and Motor Driven Auxillary Boller Feedwater Pumps). Present plant technical specifications and related committments require full flow testing of the safety injection and motor driven auxiliary boiler feedwater pumps prior to startup following each reactor refueling. These full flow tests differ from the Section XI required tests of these pumps which are performed under minimum flow conditions using re-circulation loops. Full flow tests are maximum capability tests and serve to verify pump operability at conditions closely approxi-mating those for which the pumps are designed. It is intended that these full flow tests serve in lieu of the Section XI required re-circulation flow tests during refueling shutdowns. Subsequent re-circulation flow tests will commence two months (+ 25%) from the 4 1840 250

corresponding full flow test. Although flew rate, suction, dis-charge and differential pressures will be obtained during full flow testing, test results will not be comparable to those obtained from recirculation tests. Exception is therefore taken to obtaining Section XI specified test data during full flow tests for purposes of comparison with those obtained during recirculation flow tests. Evaluation: The full flow tests as described are considered to be . more conservative from a hydraulic performance evaluation stand-point than the miniflow recirculation listing, in that they serve to verify pump operability at conditions closely approximating de- . sign conditions. Therefore, it is recommended that the Licensee be allowed to conduct these full flow tests in lieu of the recircula-tion miniflow tests during refueling shutdowns as requested. It should be noted that the reference in this paragraph to recircu-lation testing two months after full flow testing should be unac-ceptable and has been covered by the evaluation of paragraph 2.1. See Iten 1.1.1. 1.2 Safety Injection Pumps (21, 22, 23) 1.2.1 Relief Reauest: Exempt Safety Injection Pumps 21, 22, and 23 from having to meet the allowable ranges of test quantities as defined in Table IWP-3100-2 for the Safety Injection Pump hydraulic perfor-mance parameters. Code Reauirement: (IWP-3210, Allowable ranges of inservice test quantities). The allowable ranges of inservice test quantities in relation to the reference values, are tabulated in Table IWP-3100-

2. In the event these ranges cannot be met, the Owner shall speci-fy in the pump record the reduced range limits to allow the pump to fulfill its function, and those limits shall be used in lieu of the ranges given in Table IWP-3100-2.

Licensee Basis for Relief Reauest:

1. Criteria A (Miniflow conditions of 25 to 35 gpm).

a. The Safety Injection Pumps shall be considered operable if the pump heads are greater than 3,292 feet, or

b. If one pump head is below 3,292 feet, the Safety Injection Pumps shall be considered operable if the heads for the two higher head pumps are in the acceptance region of Figure E5-1 in Supplement 3.

2. Criteria B (Miniflow conditions of less that 25 gpm for one or more pumps).

a. The Safety Injection Pumps shall be considered operable if the punp heads are greater than 3,311 feet, or, 5

1840 251

b. If one pump head is below 3,311 feet, the Safety Injection Pumps shall be considered operable if the heads fcr the two higher head pumps are in the acceptance region of Figure E5-2 in Supplement 3.

These pumps should be exempt from meeting the allowable ranges of test quantities as defined in Table IWP-3100-2 for the Safety Injec- , tion Pump hydraulic performance parameters. Instead, the currently defined parameters as pennitted under IWP-3210 should be substitut-ed in its place. ~ Evaluation: (Reference note 1, supplement 3). The Licensee's re-lief request is interpreted as asking relief from using the Code rules and procedures designed to detect changes in pump operating perfomance, and to substitute instead a set of go/no-go limits for a system of pumps. As limits, the Licensee's proposal is taken heed of when a pump becomes a problem. The Code procedure is ex-pected to provide trend data that can detect changes in pump per-fonnance before the pump no-go limits are reached. One is not a substitute for the other. Reference values should be established (IWP-3210) for the individual pumps and test data analyzed relative to these reference values for trend purposes so that corrective action can be initiated per IWP-3230. Based on the above evaluation, therefore, it is recommended that this relief rec.uest be denied. 1.2.2 Relief Request: A bearing temperature of the Safety Injection Pumps shall be considered stabilized after 15 minutes of pump oper-ation. Code Requirement: When measurement of bearing temperature is re-quired, each pump shall be run until the bearing temperatures (IWP-4310) stabilize, and then the quantities specified shall be measured or observed and recorded. A bearing temperature shall be considered stable when three successive readings taken at ten minute intervals do not vary by more than 3 percent. Licensee Basis for Relief Request: Exception is taken to the time interval requirements between successive measurements of bearing temperature as specified by paragraph IWP-3500(b). Pump operating time for purposes of testing is severely limited by potential pump overheating under the minimum flow conditions dictated by the test circuit. Accordingly, bearing temperature will be measured once, af ter fifteen minutes of pump operation. Evaluation: (Reference note 5, supplement 3). Operating experi-ence is used to justify the Licensee's contention that bearing temperature is sufficiently stabilized after 15 minutes of pump operation to permit measurement, and that pump overheating can re-sult from running the pumps longer at miniflow conditions. It is recommended, therefore, that relief be granted as requested. 6 1840 252

1.3 Residual Heat Removal Pumps (21, 22) 1.J.1 Relief Request: A bearing temperature of the RHR Pumps shall be considered stabilized after lb minutes of pump operation. _ Code Requirement: See Code Requirement Item 1.2.2. , Licensee Basis for Relief Request: See Licensee Basis for Relief Request Item 1.2.2. Evaluation: (Reference note 5, supplement 3). Operating experi-ence is used to justify the Licensee's contention that bearing temperature is sufficiently stabilized after 15 minutes of pump operation to per.rit measurement, and that pump overheating can re-sult from running the ' pumps longer at miniflow conditions. It is recommended, therefore, that relief be granted as requested. 1.3.2 Relief Request: These RHR Pumps are to be lubricated by either sealed grease type bearings or pumped fluid. Code Requirement: Table IWP-3100-1 requires that proper lubricant level or pressure be observed. Licensee Basis for Relief Request: The design of these pumps does not incorporate independent lubrication systems having measurable or observable characteristics. Evaluation: (Reference note 8, supplement 3). These pumps are lubricated by the pumped fluid, therefore, checking the lubricant level does not apply. It is recommended that relief be granted as requested. 1.4 Containment Soray Iumps (21, 22) 1.4.1 Relief Request: A bearing temperature of the Containment Spray Pumps shall be considered stabilized after 15 minuties of pump operation. Code Requiremcnt: See Code Requirement Item 1.2.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Request Item 1.2.2. Evaluation: (Reference note 5, supplement 3). Operating experi-ence is used to justify the Licensee's contention that bearing temperature is sufficiently stabilized after 15 minutes of pump. operation to permit measurement, and that pump overheating can re-sult from running the pumps longer at miniflow conditions. It is recommended, therefore, that relief be granted as requested. 1.5 Component Cooling Pumps (21, 22, 23) 1840 253 1.5.1 Relief Reouest: Withhold implementing the required tests on Com-ponent Cooling Pumps 21, 22, and 23 until the proper modifications are completed. 7

Code Requirement: See Code Requi rement Item 1.1.3. Licensee Basis for Relief Reauest: Due to the demands of dependent systems, the individual testing of Component Cooling Pumps as re-quired by IWP-3400(a) cculd jeopardize plant operation. Al though instrumentation is installed which will pennit the recording of in-let pressure of each pump, pressure measurement on the pump dis- . charge can only be monitored at the common discharge header. The plant design does not incorporate independent flow measurement in-strumentation. Currently, correct performance of these pumps can only be assessed on their continued ability to perfonn their in-tended function. An engineering review is underway to provide for independent measurement of the hydraulic parameters for each pump as required by IWP-3400(a) and exception is taken to implementing the required tests on these pumps until modifications have been complet ed. Evaluation: (Reference note 2, supplement 3). The Licensee has indicated that present plans call for the modifications to be com-pleted during the fourth refueling period towards the end of 1980. It is reccamended that this relief request be granted for the test period covered by this cubmittal. The subject should be reviewed upon receipt of future submittals until the modifications are com-pleted, and it is shown that the Licensee intends to satisfy Code requirements. 1.6 Auxiliary Ccmponent Cooling Pumps (21, 22) 1.6.1 Relief Request: Auxiliary Component Cooling Pumps 21 and 22 are to be lubricated by either sealed grease type bearings or pump fluid. Code Requirement: See Code Requirement Item 1.3.2. Licensee Basis for Relief Request: The design of these pumps do not incorporate independent lubrication systems having measurable or observable characteristics. Evaluation: (Reference note 8, supplement 3). The pumps are equipped with bearings that are grease lubricated, therefore, checking the lubricant level does not apply. It is reccmmended that relief be granted as requested. 1.7 Service Water Pumps (21, 22, 23, 24, 25, 26) 1.7.1 Relief Request: Withhold implementing the required tests on Scr-vice Water Pumps 21, 22, 23, 24, 25, and 26 until the proper mod-ifications are completed. Code Requirement: See Code Requirement Item 1.1.3 Licensee Basis for Relief Request: The service water pumps are vertical design with no means of direct inlet pressure measurement 8 1840 254

as required by IWP-4200 at this time. Due to demands of dependent systems, the individual testing of Service Water Pumps, as required by IWP-3400(a), cou!d jeopardize plant operation. Although individual pump discharge pressures- can be measured, the plant de-sign does not incorporate any flow measurenent instrumentation. Currently, correct performance of these pumps can only be assessed on their continued ability to perform their intendd function. An engineering review is underway to provide for independer.t measure-ment of the hydraulic parameters of each pump and exception is taken to implenenting the required tests on the Service Water Pumps until appropriate modifications have been completed. Evaluation: (Reference note 3, supplanent 3). The Licensee has indicated that present plans call for the modifications to be com-pleted during the fourth refueling period towards the end of 1980. It is recommended that this relief request be granted for the test period covered by this submittal. The subject should be reviewed upon receipt of future submittals until the modifications are com-pleted, and it is shown that the Licensee intends to satisfy Code requirements. 1.7.2 Relief Request: The Service Water Pumps are to be lubricated by either sealed grease type bearings or pumped fluid. Code Requirement: See Code Requirement Item 1.3.2. Licensee Basis for Relief Request: The design of these pumps do not incorporate independent lubrication systems having measurable or observable characteristics. Evaluation: (Reference note 8, supplement 3). These pumps' be-arings are lubricated by the pumped fluid, therefore, checking the lubricant level does not apply. It is recanmended that relief be granted as requested. 1.8 Auxiliary Feedwater Pumps (21, 23) - Motor Driven 1.8.1 Relief Reauest: A bearing temperature of the Auxiliary Feedwater Pumps shall be considered stabilized after 15 minutes of pump oper-ation. Code Requirement: See Code Requirement Item 1.2.2. p Licensee Basis for Relief Request: See Licensee Basis for Relief Request Item 1.2.2. Evaluation: (Reference note 5, supplement 3). Operating experi-ence is used to justify the Licensee's contention that bearing temperature is sufficiently stabilized after 15 minutes of oump operation to permit measurement, and that nump overheating can re-sult from running the pumps longer at miniflow conditions. It is recommended, therefore, that relief be granted as requested. g 9

1.9 Recirculation Purops (21, 22) 1.9.1 Relief Request: A bearing temperature of the Recirculation Pumps shall be considered stabilized after 15 minutes of pump operation. Code Requirement: See Code Requirement Item 1.2.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Request Item 1.2.2. Evaluation: (Reference note 5, supplement 3). Operating experi-ence is used to justify the Licensee's contention that bearing ~ temperature is sufficiently stabilized after 15 minutes of pump operation to permit measurement, and that pump overheating can re-sult fran running the pumps longer at miniflow conditions. It is recommended, therefore, that relief be granted as requested. 1.9.2 Relief Request: Recirculation Pumps 21 and 22 are to be lubricated by either sealed grease type bearings or pumped fluid. Code Requirement: See Code Requirement Item 1.3.2. Licensee Basis for Relief Request: The design of these pumps do not incorporate inaependent lubrication systems having measurable or observable characteristics. Evaluation: (Reference note 8, supplement 3). These pumps' be-aring are lubricated by the pumped fluid, therefore checking the lubricant level does not apply. It is recanmended that relief be granted as requested. 10 1840 256

2.0 VALVES, INSERVICE TESTING PROGRAM 2.1 General 2.1.1 The scope of this review is limited to those valves which perform a safety related function. Safety related valves, for the purpose of IST, have been defined as those valves that are necessary to func-tion to safely shutdown the plant and/or mitigate the consequences of an accident. As a minimum, all valves that receive a contain-ment isolation signal or a safety injection signal shall be in-cluded in the IST program. The following guidelines were developed after review of some ini-tial IST programs. 2.1.2 Leak Testing of Valves which Perfonn a Pressure Isolation Function There are several safety systems connected to the reactor coolant pressure boundary that have design pressures that are belcw the re-actor coolant system operating pressure. It is required that there be redundant isolation valves forming the interface between these high and low pressure systems to prevent the low pressure systems from being subjected to pressures which exceeds their design limits. In this role the valves are performing a pressure isola-tion function. The redundant isolation provided by these valves regarding their pressure isolation function is inportant. It is considered neces-sary to provide assurance that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For this reason it is believed that some method, such as a leak testing, should be used to assure their condition is suf-ficient to maintain this pressure isolation function. In the event that leak testing is selected as the appropriate procedure for reaching this objective, the staff believes that the following valves should be categorized as A or AC and leak tested in accordance with IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are: o Safety Injection System (A206744) 857A 85/J 897A 85/B 85/K 8978 857C 857L 897C 857D 857M 8970 857E 895A 838A 857F 895S 838B 857G 895C 838C 857H 895D 8380 We have discussed this matter and identified the valves listed above to the Licensee. The Licensee has agreed to consider leak 1840 257

testing these valves in accordance with IWV-3420 of the applicable edition of the ASME Code and to categorize these valves with the appropriate designation. If the Licensee detemines that leak testing is not necessay because there are other methods that the Licensee has and will use to detemine each valve's condition, the Licensee will provide to the NRC for evaluation on a valve-by-valve basis the details of the method used that clearly demonstrates the condition of each valve. 2.1.3 Containment Isolation Valves The Appendix J review for this plant is a completely separate re-view from this IST program review. However, the determinations made by that review are directly applicable to the IST program. The present IST submittal should be acceptable until the Appendix J review is completed. At that time, the licensee will be required to amend his IST program to reflect the conclusions of the Appendix J review. 2.1.4 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIV) All CIVs shall be classified as Category A valves. The Category A valve leak rate test requirements of IWV-3420 (a-e) have been superceded by Appendix J requirements for CIVs. The staff has con-cluded that the applicable leak test procedures and requirements for CIVs are detemined by 10 CFR 50 Appendix J. Relief from para-graph IWV-3420 (a-e) for CIVs presents no safety problem since the intent of IWV-3420 (a-e) is met by the Appendix J requirements. Sections f and g of IWV-3420 must be met by the licensee otherwise relief must be requested from these paragraphs. It should be noted that these paragraphs are only applicable where a type C Appendix J leak test is performed. The safety function of CIVs and thus passive CIVs is to perform leak limiting barriers. These are valves, which are normally closed, thus in their safety position, and are not required to open to mitigate the consequences of an accident or to safely shutdown the plant. Therefore, the operability of these valves is inconse-quential with regard to the safety function for which they perform. It is thus concluded that the quarterly stroke and stroke time measurement are meaningless for passive CIVs. 2.1.5 Stroke Requirements for Passive Valves These valves are normally closed and thus in their safety-related position and are not required to change position, that is to open or close to mitigate the consequences of an accident or to safely shutdown the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function for which they perfo rm. It is thus concluded that the quarterly stroke and stroke time measurement are meaningless for passive valves. 12 1840 258

2.1.6 Valves to be Tested at Cold Shutdowns Valve testing should commence not later than 48 hours after shut-down, and continue until complete or plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be perfomed during subsequent cold shutdowns to meet the Code specified testing frequency. In the case of valves exercised less frequently than cold shutdown (i.e., refueling), relief from the Code requirement must be re-quested. These cases are treated as such in this review. ~ 2.1.7 Valve Exercising Requirements ASME Code, Section XI, Subsection IWV-3410(a) requires that Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-1), (e), and (f). IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in 'NV-3420(b). IWV-3700 requires no regular testing for Code Category E valves. Opera-tional checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where:

a. It is not practical to exercise the valves to the position re-quired to fulfill their function or to the partial position during plant operation.

b. It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

2 .1 .8 Changes to the Technical Specifications In a November 1976 letter to the Consolidated Edison Company of New York, the NRC provided an attachment entitled "NRC Staff Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that when one train of a redundant system such as in the ECCS in inoperable, nonredundant valves in the remaining train should not be cycled since their failure would cause a loss of total system function. For example, during power operation in some plants, there are stated minimum re-quirements for systems which make up the ECCS which allow certian limiting conditions for operation to exist at any one time and if the system is not restored to meet the requirements within the time period specified in a plant's Technical Specification the reactor is required to be put in some other mode. Furthemore, prior to initiating repairs all valves and interlocks in the system that 13 1840 259

provide a duplicate function are required to be tested to demon-strate operability immediately and periodically thereafter during power operation. For such plants this situation would be contrary to the NRC guidelines as stated in the document mentioned above. The Indian Point, Unit 2, Technical Specifications may have re-quirements that are contrary to the above mentioned guidelines. We , have discussed this situation with the Licensee and the Licensee has agreed to review the Technical Specification and to consider the need to propose Technical Specification changes which would . have the effect of precluding such testing. If, after making this consideration, the licensee detemines that the TS should not be changed because the guidelines are not appli-cable or if that the guidelines cannot be followed, the Licensee shall submit to the NRC the reasons that led to their determination for each potentially affected valve. In the Licensee submittal, the potentially affected sections of the TS, in addition to the valves, should be identified. 2.2 General Relief Requests 2.2.1 Relief Request: All Category A valves will meet Appendix J leak testing requirements in lieu of Section XI requirements. Code Requirement: IWV-3420 Valve Leak Rate Test. Category A valves shall be leak-tested. Tests shall be conducted at the same (or greater) frequency as scheduled refueling outages, but not less than once every two years. Valve seat leakage tests shall be made with the pressure differential in the same direction as will be ap-plied when the valve is perfoming its function with the following exceptions:

1. Any globe type valve may be tested with pressure under seat.

2. Butterfly valves may be tested in either direction, provided their seat construction is designed for sealing against pres-sure on either side.

3. Gate valves with two-piece disks may be tested by pressurizing them between the seats.

4. All valves (except check valves) may be tested in either direc-

, tion if the function differential pressure is 15 psi or less.

5. The use of leakage tests involving pressure differentials lower than function pressure differentials are permitted in those types of valves in which :ervice pressure will tend to diminish the overall leakage channel opening, as by pressing the disk into or onto the seat with greater force. Gate valves, check valves, and globe type valves having function pressure dif-ferential applied over the seat, are examples of valve ap-plications satisfying this requirement. When leakage tests are 14 1840 260

made in such cases using pressures lower than function maximum pressure differential, the observed leakage shall be adjusted to function maximum pressure differential value by calculation appropriate to the test media and the ratio between test and function pressure differential assuming leakage to be directly proportional to the pressure differential to the one-half power. ~

6. Any valves not qualifying for reduced pressure testing as de-fined in 3420(c)(5) shall be leak-tested at full maximum func-tion pressure differential, with adjustment by calculation if needed to compensate for a difference between service and test media.

Valve seat leakage may be determined by:

1. Draining the line, closing the valve, bringing one side to test pressure, and measuring leakage through a downstream telltale connection, or,

2. By measuring feed rate required to maintain pressure between two valves, or between two seats of a gate valve, provided the total apparent leak rate is charged to the valve or gate valve seat being tested, and that the conditions required by IWV-3420(c) are satisfied.

The test medium shall be specified by the Owner. Licensee Basis for Relief Recuest: Appendix J leak testing meets the intent of Section XI Requirements. Evaluation: The Category A valve leak rate test requirements of IWV-3420 (a-e) have been superceded by Appendix J requirements for CIVs. The NRC staff has concluded that the applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J. Relief from paragraph IWV-3420 (a-e) for CIVs presents no safety problem since the intent o' IWV-3420 (a-e) is met by the Appendix J requirements. Section f and g of IWV-3420 must be met by the licensee otherwise relief must be requested from these paragraphs. It should be noted thct this relief request applies only where a type C Appendix J leak test is performed. Therefore, it is recommended that relief by granted from the leak test requirements of Section XI for the following listed CIVs. o Safety Injection System 867A 851A 888A 867B 851B 888B 869A 859A 863 869B 859C 4312 850A 885A 743 8508 885B 1870 878A 8788 1840 261 15

o Auxiliary Coolant System 744 784 798 741 FCV-625 791 732 796 797 793 o Chemical and Volume Control System 222 241A 250A 226 241B 250B 205 241C 250C 201 241D 2500 202 227 o Reactor Coolant System 548 518 580A 549 519 580B 550 552 o Service Water System SWN-41 (5 valves) SWN-42 (5 valves) SWN-43 (5 valves) SWN-44 (5 valves) SWN-51 SWN-71 (5 valves) o Sampling System 956A 956H 956B 958 956C 959 956D 990A 956E 990B 956F 990C 956G o Post Accident Containment Air Sampling System 1875A 1875D 1875G 18758 1875E- 1875H 1875C 1875F 1875J o Hydrogen Recombiner System 1882A 1876-9 4430 1882-9 4431 IV-5A 4432 IV-38 4429 IV-5B 1875-9 IV-3A 1875-8 IV-2A IV-2B 1876-8 16 1840 262

o Steam Generator Blowdown and Sampling System PCV-1223 PCV-1226 PCV-1215A PCV-1223A PCV-1226A PCV-1216 PCV-1224 PCV-1214 PCV-1216A PCV-1224A PCV-1214A PCV-1217 PCV-1225 PCV-1215 PCV-1217A PCV-1225A o Waste Disposal System 1786 1789 1787 1702 1610 1705 1616 1728 1788 1723 o Miscellaneous CIV's 1190 UH-43 85D 1191 UH-44 95A 1192 1234 95B 1170 1235 95C 1171 1236 95D 1172 1237 1814A 1173 SA-24 (2 valves) 1814B PCV-1228 MV-17 (2 valves) 1814C PCV-1229 85A IA-39 PCV-1230 85B E-1 E-2 E-3 E-5 2.3 Safety Injection System (A206744) 2.3.1 Code Relief - Category A Valves 2.3.1.1 Relief Request: Valves 867A and 867B will not be full stroke exer-c' sed every 3 months to the requirements of Section XI. Code Reauirement: Category A valves shall be exercised at least once every 3 months with the exceptions as shown in the following paragraph. They shall be leak tested at the same (or greater) frequency as scheduled refueling outages but not less than once every two years. Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant opera-tion. If only limited operation is practical during plant opera-tion the valve shall be part stroke exercised during plant opera-tion and full stroked during each cold shutdown; in case of fre-quent cold shutdowns these valves need not be exercised more often than once every 3 months. Valves that cannot be operated during normal plant operation shall be specifically identified by the. 17 1840 263

Owner and shall be full stroke exercised during each cold shutdown; in case of frequent cold shutdowns these valves need not be exer-cised more of ten than once every 3 months. For Category C Code requirements, see Item 2.3.3.1. A combination of categories, such as categories AC are to be used when more than one distinguishing category characteristic is applicable. In such , cases, all requirements of each of the individual categories are applicable, alth Jh duplicat'a or repetition of common testing requirements is not necessary Licensee Basis for Relief Request: Full stroking these valves every 3 months is impractical during nomal plant operations. Part stroke exercising during monthly containment spray pump tests is practical . Evaluation: This evaluation need only address the category C exer-cising requirements of the subject check valves. It is recommended that relief be granted from the IWV-3410 requirement for category A valves as this paragraph does not apply to check valves. The containment Ssray discharge check valves, 867A and 867B are closed during plant operation and are required to open when the containment spray pumps are activated to supply reactor water stor-age tank (RWST) water / spray additive to the containment spray head-ers. The check valves will be part stroke exercised at least every 2 months during the proposed containment spray pump tests (recircula-tion /mi ni fl ow) . Flow through the valves during these pump tests is expected to be 25-35 gpm as compared to the design flow of approxi-mately 2600 gpm. The Licensee has indicated that full-stroke exercising these vaives is not practical at anytime. The valves are not designed with mechanical external actuators, and are also a welded design with no provisions for disassembling and stroking in the installed condi-tion. The only way to full stroke exercise would be to activate the containment spray pumps and spray down containment, in that the valves cannot be externally stroked (mechanically) or internally stroked (disassembling) in place and that spraying down containment is highly impractical . It is believed that the Licensee has demon-strated that part stroke exercising is the practical alternative. The NRC has agreed to review the testing proposed for these valves and determine if the degree of testing (part stroke at frequency proposed) is adequate to justify granting relief from full stroke exercising. Until this is accomplished, it is recommended that the relief request for not full stroke exercising at any time during their inservice life be denied. 2.3.1.2 Relief Request: Valves 850;. and 850B will be exempt from the exer-c1 sing requirements of IWV-3410 for Category A valves. 1g 1840 264

Code Recuirement: See Code Requirment Its 2.3.1.1. Licensee Basis for Relief Request: These valves are either locked open or lockea closed manual Containment Isolation Valves and as such are categorized as category AE valves. As a result of their locked status, these valves will satisfy the cateogyr E require-ments set forth in IWV-3700. However, since they are Contairment . Isolation Valves, these valves will also satisfy the category A leak testing requirments of IWV-3420 but will be exempt frm the exercising requirements of IWV-3410. Evaluation: 850A and 850B are manual Containment Isolation Valves on the discharges of the safety-irdection pumps. The valves are locked open during normal plant operation, and are required to be closed folicwing shutdown of the SI pumps at some time af ter the design basis accident condition, in that the valves are CIV's. The Licensee was requested to and has agreed to review these valves and determine if the Code required (fu11/ stroke /3 month) exercise test could be accmplished, or if any stroke and/or test frequency other than the Code requirement could be proposed. The Licensee has also agreed to provide a basis to justify this proposal . Until this infomation is received and reviewed, it is recamrended that any request for relief from the Code exercising requirement be de nied . 2.3.1.3 Relief Request: Valves 859A and 859C will not be stroked to the requirements of Section XI. Code Reauirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Recuest: These valves are passive CIV's ano are locked closed, therefore exercising the is not necessary. Evaluation: Valves 859A and 859C are manual locked closed CIV's in the 5.1. pump test circuit. These valves are normally closed dur-ing nomal plant operation and have a safety function to close. Therefore, they can be considered passive valves. Per Item 2.1.5 for passive valves, it is recamended that relief be granted frm Section XI stroking requirements. 2.3.1.4 Relief Request: Valves 863 and 4312 will not be stroked to the re-quirsents of Section XI. Code Requirement: See Code Requi rment Its 2.3.1.1. ~ Licensee Basis for Relief Reouest: These valves are passive CIV's and are normally closea, wnich are required to be closed during an accident condition. 19 1840 265

Evaluation: Valve 4312 is a category AC Check Valve. Both valves (863 and 4312) are Containment Isolation Valves in the GN2 supply line to the accumulators. These valves are nomally closed valves, whose safety function is to close, as such, it is considered a pas-sive valve. Therefore, it is recommended, per Item 2.1.5, that re-lief be granted from the stroking requirements of the Code. ~ 2.3.1.5 Relief Request: Valves 743 and 1870 will not be stroked to the re-quirements of Section XI. Code Requirement: See Code Requi rement Item 2.3.1.1. Licensee Basis for Relief Request: These valves are passive CIV's and are normally open ano are required to be open during an acci-dent. Evaluation: Valves /43 and 1870 are locked open valves in the min 1 flow test path cf the Residual Heat Removal (RHR) Pumps. These valves are also CIV's. Valves 743 and 1870 are nomally open and are manually closed at some time after the accident initiation. However, this item must remain open until such time as the Licensee reviews and detemines if stroking these valves will be acccmplish-ed per Category A requirements. It is recommended that this relief request, therefore, be denied at this time. 2.3.2 Code Relief - Category B Valves 2.3.2.1 Relief Request: Valves 856A, 856C, 856D, and 856E will be full-stroke exercised at refueling outages in lieu of Section XI re-quirements. Code Requirement: Category B valves shall be exercised at least once every 3 months with the exceptions as shown in the following paragraph. Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant opera-tion. If only limited operation is practical during plant opera-tion the valve shall be part stroke exercised during plant opera-tion and full stroked during each cola shut; in case of frequent cold shutdowns these valves need not be exercised more often than once every 3 months. Valves that cannot be operated during normal plant operation shall be specifically identified by the Owner and shall be full stroke exercised during each cold shutdown; in case of frequent cold shutdcwns these valves need not be exercised more often than once every 3 months. Licensee Basis for Relief Request: These valves cannot be operated during normaT plant operation but will be full-stroke exercised at refueling outages. Part stroke exercising these valves during nomal plant operations is also impractical. 1840 266

Evaluation: Valves 856A, 856C, 8560 and 856E are shutoff valves in the SI lines which are in the cold legs of the Reactor Coolant System (RCS). These are nomally open valves whose function is to close when the hot leg safety injection is required. Pre sently , the Licensee does not intend to full stroke exercise these valves on a quarterly basis. This item must remain open until such time as the Licensee provides sufficient technical justification for not . exercising these valves quarterly. Therefore, until such informa-tion is provided, it is recommended that this relief request be de-nied. 2.3.2.2 Relief Reauest: Valves 842 and 843 will be full stroke exercised at refueling outages in lieu of Section XI requirements. QdeRequirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Reouest: These valves cannot be part stroke exercised either during normal plant operation or at cold shutdowns but can be full stroke exercised at refueling outages. Evaluation: Valves 842 and 843 are valves in the S.I. pump test line to the Reactor Water Storage Tank (RWST). These valves are normally open and have a safety function to close when the Safety Injection (SI) flow begins to travel to the RCS. These valves are open or closed only valves, therefore, part stroke exercising them is impractical during normal plant operation. Exercising the valves quarterly could compromise the SI pump opera-tion if the valves were to fail in a closed position. If the valves were in the closed position and the pumps were started, the result would be a dead head condition which most likely would cause damage to the pumps. The Licensee presently intends to full stroke exercise these valves at refueling outages. No justification, however, has been given for not full stroke exercising these valves at cold shu 3 downs. Un-til sufficient technical documentation is provided to justify not stroking these valves at cold shutdowns, it is recommended that re-lief be denied. 2.3.2.3. Relief Request: Valves 1831 and 1821 will be full stroke exer-cised at refueling outages in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Request: These valves cannot be part stroke exercised either during nomal plant operation or at cold shutdowns but can be full stroke exercised at re:'ueling outages. Evaluation: Valves 1831 and 1821 are Boron Injection Tank (BIT) outlet shutoff valves. These vah es are also open or closed only valves, therefore, part stroke exc cising them is impractical 1840 267

during normal plant operation. The valves are normally open and have a safety function to close upon the initiation of a BIT low level signal . Exercising the valves quarterly places the BIT system in a non-conservative condition (i.e., the failure of the valves in a closed position nullifies the availability of the BIT system in the event - of a concurrent emergency situation). The Licensee presently pro-poses to full stroke exercise these valves at refueling outages. No justification, however, has been given for not full stroke exer- . cisng these valves at cold shutdovins. Until sufficient technical document 1 tion is provided to justify not stroking these valves at cold shutdowns, it is recommended that this relief request be denied. 2.3.2.4 Relief Request: Valves 1822A and 1822B will be full stroke exer-c1 sed at refueling outages in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Request: These valves cannot be part stroke exercised either during nomal plant operation or at cold shutdowns but can be full stroke exercised at refueling outages. Evaluation: Valves 1822A and 1822B are shutoff valves on the Boron Injection Tank (BIT) outlet lines. These valves are also open or closed only valves, therefore, part stroke exercising them is impractical during normal plant operation the valves are normally closed and their safety function is to open. Cycling these valves quarterly requires that valves 1831 and 1821 be closed in order to prevent concentrated boron solution from get-ting into the downstream plumbing. As a result valves 1831 and 1821 cannot be cycled quarterly. The Licensee presently proposes to full troke exercise these valves at refueling outages. No detailed technical justification has been given for not full stroke exercising these valves at cold shutdowns. Until sufficient technical documentation is provided to justify not stroking these valves at cold shutdowns, it is recom-mended that this relief request be denied. 2.3.3 Code Relief - Category C Check Valves . 2.3.3.1 Relief Request: Valves 857A, 857B, 857C and 857D will be full stroke exercised at refueling outages in lieu of Section XI re-quirements. Code Requirement: Check valves shall be exercised at least once every 3 months, with the exceptions as shown in the following para-graph. 22 1840 268

Check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant cperation. If only limited operation is practical during plant operation the check valve shall be part stroke exercised during plant operation and full strcked during each cold shutdcwn. In case of frequent cold shutdowns these check valves need not be ex-ercised nore of ten than once every 3 months. Check valves that cannot be operated during normal plant operation shall be specifi-cally identified by the Owner and shall be full stroke exercised during each cold shutdown. In case of frequent cold shutdowns these check valves need not be exercised trore of ten than once every 3 months. Licensee Basis for Relief Request: Full stroke or part stroke ex-ercising these valves during nonnal plant operations is impractical because the reactor coolant pressure cannot be overcome. Evaluation: Valves 857A, 857B, 857C, and 857D are Pressure Isola-tion Check Valves in the hot leg irdection lines to the RCS and are at the interface of the RCS and Safety Injection System (SIS). The valves are held closed by the RCS pressure during nonnal plant operation, and their emergency function is to open in order to pennit ficw fran the High Pressure Safety Injection (HPSI) pumps into the RCS following a loss of coolant accident (LOCA). The SIS configuration is such that, the only practical way the valves can be exercised is by activating the HPSI pumps and es-tablishing flow through the valves. During normal plant operation, the RCS pressure is approximately 2200 psig. The HPSI pumps do not have the pressure capabili ty (design discharge pressure approximately 1700 psig) to overcome the RCS pressure and establish flow through the Check Valves. Part of the temperature over pressure protection requirements at cold shut-downs is such that the HPSI pumps be deactivated when the RCS is pressurized and below 1900 psig. This is to prevent an inadvertant pressurization of the RCS by the HPSI pumps at this time. The re-fore, flow cannot be established through the Check Valves by the HPSI pumps during these cold shutdowns. Therefore, it is concluded that the Licensee has demonstrated the impracticality of part or full stroke exercising every 3 months and at cold shutdowns. Full strcke exercising these valves at re-fueling outages is the practical alternative. It is recommended that relief be granted as requested. 2.3.3.2 Relief Recuest: Valves 857G, 857H, 857M, and 857F will be full stroke exercised at refueling outages in lieu of Section XI re-qui rements. Code Requirement: See Code Requirement Item 2.3.3.1. 23 1840 269

Licensee Basis for Relief Request: Full stroke or part strcke ex-ercising these valves during nonnal plant operations is impractical because the reactor coolarit pressure cannot be overcome. Evaluation: These pressure isolation check valves are in the hot leg injection lines from the HPSI pumps. They are closed during normal plant operation, and their emergency function is to open to permit flow frcm the HPSI pumps to the RCS following a LOCA. 857M, F, G, and H are upstream and in series with 857A, B, C, and D re-spectively. Since 857A thru D cannot be exercised quarterly or at ~ cold shutdowns, the evaluation written for 857A, B, C, and D also applies to the subject check valves. Therefore, it is concluded that the Licensee has demonstrated the impracticality of part or full stroke exercising every 3 months and at cold shutdowns. Full stroke exercising these valves at re-fueling outages is the practical alternative. It is recommended that relief be granted as requested. 2.3.3.3 Relief Request: Valves 857E, 857J, 857K and 857L will b, full stroke exercised at refueling outages in lieu of Section XI re-quirements. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: Full stroke or part stroke ex-ercising these valves during nonnal plant operations is impractical because the reactor coolant pressure cannot be overcome. Evaluation: These pressure isolation check valves are in the cold leg injection lines from the HPSI pumps. 857E/J and 857K/L are up-stream and in series with 897A and 897C respectivey. They are closed during nonnal plant operation, and their emergency function is to open to permit flow from the HPSI pumps to the RCS following a LOCA. Since 897A and 897C cannot be exercised quarterly er at cold shutdowns, the evaluation written for these valves also ap-plies to the Subject check valves. Therefore, it is cuncluded that the Licensee has demonstrated the impracticality of part or full stroke exercising every 3 months and at cold shutdowns. Full stroke exercising at refueling outages is the practical alternative. It is recommended that relief be granted as requested. 2.3.3.4 Relief Request: Valves 895A, 895B, 895C, and 895D will not be full or part stroke exercised during nonnal plant operations but will be part stroke exercised at refueling cutages. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: Full or part stroke exercising these valves during normal plant operation is impractical. 24 1840 270

Evaluation: Valves 895A, 8958, 89bC, and 895D are Pressure Isola-tion Check Valves in the outlet lines from the accumulators (one per accumulator). They are closed during nonnal plant operation,

           'd their emergency function is to open following a LOCA, (RCS pressure drops below approximately 650 psig) to allcw water fran the accumulators to transfer to the RCS.

The SIS configuration is such that the only practical way the valves can be exercised is by blowing down water fran the accumu-lators to the RCS. 895A thru 895D are upstream and in series with 897A thru 8970 which are held closed at this condition by a differ- ~ ential pressure of about 1550 psig (res. at 2200 psig vs. accumula-tors at 650 psig). Therefore, flow cannot be established fraa the accumulators during normal power conditions. Part of the low temperature over-pressurization protection re-quirements at cold shutdowns, is that the M0Vs 895A thru 895D are closed when the RCS pressure is reducec below 1000 psig. These MCV's are in the accumulator outlet lines, and are upstream and in series with the subject check valves. Therefore, flow cannot be established from the accumulators during these cold shutdown con-ditions. The Licensee has agreed (SER meeting) to part stroke exercise these check valves at refueling outages, but has not presented specific reasons when the valves cannot be full stroke exercised at some time during their inservice life. In order to couplete the evaluation, the Licensee should provide information concerning the degree of part stroke exercising ex-pected during tests such as percentage of design flowrates ob-tained, or some other measure. The Licensee should also give specific reasons why full stroking these valves cannot be accan-plished at refueling outages or at some tin.e during inservice life. Until this infonnation is received and reviewed, it is reconmended this relief request be denied. 2.3.3.5 Relief Request: Valves 886A and 886B will be full stroke exercised at refueling outages in lieu of Section XI requirements. , Code Requirement: See Code Requirement Itan 2.3.3.1. Licensee Basis for Relief Request: These valves cannot be full or part stroke exercised quarterly during nonnal plant operations but can be full stroke exercised at refueling outages. Evaluation: Valves 886A anc 886B are recirculation outlet valves from the recirculation pumps of the Safety Injection System (SIS). These valves are nonnally closed and have an emergency function to open. When the recirculation pumps are activated, the re-circulation mode fran the recirculation sump to the RCS, is initiated. 25

                                                                ~1840 271

These valves are located inside containment, therefore, the only means of opening them is by activating the recirculation pumps. Full stroke exercising these valves quarterly during nomal plant operations is impractical because the pumps which feed water to the valves are located in the sump. If operated during nomal plant operations, the sump will not have enough water to operate the pumps. The pumps cannot be operated dry because this can lead to damage. These valves cannot be full stroke exercised at cold shutdowns because the sump is dry at that time. Filling the sump for the pump tests requires approximately 6000 gallons which creates a radioactive waste problem. This item must remain open until such time as the Licensee confims that full stroke exercising of these valves will be at refueling outages. 2.3.3.6 Relief Request: Valve 881 will be part stroke exercised during the monthly RHR pump tests. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request. Valve 881 cannot be full stroke exercised during colo shutdowns out can be part stroke exercised quarterly during the RHR pump tests. Evaluation: Valve 881 is a recirculation inlet check valve to the RHR pumps from the Reactor Water Storage Tank. The valve is nom-ally closed and has an emergency function to open when the RHR pumps are used in the LPSI mode. This item must remain open until such time as the Licensee provides whether the flow at recircula-tion during cold shutdown and/or refueling is a full stroke exer-cise. Until such technical information is provided, it is recom-mended that this relief request be denied. 2.3.3.7 Relief Request: Valve 879A and 8798 will not meet the requirements of Section XI. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: None provided. Evaluation: Valves 879A and 879B are Check Valves of the Safety Injection System. The Licensee is presently reviewing the pos-sibility of adding these valves to the IST program as category C type valves. This item must remain open until such time as the Licensee addresses all exercises, (full stroke /part stroke at frequencies of quarterly, cold shutdown, or refueling) and decides which is the most applicable to the situation. 2.3.3.8 Relief Request: Valve 847 will be part stroke er.ercised monthly during SI pump tests and will be full stroke exercised at refueling outages during the SI pump tests. 1840 272

Code Requirenent: See Code Requirement Item 2.a.3.1. Licensee Basis for Relief Request: These valves cannot be full stroke exercised at colo shutdowns but can be part stroke exercised monthly during the SI pump tests on recirculation and full stroke exercisel at refueling outages during the SI oump tests. Eval uatio t: Valve 847 is a check valve lova6ed at the inlet to the Safety Infection (SI) pumps from the Refueling Water Storage Tank (RWST). ibis valve is normally closed and has an emergency func-tion +; open. The only practical means to exercise this check vahe is to activate the SI pumps and flow water from the RWST to the Reactor Coolant System (RCS). Full stroke exercising the valve quarterly while the plant is at normal operating power is impracti-cal in that the RCS pressure is at approximately 2250 psig. This pressure locks out the check valve at the RCS/ SIS interface that are downstream and in series with the subject check valve. The head available from the SI pumps is not enough to overcome the RCS pressure, thereby preventing flow. It is also impractical to ex-ercise the valve at cold shutdowns. The SI pumps are deactivated when the RCS pressure goes below 1900 psig as part of the overpres-sure protection requirements. The valve is part stroke exercised monthly during the SI pump tests in the recirculation test mode, and full stroke exercised at re-fueling outages during the SI pump tests. Therefore, it is recom-mended, due to the impracticality caused by plant design, that re-lief be granted to fu'l stroke exercise this valve at refueling outages in lieu of Section XI requirements. 2.3.3.9 Relief Request: Valves 849A, 849B, 852A, and 852B will be part stroke exercised quarterly and will be full stroke exercised at re-fueling outages during full flow SI pump tests. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: These valvas cannot be full stroke exercised to the requirements of Secti: n XI, but can be part stroke exercised quarterly during accumulato toping and full stroke exercised at refueling outages during full flow SI pump tests. Evaluation: Valves 849A, 849B, 852A, and 8528 are Check Valves locateo at the outlet of the SI pumps. These valves are normally closed and have an emergency function to open. Full stroke exer-cising these valves quarterly while the plant is at normal operat-ing power is impractical in that the RCS pressure is at approxi-mately 2250 psig. This pressure locks out these check valves at the RCS/ SIS interface that are downstream and in series with the subject check valve. The head available from the SI pumps is not enough to overcome the RCS pressure, thereby preventing flow. 7 1840 273

It is also impractical to exercise these valves at cold shutdowns. The SI pumps are deactivated when the RCS pressure goes below 1900 psig as part of the low temperature over-pressurization protection requirements. These valves are part stroke exercised at least on a quarterly basis during the accumulator top off operations and full stroke ex-ercised at refueling outages during the SI pump tests. Therefore, it is recommended, due to the impracticality caused by plant design, that relief be granted to full stroke exercise these valves at refueling outages in lieu of Section XI requirements. 2.3.3.10 Relief Request: Valves 1838A and 1838B will not meet the require-ments of Section XI. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: none provided. Evaluation: Valves 1838A and 1838B are check valves in the lines from the spray additive tank to the ductors of the containment spray pumps. These valves are nomally closed, and have an em-ergency function to open when the containment spray pumps are activated. This item must renain open until such time as the Licensee provides the extent to which these valves will be stroked and at what frequency. 2.4 Auxiliary Coolant System (A206738) 2.4.1 Code Relief - Category A Valves 2.4.1.1 Relief Request: Valve 744 will be full stroke exercised at re-fueling outages in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Valve 744 cannot be full stroke exercised during nomal plant operations but can be full stroke ex-ercised at refueling outages. Part stroke exercising this valve during nomal plant operations is also impractical. Evaluation: Valve 744 is a RHR pumps outlet shutoff valve. This valve is also an open or closed only valve, therefore, part stroke exercising it is impractical during ncmal . plant operation. This valve is a CIV - normally open and has an emergency function to close following the temination of the leu pressure safety injec-tion (LPSI) mode. Full stroke exercising the valve quarterly is impractical in that a failure of the valve in the closed position nullifies the function of the residual heat removal (RHR) pumps in the LPSI mode, should an emergency occur, concurrent with the valve failure. The valve cannot be exercised at cold shutdowns because closing the valve 28 1840 274

will teminate the nomal RHR cooling mode (required to maintain cold shutdown). This valve however, will be full stroke exercised at refueling cutages. Therefore, it is recommended, due to the impracticality caused by plant design and per NRC guidelines, that relief be granted to full stroke exercise this valve at refueling outages in lieu of Section . XI requirements. 2.4.1.2 Relief Request: Valve 732 will not be stroked to the requirements . of Section XI. vode Reauirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Valve 732 is a passive CIV and is locked closed, therefore, exercising it is not necessary. Evaluation: Valve 732 is a locked closed CIV in the steam genera-tor lines, which is in the hot legs of the Reactor Coolant System (RCS). This is a normally closed valve, whose safety function is to close, therefore it can be considered a Passive Valve. It is recommended, per item 2.1.5, that relief be granted from the stroking requirements of the Code. 2.5 Chemical and Control Volume System ( A206745 and A206746) 2.5.1 Code Relief - Category A Valves 2.5.1.1 Relief Request: Valve 227 will not be stroked to the requirements of Section XI. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: This valve is a passive CIV and is normally closed, wnich is required to be closed during an acci-dent condition. Evaluation: Valve 227 is a Containment Isolation Valve in the hot

         'R9 charging line to the Reactor Coolant System (RCS). This is a normally closed valve, whose safety function is to close, there-fore, it can be considered a Passive Valve.      It is recommended, per item 2.1.5, that relief be granted from Section Xi requirements.

2.5.1.2 Relief Request: Valves 201 and 202 will be full stroke exercised at refueling outages in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Full strcke exercising these valves quarterly, which are normally open valves, is impractical during nomal plant operations, but can be full stroke exercised at refueling outages. Part stroke exercising these valves during nomal plant operations is also impractical . 29 1840 275

Evaluation: Valves 201 and 202 are manual letdown shutoff valves in the cnarging flow line to the nonregenerative heat exchanger. In addition, these valves are open or closed only valves, there-fore, part stroke exercising them is impractical during normal plant operation. Full stroke exercising the valves quarterly is also impractical during normal plant operation because it would inhibit the control of the reactor coolant level control system. Closing these valves at any time during normal plant operation would shutdown the charging flow creating a potential for a low level reactor trip. The Licensee presently plans to full stroke exercise these valves at refueling outages and also intends to investigate the possibil-ity of full stroke exercising these valves at cold shutdowns. This item must remain open because to date, the Licensee has not pro-vided sufficient technical justification to grant relief to a re-fueling outage frequency. Until sufficient technical documentation is provided to justify not stroking these valves at cold shutdowns, it is recommended that this relief request be denied. 2.5.1.3 Relief Request: Valves 205 and 226 will be full stroke exercised at refueling outages in lieu of Section XI requirements. Code Reauirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Full stroke exercising these valves quarterly, whicn are normally open valves, is impractical during normal plant operations but can be full stroke exercised at refueling outages. Part stroke exercising these valves during normal plant operations is also impractical . Evaluation: Valves 205 and 226 are manual charging shutoff valves in the cnarging flow line to the regenerative heat exchanger. In addition, these valves are open or closed only valves, therefore, part stroke exercising them is impractical during normal plant operation. Full stroke exercising the valves quarterly is also impractical during normal plant operation because it would inhibit the control of the reactor coolant level control system. Closing these valves at any time during normal plant operation would shut-down the charging flow creating a potential for a low level reactor trip. The Licensee presently plans to full stroke exercise these valves at refueling outages and also intends to investigate the possi-bility of full stroke exercising these valves at cold shutdowns. This item must remain open because to date, the Licensee has not provided sufficient technical justification to grant relief to a refueling outage frequency. Until sufficient technical documentation is provided to justify not stroking these valves at cold shutdowns, it is recommended that this relief request be denied. 30 1840 276

2.6 Reactor Coolant System (A206747) 2.6.1 Code Relief - Category A Valves 2.6.1.1 Relief Request: Valve 518 will not be stroked to the requirenents or Section XI. Code Requirement: See Lode Requirement Item 2.3.1.1 for category A ano see Iten 2.3.3.1 for category C valves. Licensee Basis for Relief Request: This valve is a passive CIV, and is normally closed, which is required to be closed during an accident condition. Evaluation: Valve 518 is a category AC contaiment isolation check valve located in the nitrogen supply manifold of the waste disposal system to the pressure relief tank. This is a nonnally closed valve, whose safety function is to close, therefore, it can be con-sidered a passive valve. It is reconmended per iten 2.1.5 that re-lief be granted from the stroking requirements of the Code. 2.6.1.2 Re'ief Request: Valves 580A and 580B will not be stroked to the requirenents of Section XI. Code Requirement: See Code Requirenent Item 2.3.1.1. Licensee Basis for Relief Request: These valves are passive CIV's and are normally closed, which are required to be closed during an accident condition. Evaluation: Valves 580A and 580B are contairment isolation valves in the cead weight tester system and are used during calibration of the dead weight tester. They are nonnally closed valves, dose safety function is to close, therefore, they can be considered pas-sive valves. It is reconmended, per iten 2.1.5, that relief be granted fran the stroking requirements of the Code. 2.6.2 Code Relief - Category B Valves 2.6.2.1 Relief Request: Val ves 535, 536, PCV-456 and PCV-455C will be full stroke exercised at refueling outages in lieu of Section XI re-quirements. Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Request: Full stroke exercising these valves is impractical during nomal plant operations or at cold shutdowns, but can be full stroke exercised at refueling outages. Part strde exercising these valves during nonnal plant operations or at coi shutdowns is also impractical . 1840 277 31

Evaluation: Valves 535, 536, PCV-456 and PCV-455C are part of the low temperature over-pressurization protection system. This item must remain open until such time as the Licensee reviews these valves to determine if they will be kept in the IST program or be included as technical specification requirements only. If it is decided that these valves are to remain in the IST program, the Licensee is expected to provide the necessary detailed justifica-tion for not full or part stroke exercising quarterly or at cold shutdowns. Thereby justify full stroke exercising at refueling outages as requested in the submittal. Until such time as this decision is made and justification present-ed and evaluated, it is recommended that this relief request be de-nied. 2.7 Service Water System (A206739) 2.7.1 Code Relief - Category A Valves 4 2.7.1.1 Relief Request: Valves SWN-41 (5 valves), and SWN-44 (5 valves) will be full stroke exercised at refueling outages in lieu of Sec-tion XI requirements. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Full stroke exercising these valves is impractical during normal plant operation, but they can be full stroke exercised at refueling outages. Part stroke ex-ercising these valves during normal plant operation is also impractical. Evaluation: SWN-41 (5 valves) and SWN-44 (5 valves) are manually operated inlet and return valves respectively, to the containment building ventilation cooling coils. In addition, these valves are CIV's. The valves are normally open, and are manually closed at some time following the accident condition. Full or part stroke exercising the valves quarterly to the closed position, during normal plant operation, is impractical, in that doing so would shutoff service water to the coolers and most likely result in high containment temperature. The Licensee plans to full stroke exer-cise these valves at refueling outages. This item must remain open however, until such time as the Licensee reviews the valves and determines if they will be cycled closed at cold shutdowns.

 ,2.7.1.2     Relief Request: Valves SWN-71 (5 valves) will be full stroke ex-ercised at refueling outages in lieu of Section XI requirements.

Code Requirement: See Code Requirement Item 2.3.1.1. eRequires NRC Review 32

Licensee Basis for Relief Request: Full stroke exercising these valves 1s impractical during nomal plant operation, but can be full stroke exercised at refueling outages. Part stroke exercising these valves during normal plant operation is also impractical. Evaluation: SWN-71 (5 valves) are return valves from the recir-culation fan motor coolers. In addition, these valves are CIV's. The valves are normally open, and are manually closed at some time following the accident condition. Full or part stroke exercising the valves quarterly to the closed position, during nonnal plant operation, is impractical, in that doing so would shutoff service ~ water to the motor coolers most likely resulting in fan motor damage. The Licensee plans to full stroke exercise these valves at refueling outages. This item nust remain open however, until such time as the Licensee reviews the valves and determines if they will be cycled closed at cold shutdowns. Therefore, until sufficient technical justification is provided for not stroke exercising these valves at cold shutdowns, it is recaiuended that this relief request be denied. f2.7.1.3 Relief Request: Valves SWN-42 (5 valves) and SWN-43 (5 valves) will not be stroked to the requirements of Section XI. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: Valves SWN-42 and SWN-43 (5 valves each) are passive CIV's and are nonnally closed, which are required to be closed during an accident condition. Evaluation: SWN-42 (5 valves) and SWN-43 (5 valves) are designated as CIV's and are located in the fan cooler drain lines. Emergency function is to close, therefore, they can be considered passive valves. It is recommended, per item 2.1.b, that relief be granted from the stroking requirements of the Code. 2.7.2 Code Relief - Category B Valves 42.7.2.1 Relief Request: Valves FCV-1111 and FCV-1112 will be f ull stroke exercised at refueling outages in lieu of Section XI requirements. Code Requirement: See Code Requi rement Item 2.3.2.1. Licensee Basis for Relief Request: These valves cannot be exer-c1 sed during normal plant operations or at cold shutdowns, but can be full stroke exercised at refueling outages. Part stroke exer-cising these valves during nonnal plant operations or at cold shut-downs is also impractical. Evaluation: Valves FCV-1111 and FCV-1112 are in the normal service water supply to ~the conventional plant equipment. The Licensee plans to full stroke exercise these valves at refueling outages, but has not provided sufficient technical justification for not full or part stroke exercising them during normal power operations

  ; Requires NRC Review 33                             1840 279

or at cold shutdowns. This its must rmain open until such time as the Licensee reviews these valves and provides adequate tech-nical justification for not exercising these valves during nomal power operations or cold shutdowns. It is recommended that this relief request be denied at this time. . 2.8 Post Accident Containment Air Sampling System (Special Pullout) 2.8.1 Coce Relief - Category A Valves ~ 2.8.1.1 Relief Reauest: Val ve s 1875 A , 1875 B , 1875 C , 18750, 1875 E , 1875 F , 1875G,1875H, and 1875) will not be stroked to the requirments of Section XI. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: These valves are passive CIV's and are normally closed, witch are required to be closed during an accident condition. Evaluation: Valves 1875A thru J are Containment Isolation Valves in tne post accident contaiment air sampling systs. The valves are normally closed valves whose emergency function is to close, therefore, they can be considered passive valves. It is recam-mended, per item 2.1.5. that relief be granted from the stroking requirments of the Code. 2.9 Hydrogen Recombiner System (A206741) 2.9.1 Code Relief - Category A Valves 2.9.1.1 Relief Request: Valves 1882A,1876A,1875A,1876B, and 1875B will not be stroked to the requirements of Section XI. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Reauest: These valves are not required to cnange tneir position for any safety function. Evaluation: Vales 1882-9,1876-9,1875-9,1876-8, and 1875-8 are CIV's in the hydrogen recombiner system. The valves are normally closed valves, whose mergency function is to close, therefore, they can De considered passive valves. It is recommended, per Item 2.1.5, that relief be granted fran the stroking requirments of the Code. ~ 2.10 Waste Disposal System (A206737) and (A206743) 2.10.1 Code Relief - Category A Valves 2.10.1.1 Relief Reauest: Valve 1616 will not be stroked to the requirements et Section XI. 34 - 1840 280

Code Recuirement: See Code Requirment Its 2.3.1.1 for category A and see item 2.3.3.1 for category C valves. Licensee Basis for Relief Request: This valve is a Passive CIV, and is nomally closed, vk11ch is required to be closed during an accident condition. Evaluation: Valve 1616 is a category AC Containment Isolation Check Valve located in the nitrogen supply manifold of the waste dis osal system to the pressure relief tank. This is a normally closed valve, vkiose safety function is to close, therefore, it can be considered a Passive Valve. It is recommended, per item 2.1.5, that relf ' be granted fra the stroking requirments of the Code. 2.11 Main Steam System (A206734) 2.11.1 Code Relief - Category B Valves

  # 2.11.1.1  Relief Request: Valves MS-41 and MS-42 will be stroked every 6 months wnen the auxiliary feedwater pumps are in use.

Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Reauest: These valves cannot be stroked every 3 months according to Section XI requirments but will be stroked at 6 month intervals when the auxiliary feedwater pumps are used. Evaluation: MS-41 and MS-42 are shutof f valves in the steam supply lines to tne steam driven feedwater pump's turbine. Presently this auxiliary feedwater pump is not in the IST program. The pump is run at 6 month intervals and the subject valves, exercised at this interval as well. Testing of these valves is tied with the possi-bility of the Licensee including the auxiliary feedwater pump in the IST program. This item must reain open until such time as the Licensee reviews this auxiliary feedwater pump for possible inclu-sion in the IST program and the testing of this pump is defined. Therefore, it is recommended, that until the review is complete, the above relief request should be denied. 2.11.1.2 Relief Request: Valves PCV-1310A and PCV-1310B will be full stroke axercised at refueling outages in lieu of Section XI requirements. code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Request: These valves cannot be full

~             stroke exercised during normal plant operations or at cgl       t-
                                                                                     }

downs, but can be full stroke exercised at refueling outja -P . stroke exercising these valves during normal plant operations or at cold shutdowns is also impractical . FRequires NRC Review 35 1840 281

Evaluation: Valves PCV-1310A and PCV-1310B are Air Operated Shut-off Valves in the steam supply lines to the turbine driven auxili-ary feedwater pump. The Licensee plans to full strcke exercise these valves at refueling outages, but has not provided sufficient technical justification for not full or part stroke exercising them during normal plant operations or cold shutdowns. . This item must remain open until such time as the Licensee reviews these valves and provides sufficient technical infomation to justify not exercising these valves quarterly or at cold shutdowns. ~ It is recommended that this relief request be denied at this time. 2.12 Boiler Feedwater System ( A206736) 2.12.1 Code Relief - Category B Valves

 # 2.12.1.1  Relief Request: Valves FCV-427L, FCV-437L, FCV-417L, and FCV-447L will be full stroke exercised at refueling outages in lieu of Sec-tion XI requirements.

Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis for Relief Request: These valves cannot be full strcke exercised curing nomal piant operations or at cold shut-downs, but can be full stroke exercised at refueling outages. Part stroke exercising these valves during nomal plant operations or at cold shutdowns is also impractical . Evaluation: Valves FCV-427L, FCV-437L, FCV-417L, and FCV-447L are shutof f valves in the feedwater regulator bypass lines (low flow control path). The Licensee was requested and has agreed to review these valves to detemine if ful1 or part stroke exercising is practical on a quarterly basis during normal plant operations. The Licensee presently plans to full stroke exercise these valves at refueling outages. This item must remain open until such time as the Licensee provides sufficient technical justification for not ex-ercising these valves during normal plant operations or at cold shutdowns. At this time, it is recmmended that this relief re-quest be denied. 2.12.2 Code Relief - Category C - Check Valves 2.12.2.1 Relief Request: Valves BFD-79 (4 in all), will be full stroke exercised at refueling outages and part stroke exercised at cold shutdowns in lieu of Section XI requirements. ~ Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: These valves cannot be full or part stroke exercised quarterly during nomal plant operations and also cannot be full stroke exercised at cold shutdowns. These FRequires Nki, Review 18/0t 282 36

valves can be full strcke exercised at refueling outages and part stroke exercised at cold shutdowns. Evaluation: BFD-79 (4 valves) are Check Valves in the auxiliary feeuwater lines at the interface of the main feedwater line. The Check Valves are kept closed by the main feedwater system pressure during power operations. Their energency function is to open when , the auxiliary feedwater pumps are activated to supply emergency feedwater fran the Condensate Storage Tank (CST). Exercising these Check Valves quarterly is impractical in that the auxiliary feed- . water pumps must be activated to ficw ambient tenperature water from the CST to the Steam Generators (SG) which can result in ther-mal shocking the SG tubing. Full stroke exercising at cold shutdowns is impractical in that the high flowrates required for full stroke exercising make it dif-ficult to control water levels in the SG's. Excessively high water levels in the SG's can result in water in the steamlines, which can lead to turbine damage when power operations are resumed. The Licensee presently plans to part stroke exercise these Check Valves at cold shutdowns and full stroke exercise them at refueling outages. The Licensee has adequately demonstrated the impracticality due to plant design of exercising the subject Check Valves quarterly and of full strcke exercising them at cold shutdowns. Therefore, i t is recommended, per HRC guidelines, that relief be granted as request-ed. 2.12.2.2. Relief Request: Val ves BFD-39, BFD-34, BFD-37, BFD-35, BFD-42, a nd BFO-40 will De full stroke exercised at refueling outages and part stroke exercised at cold shutdowns in lieu of Section XI require-ments. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Reauest: These valves cannot be full or part stroke exercised auarterly during nonnal plant operations and also cannot be full stroke exercised at cold shutdowns. These valves can be full stroke exercised at refueling outages and part stroke exercised at cold shutdowns. Evaluation: BFD-39 and BFD-34 are auxiliary feedwater pump (motor criven) discharge check valves. BFD-3 5, BFD-3 7, BFD-40, a nd BFD-4 2 are Check Valves in the auxiliary feedwater supply lines from the ~ motor driven auxiliary feedwater pumps that are redundant isolation valves in series with check valves FBD-79. The subject Check valves are nonnally closed and have an energency function to open when the auxiliary feedwater pumps (motor driven) are activated to provide condensate storage tank water to the steam generators. It should be noted that the motor driven auxiliary feedwater pump test recirculation lines are upstrean, of these Check Valves thus preclu-ding any exercising during monthly pump tests. 37 1840 283

Part stroke exercising at cold shutdowns and full ctroke exercising at refueling outages is justified, based on the evaluation given for the cFD-79's, see item 2.12.2.1. Therefore, it is recommended per NRC guidelines, that relief be granted as requested. 2.12.2.3 Relief Request: Valves BFD-31 and BFD-47 (4 valves) will be full stroke exercised at refueling outages in lieu of Section XI re-quirements. Code Requirement: See Code Requirement Item 2.3.3.1. ~ Licensee Basis for Relief Request: These valves cannot be full or part stroke exercised quarterly during nomal plant operations and also can neither be full or part stroke exercised at cold shut-downs. Evaluation: Valve BFD-31 is an auxiliary feedwater pump (turbine driven) discharge Check Valve. BFD-47 (4 valves) are in the aux-iliary feedwater supply line from the turbine driven pump and are redundant isolation valves in series with the valves designated BFD-79. The subject Check Valves are nomally closed and have an emergency function to ope. when the turbine driven auxiliary feedwater pump is activated to provide condensate storage tank water to the steam generators. It should be noted that the pumps test recirculation line is upstream of the Check Valves thus precluding any exercising during periodic pump tests. Part stroke exercising at cold shutdowns is impractical in this case due to the fact that there is na steam available for stroking (either full or part stroking). Full stroke exercising at refuel-ing outages is justified, based on the evaluation given for the BFD-79 valves, see item 2.12.2.1. Therefore, is is recommended per NRC guidelines, that relief be granted as requested. 2.13 Condensate and Boiler Feed Pumn System ( A206735) 2.13.1 Code Relief - Category C - Check Valves 2.13.1.1 Relief Request: Valves CT-32 and CT-26 will be full stroke exer-cised at refueling outages and part stroke exercised at cold shut-downs in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: These valves cannot be full or part stroke exercised quarterly during normal plant operations and also cannot be full stroke exercised at cold shutdowns. These valves can be full stroke exercised at refueling outages and part stroke exercised at cold shutdowns. 38 1840 284

Evaluation: Valves CT-32 and CT-26 are inlet Check Valves to the motor driven auxiliary feedwater pumps from the condensate storage water tans. The Check Valves are nonnally closed and have an emer-gency function to open when the motor driven auxiliary feedwater pumps are activated to provide condensate storage tank water to the steam generators. The valves are presently part stroke exercised during pump testing at a frequency greater than the Code required. In that these Check Valves are upstream, und in series with the BFD-79s, full stroke exercising quarterly and at cold shtudowns is considered impractical. This is based on the evaluation given for ~ the BFD-79 valves, see item 2.12.2.1. Therefore, it is recommend-ed, per NRC guidelines, that relief be granted as requested. 2.13.1.2 Relief Request: Valve CT-29 will be full stroke exercised at re-fueling outages in lieu of Section XI requirements. Code Requirement: See Code Requirement Item 2.3.3.1. Licensee Basis for Relief Request: This valve cannot be full or part stroke exercised quarterly during normal plant operations and also can neither be full or part stroke exercised at cold shut-downs. Evaluation: Valve CT-29 is an inlet Check Valve to the turbine ariven auxiliary feedwater pump from the condensate storage water tank. The Check Valve is normally closed, and has an emergency function to open when the turbine driven auxiliary feedwater pump is activated to provide condensate storage tank water to the steam generators. Part stroke exercising this valve, like CT-32 and CT-26 (per item 2.13.1.1) is upstream and in series with the BFD-79 valves, so ful' stroke exercising quarterly and at cold shutdowns is also considered impractical . This is based on the evaluation given for the BFD-79 valves, see item 2.12.2.1. Therefore, it is recommended, per NRC guidelines, that relief be granted as requested.

 #2.14      Miscellaneous CIV's 2.14.1    Code Relief - Category A Valves 2.14.1.1  Relief Reauest: Valves 85A, 85B, 85C, 850, 95A, 95B, 95C, 95D, MV-17 (2 valves), SA-24 (2 valves), 1170, 1171, 1172, and 1173 will not be stroked to the requirements of Section XI.

Qde Re irement: See Code 0.equirement Item 2.3.1.1. Licensee Basis for Relief Request: These valves are passive CIV's and are normally closed, which are required to be closed during an accident condition. Evaluation: Valves 85A, 85B, 85C, 85D, 95A, 95B, 95C, 950, MV-17 (2 valves), SA-24 (2. valves) 1170, 1171, 1172, and 1173 are Miscel-laneous Containment Isolation Valves (CIV's). Valves 85A, 85B,

  ?P+10's were not available to detennine whether or not NRC Review is required 39 1840 285

85C, 850, 95A, 958, 95C, and 950 are located in the 80' elevation personnel airlock. It should be noted that the A and B designated valves in each case are Check Valves. Valves MV-17 (2 valves) and SA-24 (2 valves) are city water to containnent and service air to containment valves respectively. Valves 1170, 1171, 1172, and 1173 are valves located in the containment purge system. All the above valves are nomally closed during power operations, and their safety function is to close. As such, these valves are considered passive. Therefore, it is recommended, per item 2.1.5, that relief be granted from the strokng rcquirements of the Code. ~ 2.14.1.2 Relief Request: Valves 1814A,18148, and 1814C will satisfy Cate-gory E requirements set forth in IWV-3700, but since they are CIV's, these valves will also satisfy the Category A leak testing requirements of I';V-3420. They will be exempt from the exercising requirements of iWV-3410. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: These valves will satisfy the above requirements because of their locked status. Evaluation: Valves 1814A,1814B, ar! 1814C are CIVs located in the containment pressure sensing instrument lines. The Licensee plans to review these valves for cycling requirenents. Therefore, until such time as the Licensee provides sufficient technical information for the cycling requirements, it is recommended that this relief request be denied. 2.14.1.3 Relief Request: Valves UH-43 and UH-4* will i at be stroked to the requirements of Section XI. Code Requirement: See Code Requirement Iten 2.3.1.1. Licensee Basis for Relief Request: These valves are passive CIV's and are locked closed, therefore exercising them is not necessary. Evaluation: Valves UH-43 and UH-44 are locked closed CIVs in the auxiliary steam system. They are nomally closed, during power operation, and have a safety function to close. Therefore, these valves are considered passive valves. It is recommended then, per item 2.1.5, that relief be granted from the stroking requirements of the Code. 2.14.1.4 Relief Request: Valve PCV-1228 will be full stroke exercised at refueling outages in lieu of Section XI requirements. ~ Coie Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis for Relief Request: This valve cannot be full stroke exercised during nomal plant operations or at cold shut - downs, but can be full stroke exercised at refueling outages. Part stroke exercising this valve during nomal plant operations or at cold shutdowns is also impractical . . 40 1840 286

Evaluation: Valve PCV-1228 i: a nonaally open CIV in the Instru-ment Air System (Post Accident Venting Supply). The valve design is such that is can be only full stroke exercised (an open or closed only valve), therefore part stroke exercising it is impractical both during nonnal plant operation or cold shutdown. Full stroke exercising the valve quarterly during power operations or at cold shutdowns is considered impractical in that it shuts off the operating air supply to the valves inside containment, which are required to be operational during both power and cold shutdown operations. The Licensee plans to full stroke exercise the valve at refueling outages. Therefore, it is recommended that relief be granted to full stroke exercise this valve at refueling outages in lieu of Section XI requirements. 2.14.1.5 Relief Request: Valve IA-39 will satisfy the category A leak test-ing requirements of IWV-3420 and will be exempt frcm the exercising requirement of IWV-3410 and IWV-3520. Code Requirement: See Code P,equirement Item 2.3.1.1 for category A and for category C valves see Item 2.3.3.1. Licensee Basis for Relief Request: These valves are check valves that serve as containment isolation valves and as such are cate-gorized as category AC. Accordingly, these valves will satisfy the category A leak testing requirements of IWV-3420. Existing plant design and construction provides no means for indication or veri-fication of check valve disk motion in either direction. However, proper position for satisfying the containment isolation function is confinned by acceptable category A valve leak rate testing res ul t s. Therefore, these category AC check valves will be exempt from the exercising requirement of IWV-3410 and IWV-3520. Evaluaticn: IA-39 is a CIV (check valve) in the instrument air system (Post Accident Venting Supply). Exercising the valve closed would require shuting off the operating air supply to the other valves which are required to be operational during power and cold shutdown operations. Based on this, and based on the reasoning given by the Licensee in his " Basis for Relief Request," it is reconmended that relief be granted from the Code required exercise frequency. O 1840 287 41

3.0 COLD SHUTDOWN TESTING OF VALVES 3.1 General : 3.1.1 Valves shall be exercised to the position required to fulfill their func., ion unless such operation is not practical during plant oper-ation. If only limited operation is practical during plant oper-ation, the valve shall be part-stroke exercised during plant oper-ation and full-stroke exercised during cold shutdowns. Valves that cannot be exercised during plant operation shall be full-stroke ex- , ercised during cold shutdowns. Full-stroke exercising during cold shutdowns for valves not full-stroke exercised during plant oper-ation shall be on a frequency detennined by the intervals between shutdowns as follows: for intervals of 3 months or longer, exer-cise during each shutdown; for intervals of less than 3 months, full-stroke exercise is not required unless 3 months have passed since last shutdown exercise. The intent of this section is to satisfy the requirements of the NRC letter dated January 13, 1978, i .e. , "NRC Staff Guidance For Preparing Pump and Valve Testing Program Descriptions and Associ-ated Relief Requests Pursuant to 10 CFR 50.55 a(g)," specifically sectic,n 5, page 7. 3.2 Safety Injection System ( A206744) 3.2.1 Category B Valves 3.2.1.1 Valves: 856B and 856F Code Requirement: See Code Requirement Item 2.3.2.1 Licensee Basis: These valves cannot be full-stroke exercised quarterly during normal plant operation in that if the valves failed in the open position during nonnal plant operation and a loss of coolant accident (LOCA) were to occur, a potential for steam binding could take place, which would prevent an adequate flow of reactor cooling water from reaching the core. Evaluation: Valves 856B ond 85SF are shut-off valves in the Safety Injection (SI) lines leading to the hot legs of the Reactor Coolant System (RCS), and are valves that are only capable of being full-stroke exercised. Part-stroke exercising these valves would be impractical during normal plant operation. The valves are normally closed and have a safety function to open approximately 24 hours after the cold leg injection has been initiated. Full-stroke exercising the valves quarterly while the ~ plant is at nonnal operating power is impractical in that a failure in the closed position, concurrent with a loss of coolant accident (LOCA), can result in a steam-binding affect which would prevent adequate cooling water from reaching the core. It is recommended, per NRC guidelines, that the Licensee be allowed to full-stroke ex-ercise these valves at cold shutdowns. , 42 1840 288

3.2.2 Category C - Check Valves 3.2.2.1 Valves: 897A, 897B, 897C and 8970 Code Requirement: See Code Requirement Item 2.3.2.1 Licensee Basis: These check valves cannot be full or pert-stroke . exercised every 3 months while the plant is in normal operation. The Reactor Coolant System (RCS) operates at approximately 2200 psig which acts to keep thea closed. These cneck valves will be . full-stroke exercised at cold shutdowns. Evaluation: Valves 897A, 897B, 897C and 897D are pressure isola-tion check valves in the cold leg injection lines to the RCS and are at the interface of the RCS and Safety Injection System (SIS). The valves are held closed by the RCS pressure during normal power operation, and their emergency function is to open to pennit flow from the SIS into the RCS following a LOCA. 897A and 897C are in the flowpaths from the High Pressure Safety Injection (HPSI) pumps, and 897A thru 8970 are in the flowpaths from the recirculation pumps, RHR pumps, and from the respective accumulators. The system configuration is such, that the only practical way the valves can be exercised is by putting flow through them from one of the SI pumps or accumulators. During normal power operations, the RCS pressure is approximately 2200 psig. None of the forementioned pumps or accumulators have the pressure capability to overcme this RCS pressure in order to establisn flow through the check valves. All four check valves will be full-stroke exercised during each cold shutdown when the residual heat removal mode of cooling is in operation. It is recommended then, due to the impracticality caused by plant design, that the Licensee be allowed to full-stroke exercise these valves at cold shutdowns. 3.2.2.2 Valves: 838A, 838B, 838C and 8380 Code Requirement: See Code Requirement Item 2.3.3.1 Licensee Basis: These check valves cannot be full or part-stroke exercised every 3 months while the plant is in normal operation. The Reactor Coolant System (RCS) operates at approximately 2200 psig, which acts to keep check valves 897A, B, C, D closed. The 897 valves are downstream of and in the respective flowpaths of the subject check valves. These 838 valves will be full-stroke exer-cised at cold hutdowns. Evaluation: Pressure isolation valves 838A, 838B, 838C and 838D are in the cold leg injection lines from the recirculation pumps and Residual Heat Removal (RHR) pumps. The valves are held closed by the RCS pressure during normal power operation, and their emer-gency function is to open to permit flow from the RHR (LPSI Mode) or recirculation pumps to the RCS following a LOCA. 838A thru 838D 43 1840 289

are upstrema and in series with 897A thru 897D respectively, in that 897A thru 897D cannot be opened quarterly, the evaluation for 897A thru 897D applies for the subject check valves. 838A thru 8380 will be full stroke exercised at cold shutdowns when the re-sidual heat renoval mode of cooling is in operation. It is recommended then, due to the impracticality caused by plant design, that the Licensee be allowed to full stroke exercise these valves at cold shutdowns. ~ 3.3 Auxiliary Coolant System (A206738) 3.3.1 Category A Valves 3.3.1.1 Valves: 797, 784, and FCV-625 Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis: These valves cannot be full stroke exercised quarterly curing normal plant operation. To do so would damage the Reactor Coolant (RC) pumps by causing loss of bearing cooling water. Evaluation: Val ves 797, 784, and FCV-625 are all containnent isolation valves in the component cooling system that supplies coolant water to the RHR pump's bearing oil coolers and thermal barriers. The valve is nonnally open and has an energency function to close following the receipt of a containment isolation signal. This valve is also an open or closed only valve, therefore, part stroke exercising it is impractical. Full stroke exercising the valve quarterly while the plant is at normal operating power is also impractical in that doing so, shuts off coolant water to the reactor coolant pumps bearing oil cooler and can result in damage to the RC pump bearings. The valve will be full stroke exercised at those cold shutdown conditions (includes refueling) where the RC pumps can be shutdown. Valve 784 is a CIV in the component cooling system on the return leg from the RC pump motor bearing coolers. The valve is normally open and has an emergency function to close upon receipt of a con-tainment isolation signal. Valve FCV-625 is a CIV in the component cooling system on the return leg from the thermal barriers. The valve is also normally open and has an emergency function to close upon receipt of a containment isolation signal . Both valves 784 and FCV-625, like valve 797, are open or closed only valves and are impractical to full stroke exercise quarterly and part stroke exercised during normal plant operation. There-fore, it is recanmended, per NRC guidelines, that the Licensee be allowed to full stroke exercise these valves at cold shutdowns. 44 1840 290

3.3.1.2 Valve: 741 Ccde Requirement: See Code Requi raaent Iten 2.3.1.1. Licensee Basis: None provided. Evaluation: Valve 741 is a category AC check valve and a contain-ment 1 solation valve in the outlet line from the Residual Heat Re-moval (RHR) pumps. This valve is r.ormally closed, and its safety related function is to open when the RHR pumps are used in the LPSI mode of emergency cooling. This valve will be full stroke ex-ercised at cold shutdowns during the normal shutdown cooling mode of operation of the RHR pumps. However, this item must renain open until such time as the Licensee determines if the RHR monthly pump tests at miniflow conditions full stroke exercises the subjsct check valve quarterly. 3.3.2 Category B Valves 3.3.2.1 Valves: 822A and 822C Code Requirement: See Code Requirerent Item 2.3.2.1. Licensee Basis: These valves cannot be exercised quarterly during nonnal plant operation. To do so may divert flow fran the canpo-nent cooling systen via these 12" valves. Evaluation: Valves 822A and 822B are shutoff valves in the com-ponent cooling system on the returi. leg from the residual heat ex-changers. The valves are normally closed and have an emergency function to open in order to allow component cooling water flow to the residuil heat exchangers. These valves are also open or closed only valves therefore, part stroke exercising them is impractical. The Licensee presently plans not to full stroke exercise these valves quarterly in that doing so would divert flow from the com-ponent cooling system. This could result in a reduced cooling flow to the RC pump coolers and thermal barriers which can result in creating a potential for overheating and damaging the RC pumps. These valves will be full stroke exercised at cold shutdowns. Therefore, it is recamnended, per NRC guidelines, that the Licensee be allowed to full stroke exercise these valves at cold shutdowns. 3.3.2.2 Valve: 769 Code Requirement: See Code Requi rer<ent Item 2.3.2.1. Licensee Basis: This valve cannot be full stroke exercised quar-terly during normal plant operation. To do so would damage the reactor coolant pumps by causing loss of bearing cooling water. 1840 291

Evaluation: Valve 769 is a shutoff valve in that part of the con-ponent cooling system that supplies coolant water to the RHR pump's bearing oil coolers and thermal barriers. The valve is nomally cpen and has an emergency function to close following the receipt of a containment isolation signal. This valve is also an open or closed only valve, therefore, part stroke exercising it is impractical . Full stroke exercising the valve quarterly while the plant is at normal operating power is also impractical in that doing so, shuts off coolant water to the reactor coolant (RC) pumps bearing oil cooler and can result in damage to the RC pump be- ~ arings. The valve will be full stroke exercised at those cold shutdown conditions (includes refueling) where the RC pumps can be shutdown. Therefore, it is reconimended, per NRC guidelines, that the Licensee be allowed to full stroke exercise this valve at cold shutdowns. 3.3.2.3 Valve: 786 Code Recuireme,n: See Code P,equirement Item 2.3.2.1. Licensee Ba m : This valve cannot be full stroke exercised quar-terly durit.g nomal plant operation. To do so would damage the reactor coolant pumps by causing loss of bearing cooling water. Evaluation: Valve 786 is a shutoff valve in the component cooling system on the return leg from the RCP motor bearing coolers. The valve is normally open and has an emergency function to close upon receipt of a containment isolation signal. This valve is also an open or closed only valve therefore, part stroke exercising it is impractical. Full stroke exercising the valve quarterly while the plant is at normal operating power is also impractical in that doing so shuts off coolant water to the Reactor Coolant (RC) pumps bearing oil cooler and can result in damage to the RC pump be-arings. The valve will be full strcke exercised at those cold shutdown conditions (includes refueling) where the RC pumps can be shutdown. There%re, it is recommended, per NRC guidelines, that the Licensee be allowed to full stroke exercise this valve at cold shutdowns. 3.3.2.4 Valve: 789 Code Reauirement: See Code Requirement Item 2.3.2.1. Licensee Basis: This valve cannot be full stroke exercised quar-terly during nomal plant operation. To do so would damage the Reactor Coolant pumps by causing loss of bearing cooling water. Evaluation: Valve 789 is a shutoff valve in the component cooling system on the return leg fraa the themal barriers. The valve is normally open and has an emergency function to close upon receipt 46 1840 292

of a containment . isolation signal. This valve is also an open or closed only valve, therefore, part stroke exercising it is impractical . Full stroke exercising the valve quarterly while the plant is at nor:r.al operating power is also impractical in that doing so, shuts off coolant water to the Reactor Coolant (RC) pumps bearing oil cooler and can result in damage to the RC pump be-arings. The valve will be full stroke exercised at those cold ~ shutdown conditions (includes refueling) where the RC pumps can be shutdown. ~ Therefore, it is recanmended, per NRC guidelines, that the Licensee be allowed to full stroke exercise this valve at cold shutdowns. 3.4 Chemical and Volume Control System (A206745 and A206746) 3.4.1 Category A Valves 3.4.1.1 Valve: 222 Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis: This valve cannot be full stroke exercised during normal plant operation in that if the valve were in the closed position during nonnal plant operation, a loss of Reactor Coolant (RC) pump seal water flow would result, thus damaging the RC pumps. The RC pumps must be off in order to full stroke exercise at cold shutdowns. Evaluation: Valve 222 is a shutoff valve in the RC pump seal water return line. In addition, this valve is an open or closed only valve, therefore, part stroke exercising it is impractical . Ful l stroke exercising the valve quarterly during normal plant operation is also impractical in that this action would perturb reactor cool-ant pump seal water flow and thus could damage the seals as a re-sul t. This valve will be full stroke exercised at those cold shutdowns when the RC pumps are not in use. lherefore, it is recommended, per NRC guidelines, that the Licensee be allowed to full stroke exercise thi s valve at cold shutdowns. 3.4.1.2 Valves: 241A, 241B, 241C, 2410, 250A, 2508, 250C, and 250D. Code Requirement: See Code Requi rement Item 2.3.1.1 Licensee Basis: These valves cannot be fullstroke exercised during normal plant operation in that if the valves were in the closed pcsition during nonnal plant operation, a loss of RC pump seal water would result, thus damaging the RC pumps. The RC pumps must be off in order to full stroke exercise at cold shutdowns. Evaluation: Val ves 241A, 2418, 241C, 241D , 250A, 2500, 250C, a nd 25JD are shutoff valves in the charging lines to the RC pump seals. 1840'293

In addition, these valves are open or closed only valves, there-fore, part stroke exercising them is impractical. Full stroke ex-ercising the valves quarterly during nomal plant operation is also impractical in that this action would perturb RC pump seal water flow and thus could damage the seals as a result. These valves will be full stroke exercised at those cold shutdowns when the RC pumps are not in use. Therefore, it is recommended, per fiRC guidelines, that the Licensee ~ be allowed to full stroke exercise these valves at cold shutdowns. 3.4.1.2 Val ves : 241A, 241B, 241C, 2410, 250A, 2508, 250C, and 2 BOD. Code Requirement: See Code Requirement Item 2.3.1.1. Licensee Basis: These valves cannot be full stroke exercised dur-ing nomal plant cperation in that if the valves were in the closed position during normal plant operation, a loss of RC pump seal water would result, thus damaging the RC pumps. The RC pumps must be off in order to full stroke exercise at cold shutdowns. Evaluation: Val ves 241A, 241B, 241C, 2410, 250A, 250B, 250C , and 2500 are shutoff valves in the charging lines to the RC pump seals. In addition, these valves are open or closed only valves, there-fore, part stroke exercising them is impractical. Full stroke ex-ercising the valves quarterly during normal plant operation is also impractical in that this action would perturb RC pump seal water flow and thus damage the seals as a result. These valves will be full stroke exercised at those cold shutdowns when the RC pumps are not in use. Therefore, it is recommended, per fiRC guidelines, that the Licensee be allowed to full stroke exercise these valves at cold shutdowns. 3.5 Boiler Feedwater System (A206736) 3.5.1 Category B Valves 3.5.1.1 Valves: FCV-427, FCV-41/, FCV-43/, and FCV-447. Code Requirement: See Code Requirement Item 2.3.2.1. Licensee Basis: These valves cannot be full stroke exercised quarterly during normal plant operation. Full stroking would cause a reactor trip. The reactor trip would be caused by a loss of feedwater. Evaluation: Valves FCV-427, FCV-417, FCV-43 7, and FCV-447 are the main feedwater regulators which are open during power operations to control the main fecdwater supply to the steam generators. 48 1840 294

Exercising these valves quarterly is impractical during power oper-ations in that it would shutoff the feedwater to the steam genera-tors, which could result in a reactor trip condition. The Licensee is proposing to full stroke exercise these valves at cold shut-downs. The Licensee has adequately demonstrated the impracticality of full stroke exercising these valves quarterly. Therefore, it is recom-mended, per NRC guidelines, that the licensee be allowed to full stroke exercise these valves at cold shutdowns. Presently, the timing for these valves, has not been addressed. 3.6 Main Steam System (A206734) 3.6.1 Category B Valves 3.6.1.1 Valves: MS-1-21, MS-1-22, MS-1-23, and MS-1-24. Code Requirement: See Code Requirement Items 2.3.2.1 and 2.3.3.1. Licensee Basis: These Main Steam Isolation Valves (MSIVs) are categorized as BC. They are stop check type valves with pneumatic operators holding the valve disks out of the main steam flow path. The MSIVs will satisfy the exer cising requirements of IWV-3410 but, as permitted by IWV-3410(b)(1), will be full stroke exercised only during cold shutdown at refueling outages as presently required by the plant technical specifications. Part stroke exercising of these valves during normal plant operation is not practical. Evaluation: These MSIVs cannot be full stroke or part stroke ex-erciseo quarterly because to do so would cause a reactor trip. The reactor trip would be caused by the turbine tripping off the line. The turbine trip would be based on receiving a Valve Position Change Signal. The Licensee has adequately demonstrated the im-practicality of full stroke exercising these valves quarterly. Therefore, it is recommended, per NRC guidelines, that the licensee be allcwed to full stroke exercise these valves at cold shutdowns. Presently the timing for these valves has not been addressed. 1840 295

4.0 PROGRAM BREAKD0WN 4 .1 Safety Injection System ( A206744) 4.1.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category

                  %869A                AE                880A            B

. %8698 AE 880B B

                  %851A                A                 880C            B 18518                A                 8800            B
                  '7485A               A                 880E            B "J 85B               A                 880F            B
                  *J88A                A                 880G            B "J 88B               A                 880H            B "J78A                AE                880J            B
                  %878B                AE                880K            B 866A               B                 846             E 866B               B                1860             E 866C               B                1806A            E 866D               B                1806B            E 887A               B                1841             E 887B               B                1839A            E 889A               B                1839B            E 889B               B                1823F            E "J76A                B                 873B            E
                  #476B                B 1802A               B 4.1.2       The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore will be added to the resubmittal as shown.

Valve Category Valve Category 886A C 848A E 886B C 8488 E 881 C 849A C 865A E 849B . C 865B E 852A C 879A C 852B C 8798 C 1838A C ~ 847 C 1838B C

   %     876A and 876B. The licensee will review valve alignment required to test these valves to see if the system is piaced in a non-aligned situation.
   %     Valves 869A&B, 851 A&B, 885A&B, 888A&B and 878A&B will meet the Code for stroking only.

1840 296 50

4.1.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "HRC Staff Guidance for Preparing Pump / Val ve Testing.. . ," dated January 13, 1978). Valve Valve . 1805 891C 882 891D 1810 855 . 894A 1828 894B 1815 894C 892A 894D 892B 898 892C 891A 892D 891B 4.1.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Additional infonnation is required be the NRC to verify the impracticality of full stroke exercising every 3 months. Valve Category Valve Category 856B B 8970 C 856F B 838A C 897A C 838B C 897B C 838C C 897C C 8380 C 4.1.5 The following are valves in the IST submittal that cannot meet the requirenents of Section XI and relief has been requested. Valve C tegory Valve Category

               +867A               AC                 843              B
               +867B               AC                 857A             C
               +850A               AE                 857B             C
               +850B               AE                 857C            C
               +859A               AE                 857D             C
               +859C               AE                 857G             C
               +863                A                  857H             C
             +4312                 AC                 857M             C
               +743                AE                 857F             C
             +1870                 AE                 857E             C

~ 856A B 857L C 856C B 857K C 8560 B 857J C 856E B 895A C

 +     General Reliet Request 2.2.1 1840 297 51

Valve Category Valve Category 842 B 895B C 895C C 849B C 895D C 852A C 886A C 8528 C 886B C 1838A C . 881 C 18388 C 879A C 1831 B 879B C 1821 B . 847 C 1822A B 849A C 1822B B 4.2 Auxiliary Coolant System (A206738) 4.2.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirenent. Valve Category Valve Category

               %796                  A                    735A            E
               %793                  A                    735B            E
               %798                  A                   1819             E
               %791                  A                    832             E 745A                B                    761A            C 745B                B                    761B            C HCV-638                B                    761C            C HCV-640                B                    758             C 739A                E                    755A            C 739B                E                    755B            C 742                 E                   %746             B
                                                         %747             B 4.2.2       The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore will be added to the resubmittal as shown.

Valve Category Valve Category 761A C 758 C 761B C 755A C 761C C 755B C ~ 4.2.3 The following are valves that were listed in the IST submittal and were deleted fran the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing Pump / Val ve Testing. . . ," da ted Janua ry 13, 1978).

 %     /46 and 747. Licensee will perfom a review to detemine what position valve to be in during normal operation. Currently these valves are closed during operation.
 %     796, 793, 798 and 791. Will meet the Code for stroking only.

52 1840 298

Valve Valve 730 18730 731 831 734A 7 82 734B 783A 734E 783B ~ 734F 783C 733C 783D RCV-017 785B . 756A 7 92 756B 819A 1873A 819B 1873B 835 1873C 1036 4.2.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Additional information is required by the NRC to verify the impracticality of full stroke exercising every 3 months. Valve Category valve Category

               +741                AC                 822B             B
               +797                A                  769              B
               +784                A                  786              B
            +FCV-625               A                  789              8 822A               B 4.2.5      The following are valves in the IST submittal that cannot meet the requirenents of Section XI and relief has been requested.

Valve Category Valve Category

               +744                A                 +732              AE 4.3        Chemical and Volume Control System ( A206745)

(A206746) 4.3.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirenent. Valve Category Valve Category 200A B 200C B ~ 4.3.2 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "HRC Staff Guidance for Preparing Pump / Valve Testing. . . ," dated January 13, 1978).

 +     General Reliet Request 2.2.1                                 8    0 299 53

Valve Valve 1100 LCV-112A 1247 387 1133 391 PCV-1049 343B 1269 3238 1679 TCV-149 1109 309 1104 311A

.                           1119                         340A 1120                         346 HCV-133                        352 212                         269 LCV-459                    FCV-111B 204A                    LCV-112C 204B                    FC -110B 213                         293 HCV-123                    FCV-110A 215                     LCV-112B PCV-135                        28 8 271                         333 310                         364 313                         367A HC V-104                       367B 358                     HCV-105 372                         366 295                         237 285                         281 FCV-111A                       273 265                         276 268                         359 218                         371 203                       1263 264                       1264 231                       1102 234 4.3.3       The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Additional infonnation is required by the NRC to verify the impracticality of full stroke exercising every 3 months.

Valve Category Valve Category

                +241A                A                +250B             A

~

                +241B                A                +2 50C            A
                +241C                A                +2500             A
                +241D                A                +2 22             A
                +250A                A 1840 300
  +     6eneral de jet Request 2.2.1 54

4.3.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category

                +226                 A                    +202              A
                +205                  A                   +2 27             A
                +201                 A 4.4        Reactor Coolant System (A206747) 4.4.1      The following are valves in the IST program which the licensee intends to test to the applicable code requirenent.

g Category Valve Category

                %549                  A                   %519              A
                %548                  A                PCV-464              C
                %550                  A                PCV-466              C
                %552                  A                PCV-468              C 4.4.2      The following are valves that were listed in the IST submittal and were deleted fran the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing Pump / Val ve Testing . . . ," dated Janua ry 13, 1978).

Valve PCV-455A PCV-455B 4.4.3 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category

                +518                  AC                   535              B
                +560A                 A                PCV-456              B 580B                 A                PCV-455C             B 536                  B 4.5        Service Water System (A206739) 4.5.1      The following are valves in the IST program which the licensee intends to test to the applicable code requirenent.

Valve Category Valve Category

               %SWN-51                A                FCV-1176             B (5 valves)                                FCV-1176A            B
  +     Ge neral Relief Request 2.2.1
  %     These valves will meet the Code for stroking only.             ,
                                                                          ]84Q jQj 55

Valve Category Valve Category TCV-1104 B SWN-1 C TCV-1105 B (6 check valves) 4.5.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore will be added to the resubmittal as showri. Valve Category SWN-1 C (6 check valves) 4.5.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing Pump / Val ve Testing.. . ," dated January 13, 1978). Valve Valve SWN-31 SWN-4 SWN-29 SWN-5 SWN-30 SWN-6 SWN-33 (2 valves) SWN-7 SWN-32 SWN-27 (2 valves) SWN-39 SWN-70 (2 val ves) SWN-38 SWN-63 (3 valves) SWN-40 (2 val ves) SWN-36 (2 val ves) 4.5.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category

               +SWN-41               A               +SWN-43               A (5 valves)                            ( 5 va' ve s)
               +SWN-44               A              FCV-111                B (5 valves)                          FCV-1112               B
               +SWN-71               A               +SWN-42               AC (5 valves)                            (5 valves) 4.6         Sampling System ( A206748) 4.6.1       The following are valves in the IST progran which the licensee intends to test to the applicable code requirement.

Valve Category Valve Category

                %956A                A                %956H                A
                %956B                A                %958                 A
 +     Ge neral Reli ef Request 2.2.1
 %     These valves will meet the Code for stroking only.

1840 302 56

Valve Category Valve Category

               %956C                 A                 %959            A
               %956D                 A                 %990A           A
               %956E                 A                 %990B           A
               %956F                 A                 %990C           A
               %956G                 A 4.6.2       The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related

, (safety related as defined by "NRC Staff Guidance for Preparing Pump / Val ve Testing. . . ," dated January 13, 1978). Valve Valve 951 974A 953 974B 955A 975 955B 4.7 Post Accident Containment Air Sampling System (Special pullout) 4.7.1 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category

              +1875A                 A                +1875F           A
              +1875B                 A                +187SG           A
              +1875C                 A                +1875H           A
              +1875D                 A                +1875]           A
              +1875E                 A 4.8        Hydrogen Recombiner System (A206741) 4.8.1      The following are valves in the IST program which the licensee intends to test to the applicable code requirment.

Valve Category valve Category

              %1882A                 A                %IV-5A           A
              %4432                  A                %4429            A
              %IV-5B                 A                %IV-3 A          A
              %4431                 A                 %IV-2A           A
              %IV-3B                 A                %IV-2B           A
              %4430                 A 4.8.2      The following are valves in the IST submittal that cannot meet the requirments of Section XI and relief has been requested.
 +     Ge neral Relief Request 2.2.1                                 1840 303
 %   .These valves will meet t e Code for stroking only.

57

Valve Category Valve Category

             +1882 A               A             +1876B               A
             +1876A                A             +1875B              A
             +1875A                A 4.9        Steam Generator Blowdown and Sampling System ( A206742) 4.9.1      The following are valves in the IST progra which the licensee intends to test to the applicable code requirement.

Valve Category Valve Category

            %PCV-1223              A            %PCV-1214            A
            %PCV-1223A             A            %PCV-1214A            A
            %PCV-1224              A            %PCV-1215            A
            %PCV-1225              A            %PCV-1215A            A
            %PCV-1225A             A            %PCV-1216            A
            %PCV-1226              A            %PCV-1216 A           A
            %PCV-1226A             A            %PCV-1217            A
            %PCV-1224A             A            %PCV-1217 A           A 4.10       Waste Disposal System ( A206737)

(A206743) 4.10.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirenent. Valve Category Valve Category

             %1786                 A             %1702                A
             %1787                 A             %1705               A
             %1610                 A             %1728                A
             %1788                 A             %1723               A
             %1769                 A 4.10.2     The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.

Valve Category

                         +1616                    AC 4.11       Main Steam System (A206734) 4.11.1     The following are valves in the IST program which the licensee intends to test to the applicable code requirement.

Valve Category Valve Category PCV-1139 B MS-47 C 4CV-1118 B (4 valves) 40 W4

 +     General Relief Request 2.2.1
 %     These valves will meet the Code for stroking only.

58

Valve Category Valve Category MS-4 5 C MS-48 C (4 valves) (4 valves) E46 C M49 C (4 valves) (4 valves) 4.11.2 The following are valves that were listed in the IST submittal and ere deleted frta the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing . Pump / Val ve Testing . . . ," dated January 13, 1978). Valve Valve PCV-1135 PCV-1137 PCV-1134 MS-52 PCV-1136 4.11.3 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category MS-41 B PCV-1310 B MS-4 2 B PCV-1310B B 4.11.4 The following are valves in the IST submittal that canna be full stroke exercised every 3 months but will meet the requirements of Section XI. Additional information is required by the NRC to verify the impracticality of full stroke exercising every 3 months. Valve Category Valve Category

             %MS-1-21                BC               %MS-1-23          BC
             %MS-1-22                BC               %MS-1-2 4         BC 4.12        Boiler Feedwater System ( A206736) 4.12.1      The following are valves in the IST program which the licensee intends to test to the applicable code requirement.

Valve Category Valve Category FCV-406A B FCV-405D B FCV-406B B FCV-1123 B FCV-406C B FCV-1121 B FCV-406D B PCV-1213 B FCV-405A B BFD-74 B FCV-405B B BFD-51 E FCV-405C B

 %    The licensee must provide a relief request with technical justification to allow stroke timing of these valves at refueling outages in lieu of stroke timing at cold shutdown.

59 1840 305

4.12.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore will be added to the resubmittal as shown. Valve Category Valve Category B FD-39 C BFD-40 C , BFD-34 C BFD-79 C B FD-37 C (4 valves) BFD-35 C BFD-47 C , B FD-42 C (4 valves) BFD-31 C 4.12.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing Pump / Val ve Testing . . . ," da ted Janua ry 13, 1978). Valve BFD-69 BFD-77 BFD-78 4.12.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Addi tional information is required by the NRC to verify the impracticality of full stroke exercising every 3 months. Valve Category Valve Category

           %FCV-427                B                 %FCV-417           B
           ?FCV-437                B                 tFCV-447           B 4.12.5    The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.

Valve Category Valve Category FCV-427L B BFD-35 C FCV-417L B BFD-42 C FCV-437L B BFD-40 C FCV-447L B B FD-79 C BFD-39 C (4 valves) BFD-37 C BFD-47 C BFD-31 C 4.13 Condensate and Boiler Feedpump System (A206735) 4.13.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirenent. t FCV-417, 427, 437 and 447. Licensee to address stroke timing. 60

Valve Category Valve Category

             %PCV-1188              B                %PCV-1189            B
             %PCV-1187              B                %LCV-1158            8 4.13.2      The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore

, will be added to the resubmittal as shown. Valve Category Valve Category CT-32 C %CT-33 E CT-26 C %CT-27 E CT-29 C %CT-30 E

              %CT-6                 E 4.13.3      The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance for Preparing Pump / Valve Testing. . . ," dated January 13, 1978).

Valve CT-35 (3 valves) 4.13.4 The following are valves in the IST submittal that cannot meet the requirments of Section XI and relief has been requested. Valve C_ategory CT-32 C CT-26 C CT-29 C 4.14 Miscellaneous CIV's 4.14.1 The following are valves in the IST progran which the licensee intends to test to the applicable code requirement. Valve Category Ve,ve Category

              %E-1                  A                %PCV-1229            A
              %E-2                  A                %PCV-1230            A
              %E-3                  A                %1234                A
              %E-5                  A                %1235                A
              %1190                 A                %1236                A
              %1191                 A                %1237                A
              %1192                 A L    PCV-ll87, 1166 and 1189, LCV-1158.        Licensee will review these valves for safety related function.
 %    CT-6, CT-30, CT-33 and CT-27. Added to program if locked open. Othe r-wise will not be added to program.
 %    All valves in Section 4.14.1 will meet the Code for stroking only.

61 1840 307

4.14.2 The folicwing are valves in the IST submittal that cannot te2t the requirements of Section XI and relief has been requested. valve Category Valve Category

              +85A                  AC            +MV-17             A
              +85B                  AC              (2 valves)

, +85C A +SA-24 A

              +850                  A               (2 valves)
              +95A                  AC            +PCV-1228          A
.             +958                  AC            +IA-39             AC
              +95C                  A             +1170              A
              +95D                  A             +1171              A
              +1814A                AE            +1172              A
              +1814B                AE            +1173              A
              +1814C                AE            +UH-43             AE
              +UH -4 4              AE
  + General Kelier Request 2.2.1 o

62 1840 308

L.0 f1ISCELLANE0VS C0frENTS 5.1 Augmented Inspections of Valves It is recamended that the Nuclear Regulatory Commission (NRC) take a position of requiring augmented inspections for valves that are currently designated as Category E in this IST program, and are proven to be of safety significance. The Code, to date, has not addressed the generic function of these , valves during an accident situation. It is most essential that these safety related valves be in the correct position during an accident situation. Safety related is defined by "NRC Staff Guid-ar,ce for Preparing Pump and Val ve testing.. . ," dated January 13, 1978. This definition states " safety related are those pumps and

                                           ~

valves necessary to safely shutdown the plant or mitigate the con-sequences of an accident." Should these valves be in the incorrect position a safe shutdown may not be possible. The Code chooses to ignore this type of valve with statments of the fonn: "IWV-1300 Exclusions. Valves that are not covered by this Subsection include valves used for operating convenience only such as manual vent, drain, instrument and test valves and valves used for maintenance o nly . " It is inconsistent to be concerned solely with the operability of some valves (Category A, B, C, and D) when others (Category E valves incorrectly positioned) will nullify the operation of the pumps and Category A, B, C, and D valves. In light of recent events this inconsistency should be addressed and resolved. The concept of " augmented inspection" is to have periodic visual inspections, with written records, of the position of the valves. This concept might be a method of standardizing the procedures re-lating to passive valves (Category E, and non-CaG 1ory E type), position verification. Valves that the NRC shoula be concerned with are Category E, and non-Category E type valves, such as on the accumulator discharge outlets, valves on either side of safety re-lated pumps, and valves in the ECCS injection path or recirculation path (RWST to RCS, pump to RCS, Emergency Feedwater fl ow path). This concept of augmented inspections is not origina', the NRC stated it could be used in its November 17, 1976 letter to the Power Authority of the State of New York. This was a generic let-ter that went to all operating plants. The topic of the letter wa i WRC Staff Guidance for Complying with 10 CFR 50.55a(g) - Inservice Inspection Requirements. ~ 5.2 Specific Valves Requiring Augmented Inspection As stated in the May 15, 1979 letter to Mr. Alan Wang, HRC frm Mr. Thomas Restivo, BNL, there are at least seven valves which BNL has reservations concerning their deletion from the IST Program. It is 1840 309 63

BNL's concern that vaives 882,1810, 894 A, 894B, 894C, 894D , a nd 898 remain in the IST program and furthermore, it is recommended that an Augmented Inspection requirment be placed on these valves. 5.3 Miscellaneous Comments - For Pumps

1. The licensee was requested and has agreed to review the turbine driven Auxiliary Feedwater Pump for possible inclusion ir, the IST Program.

, The following paragraphs and notes are found in the Inservice Inspection and Testing Program Supplement No. 3 dated February, 1979:

2. Paragraph 2.2, page ES-1 is not a relief request. It is presented for information purposes.

3. Paragraph 3.1, page ES-2 is not a relief request. It is presented for information purposes.

4. Note-7, page E5-7 is not a relief request. It is presented for information purposes.

5. Note-5, page ES-7 has been deleted as a relief request against the Auxiliary Component Cooling Pumps.

6. Note-6, page ES-7 is not a relief request. It is presented for information purposes, e

m 1840 310 64

CONCLUSI0fl The Inservice Testing Program submitted by the Consolidated Edison Company of New York, Inc. for the Indian Point Station, Unit 2 and modified by this evaluation report is in general compliance with the requirements of Sec-tion XI of the 1974 Edition and Addenda through the Summer of 1975 of the ASiE Boiler and Pressure Vessel Code as required by 10 CFR 50.55 a(g), and HRC Staff Guidance letters and briefings. Those itens not found to be in compli-ance with the above, will be addressed in the licensee's response to the SER

, meeting al.d evaluated further.

O i 1840 311 65

ACKt10WLEDGEMEllT The authors would like to acknowledge Mr. Michael Melone's assis-tance in researching and preparing this report. 3 I O A 1840 312 66

DISTRIBul10N E. Adensata 1 R. Cerbone 1 h P. Check 1 C. Cheng 5 A. Coppola 1 G. Edison 1 C. Eisenhut 1 B. Grimes 1 R. Hall 2 W. Kato 1 G. Lainas 1 V. Lettieri 3 V. Noonan 1 W. Osborne 2 T. Restivo 1 V. Stello 1 T. Tel ford 1 H. Todosow 2 A. Wang 1 NRC - Division of Technical 8 Information and Control 2 1840 313}}