ML19269C505

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Forwards Requests for Exceptions to Inservice Testing Requirements for Pumps & Valves
ML19269C505
Person / Time
Site: North Anna 
Issue date: 01/31/1979
From: Stallings C
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Harold Denton, Parr O
Office of Nuclear Reactor Regulation
References
046, 46, NUDOCS 7902050152
Download: ML19269C505 (31)


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Vinonn:A E ntrrnic Ann l'owntre CO>t PANY H ic n x oNn. VI HOIN I A 23261 January 31, 1979 Mr. Harold R. Denton, Director Serial No. 046 Of fice of Nuclear Reactor Regulation P0/TJW:sej Attn:

Mr. 0.D. Parr, Chie f Docket No.:

50-339 Light Water Reactors Branch No. 3 Division of Project Management U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Mr. Denton:

Specification 4.0.5 of the proposed Technical Specifications for North Anna Unit 2, requires ASME Code Class 1, 2 and 3 pumps and valves to be tested in accordance with Section XI of the ASME Boiler and Pressure Code (1974 Edition with Addenda through the summer 1975) except where specific weitten relief has been granted by the Nuclear Regulatory Connission.

North Anna unit 2 was not, however, designed to meet the detailed inservice testing requirements of subsec-tions IWP and IWV of ASME Code,Section XI.

Therefore, pursuant to 10 CFR 50.55a, (g)(6)(i), we request the specific exceptions for the testing of pumps and valves as outlined in Attachments A and B.

Very truly yours, C. M. Stallings

[N Vice President-Power Supply and Production Operations Attachments A.

Requested Exceptions to the Inservice Testing Requirements for Pumps as Set Forth In Subsection IWP to Section XI of the ASME Code, 1974 Edition with Addenda through the summer of 1975, North Anna Unit 2.

B.

Requested Exceptions to the Inservice Testing Requirements for Valves as Set Forth In Subsection IWV to Section XI of the ASME Code, 1974 Edition with Addenda through the summer of 1975, North Anna Unit 2.

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ATTACIDIENT A REQUESTED EXCEPTIONS TO THE INSERVICE TESTING REQUIREMENTS FOR PUMPS AS SET FORTH IN SUBSECTION IWV TO SECTION XI 0F THE ASME CODE 1974 EDITION WITH ADDENDA THROUGH THE SUMMER OF 197.5 NORTH ANNA UNIT 2

ATTACilMENT A.O -

l' Af ;l 1 of 4 SYSTI:t1 l'ItOPI:lt

^

l tir11' ilAMl:

CI. ASS til:ri TSTAriCE l',

AP Q

V LilBE T

I41:11AllES HI:OllESTEl 2

b fillttisi:11

,_ p., y g g,

V-VAltI AllLl Olt

_ :--. 2 Itle rn ct ini 2-CC-P-1A Component 3

V YES M

REL.

REL.

M M

A EXCEPTION 1 Cooling Pump e,**

2-CC-P-1B COMPONENT COOLING 3

V YES M

REL.

REL.

M M

A EXCEPTION 1 PUMP 2-Cll-F-1 A CIIARGING PUMP 2

NOTE 1,2 YES REL.

REL.

M M

M A

EXCEPTION 2 2-Cil-P-1B CIIARGING PUMP 2

flOTE 1,2 YES REL.

REL.

M M

M A

EXCEPTION 2 2-Cll-P-lC CllARGING PUMP 2

NOTE 1,2 YES REL.

REL.

M M

M A

EXCEPTION 2 l-611-P-2C BORIC ACID TRANSFER 2

P YES REL.

REL. NME]

RSL REL.

REL EXCEPTION 3 PUMP l-Cll-P-2D BORIC ACID TRAMSFER 2

F YES REL.

REL. NME]

REL REL.

REL EXCEPTION 3 PilMP 2-CL-P-2A SCREENWASil PUMP 3

F YES REL.

REL.

NOTE 1 M

REL.

NOTE 3

EXCEPTION 4 (CIRCULATING WATER)

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ATTACliMEllT A.O PAGI: 2 of s SYSTI:l1 l'ROPl:R

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let!!!P !!AMM CI. ASS I41:SISTAtlCI:

l'.

AP Q

V 1.U BE T

I<EMA RKS 14EOUESTEI 1

b 191111ti:R

.-F

'D 9-VAi: Anu:

oli EL12SSUJa _ _._____. _

i 1-FC-P-1B SPENT FUEL PIT PUMP 3

F YES M

M 10TE M

M A

NA 1,4 2-FU-P-3A IIALF SIZE AUXILIARY 3

F YES M

M (10TE 1 M

M A

NA FEED PUMP 2-FW-P-3B llALF SIZE AUXILIARY

'4 F

YES M

M IJOTE 1 M

M A

NA FEED PUMP 2-QS-P-1A QUENCII SPRAY PUMP 3

F YES M

M NOTE 1 M

M A

NA 2-QS-P-1B QUENCll SPRAY PUliP 3

F YES M

M NOTE 1 M

M A

NA 2-Ril-P-1 A RESIDUAL llEAT 2

P YES RELIEI EXCEPTION 5 REMOVAL PUMP 2-RH-P-1B RESIDUAL llEAT 2

F YES RELIEI-EXCEPTION 5 I'.EMOVAL PUMP 2-RS-P-lA INSIDE RECIRCULATIOII 2

V YES RELIEF NOTE EXCEPTION 6 SPRAY PUMP

ATTACIIMENT A.O l'M;E 3 Of 4

(;ySTI:M PROPl:R l'tittP 11AttM Cl. ASS Iti:Til STAf1CE P.

AP Q

V 1.IIIlE T

REMAl*S g,

7, g g.g I) t it irit ti;!(

Iti;Olli:GTI.,I J

V-VAlt I Altl.M OR I'ldsi;Lil U 2-RS-P-1B INSIDE RECIRCULATIOt 2

V YES RELIEE NME l

EXCEPTION 6 SPRAY PUMP 2-RS-P-2A OUTSIDE RECIRCULATIt 'N 2

P YES RELIEI NOTE l

EXCEPTION 7 SPRAY PUMP 2-RS-P-28 OUTSIDE RECIRCULATIt iN 2

F YES RELIEE NOTE I

EXCEPTION 7 SPRAY PUMP 2-SI-P-1A IDW IIEAD SAFETY 2

F YES

'lE L.

REL.

NOTE 1 M

REL.

NOTE 5

EXCEPTION 8 INJECTION PUMP 2

P YES REL.

REL.

NOTE 1 M

REL.

NOTE I

EXCEPTION 8 2-SI-P-1B LOW IIEAD SAFETY INJECTION PUMP 2-SW-P-1A SERVICE WATER PUMP 3

V YES REL.

REL.

REL.

M REL.

NOTE I

EXCEPTION 9 2-SW-P-1B SERVICE WATER PUMP 3

V YES REL.

REL.

REL.

M REL.

NME I

EXCEPTION 9 ICREENWASil PUMP (SERVICE WATER) 2-SW-P-2 3

F YES REL.

REL.

NOTE 3 M

REL.

NME l

EXCEPTION 10

ATTACHMENT A.O l' AG1:4 Of 4 sySTlqrt l'IM H'l'li "A

l't if tl' IJAMi; Ct. ASS lil::i l:iTAIJUl:

l'.

AP Q

V 1.1 11.l:

T 14t:f1AlWS lif lf il'l.I' 14I 9U l' UTl:1 1

I'

,. _ y y.g.g g,g q,;g V-

'IAl:l Al'I.l:

f lt l!!:tE!Ill!

2-SW-P-4 AUXILIARY SER/ ICE 3

V YES REL.

REL.

REL, M

REL.

110TE 3 EXCEPTIOt14 WATER PUMP 2-SW-P-5 RADIATIOt1 mot 1ITORIN' 3

F YES IU'LIEl EXCEPTIOt1 11 SAMPLE PUMP 2-SW-P-6 RADIATIOt1 mot 1ITORIN'i 3

F YES RELIEl EXCEPTION 11 SAMPLE PUMP 2-SW-P-7 RT.DIATION MONITORIt1L 3

F YES RELIE1 EXCEPTION 11 SAMPLE PUt1P 2-SW-P-8 RADIATIOt1 MONITORINt 3

F YES RELIEl EXCEPTION 11 SAMPLE PUMP 2-RS-P-3A CASING COOLIt1G 3

F YES M

M NOTE M

REL.

A EXCEPTIOt1 12 PUMP 2-RS-P-3B CASI!1G COOLING 3

F YES M

M NOTE M

REL.

A EXCEPTION 12 PtlMP

Attachment A.1 Page 1 of 2 EXCEPTIONS An exception is required to IWP-4210. Gage lines have not been provided with a suitable means to assure or determine the presence or absence of liquid when that presence or absence could produce a difference of more than 0.25% in the indicated value of the measured pressure. Reference values and subsequent test values will all be taken with the gage lines as designed. Therefore, any error vould be common to all values recorded and not affect the evaluation of the data.

An exception is required to IWP-4110.

Instrumentation included under this exception is only + 4% accurate.

1.

The accuracy of flow instrumentation at normal operating flows is about

+ 8%.

This accuracy does not lend itself to satisfying the requirements of Table IWP-2100-2 where the acceptable range is +2% -6%.

In addition, varying flow rates interferes with normal plant operation since flows h;ve been balanced to meet heat load requirements. Therefore, the AP and Q f;r each of these cumps will be recorded but not compared to reference valuen ror head curve verifica-tion. Additionally, motor current will be recorded for comparison purposes.

2.

Suction pressure instrumentation is not installed nor required. These pumps are capable of producing greater than 2400 psig discharge pressure, while the suction pressure would nominally be 15 to 20 psig.

The Volume Control Tank pressure will be recorded using Control Room indication to establish initial conditions for testing.

This indication is about 4% accurate.

3.

Monitoring discharge pressure monthly is considered sufficient since these pumps provide the driving force to deliver boric acid to the charging pump suction and operator observation of boration and chemical analysis of boron concentration will indicate whether desired results have been achieved.

The Boric Acid Tanks serve as the head for these pumps. Tank level will be observed from the Control Room to establish initial conditions for testing.

This indi-cation is about 4% accurate. The pump is totally encased in insulation making Tb, V and Lubricant level or pressure impossible to measure or observe.

4.

This pump takes suction from Lake Anna. The reservoir has a minimum level required by Technical Specifications.

This indication which is about 4% accurate, will be observed from the Control Room to establish initial conditions for testing.

Proper lubricant pressure or level cannot be observed since the bearings are in the main flow path.

Attachment A.1 Page 2 of 2 5.

In accordance with Technical Specification 4.7.9.1, measured quantities will be obtained at least every 18 months.

These pu.nps are not Engineered Safety Features pumps.

Operability during extended use can be determined by monitoring reactor coolant system temperature.

Due to location of Pi instrumentation, meaningful data can only be obtained with the pump in operation.

6.

These pumps are run dry to verify operaticul readiness; therefore, Pi, AP, Q and Proper Lubricant Level or Pressure cannot be measured.

Each pump is equipped with a sensor to detect pump rotation.

In addition, a vibration alarm associated with each pump will alert Control Room personnel to excessive pump vibration.

7.

These pumps will be run dry or wet to verify operational readiness.

Each will be observed to verify rotation. At least once per 18 months, each will be tested on its recirculation path when flow and discharge pressure will be observed. A vibration alarm associated with each pump will alert Control Room personnel to excessive pump vibration.

Due to pump design, it is not possible to measure a suction pressure.

Proper lubricant level or pressure is not required since bearings are in the main flow path.

8.

These pumps take suction from the RWST for pump performance testing.

This tank has a minimum level required by Technical Specifications, which will be observed from the Control Room. This indication is about 4% accurate.

Proper lubricant level or pressure cannot be observed since bearings are in the main ficw path.

9.

The accuracy of flow instrumentation at normal operatin] flows is about

+ 8%.

This accuracy does not lend itself to satisfying the requirements of Table IWP-2100 2 where the acceptable range is +2% -6%.

In addition, varying flow rates interferes with normal plant operation since flows have been balanced to meet heat load requirements. Therefore, the discharge pressure and Q for each pump will be recorded but not compared to reference values for head curve verification.

Thase pumps take suction from the Service Water Reservoir, which has a minimum level required by Technical Specifications.

This level indication, which is about 4% accurate, will be observed from the Control Room to establish initial conditions for testing.

Proper lubricant level or pressure cannot be observed since bearings are in the main flow path. Motor current will be recorded for comparison purposes.

10.

This pumn takes suction from the Service Water Reservoir, which has a minimum required level by Technical Specifications.

This level indication, which is about 4% accurate, will be observed from the Control Room to establish initial conditions for testings.

Proper lubricant level or pressure cannot be c5 served since bearings are in the main flow path.

11.

The flow paths of these pumps are normally dry. Atleast once per 18 month, each pump will be automatically started in conjunction with a test signal for Containment Depressurization Actuation.

12.

The bearing lubrication for these pumps is grease instead of oil.

The grease will be checked annually.

Attachment A.2 Page 1 of 1 NOTES Note 1 In a fixed resistance system, it is required to measure AP or 0, not both (IWP Table 3100-1).

Note 2 When these pumps are operated on recirculation flow, the system is fixed resistance.

When they are tested as the operating pump, the system is variable resistance.

Note 3 Reference is made to IWP 4310 which establishes exception to Tb for bearings within the main flow path.

Note 4 Pump will be tested only when there is water in the spent fuel pit.

Note 5 Symbols and abbreviations from Attachment A.0 are as follows:

M - Monthly A - Annually Rel - Relief Requested

ATTACHMENT B REQUESTED EXCEPTIONS TO THE INSERVICE TESTING REQUIREMENTS FOR VALVES AS SET FORTH IN SUBSECTION IWV TO SECTION XI 0F THE ASME CODE 1974 EDITION WITH ADDENDA THROUGH SUMMER 1975 NORTH ANNA UNIT 2

Attachment B.O Page 1 of 2 STATEMENT OF PARTICULARS A review of ASME class 1, 2, 3 valves has been completed for the North Anna Unit 2 Systems.

Attachment B.1 provides a tabulation of the valves that are subject to the testing requirements of ASME Boiler and Pressure Vessel Coc, 1974 edition, subsection IWV with addenda through summer 1975.

e The tab.e identifies the valves to be tested, valve code classes, and valve category per IWV-2000. Relief from the testing requirements of ASME XI is requested when they are determined to be impractical.

Specific information regarding the code requirement determined to be impractical and alternate testing programs are noted in Attachment B.2.

Leak testing of containment isolation valves shall be performed in accordance with Appendix J of 10CFR50 in lieu of ASME XI subsection IWV.

There are n-testable Category D valves in North Anna Unit 2 Systems.

A.t Category E vat.cs shall be tested in accordance with IWV-3700.

Any inspection requirements identified as impractical during the course of the inspection period will be noted and includ ?

cne inspection program at the time of the next revision.

When one valve in a redundant safety related system is found inoperable during testing, non-redundant valves in the remaining train will not be cycled as procedures require but will be cycled af ter the first inoperable valve in the system is returned to service.

This valve testing program addresses all valves determined to be essential in the mitigation of the consequences of an accident. The program has been reviewed to assure that testing the valves at the intervals speci-fied will not plant in an unsafe condition. Where practical, valves will be cycled at 3 month test intervals.

Attachment B.0 Page 2 of 2 System Abbreviation System Name BD Steam Generator Blowdown CC Component Cooling CVCS Chemical and Volume Control System CV Containment Vacuum DA Containment Sump Drains DG Primary Drains FW Feedwater HV Habitability and Ventilation LM Leakage Monitoring MS Main Steam QS Quench Spray RM Radiation Monitoring RS Recirculation Spray RC Reactor Coolant RH Residual Heat Removal SI Safety Injection SS Sampling SW Service Water 7G Vent Gas

Attachment B.1

~

iAcM 1 of 16 TEST 1*ltl:OUENCY AE Ml:

ASME HEi,I E P I1I XI RPOUESTl:I) lil:llAlW:

VAI,Vl; FUICP1OH

CAT, CAT.

1 XI:!u' ISM l.MA K AGE Every 3 Each TV-BD-200 Containment Steam Months Refueling NA A, B, C, D, E,F Generator Blowdown Isolation II A

No Valves Containment Air Recirculation Cold Each

~2

^ddC Coils Isolation Valves A

Yes Shutdown Refueling Note 1 70 RCP's Thermal Barrier Each Each TV -CC 201 A, B III A

Yes Refueling Refueling Note 2 Containment Isolation Valves RCP's, UBLO, LBLO and Stator Each Each TV -CC-202 A' B Cooler Containme.ic Isolation III A

Yes Refueling Refueling Note 2 C,D,E,F Valves RilR HX Return Line Every 3 Each TV -CC-203 A, B Months Refueling NA Coatainment Isolation Valves III A

No RCP's UBLO, LBLO ead State" Each Each TV-CC-204 A, B, C Cooler Containmer.t Isolation III A

Yes Refueling Refueling Note 2 Valves RV-CC-228A, B RHR llX Relief Valve III C

No Note 3 NA Note 3 CC Pump Discharge Every 3 2-CC-10, 27 Check Valves III C

NO Months NA NA

Attachment B.1 l' AGE 2 of ]6 TEST FitEQUErlCY AS11E ASME l<EI.I EF III XI REQUESTED REf1 ARKS VAINE FUNCTION CAT.

CAT.

EXERCISE LEAKAGE RCP's UBLO, LBLO and Stator Each Each 2-CC-78,115,152 Cooler Inlet Check Valves III AC Yes Refueling Refueling Note 2 Each Each 2-CC-194, 199 RHR llX Inlet C:,eck Valves III AC Yes Refueling Refueling Note 4 Every 3 Each HuV-2200 A, B, C Hand Control Letdown Valves II A

No Months Refueling NA Every 3 Each flCV-2142 Letdown from RHR II A

No Months Refueling NA Charging Pump Suction Cold MOV-2115 B,D,C,E Isolation Valves II B

Yes Shutdown NA Note 5 2-CH-P-1A Suction Every 3 MOV-2267 A, B Valves II B

No Months NA NA Ever 3 MOV-2269 A, B 2-CH-P-1B Suction Valves II B

No Every 3 MOV-2270 A, B 2-Cll-P-lC Suction Valves II B

No Months NA NA

AttachmentB.1 i>nce 3 of 16 Tl:ST l'REQUENCY ASill:

ASt1E REl,IEP III XI kFQUESTI:D ltEMARDi VAI.VI.

FutlC"PIDt3 CAT.

CAT.

EXERCISE I,EAKAGE Charging Pump Recirculation Every 3 MOV-2275 A, B, C Valves II B

No Months NA NA MOV-2286 A, B, C Every 3 Charging Pump Discharge Valves II B

No Months NA NA MOV-2287 A, B, C Each Each MOV-2289A Normal Charging Header Isolation II A

Yes Refueling Refueling Note 6 Valve Each MOV-2289B Normal Charging Header Isolation II B

Yes Refueling' NA Note 6 Valve Cold MOV-2350 Emergency Boration Valve II B

Yes Shutdown NA Note 7 Charging Pump Recirculation Each MOV-2373 Ileader Isolation Valve II B

Yes Refueling NA Note 24 Reactor Coolant Pump Seal Water Each Each MOV-Return Containment Isolation II A

Yes Refueling Refueling Note 8 Valves RV-2203 Letdown Header Relief Valve II AC No Note 3 Each Note 3 Refueling

Attachment B.1 ract: 4 of 16

=

TEST PREQUEllCY ASflU ASME RELIEP III XI REQUESTI:D REllA!:XS VAINE FUtlCTIO!!

CAT.

CAT.

EXERCISE LEAKAGE:

RV-2209 Letdown Header Relief Valve II C

No Note 3

NA Note 3.

RV-2257 Volume Control Tank Relief Valve II C

No Note 3

NA Note 3 Each.

Each Note 9 TV-2204 Letdown Header Containment II A

Yes Refueling Refueling Isolation Valve Boric Acid Transfer Pump Every 3 1-CH-ll8, 133 Discharge Check Valve II C

No Months NA NA Emergency Boration Cold 2-CH-lS9 Path Check Valve II C

Yes Shutdown NA Note 7 2-CH-178 Charging Pump Discharge Every 3 193 Check Valves II C

No Months NA NA 208 401 Containment Vacuum Pump Every 3 Each TV-CV-250 A, B, A

N Suction Isolation Valves Months Refueling NA C, D Reactor Containment Sump Each NA TV-DA-200 A, B Pump Discharge Containment A

No

{onbs Refueling Isolation Valve

Attachment B.1 rAct: 5 of 16 TO:ST l'ltt:(ilJl.'tJCY ASf11; ASMI:

1t81.11T I11 Xf 1(1:Qlll:1;TI:1) lil:MAIC var.vi:

runcP lotl

CAT, CAT.

L:xt :lu 'I S L:

1.t: A K AGl:

Primary Drains Transfer Every 3 Each TV-DG-200 A, B Pump Containment Isolation A

No Months Refueling NA Trip Valves Auxiliary Feedwater Pump flCV-FW-200A, B Adenission Valves to III E

No NA NA NA Steam Generators Auxiliary Feedwater Pump Each IlCV-FW-200C Admission Valve to III B

Yes Refueling NA Note 10 Steam Generator Auxiliary Feedwater Pump MOV-FW-200A,C Admission Valves to III E

No NA NA NA Steam Generators Auxiliary Feedwater Pump b

MOV-FW-200 B, D Admission Valves to III B

Yes k

ling NA Note 10 Steam Generators Turbine Auxiliary Feedwater RV-FW-200 Pump Discharge Relief III C

No Note 3 NA Note 3 Valve Main Feedwater Check Each 2-FW-62, 94, 126 Valve at Penetration II C

10 Refueling NA Note 11 Auxiliary Feedwater lieader Each 2-FW-70, 102, 134 Check Valves at Main II C

No Refueling NA Note 12 Feedwater 11eader

Attachment B.1 Page 6 of 16 TEST PREQUEllCY ASME ASMf; REl.IEP III XI REQUESTED IWMAl:MS VAINf' FUNCTION CAT.

CAT.

EXERCISE LEAKAGE Every 3 2-FW-150, 167, 185 Auxiliary Feedwater Pumps 156, 172, 192 Discharge and Recirculation III C

No Months NA NA Check Valves ach Auxiliary Feedwater lleader 2-FW-95, 129, 279 Check Valves III C

Yes Refueling NA Note lc MOV-HV-200 A, B, Containment Purge and Cold Each C, D Exhaust Isolation Valves A

Yes Shutdown Refueling Note 17 MOV-HV-201, 202 TV-LM-200 A, B, C, Leakage Monitoring Every 3 Each D, E, F, Containment Isolation Valves A

No Months Refueling NA C, il Every 3 Each Leakage Monitoring Reference TV-LM 201 A, B, C, Containment Isolation Valves' A

No Months Refueling NA SV-MS-201 A,B,C Main Steam Safety 202 A,B,C Valves II C

No Note 3 NA Note 3 203 A,B,C 204 A,B C a

205 A,B,C

Attachment Bl Page 7 of 16 TI:ST FitCOUi;tlCY AS!1C ASt1C IEl,1 H P II1 XI RCQllf:STEl) l< i. . i T.n VAINE PutlCTIO!1 CAT.

CAT, EXEla'ISE LEAKAGE TV-MS-201 A, B, C Main Steam Trip Isolation Valves II B

Yes hu down Main Steam to Auxiliary Every 3 TV-MS-211 A, B Feedwater Turbine Pump III B

N Months NA NA Main Steam to Auxiliary Every 3 Feedwater Turbine Pump III C

No NA NA 2-MS-117,119,121 Check Valves Months PG Water to Pressurizer Every 3 Each TV-2519A Relief Tank Containment g

no Isolation Valve Months Refueling NA

Attachment B.1 iAcc 8 of 16 TCST Pl(B(!!!EllCY ASilB Ant 1E f<El.l MP III XI Iti:QllCSTl;D lil MA1:KS VAINE PUtJCT IO!J

CAT, CAT.

EXI:RCISE I,MA K AGl:

Chemical Addition Tank Every 3 MOV-QS-202 A, B Discharge Isolation II B

No Months NA NA Valve Quench Spray Pump Each Each 2-QS-ll, 22 Containment Isolation II AC Yes Refueling Refueling Note 14 Check Valve Containment Radiation Every 3 Each TV-RM-200 A,B,C,0 Monitoring Isolation A

N "A

Months Refueling Trip Valves Casing Cooling Pump Every 3 Each MOV-RS-200 A' Discharge Valves II A

No Months Refueling NA Outside Recirculation Spray Each MOV-RS-255A, B Pump Suction Valves II B

yes Refueling NA Note 10 Outside Recirculation Spray Each MOV-RS-256A, B Pump Discharge Valves II B

Yes Refueling NA Note 10 Outside Recirculation Spray Each Each 2-RS-20, 30 Pump Discharge and Containment II AC Yes Refueling Refueling Note 14 Isolation Check Valves 2-RS-103, 118 Casing Cooling Pump Each Discharge Check Valves to II C

Yes Refueling NA Note 15 Outside Recirculation Pumps l

Attachment B.1 pace 9 of 16 TEST PREQ NCY ASME ASME RELIEF III XI REQUESTED REl1AIO:S VALVE FUNCTIO!1 CAT.

CAT.

EXERCISE LEAKAGE SV-2551 A, B, C Pressurizer Safety Valves I

C No Note 3

NA Note 3 Containment Isolation Valves Each 2-RC-143, 145 for Pressurizer Pressure I

AE No NA Refueling NA Dead Weight Tester Every 3 IICV-2758 RilR HX Flow Control Valve II B

No Months NA NA FCV-2605 RilR llX Bypass Control Valve II B

N s

NA NA MOV-RilR System Isclation Valves I

B Yes NA Note 16 down 2720 A, B RV-2721 A, B RHR System Relief Valves II C

No Note 3

NA Note 3 RilR Pump Discharge Cold 2-Ril-7, 15 Check Valves II C

No Shutdown NA Note 16 2-RH-37, 38 RilR Containment II AE No NA Each Refueling NA Isolation Valves

Attachnent B.1 l0 of 16 Pacc TEST l'lWQUEt4CY ASME ASME It El.l EP III XI ItEQtlESTl:D t<t EAIC, VAINE FullCTION

CAT, CAT.

EXEltCISE I.EAl' AGE Low Head Safety Injection Every 3 MOV-2860 A, B Pump Suction from Containment II B

No Months NA NA Sump i

Low Head Safety Injection Every 3 MOV-2862 A, B Pump Suction from the II B

No Months NA NA Refueling Water Storage Tank Low Head Safety Injection Every 3 MOV-2863 A to Charging Pump Suction II B

No Months NA NA Low Head Safety Injection Cold MOV-2863 B to Charging Pump Suction II B

Yes Shutdown NA Note 5 Cold MOV-2865 A, B, C Accumulator Outlet Valves II B

Yes Shutdown NA Note 19 Boron Injection Tank Every 3 MOV-2867 A, B Inlet Valves II B

No fionths NA NA MOV-2867 C,D Boron Injection Tank Every 3 Each Outlet Valves II A

No Months Refueling NA MOV-2836 liigh Head Safety Injection II AE Yes Each Each Note 18 MOV-2869 A, B Off Charging Header Refueling Refueling

Attachment B.1 l' AGE ll of 16 TEST Ff(EQUE!1CY ASME ASME I<EI,I EP III XI ItEQUESTED l<tMALKS VALVE FUNCTIOl1 CAT.

CAT.

EXERCISE LEAKAGE Low Head Safety Injection Cold Each MOV-2890 A, B to Hot Legs II AE Yes Shutdown Refueling Note 20 Low Head Safety Injection Cold Each MOV-2890 C, D to Cold Legs II A

Yes Shutdown Refueling Note 20 Low Head Safety Injection RV-2845 A, B, C Pump Discharge Relief II C

No Note 3 NA Note 3 Valves Boron Injection Tank RJ-?8578 Relief Valve II C

No Note 3 NA Note 3 Accumulator Test Line Every 3 Each TV-Containment Isolation A

No Months Refueling NA 2

Trip Valves Accumulator Nitrogen Purge Every 3 Each TV-SI-200 Containment Isolation A

No Months Refueling NA Trip Valve Accumulator to Waste Gas Every 3 Each TV-SI-201 System Containment Isolation A

No Months Refueling NA Valves Boron Injectior. T;..'c II B

No Every 3 NA NA TV-2884 A, B, C Recirculation Trip "ilves Months

Attachment B.1 iAcc 12 of 16 TEST l'l<C(juENCY ASMC ASMC REI,I E P

[II Xf l<EQUEm'l:1)

IWMAlW:.

VAI.VH PIIN( T it d

( 'AT.

( *AT,

U XI:!A'I SI:

I.EAKAGE 2-SI-1, 21 Low ilead Safety Injection Each Pump Check Valves from II C

Yes Refueling NA Note 21 Containment Sump Low Ilead Safety Injection Every 3 2-SI-9, 32 Pump Discharge Check II C

No Months NA NA Valves Refueling Water Storage Cold 2-SI-18 Tank to Charging Pump II C

Yes Shutdown NA Note 7

Suction Check Valve Low ilead Safety Injection Every 3 2-SI-19 Pump Check Valve from II C

No Months NA NA Refueling Water Storage Tank Low Ilead Safety Injection Every 3 2-SI-6, 29 Pump Seal Water Supply II C

No Months NA NA Check Valve Low flead Safety Injection Every 3 2-SI-12, 35 Pump Recirculation Check II C

No Months NA NA Valves Boron Injection Tank Every 3 2-SI-70 Recirculation Check Valve II C

No Months NA NA High llead Safety Injection Each Each 2-SI-85, 93, 107, to Cold Legs Containment II AC Yes Refueling Refueling Note 22 119 Isolation Check Valves

Attachment B.1 PAGC 13 of 16 TEST l'HEQUEth:Y AS!4E AStiE REI,ICP III XI REQUESTED Rt:: tat:KS VALVE FuriCTIOt1 CAT.

CAT.

EXERCISE LEAKAGE High Head Safety Injection Each 2-SI~90' 98' 104 to Cold legs I

C Yes Refueling NA Note 22 Low Head Safety Injection to Each Each 2-SI-91, 105, 99 Cold Legs Containment I

AC Yes Refueling Refueling Note 23 Isolation Check Valves Cold Leg Safety Each Each 2-SI-92, 100, 106 Injection Admission I

AC Yes Retucling Refueling Note 22 Check Valves Hot Leg Safety Fach 2-SI-113, 118, 125 Injection Admission I

C Yes Refueling NA No'te 22 Check Valves Low Head Safety Injection Each 2-S1-112, 117, 124 to Hot Legs I

C Yes Refueling NA Note 23 Low Head Safety Injection Each Each 2-SI-126, 128 to Hot Legs Containment II AC Yes Refueling Refueling Note 23 Isolation Check Valves Each Each 2-SI-15 '

Accumulator Discharge Check I

AC Yes Refueling Refueling Note 25

]0 8

Valves Accumulator Relief Valves I

C No Note 3 NA Note 3 RV-2858 A, B, C

Attachment B.1 I t.uE 14 of 16 r

TEST l'l<lq)tlENCY ASfiM ASME REl.1 Ul' Iii XI REQth:STED 14!14A!412i VAINf:

I'UtlCT I O!1 CAT.

CAT.

1:XERC ISH 1.MAKAGl; Pressurizer Liquid Space Every 3 Each TV-SS-200 A, 8 Sample Line Containment I

A No Months Refueling NA Isolation Valves Pressurizer Vapor Space Every 3 Each TV-SS-201 A, B Sample Line Containment I

A No Months Refueling NA Isolation Valves Primary Coolant Cold Leg Every 3 Each Sample Line Containment I

A No Months Refueling NA TV-SS-202 A, B Isolation RHR System Sample Line Every 3 Each TV]SS]207A,B SS 203 Containment Isolation II A

No Months Refueling NA TV Pressurizer Relief Tank Gas Every 3 Each TV-SS-204 A, B Space Sample Line Containment A

No Months Refueling NA Isolation Primary Coolant Hot Leg Every 3 Each TV-SS-206 A, B Sample Line Containment I

A No Months Refueling NA Isolation Valves Steam Generator Sample Every 3 Each TV-SS-212 A, d Line Containment II A

No Months Refueling NA Isolation Valves Each MOV-SW-201 A,B,C,D Recirculation Spray HX MOV-SW-20S A,B,C,D Isolation Valves III B

Yes Refueling NA Note 26

Attachnent B.1 I'AGU 15 of 16 TMST PRCQUENCY AS!!C ASMI' RCI,1EP III XI REQUESTED HlO!Ai4Kb VALVE PUt!CTIOr3 CAT.

CAT.

EXCRCISE LEAKAGE I

Recirculation Spray llX Each Each MOV-SW-203 A,B,C,0 Containment Isolation III A

Yes Refueling Refueling Note 10 MOV-5W-204 A,B,C,0 Valves Every 3 MOV-SW-208 A, B Component Cooling IlX Isolation III B

No Months NA NA Valves Every 3 MOV-SW-215 A, 8 Auxiliary Service Water III B

N Months NA NA MOV-SW-217 Pump Discharge Valves Recirculation Spray llX RV-SW-200 A,B,C,D Relief Valves III C

No Note 3 NA Note 3 Component Cooling MX RV-SW-201 A,B Relief Valves III C

No Note 3 NA Note 3 Auxiliary Service Water Every 3 2-SW-24 Pump Discharge Check III C

No Months NA NA Valve Service Water to Recirculation 2-SW-68, 70 Spray l1X Check Valves III C

Yes Ref eling NA Note 26 Recirculation Spray llX Each Each 2-SW-74 84, 94, Inlet Containment III AC Yes Refueling Refueling Note 26 104 Isolation Check Valves

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Attachment B.2 Page 1 of 3 NOTES 1.

Closing of these valves during pow-r operations would seriously impair the heat removal capability of the containment ventilation system.

These valves are vital for continued power operations. As an alternative, they will be cycled each cold shutdown.

2.

Component cooling water flow to the reactor coolant pumps is required at all times the pumps are in operation. Failure of one of these valves in a closed position during cycling would result in a loss of the cooling flow to the pump.

Power operated valves in these systems will be cycled at each refueling when the reactor coolant pumps are inoperative.

Verification of check valve operation to the open position will be performed each time coolant flow is re-established after each refueling.

3.

The frequency and qunatity of relief valves subject to test at each refueling outage will be in accordance with IWV-3500.

4.

Check valves remain in a normally open position with component cooling flow to the heat exchangers. Verification that check valves re-open will be obtained when flow is interrupted and re-established for the cycling tests of the associated power operated valves.

5.

Exercising this valve during power operation would require the charging pump suctions to be aligned with the refueling water storage tank.

This would cause a sudden increase in RCS boron inventory.

It will be exercised during cold shutdown when the RCS is borated to shutdown conditions.

6.

Failure of these valves in a closed position during exercising would cause a loss of charging flow and could result in an inability to maintain reactor coolant inventory. There valves will be exercised when the charging system is not in use during a refueling shutdown.

7.

Exercising this valve during operation could cause a sudden increase in RCS boron inventory.

It shall be exercised at cold shutdown when the RCS is already borated to shutdown conditions.

8.

To protect pump seals, flow to them is required at all times during power operation or cold shutdown.

Exercising of these valves will be performed during refueling outages when risk of equipment damage is eliminated by securing the pumps.

9.

This valve'cannot be exercised when the charging and 'etdown systems are in operation due to the high risk of overpressurization of the RCS.

It will be exercised at refueling outages when the charging and letdown systems are secured.

10. These valves are in the position required to fulfill their function.

Exercising this valve will not improve its operational readiness.

Exercising this valve may actually decrease system reliability if the valve fails in a nonconservative position. As an alternate, it will be exercised at refueling outages.

Attachment B.2 Page 2 of

11. Closure of mainsteam or feedwater valves during normal operations would result in turbine and reactor trips. These valves are closed during the process of shutdown and reopened during plant start-up.

Operation of these valves will be verified at each refueling.

12. Opening of these valves during power operations would introduce cold Auxiliary Feedwater to the Steam Generators resulting in possible thermal stress.

As an alternative, these valves will be checked each re fue ling.

13. Closure of these valves during power operation will result in a Reactor Trip. As an alternative, they will be cycled each reactor shutdown, but not more than once every 92 days.
14. It is not possible to verify that this normally closed check valve opens without initiation of spray through the upper containment header or by visual observation inside the containment. This valve shall be exercised during refueling outages.
15. It is impractical to exercise this check valve during power coeration per IWV-3520. Opening the test valve would break containment vacuum.

The check valves shall be exercised at refueling outages.

16. Operation of RHR System Valves during power cperations would subject the RHR System to full RCS pressure. Valves in the RHR system will be exercised each time tne RHR system is put into operation during the cooldown and shutdown of the reactor coolant system.
17. Opening their valves during power operation would break containment vacuum and violate containment integrity. Their valves shall be exer-cised each cold shutdown, but not more than once every 92 days.
18. These normally closed valves are directly attached to the charging pump discharge header.

During operation or cold shutdown the charging system must be in operation.

If these valves were opened during these periods, uncontrolled flow to the reactor coolant system may cause overpressuriza-tion.

As an alternate, these valves shall be cycled at refueling outages.

19. These normally opened valves are in the required position for an accident and are required by Technical Specifications to remain open during power operations.

They are closed in the normal process of shutdown to cold conditions and reopened during subsequent heat up.

20. These valves are required to be open with power to t..eir operators removed during power operations. As an alternative, they will be cycled every cold shutdown, but not more than once per 92 days.
21. These normally closed check valves cannot be exercised during plant operation or cold shutdown.

No connections exist downstream of the check valve to input flow or pressure which could promote movement of the disc away from the seat.

A test connection is required between the isolation valve and the check valves but cannot be installed.

Attachment ".2 Page 3 of 3 The isolation valve and check valve are butt welded together with no spool piece between them to provide a place for the test connection. As an alternate test, the check valve bonnet shall be removed at refueling outages and the disc shall be exercised mechanically to verify free movement without binding.

22. The only way to verify that these normally closed check valves open is by initiating flow, using the charging pumps, into the reactor coolant system hot and cold legs.

If charging flow was directed to the reactor coolant system in this manner it could cause overpressurization during cold shutdown or provide a loss in charging flow control during operation.

As an alternate, these check valves shall be exercised open during refueling outages.

23. The only way to verify that these normally closed check valves can open is by initiating flow, using the low head safety injection pumps, into the reactor coolant system hot andd cold legs.

During operation or cold shutdown reactor coolant system pressure will be higher than the low head pump discharge pressure precluding flow into the vessel. As an alternate, these valves shall be exercised open at refueling outages.

24. This valve cannot be exercised without possible damage to the charging pumps. It will be exercised with the charging pumps secured at re fue ling outages.
25. To exercise this normally closed check valve would require the simulation of a loss of coolant accident, i.e.

Icw RCS pressure. The valve shall be verified operable by initiating accumulator inje<. tion to the RCS with the vessel head removed during each refueling outag e.

26. A commitment has been made to th ACRS prohibiting :he introduction of service water into the Recird. Spray Heat Ezchanger3 without subsequent drying by a compressed air purge through the heat exchanger.

Exercising this valve will be accomplished at refueling outages when service water flow will be sent through t'a heat exchangers and iir drying may be accomplished.