ML19344D046

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Request for Exemption from Certain Provisions of 10CFR50, Append J,Gen Design Criteria.Mod 760812 Exemption Request. Covers Types A,B & C Test Requirement & Exemption Requests
ML19344D046
Person / Time
Site: Oyster Creek
Issue date: 11/22/1978
From: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 7811280262
Download: ML19344D046 (16)


Text

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Jersey Central Power & Light Company Madison Avenue at Punch Bowl Road Monistown, New Jersey 07960 (201)455-8200 November 22, 1978 Director of Nuclear Reactor Regulation U.S.-Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

Subject:

Oyster Creek Nuclea Generating Station Docket No. 50-219 Request for Partial Exemption from the Requirements of 10 CFR 50 Appendix J In accordance with 10 CFR 50.12(a), Jersey Central Power 6 Light Company, owner and operator of the Oyster Creek Nuclear Generating Station, Provisional Operating License No. DPR-16, requests exemption from certain provisiens of 10CFR50, Appendix J. This letter modifies our request of August 12, 1976. We have not included proposed Technical Specification changes, since .we believe that it would be more appropriate to prepare those after receiving your response'to the exemptions that we have requested.

Since Oyster Creek went into operation in December of 1969, it is to be expected that full compliance with Appendix J, which was published on February 14, 1973, might not be achievable. In addition, the containment isolation design criteria for Oyster Creek differ from the General Design Criteria (10CFR50 Appendix A) published in 1971, on which Appendix J is in part based, further complicating the application of Appendix J to Oyster Creek.

Table 1 describes the differences between the Oyster Creek Type A test program and the Appendix J requirements. It states where we propose modifications to bring Oyster Creek into compliance with Appendix J and where we request. exemptions, with the bases for those requests. Table 2 treats Type B tests in a similar fashion.

Table 3 lists all of the valves at Oyster Creek that might be considered containment isolation valves and gives the valve number, locations (inside or outside primary containment), type, and size. It-identifies those valves which we consider to require testing under the provisions of Appendix J.II.l!. It shows which valves are presently-tested, which we are commiting to' test in the future, and those for which we request.an exemption from testing.

The commitments that are being made for Type A and Type C testing require hardware. modifications that must yet be designed and installed. Schedules for these modifications are being developed, and will be submitted to the Commission. The schedules will depend in large part- on the availability and Icad times for equipment and the schedule of future plant outages.

Very truly yours, j /b7 .k V 1 781188@ N "I an R. Finfr ik, '.

Y Vice President q

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i Jersey Central Power & Light Company is a Member of the General PutAc Utaties System

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h' Momstown, Now Jersey 07n60 C'00 4% 8?nn Director of Nuclear Reactor llegulation II.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Part ial fixemption from the Requirements of 10 CFit 50 Appendix J In accordance with 10 CI:R 50.12(a), Jersey Central Power T, Light Company, owner and operator of the Oyster Creek Nuclear Generating Station, Provisional Operating I,icense No. DPR-16, requests exemption from certain provisions of 10CFR50, Appendix J. This letter modifies our request of August 12, 1976. We have not included proposed Technical Specification changes, since we believe that it would be more appropriate to prepare those after receiving your response to the exemptions that we have requested.

Since Oyster Creek went into operation in December of 1969, it is to be expected that full compliance wi+h Appendix J , which was published on February 14, 1973, might not be achievable. In addition, the containment isolation design criteria for Oyster Creek differ from the General Design Criteria (10Cl R50 Appendix A) published in 1971, on which Appendix J is in part based , further complicat ing the application of Appendix J to Oyster Creek.

Table I describes the differences between the Oyster Creek Type A test program and the Appendix J requirements. It states where we propose modifications to bring Oyster Creek into compliance with Appendix J and where we request exemptions, with the bases for those requests. Table 2 treats Type B tests in a similar fashion.

Tabic 3 lists all of the valves at Oyster Creek that might be considered containment isolation valves and gives the valve number, locations (inside or outside primary containment) , type, and size. It identifies those valves which we consider to require testing under the provisions of Appendix J. II .ll. It shows which valves are presently tested, which we are commiting to test in the future, and those for which we request an exemption from testing.

The commitments that are being made for Type A and Type C testing require hardware modifications that must yet be designed and installed. Schedules for these modifications are being developed, and will be submitted to the Commission. The schedules will depend in large part on the availability and lead times for equipment and the schedule of future plant out a;;es .

Very truly yours,

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Ivan R. I- i n , ' c k , . r.

Vice President Jorcy Cemd Peer & lacht Conwy n a Merntwr el n'e G-ral Put+c Ut htr. G,wm

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Jersey Central Power & Light Company M d

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Mulen Aenue at Punch Bowlihvi Mornstown. New Jersey ONGn (201)4 % 8200 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C 20555

Dear Sirs:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Partial lixemption from the Requirements of 10 CFR 50 Appendix J In accordance with 10 CFR 50.12(a), Jersey Central Power 6 Light Company, owner and operator of the Oyster Creek Nuclear Generating Station, Provisional Operating License No. DPR-16, requests exemption from cc rtain provisions of 10CFR50, Appendix J. This letter modifies our request of August 12, 1976. We have not included proposed Technical Specification changes, since we believe that it would be more appropriate to prepare those after receiving your response to the exemption that we have requested.

Since Oyster Creek went into operation in December of 1969, it is to be expected that full compliance with Appendix J , which was published on February 14, 1973, might not he achievable. In addition, the containment isolation design criteria for Oyster Creek differ from the Cencral Design Criteria (10CFR50 Appendix A) published in 1971, on which Appendix J is in part based, further complicating the application of Appendix J to Oyster Creek.

Table I describes the differences between the Oyster Creek Type A test program and the Appendix J requirements. It states where we propose modifications to bring Oyster Creek. into compliance with Appendix J and where we request exemptions, with the bases for those requests. Table 2 treats Type B tests in a similar fashion.

Table 3 lists all of the valves oc Oyster Creek that might be considered containment isolation valves and gives tlw valve number, locations (inside or outside primary containment), type, and size. It identifies those valves which we consider to require testing under the provisions of Appendix J. II.ll. It shows which valves are presently tested, which we are commiting to test in the future, and those for which we request an exemption from testing.

The commitments that are being made for Type A and Type C testing require hardware modifications that must yet be designed and installed. Schedules for these modifications are being developed, and will he submitted to the Commission. The schedules will depend in large part on the availability and lead times for equipment and the schedule of future plant outages.

Very truly yours,

/ l2/?/f 2D "Ivan R. Finf ick ,,

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Vice President Jerwy Ccrea! Poer & tnpt commny r, a Memtre of the Genor p Poue Uthes Syvem

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  • s E.s Jersey Central Power & Light Cornpany 5 ' iil J.V Mahon Amujo at Punch Bowl Road Y ,

a { Morr6 town. New Jersey 07960 (201)455-8200 Director of Nuclear Reactor Regulation D.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Partial lixemption from the Requ ; ren'en t s of 10 CFR 50 Appendix J In accordance with 10 CFR 50.12(a), Jersey Central Power 6 1.ight Company, owner and operator of the Oyster Creek Nuclear Generating Station, Provisional Operating I.icense No. DPR-16, requests exemption from certain provisions of 10CFil50, Appendix J. This letter modifies our request of August 12, 1976. We have not included proposed Technical Specification changes, since we believe that it would be more appropriate to prepare those after receiving your response to the exemptions that we have requested.

Since Oyster Creek went into operation in December of 1969, it is to be expected that full compliance with Appendix J, which was published on February 14, 1973, might not be achievable. In addition, the containment isolation design criteria for Oyster Creek differ from the General Design Criteria (10CFR50 Appendix A) published in 1971, on which Appendix J is in part based, further complicating the application of Appendix J to Oyster Creek.

Table 1 describes the differences between the Oyster Creek Type A test program and the Appendix J requirements. It states where we propose modifications to bring Oyster Creek into compliance with Appendix J and where we request exemptions, with the bases Ar those requests. Table 2 treats Type B tests in a similar fashion.

Table 3 lists all of the valves at Oyster Creek that might be considered containment isolation valves and gives the valve number, locations (inside or outside primary containment), type, and size. It identifies those valves which we consider to require testing under the provisions of Appendix J.II.ll. It shows which valves are presently tested, which we are commiting to test in the future, and those for which we request an exemption from testing.

The commitments that are being made for Type A and Type C testing require hardware modifications that must yet be designed and installed. Schedules for these modifications are being developed, and will be submitted to the Commission. The schedules will depend in large part on :.nc availability and lead times for equipment and the schedule of future plant outages.

Very truly yours,

$ll/ jf!E '

Ivan R. Fin f(ock , ' r.

Vice President Jerm ccennat row A I iqht enmmo, m a Memhor of ine r,onml ruh'c t mu on setom i

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Page 1 of S .

. TABLE I OYSTER CREEK CONTAIN!!ENT LEAKAGE 111 STING PROGRAM REQWSTED EXEWTIONS FROtt 10 CFR PART 50 APPENDIX J TYPE A TEST REQUIRENS f

item Type A Test Requirements Oyster Creek Program I Those portions of the fluid systems that are part of The following systems, portions of which are part .

the reactor coolant pressure boundary and are open of the reactor coolant pressure boundary and may - "

directly to the containment atmosphere under post be open directly to the containment atmosphere under +

accident conditions and become an extension of the post accident conditions, are not opened or vented boundary of the containneent shall be opened or and drained as required by Appendix J.

vented to the containment atmosphere prior to and - .

during the test. Portions of closed system inside 1. Emergency Condenser System Condensate return loop.

containment that penetrate containment and rupture' The condensate return loop of the ECS are as a result of a loss-of-coolant accident shall be . connected to two recirculation loops below the vented to the containment atmosphere. All vented' level of the water in the reactor vessel and systems shall be drained of water or other fluids .therefore cannot be drained when fuel is in to the extent necessary to assure exposure of the the vessel. 1he EC steam lines and condenser system containment isolation valves to containment- tubes are drained and are exposed to the contain-air test r .ssure and to assure they will be sub- ment atmosphere. This system is designed to jected to the post accident differential pressure, function.during an accident and is an extension of the containment boundary. Ilaving the condensate Systems that are required to maintain the plant in return loop filled during the test will not a safe condition during the test shall be operable affect the test results. We therefore request an in their normal mode, and need not be vented. exemption frpm, draining this portion of the system.

Systems that are normally filled with water and operating under post accident conditions,such as 2. Reactor Sample line.

e c ntainment heat removal system, need not be This line connects to a recirculation line below ,

g the level of the water in the reactor vessel and nowever, the containment isolation valves in the therefore cannot be drained when fuel is in the systems defined in III. A.l(d) shall be tested in vessel. Modifications will be made to allow-local leak rate testing of this penetration.

accordance with Ill.C. The measured leakage rate '

The leakage through this penetration will be from these tests shall be reported to the Commission.

added to the ILRT results.

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3. Feedwater System.

The two feedwater lines enter the reactor vessel below the water level in the vessel during the 1

test. This prevents draining. Modifications will be made to allow Type C testing of the feedwater check valves. The leakage through these penetrations will be added to the ILRT results. -

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TABLE 1 Page 2 of 5 OYSTER CREEK CONTAINMENT LEAKAGE TESTING PRCGRAM REQUESTED EXEMPTIONS FROM 10 CFR PART 50 APPENDIX J TYPE A TEST REQUIREMENTS (CONT.)

4. Reactor Cleanup System

.This system connects to two recirculation lines below the water level in the reactor vessel, which prevents draining and venting when fuel is in the vessel. The system is in operation during the test to provide reactor water level control. Modifications will be made to allow Type C testing of the system isolation valves. The leakage through these penetrations will be added to the ILRT results.

5. Shutdown Cooliag System.

This system is in service during the Type A test to provide decay heat removal. No Type C testing is performed since this system does not contribute to post accident leakage. The system isolation valves are closed during operation. In addition, the system is closed outside the containment, is Seismic Class I and is protected from the effects of pipe ruptures. We request an exemption from the requirement for venting and draining this system.

6. CRD llydraulic Return to Reactor This line enters the reactor vessel below the water level during the Type A test, and cannot be drained and vented. Provisions will be made for local leak rate testing of the isolation valves.

The leakage from this penetration will be added to the ILRT results.

7. CRD Insert and Withdraw These lines connect to the control rod drive unit and are thus indirectly connected to the reactor coolant system. They are small lines (3/4" and I")

and are Seismic Class I and are protected from damage due to pipe ruptures. Outside the containment they enter the CRD Ilydraulic Units, which contain many valves, none of which were specifically intended for containment isolation, althouRh they may be used for that purpose. The CRD pumps would normally be operating following an accident supplying high pressure water to the drives thus preventing

Page 3 of 5 TABLE 1 OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAM REQUESTED EXEMPTIONS FROM 10 CFR PART 50 APPENDIX J TYPE A Tr.ST REQtilREMENTS (CONT.)

.outleakage from the containment. We request an exemption from the requirement to vent and drain these penetrations.

8. Liquid Poison This line connects to a sparger in the reactor vessel below the water level during the test, and cannot be drained and vented. Hodifications will be made to allow Type C testing of these isolation valves. The penetration Icakage will be added to the ILRT results.
9. Core Spray to Reactor These lines connect to a sparger in the rea: tor vessel which is below the water level during the test, and cannot be drained and vented. The core spray system forms a closed loop outside of the containment, and would not be a source of post accident leakage. The system is Seismic Class I and is protected against the effects of pipe ruptures and hem msssics. We request an exemption from the requirements for venting and draining this system.
10. Reactor llead Cooling The portion of this system outside of the containment is pressurized by the CRD pumps, preventing the outermost isolation valve from being exposed to the potential post accident differential pressure.

Changes will be made to allow proper Type A testing of this system.

11. Reactor Coolant Instruments Most of the instrument lines cannot be drained since they connect to the reactor coolant system below the level of the water during the test. The instruments are closed outside of the containment and are designed to withstand accident conditions. They are not expected to be a source of post acc; lent leakage. In addition, the lines are very small (one inch or less). We request an exemption from this requirement to vent and drain these lines.

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TABLE I OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAM REQUESTED EXDFTIONS FROM 10 CFR PART 50 APPENDIX J TYPE A TEST RI:QUIRDtENTS (GNT.)

In our August, 1976 exemption request , an exemption was requested for the instrument and service air systems. Modifications will be made to assure . - -

exposure of the isolation valves to the test pressure and to assure that there can be no leakage into the containment that could artificially improve the results of the Type A test.

1he Reactor BuildinR Closed Cooling Water System is not vented and drained during the Type A test. The portion of the system external to the containment is in service to provide cooling water for the shutdown cooling system. The portion in the contain-ment provides cooling water for the containment atmosphere cooline units. Modifications will he made to allow Type C testing of the system isolation valves. The penetration leakage will be added to the ILRT results.

The Dcmineralized Water system will be modified to -

allow proper Type A testing.

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'l TABLE 1 Page 5 of 5-OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAM REQUESTED EXEMPTIONS FROM 10 CFR PART 50 APPENDIX J TYPE A TEST REQUIREMENTS (CONT.)

f 2 Test Methods

-(a) All Type A tests shall.be conducted in (a) The' request for exemption from testing the -

accordance with the provision of the reference volume following the Type A test American National Standard N45.4-1972, is being withdrawn.

L Leakage Rate Testing of Containment Structures for Nuclear Reactors, March 16, 1972, lhe method chosen for the initial test shall normally be used. for the periodic

-tests (b). Test leakage rates shall be. calculated (b) A statistical analysis of instrument error using absolute values corrected for is performed and submitted with the. test instrument error. report. The root-mean-square error derived . .

from this analysis is not added to the measured leak rate. We believe that the supplementory test adequately accounts for instrument errors. .. '

and that adding the root-mean-square error would be overly conservative.

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i TABLE 2 Page 1 of 1 OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAM ,

REQUESTED EXEMPTIONS FROM 10 CFR PART 50 APPENDIX J TYPE B TEST REOUIREMENTS Item Type a Test Requirement Oyster Creek Program i

.I Piping Penetrations fitted with expan'sion bellows The steam line penetrations (two lines) are not tested are subject to test each refueling outage. by a local leak rate test. These penetrations consist of only one leakage barrier, making local leak rate testing of the sort done for other penetrations in- -

possible in this case. (This exemption was approved by the NRC in a letter of December 3,1976.) .

2 All preoperational and periodic Type B tests shall 1he drywell air lock will be tested in'accordance with

. be performed by local pneumatic pressurization of the guidance in Attachment A to the NRC letter of the containment, either individually or in groups, December ' 3, ~ 1976. The air lock will be tested at six

.at a pressure not less than Pa. . month intervals at a pressure of 35 psig using strong-

' backs. to prevent - the inner door from being unseated.

If the air lock is opened during the interval between ti*e 3 Air locks shall be tested at six month intervals.

However, air locks which are opened during such ' six month tests, the air lock will be tested within 72 intervals, shall be tested after each opening. , hours of every first of a series of openings, at a pressure of 10 psig. This pressure does not require the use of stronR b acks. 1hc results of the tests at 10 psig will be conservatively extrapolated to a leakage l

rate at 35 psig to determine the acceptability of each test.

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Type C Testing The attached table is a list of all valves at Oyster Creek which might be considered containment isolation valves. These valves were reviewed against the General Design Criteria and the criteria of 10 CFR 50 Appendix J.II.H. to determine if they require testing. The section from Appendix J states:

H. " Type C Tests" means tests intended to neasure containment isolation valve leakage rates. The containment isolation valves included are those that:

1. Provide a direct connection between the inside and outside atmospheres of the pri-mary reactor containment under normal operation such as purge and ventilation, vacuum relief, and instrument valves;
2. Are required to close automatically upon receipt of a coi tainment isolation signal in response to controls intended to effect containment isolation;
3. Are required to operate intermittently under postaccident conditions; and
4. Are in main steam and feedwater piping and other systems which penetrate contain-ment of direct-cycle boiling water power react ors .

The table shows the results of our evaluation. It tells which valves are presently tested and which valves will be tested in the future in accordance with Appendix J. It also indicates those valves for which we are seeking an exemption from testing or an exemption as to the methods of testing.

TI.e interpretation of H.4 caused us some difficulty. It clearly cannot mean all systems which penetrate containment, since most of those systems are sTmilar to PWR systems, which are not mentioned. We interpret it to mean "other similar systems". This would include the Main Steam Line Drains, the Emergency Condenser Steam Lines, Steam Line Vents, and Condensate Lines.

table 3: TYPE C ll: STING REQUIREMENTS, COFN11MENTS, AND EXEMPTION REQUESTS . Page 1 of 8 APPI:Nul K J II. II. PRESENTLY C0Fet1TMl.NT EXLMPTION VALVE NllMBER IDCATION TYPE SIZE 1 2 3 4 1T.STED 1D TEST - REQlH STi li PIPING SYSTEM A. O. Globo 24" NA NA Main Steam V-1-7 Inside N Y N Y Y A. O. Globe 24" NA NA-Main Steam V-1-8 Inside 'N Y N Y Y Outside A. O. Globe 24" N Y N Y Y NA NA Main Steam V-1-9 24" NA NA plain Steam V-1-10 Outside A. O. Globe N Y N Y Y 2" NA NA kLiin Steam Drain V-1-106 Inside it. O. Gate N Y N Y Y 2" NA NA Plain Ste.im Drain V-1-107 Inside M. O Gate N Y N Y Y NA NA 6 Lain Steam Drain V-1-lla Outside M. O. Gate 2" N Y N Y Y 2" N Y NA NA Main Steam Drain V-1-Ill Outside M. O. Gate N Y Y 18" Y N leedwater V-2-71 Outside Check N N N Y N 18" N Y N Feedwater V-2-72 Outo,oc Check N N N Y 18" N Y Y N Feedwater V-2-73 Inside Check N N N 18" N Y h Feedwater V-2-74 Inside Check N N N Y N N M. O. Cate i

V-5-147 Outside 6" N N N N N RBCCW to Drywell N N N N N N NBCCW to Drywell V-5-165 Inside Check 6" N N N N N RBCCW from Drywell V-5-166 Inside M. O. Cate 6" N N N N N RBCCW from Drywell V-5-167 Outside M. O. Cate 6" N N N N N 2" N N N N C. S. Test Air V-6-133 Outside L. C. Globe N N N L. C. Globe 2" N N N N C. S. Test Air V-6-134 Outside N N N L. C. Globe 2" N N N N N C. S. rest Air V-6-135 '

Outside N N f

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Page 2 of 8 TABLE 3 (CONT.)

APPENDIX J II. 11. PRESENTLY ComlTENT EXEMPTION.

VALVE NUMiti.R LOCATION TYPE SIZE I 2 3 4 TESTED TO TEST krQtlESTfD '.i l i '

PIPING SYSTEM C. S. Test Air V-6-136 Outside L. C. Globe 2" N N N N N N N Outside N N

t. . S. Test Air V-6-137 L. C. Globe 2" N N N N N C. S. Test Air V-6-138 Outside L. C. Globe 2" N N N N N N N Inst. Air Outside 2" N- N N N N N N '

Inst. Air Outside 2" N N N N N N N .

V-12-13 Check 2" N N N N N N N Demin. Water Inside Demin. Water V-12-60 Outside Diaphram 2" N N N N N N N E. C - Steam Vent V-14-1 Outside A. O. Control 3/4" N Y N Y N Y N i L. C. - Steam Vent V-14-5 Outside A. O. Control 3/4" N Y N Y N Y N I E. C. - Steam Vent V-14-19 Outside A. O. Control. 3/4" N Y N Y N Y N 1 V-14-20 Out side A. O. Cont rol 3/4" N Y N Y N Y N i E. C. - Steam Vent V-14-30 Outside M. O. Cate 10" N N Y Y N N Y E. C - Steam Line E. ' C. - Steam Line V-14-31 Outside M. O. Gate 10" N N Y Y N N Y Outside M. O. Gate 10" N Y Y N N Y 2 E. C. - Steam Line V-14-32 N V-14-33 Out side M. O. Gate 10" N N Y Y N N Y 2 E. C. - Steam Line E. C. - Cond. Line V-14-34 Outside M. O. Gate 10" N N Y Y N N Y J E. C. - Cond. Line V-14-35 Outside M. O. Cate 10" N N Y Y N N Y 2 E. C. - Cond. Line V-14-36 Inside M. O. Gate 10" N N Y Y N N Y 2 I.. C. - Cond. Line V-14-37 Inside M. O. Cate 10" N N Y Y N N Y 2

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TABLE 3 (CONT.) . g'Jge . 3 u f s APPENDIX J. II. it. PRESENTLY (XBNITMLNT EXDa> rl0N SIZE 4 . TESTED TO TEST REQUES11't> .h.-

PIPING SYSTEM VALVE NUMBER IDCATION TYPE 1, 2, , 3, Outside Check 3" N N N N N N N CRin IlyJ. to Reactor V-15-27 Ch'eck - 3" N N N N N P N 4:Rin flyd. to Reactor V-15-28 Inside 137 lines outside . Ga t e _ 1" N N N N N M N t'RD. Insert CRinWf.hdraw 137 lines Outside Cate 3/4" N N N N' N N .N Cican up from Reactor- V-16-1 Inside M. O. Cate 6" N. Y .N N N Y N Outside M. O. Gate 6" N Y N N N Y N. a Cir an up from Reactor V-16-2 C lean up.. from Reactor V-16'-4 Outside - L. C. Globe 1" N N N N N. N N

~

Outside 6" N Y N N N Y N Cleanup ' f rom Reactor 'V-16-14 M. 0. Gate Clea$up to Torus V-16-30 Outside.- S. O. Gate 1/2" N y N N N 'Y N Outside M. O. Cate 6" N Y N N N Y N Cleanup to Reactor V-16-61 Cleanup to Reactor V-16-62 Inside Check 6" N Y .N N. ~N Y N V-16-76 Outside Retlef 6" N N N N 'N N N Cleanup ' to ".orus Outside . Check 20" N N N N N N N Cleanup ' to orus V- 1 (- o4 Shutdown Jooling V-Is-1 Outside M. O. Cate 10" N N N N N N- 1N 4

M. O. Gate 10" N N N N N N N

. Shutdown Cooling- V-17-2 Outside Outside M. O. Cate 10" N N N .N N 'N N Shutdown Cooling V-17-3 Shutdown Cooling V-17-19 Inside M. O. Cate 14" N Y N N N N Y I Shutdown Cooling V-17-54 Inside M. O. Gate 14" N Y N N N N Y- i I Shutdown Cooling V-17-55 Outside M.'O. Gate 8" N N N N N .N. N Shutdown Cooling V-17-56 Outside M. O. Gate 8" N N N N N -N N l Shutdown Cooling V-17-57 Outside M. O. Cate 8" N N N N N N N i

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Page 4 of n TABLE 3 (CONT.)

APPENDIX J 11.11. PRESENTIN COFNIT>t_NT E XL b5'T I ON -

VALVL NUMtit R LOCATION TYPE SIZE 1, 3, 4 TESTED TO TEST REQUES1LD .f' Pil* LNG SYSlEM 2_

Liquid Poison V-19-16 Outside Check 1 1/2" N N N N N N N Liquid Poison V..19-20 Inside Check 1 1/2" N N N N N N N I.iquid Poison NP05A Outside Explosive 1 1/2" N N N N N N N Liquid Poisor_ NP05B Outside Explosive 1 1/2" N N N N N N N Core Spray tor x NZ-02A Inside A. O. Check 8" N N N N N N N Cure Spray tor x NZ-02B Inside A. O. Check 8" N N N N N N N Core Spray tor x NZ-02C Inside A. O. Check 8" N N N N N N N Coro $ pray toRx NZ-02D inside A. O. Check 8" N N N N N N N rom V-20 3 Outside M. O. Gate 12" N N N N N N N CoreT g ay Core Spray from V-20-4 Outside M. O. Gate 12" N N N N N N N to rus Core Spray to Rx V-20-15 Outside M. O. Cate 8" N N N N N N N Core Spray to Rx V-20-21 Outside M. O. Gate 8" N N N N N N N Core Spray V-20-26 Outside M. O. Gate 6" N N N N N N N Core Spray V-20-27 Outside .M. O. Cate 6" N N N N N N N V-20-30 Outside Check 6" N N N N N N N Core Spray V-20-31 Outside Check 6" N N N N N N N Core Spray Cure Spray from V-20-32 Outside M. O. Cate 12" N N N N N N N t o rus Core Spray from V-20-33 Outside M. O. Gate 12" N N N N N N N forus Core Spr.iy to R 3 V-20-40 Outside M. O. Cate 8" N N N N N N N Core Spray to 1(x V-20-41 Outside M. O. Gate 8" N N N N N N N

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I

! TABLE 3 (CONT.) Pege 5 of g -

i-APPENDI E J II . H. PRESENTLY OM441THENT iE1LMPTION SIZE 2 3 4 TESTED - 10 TEST REQUESTliD ' M i!!i PIPING SYSTEM VALVE NUMBLR ' LOCATION TYPE 1 Core Spray V-20-92 Outside. A. O. Cate' 1 1/2" N N N N N N N Outside A. O. Cate 1 1/2" N N N N N N N  ;

Co rc , Spray ' V-20-93 Containment Spray V-21-1 Outside M. O. Cate .12" N N N N N N N Containment Spray V-21-3 Outside M. O Cate 12" N. .N N.N N N N .,

Containment Spray V-21-5 Outside M. O. Cate' 14" .N N N N N N .N

i. .Cuntainment Spray .V-21-7 Outside M. O. Gate 12" N- N N N N N N i

Containment ' Spray V-21-9 Outside M. O. Cate 12" N N .N N N N N l

Containment Spray 'V-21-Il Outside M. O. Gate 14" N N N N N N N V-21 'Outside M. O. Cate 6" N N N N N N N

~ Containment Spray i

containment Spray V-21-IS'- Outside M. O. Cate 4" N N N N N N N N'

. Containment Spray, V-21-17 Outside M. O. Cate 6" N N N N N N Containment Spray .V-21 Outside M. O. Gate 4" N N N N N N N Containment Spray V-21-19 Outside Check 1" N- N N N N N .N Containment Spray V-21-20 Outside Check 1" N N N N N N N DW Egip. Drain V-22-1 Outside A.O. Globe 2" ' N Y N N Y(o) NA~ NA V-22-2 Outside A.O. Globe 2" N Y N N Y NA NA DW Egip. Drain Iloor Drain V-22-28 Outside A.O.' Globe 2" N Y N N Y(o) NA NA 1

Outside .. A.O. Globe 2" N Y N- N Y NA NA

' Floor Drain V-22-29 i

4 l

b

_ - e -m

._. . .. . _ . , - ._ . _.-. _ ..-.m _ __ _ = _ . _ _ _ _ . , , _ . . . _ . . _ ,_ _ . . _ . , _. .

Page S of ti TABLE 3 (CONT.)

r APPENDIX J 11. II. PRESENTLY. COh041THEffr lit! W TinN .

VALVI: NUMBER IDCATION TYPE SIZE 1. 2 3 4 TESTED 10 TEST REQtJESTLD y

'.>it-PIPt.\G SYSTEM 8" NA NA t rywcl! Ny Purge V-23-13 Outside A.O. Butterfly Y Y N N .Y .

A.O. Butterfly 8" NA . ' NA torywc!! N2 Purp V-23-14 Outside Y Y N N Y(o)

NA- NA

- ' lorus N2 Purge V-23-15 Outside A,0. Butterfly 8" Y .Y N N Y A.O. Butterfly 8" N N Y(o) NA NA lorus N, Purge V-23-16 Outside Y Y Outside A.O.. Globe 2" N Y N N Y NA NA t lEywell Ny Makeup V-23-17 A. O. Globe 2" N. N N Y(o)' NA NA

tirywell N2 Makeup V-23-18 Outside Y Outside A.O. Globe" 2" N .Y- N. N Y NA NA-torus'Ny Rikeup V-23-19 A.O. Globe 2" N N Y(o) NA NA

. lorus N2 Makeup- V-23-20 Outside N Y A.O. Globe NA . NA~

lirywell Vent Bypass V-23-21 Outside 2" Y Y N N Y(o)'

A.O. Globe 2" 'N N' NA NA Drywell Vent. Bypass V-23-22 Outside Y Y Y Inside .A.O. Control 3/4" N Y .N N N Y N Reactor Sample V-24-29 V-24-30 Outside A.O. Control 3/4" N Y N N N Y N H ctor Sample 20" y .N Y NA' NA.

' lorus to Rx Hldg. V-26-15 Outside Check Y N Vac. Hrcaker NA V-26-16 Outside A.O.. Butterfly 20" Y N Y N Y(o) NA lorus to R Bldg.

Jac. Brcaler 20" Y NA NA forus to R Bldg. V-26 Outside Check Y N Y N Vac.Brealer 20" NA NA [

3

'lierus to R H V-26-18 Outside A.O. Butterfly Y N Y N Y(o) >

Vac. Hrcaler!dg.

lirywell Vent , V-27-1 Outside A.O.' Butterfly 18" Y Y N N Y NA NA V-27-2 Outside A.O. Butterfly 18" Y Y N N Y(o) NA NA ifrywell Vent i

l 4

1 9

Page 7 of 8 TABLL . .t (CONT.)

APPL.NDlX J 11 H . P RESENTI.Y CO*llEvr EXIJsiloN .

IDCATION TYPE SIZE I 2 3 4 TESTED TO Ti$7 " REQill STI'D .

PIPING SYSTI.M val.VP M)MBl:R Y Y N Y NA NA Isrywell Purge ' Inlet V-27-3 Outside A.O. Br,tterfly 18" N A.O. Butterfly 18" Y N N Y(o) NA NA tirywell' Purge Inlet . 'V-27-4 ' Outside Y A.O. Butterfly .12" Y Y N N Y(o)' ~NA- NA' lorus Vent V-25-17 'Outside NA N4 l'onts Vent .'V-28-18 Outside A.O. Butterfly; 12" Y Y N N Y Globe 2" Y Y N N Y(o) NA .NA Turus Vent V-28-47 Outside N. N. N N N Rx Ilead Cooling V-31-2 'Outside A. O. Gate. 2'? N N Inside Check  !"

2 N N N N N N N km licad Cooling V-31-5.

N N N N N N 'N Rx Coolant. Inst. I valve cach of 59 lines ' 0+.tside E.F. Check I" Globe 1" N N N 'N N N' N Rx Coolant Inst. I valve cach of 59 lines Outside N- N N N lirywell Pressure Inst. I valve each line Outside .1" .N N. N Outside ~N N N N N N N' lorus Pressure Inst. .

Outside Cate 2" - N N N N N N N Torus Level Inst. .V-20-62 Cate 2" N N N N N N N V-20-63 Outside.

2" N N N N N N. N Inst. Ny~ to Drywcli V-6-1003 Outside Gate V-6-1004 Outside Control 2" N N N N- N' ,N N N N Y- N N TIP 1 valve . cach of 4 lines ' Outside Ball 1/4" N Y 1 valve each of 4 lines Outside Shear 1/4" N N 'N N N N N TIP

Page 8 of 8 TABLE 3 (CONT.)

NOTES Abbrevia tions : M.O. - Fbtor operated A.O. - Air Operated E.F. - Excess Flow I.. C . - lockcJ closed S.O. - Solenoid Operated N. - No Y. - Yes Y(o) - Yes, but valve is tested in direction opposite to the direction of intended isolation N.A. - Not upplicable R - Reactor C.S* - Containment Spray E.C. - Emergency Condenser R.B.C.C.W - Reactor building closed cooling water

1. The E. C. Steam vent connections are outside the outermost E. C. steam line isolation valves, and therefore V-14-1, 5, 19, and 20 would not normally be considered isolation valves. Ilowever, since the E. C. steam line isoletion salves do not close automatically, except in case of an E. C. Line break, the vents could bypass containment isolation if they were not closed or were leaking.
2. An exemption from testing is being sought for the E. C. steam line and condensate line isolation valves. The E. C.

system is designed to be operable following an accident and acts as an extension of the containment boundary. It is I..

not a source of leakage during the post accident period. It is isolated automatically only on high t' low, or manually on radiation in the condenser shell vent.

5 This sytem is being reevaluated. It will be modified so that the isolation valves are exposed to the Type A test differential pressure and to assure that no air can leak into the containment and interfere with the test.

4. An exemption is being sought on the basis that the Shutdown Cooling System would not be expected to be a source of post accident leakage. The system isolation valves are closed during power operation. The system is closed outside containment, is Seismic Class I and is protected from the effects of pipe ruptures.

~

5. These valves will' bo locally Icak rate tested in order to comply with Type A testing requirements.

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