ML19345G512

Forwards Editorial Revisions to Inservice Insp Program

ML19345G512
Person / Time
Site:	Davis Besse
Issue date:	03/31/1981
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
702, TAC-10985, TAC-11316, NUDOCS 8104070418
Download: ML19345G512 (32)

Text

{{#Wiki_filter:. Docket No. 50-346 TOLEDO License No. NPF-3 . EDISON Seri. No. 702 March 31, 1981 a.c-e.nc p cac se . x yn,h .' 'vw s,.t pi me .n Ei /,. Q '., i j,. '; y Ik,UL t e '-{' - 'jj Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz Operating Reactor Branch No. A _j , c g 'g - - Division of Operating Reactors j [.5 _ b # T United States Nuclear Regulatory Commission kyy v.s. q"'g,ic,. Washington, DC 20555 f., / % )/./4 {T /

Dear Mr. Stolz:

This letter is to transmit editorial revisions to the Inservice In-spection Program for the Davis-Besse Nuclear Station Unit No. I which was submitted by letter on May 15, 1980 (Serial No. 616), and revised on December 15, 1980 (Serial No. 671). Please find attached five (5) copies of the letter revision delineating the editorial changes to the Inservice Inspection Program. The editorial changes made in this revision reflect the results of telephone conversations with Mr. A. J. Cappucci, U.S. Nuclear Regulatory Commission and Mr. T. Cook, EG&G Inc. This letter revision depicts the editorial changes showing by page number the changes made. Any additions that become necessary, due to modifications and changes to this program during the course of the remainder of the 120 month inter-val, which do not meet the code testing requirements will be implemented as needed. U.S. Nuclear Regulatory Commission notification will follow these changes. Very truly yours, RPC:TWH ds d/1 Attachment rpool cc: 3 Luis Reyes - DB 1 Resident Inspector i I l THE TCLEDO EC:SCN COMPANY ECISON PLAZA 300 MACISCN AVENUE TOLEDO OH10 43652 0 7 () {

SUPE.ARY CF REVISICNE TO THE INSERVICE INSPECTION PROGRAM FOR THE DAVIS-BESSE NUCLEAR STATICN UNIT NO. 1 Page I-l Changed start of program from June 27, D 77, to November 21, 1977 I-6 D. CCDE EXCEPTICNS changed to RELIEF REQUESTS I-7 Code Exceptions changed to Relief Requests I-8 Code Exceptions changed to Relief Requests I-9 Code Exceptions changed to Relief Requests II-l Changed start of program from June 27, 1977, to November 21, 1977 II-20 Test Frequency changed frcm Q to C for Valve Number CV187, Cvl91, and CVil7 II-25 Test Frequency changed frcm R to C for Valve Number RC10 II-32 Max. Stroke Time (Sec.) 31 for Valve Number DH63 I!-33 Max. Stroke Time (Sec.) 18 for Valve Nu=ber DH64 II-50 Max. Stroke Time (Sec.) 70 for Valve Nu ber SW1382 Max. Stroke Time (Sec.) 67 for Valve Number SW1383 II-57 D. CCDE EXCEPTICNS changed to RELIEF REQUESTS II-58 Code Exceptions changed to Relief Requests II-59 Code Exceptions changed to Relief Requests II-60 Code Exceptions changed to Relief Requests Relief Request Nu=ber 4 added, "The reason for not full stroking the check valve is that the auxiliary boiler will not provide enough steam for the pump to spin fast enough." II-61 Code Exceptions changed to Relief Requests II-62 Coue Exceptions changed to Relief Requests II-63 Code Exceptions changed to Relief Requests

Scamary of Revisions to the Inservice Inspect.on Program Page 2 4 page II-64 Code Exceptions changed to Relief Requests Relief Request Number 14 added, " Cooling water to the reactor coolant cumps is required recept at refueling." II-65 Code Exceptions changed to Relief Requests Relief Request Number 15 added, "Coeling water to the reactor coolant pumps is required except at refueling." II-66 Code Exceptions changed to Relief Requests II-67 Code Exceptions changed to Relief Requests Relief Request Number 19 added, "when an adequate expansion volume is available." II-68 Code Exceptions changed to Relief Requests II-69 Code Exceptions changed to Relief Requests II-70 Code Exceptions changed to Relief Requests Relief Request Number 26 - removed statement pertaining to radiation and added, " Loss of pressurizer level control can cause reactor trip." III-l Changed start of program from June 27, 1977, to November 21, 1977 l III-66 D. CODE EXCEPTICNS changed to RELIEF REQUESTS l l III-66a Code Exceptions changed to Relief Requests IV-1 Changed start of program from June 27, 977, to November 21, 1977 l l l I l l l w, w -s ~-,v s-a.e -a e-s e

J 4 i 4 PC.'G TEST PROGRAM i { A. PROGRAM ST.'?.ARY "'he P=p Test program identifies test requirements fer all safety I related p=ps, either these that are tested in accordance with the requirements cf Subsection I*a'P of the ASME Boiler and Pressure vessel Code,1977 Edition and addenda through the Su=r.'er 107s Addenda er these for which the Code requirements have been fc=d to be i= practical. The P'. p Test Program will be applicable for the re=ainder cf the 120 month interval which started en November 21, 1977, after which the g program will be reviewed and updated as appropriate with that edition cf the Code and Addenda ~in effect net more than twelve =enths pricr i to the start of the next 120 month interval. Individual pu. p test requirements are presented in Section C by a coded P =p Test Progra= Table. ~he codes used for this able are defined in Section E. '!?.e Pump Test Program Table of Section C is arranged in numerical sequence by Inservice. Inspection Instrument Drawing (ISID) n=ter. Section T. prevides justificatien for the exceptions taken to Code test requirements as provided for in 10 CTR SC.55a(g) (5) (iii). Justification for each request for relief is general in nature and pertains to requirements fcund to be impractical for all pu=ps. Relief Requests are numbered and referenced by nurier as Code Exceptiens on the P M Test Program Table. ) B. P:!.47 TIST PROGRAM TABI.E FCRMAT -"'he Pu=p Test Program Table has been ceded to provide the folicwing infer =ation: 1. System and Drawine N eter. System the pump is in and the ISID s n=ber. 2. Cocrdinates. Ix>catien on the ISID where the pump is found.. 2. Pume Nu=ber.. Unique number assigned to each pump. 4. Speed n*. These parameters are addressed with one of the fc110w:.ng entries which indicates test interval er applicability: 4 NR - Net Required NA - Not Available. M - Mcnthly.Tast-i Ouarte-ly' Test .:Q Rev. 2-2/61.

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-r...r ..r.~g w-=e e a f- .e. 3 his se: icn provides jus ificatien fer the exceptiens taken :: Code test requirements as provided for in 10 CTR SC.55a(g) (5) (iii). Each Relief Request is identified by a =irce n=ber and identifies the pu: p(s) for which the Relief Regaes: is being taken. Che specific Code test reg; ire =ent found :: be i=eractical is defined, and the basis fer exclusien frc= code require =ents is presented. Any testing performed in lieu cf Code reTaire=ents is spe:ified. Felief FeTaests are n=bered and referen:ed by n:=ber as Code Exceptiens en the P. p Cest Progra Cable fer specific p =ps.

• his section als: resents a s--=ry of. ast.:. n. testing.

r 1. Felief Pecuests a. Felief Re uest ! =1er 1 C:=penen s: Auxiliary Feedwater F. ps P14-1. F14-2 High Press = e Inje::icn P. ps PSE-1, PSE-

• cw Press =e Injecti n P*...ps 742-1, P42-2 Contain=ent Spray P. ps P56-1, 756-2 C =penent Cocling P=ps P43-1, 743-2, 743-3 Service Water P=ps P3-1, 7 3-0, P 3-3 F=

icn: E=ergency core cocling Safatv. related eTaip=ent coclinc. Class: and 2 Ces: ReTaire=ents : Menthly inservice test Basis for Relief ReTaest: Mer.thly Section X: cperability tes ing has been a Ce hni=al Specificati n reTaire=ent for these pu=ps since April 22, 1977. An analysis cf the results of these tests and := parable data frem ether cperating plants have shewn no significant changes in perfermance. Based on this analysis, the continuatien of Seenien X =cnthlv. testing wculd not significan:1v. increase plant safety. "'he Auxiliary Feedwater, High Frassure In;ectien, Low Pressure Injection, and Centain=unt 5rray ?=es are standby pc.:s whose centinuous Opera i:n is ne: reTaired. '"he C==penen: Cocling and Se:tice Water P=ps are c:n inueusly ru.:.ing, and any significant degradatien will be detected d=ing ner=al cpera.icn. I-6 ., /ei . e r. t 4.

?cnthly pu=p testing requires a total of at least 270 hours per year of pump operatien; at least 714 man-hcurs per year for data acquisitiens at least 60 man-hours per year for data reduction, analysis, and record keeping. This amounts to a total of 774 man-heurs per year. At a conservative total cost of S20.00 per =an-hour, this amounts to $15,480.00 per year. Based upon the average exposure rates in the areas of the Auxiliary Feedwater, High Pressure Injection, Low Pressure Injectien, and Containment Spray Pumps, the total man rems exposure per year for pump testing is approximately 2.0 man rems. At the present conservatively estimated cost of $10,000.00 per man rem to plant personnel, this exposure costs an additional S20,000.00 per year. Total cost to our customers is approximately 535,480.00 per year for no significant increase in safety. Alternate Testing: Pu=ps will be tested in compliance with ASME Sec-ion XI once per quarter and will be jogged monthly and flow measured. This is in agreement with present changes that are being knplemented in Subsection IWP of the Code. The revision to change pu=p testing to a three month int eval in IWP-3400 has been approved and will be inc.luded in future Addenda. See Minutes of the Nevember 28, 1979, meetinc of the Operating and Maintenance Working Group - Testing of Pumps and Valves in San Jose, California, dared January 9,1980. l b. Relief Request Number 2 i j Compenents: Auxiliary Feedwater Pumps P14-1, P14-2 [ High Pressure Injection Pumps P58-1, P58-2 l Low Pressure Injection Pu=ps P42-1, P42-2 l Containment Spray Pumps P56-1, P56-2 Component Cooling Pumps P43-1, P43-2, P43-3 I Service Water Pumps P3-1, P3-2, P3-3 lI. Function: Emergency core cooling Safety related equipment cooling Class: 2 and 3 Test Requirements: Measure pump bearing temperature yearly i 1-7 Rev. 2-2/81

1 r Basis for Relief Request: The referenced edition of the Code requires bearing temperature to be recorded annually. It has been de=cnstrated by experience that bearing te=perature rise occurs only minutas prior tc Therefore, the d'tection of possible bearing failure. e bearing failure by a yearly te parature =easurement is extremely unlikely. It requires at least an hcur of pu=p Operation to achieve stable bearing te=peratures. The 'small probability of detecting bearing failure by temperature =aasurement does not justify the additional pu=p cperating time required te obtain the measurements. Alternate Testing: None. This is in agreement with present changes that are being i=plemented in Subsection IWP cf the Code :: delete yearly bearing te=perature =easurement. Celetien of bearing temperature has been approved and will be included in future Addenda. See Minutes of the November 28, 1979, =eeting cf the Operating and Maintenance Working Group - Testing of Pu=ps a.d valves in San Jose, California, dated January 9, 1980. 4 c. Relief Recuest Nu=ber 3 Compenants: Auxiliary Feedwater Pump ' P14-1, Pli-2 High Pressure Injection < umps 758-1, P58-2 Ica Pressure injection Pumps P42-1, P42-2 Centainment Spray Pu=ps P56-1, P56-2 Component Cooling Pumps P43-1, P43-2, P43-3 Service Water Pumps P3-1, P3-2, P3-3 ] Function: Emergency core eccling Safety related equipment cooling Class: 2 and 3 Test Requirements: Observation of proper lubrication level or pressure Basis for Relief Request: The observation of lubrication level or pressure is a =aintenance function not an operability test function. ' Pump lubrication requirements are deter =ined by the pump manufacturer and plant operation. I-B Rev. 2-2/81 m .-.--. - u. -..m.mm. m u-.

Alternate Testing: P=p lubrication requirenents are part of the plant maintenance procedures rather than Section X: cperability test requirements. his is in agreement w:.th present changes that are being i=ple=ented in Subsection I*a'? cf the Code. ~he revisien to el:.rinate observation of lubrication level or pressure frem the Code has been approved and will be included in future Addenda. See Minutes of the Nove.ber 25, 1979, meeting cf the Cperating and Maintenance Working Group - Testing of Pumps and Valves in San Jese, Cal.fernia, dated January 9, 1980, d. Re.'.ief Recuest Nu=ber 4 C=penents : Cc=penent Cocling Pu=ps P43-1, 743-2, P43-3 Service Water P=ps P3-1, P3-2, P 3-3 Function: Safety related equipment eccling Class: 3 Test Requirements: Operability testing of installed spare pumps Basis for Relief Request: Any ene of the three ec=penent coeling or three component service water p=ps is an ins alled spare. One pump is nor= ally runnir7, the seccnd is aligned as an aute=atic backup to ne operating p=p, and the third p=p is electrically discennected and manually valved out of the system. In the event of failure of the operating pu=p, the second autceanically starts, and the installed sp ee is

• electrically connected and manually valved in as the reserve pu=p.

Alternate Testing: The ner= ally operating and reserie pumps will be tested. The instal'.ed spare needs te be tested caly when it is connecte?. to the system. 2. Past Puen Performance

• he following infernation is submitted for your review:

a. P=p Past Perfcr.ance ::ata b. P=p Past Perf 3r=ance Statistical Ar.alysis I-9 Rev. 2-2/81

II. VAI.VP. TEST PROGPM A. PPOGPM S*lMERY

• he Valve Test Progtem identifies test requirements for all sr.fety related valves eithar those that are tested in accordance with the requirements of Subsection IWV of the AS.5' Bo'.ler and Pressure vessel Code,1977 Editicn and addenda through the Su=mer 1978 Addenda or those for which the Code requirements have been found to be impractical.

The Valve Test Program will be applicable for the remainder of the 120 month interval which started on Nove=ber 21, 1977, after which the precram will be reviewed and updated as apprcpriate with that edition of the Code and Addenda in effect not more than tv41ve months prior te the start of the nexs. 120 month interval. ' Individual valve test requirements are presented in Secticn C by coded Valve Test Program Tables. The codes used for these tables are defined in Section 3 and su=marized in Figure 1. "he Valve Test Program Tables of Section C are arranged in numerital sequence by Inservice Inspection Instrument Drawing (ISIO) numbet. Section D provides justification for the exceptions taken to Code test requirements as provided for in 10 CFR 50.55a(g) (5) (iii). Two types of justification are provided. The first is general in nature and pertains to Code requirements found to be i= practical for all valves. The second type is used to justify requests for relief for specific valves. Relief Requests are numbered and referenced by nu=ber as Code Exceptiens on the Valve Test Progra= Tables for specific valves. B. VALVE TEST PROGPRI TABLE FCRMAT 1. Valve Number. Unique number assigned to each valve. t .C.2 -,1.as s. ASME Class. 2. 3. Drawing Coordinates. Location on the ISID where the valve is found. 4. Valve Categerv. Valve Category as defined in Subsection IWV-2200. 5. Passive. An 'X' in this column indicates that a valve is passive as defined in Subsection IWV-2100. All other valves are active valves as described. These valves mechanically constrained to prevent changing positions are designated as 'L' in the Test Requirement column. Those valves whose position is controlled by plant administrative procedures only are designated as 'P' in the Test Requirement colu=n. II-l Rev. 2-2/81 ~ -.

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D. RILIEF.8.E;CESTS This section provides justification for the exceptions taken to Code test requirements as provided for in 10 CFR 50.55a(g) (5) (iii). Each Relief Request is identified by a unique nu=ber and identifies the valve (s) for which the Relief Request is being taken. The specific Code test requirement found to be impractical is defined, and the basis for exclusion from Code requirements is presented. Any testing performed in lieu of Code requirements is specified. Two types of justification are provided. The first is general in nature and pertains to Code requirements found to be i= practical for all valves. The second type is used to justify Relief Requests for specific valves. Relief Requests are numbered and referenced by number as Code Exceptions on the Valve Test Program Tables for specific valves. 1. General Relief Requests a. Relief Request Number G-1 Components: All safety related power operated valves Function: Power operated valve timing requirements l Class: All Test Requirements: Section XI, IWV-3413(b) l l "The stroke time of power operated valves shall l be measured to the nearest second or.10% of the l maximum allowable stroke time, whichever is less, whenever such a valve is full stroke tested." l Basis for Relief Request: For valves with stroke times l of less than 10 seconds, this would require measuring i stroke times to within a fraction of a second. Valve timing is performed using a stopwatch either by directly observing valve movement or by observing remote position indicators. Neither method can be relied upon to yield results with accuracy of less than a second. Alternate Testing: The stroke time of all power operated valves shall be measured to the nearest second. I II-57 Rev. 2-2/81

1 b. Relief Reques-Nu ber G-2 Ocmponents: All safety related pcwer operated valves 1 Function: Power operated valve tirdng requirements Class: All Test Requirements: Section XI, IW-3413(c) "If an increase in stroke time of 25% or more frem the previous test for valves with stroke time greater than 10 seconds or 50% or more for valves with s roke time less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until ccrrective action is taken at which ti=e the original test frequency shall be resumed." Basis for Relief Request: Cperating experience has indicated that individual valve timing is influenced by many factors such as changes in temperature, humidity, fluctuation in power source, li=it switch adjustment, etc. Because of these outside factors, timing data can exhibit scatter which exceeds the Code criteria but which is still less than the maximum full stroke time. Iacking in the Code requirements is any provision for verifying test results prior to placing the valve on an accelerated test frequency. The present Code does not require any action for valves whose stroke time suddenly decreases a significant amount. Any marked decrease outside the normal band of stroke times could indicate a =ajor mechanical problem such as the power operator being disconnected from the valve. Any significant decrease in stroke time should be investigated to determine if the valve and pcwer actuater are capable of performing their function. Alternate Testing: Maxir.sn full stroke times shall be established for each valve based upon required valve response time to assure adequate system response for safety related functions. Valve test times will be acceptable if less than the maximum allowed. If test time exceeds the maximum allowed, the valve will be immediately retested and corrective action taken as appropriate. Any significant decrease in valve test time will insnediately be investigated and appropriate corrective action taken. II-58 Rev. 2-2/81'

2. Specific Pelief Requests a. Pelief Request Number 1 Ccmpenents: M5100, M5101 Function: Main steam isolaticn valves Class: 2 Test Requirements: Quarterly stroking Basis for Relief Request: Cycling valve during ner=al operation results in loss of main steam to turbine which causes a reactor trip. Alternate Testing: Valve will be full stroke tested during cold shutdown. Partial stroking during normal operation is not possible because partial stroking can only be performed locally at the valve. If valve was to inadvertently fail close during test, the main steam reliefs would lift. The local test station is located in the area which fills with steam froia the main steam reliefs. Entry into area is strictly controlled during operation. No remote partial stroke capability is available. b. Relief Request Number 2 Deleted c. Relief Request Number 3 Deleted l t l l t i l l l l II-59 Rev. 2-2/81 u.

d. Relief Request Nu=ber 4 Components: AT29, AT43, AT72, AF73, AT74, AT75 Function: Auxiliary feedwater check valves to the steam generators Class: 3 Test Requirements: Cuarterly forward flow stroking Basis for Relief Request: Cycling valve would require injection cf auxiliary feedwater into the steam generator which would thermal shock the auxiliary feedwater nc::les. The reason for not full stroking the check valve is that the auxiliary bciler will not provide enough stem: for the pump to spin f ast enough. Alternate Testing: Valve will be partial st.wr.e forward flow cycled during refueling when the steam generator is cold. valve cannot be partial stroked during normal operation or full stroked at any time without injecting auxiliary feedwater into the steam generator and thermal shocking the auxiliary feedwater nor:les. e. Relief Request Number 5 Components: TW601, FW612 Function: Main fetdwater isolation valve to the steca generator Class: 2 Test Requirements: Quarterly stroking l l Basis for Relief Request: Cycling valve during ncrmal l operation would cause loss of main feedwater te l steam generator which would cause reactor trip. t Alternate Testing: Valve will be full stroke tested at cold shutdown. valve design precludes partial stroke testing during normal operation. f. Relief Request Number 6 I Deleted g. Relief Request Number 7 1 Deleted i i i II-60 Rev. 2-2/81 i l

1 h. Relief Request Number 8 Components: CVil7, CVIS6, CVla7, CVl91, CV209, CV210 Function: Hydrogen dilution air to containment check valves Class: 2 and 3 Test Requirements: Quarterly forward flow stroking Basis for Relief Request: Cycling can only be performed by injecting air from the hydrogen dilution blowers into the containment. This air must be purged from the contairment to the environment. Purge time is li=ited to 90 hours per year during normal operation. Testing could cause excessive purging with resulting increase in releases to the environment. Alternate Testing: Valve will be cycled at cold shutdown. No partial stroking is possible during normal operation without-injecting air into the containment,

i. Relief Request Number 9 Components: CV5080 through cv508i Function: Contairment vacuum breaker valves Class: 2 Test Requirements: Quarterly forward flow stroking Basis for Relief Request: Forward flow cycling can only be performed by entering the annular area between the contairment and shield building and verifying freedom of valve by hand. F.ntry to this area during power operation is strictly controlled and i

limited to ent:/ only when absolutely necessary. (As per Special Order No. 84-4, Revision'4, dated January 5,1979) Alternate Testing: Valve will be verified for freedom of valve movement at -L*d shutdown. Valve design precludes partial s* ck.: y caring normal operation. II-61 Rev. 2-2/81 e, e ei

i 1

j. Relief Request Nur.ber 10 Deleted k.

Relief Request Nur.ber 11 Cc=ponents: RClO Function: Pressurirer spray centrol Class ' Test Requirements: Quarterly stroking and timing Basis for Relief Request: Failure of valve in the closed position would result in loss of reacter coolant system pressure control which is required during normal operatien. Alternate Testing: Valve will be full stroke tested during cold shutdown. Valve design precludes partial stroke testing during normal operatien. II-62 Rev. 2-2/81

1. Relief Request Nurber 12 Components: RC2A Function: Pressurizer pressure centrol valve Class: 1 Test Requirements: Quarterly stroking and timing Basis for Relief Request: Full stroking cannot be visually verified on this valve since the valve mechanism is all internal. A test can be performed by clesing the block valve and seeing if RC2A solenoid energi:es and de-energi:es properly. Stroke timing is impractical as the valve mechanism is all internal and the valve is pilot actuated. You can =easure the position of the pilot but not of the valve itself. This is not a motor cperated valve. There is no fail-safe positien of this valve. RC2A is tested in PT 5164.02, Pressurizer Power Relief Valve Periodic Test, in conjuncticn with ST 5030.04, RCS Pressure to the RPS Refueling Period Calibration Procedure, at least once per 18 months with the unit in cold shutdewn (or refueling mode). This test verifies that RC2A will cpen when its associated solenoid is energized and will close when the solenoid is de-energized. This test is nor= ally run with the RCS pressure at 2155 psig but can also be perfermed at <[2155 psig but )>500 psig in the RCS. This test also verifies that the sciencid associated with RC2A will be energized at a signal equivalent to an RCS pressure of 2400 ; 16 psig and de-energized by a signal-equivalent to an RCS pressure of 23501 16 psig. This phase is run by simulating output signals fro = the RPS to P5HL-RC2-5 in the NNI cabinets and verifying proper cperation-of the solencid at RC2A. ST 5030.04 will verify that the instn: ment strings for the RPS pressure transmitters selectable for use in the NNI >;e calibrated from the pressure transmitters to the output of the RPS cabinets. An acoustic monitor is used to verify valve opening and closing. Alternate Testing: Valve may be effectively part stroked during normal operation in response to pressurizer conditions. valve will be full stroked at refueling during performance of plant procedure PT 5164.02 which also verifies pressure set point. No valve timing is possible. II-63 Rev. 2-2/81

m. Relief Request Nu=ber 13 Compcnents: MU33 Function: Normal makeup water to the Reactor Coolant System Class: 2 Test Requirements: Quarterly stroking Basis for Relief Request: Failure of valve in the clesed position during tt.t would result in total loss of normal makeup to the Reactor Coolant System. Makeup is required during normal operation. Alternate Testing: Valve will be cycled at cold shutdown when makeup water is not required. Valve design precludes partial stroking during normal operation, n. Relief Request Number 14 Components: MC242, MU243, MU244, M"245 Function: Reactor coolant pump seal water check valve Class: 2 Test Requirements: Quarterly reverse flow stroking l Basis for Relief Request: Reverse flow cycling during ' normal operation or cold shutdown would require i stopping reacecr coolant pump seal cooling water flow. Cooling water to the reactor coolant pumps is required j ( except at refueling. This would damage reactor coolant 3 pump seals and is not permitted by plant procedure. l l Alternate Testing: Reverse flow stroking will be l cycled at refueling. Cooling water to the reactor ] coolant pumps is required except at refueling. System 3 [ . operation precludes partial stroke testing during normal operation. II-64 Rev. 2-2/81

o. Relief Request Number 15 Components: MU66A, MU663, MU660. MU66D, MC59A MC593, MU59C, MU59D, MU38 Function: Reactor coolant pump seal water isolation valve Class: 2 Test Requirements: Quarterly stroking Basis for Relief Request: Cycling valve during normal operation would stop reactor coolant pump seal cooling water flow. Cooling water to the reactor coolant pumps is required except at refueling. This would damage E reacter coolant pu=p seals and is not permitted by plant operating procedure. Alternate Testing: Valve will be cycled at refueling. Cooling water to the reactor coclant pumps is required except at refueling. Valve design precludes partial 5 stroke testing during normal operation. p. Relief Request Number 16 Compenents: DH9A, OH9B Function: Containment emergency sump isolation valve Class: 2 Test Requireme,ts: Quarterly stroking Basis for Relief Request: Cycling valve would introduce borated water from the borated water storage tank directly into the containment emergency sump. Valve is interlocked with DH7A (DH73) and can only be tested when the borated water storage tank can be isolated. Alternate Testing: Valve will be cycled at refueling when the borated water storage tank can be isolated. Valve cannot be partial stroke tested during normal operation without injecting borated water into the containment emergency su=p. II-65 Rev. 2-2/81

t q. Relief Request Number 17 Compenents: CF28, CF29 Function: Core flood tank isolation check valve Class: 1 Test Requirements: Quarterly forward flow stroking Basis for Relief Request: Forward flow cycling cannot be performed during normal cperation or cold shutdown when the Reactor Coolant System is filled and pressurized to pressure greater than that of the core flood tank. Full stroke is precluded by system design. Alternate Testing: Valve will be part stroke tested at refueling when the contents of the core flood tank can be partially. dumped into the Reacter Cociant System while monitoring core flood tank level. r. Relief Request Nu=ber 18 Ccmponents: CF30, CF31, DH76, DH77 Function: Low pressure injection check valve Class: 1 Test Requirements: Quarterly forward stroking Basis for Relief Request: Forward flow cycling can only l be performed by injecting water from the Decay Heat l System into the Reactor Coolant System. This can only l be done-at cold shutdown when Reactor Coolant System pressure is low enough to permit injection. Alternate Testing: Valve will be forward flow cycled at cold shutdown. System operation precludes partial stroke testing during normal operation when Reactor Coolant System pressure is greater than the Decay Heat l l System design pressure. ll. i l l L I 1 - II-66 r l Rev. 2-2/81 l

s. Relief Request Number 19 Components: HP48, HP49, HP50, HP51 HP56, HP57, HP58, HP59 Function: High pressure injection check valve Class: 1 Test Requirements: Quarterly ferward flow stroking Basis for Relief Request: Valve can only be cycled by high pressure injection flow. High pressure injection during nor=al operation or cold shutdown could introduce cold water into the significantly hotter Reactor Coolant System. This would thermal shock the high pressure injection no :le. Additionally high pressure injecticn during cold shutdown could subject the Reactor Coolant System to pressures higher than allowed in the cold shutdown mode. Alternate Testing: Valve will be forward flow cycled at refueling when an adequate expansion volume is l available. System operation precludes partial strcke 3 testing during normal operation. t. Relief Request Number 20 Deleted Relief Request Ncider 21 u. Components: CC1411A, CC14113, CC1407A, CCl407B Function: Component cooling water isolation valve 1 1 Class: 2 Test Requirements: Quarterly stroking Basis for Relief Request: Cycling valve during normal l operation or cold shutdown requires shutting off cooling l water to the reactor coolant pumps which would cause extensive damage to the pumps. Cooling water to the reactor coolant pumps is required except at refueling. Alternate Testing: Valve will be full stroke tested at refueling. Valve design precludes partial stroke testing during normal operation. II-67 Rev. 2-2/81

v. Relief Request Nu=ber 22 Components : 001460 Function: Component cooling water isclation valve Class: 3 Test Requirements: Quarterly stroking Basis for Relief Request: Cycling valve during ncrmal operation or cold shutdown requires shutting off cooling water to the makeup pump coolers which could cause damage to the pu=ps. Cocling water to the pumps can only be shut off during cold shutdown. Alternate Testing: Valve will be full stroke tested at cold shutdown. Valve design precludes partial stroke testing during normal operation. w. Relief Request Nu=ber 23 Components: CC1567A, CC15673 Functicn: Component cooling water isolation valve Class: 2 Test Requirements: Quarterly stroking Basis for Relief Request: Cycling valve would require shutting off cooling water to the control rod drives I which can only be done at cold shutdown. Alternate Testing: Valve will be full stroke tested at cold shutdown. Valve design precludes partial stroke testing during normal operation. II-68 Rev. 2-2/81 .. -~ _

4 x. Relief Request Nur.ber 24 Components: SW57 Function: Service water isolation check valve Class: 3 Test Requirements: Quarterly reverse flow stroking Basis for Relief Request: Reverse flow cycling requires stopping cooling water flow through the turbine plant cooling water heat exchangers which could result in extensive equipment damage. Alternate Testing: Valve will be reverse flow cycled at refueling when cooling water is not required. System operation precludes partial st_oke testing during normal operation. y. Relief Request Number 25 k Components: IA501, SA502, NN58, CV209, CV210, CV124, CV125, CF15, CF16, RCll3 ( Function: Containment isolation check valves i I Class:1 or 2 Test Requirements: Quarterly reverse flow stroking l Basis for Relief Request: Verification of reverse flow closing can only practicably be accomplished by leak testing. This testing can only be performed at refueling. l Alternate Testing: Valve will be reverse flow l closure tested at refueling during the performance of an Appendix J, Type C, test. l II-69 I Rev. 2-2/81 i

Relief Request Number 26 Components: MU2A Function: Letdown isolation valve Class: 2 Test Requirements: Quarterly stroking and timing Basis for Relief Request: If this valve were to fail in the closed position during testing, loss of normal letdown would result. Letdown is required to control reactor coolant inventory as the required reactor coolant pump seal injection continuously 'dds water to the Reactor Coolant System. Less of pressurizer j level control can cause reac'.or trip. J Alternate Testing: Exercise valve and measure stroke time during cold shutdown when access to the valve is not prohibited. l aa. Relief Request Number 27 l Components: HP2A, HP2B, HP20, HP2D runction: High pressure injection isolation valves i t Class: 2 f Test Requirements: Quarterly stroking and timing Basis for Relief Request: No pressure monitor devices are installed on the upstream side of these valves. The upstream piping is isolated from reactor coolant system pressure by two check valves. Cycling these valves daring normal operation may allow high pressure l water to be released -into the high pressure injection system. Alternate Testing: Valves will be stroked and timed at cold shutdown when the reactor coolant system is depressurized. I 1 II-70 l Rev. 2-2/81 i

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D. FII.!EF FI;i.TSTS This section provides justification for the exceptions taken to Code test requirements as provided fer in 10 CFR SC.55a f g) (5) (iti). Each Relief Request is identified by a unique number und identifies the item (s) for which the Relief Request is being taken. The specific Code test requirement found te be impractical is defined, and the basis for exclusion from Code requirerents is presented. Any testing perferred in lieu of Code requirements is specified. 1. Felief Recuest Number 1 Compenents: Reacter Coolant Pumps P36-1, P36-2, 736-3, P36-4 Function: Peactor coolant circulation Class: 1 Test Requirements: Vclumetric and surface examination of the reactor coolant pump casing welds Basis for Relief Request: The reactor coolant pu=p casing welds are too thick for examination by using present state of the art ultrasonic techniques. For a baseline these welds are radiographed. However, for inservice inspecticn the background radiation will be toc high maktng radiography i= practical. Alternate Testing: Surface examinatien only 2. Reliaf Request Number 2 Components: Control rod drive nec:le flange bolts and nuts Function: Secure control-rod drive hou~ sing to reacter vessel head Class: 1 Testing Requirement: Visually examine (VT-1) all bolts and nuts j Basis for Relief Request: _It is impractical to visually examine the eight flange bolts on each Of the 69 CPM.s from the platform of the head service structure, approximately 20 feet above the flange surface. Most of the peripheral CRDM bolts and nuts can be cbserved through the twelve inch i diameter ports in the service structure cylinder, the other CRDM bolts and nuts are not accessible for examination. i { l Alternate. Testing: Examine bolts and nuts en ten percent of peripheral CRDMs to coincide with Categt ry B-0, " Pressure Retaining Welds in CRD Housings". III-66 [ Rev. 2-2/81

3. Relief Fecuest Nuri:er 3 Cc=penents: Oecay Heat Eemoval Cocler E17-1 and E17-2 Function: Decay heat re=cval, i Class: 2 Test Require =ene.s: Volumetric ex=-*.ation of shell to flange weld 'G' Basis for Relief Request: On the flange side of the weld, the slepe of the hase material precludes ultrasenic examinatien frem this side of the weld. Alternate Testing: Volumetric examinatien frc= ene side of weld only (refer to sketch). I i i 6c.a u.- Rev.-2-2/S1

IV. SYSTEM PRESSURE TEST PROGRAM The System Pressure Test Program for all safety related systems will be conducted in accordance with Table IWB-2500-1, Table IWC-2500-1 or Table IWD-2500-1 and will meet the requirements of Subsection IWB-5000, IWC-5000 or IWD-5000, as appropriate, of the ASME Boiler and Pressure Vessel Code, 1977 Edition, and Addenda through Summer 1978 Addenda. The Systen Pressure Test Program will be applicable for the remainder of the 120-month interval, which started November 21, 1977 after whic!. the 3 Program will be reviewed and updated, as appropriate, with the Edition of the Code and Addenda in effect not more than 12 months prior to the start of the next 120-month interval. All tests shall be conducted in accordance with the Inspection Program B of Section XI. In the event that no safety or relief valve is provided within the test boundary, for tests performed under IWC-5000 or IWD-5000, the system's normal operating pressure will be used to determine the System Pressure Test and System Hydrostatic Test pressures to be used. In no case will the maximum pressure rating (with a 7 percent safety factor) of the lowest rated component be exceeded. l l l l IV. Rev. 2 - 2/81 -..}}