ML20072R411
| ML20072R411 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/09/1994 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20072R405 | List: |
| References | |
| PROC-940909, NUDOCS 9409130182 | |
| Download: ML20072R411 (169) | |
Text
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l SECTION 4.0 INSERVICE TESTING PROGRAM PLAN FOR VALVES 1
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l 940912.0182 940909 PDR ADOCK 05000454 P
Rev. 13 TABLE OF CONTENTS 4.0 Inservice Testing Program Plan for Valves i
4.1 Program Description i
4.2 Program References 4.3 Program Tables - Units 1 and 2 4.4 Notes / Cold Shutdown Justifications Note 1 Main Steam Isolation Valves Note 2 CV Emergency Boration System Flowpath Valves j
Note 3 Main Feedwater Isolation Valves Note 4 CV System Letdown and Make-up Isolatica Valves Note 5 RHR Pump Suction Isolation Valves Note 6 Intersystem LOCA Valves Note 7 Reactor Vessel Head Vent Valves Note 8 CV, RHR Pump Discharge Check Valvas Note 9 RHR ECCS Check Valves Note 10 Main Feedwater Waterhammer Prevention Valves Note 11 VQ Purge Supply and Exhaust Isolation Valves Note 12 AF Suction and Steam Generator Check Valves Note 13 CV High Head Injection Isolation Valves Note 14 SVAG Valves Note 15
" Deleted" Note 16 Main Feedwater Regulating Valves I
Note 17 Main Feedwater Regulating Bypass Valves Note 18
" Deleted" Note 19
" Deleted" (Incorporated into Note 14)
Note 20 Position Indication Testing of Solenoid Valves Note 21 Main Feedwater Tempering Flow Isolation Valves Note 22 Hydrogen Monitoring System Check Valves Note 23 Event V Check Valves
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Note 24 Pressure Relief Check Valves Note 25 SI Pump Suction Check Valve (1/2 SIB 926)
Note 26 CV Pump Suction Check Valve (1/2 CV8546)
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Note 27 RH Pump Suction Check Valves (1/2 SIB 958A/B)
Note 28 VCT Outlet Check Valve (1/2 CV8440)
Note 29 Emergency Boration Check Valve (1/2 CV8442)
Note 30 AF Check Valve Leak 9 ecks (1/2 AF014A-H) j Note 31 CV/SI Mini-Flow Recirculation Line Check Valve Full l
Flow Testing (1/2 CV8480A/B and 1/2 SI8919A/B) l Note 32
" Deleted" Note 33 SX Make-Up Pump Discharge Check Valves (OSX028A/B)
Note 34 SD Containment Isolation Valves (1/2 SD002A-H, 1/2 SD005A-D)
Note 35 RH Containment Isolation Valves (1/2 RH8705A/B)
Note 36 RY PORV's and Block Valves Note 37 Process Radiation Check Valves (1/2 PR032)
Note 38 Process Sampling Check Valves (1/2 PS231A,B) l (9997D/WPF/083094) 4.0 - page 1 of 3
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Rev. 13 4.4 (Cont.)
n Note 39 Nitrogen Supply to SI Accumulator Check Valves (1/2 SIB 968)
Note 40 Safety Injection Check Valves (1/2 SI8815, 1/2 SI8900A-D,1/2 SI8818A-D, 1/2 SIB 819A-D, i
1/2 SI8841A,B, 1/2 SI8905A-D, 1/2 SI8949A-D)
Note 41 RH Hot Leg Suction Pressure Relief Check Valves (1/2 RH8705A,B) j Note 42 Erfa*., Injection Cold Leg Pressure Isolation Valves (1/2 SIB 948A-D)
Note 43 RH Crosstie Valves (1/2RH8716A,B)
Note 44 Component Cooling Non-Essential Load Isolation Valves (1/2CC9415)
Note 45 Feedwater Tempering Flow Check Valves (1/2FWO36A-D)
Note 46 Main Feedwater Header Flow Check Valves (1/2FWO79A-D)
VC-1 Safety Injection Accumulator Discharge.MOVs i
(1/2SI88 08 A-D)
VC-2 RCP Seal Injection Inlet MOVs & Check Valves l
VC-3 Blowdown Flow Control /High Energy Line Break (HELB)
Isolation Valves VC-4 Charging and Volume Control System Letdown Isolation and Letdown Orifice Isolation Valves I
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4.5 Technical Approaches and Positions l
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VA-01 Method of Stroke Timing Valves VA-02 Method of Fall Safe Testing Valves VA-03 Method of Exercising Check Valves.
VA-04 Determining Limiting Values of Full-Stroke Times for Power-Operated Valves.
(reference stroke time 110 seconds) l l
VA-05 Justification for Exercising the U-0 CC Heat Exchanger i
and Pump Isolation Valves on a U-2 Cold Shutdown Frequency l
VA-06 Stroke Time Corrective Actions 4.6 Relief Requests l
VR-1 Appendix J Valves VR-2 Containment Spray NaOH Additive Check Valves Draft VR-2A Containment Spray NaOH Additive Check Valves VR-3 Safety Injection ECCS Check Valves l
VR-4 Containment Spray. Discharge and Ring Header Check Valves VR-5 Accumulator Discharge Check' Valves Testing Frequency l
\\R-6 SI Pump Suction Check Valve VR-7
" Deleted" (Incorporated into VR-12 and VR-17)
VR-8 Component Cooling RC Pump Thermal Barrier Valves VR-9 RC Pump Seal Injection CV Check Valves L
VR-10 Instrument Air Containment Isolation Valves i
VR-11
" Deleted" (per EG & G recommendation)
VR-12 Trending of Fast Actuating Valves (9997D/WPF/083094) 4.0 - page 2 of 3
Rev. 13 4.6 (Cont.)
VR-13 Diesel Generator Air Start Valves VR-14
" Deleted" (using ASME method instead of requesting exemption from position indication testing of solenoid operated valves)
VR-15 Safety Injection ECCS Check Valve Testing during Refueling Outage DRAFT VR-15A CV Injection Related Check Valves DRAFT VR-15B RH Suction Isolation Thermal / Pressure Relief Check valves DRAFT VR-15C SI Injection Related Check Valves DRAFT VR-15D RH/SI Hot Leg Injection Related Check Valves VR-16 Containment Sump Outlet Isolation Valve Testing During Refueling VR-17 Motor Driven Auxiliary Feedwater Pump L.O. Cooler Solenoid Valve Stroke Testing i
VR-18
" Deleted" re-organized into several relief requests VR-19 Auxiliary Feedwater Check Valves VR-20 Trending of Power-Operated Valve Stroke Times l
(reference stroke times >10 seconds)
VR-21 Draft " Withdrawn" per SER 9/14/90 VR-22
" Withdrawn" VR-23 Primary Water Supply to PRT Check Valves and Nitrogen l
Supply to PRT Check Valves
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l VR-24 Chilled Water to RCFC Coils Check Valves VR-25 Containment Spray Eductor Discharge Check Valves l
DRAFT VR-26 Fire Protection Inside Containment Isolation Valves DRAFT VR-27 Charging & Volume Control Loop Fill Check Valves I
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7 SECTION 4.1 PROGRAM DESCRIPTION
Rev. 13 PROGRAM DESCRIPTION The Inservice Testing (IST) Program for Class 1, 2,
& 3 valves meets the requirements of Subsection IWV of the ASME Section XI Code, 1983 Edition, through the Summer of 1983 Addenda. Where code requirements are determined to be impractical, specific requests for relief are written, referenced, and included with the tables. Additional valve relief requests may be necessary and these will be identified and submitted during subsequent program revisions. Byron Station received a Safety Evaluation Report (SER) on September 15, 1988 and is listed in Table 2 of NRC Generic Letter 89-04 as a plant with a reviewed IST Program and SER issued. Per NRC Generic Letter 89-04, the status of relief requests as stated in the SER is unchanged. Any modifications to Byron Station relief requests approved in the SER (VR-1 through VR-17) which are covered by one of the eleven positions discussed in NRC Generic Letter 89-04, Attachment 1, must be performed in accordance with the guidelines given in the Generic Letter.
Pre-approval is granted for all relief requests submitted which are consistent with the eleven positions given. New relief requests dealing with a position n2a covered by NRC Generic Letter 89-04, Attachment 1, must receive NRC approval prior to implementation. The table lists all code Class 1, 2,
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& 3 valves which have been assigned a specific code category as directed by Subsection IWV of Section XI.
The table is organized according to operating system and listed in valve number order using P&ID references to further categorize.
The valves subject to ISI testing are those valves which are identified in accordance with the scope of ASME Section XI, Subsection IWV-1100:
"This Subsection provides the rules and requirements for inservice testing to assess operational readiness of certain Class 1, 2, and 3 valves (and their actuating and position indicating systems) in light-water cooled nuclear power plants, which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident."
Exceptions to this scope are those valves which are exempt, but added to the program based on NRC mandates. These valves are identified in the program notes and relief requests.
After installation and prior to service, all valves identified in this program were tested as required by Subsection IWV-3100 of Section XI of the ASME Code.
These tests were conducted under conditions similar to those to be experienced during subsequent inservice tests. When a valve or its control system has been replaced or undergone maintenance that could affect its performance, it will be retested prior to its return to service, to demonstrate that all performance parameters are within acceptable limits.
(9997D/WPF/083094) 4.1 Page 1 of 2
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l Rev. 13 l
As required by NRC Generic Letter 89-04, Attachment 1, Position 5, the limiting value of full-stroke time will be based on the valve reference or average stroke time of the valve when it is known to be in good condition and operating properly. This limiting value is based on a reasonable deviation from this reference stroke time based on valve size, valve type, actuator type, system design, dual unit / dual train design, etc.
The deviation should not be so restrictive that it results
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in a valve being declared inoperable due to reasonable stroke time variations. However, the deviation used to establish the limit should be such that corrective action would be taken for a valve that may not perform its intended function. New or additional reference values may be required if:
1)
A valve has been replaced, 2)
When a reference value or set of values may have been affected by repair or routine servicing of a valve, or 3)
If it is necessary or desirable for some reason other than 1) or 2) above.
1 NRC Generic Letter 89-04, Attachment 1, Positions 1-3 discuss full stroke, alternatives to full stroke, and backflow testing of check valves, respectively. A valid full stroke test is one in which verification of maximum required accident condition flow through the valve is obtained. The minimum acceptable flow value for a specific valve is determined from Technical Specifications, UFSAR, manufacturers data, engineering calculations, etc.
An alternative to full stroke testing includes, but is not limited to, a sample disassembly and inspection program of valves grouped by similarity of design (manufacturer, size, model number, materials of construction, etc.) and j
service conditions (including valve orientation). This sample l
disassembly and inspection program will be performed during refueling outages. A backflow test verifies that the disc travels to the seat promptly on cessation or reversal of flow, for check valves which perform a safety function in the closed direction.
For category A/C l
check valves (valves that have a specified leak rate limit and are self-actuated in response to a system characteristic), the backflow test I
is satisfied by performing the leak-rate test.
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Per NRC Generic Letter 89-04, Attachment 1, Position #8, whenever valve i
data is determined to be within the Required Action Range, the valve is I
inoperable, and the Technical Specification LCO Action Statement time l
starts.
In the event a valve must be declared inoperable as a result of l
inservice testing, limitations on plant operations will be as stated in l
the Technical Specifications.
Section XI of the ASME Boiler and Pressure Vessel Code shall not be construed to supersede the requirements of the Technical Specifications.
(9997D/WPF/083094) 4.1 Page 2 of 2 l
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SECTION 4.2 PROGRAM REFERENCES
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PROGRAM REFERENCBS I
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Title 10, Code of Federal Regulations, Part 50, Domestic Licensing of Production and Utilization Facilities, particularly Section 50.55a, Codes and Standards.
2.
ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice j
Inspection of Nuclear Power Plant Components, 1983 Edition, Summer 1983 Addenda.
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ASME/ ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, including 1988 Addenda, Part 10, Inservice Testing of Valves in Light Water Reactor Power Plants.
4.
U. S. Nuclear Regulatory Commission, Generic Letter 89-04, Guidance on l
Developing Acceptable Inservice Testing Programs.
5.
Byron Station UFSAR, Section 3.9.6.2, Inservice Testing of Valves.
6.
Byron Station Technical Specification 3/4.0.5, Generic ASME Program Requirement.
7.
Byron Station Technical Staff Procedure, BVP 200-2, ISI Requirements for Valves.
NRC Safety Evaluation Reports (SER's) 8.
1 a.
09/15/88 (Initial Program Plan Review) l b.
09/14/90 (Supplemental Program Plan Review) l c.
09/14/90 (Relief Requests VR-21 and VR-22 Review)
I d.
08/16/91 (Relief Request VR-4 Review) e.
01/31/92 (Relief Requests VR-2, VR-18, VR-19, VR-20 Reveiw) f.
01/25/93 (Relief Requests VR-4 Review) 9.
Byron Station IST Valve Program Plan Responses (file: 3.11.0240) a.
Byron Letter 88-1321 (Initial Program Plan Review Response) 10.
Minutes of the Public Meeting on Generic Letter 89-04, dated October 25, 1989, Question 40 l
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(9997D/WPF/083094) 4.2 Page 1 of 1 l
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t SECTION 4.3 PROGRAM TABLES j
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Rev. 13 TABLE DESCRIPTION The following information is included in the summary tables:
A.
REVISION 1
The revision corresponds to the current revision of the program.
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PAGE The pages are numbered sequentially and show the total number of tables.
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C.
VALVE NUMBER The valve number references the unique Byron Station equipment piece number (EPN).
This specific valve number identifies the unit and system.
D.
P&ID The P&ID column references the specific P&ID number which the valves are located on.
The Unit 2 P&ID number is given directly underneath the Unit 1 P&ID number.
E.
CLASS The class refers to the ASME class assigned to the specific valve.
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VALVE CATEGORY The valve category identifies the valve category defined in subarticle IWV-2200 of ASME Section XI.
G.
VALVE SIZE The valve size lists the nominal pipe size of each valve in inches.
(9997D/WPF/083094) 4.3 Page 1 of 5
4 Rev. 13 H.
VALVE TYPE The valve type categorizes the valve as to its valve design. The following abbreviations will be used to identify specific valve types:
Gate GA Globe GL Butterfly BTF Check CK Safety Valve SV Relief Valve RV Power Operated Relief Valve PORV Diaphragm Seated D
Plug P
Angle AN I.
ACT. TYPE The actuator type identifies the valve actuator. The following abbreviations will be used to designate specific types of valve actuators:
Motor Operated M.O.
Air Operated A.O.
l Hydraulic Operated H.O.
Self Actuated S.A.
Manual M
Solenoid Operated S.O.
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NORMAL POSITION Normal position identifies the normal operating position of a specific valve. Q for open and Q for closed.
K.
STROKE DIRECT.
The stroke direction identifies the direction the valve actuator moves a specific valve stem to place the valve disc in a position to perform its designed safety function (s).
Q for open, and C for closed. This identifies the direction (s) the valve stem will move when tested.
Note: Exercising of a power operated valve will involve stroking the valve to both its open and closed position. The valve will only be timed, however, in the direction (s) designated to perform its safety function (s). Therefore, the program plan specifies only the direction (s) in which valves must be stroke timed.
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Rev. 13 L.
TEST METHOD The test method column identifies specific tests which will be performed on specific valves to fulfill the requirements of Subsection IWV of ASME Section XI.
The test and abbreviations used are as follows:
1.
(Bt) Check Valve Back Flow Test The check valve disc will be exercised to the closed position required to fulfill its safety function by verifying that the disc travels to the seat promptly on cessation or reversal of flow.
2.
(Ct) Check Valve Full Stroke Test The check valve disc will be exercised to the open position required to fulfill its safety function by verifying the maximum required accident flow through the valve or alternatives to full flow testing, per NRC Generic Letter 89-04, Attachment 1, c
Positions 1 and 2.
3.
(Ft) Fail Safe Test Valves with fail safe actuators will be tested to verify the valve operator moves the valve stem to the required fail safe position upon loss of actuating power, in accordance with IWV-3415.
This will be accomplished during the normal stroking of the valve.
Upon stroking a valve to its fail safe position, the solenoid operator is de-energized causing air to be vented which in turn allows the spring to move the valve to its fail safe position.
This condition simulates loss of actuating power (Electric and/or Air) and hence satisfies the fail safe test requirements of IWV-3415.
4.
(It) Position Indication Check Valves which are identified to require a Position Indication Test I
will be inspected in accordance with IWV-3300 of ASME Section XI.
5.
(Lt) Seat Leakace Test The seat leakage tests will meet the requirements of IWV-3420 for Category A valves. On these valves, seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their safety function.
(9997D/WPF/083094) 4.3 Page 3 of 5 1
Rev. 13 6.
(Rt) Safety Valve Setooint Check Safety valve setpoints will be verified in accordance with IWV-3510 of ASME Section XI.
j 7.
(St) Pull Stroke Test Valve exercising tests of Category A and B valves will be l
performed in accordance with IWV-3410.
The test will include full stroke testing to verify operability in the direction required to l
fulfill the required safety function.
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(Xt) Part-Stroke Test
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If only limited cperation is practical during plant operation, the 1
valves shall be part-stroke LXt) exercised during plant operation and full-stroke exercised during cold shutdowns, in accordance with IWV-3412 or INV-3522.
M.
TEST MODE Denotes the frequency and plant condition necessary to perform a given test.
The following abbreviations are used:
Normal Doeration (OP)
Tests designated "OP" will be performed once every 3 months, except in j
those modes in which the valve is not required to be operable.
l Semiannual (S)
Tests with this designation will be conducted once every 6 months, except in those modes in which the valve is not required to be operable, i
Cold Shutdown (CS1 l
Valves that cannot be operated during plant operation shall be full stroke exercised during cold shutdowns. Valve testing will commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, with completion of cold shutdown valve testing not being a prerequisite to plant startup. Valve tests which are not completed during a cold shutdown, shall be completed during subsequent cold shutdowns to meet the Code Specified Testing Frequency.
For planned shutdowns, where ample time is available, and testing all the valves identified for cold shutdown test frequency in the IST Program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
In case of frequent cold shutdowns, valve testing need not be performed more often than once during any three-month period.
(9997D/WPF/083094) 4.3 Page 4 of 5 i
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Rev. 13 Reactor Refuelina (RR)
Tests with this designation will be conducted during reactor refueling outages only.
N.
RELIEF REOUEST l
Relief requests reference a specific request for relief from code requirements. All relief requests are included in Section 4.6.
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NOTES i
Notes provide a short explanation concerning a particular IST valve.
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All notes are included in Section 4.4.
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TECHNICAL APPROACHES AND POSITIONS i
Technical approaches and. positions provide detailed discussions on a particular IST topic. All technical approaches and positions are included in Section 4.5.
Q.
REMARKS Remarks reference other information useful in determining valve testing requirements or methods.
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INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATIO98 UNITS O.1. 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P41D CLASS CATEGORY (fN )
TYPE TYPE POS! TION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2AFOO1 A M 37 3
C 6.0 CK S.A.
C O
Xt/Ct OP/CS 12 3
M-122 C
Bt RR VR-19 3
1/2AFOO10 M-3 7 3
C 6.0 CK S.A.
C O
Xt/Ct OP/CS 12 3
M-122 C
Bt RR VR-19 3
1/2 AFOO3A M 37 3
C 6.0 CK S.A.
C 0
Xt/Ct OP/CS 12 3
M.122 1/2 AFOO3B M-3 7 3
C 6.0 CK S.A.
C O
Xt/Ct OP/CS 12 3
M-122 1
1/2AFOO6A M-3 7 3
8 6.0 GA M.D.
C O
St OP 1
M-122 it RR 1/2AFOO68 M-3 7 3
8 6.0 GA M.O.
C O
St OP 1
M-122 It RR 1/2 AF013 A M-3 7 2
8 4.0 GL M.O.
O C
St OP 1
I M-122 it RR 1/2AFO13B M-3 7 2
8 40 GL M.O.
O C
St OP 1
M-122 it RR 1/2 AF013C M-3T 2
B 4.0 GL M.O.
O C
St OP 1
M-122 It RR 1/2AFO13D M-3 7 2
8 4.0 GL M.O.
O C
St OP 1
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M-122 It RR 1/2 AF013E M-3 7 2
B 4.0 GL M.O.
O C
St OP 1
M-122 it RR 1/2 AF013F M-3 7 2
8 4.0 GL M.O.
O C
St OP 1
M-122 it RR 1/2 AF013G M-3 7 2
B 4.0 GL M.O.
O C
St OP 1
M-122 it RM 1/2 APO13H M-3 7 2
5 4.0 OL M.O.
O C
5t OP 1
M-12 2 It RR 1/2 AF014 A M-37 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M-122 C
Bt CS 12.30 3
1/2 AF014B M-37 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M-122 C
Bt CS 12.30 3
1/;AF014C M-3 7 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M-122 C
Bt CS 12,30 3
1/2AF014D M-3 7 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M-122 C
Bt CS 12,30 3
1/2AF014E M-37 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M-122 C
Bt CS 12,30 3
1/2AF014F M-37 2
C 4.0 CK S.A.
C 0
Ct CS 12 3-M-122 C
Bt CS 12.30 3
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INSERVICE TESTING PROGRAM PLAN CLASS 1. 2. 3 AND AUGMENTED VALVES BYRON NUCLE AR POWER STATION UNITS 0,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBE R P&lD CLASS CATEGORY UN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2AF014G M-3 7 2
C 4.0 CK S.A.
C O
Ct CS 12 3
M 122 C
Bt CS 12,30 3
1/2 AF014H M-3 7 2
C 4.0 CK S.A.
C 0
Ct CS 12 3
M-122 C
Bt CS 12,30 3
II2 AF017 A M-3 7 3
B 6.0 GA M.O.
C O
St OP 1
M-122 it RR 1/2AF017B M.3 7 3
8 6.0 GA M.O.
C O
St OP 1
M-122 ft RR 1/2AF029A M-3 7 3
C 6.0 CK S.A.
C O
C CS 12 3
M.122 II2AF029B M-3 7 3
C 6.0 CK S. A.
C O
Ct CS 12 3
M-122 (p:\\wp\\docmntdivalves2. xis 490194) 4.3 - Page 2 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1, 2, 3 CND OUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REllEF POS.
NUMBER P&tD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2CC685 M-66-1 A 2
A 4.0 GA M.O.
O C
St CS VR-8 1
M-139-1 it RR Lt RR VR-1 112CC9412A M-66-2 3
B 12.0 GA M.O.
C O
St OP 1
M 139-2 it RR 1/2CC94128 M-66-2 3
8 12.0 GA M.O.
C O
St OP 1
M-139-2 ft RR 1/2CC9413A M-66-1 A 2
A 6.0 GA M.O.
O C
St CS VR-8 1
M-139-1 it RR Lt RR VR-1 1/2CC9414 M-66-1 A 2
A 6.0 GA M.O.
O C
St CS VR-8 1
M-139-1 It RR Lt RR VR-1 1/2CC9415 M-66-4D 3
8 16.0 GA M.O.
O C/O St CS 44 1
It RR 1/2CC9416 M-66-1 A 2
A 6.0 GA M.O.
O C
St CS VR-8 1
M-139-1 it RR Lt RR VR-1 1/2CC943 7 A M-66-1 A 2
8 3.0 GL A.O.
C C/O St/Ft OP 1,2 M-139-1 It RR 1/2CC9437B M-66-1 A 2
8 3.0 GL A.O.
O C/O St/Ft OP 1,2 M-139-1 ft RR 1/2CC9438 M 66-1 A 2
A 4.0 GA M.O.
O C
Lt RR VR-1 M-139-1 It RR St CS VR-8 1
1/2CC9458 M-66-38 3
B 16.0 GA M
O O/C St CS 6
1/2CC9459A M-66-3 A 3
8 16.0 GA M
O O/C St CS 6
1CC94598 M-66-3A 3
8 16.0 GA M
O O/C St CS 5
2CC94598 M-66-3 A 3
B 16.0 GA M
C O/C St CS 5
1/2CC9463 A M 38 3
C 12.0 CK S.A.
C O
Ct/Bt OP 32 3
C 1/2CC94638 M-66-38 3
C 12.0 CK S.A.
C O
Ct/Bt OP 32 3
C OCC9464 M-66-3B 3
C 12.0 CK S.A.
C O
Ct/8t OP 32 3
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INSERVICE TESTING PROGRQM PLAN CLOSS 1. 2,3 QND AUGMENTED VALVES BYRON NUCLEGR POWER STATION UNITS 0.1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lO CLASS CATEGORY
{tN )
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2CC9467A M-66-40 3
8 16.0 GA M
O O/C St CS 6
1CC9467B M-66-4D 3
8 16.0 GA M
O O/C St CS 5
2CC9467B M-66-40 3
8 16,0 GA M
C O/C St CS 6
1/2CC9467C M-66-38 3
8 16.0 GA M
O O/C St CS 6
1/2CC9473A M 66-38 3
8 16.0 GA M.O.
C CtO St OP 1
ft RR 1/2CC94738 M-66 35 3
8 18.0 OA M.O.
C C/O 5t OP 1
ft RR 1/2CC9486 M-66-1 A 2
AC 6.0 CK S.A.
O C
Lt/Bt RR/CS VR-1, 8 3
M-139-1 0
Ct OP 3
1/2CC9618 M-66-1 A 2
AC O.78 CK 5 A.
C C
Lt!St RR/CS VM 1, a 3
M.1391 0
Ct MR VR 8 34 3
li2CC9634 M-651 A 2
AC O.75 CK S.A.
C C
Lt/Bt RR/CS VM.1, 8 3
M-139-1 O
Ct CS VR-8 24 3
i l
f (p:\\wp\\docrrmtdivalves2. mis 490194) 4.3 - Page 4 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2CS001 A M-61 -4 2
8 14.0 GA M.O.
O C
St OP 1
M-136-4 ft RR l
1/2CSOO18 M 4 2
B 14.0 GA M.O.
O C
St OP 1
M-136-4 ft RR 1/2CS003 A M-46-1 A 2
C 10.0 CK S.A.
C O
Xt/Ct OP/RR VR4 3
M-129-1 A 1/2CS0038 M-46-1 A 2
C 10.0 CK S.A.
C O
Xt/C1 OPillR VR-4 3
M-129-1 A 1/2CSOO7A M-4 6-1 C 2
A 10.0 GA M.O.
C O/C Lt RR VR-1 M-129-1C St OP 1
it RR 1/2CSOO7B M 1 C 2
A 10.0 GA M.O.
C O/C Lt RR VR-1 M-129-1C St OP 1
It RR 1/2CS008 A M-4 6-1 C 2
AC 10.0 CK S.A.
C O
Ct/Bt RR VR-4 3
M-129-1 C C
Lt RR VR-1 3
1/2CSOO88 M 1 C 2
AC 10.0 CK S.A.
C O
Ct/Bt RR VR-4 3
M-129-1C C
Lt RR VR-1 3
1/2CS00SA M-614 2
8 16.0 GA M.O.
C O
St OP 1
M-136-4 it RR 1/2CS009B M-61 4 2
8 16.0 GA M.O.
C O
St OP 1
M-136-4 it RR 1/2CSO11 A M-46-1 A 2
C 6.0 CK S.A.
C O
Xt OP 3
M 129-1 A Ct RR VR-25 3
1/2CS011B M-46-1 A 2
C 6.0 CK S.A.
C O
Xt OP 3
M-129-1 A Ct RR VR-26 3
1/2CSO10A M-46-1 B 2
B 3.0 OA M.O.
C O/C Bt OP 1
M-12815 it RR 1/2CSO195 M-46-18 2
8 3.0 GA M.O.
C O/C 5:
M-129-18 ft RR 1/2CSO20A M-46-18 2
C 3.0 CK S.A.
C O
C1 RR VR-2 3
l M-129-1 A C
Bt OP 3
1/2CSO20B M-46 18 2
C 3.0 CK S.A.
C O
Ct RR VR-2 3
M-129-1 A C
Bt OP 3
i i
(pawp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 6 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REllEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2CV1128 M 64-4A 2
8 4.0 GA M.O.
O C
St CS 4,28 1
M-138-4 it RR 1/2CV112C M-64-4 A 2
B 4.0 GA M.O.
O C
St CS 4,28 1
M-138-4 it RR 1/2CV1120 M-64-48 2
B 8.0 GA M.O.
C O/C St CS 2
1 M-1384 ft RR 1/2CV112E M-64-48 2
B 8.0 GA M.O.
C O/C St CS 2
1 M-138-4 It RR 1/2CV128 M-64-5 2
B 2O GL A.O.
C C
St/Ft OP M-138-5 A 11 RR 1/2CV459 M-64-5 1
B 3.0 GL A.O.
O C
St/Ft CS VC-4 M-138-58 it RR 1/2CV460 M-64-5 1
B 3.0 GL A.O.
O C
St/Ft CS VC-4 M-138-5B 11 RR 1/2CV8100 M-64 2 2
A 2.0 GL M.O.
O C
St CS VR-9 1
M-138-2 it RR Lt RR VR-1 1/2CV8104 M-64-48 2
B 3.0 GL M.O.
C O
St CS 2
1 M-138-4 ft RR 1/2CV8105 M-64-38 2
8 3.0 GA M.O.
O C
St CS 4
1 M-13S-38 11 RR 1/2CV8106 M-64-3B 2
B 3.0 GA M.O.
O C
St CS 4
1 M-138-38 ft RR 1/2CVS l10 M-64-3 A 2
B 2.0 GL M.O.
O C/O St OP 1
M-138-3 ft RR 1/2CV8111 M 64-3A 2
B 2.0 GL M.O.
O C/O St OP 1
M-138-3 ft RR 1/2CV8112 M 64-2 2
A 2.0 GL M.O.
O C
St CS VR-9 1
M-138-2 it RR Lt RR VR-1 1/2CV8113 M-64-2 2
AC O.75 CK S.A.
C C
Lt/Bt RR/CS VR-1. 9 3
l M-138-2 O
Ct RR VR-9 24 3
l 1/2CV8114 M-64-3A 2
8 2.0 GL S.O.
O C/O St OP VR-12 1
M-138-3 ft RR 20 l
l 1/2CV8116 M-64-3A 2
B 2.0 GL S.O.
O C/O St OP VR-12 1
M-138-3 ft RR 20 (p:\\wp\\docmntd\\ valves 2.xis490194) 4.3 - Page 6 of 41
INSERVICE YESTING PROGRQM PLAN CLASS 1,2. 3 AND CUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY flN )
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (val -
REMARKS 1/2CV8149A M-64-5 2
8 3.0 GL A.O.
C C
St/Ft CS VC-4 M-138-58 it RR 1/2CV81498 M-64-5 2
B 3.0 GL A.O.
O C
St/Ft CS VC-4 M-138-58 it RR 1/2CV8149C M-64-5 2
8 3.0 GL A.O.
C C
St/Ft CS VC-4 M-138-5B lt RR 1/2CV8152 M-64-5 2
A 3.0 GL A O.
O C/O St CS 4
1 M-138-5 A It RR R
C5 4
2 Lt RR VR-1 1/2CV8153A M-64-2 1
B 1.0 GL A.O.
O C
St/Ft OP M-138-2 it RR 1/2CV81538 M-64-2 1
B 1.0 GL A.O.
C C
St/Ft OP M-138 2 it RR 1/2CV8160 M-64-5 2
A 3.0 GL A.O.
O C/O St CS 4
2 Lt RR VR-1 1/2CV6348 M-64-38 2
BC 2.0 CK S. A.
C C
Bt RR VR-27 3
M-138-3B 1/2CV8355 A M 1 2
8 2.0 GL M.O.
O C
St CS VC-2 M-138-1 It RR 1/2CV8355B M 1 2
8 2.0 GL M.O.
O C
St CS VC-2 M-138-1 It RR 1/2CV8355C M-64-2 2
B 2.0 GL M.O.
O C
St CS VC-2 M-138-2 It RR 1/2CV83560 M-64-2 2
8 2.0 GL M.O.
O C
51 C5 VC 2 M-138-2 it RR 1/2CV8368A M 641 2
BC 2.0 CK S A.
O C
8t CS VC-2 3
M-138-1 1/2CV8368B M-64-1 2
BC 2.0 CK S.A.
O C
Bt CS VC-2 3
M.138-1 1/2CV8368C M-64-2 2
BC 2.0 CK S.A.
O C
Bt CS VC-2 3
M-138-2 1/2CV8388D M-64-2 2
BC 2.0 CK S.A.
O C
8t CS VC-2 3
M-138-2 1/2CV8440 M-64-4 B 2
C 4.0 CK S.A.
O C
Bt CS 28 3
M-138-4B O
Ct OP 3
1/2CV8442 -
M-64-4B 2
C 2.0 CK S.A.
C O
Ct CS 2,29 3
M-138-4 (p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 7 of 41
i INSERVICE TESTING PROGRAM PLAN r
t' LASS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION I
l UNITS O.1,2 l
Revision 13 VALVE TECH.
[
VALVE
. VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REOUEST NOTES (VA)
REMARKS 1/2CV8480A M-64-3A 2
C 2.0 CK S.A.
.C O_
. Ct OP 31 3
M 138 3 C
8t OP 3~
1/2CV84808 M-64-3A --
2 C
2.0 CK S.A.
C O
Ct OP 31 3
M-138-3 C
8t OP 3
t/2CV8481A M-64-3A 2
C 4.0 CK S.A.
C O
CttXt CS/OP VR-16 3
M-138-3 A C
8t -
1/2CV84818 M-64-3A 2
.C 4.0 CK S.A.
C O
Ct/xt
. CS/OP VR-15 3
M-138-3 A C
8t OP 3
1/2CV8848 M-84-48 2
C 8.0 CK S..A.
C O
Ct
.C8
. VR 18 2, 28 3
M-138-4 1/2CV8804A M-64-48 2
8 8.0 GA M.O.
C O
St.
CS 2
1 M-138-4 ft RR l
F l
j i
i (p:\\wp\\docmntd\\velves2.xis-090194) 4.3 - Page 8 of 41
_ _ -,.. _,, = -....
INSERVICE TESTING PROGRAM PLDN CLASS 1,2. 3 CND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1,2 Revision 13 VALVE l
TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lO CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2DG5182A M-152-20 NONE B
3.0 GA S.O.
C O
St OP VR-13 (TYPICAU 1/2DG5182B M 152-20 NONE B
3.0 GA S.O.
C O
St OP VR-13 (TYPICAU 1/2DG5183A M-152-20 NONE B
3.0 GA S.O.
C O
St OP VR-13 (TYPfCAL) 1/2DG51838 M-152 20 NONE B
3.0 GA S.O.
C O
St OP VR-13 (TYPICAU 1/2DG5184A M-152-20 NONE C
3.0 CK S.A.
C O
Ct OP VR-13 3
(TYPICAU 1/2DG51848 M-162-20 NONE C
3.0 CK S. A.
C O
Ct OP VR-13 3
(TYPICAU 1/2DG6185A M-152-20 NONE C
3.0 CE S.A.
C O
Ct OP VR-13 3
(TYPICAU 1/2DG51858 M-162-20 NONE C
3.0 CK S.A.
C O
Ct OP VR-13 3
(TYPICAL)..
(php\\docmntd\\ valves 2.xisW194) 4.3. Page 9 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYRON NGCLEQR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY UN)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2DOOO3A M-bO-1B 3
C 1.5 CK S.A.
C O
Ct OP 3
M-130-1 A C
Bt OP 3
1/2000038 M-501 A 3
C 1.5 CK S.A.
C O
Ct OP 3
M.130-1 B C
Bt OP 3
II2DOOO3C M-50-1 B 3
C 1.5 CK S.A.
C O
Ct OP 3
M-130-1 A C
Bt OP 3
1/200001I5 M 50-1 A 3
C 1.5 CK S.A.
C O
Ct OP 3
M 130-1B C
Bt OP 3
(p Awp\\docmntd\\ valves 2. mis 490194) 4.3 - Page 10 of 41 I
i
INSERVICE TESTING PROGRAM PLAN CLASS 1. 2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVt-VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lO CLASS CATEGORY (IN I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2FCOO9 M-63-1 A 2
A 4.0 P
M C
C Lt RR VR-1 PASStVE 1/2FC010 M-631 A 2
A 4.0 P
M C
C Lt RR VR-1 PASSIVE 1/2FC011 M 1 B 2
A 3.0 P
M C
C Lt RR VR-1 PASSIVE M-631C 1/2FC012 M 1 B 2
A 3.0 P
M C
C Lt RR VR-1 PASSIVE M 63-1C (p:\\wp\\docmntd\\ valves 2.xis490194) 4.3 - Page 11 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 (WD AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY (INJ TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2FPO10 M 52-1 2
8 4.0 GA A.O.
O C
St OP 1
1/2FP345 M-62-1 2
BC 8
CK S.A.
C C
Bt RR VR-26 3
(p:\\wp\\docmntd\\ valves 2. mis 4901 b ",
4.3 - Page 12 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 CND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY UN.)
TYPE TYPE POSITION Dl RECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2FWOO3A M -3 6-1 C 2
B 16.0 GA H.O.
O C
St/Xt CS/OP 3
1 M-121-1 B lt RR 1/2FWOO98 M-36-1 A 2
B 16.0 GA H.O.
O C
St/Xt CS/OP 3
1 M.121-1 D lt RR 1/2FWOO9C M-3 6-1 D 2
B 16.0 GA H.O.
O C
St/Xt CS/OP 3
1 M-121-1 A It RR 1/2FWOO9D M 18 2
B 16.0 GA H.O.
O C
St/Xt CS/OP 3
1 M-121 1C lt RR 1/2FWO34 A M-3 6-1 C NONE B
2.0 GL A.O.
O C
Ft RR 21 2
M-121-1 B 1/2FWO348 M-36-1 A NONE B
2.0 GL A.O.
O C
Ft RR 21 2
M-121 1D 1/2FWO34C M I D NONE B
2.0 GL A.O.
O C
Ft RR 21 2
M-121-1 A 1/2FWO34D M 1 B NONE B
2.0 GL A.O.
O C
Ft RR 21 2
M-121 -1 C 1/2FWO35A M 1 C 2
8 3.0 GL A.O.
O C
St OP 1
1/2FWO35B M-36-1 A 2
8 3.0 GL A.O.
O C
St OP 1
1/2FWO35C M 1 D 2
8 3.0 GL A.O.
O C
St OP 1
1/2FWO350 M 1 B 2
B 3.0 GL A.O.
O C
St OP 1
1/2FWO36A M -3 6-I C 2
C 3.0 CK S.A.
O C
Bt CS 45 3
M-121 1 B 1/2FWO36B M-36-1 A 2
C 3.0 CK S.A.
O C
Bt CS 45 3
M-121-1 A 1/2FWO36C M-3 6-1 D 2
C 3.0 CK S.A.
O C
Bt CS 45 3
M-121-1 C 1/2FWO36D M-36 1 B 2
C 3.0 CK S.A.
O C
Bt CS 45 3
M-121 1C (p:\\wp\\docmntd\\ valves 2.xts-090194) 4.3 - Page 13 of 41
.na_
.m..
..u_.
..._ m.
m-..
._....m.._.... _.. ~.. m m
~ _.
.m..
.-_-m
..._..-m INSERVICE TESTING PROGRAM PLAN i
CLASS 1. 2. 3 AND AL*3MENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lO CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2FWO39 A M-36-1C 2
B 6.0 GA A.O.
O C
St CS 10 1
M 121-1B lt RR 7
Ft CS 10 2
1/2FWO398 M-36-1 A 2
B 6.0 GA A.O.
O C
St CS 10 1
1/2FWO3SC M-36-I D 2
B 6.0 GA A.O.
O C
St CS 10 1
1/2FWO390 M 1 B 2
8 6.0 GA A.O.
O C
St CS 10 1
1/2FWO43 A M 1 C 2
B 3.0 GL A.O.
C C
St CP 1
1/2FWO43B M-36-1 A 2
8 3.0 GL A.O.
C C
St OP 1
1/2FWO43C M l O 2
8 3.0 GL A.O.
C C
St OP 1
1/2FWO43D M-36-1 B 2
B 3.0 GL A.O.
C C
St OP-1 M-121-1 C lt RR Ft OP 2
1/2FWO79A M 1 C 2
C 16.0 CK S. A.
O C
Bt CS 46 3
M-121 1 B 1/2FWO798 M-36-1 A 2
C 18.0 CK 5.A.
O C
Bt C5 49 3
M 121-10 1/2FWO79C M-36-10 2
C 16.0 CK S.A-O C
8t CS 46 3
M-121-1 A 1/2FWO790 M 1 B 2
C 16.0 CK S.A.
O C
Bt CS 46 3
M 121 1C 1/2FW510 M-36-1C NONE B
16.0 AN A.O.
O C
Ft RR 16 2
M-121 1 1/2FW510A M 1 C NONE B
4.0 GA A.O.
C C
Ft RR 17 2
M 121-1 1/2FW520 M-36-1 A NONE B
16.0 AN A.O.
O C
Ft RR 16 2
M-121-1 1/2FW520A M-36-1 A NONE B
4.0 GA A.O.
C C
Ft RR 17 2
M-121-1 l
(p:\\wo\\docmntd\\ valves 2.xis-090194) 4.3 - Page 14 of 41
INSERVtCE TESTING PROGCMM PLAN CLCSS 1. 2. 3 AND CUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS 0.1. 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2FW530 M 1 D NONE B
18.0 AN A.O.
O C
Ft RR 16 2
M.121-1 1/2FW530A M 36-1D NONE B
4.0 GA A.O.
C C
Ft RR 17 2
M-121 1 1/2FW540 M 1 B NONE B
16.0 AN A.O.
O C
Ft RR 16 2
M-121 1 1/2FW540A M-36-1 B NONE 8
4.0 GA A.O.
C C
Ft RR 17 2
M-121 - 1 (pdwp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 16 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYROM WUCLECR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE
- ACT, NORMAL STROKE TEST TEST REllEF POS.
NUMBER P&lD CLASS CATEGORY (IN.I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/21A065 M-5 5-4 2
A 3.0 GL A.O.
O C
Lt RR VR-1 M-55 5 St RR VR-10 1
Ft RR VR-10 2
It RR 1/24A066 M-55-4 2
A 3.0 GL A.O.
O C/O Lt RR VR-1 M 65-6 St RR VR lO 1
Ft RR VR-10 2
it RR lt2tA091 M-5 5-4 2
AC O.75 CK S.A.
C C
Lt!Bt RR VR-1,10 3
M - 5 5-5 O
Ct RR VR-10 3
(p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 16 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1. 2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY uni TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS ti2MSOO1 A M-35-2 2
8 30.25 GA H.O.
O C
St/Xt CS/OP 1
1 M-120-2A It RR 1/2MSOO18 M 35-1 2
8 32.75 GA H.O.
O C
St/Xt CS/OP 1
.1 M-120-1 it RR 1/2MSOO1C M-3 5-2 2
8 32.75 GA H.O.
O C
St/Xt CS/OP 1
1 M-120-28 ft RR 1/2MSOO10 M-35-1 2
8 30.25 GA H.O.
O C
St/Xt CS/OP 1
1 M-120-1 It RR -
1/2MSO13A M-35-2 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-2A 10.0 1/2MSO138 M-35-1 2
C 6.0 X SV S.A.
C O/C Rt
- RR M-120-1 10.0 1/2MSO13C M-35-2 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-28 10.0 1/2MSO13D M-35-1 2
C 60X SV S.A.
C O/C Rt RR M-120-1 10.0 1/2MSO14A M-35-2
.2 C
6.0 X SV S.A.
C O/C Rt RR M-120-2 A 10.0 ti2MSO14e M-35-1 2
C 6.0 X SV 8.A.
C O/C Rt RR M 1201 10.0 1/2MSO14C M-35-2 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-2B 10.0 1/2MSO140 M 35-1 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-1 10.0 1/2MSO15A M-35-2 2
'C 6.0 X SV S.A.
C O/C Rt RR M-120-2 A 10.0 1/2MSO150 M-35-1 2
C 6.0 X SV S.A.
C O/C Rt RR M 120-1 10.0 1/2MSO15C M-3 5-2 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-28 10.0 1/2MSO15D M-35-1 2
C 6.0 X SV S.A.
C O/C Rt RR M-120-1 10.0 1/2MSOt 6A M-35-2 2
C 6.0 X SV S.A.
O O/C Rt ~
RR M-120-2 A 10.0 1/2MSO168 M 1 2
C 6.0 X SV S.A.
O O/C Rt RR M-120-1 10.0 1/2MSOl6C M-35-2 2
C 6.0 X SV S.A.
O O/C Rt RR M-120-28 10.0 1/2MSOl60 M-35-1 2
C 6.0 X SV S.A.
O O/C Rt RR M-120-1 10.0 (p3wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 17 of 41
.mm..__.
INSERVICE TESTING PROGRAM PLAN CLASS 1,13 AND QUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1. 2 Revision 13 i
VALVE TECH.
VALVE VALVE SIZE VALVE
- ACT, NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lO CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2MSO17 A M-35-2 2
C 6.0 X SV S.A.
O O/C Rt RR M-120$ 2 A 10.0 1/2MSO178 M-35-1 2
C 6.0 X SV S.A.
O O/C Rt RR M 120-1 10.0 1/2MSO17C M-3 5-2 2
C 6.0 X SV S.A.
O O/C Rt RR i
M-120-28 10.0 1/2MSO170 M-35-1 2
C 6.0 X SV S.A.
O O/C Rt RR M-120-1 10.0 1/2MSO18 A M-35-2 2
8 6.0 X PORV H.O.
C C/O St OP Vit-12 1
1/2MSO188 M-35-1 2
B 6.0 X PORV H.O.
C C/O St OP VR-12 1
7 1/2MSO18C M-35-2 2
8 6.0 X PORV H.O.
C C/O St OP VR-12 1
l 1/2MSO18D M 1 2
8 6.0 X PORV H.O.
C C/O St OP VR-12 1
+
M-1201 6.0 ft RR R
1/2MSO19A M-35-2 2
8 8.0 GA M
O C
St OP M-120-2A 1/2MSO198 M-35 1 2
B 8.0 GA M
O C
St OP M-120-1 1/2MSO19C M-35-2 2
8 8.0 GA M
O C
St OP M-120-2B 1/2MSO19D M-35-1 2
8 8.0 GA M
O C
St OP M-120-1 1/2MS101 A M-35-2 2
B 4.0 GA A.O.
C C
St OP 1
1/2MS1018 M 1 2
8 4.0 GA A.O.
C C
St OP 1
1/2MS101C M-35-1 2
8 4.0 GA A.O.
C C
St OP 1
1/2MS101D M-35-1 2
8 4.0 GA A.O.
C C
St OP 1
i (p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 18 of 41
ttcSERVICE TESVING PROGRAM PLAN CLASS 1,3,3 AND CUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lO CLASS CATEGORY ON.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/20GO57A M-4 7-2 2
A 3.0 BTF M.O.
M-150-2 ft RR OOGO59 M4 7-2 2
B 2.0 BF M.O.
C O
St OP tt RR OOGO61 M-4 7-2 2
8 2.0 BF M.O.
C O
8 2.0 BF M.O.
C 0
St OP tt RR OOGO63 M-4 7-2 2
B 2.0 BF M.O.
C O
St OP lt RR OOGO64 M47-2 2
8 2.0 BF M.O.
C O
St OP tt RR OOGO6b M-150-2 2
B 2.0 BF M.O.
C O
St OP tt RR 1/20GO79 M4 7-2 2
A 3.0 BTF M.O.
C C/O Lt RR VR-1 M-150-2 St OP 1
ft RR 1/20GO80 M47-2 2
A 3.0 BTF M.O.
C C/O Lt RR VH-1 M-150-2 St OP 1
ft RR 1/20 GO81 M-4 7-2 2
A 3.0 BTF M.O.
C C/O Lt RR VR-1 M-150-2 St OP 1
It RR 1/2OGO82 M-47-2 2
A 3.0 BTF M.O.
C C/O Lt RR VR-1 eM-150-2 St OP 1
It RM 1/200083 M472 2
A 3.0 8TF M.O.
C C/O Lt RR VR 1 M-150-2 St OP 1
ft RR 1/2OGO84 M-4 7-2 2
A 3.0 BTF M.O.
C C/O Lt RR VR-1 M-150-2 St OP 1
i tt RR 1/20GO85 M-4 7-2 2
A 3.0 BTF M.O.
C C/O Lt PR VR-1 M-150-2 St OP 1
ft RR l
(p Aw p\\docmnt d\\v alve s 2. xis- 090194 )
4.3 - Page 19 of 41 i
l l
IRSERVICE TESTING PROGRAM PLAN CLllSS 1,2,3 AND AUGMEPUED VALVES BYRON NUCLEAR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2PROO1A M-78 10 2
A 1.0 GL A.O.
O C
St OP 1
ft RR 1/2PROO1B M-78-10 2
A 1.0 GL A.O.
O C
St OP 1
It RR 1/2PROO2E M-78-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASSIVE 1/2PROO2F M-78-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASSIVE 1/2PROO2G M 78-6 2
AC 2.0 CK S.A.
C C
Lt RR VR-1 3
PASSIVE 1/2PROO2H M-78-6 2
AC 2.0 CK S.A.
C C
Lt RR VR-1 3
PASSIVE 1/2 PRO 32 M-7810 2
AC 1.0 CK S.A, C
C Lt/Bt RR/CS VR-1 37 3
PASStVE M-151 1 1/2 PRO 33A M-7 8-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASStVE 1/2 PRO 330 M-78-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASSIVE 1/2 PRO 33C M-78-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASSIVE 1/2 PRO 330 M-78-6 2
A 2.0 GL M
C C
Lt RR VR-1 PASSIVE It2 PROS 6 M-78-10 2
A 1.0 GL A.O.
O C
it RR St OP VR-12 1
1 (p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 20 of 41 1
1 i
INSERVICE TESTING PROGRAM PLAN CLASS 1. 2. 3 AND AUGMENTED ifC1VES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBEit P&lO CLASS CATEGORY tlN.I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2PS228A Lt RR VR-1 M $8-7 2
A O.5 GL S.O.
O C/O St OP VR 12 1
M4 40-6 Ft OP 2
h RR 20 1/2PS2288 Lt RR VR-1 M 68-7 2
A O.5 GL S.O.
O C/O St CP VR-12 1
A4-140-6 Ft OP 2
h RR 20 1/2PS229A Lt RR VR 1 M-68-7 2
A O.5 GL S.O.
O C/O St OP VR-12 1
M 140 6 Ft OP 2
h RR 20 1/2PS2298 Lt RR VR-1 M-68-7 2
A O.5 GL S.O.
O C/O St OP VR-12 1
M-140 6 Ft OP 2
h RR 20 1/2PS230A Lt RR VR-1 M-68-7 2
A 1.0 GL S.O.
C C/O St OP VR-12 1
M-1446 Ft OP 2
h RR 20 1/2PS2308 Lt RR VP.-1 M-68-7 2
A 1.0 GL S.O.
C C/O St OP VR 12 1
M 140-6 Ft OP 2
h RR 20 1/2PS231 A M-68-7 2
A
.75 CK E.A.
C C
Lt!9t RR/CS VR 1 35 3
M 140-4 O
Ct OP 22 3
1/2PS2318 M-64-7 2
A
.76 CK-S.A.
C C
Lt/Bt RR/CS VR-l 34 3
M 140-8 O
Ct OP 22 3
1/2PS9354 A St OP 1
M-68-1 B 2
A O.375 GL A.O.
C C
Lt RR VR-1 M-140-1 It RR Ft OP 2
l 1/2PS9354B St OP VR-12 1
M-68-18 2
A O375 GL A.O.
C C
Lt RR VR-1 M-1401 It RR Ft OP 2
(p Awp\\docmntswalves2.xis-090194) 4.3 - Page 21 of 41 i
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!NSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND CaOGMENTED VALVES BYRON NUCLEAR POWER STATION LWtTS 0.1. 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY flN1 TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (val REMARKS 1/2RC014 A M 60-18 1
B 1.0 GL S O.
C O/C St CS VR-12 7
1 M 135-1B Ft CS 7
2 h
RR 20 1/2RC0148 M 60-1B 1
8 1.0 GL S.O.
C O/C St CS VR-12 7
1 M-135-1B Ft CS 7
2 h
RR 20 1/2RC014C M 1 B 1
8 1.0 GL S.O.
C O/C St CS VR-12 7
1 M-135 1 B Ft CS 7
2 h
RR 20 1/2RCO140 M-60-18 1
8 1.0 GL S.O.
C O/C St CS V3-12 7
1 M-1351B Ft CS 7
2 h
RR 20 (p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 23 of 41
INSERVICE TESTING PROGRAM PLCJ4 CLASS 1,2. 3 CND QUGMENTED VALUES BYRON NUCLEAR POWER STATION UNITS O.1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORPAAL STROKE TEST TEST RELIEF POS.
NUMBER P&lO CLASS CATEGORY UN)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2RE1003 M 1 2
A J.O D
A.O.
C C
5t OP 1
M-141 1 Lt RR VR-1 It RR Ft OP 2
1/2RE9157 M-70-1 2
A 1.0 0
A.O.
O C
St OP VR-12 1
M-141 -1 Lt RR VR-1 ft RR Ft OP 2
1/2RE9159A M 70-1 2
A
.75 0
A.O.
O C
St OP VR-12 1
M-141 -1 Lt RR VR-1 It RR Ft OP 2
1/2RE91598 M-70-1 2
A
.75 D
A.O.
C C
St OP VR-12 1
M-141-1 Lt RR VR-1 ft RR Ft OP 2
1/2RE9160A M 1 2
A 1.0 D
A.O.
O C
St OP VR-12 1
M-141-1 Lt RR VR-1 ft RR Ft OP 2
1/2RE91600 M-701 2
A 1.0 0
A.O.
O C
St OP VR-12 1
M-141-1 Lt RR VR-1 it RR Ft OP 2
1/2RE9170 M-701 2
A 3.0 D
A.O.
O C
St OP VR-12 1
M-141 1 Lt RR VR-1 It RR Ft OP 2
{p:\\wp\\docmntd\\vatves2.xts-090194) 4.3 - Page 24 of 41
INSERVtCE TESTING PROGRAM PLAN CLASS 1. 2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&tD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2RF026 M-48-68 2
A 2.0 P
A.O.
O C
1/2RF027 M-48-6A 2
A 2.0 P
A.O.
O C
(p$wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 25 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND QUGMEN7ED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (INJ TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2RH610 M 62 2
B 3.0 GA M.O.
O C/O St OP 1,4 M-137 ft RR 1/2RH611 M 62 2
B 3.0 GA M.O.
O C/O St OP 1,4 M.137 It RR 1/2RH8701 A M-62 1
A 12.0 GA M.O.
C O/C St CS 5
1/2RH8701B M-62 1
A 12.0 GA M.O.
C O/C St CS 6
1/2RH8 702A M-62 1
A 12.0 GA M.O.
C O/C St CS 5
1/2RH8 702B M 62 1
A 12.0 GA M.O.
C O/C St CS 5
1/2RH8 705 A M-62 2
.75 CK S.A.
C C
Lt/Bt CS 6,41 3
M 137 O
Ct CS 24,35,41 3
1/2RH8 7050 M-62 2
.75 CK S.A.
C C
Lt/Bt CS 6,41 3
M-137 O
Ct CS 24,35,41 3
1/2RH8708 A M-62 2
C 3.0 X RV S.A.
C O
Rt RR M-13 7 4.0 C
1/2HH8708B M-62 2
C 3.0 X RV S.A.
C O
Rt RR M-137 4.0 C
1/2RH8716A M-62 2
B S.0 GA M.O.
O C/O St CS 43 1, 4 M-137 ft RR 1/2RH8 7168 M-62 2
8 8.0 OA M.O.
O C/O St CS 43 1, 4 M-137 ft RR 1/2RH8730A M-62 2
C 8.0 CK S.A.
C O
Ct/Xt CS/OP 8
3 M-137 C
Bt CS
?
1/2RH8 7308 M-62 2
C 8.0 CK S.A.
C O
Ct/Xt CS/OP 8
3 M-137 C
Bt CS 3
(p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 26 of 41
INSERVICE TESTING PROGRAM PLCJ4 CLASS 1,2,3 AND CUGMENTED VALVES BYROE4 NUCLEAR POWER STATION UNITS O.1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lO CLASS CATEGORY (IN 1 TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2RYO75 M-2060-6 2
A O.5 GL M
C C
Lt RR VR-1 PASSIVE M-2135-6 1/2RY455 A M-60-5 1
B 3.0 PORV A.O.
C O/C St CS 36 1
1/2RY456 M 60 5 1
8 3.0 PORV A.0, C
O/C St CS 36 1
1/2RY8000A M-60-5 1
8 3.0 GA M.O.
O C
St OP 1
M-135-5 it RR 36 1/2RY80008 M-60-5 1
B 3.0 GA M.O.
O C
St OP 1
M-135-5 it RR 36 1/2RY8010A M 60-5 1
C 6.0 SV S.A.
C O/C Rt RR M-135-5 it RR 36 1/2RY80108 M 60 5 1
C 6.0 SV S.A.
C O/C Rt RR M 13 5-5 It RR 36 1/2RY8010C M-60-5 1
C 6.0 SV S.A.
C O!C Rt PR M-135-5 li RR 36 1/2RY 8025 M-60-6 St OP 1
M-135-6 2
A
.375 GL
. A.O.
C-C Lt RR VR-1 k
1/2RY8026 M-60-6 St OP 1
M-135-6 2
A
.375 GL A.O.
O C
Lt RR VR-1 h
1/2RY8028 M 60 6 St OP 1
M-135-6 2
A
.75 D
A.O.
O C
36 Ft OP 2
1/2RY8033 M-64 6 St OP VR-12 1
M-135-6 2
A O.8 D
A.O.
O C
1/2RY8046 M-60-6 2
AC 3.0 CK S.A.
C C
Lt/Bt RR/CS -
VR-1. 23 3
PASSIVE M-135-6 3
1/2RY8047 M 60-6 2
AC O.75 CK S.A.
C
-C Lt/St RR VR-1, 23 3
PASSIVE M-135-6 3
1 (p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 27 of 41
INSERVICE TESTING PROGMM PLCJ4 CLASS 1,2, 3 AND AUGMENTED VALVES BYRON NUCLECR POWER STATION UNITS 0,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY (tN )
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2SA032 M-54-2 2
A 1.5 GA A.O.
O C
1/2SA033 M-54-2 2
A 1.5 GA A.O.
O C
Lt BR VR-1 St OP 1
I (p:\\wp\\docmrad\\ valves 2.xis-090194) 4.3 - Page 28 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,3. 3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1, 2 Rewston 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION
- DIRECT, METHOD MODE REOUEST NOTES (VA)
REMARKS 1/2SDOO2 A M-48-5 A/B 2
A 2.0 GL A.O.
O C
1/250002B M-48-5 A/B 2
A 2.0 GL A.O.
O C
1/2SDOO2C M-48-5 A/B 2
A 2.0 GL A.O.
O C
1/250002D M 48-5A/B 2
A 2.0 GL A.O.
O C
1/2SDOO2E M-48-5 A/8 2
A 2.0 GL A.O.
O C
1/2SDOO2F M-48-5 A/B 2
A 2.0 GL A.O.
O C
1/2SDOO2G M-48-5 A/B 2
A 2.0 GL A.O.
O C
1/2SDOO2H M-48-5A/B 2
A 2.0 GL A.O.
O C
(p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 29 of 41
i INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND CUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&iD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2SDOOS A M48-bA/B 2
A O.375 GL A.O.
O C
St OP 1
1/25D005B M48-5A/D 2
A O.375 GL A.O.
O C
St OP 1
1/2SDOO5C M 48-5A/B 2
A O.375 GL A.O.
O C
St OP 1
1/2SDOO50 M48-5A/B 2
A O.375 GL A.O.
O C
St OP 1
ISDO54A M48-5A 2
a 2.0 GL A.O.
O C
Ft. St CS VC-3 1/2S00548 M-48-5A 2
B 2.0 GL A.O.
O C
Ft, St CS VC-3 M-48 5B ISDO54C M-48-5A 2
B 2.0 GL A.O.
O C
Ft, St CS VC-3 1(2SDO540 M48-5A 2
.B 2.0 GL A.O.
O C
Ft. St CS VC-3 M48-5B ISDO54E M-48-5 A 2
B 2.0 GL A.O.
O C
Ft, St CS VC-3 t/25 DOS 4F M43 8A 2
0 2.0 GL A.O.
O C
Pt, 5t C5 VC,3 M-48 55 ISDO54G M-48-5A 2
B 2.0 GL A.O.
O C
Ft. St CS VC-3 1/2SDOS4H M-48-5 A 2
6 2.0 GL A.O.
O C
Ft. St CS VC-3 M48-58 r
i I
(p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 30 of 41 i
INSERVICE TESTING PROGRAM PLAN CLASS 1. 2,3 CND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS li2St8801 A M-61 2 2
B 4.0 GA M.O.
C O/C St CS 13 1
M - 136-2 ft RR 1/2S188018 M 61-2 2
B 4.0 GA M.O.
C O/C St CS 13 1
M-136-2 It RR 1/2S18802 A M-61-3 2
8 4.0 GA M.O.
C O/C St CS 14 1
M-136-3 It RR 1/2S18A028 M-61 3 2
B 4.0 GA M.O.
C O/C St CS 14 1
M-136-3 It RR 1/2S188048 M-61-1 A 2
8 8.0 GA M.O.
C O
St OP 1
M-138-1 it RR l
1/2St88Cwl M-61-1A 2
8 8.0 GA M.O.
O C
St CS 14 1
M-136-1 ft RR 1/2 SIS 807 A M-61-1 A 2
B 6.0 GA M.O.
C O
St OP 1
M-136-1 it RR 1/2SI88078 M 61 1 A 2
B 6.0 GA M.O.
C O
St OP 1
M-136-1 ft RR 1/2518808 A M-61-6 1
B 10.0 GT M.O.
O O/C St CS VC-1 1
M-136-6 11 RR 1/25488088 M-61-6 1
8 10.0 GT M.O.
M-136-5 it RR 1/2S18808C M-61 -6 1
8 10.0 GT M.D.
O O/C St CS VC-1 1
M-136-6 it RR 1/2S188080 M-61-6 1
8 10.0 GT M.O.
O O/C St CS VC-1 1
M-136-6 ft RR 1/2 SIS 809A M-614 2
8 8.0 GA M.O.
O Ort St CS 14 1
M-136-4 it RR 1/2S!8809B M-61 -4 2
8 8.0 GA M.O.
O O/C St CS 14 1
M-136-4 ft RR 1/2St8811 A M-61 -4 2
8 24.0 GA M.O.
C Ort St RR VR-16 1
M-136-4 ft RR 1/2 SIB 8118 M-61 -4 2
8 24.0 GA M.O.
C O,C St RR VR-16 1
M-136-4 it RR 1/2Si8812A M-61 4 2
B 12.0 GA M.O.
O C
St OP 1
M-136-4 It RR 1/25188128 M 61-4 2
B 12.0 GA M.O.
O C
St OP 1
M-136-4 it RR 1/2S18813 M 61-1B 2
8 2.0 GL M.O.
O C
St CS 14 1
M-136-1 It RR f p:\\wp\\docmnt d\\ valves 2.xis-090194) 4.3 - Page 31 of 41
INSERVICE TESVING PROGMM PLAN
[
CLASS 1,2,3 CJJD AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1. 2 Rewsion 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY ttN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2S18814 M-61 1 A 2
8 1.5 GL M.O.
O C
St OP 1
M-136-1 It RR 1/2S18815 M-61 -2 1
AC 3.0 CK S.A.
C O
Ct CS VR 15 3
M-136-2 C
1/2Sl8818A M-61 -4 1
AC 6.0 CK S.A.
C O
Ct/Bt CS 6.9.23,40 3
M-136-4 C
Lt RR 1/2518818B M-61 -4 1
AC 6.0 CK S.A.
C O
Ct/Bt CS 6,9,23,40 3
M-136-4 C
Lt RR 1/2Si8818C M-61 4 1
AC 6.0 CK S.A.
C O
Ct/Bt CS 8,8,23,40 3
M-136-4 C
Lt RR 1/25188180 M-61 -4 1
AC 6.0 CK S.A.
C O
Ct/Bt CS 8,S.23.40 3
r M-136-4 C
Lt RR 1/2S18819 A M-61 -3 1
AC 2.0 CK S.A.
C O
Lt/Bt RR/CS 6,23,40 3
M-136-3 C
Ct RR VR-15 3
1/2S!8819B M-61 -3 1
AC 2.0 CK S.A.
C O
Lt/Bt RR/CS 6,23,40 3
M-136-3 C
Ct RR VR-15 3
1/2Sl8819C M-61-3 1
AC 2.0 CK S.A.
C O
Lt/Bt RR/CS 6,23,40 3
M-136-3 C
Ct RR VR-16 3
1/25488190 M-61-3 1
AC 2.0 CK S.A.
C O
Lt/Bt RR/CS 6,23.4G 3
M-136-3 C
Ct RR VR-15 3
1/2S18821 A M-61-3 2
B 4.0 GA M.O.
O C/O St OP 1
M-136-3 it RR 1/2S188218 M-61 -3 2
B 4.0 GA M.O.
O C/O St OP 1
M-136-3 ft RR 1/2S18835 M-61 -3 2
B 4.0 GA M.O.
O C/O St CS 14 1
M-136-3 ft RR -
1/asise40 M-e t -3 2
8 12.0 QA M.O.
C C/O at C5 14 1
M-136-3 it RR 1/2518841 A M-81-3 1
AC 8.0 CK S.A.
C C
Lt RR M-136-3 O
Ct/Bt CS VR-15 6,40 3
1/25188418 M-61-3 1
AC 8.0 g
CK S.A.
C C
Lt RR M-136-3 l
0 Ct/Bt CS VR-15 6,40 3
(p:\\wp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 32 of 41 i
I
..m..
m-..
- -.. ~.
INSERVICE TESTING PROGRAM PLAN CLASS 1. 2. 3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS 0.1. 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2S18871 M 6 2
A
.75 GL A.O.
C C
St OP V412 1
M-136-6 Lt RR VR-1 PASSIVE tt RR Ft OP 2
1/2S18880 M-61-6 2
A 1.0 GL A.O.
C C
St OP 1
M-136-6 Lt RR VR-1 PASSIVE It RR Ft OP 2
1/2S18888 M-61 3 2
A
.75 GL A.O.
C C
St OP 1
M-136-3 Lt RR VR-1 PASStVE lt RR Ft OP 2
1/2St8900A M-61-2 1
AC 1.5 CK S.A.
C O
Ct CS VR-15 3
M.136-2 C
Lt/Bt RR/CS 6,40 3
1/2S189008 M-61-2 1
AC 1.6 CK S.A.
C O
Ct CS VR-16 3
M-136-2 C
Lt/Bt RR/CS 6,40 3
1/2S18900C M-61 2 1
AC 1.6 CK S.A.
C O
Ct CS VR-15 3
M 136-2 C
Lt/Bt RR/CS 6.40 3
1/2St89000 M-61-2 1
AC 1.6 CK S.A.
C O
Ct.
CS VR-16 3
M-136-2 C
Lt/Bt RR/CS 6.40 3
1/2S18905 A M-61 3 1
AC 2.0 CK S. A.
C O
Ct RR VR-15 3
M-136-3 C
Lt/Bt RR/CS 6,40 3
1/2518905B M-61 -3 1
AC 2.0 CK S.A.
C O
Ct PR VR-15 3
M-136-3 C
Lt/Bt RR/CS
- 6. 40 3
1/2Sl8905C M-61-3 1
AC 2.0 CK S.A.
C O
Ct RR VR-16 3
M-136-3 C
Lt/Bt RR/CS 6,40 3
1/2Si8906D M-61 3 1
AC 2.0 CK S.A.
C O
Ct RR VR-16 3
M-136-3 C
Lt/Bt RR/CS 6,40 3
1/2Sl8919A M-61-1 A 2
C 1.6 CK S.A.
C O
Ct OP 3
M-136-1 C
Bt OP 31 3
1/2S18919B M-61 1A 2
C 1.5 CK S.A.
O O
Ct OP 3
M-1361 C
Bt OP 31 3
1/2Sl8920 M-61 1A 2
B 1.5 GL M.O-O C
St OP 1
M-136-1 ft RR 1/2Sl8922A M-61-1A 2
C 4.0 CK S.A.
C O
Ct RR VR-3 3
M-136-1 C
Bt OP 3
1/2518922B M-61-1 A 2
C 4.0 CK S.A.
C O
Ct RR VR-3 3
M-136-1 C
Bt OP 3
1/2Sl8924 M-61-1 A 2
8 6.0 GA M.O.
O C/O St OP 1
M-136-1 It RR (pdwp\\docmntdivalves2.xts-090194) 4.3 - Page 33 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMEMTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&tD CLASS CATEGORY llN.)
TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2S18926 M-61 1A 2
C 8.0 CK S.A.
C O
Ct/Xt RR/OP VR-6 25 3
M-136-1 II2S18948A M 61-5 1
AC 10.0 CK S.A.
C C
M-136-5 0
Xt/Ct CS 42 3
1/2Sl8948B M 61-5 1
AC 10.0 CK S.A.
C C
M-136 5 0
Xt/Ct CS 42 3
1/2St8948C M-61-6 1
AC 10.0 CK S.A.
C C
M-136 6 0
Xt!Ct CS 42 3
1/2St89480 M-61 -6 1
AC 10.0 CK S.A.
C C
M-136-6 0
Xt/Ct CS 42 3
1/2 stb 949A M-61-3 1
AC 6.0 CK S.A.
C C
Lt/Bt RR/CS 6,40 3
M-136-3 O
Ct RR VR-15 3
1/2Sl89498 M-61 -3 1
AC 6.0 CK S.A.
C C
Lt/Bt RR/CS 6,40 3
M-136-3 O
Ct RR VR-15 3
1/2StS949C M-61-3 1
AC 6.0 CK S.A-C C
Lt/St RR/CS 6,40 3
M-136-3 O
Ct RR VR 15 3
1/2S48949D M-61-3 1
AC 6.0 CK S.A.
C C
Lt/Bt RR/CS 6,40 3
M-136-3 O
Ct RR VR-15 3
1/2Sl8956A M-61 5 1
AC 10.0 CK S.A.
C C
Lt/Bt CS VR-5 6
3 M-136-5 O
Ct RR VR-5 3
1/2Sl8956B M-61 -5 1
AC 10.0 CK S.A.
C C
Lt/Bt CS VR-5 6
3 M-136-5 O
Ct RR VR-5 3
1/2Sl8950C M-61 -6 1
AC 10.0 CK S.A.
C C
Lt/Bt CS VR-6 6
3 M-138 6 O
Ct RR VR-5 3
1/2St89560 M-61 -6 1
AC 10.0 CK S.A.
C C
Lt/Bt CS VR-5 6
3 M-136-6 O
Ct RR VR-5 3
(p:\\wp\\docmntd\\ valves 2.xis-0901941 4.3 - Page 34 of 41
INSERVICE YESTING PROGRAM PLAN CLASS 1. 2,3 AkD AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O.1. 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN.)
TYPE TYPE POSITION DIRECT. -
METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2 stb 958A M-61 -4 2
C 12.0 CK S.A.
C O
Ct CS 9
3 M-136-4 C
Bt OP 27 3
1/2S189588 M-61 -4 2
C 12,0 CK S.A.
C O
Ct CS 9
3 M-136-4 C
Bt OP 27 3
1/2S18964 M-61 6 2
A
.75 GL A.O.
C C
St OP 1
M-136-6 Lt RR VR I PASSIVE lt RR R
1/2S18968 M 616 2
AC 1.0 CK S.A.
C C
Ltet RR/CS VR 1 39 3
PASSIVE M-136-6
- i i
?
L i
(p:\\wpidocmntd\\ valves 2.xis-090194) 4.3 - Page 35 of 41 I
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WSERVICE TESTING PROGRAM P1.fN CLASS 1,2. 3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS 0,1,2 Rewsion 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN 1 TYPE TYPE POSITION DIRECT.
.AETHOO MODE REQUEST NOTES (VA)
REMARKS 1/2SXOO2A M 1 B 3
C 36.0 CK S.A.
C O
Ct CP 3
C Bt OP 3
1/2SXOO2B M-421 A 3
C 36.0 CK S.A.
C 0
Ct OP 3
C Bt GP 3
1/2SX005 M-42-1 A 3
8 30.0 BF M O.
C O
St OP 1
It RR 1
OSXOO7 M-42-2 A 3
8 24.0 BTF M.O.
C O
St OP 1
ft RR 1/2SX016A M-42-5B 2
B 16.0 BiF M.O.
O OC St OP 1
M-126-3 ft RR 1/2SXOl68 M-42-5 A 2
8 16.0 BTF M.O.
O O/C St OP 1
M-126-3 it RR 1/2SXO27 A M 42-68 2
B 16.0 BTF M.O.
O O/C St OP 1
M-12 6-3 It RR 1/2SXO2 7B M-4 2-5 A 2
8 16.0 S1F M.O.
O O/C St OP 1
M-126-3 ft RR OSXO28A M-42 6 3
C 8.0 CK S.A.
C 0
Ct OP 3
C at OP 3
OSXO288 M-42-6 3
C 8.0 CK S.A.
C O
Ct OP 3
C Bt OP 3
1/2SX101 A M-42-3 3
B 1.6 GL S.O.
C O
St OP VR-17 M-126-1 Ft OP 2
It2SX112A M -4 2-3 3
8 12.0 BTF A.O.
O C
St OP 1
1/2SX112B M-4 2-3 3
8 12.0 BTF A.O.
O C
St OP 1
1/2SX114 A M-4 2-3 3
8 12.0 BlF A.O.
O C
St OP 1
1/2SX114B M-42-3 3
8 12.0 BTF A.O.
O C
St OP 1
1/2SX116A M-42-28 3
C 3.0 CK S.A.
O O
Ct OP 3
M-42-2B 1/2SX116B M-42-2 A 3
C CK S.A.
O O
Ct OP 3
M 42-2A l
(p Awp\\docmntd\\ valves 2.mts-090194) 4.3 - Page 36 of 41
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7 7
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4 4
4 4
4 1 4 1 4
4 4
4 4
4 4
4 4
4 4
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M M
M M
M M
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M M
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3 3
6 7
2 2
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6 6
6 6
6 6
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1 I
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X X
X X
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INSERVICE TESTING PROGRAM PLAN CLASS 1,2. 3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATIOM UNITS 0.1,2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&tD CLASS CATEGORY (IN )
TYPE TYPE POSITION D! RECT, METHOD MODE REQUEST NOTES (VA)
REMARKS 1/2SX169A M423 3
B 10.0 BTF A.O.
C O
St OP 1
M 128-1 h
112SX1698 M-42-3 3
B 10.0 BIF A.O.
C O
St GP 1
1/2SX173 M42-3 3
8 6.0 GA A.O.
C O
St OP 1
M-1261 Ft OP 2
1/2SX174 M-42 3 3
C 6.0 CK S.A.
C 0
Ct OP 3
M-12 6-1 1/26X178 M 42-3 3
8 6.0 GA A.O.
C O
5t OP 1
M-128-1 Ft OP 2
(p:\\wp\\docmntdivalves2. mis-090194) 4.3 - Page 38 of 41
INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS 0,1,2 Revision 13 i
VALVE TECH.
I VALVE VALVE SIZE VALVE
- ACT, NORMAL STROKE TEST TEST REUEF POS.
NUMBER P&lD CLASS CATEGORY llN )
TYPE TYPE POSITION DIRECT.
METHOO MODE REQUEST NOTES (val REMARKS I/2VOOO1A M-105 1 2
A 48.0 BTF H.O.
C C
Lt S
VR-1 11 M-1061 St CS 11 1
PASSIVE it RR 1/2VQOO18 M-105-1 2
A 48.0 BTF H.O.
C C
Lt S
VR-1 11 M-106-1 St CS 11 1
PASSIVE It RR 1/2VQ002A M-105-1 2
A 48.0 BTF H.O.
C C
Lt S
VR-1 11 M-1061 St CS 11 1
PASSIVE It RR 1/2VQOO2B M 1051 2
A 48.0 BTF H.O.
C C
Lt S
VM-1 11 M-106-1 St CS 11 1
PASSIVE It RR 1/2VOOO3 M 1051 2
A 8.0 BIF A.O.
C C
Lt OP VR-1 11 M-106-1 St OP 1
PASSIVE It RR 1/2VQOO4A M-105-1 2
A 8.0 BTF A.O.
C C
Lt OP VR-1 11 M-106-1 St OP 1
PASSIVE It RR 1/2VOOO48 M-105-1 2
A 8.0 STF A.O.
C C
Lt OP VR.1 11 M-106-1 St OP 1
PASSIVE It RR 1/2VOOOS A M-105-1 2
A 8.0 BTF A.O.
C C
Lt OP VR 1 11 M-106-1 St OP 1
PASSIVE lt RR 1/2VQOO5B M-105-1 2
A 8.0 BIF A.O.
C C
Lt OP VR-1 11 M.106-1 St OP 1
PASSIVE lt RR 1/2VOOO5C M-105-1 2
A 8.0 BIF A.O.
C C
Lt OP
% R-1 11 M-106-1 St OP 1
PASSIVE lt RR 1/2v0016 M 105-3 2
A O.5 GL M
C C
Lt RR VR-1 PASSIVE 1/2VOO17 M-105-3 2
A O.5 GL M
C C
Lt RR VR-1 PASSIVE 1/2VQO18 M-105-3 2
A O.6 GL M
C C
Lt RR VR-1 PASSIVE i
1/2VQO19 M-105-3 2
A O.5 GL M
C C
Lt RR
- VR-1 PASSIVE l
(pdwp\\docmntd\\ valves 2.xis-090194) 4.3 - Page 39 of 41
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INSERVICE TESTING PROGRAM PLQN CLQSS 1,2. 3 AND QUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1, 2 Revision 13 VALVE TECH.
VALVE VALVE SIZE VALVE ACT.
NORMAL STROKE TEST TEST RELIEF POS.
NUMBER P&lD CLASS CATEGORY (IN I TYPE TYPE POSITION DIRECT.
METHOD MODE REQUEST NOTES (VA)
REMARKS OWOOO2A M-118-1 3
BC 3.0 CK S. A.
O O
Ct OP 3
OWOOO2B M-118-1 3
BC 3.0 CK S A.
O O
Ct OP 3
1/2WOOO6A M-118-5 2
A 10.0 GA M.O.
O C
St OP 1
M-118-7 Lt RR VR-1 It RR 1/2WOOO68 M-118-5 2
A 10.0 GA M.O.
O C
St OP 1
M.118-7 Lt RR VR-1 It RR 1/2WOOO7 A M-118-5 2
AC 10.0 CK S.A.
C C
Lt/91 RR VR-1, 24 3
PASSIVE M-118-7 1/2WOOO7B M-118 5 2
AC 10.0 CK S.A.
C C
Lt/Bt RR VR-1, 24 3
PASSIVE M 118-7 1/2 WOO 20A St OP 1
M-118-5 2
A 10.0 GA M.O.
O C
Lt RR VR-1 M-118-7 ft RR 1/2 WOO 20s St OP 1
M-118-5 2
A 10.0 GA M 0.
O C
Lt RR VR-1 M-118-7 ft RR 1/2 WOO 56 A St OP 1
M-118-5 2
A 10.0 GA M.O.
O C
Lt RR VR 1 M-118-7 ft RR 1/2 WOO 568 St OP 1
M-118-5 2
A 10.0 GA M.O.
O C
(pdwp\\docmntdivaives2. mis 490194) 4.3 - Page 41 of 41
m SECTION 4.4 NOTES I
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Rev. 13
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NOTE 1 1
Closure of the Main Steam isolation valves 1MS001A-D or 2MS001A-D during unit l
operation would result in reactor trip and safety injection actuation.
To avoid this transient, these valves will be partially stroked every three months.
Full stroke testing will be done during Modes 4, 5,
or 6 as plant conditions allow, per 1WV-3412.
NOTE 2 The testing of any emergency boration flowpath valves during unit operation is not practical.
Stroke testing the Boric Acid injection isolation valve 1CV8104 /2 CV8104 and check valve ICVB442/2CV8442, the RH to CV pump suction isolation valve 1CV8804A/2CV8804A, or the RWST to CV pump suction isolation valves 1CV112D,E/2CV112D,E, could result in boration of the RCS, resulting in l
a cooldown transient. Aligning the system in this configuration even for a l
short duration is, therefore, unacceptable. These valves will be stroked tested during cold shutdown, in accordance with INV-3412.
l NOTE 3 These valves are the Main Feedwater isolation valves:
IFWOO9A-D/2FWOO9A-D, and cannot be fully stroked during operation as feedwater would be terminated j
causing a reactor trip. They will, however, be partially stoke tested during
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operation as well as full stroke tested during cold shutdown, per the requirements of INV-3412.
i NOTE 4 Closure of these letdown and makeup valves 1CV112B,C/2CV112B,C, 1CV8105/2CV8105, 1CV8106/2CV8106, 1CV8152/2CV8152 and ICV 8160/2CV8160 during normal unit operation would cause a loss of charging flow which would result in a reactor coolant inventory transient, and possibly, a subsequent reactor trip.
These valves will be fully stroke / fail safe exercised during cold shutdown as required by IWV-3412.
NOTE 5 The 1RH8701A/B, 1RH8702A/B, 2RH8701A/B, and 2RHB702A/B valves are the isolation boundary between the Residual Heat Removal Pumps and the Reactor Coolant System.
Opening one of these valves during unit operation will leave only one valve isolating RHR from the high RCS pressure. This would place the l
plant in an undesirable condition. Therefore, these valves will be full stroke l
tested during cold shutdown, per IWV-3522.
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(9997D/WPF/083094) 4,4 page 1 of 16 l
Rev. 13 NOTE 6 The following valves have been identified as intersystem LOCA valves.
They form a pressure boundary between the RCS and other essential components in order to protect these components from damage. These valves will be leak tested in accordance with the Byron Technical specifications.
Performance of the leak test on these valves also satisfies the back-flow test required for check valves by NRC Generic Letter 89-04.
Byron Unit 1 and Unit 2 Intersystem LOCA Valves 1RH8701A/B 1RH8702A/B 2RH8701A/B 2RH8702A/B 1RH8705A/B*
ISI8815 2RH8705A/B' 2 SIB 815 ISI8818A-D ISIB905A-D 2SI8818A-D 2 SIB 905A-D ISIB819A-D ISIB948A-D 2SI8819A-D 2SI8948A-D 1SI8841A/B ISIB949A-D 2SI8841A/B 2SI8949A-D ISI8900A-D ISI8956A-D 2SI8900A-D 2 SIB 956A-D l
- Not true pressure isolation valves - not listed in Tech Specs.
NOTE 7 The Reactor Pressure Vessel Vent Valves 1RC014A-D and 2ROO14A-D cannot be stroked during unit operation, as they provide a pressure boundary between the Reactor Coolant system and containment atmosphere.
Failure of one of these valves in the open position would result in leaving only one valve as the high pressure boundary.
These valves will be full stroke / fail safe exercised when i
the RCS pressure is at a minimum during cold shutdown, per INV-3412.
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I NOTE 8 The Residual Heat Removal Pump discharge check valves 1RH8730A/B and 2RH8730A/B cannot be full stroke exercised during unit operation due to the high RCS pressure. These check valves will be partial stroke tested, however, l
on a quarterly basis and full stroke exercised during cold shutdown.
This is l
in accordance with IWV-3522 l
NOTE 9 Due to the RCS pressure, the. check valves listed below cannot be full stroke exercised during unit operation:
1 SIB 818A-D 2 SIB 818A-D RHR Cold Leg Injection l
1SI8958A/B 2SI8958A/B RWST to RHR Pump Suction These valves will be full stroke exercised during cold shutdown, in accordance with IWV-3522.
(9997D/WPF/083094) 4.4 Page 2 of 16 I
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Rev. 13 NOTE 10 i
The 1FWO39A-D and 2FWO39A-D valves cannot be stroke tested during unit operation as closure of these valves would result in termination of the l
waterhammer prevention feedwater flow. This would result in undesirable affects on the System Generators. These valves will be full stroke / fail safe tested during cold shutdown, per IWV-3412.
NOTE 11 The Primary Containment Purge Supply and Exhaust Valves IVQ001A/B, IVQOO2A/B, 2VQ001A/B, and 2VQ002A/B cannot be stroke timed during unit operation.
These 48-inch valves are the only isolation points between the containment atmosphere and the environment. Stroking these valves at any time other than mode 5 or 6 would be a violation of the Byron Technical Specifications. These valves will be full stroke tested during cold shutdown, in accordance with IWV-3412.
These valves will be leak tested semiannually, in accordance with Byron Station Technical Specifications.
The Primary Containment Mini-Purge and Exhaust Valves IVQOO4A/B, IVQ005A/B/C, 2VQ004A/B, and 2VQ005A/B/C, and the Post LOCA Purge Exhaust Valves IVQ003/2VQ003 will be leak tested every 3 months, in accordance with Byron Station Technical Specifications.
NOTE 12 The Auxiliary Feedwater check valves 1AF001A/B, 1AF003A/B, 1AF014A-H, 1AF029A/B, 2AF001A/B, 2AF003A/B, 2AF014A-H, and 2AF029A/B cannot be full stroke tested during unit operation, as this would induce potentially damaging thermal stresses in the upper feedwater nozzle piping. The 1AF001A/B, 1AF003A/B, and 2AF003A/B valves will be partially stroke tested during operation, and all valves full stroke tested during cold shutdown. This will be performed per Tech Spec 4.7.1.2.2 and is in accordance with 1WV-3522.
NOTE 13 The High Head Injection Isolation Valves 1SIBB01A/B and 2SI8801A/B cannot be stroke tested during unit operation. These valves isolate the CV system from the RCS.
Opening them during operation would enable charging flow to pass directly into the RCS, bypassing the regenerative heat exchanger. The temperature difference of the charging flow and the RCS could result in damaging thermal stresses to the cold leg nozzles as well as cause a reactivity change which would, in turn, cause a plant transient. These valves will be full stroke tested during cold shutdown in accordance with IWV-3412.
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Rev. 13 NOTE 14 The safety injection system SVAG (Spurious Valve Actuation Group) valves ISI8802A/B, 1 SIB 806, ISI8809A/B, ISIB813, 1SI8835, ISI8840, 2SI8802A/B, 1
2SI8806, 2SI8809A/B, 2SI8813, 2SI8835, and 2SI8840 cannot be stroke tested l
during unit operation.
These valves are required by the Technical Specifications to be de-energized in their proper positions during unit operation. Stroking them would be a violation of the Technical Specifications as well as defeating the de-energized SVAG valve principle.
These valves will J
be stroke tested during cold shutdown when they are not required to be de-i energized. This is in accordance with INV-3412.
NOTE 15
" DELETED" NOTE 16 These feedwater valves are exempt from all ASME Section XI testing requirements per IWV-1100 and 1WV-1200.
They are included in the program for operability tracking purposes only. The closure of the Main Feedwater j
Regulating Valves IFW510, IFW520, 1FW530, 1FW540, 2FW510, 2FW520, 2FW530, and 2FW540 during unit operation would cause a loss of feedwater to the steam generators, resulting in a plant transient with a possible reactor trip as a result. These valves will be fail safe (Ft) tested pursuant to the Byron Station Technical Specifications.
NOTE 17 These feedwater valves are exempt from all ASME Section XI testing requirements per INV-1100 and IWV-1200.
They are included in the program for operability tracking purposes only. The closure of the Main Feedwater i
Regulating Bypass Valves 1FW510A, 1FW520A, 1FW530A, 1FW540A, 2FW510A, 2FW520A, 2FW530A, and 2FW540A during unit operation would require the Main Feedwater Regulating Valves to correct for bypassed flow and could result in a plant transient with a possible reactor trip as a result. These valves will be fail safe (Ft) tested pursuant to the Byron Station Technical Specifications.
i NOTE 18
" DELETED" l
NOTE 19
" DELETED" (Incorporated into NOTE 14) l (9997D/WPF/083094) 4.4 Page 4 of 16 I
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Rev. 13 NOTE 20 The remote position indicator for these valves cannot be observed directly due to the encapsulated design of the solenoid valve body. During the indication test, indirect evidence of the necessary valve disk movement shall be used, in accordance with IWV-3412 (b).
These valves affected are listed below:
1CV8114 1PS230A/B 2PS228A/B 1CV8116 1RC014A-D 2PS229A/B 1PS228A/B 2CV8114 2PS230A/B 1PS229A/B 2CV8116 2RC014A-D NOTE 21 The Main Feedwater Tempering Flow Isolation Valves 1/2FWO34A-D are exempt from all ASME Section XI testing requirements per INV-1100 and IWV1200. They are included in the program for operability tracking purposes only, and will be fail safe (Ft) tested pursuant to the Byron Station Technical Specifications.
i NOTE 22 Per NRC request, the post-accident hydrogen monitoring system check valves 1/2PS231A and 1/2PS231B will be stroke exercised open on a quarterly frequency to verify operability.
NOTE 23 1
1/2SI8818A-D, 1/2SI8819A-D, and 1/2SI8948A/B are Event V check valves, which are defined as two check valves in series at a low pressure /RCS interface whose failure may result in a LOCA that bypasses containment.
They are individually leak-tested in accordance with NRC generic letter 89-04, position
- 4b.
NOTE 24 1/2CC9518, 1/2CC9534, 1/2CV8113, and 1/2RH8705A/B are check valves designed to relieve pressure between two containment isolation valves.
The full flow limiting value is zero, since the safety function of these valves in the open direction is to relieve pressure only.
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l Rev. 13 NOTE 25 Check valve 1/2SI8926 prevents flow from the Safety Injection (SI) pump suction line to the Refueling Water Storage Tank (RWST).
The SI pumps are normally lined up in the INJECTION MODE to take suction from the RWST.
This check valve would stop reverse flow when the SI pumps are transferred to HOT / COLD LEG RECIRCULATION MODE to prevent contamination of the RWST.
However, the 1/2SI8806 M.O.V. is in series with this check valve and would be closed to prevent reverse flow as directed by the emergency procedures.
Therefore, no backflow test (Bt) is required for 1/2SI8926.
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NOTE 26 Check valve 1/2CV8546 prevents flow from the Chemical and Volume Control (CV) pump suction line to the Refueling Water Storage Tank (RWST).
The CV pumps are normally lined up in the INJECTION MODE to take suction from the RWST.
This check valve would stop reverse flow when the CV pumps are transferred to HOT / COLD LEG INJECTION MODE to prevent contamination of the RWST.
- However, the 1/2CV112D and 1/2CV112E M.O.V.'s are in series with this check valve and would be closed to prevent reverse flow as directed by the emergency procedures. Therefore, no back flow test (Bt) is required for 1/2CV8546.
NOTE 27 Check valves 1/2SI8958A/B prevent flow from the Residual Heat (RH) Removal pump suction line to the Refueling Water Storage Tank (RWST),
The RH pumps I
are normally lined up in the INJECTION MODE to take suction from the RWST.
l These check valves would stop reverse flow when the RH pumps are transferred to HOT / COLD LEG RECIRCULATION MODE to prevent contamination of the RWST.
The 1/2SI8812A/B M.O.V.'s are in series with these check valves and would be closed to prevent reverse flow as directed by the emergency procedures.
In addition, the RH suction valves 1/2 SIB 812A/B, 1/2RH8701A/B or 1/2RH8702A/B, and 1/2 SIB 811A/B are electrically interlocked to prevent the backflow to the RWST when the RH system is in a RECIRCULATION MODE.
However, during the injection n. ode, if a pump fails to start, these values are relied upon to prevent diversionary flow back to the RWST.
NOTE 28 The 1/2CV8440 check valves allow seal water return to the suction of the CV pumps.
During the hot leg recirculation phase of an SI, the VCT outlet check valve prevents diversionary flow back to the VCT via the seal water heat exchanger relief valve, which could potentially lead to an unfiltered release of radioactivity to the environment. These valves can only be tested in cold shutdown, when all 4 RCPS and charging pumps are off.
Refer to CHRON
- 0117821, dated November 23, 1992.
l (9997D/WPF/083094) 4.4 Page 6 of 16
Rev. 13 NOTE 29 Check valve 1/2CV8442 prevents flow from the Chemical and Volume Control (CV) pump suction header to the boric acid transfer pump. This line is normally isolated by the 1/2CV8104 emergency boration valve. This valve would only be opened during an emergency with the boric acid transfer pump running. This check valve is unnecessary with the current system operation, and thus, no back flow testing of 1/2CV8442 is required.
NME30 Check valves 1/2AF014A-H are verified to be closed each shift by the Operating Department, by verifying that the temperature at 1/2AF005A-H is s 130*F, per BOP 199-A40 (U-1) and BOP 199-A61 (U-2).
If the temperature is > 130*F at any 1/2AF005 valve, then abnormal operating procedure 1/2 BOA SEC-7, " Auxiliary Feedwater Check Valve Leakage", is entered to isolate and cool down the affected lines. This shiftly monitoring of 1/2AF014A-H in the closed position adequately monitors the status of these valves during unit operation.
However, at the NRC's request, the official IST back flow test will be
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performed following the full flow test during cold shutdowns.
NOTE 31 Check valves 1/2CV8480A/B and 1/2 SIB 919A/B are the Centrifugal Charging Pump and Safety Injection Pump mini-flow recirculation line valves which open to prevent full recirculation flow during IST Surveillances.
Since full stroke for these valves will depend on the reference point of testing, acceptable full stroke will be verified whenever the recorded mini-recirculation flowrate is within the " acceptable" or " alert" ranges given in the IST Pump Surveillance.
NOTE 32
" Deleted" NME 3 3 The Essential Service Water (SX) and Make-Up Pump discharge check valves j
(OSX028A/B) open to permit make-up water flow from the Rock River to the SX System Basin. These check valves are downstream at the pump discharge tap-off to the SX Make-Up Jacket Water Heat Exchanger and Gear Oil Cooler.
Since this tap-off line is orificed, the flowrate through this line, and therefore the flowrate through pump discharge check valves OSX028A/B, will depend on the reference point of testing. Acceptable OSX028A/B full stroke will be verified whenever the recorded total pump flow minus the tap-off line flow is within
" Acceptable" range contained in the ASME pump surveillance.
(9997D/WPF/083094) 4.4 Page 7 of 16
Rev. 13 NOTE 34 Per Byron Technical Specifications Amendment valves 1/2SD002A-H, 1/2SD005A-D have been removed from the list of valves to be tested under 10CFR50 Appendix J and will now be tested per ASME Code Section XI, IWV-3420.
NOTE 35 The 1/2RH8705A/B check valves will operability tested by verifying that there is depressurization in line 1/2RH26AA-3/4 and 1/2RH26AB-3/4 when they are opened. This is a test method which was approvel oy the NRC in SER 09/14/90.
NOTE 36 PORV's 1/2RY455A and 1/2RY456 will be stroke tested on a cold shutdown frequency and valves 1/2RY8025, 1/2RY8026, 1/2RY8028, 1/2RY8010A, 1/2RY80108, 1/2RY8010C, 1/2RY8033, 1/2RY8000A, 1/2RY8000B, 1/2RY455A and 1/2RY456 will receive position indication tests on a refuel frequency per Generic Letter 90-06.
NOTE 37 l
l The Process Radiation Containment Isolation check valves 1PR032 and 2PR032 cannot be back flow tested during unit operation due to their location.
The test method used to backflow test these valves requires containment entry.
These valves will be backflow tested during cold shutdown.
NOTE 38 The Process Sampling Hydrogen Monitor Containment Isolation check valves l
1PS231A, B and 2PS231A, B cannot be back flow tested during unit operation due to their location. The test method used to backflow test these valves requires containment entry. These valves will be backflow tested during cold shutdown.
NOTE 39 The Nitrogen Supply to the SI Accumulator Containment Isolation check valves 1SI8968 and 2 SIB 968 cannot be backflow tested during unit operation due to their location.
The test method used to backflow test these valves requires containment entry.
These valves will be backflow tested during cold shutdown.
(9997D/WPF/083094) 4.4 Page 8 of 16
Rev. 13 NOTE 40 The following valves are backflow tested by way of a seat leakage test.
These j
valves are inside containment and cannot be tested without entering containment. Since it is not radiologically prudent to make containment entries for routine testing, these valves will be backflow tested during cold shutdown.
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1/2 SIB 815 1/2SI8900A-D 1/2 SIB 818A-D 1/2SI8905A-D 1/2SI8819A-D 1/2SI8949A-D 1/2SI8841A,B NOTE 41 The RH Hot Leg Suction Pressure Relief Check Valves (1/2RH8705A,B) are full stroke and backflow tested using a method which requires containment entry.
Since it is not radiologically prudent to make containment entries for routine testing, these valves will be full stroke and backflow tested during cold shutdown.
NOTE 42 The 1/2SI8948A-D Safety Injection Cold Leg Pressure Isolation Valves cannot be tested during plant operation due to the high pressure of the RCS system relative to the pressures attainable through the RH and SI pumps. They will be full flow and backflow tested at cold shutdown.
i NOTE 43 i
The 1/2RH8716A/B "RHR Cross Tie" valves are out-of-service open per Technical Specifications and can only be exercised during cold shutdown or refuel.
NOTE 44 l
The 1/2CC9415 valves are motor-operated 16" Gate valves and are in the supply line to the RCPs and other non-essential Component Cooling Water loads. They close to isolate non-essential loads from essential loads during accident conditions. These valves may only be closed with all 4 RCPs off.
Therefore, i
l these valves will be tested at Cold Shutdown with all 4 RCPs off.
Refer to VR-8 for additional information.
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Rev. 13 l'
NOTE 45 t
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The feedwater tempering flow check valves (1/2 FWO36A-D) are open during full /high power operation to ensure the S/G upper nozzle subcooled margin is maintained above the 75*F minimum. They also open to allow tempering flow during shutdown and startup.
They close to provide an immediate isolation function during a feedwater line break accident to mitigate a loss of i
secondary make-up and/or inventory.
These are 3 inch swing type check valves with no position indication.
Flow through this line at full /high power cannot be stopped for longer than one minute while in Mode 1.
Also, flow / pressure is always toward the Steam Generators (S/Gs) during operation, making it impractical to perform a back leakage or back pressure test to prove valve closure. Theses check valves will be tested during cold shutdowns using non-intrusive techniques to prove valve closure.
NOTE 46 These valves (1/2 FWO79A-D) are the main feedwater header flow check valves.
They open to allow main feedwater flow during power operation. They close to provide an immediate (2 to 3 second) isolation function during a feedwater line break accident to mitigate a loss of secondary make-up and/or inventory.
~ The safety function in the close position is to provide pressure integrity of the piping between the safety related portion and the non-safety related portion. They are 16 inch tilting disc type check valves utilizing a piston and rod assembly as an anti-slam mechanism.
These check valves have no external position indicators to provide disc position. Also, flow / pressure is always toward the Steam Generators (S/Gs) during normal operation, making it impractical and unsafe to perform a back leakage or back pressure test to prove valve closure on a quarterly basis. The main feedwater flow check r
I valves cannot be stroked closed during power operation without causing a reactor trip due to low S/G level.
These check valves will be tested during cold shutdowns when bonnet temperature is less than 100* F using ultrasonic techniques to prove closure.
Closure is determined by the piston rod height as measured using an ultrasonic straight beam technique, similar to that used for measuring the height of l
sediment in a pipe. A transducer is placed on the piston cylinder and the l
backwall is brought up (range / depth and amplitude) on the scope above the l
piston. As the transducer is lowered, the backv ll signal will decrease, while the top of the piston rod signal starts to appear.
This transition zone is used to give the disc position, since the piston rod is connected to the i
disc.
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Rey, 13 i
COLD SHUTDOWN JUSTIFICATION NUMBER VC-1 COMPONENT IDENTIFICATION (Safety Injection Accumulator Discharge Motor Operated Valves).
Motor Operated Valves IWV-2200 CODE DRAWING DRAWING VALVE NUMBER CATEGORY CLASS NUMBER COORDINATE 1(2) SIB 808A B
1 M 61(136) -5 C6 (C3) 1(2)SI8808B B
1 M 61(136)-5 C4 (C6) 1(2)SI8808C B
1 M 61(136)-6 C7 (D2) 1(2)SI8808D B
1 M 61(136)-6 C5 (D4)
FUNCTION (S):
The SI8808 valves are Motor Operated Safety Injection Accumulator Discharge Isolation Valves.
These valves are OPEN with Power Removed for Modes 1, 2,
and 3 with Pressurizer Pressure above 1000 psig. These valves were included in the IST Program for their need to be closed after all of the water in the Accumulator has been injected into the RCS.
Closure of these valves would prevent injection of a Nitrogen bubble into the RCS.
These valves were included in the IST Program for testing in Both OPEN and CLOSED directions.
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JUSTIFICATION:
I Technical Specification 3/4.5.1.a requires "The (Accumulator) isolation valve open and power removed." while in Modes 1, 2 or 3 (with pressurizer pressure above 1000 psig).
Since the Technical Specifications require these valves to be OPEN with power to their motor operators removed during periods when pressurizer pressure is above 1000 psig, the valves cannot be exercised every three months.
In lieu of stroke time testing the valves every three months, these valves will be tested during heatup or cooldown (the pressure transition between 800 and 1000 l
psig pressurizer pressure) or, they will be tested with the RCS depressurized and the associated accumulator vented and drained.
(9997D/WPF/083094) 4.4 Page 11 of 16 i
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Rev. 13 COLD SHUTDOWN JUSTIFICATION NUMBER VC-2 COMPONENT IDENTIFICATION (RCP Seal Injection Inlet Motor Operated Valves and Check Valves).
Motor Operated Valves IWV-2200 CODE DRAWING DRAWING VALVE NUMBER CATEGORY CLASS NUMBER COORDINATG 1 (2) CV8355A B
2 M 64(138)-1 B8 (BB) 1 (2) CV8355B B
2 M 64 (138)-1 B4 (B4) 1 (2) CV8355C B
2 M 64 (138)-2 B8 (B8) 1 (2) CV8355D B
2 M 64 (138)-2 B5 (BS) i Check Valves IWV-2200 CODE DRAWING DRAWING l
VALVE NUMBER CATEGORY CLASS NUMBER COORDINATE 1 (2) CV8368A BC 2
M 64 (138)-1 B7 (B7) 1(2)CV8368B BC 2
M 64 (138)-1 C4-(C4) 1 (2 ) CV8368C BC 2
M 64 (138)-2 B8 (B8) i 1 (2) CV8368D BC 2
M 64 (138) -2 BS (B5)
FUNCTION (S)-
The CV8355 valves are Motor Operated Isolation valves in the seal injection line to the Reactor Coolant Pumps. Additionally, the CV8355s are designated t
l Containment Isolation valves but are exempt from Local Leak Rate Testing of 10 CFR 50, Appendix J.
The CV8355s have no automatic closure function as part of Containment Isolation.
l The CV8368 valves are Check Valves in the seal injection line to the Reactor i
Coolant Pumps. Additionally, the CV8368s are designated Containment Isolation valves but are exempt from Local Leak Rate Testing of 10 CFR 50, Appendix J.
I JUSTIFICATION:
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Reactor Coolant Pumps (RCPs) are required to be in operation in Mode 1, Power Operation.
Seal injection flow must be maintained when the RCPs are running.
Seal injection flow stoppage with the RCPs in operation, even for short duration, is detrimental to the RCP seals. The above listed valves are Seal Injection Inlet valves and are designated Containment Isolation valves (CIVs).
i (9997D/WPF/083094) 4.4 Page 12 of 16 i
Rev. 13 COLD SHUTDOWN JUSTIFICATION NUMBER VC-2 (continued)
These valves are exempt from Local Leakage Rate testing of 10 CFR 50, Appendix J, but due to their designation as CIVs, they will be tested per ASME Code in the Closed direction. Due to the above, these valves will not be exercised during plant operation, but they will be exercised during Cold Shutdown WHEN THE RCPs ARE NOT RUNNING. Short duration forced outages to Cold Shutdown seldom require shutdown of RCDa as they are part of the normal heat removal loop.
It is NOT the intent of this justification to require RCP shutdown only to perform the exercise tests for these valves.
It is anticipated that these valves may not normally be tested more often that once per refueling outage. However, these valves will be tested during cold shutdowns in which the RCPs are secured for sufficient time to perform the tests.
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(9997D/WPF/083094) 4.4 Page 13 of 16 l
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Rev. 13 COLD SHUTDOWN JUSTIFICATION NUMBER VC-3 COMPONENT IDENTIFICATION (Blowdown Flow Control / High Energy Line Break (HELB] Isolation Valves).
Air Operated Valves IWV-2200 CODE DRAWING DRAWING VALVE NUMBER CATEGORY CLASS NUMBER COORDINATE I
1SD054A B
2 M 48-5A D8 1 (2) SD054B B
2 M 48-5A(5B)
D7 (D8) i 1SD054C B
2 M 48-5A D6 1 (2) SD054D B
2 M 48-5A(SB)
D6 (D6) 1SD054E B
2 M 48-5A DS 1(2)SD054F B
2 M 48-5A(5B)
D4 (D4)
ISD054G B
2 M 48-5A D3 1 (2 ) SD054H B
2 M 48-5A(5B)
D2 (D2)
FUNCTION (S):
The SD054 valves are normal Steam Generator Blowdown throttle control valves.
An additional function of the Unit 1, (A through H valves) and the Unit 2, (B
l train valves (B, D,
F, & H]) is to isolate Blowdown for High Energy Line Break.
i JUSTIFICATION:
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It is impractical to exercise and stroke time the above listed valves on a quarterly basis. The valves have no Open / Closed handswitch.
They are normally operated by means of a potentiometer which ultimately controls an l
air signal to a positioner. Attainment of repeatable stroke time results f
requires the valves to be stroked by causing (or simulating) HELB relay l
actuation. This method of closure causes multiple valve actuations resulting l
in complete steam generator blowdown isolation.
Furthermore, the remote l
position indicator, (a 0-100% indicator - not based on limit switch l
operation) may lag actual valve position. Therefore the only repeatable i
method of stroke timing these valves involves stationing personnel locally at the valve (s) to witness actual valve movement.
Full stroke exercising the valves is a Unit operation concern in that closure of these valves during normal operation presents a thermal transient to the downstream piping and components including the blowdown condenser. While the valves, piping, and components are designed to withstand this thermal transient, each transient produces stress which may lead to premature failure of the affected components.
It is prudent to minimize the number of thermal l
transients that these high energy lines are required to undergo.
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(9997D/WPF/083094) 4.4 Page 14 of 16
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Rev. 13 I
i COLD SHUTDOWN JUSTIFICATION NUMBER I
VC-3 (continued)
Personnel safety concerns exist with this stroking exercise during normal operation in that the valves are physically located in the Main Steam l
Isolation (MSIV) Valve House. This room contains the MSIVs, Feedwater Isolation Valves (FWIVs), Main Steam Safety Valves, Main Steam PORVs, and other miscellaneous piping and valves. The normal ambient temperature in this I
room with the Unit at power is greater than 110 'F.
Almost all of the piping (most of which is insulated) and instrument tubing in the room are normally at temperatures of approximately 500 'F or more. The SD054 valves are located I
above the floor some 16 to 20 feet and are not visible from the floor being l
obscured by Main Steam and Feedwater Piping.
Since personnel must be stationed locally at the valve to witness actual valve movement, it is l
necessary to climb around very hot piping in a hot and very noisy ambient atmosphere.
In some cases it may be necessary to erect scaffolding to conduct this test with the Unit in normal operation.
Due to the above, these valves will be tested in Cold Shutdowns of sufficient duration to allow safe access to the valves, including the erection of scaffolding if required.
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(9997D/WPF/083094) 4.4 Page 15 of 16
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l Rev. 13 COLD SHUTDOWN JUSTIFICATION NUMBER VC-4 COMPONENT IDENTIFICATION (Charging and Volume Control system Letdown Isolation and Letdown Orifice Isolation valves).
l Air Operated valves IWV-2200 CODE DRAWING DRAWING VALVE NUMBER CATEGORY CLASS NUMBER COORDINATE 1 (2 ) CV4 59 B
1 M 64-5 (138-5B)
E7 (F5) 1 (2 ) CV460 B
1 M 64-5(138-5B)
F8 (F7) 1 (2 ) CV8149A B
2 M 64-5 (138-5B)
F6 (E2) 1(2 ) CV814 9B B
2 M 64-5(138-5B)
F6 (E3) 1(2 ) CV814 9C B
2 M 64-5 (138-5B)
F5 (F2)
FUNCTION (S)-
CV459 & 460 valves are normally OPEN with the Unit at power, allowing letdown flow to occur. The valves auto close on low Pressurizer level and on letdown isolation due to an interlock with the orifice isolation valves.
CV8149 Orifice Isolation Valves are interlocked with CV459/460 to Close on Phase A Containment Isolation signal. One or more of these valves are normally OPEN to maintain letdown flow.
JUSTIFICATION:
(
It is impractical to exercise and stroke time the above listed valves on a l
quarterly basis. Due to the interlocks between the 459, 460, & the 8149 l
valves, excercising these valves during normal operation results in (multiple) l total letdown flow isolation events. The affect of a letdown isolation with the Unit at power is a thermal transient to the letdown lines, heat exchangers, and other components. A letdown isolation also results in some i
j amount of pressurizer level fluctuation until equilibrium letdown and makeup is re-established. While the piping and components are designed for thermal transients, each cycle presents some additional stress to all of the affected equipment.
It is prudent to minimize the number of transients the equipment is required to undergo to prevent premature failures.
Due to the above, these valves will be tested in Cold Shutdowns of sufficient duration.
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1 SECTION 4.5 TECHNICAL APPROACHES AND POSITIONS
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Rev. 13 VA-01 l
IST Technical Approach and Position A.
Comoonent Identification:
1.
==
Description:==
Method of Stroke Timing Valves - Timing using control board position indication lights (St).
2.
Component Numbers: See IST Valve Tables.
)
3.
References:
ASME Code,Section XI, Subsection IWV, paragraph IWV-3413 (a).
4.
Code Class:
1, 2,
and 3.
5.
Examination Category (s): N/A.
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6.
Item Number (s): N/A.
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B.
Recuirement:
Use of the control board open and closed lights to determine the stroke time of power-operated valves has recently become an issue for discussion in the industry.
Paragraph IWV-3413 of ASME XI defines
" full-stroke time" as "that time interval from initiation of the actuating signal to the end of the actuating cycle."
It is common l
industry practice to measure stroke time as the time interval between placing the operator switch on the control board in the "close" or 00 '" position and indication that the valve is open or closed on the t'nc;ol board (switch to light).
1 C.
Position:
It is required that the way in which the limit switch that operates the remote position indicator lights is set may result in " closed" or "open" indication before the valve obturator has actually completed its travel.
this is not considere:d to be a problem, as the purpose of the test is to determine if degradr. tion of the valve operator system is occurring, t
which is determined by observing changes in stroke time relative to the reference stroke time. Stroke time measurements should be rounded to the nearest tenth (0.1) of a second, except that stroke times less than one half (0.5) second may be rounded to 0.5 second, if appropriate.
l Standard rounding techniques are to be used when rounding stop watch
{
readings during valve stroke time testing (e.g.,
10.45 rounds to 10.5 j
and 10.44 rounds to 10.4).
Rounding to the nearest second for stroke times of 10 seconds of less, for 10% of the specified limiting stroke time for stroke times longer than 10 seconds, as allowed by ASME Section XI subparagraph IWV-3413(b), should not be used.
4.5 Page 1 of 15 (9997D/WPF/083094) l l
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Rev. 13 i
VA-02 l
IST Technical Approach and Position t
A.
Comoonent Identificationt 1.
==
Description:==
Method of Fail Safe Testing Valves.
2.
Component Numbers: See IST Valve Tables (Ft).
3.
References:
ASME Code,Section XI, Subsection IWV, paragraph IWV-3413.
4.
Code Class:
1, 2, and 3.
5.
Examination Category (s): N/A.
6.
Item Number (s) : N/A.
B.
Recuirementt Paragraph IWV-3415 of ASME XI states that "When practical, valves with fail-safe actuators shall be tested by observing the operation of the valves upon loss of actuator power".
C.
Positiont i
Most valves with fail-safe positions have actuators that use the fail-safe mechanism to stroke the valve to the fail-safe position during normal operation.
For example, an air-operated valve that fails closed may use air to open the valve against spring pressure.
When the-
)
j actuator is placed in the closed position, air is vented from the l
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diaphragm and the spring moves the obturator to the closed position.
In the cases where normal valve operator action moves the valve to the closed position by de-energizing the operator electrically, by venting air or both (e.g., an electric solenoid in the air system of a valve operator moves to the vent position on loss of power), no additional fail-safe testing is required. Valves with fail-safe actuators that do l
not operate as part of normal actuator operation must be tested by other means.
l Using a valve remote position indicator as verification of proper
(
fail-safe operation is acceptable, provided the indicator is periodically verified to be operating properly as required by ASME Code, i
Section XI, Subsection IWV, paragraph IWV-3300.
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I 4.5 Page 2 of 15 (9997D/WPF/083094)
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Rev. 13 VA-03 IST Technical Approach and Position A.
Comoonent Identification 1.
==
Description:==
Method of Full Stroke (Ct) and Back Flow (Bt)
Exercising of Check Valves.
2.
Component Numbers: See IST Valve Tests (Ct and Bt).
3.
References:
(a) NRC Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, Attachment 1, Positions 1, 2, and 3; (b) ASME Code,Section XI, Subsection IWV, paragraph IWV-3522.
4.
Code Class:
1, 2, and 3.
l 5.
Examination Category (s): N/A.
6.
Item Number (s): N/A.
B.
Recuiremente Paragraph INV-3522 of Article XI states " check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
If only limited operation is practical during plant operation, the check valve shall be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns." For check valves with no external position indication devices, the determination of when they are in full open position has proven difficult to determine. The verification of when a valve is in the full open position affects the determination of which valves are only part-stroked and thus require additional full-stroke testing during cold shutdown or refuelings.
C.
Position:
valid full-stroke exercising to the full-open or full-closed position may be accomplished by observing an external position indicator which is considered to be a positive means of determining obturator position.
l Where external position indicators are not provided, manual stroking of I
the valve is acceptable. Where a mechanical exerciser is used, the torque required to move the obturator must be recorded and meet the l
acceptance standards of subparagraph IWV-3522(b).
Per the requirements I
of the NRC Generic Letter 09-04, Attachment 1, Position 1, the other acceptable method of full-stroke exercising a check valve to the open position is to verify that the valve passes the maximum required accident condition flow. Any flow less than this is considered as a part-stroke exercise.
Flow through the valve must be determined by
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(9997D/WPF/083094) l
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Rev. 13 C.
Position: (continued)
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positive means such as permanently installed flow instruments, temporary flow instruments, or by measuring the pressure drop'across the valve or.
other in-line component. Measuring total flow through multiple parallel lines does not provide verification of flow through individual valves.
One exception to the " maximum required accident flow" requirement is the methodology used to verify full-stroke exercising of the Safety Injection (SI) Accumulator Back-up Check Valves, 1/2SI8956A-D. Because of the high maximum design flowrate of the valves, a maximum design accident flowrate test is. physically. impossible to perform. _For those valves, an Engineering calculation has been performed to determine the-minimum flowrate for full disc lift..An acceptable full-stroke exercise of these valves will be performed each refueling outage by measuring the accumulator level decrease over time, converting these parameters to a flowrate through the valve, and verifying this value is greater than or equal to the engineering calculated minimum flowrate for full disc lift.
This method is superior to sample disassembly and inspection of one valve per outage which would require unusual system line-ups, freeze seals, radiation exposure, and possible plant transients.
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Other alternatives to measuring full design accident flow or disassembly and inspection of check valves to satisfy full stroke requirements is l
allowed as long as the requirements of NRC Generic Letter 89-04,,
Positions 1, 2,'and 3 are utilized QE specific relief
' requests are approved by the NRC.
Stroking a valve to the full closed position for valves without a manual exerciser or position indicator must be verified using indirect means.
These include, but are not limited to, (1) observing pressure indications on both sides of the valve to determine if the differential pressure expected with the valve shut is obtained, or (2) opening a drain connection on the upstream side of the valve to detect. leakage rates in excess of.that expected with the valve shut.
Valves that cannot be full-stroke tested or where full-stroking cannot be verified, shall be disassembled, inspected, and manually exercised.
Valves that require disassembly for full-stroke testing during cold shutdowns or refueling still require quarterly part-stroke testing, where possible.
Testing of check valves by disassembly shall comply with the following:
a.
During valve testing by disassembly, the valve internals shall be visually inspected for worn or corroded parts, and the valve disk shall be manually exercised.
4.5 Page 4 of 15 (9997D/WPF/083094) l I
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Rev. 13 C.
Position! (continued) b.
Due to the scope of this testing, the personnel hazards involved, and system operating restrictions, valve disassembly and inspection may be performed during reactor refueling outages. Since this frequency differs from the Code required frequency, this deviation must be specifically noted in the IST program.
I c.
Where it is burdensome to disassemble and inspect all applicable valves each refueling outage, a sample i
disassembly and inspection plant for groups of identical valves in similar applications may be employed. The NRC Generic Letter 89-04 guidelines for this plan are explained i
below:
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The sample disassembly and inspection program
{
involves grouping similar valves and testing one valve in each group during each refueling outage. The sampling technique requires that each valve in the group be the same design (manufacturer, size, model number, and materials of construction) and have the same service conditions including valve orientation.
Additionally, at each disassembly the licensee must verify that the disassembled valve is capable of full-stroking and that the internals of the valve are structurally sound (no loose or corroded parts). Also, if the disassembly is to l
verify the full-stroke capability of the valve, the disk should be manually exercised.
A different valve of each group is required to be disassembled, inspected, and manually full-l stroke exercised at each successive refueling outage, until the entire group has been tested.
If the disassembled valve is not capable of being full-stroke exercised or there is binding or failure of valve internals, the remaining valves in that group must also be disassembled, inspected, and manually full-stroke exercised during the same outage.
Once this is completed, the sequence of disassembly must be repeated unless extension of the interval can be justified.
l (9997D/WPF/083094)
Rav. 13 C.
Position: (continued) l Extending the valve sample disassembly and inspection interval from disassembly of one valve in the group every refueling outage or expanding the group size would increase l
the time between testing of any particular valve in the group. With four valves in a group and an 18-month reactor cycle, each valve would be disassembled and inspected every six years.
If the fuel cycle is increased to 24 months, each valve in a four-valve sample group would be disassembled and inspected only once every eight years.
j Extension of the valve disassembly / inspection interval from l
that allowed by the Code (quarter?y or cold shutdown frequency) to longer than once every 6 years is a substantial change which may not be justified by the valve failure rate data for all valve groupings. When l
disassembly / inspection data for a valve group show a greater than 25% failure rate, the station should determine whether i
group show a greater than 25% failure rate, the station should determine whether the group size should be decreased or whether more valves from the group should be disassembled l
during every refueling outage.
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basis.
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Rev. 13 I
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VA-04 l
IST Technical Approach and Position l
l A.
Comoonent Identification:
1.
==
Description:==
Determining limiting values of full-stroke times for Power-Operated Valves.
2.
Component Numbers: See IST Valve Tables (St).
3.
References:
I a.
ASME Code,Section XI, Subsection IWV, Sub Article IWV-3413.
b.
NRC Generic Letter 89-04, Attachment A, Position 5.
c.
ANSI /ASME OM-1987 through OMb-1989 Addenda, Part 10, Section 4.2.
4.
Code Class:
1, 2, and 3.
5.
Examination Category (s): N/A.
B.
Recuirement-The IST program originally assigned a limiting value of full-stroke time based on the most conservative value from plant Technical Specifications (TS) or Updated Final Safety Analysis Report (UFSAR).
For valves not having a specified value of full-stroke, a limiting value was assigned based on manufacturers design input, engineering input, or initial valve preoperational testing. This methodology is contrary to NRC Generic Letter 89-04.
l According to NRC Generic Letter 89-04 the limiting value of full-stroke should be based on an average reference stroke time of a valve when it i
is known to be operating properly. The limiting value should be a reasonable deviation from this reference stroke time based on the valve size, valve type, and actuator type. The deviation should not be so restrictive that it results in a valve being declared inoperable due to l
reasonable stroke time variations. However, the deviation used to establish the limit should be such that corrective action would be taken for a valve that may not perform its intended function. When the l
calculated limiting value for a full-stroke is greater than a TS or l
safety analysis limit the TS or safety analysis limit should be used as l
the limiting value of full-stroke time.
Based on this, a review of each l
valve operating history was performed and an average / reference value of l
full-stroke determined.
In addition, valves were grouped together by j
system, train, unit, valve type, and actuator type to provide for a more j
thorough review in determining what would be a " reasonable" deviation from the average / reference full-stroke value.
4.5 Page 7 of 15 l
(9997D/WPF/083094) r
Rev. 13 B.
Recuirement:
(continued) i The 1983 Edition through Summer 1983 Addenda of ASME Section XI does not i
provide guidance for determining values of full-stroke. However, it does provide requirements for when to start monitoring a valves performance on a more frequent basis, also known as alert range testing.
If a valve strokes in 10 seconds or less, a 50% increase over the previous value requires it to be put on a monthly test frequency, and for valves stroking in greater than 10 seconds, a 25% increase over the previous value requires it to be put on a monthly test frequency (see VR-20).
Trending stroke times, based on the percent change from the crevious test, as ASME Section XI requires, allows gradual j
degradation to occur over a long period of time without triggering the additional trending attention that increased testing frequency requires.
Therefore, an improved method of component performance monitoring is employed which requires a valve to be placed on increased test frequency j
based on the percent change from the fixed reference value established 4
via NRC Generic Letter 89-04, Attachment 1, Position 5.
This criteria, in conjunction with establishing reference / average values of full-stroke, should allow for reasonable deviations in stroke time l
measurements without declaring a valve inoperable. The corrective l
actions specified in IWV-3417(b) of Section XI and as described in IST Program Relief Request VR-20 will be taken when a valve exceeds its
]
limiting value of full stroke.
C.
Position:
J The following criteria will be used as general guidance to establish ALERT and REQUIRED ACTION ranges for power-operated valves:
SOV's/HOV's/AOV's - Less than or ecual to 10 seconds:
ALERT RANGE:
(1.50) (Tw) - (2.0) (Tg)
REQUIRED ACTION VALUE:
> (2.0) (Tg)
MOV's - Less than or ecual to 10 seconds:
ALERT RANGE:
(1.25) (Tg) - (1.50) (T,g)
I REQUIRED ACTION VALUE:
> (1.50) (Tg) i MOV's/SOV's/HOV's/AOV's - Greater than 10 seconds:
See VR-20; this technical approach and position will not be put into application until relief request VR-20 is approved, i
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l Rev. 13 NOTES:
1.
T is the reference or average stroke value in seconds of an nt individual valve or valve grouping established when the valve is known to be operating acceptable.
2.
Standard rounding techniques are to be used when rounding off stopwatch readings during valve stroke timing (e.g. 10.45 rounds to 10.5, and 10.44 is rounded to 10.4 seconds).
Round off all measured stroke time to the nearest tenth of a second.
3.
When reference stroke values or average stroke values are affected by other parameters or conditions, then these parameters or conditions must be analyzed and the above factors adjusted.
4.
If the above calculated values exceed a Technical Specification or FSAR value, then the TS or FSAR must be used for the limiting value of full-stroke.
5.
Fast acting valves (vales which normally stroke in less than 2 seconds consistently) are included in Relief Request VR-12.
These valves are HQI assigned ALERT RANGES and are HQI trended.
6.
The above criteria is a guide and cannot cover all valves.
The ALERT RANGES and REQUIRED ACTION VALUES are selected based on j
comparison between the REFERENCE VALUE, LIMITING VALUE given in Technical Specifications /UFSAR, operating history, and calculated values using the above criteria.
7.
valves which serve the same function on dual trains (i.e.,
ICC9473A and ICC9473B) and dual units (i.e. ICC9473A and 2CC9473A) are assigned the same REQUIRED ACTION / ALERT RANGE VALUES based on human factors considerations, unless valve or system design differences exist between the trains / units.
8.
Refer to Relief Request VR-20 for related information.
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Rev. 13 VA-05 IST Technical Approach and Position A.
Component Identification:
1.
==
Description:==
Justification for exercising the Component Cooling heat exchanger and pump manual isolation valves on a U-2 Cold Shutdown frequency.
2.
Component Numbers / Functions:
a.
1/2CC9458:
CC pump Discharge Header Manual Isolation Valves which may provide for train separation in a post accident situation.
b.
1/2CC9459A: CC Pump Suction Header Crosstie Manual Isolation valves which may provide for separation / isolation of the CC
')
system into two redundant trains during recirculation phase i
I of RHR operation during a LOCA and other applicable accident modes.
c.
1/2CC9459B: CC Pump Suction Header Crosstie Manual Isolation valves which may provide for separation / isolation of Unit-1 and Unit 2 CC systems during normal cooldown and recirculation phase of RHR operation.
d.
1/2CC9467A: CC heat exchanger Outlet Header Crosstie Manual Isolation Valves which provide for possible manual isolation of flow to the unit normal plant loads if the respective CC9415 valve fails open.
I e.
1/2CC9467B: CC Heat Exchanger Header Crosstie Manual Isolation Valves which may provide for train separation while the subject unit undergoes Post LOCA cooldown.
I Provides separation / isolation of Unit-1 and Unit 2 CC systems during normal cooldown and recirculation phase of RHR operation.
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1/2CC9467C: CC Supply Header Crosstle Manual Isolation Valve which may need to be called upon due to a single failure within the CC system configuration.
3.
References:
a.
ASME Code,Section XI, Subsection IWV, paragraphs IWV-3411, 3412 b.
Draft NUREG-1482, Section 3.1.1 l
C.
OM-10, paragraphs 4.2.1.1, 4.2.1.2 i
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Rev. 13 1
4.
Code Class:
3 5.
Category:
B B.
Requirement:
Per IWV-3412, " Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation".
In related regulatory documents, section 4.2.1.2.c of OM-10 states that, "if exercising is not practicable during plant operation, it may be limited to full-stroke exercising during cold shutdowns".
Draft NUREG-1482, section 3.1.1, states that " Exercising valves at each cold shutdown outage is not a deviation from the Code and does not require a relief request".
C.
Position:
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PART A:
Manual Valves 1/2CC9459B and 1/2CC9467B are used to provide train separation and/or isolation of the component Cooling Water System. More specifically, they are aligned to place the U-0 Heat Exchanger and Pump on the U-1 or U-2 side of CCW to ensure adequate cooling during shutdowns and/or Post-Accident.
Stroking these valves quarterly or during U-1 cold shutdowns would be a considerable burden and potential safety concern. The CC system is a delicately balanced system that has the potential for becoming upset upon swapping the Unit 0 Heat Exchanger and Pump from one unit to the other. History has shown that stroking these valves will cause oscillation in the lines, disrupt flow balancing due to D/P differences-throughout the system, and would place the normal loads at risk for adequate cooling.
For instance, the CC685 valve, which is the Reactor Coolant Pump thermal barrier Component Cooling Water return valve, autocloses on high flow, which would result in a loss of flow to the RCP thermal barriers. This valve could potentially close during the CC stroke tests due to the upset flow conditions.
In addition, the CC surge tanks will be at risk of draining, resulting in possible pump trips on low-low level. The potential problems would only be compounded by stroking these valves during a U-1 cold shutdown since the U-0 heat exchanger and pump will be in use on the U-1 train. Hence, Byron considers it impractical to perform this testing quarterly or during a
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U-1 cold shutdown.
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I Rev. 13 i
A review of maintenance history dating back to 1983, shows there has i
been no evidence of valve exercising malfunctions from that time to the t
present, further justifying that exercising these valves on a quarterly basis would result in no value added. The 1/2CC9459B and 1/2CC9467B valves will be exercised at the same frequency as each U-2 Cold Shutdown, or a minimum of once every 18 months due to each U-2 Refueling Outage. This is when the U-0 heat exchanger and pump are normally swapped to U-2, necessitating the stroking of these valves. This-t frequency, rather than quarterly, will reduce the likelihood of a CC system malfunction caused by stroking these manual valves.
PART Br The 1/2CC9467A valves should not be stroked on a quarterly basis for i
reasons similar to that expressed in part A.
One function of these valves is to isolate flow to the normal plant loads in a post-accident situation if the respective CC9415 valve.were to fail open. This would be an undesirable exercise during normal operations. When the plant is in its normal lineup, isolation of the 2CC9467A valve would indeed isolate flow to the normal plant loads.
For U-1, if.the ICC9467A valve
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were isolated, CC flow would need to be diverted through the U-0 heat exchanger, which may cause disruptions within the CC system.
If the U-0 heat exchanger was aligned to the U-2 side, the opposite affects would be felt.
For these reasons, these valves will also be exercised during U-2 Cold Shutdowns with the valves from part A.
Part C Exercising the remaining valves (1/2CC9458, 1/2CC9459A, and 1/2CC9467C) on a quarterly basis would not result in as much of a burden as the i
previously mentioned valves. However, the exercising of these valves on a quarterly basis would clearly be impractical for the following reasons. As with all of the CC valves mentioned, maintenance history since 1983 indicates that there have not been any problems associated with these valves concerning the actual manual exercising of them.
l There are no indications of binding or other trouble exercising the I
valves.
The work on them has consisted nearly entirely of early re-packs during initial installation and startup, and a couple of^11mit switch adjustments..One of the main reasons for incorporating IST l-testing is to monitor for. degradation, and there would be no value added j
to exercising these valves on a quarterly basis. These valves will be exercised at the same time as the other valves in this position, on a i
U-2 Cold Shutdown basis.
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Rev. 13
==
Conclusions:==
Besides the previous justifications mentioned, for each set of valves, the UFSAR " active valve" table 3.9-16 doec not list any of these valves as " active" and section 9.2.2.4 gives justification that these valves are not required in the short term following an accident. Also, the UFSAR states that if there was a single failure of a valve in the long term, making it undesirable to use a particular pump and heat exchanger, sufficient cooling would be provided with a different subsystem.
Testing these valves is conservative on Byron's part, and quarterly testing is less significant that in other cases due to the design of the system. All the valves listed in this position experience minimal wear and a minimum eighteen month manual exercise frequency (U-2 Cold Shutdown) should be sufficient to detect a problem.
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Rev. 13 VA-06 IST Technical Approach and Position A.
Comoonent Identification:
1.
==
Description:==
Stroke Time Corrective Actions.
2.
Component Numbers: All Power Operated Valves, except those identified in VR-12 (rapid-acting valves).
3.
References:
(a) Subarticle IWV-3417(a); (b) OM-10, Section 4.2.1.9.
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4.
Category: A and B.
B.
Recuirement:
Per IWV-3417 (a), if, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke
(
times greater than 10 seconds, or 50% or more for valves with full-l stroke times less than or equal to 10 seconds is observed, test l
frequency shall be increased to once each month until corrective action l
is taken, at which time the original test frequency shall be resumed.
In any case, any abnormality or erratic action shall be reported.
C.
Position l
The Code requirement for increased frequency testing is based on a j
comparison between the current stroke time and the previous stroke time.
Depending on the stroke duration and the percentage increase, monthly testing may be required. This approach, if not checked by trending, allows for the threshold for more frequent testing to slowly creep up over time.
For example, an increase of 10% at each quarterly test could take place over a period of one year without any action being required.
This variable limit is also difficult to administer because the limit is not a permanent entry in the test procedure.
A more appropriate method to be used should be based on an empirically derived fixed limit using valve operating history, valve condition and comparison with other valves of similar design (valve size, valve type, and actuator type). This allows for a more thorough review in l
determining what the " reasonable deviation" from the average / reference l
stroke value should be for an individual or group of valves (See VR-20 l
and VA-4).
For those valves that are identified for stroke testing in cold shutdown or refueling only, these valves cannot be placed on a roonthly testing frequency for the reasons already presented in the valve test program.
Since the Code does not provide any direction for these frequencies of test, it is unclear if these valves are even to be included in the context of IWV-3417 (a).
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l Rev. 13 1
C.
Position:
(continued) l
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l For all power operated valves which normally stroke in greater than two seconds, an alert range will be established based on reaching a given percent increase from the reference average value. The maximum limiting value of full stroke is established per Technical Approach and Position, VA-04 and Relief Request VR-20.
The reference value used to determine the alert range will be reconfirmed following maintenance activities that could affect valve j
stroke time, or a new limit will be established based on the new stroke time.
For valves that can only be stroke timed in cold shutdown or refueling, once the valve (s) enter the alert range, they will be retested.
If the retest is acceptable, then an evaluation will be performed to determine the cause.
If the retest is unacceptable, then the valve will be declared inoperable until corrective actions are taken or an evaluation is completed justifying continued operability.
For valves that are stroke timed quarterly, when the alert range is exceeded, the valve will be immediately retested.
If the retest is acceptable, then an evaluation will document this deviation.
If the retest is unacceptable, the valve will be placed on a monthly testing frequency until corrective action is taken or an evaluation is completed, justifying continued operability providing the limiting valve j
or full stroke is not exceeded.
I Using fixed alert ranges based on the reference value established when a valve is known to be operating acceptably will ensure that gradual valve performance degradation is monitored and evaluated, by placing the valve on an increased testing frequency when the stroke time exceeds a fixed multiple of the reference value. This method is superior to that required by the Code in that the point of reference used to evaluate the performance trend on a valve remains fixed.
The alternate test method uses the same percentage increase as the Code, except that it is applied to the reference value.
Performing an engineering evaluation / investigation when a cold shutdown / refueling valve enters the alert range, providing the retest is acceptable, is adequate to monitor the valve for degradation.
This position will be gradually incorporated to support Byron's ten year update in 1995.
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4.5 Page 15 of 15 l
(9997D/WPF/083094) l
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i SECTION 4.6 RELIEF REQUESTS I
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l t
1 i
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Rev. 13 I
RELIEF REOUEST VR-1 l
1.
Valve Number:
All primary containment isolation valves in this program are listed as Category A:
VALVE #
VALVE #
VALVE #
1) 1CC685 41)
IFR033B 81)
ISI8888 2)
ICC9413A 42)
IPR 033C 82)
ISIB964 3)
ICC9414 43)
IPR 033D 83)
ISI8968 4) 1CC9416 44)
IPR 066 84) 1VQ001A 5)
ICC9438 45)
IPS228A 85) 1VQ001B 6) 1CC9486 46)
IPS228B 86) 1VQ002A 7) 1CC9518 47)
IPS229A 87) 1VQOO2B 8) 1CC9534 48) 1PS229B 88) 1VQ003 9) 1CS007A 49)
IPS230A 89) 1VQ004A 10) 1CS007B 50) 1PS230B 90) 1VQ004B 11) 1CS008A 51)
IPS231A 91) 1VQ005A 12) 1CS008B 52) 1PS231B 92) 1VQ005B 13) 1CV8100 53) 1PS9354A 93)
IVQ005C 14) 1CV8112 54) 1PS9354B 94)
IVQOl6 15) 1CV8113 55) 1PS9355A 95) 1VQ017 16)
ICV 8152 56) 1PS9355B 96) 1VQO18 17) 1CV8160 57)
IPS9356A 97) 1VQO19 18) 1FC009 58)
IPS9356B 98) 1WM190 19) 1FC010 59)
IPS9357A 99) 1WM191 20) 1FC011 60) 1PS9357B 100) 1WOOO6A 21) 1FC012 61) 1RE1003 101) 1WOOO6B l
22)
IIA 065 62) 1RE9157 102) 1WOOO7A 23)
IIA 066 63) 1RE9159A 103)
IWOOO7B 24)
IIA 091 64) 1RE9159B 104) 1 WOO 20A 25) 10G057A 65) 1RE9160A 105) 1 WOO 20B 26) 10G079 66) 1RE9160B 106) 1 WOO 56A 27) 10G080 67) 1RE9170 107) 1 WOOS 6B j
28) 10G081 68) 1RF026 29) 10G082 69) 1RF027 l
30) 10G083 70) 1RYO75 I
31) 10G084 71) 1RY8025 32) 10G085 72) 1RY8026 33) 1PR001A 73) 1RY8028 34) 1PR001B 74) 1RY8033 35) 1PR002E 75) 1RY8046 36) 1PR002F 76) 1RY8047 37) 1PR002G 77)
ISA032 38) 1PR002H 78)
ISA033 39) 1PR032 79)
ISI8871 l
40) 1PR033A 80)
ISI8880 (9997D/WPF/083094) 4.6 Page 1 of 74
l Rev. 13 RELIEF REOUEST VR-1 (continued) 1.
Valve Number:
(continued)
VALVE #
VALVE #
VALVE #
l l
108) 2CC685 148) 2PR033B 189) 2SI8964 l
109) 2CC9413A 149) 2PR033C 190) 2SI8968 110) 2CC9414 150) 2PR033D 191) 2VQ001A 111) 2CC9416 151) 2PR066 192) 2VQ001B 112) 2CC9438 152) 2PS228A 193) 2VQ002A l
113) 2CC9486 153) 2PS228B 194) 2VQOO2B l
114) 2CC9518 154) 2PS229A 195) 2VQOO3 l
115) 2CC9534 155) 2PS229B 196) 2VQ004A l
116) 2CS007A 156) 2PS230A 197) 2VQ004B 117) 2CS007B 157) 2PS230B 198) 2VQ005A 118) 2CS008A 158) 2PS231A 199) 2VQ005B l
119) 2CS008B 159) 2PS231B 200) 2VQ005C 120) 2CV8100 160) 2PS9354A 201) 2VQ016 121) 2CV8112 161) 2PS9354B 202) 2VQ017 122) 2CV8113 162) 2PS9355A 203) 2VQ018 123) 2CV8152 163) 2PS9355B 204) 2VQ019 124) 2CV8160 164) 2PS9356A 205) 2WM190 125) 2FC009 165) 2PS9356B 206) 2WM191 126) 2FC010 166) 2PS9357A 207) 2WOOO6A 127) 2FC011 167) 2PS9357B 208) 2WOOO6B 128) 2FC012 168) 2RE1003 209) 2WOOO7A l
129) 2IA065 169) 2RE9157 210) 2WOOO7B l
130) 2IA066 170) 2RE9159A 211) 2 WOO 20A 131) 2IA091 171) 2RE9159B 212) 2 WOO 20B 132) 20G057A 172) 2RE9160A 213) 2 WOO 56A 133) 20G079 173) 2RE9160B 214) 2 WOO 56B 134) 20G080 174) 2RE9170 135) 20G081 175) 2RF026 136) 20G082 176) 2RF027 137) 20G083 177) 2RYO75 138) 20G084 178) 2RY8025 j
139) 20G085 179) 2RY8026 140) 2PR001A 180) 2RY8028 141) 2PR001B 181) 2RY8033 142) 2PR002E 182) 2RY8046 143) 2PR002F 183) 2RY8047 144) 2PR002G 184) 2SA032 145) 2PR002H 185) 2SA033 146) 2PR032 186) 2SI8871 147) 2PR033A 187) 2SI8880 188) 2SI8888 l
l (9997D/WPF/083094) 4.6 Page 2 cf 74
Rev. 13 EELIEF REOUEST VR-1 (continued) 2.
Number of Iteru 212 d
3.
ASME Code Cateoorv: A 4.
ASME Code,Section XI Recuirements:
Seat Leakage Measurement per IWV-3420.
5.
Basis for Relief:
Primary containment isolation valves will be set leak tested in accordance with 10CFR50, Appendix J.
For these valves,Section XI testing requirements are essentially equivalent to those of Appendix J.
6.
Alternate Testina-Primary containment isolation valves shall be set leak rate tested in accordance with the requirements of 10CFR50, Appendix J.
The results of such leak rate measurements shall be analyzed and corrected, as necessary, in accordance with the guidance set forth in ASME Code Section XI, Subsection IWV, paragraphs INV-3426 and IWV-3427(a).
The trending requirements of IWV-3427(b) will ngt be utilized.
7.
Justification:
l No additional information concerning valve leakage would be gained by
)
performing separate tests to both Section XI and Appendix J.
Therefore, overall plant safety is not affected. As specified per NRC Generic Letter 89-04, Attachment 1, position 10, the usefulness of INV-3427 (b) does not justify the burden of complying with this requirement.
8.
Acolicable Time Period:
This relief is requested once per two years during the first inspection interval.
9.
Acoroval Status:
a.
Relief granted per SER 9/15/88 contingent upon compliance with ASME Section XI IWV-3426, 27.
b.
Revised to comply with ASME Section XI IWV-3426, 27 in Byron SER Response 12/16/88 (Byron Station Letter 88-1321).
c.
Relief granted per NRC Generic Letter 89-04.
d.
Deleted SD valves per Technical Specification Amendment #39.
e.
Relief granted per SER 9/14/90.
f.
1/2RYO75 Valve added to relief.
Relief granted for same reasons as noted in SER 9/14/90.
(9997D/WPF/083094) 4.6 Page 3 of 74
Rev. 13 RELIEF REOUEST VR-2 1.
Valve Number:
1CS020A 2CS020A 1CS020B 2CS020B 2.
Number of Items:
4 3.
ASME Code Catecorve C l
4.
ASME Code.Section XI Reauirements:
Exercise check valves to the position required to fulfill their function (open - CT; closed - BT) unless such operation is not practical during plant operation, per IWV-3522.
5.
Basis for Relief:
The check valves in the spray additive system cannot be stroked without l
introducing NaOH into the CS system.
I 6.
Alternate Testina:
The A train and B train valves are of the same design (manufacturer, i
size, model number, and materials construction) and have the same service conditions, including orientation, therefore they form a sample disassenbly group.
l Group 1 Group 2 1CS020A 2CS020A 1CS020B 2CS020B One valve from each group, on a per unit basis, will be tested each refueling outage.
If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of valve internals, the remaining valve on the affected unit will be inspected.
7.
Justification:
l Full flow testing of these valves can not be accomplished without posing l
a serious threat to the safety of equipment and personnel.
It is impractical to either full or part stroke exercise these valves since flow through these valves would result in the troduction of NaOH into i
the CS system.
Full-flow testing would require a special test hook-up and necessitate flushing the system.
l (9997D/WPF/083094) 4.6 Page 4 of 74 l
i I
l Rev. 13 RELTEF REOUEST VR-2 (continued) i 7
Justification:
(continued)
The alternate test frequency is justifiable in that maintenance history and previous inspections of these valves at Byron and Braidwood stations has shown no evidence of degradation or physical impairment (this is to be expected since the valves see very limited operation).
Industry 3
l experience, as documented in NPRDS, showed no history of problems with j
these valves. A company wide check valve evaluation addressing the l
"EPRI Applications guidelines for Check Valves in Nuclear Power Plants" revealed that the location, orientation and application of these valves are not conducive to the type of wear or degradation correlated with SOER 86-03 type problems, but these valves still require some level of monitoring to detect hidden problems.
l l
l The wafer type design of the valve body for these valves make their l
removal a simple process, with little chance of damage to their internals. Also, there is no disassembly of internal parts required; all wear surfaces are accessible by visual examination. After inspection and stroke testing, the valve is reinstalled into the line l
I and post maintenance testing is performed.
The valve inspection l
procedure requires post-inspection visual examination of the check valve i
to insure that the pin is oriented properly and that the flow direction is correct.
The alternate test method is sufficient to insure operability of these valves and is consistent with Generic Letter 89-04.
8.
Acolicable Time Period; i
This relief is requested once per quarter during the first inspection interval.
9.
Accroval Status:
a.
Relief to disassemble in place of full flow testing granted per SER 9/15/88.
b.
Relief to disassemble in place of full flow testing granted per Generic Letter 89-04, c.
Relief to disassemble in place of full flow testing granted per SER 9/14/90.
d.
Revised to include both full flow (CT) test and back flow (BT) test; relief granted per Generic Letter 89-04, e.
Relief granted per SER 1/31/92 provided licensee complies with GL 89-04, position 2.
(9997D/WPF/083094) 4.6 Page 5 of 74
l Rev. 13 DRAFT RELIEF REOUEST VR-2a 1.
Valve Number:
ICS020A 2CS020A 1CS020B 2CS020B 2.
Number of Items:
4 i
3.
ASME Code Catecorv: C l
l 4.
ASME Code,Section XI Recuirements:
l Exercise check valves to the position required to fulfill their function (CT/Open, BT/ Closed) quarterly, unless such operation is not practical during plant operation per IWV-3521, or exercise during cold shutdown per INV-3522.
5.
Basis for Relief:
l l
These check valves in the spray additive system (CS) cannot be stroked without introducing NaOH into the CS system, unless the piping between the NaOH storage tank and the injection isolation valves, 1/2CS021A/B, is drained into containers. This amounts to almost two 55 gallon drums of potentially (radioactive / toxic) mixed waste that requires either recycling or disposal. Then, primary water is connected to the CS system via special test connections and is used La flow test the line to ensure that the proper Technical Specification eductor flow rate can be passed.
The problem with disposal stems from the caustic being slightly contaminated, as well as having a high pH.
Recycling (pouring the contents of the drums back into the NaOH tank) is not always a viable option either, considering the caustic has been contained in a stagnant line (up to five years) and may not meet chemistry requirements.
- Thus, storage of hazardous mixed waste can become very costly. This is due to i
the non-existence of commercial disposal facilities for mixed waste, which means that any mixed waste generated would have to be stored on-site. Also, the draining and handling of this highly caustic material l
poses a significant hazard to personnel, and can result in loss of eye sight and/or chemical burns, if splashed or spilled.
i 1
(9997D/WPF/083094) 4.6 Page 6 of 74
l Rev. 13 i
i l
DRAFT BELIEF REOUEST VR-2a 6.
Alternate Testina:
Group 1 Group 2 1CS020A 2CS020A 1CS020B 2CS020B The A and B train valves are of the same design (manufacturer, size, model number, and materials of construction) and have the same service conditions, including orientation. This forms an acceptable sample disassembly group per Generic Letter 89-04, Position 2c.
j Each group will be disassembled and visually inspected at the same frequency as the Technical Specification eductor flow test, conducted at least once every five years.
The visual inspection of internals will l
precede the eductor flow test.
?
7.
Justification:
If the disassembled valve is not capable of being manually full-stroked exercised or there is binding or failure of internals, the remaining valve on the affected unit will be evaluated for further action as well.
Full flow testing of these valves cannot be accomplished without posing a serious threat to the safety of equipment and personnel.
It is impractical to either full or partial stroke exercise these valves since flow through them requires draining and flushing the piping to prevent the introduction of caustic effluent into the CS system.
The problem of mixed waste disposal or recycling created by system draining of approximately two 55 gallon drums is considered an undue hardship, if the Code requirements are imposed.
The alternate test frequency (same frequency as the Technical Specification eductor flow test of at least once every five years) is justifiable in that maintenance history and previous inspections of i
these valves at both Byron and Braidwood stations have shown no evidence
(
of degradation or physical impairments (i.e. corrosion, chemical l
buildup, wear). This is to be expected since these valves see limited operation (flow in line during eductor flow test only).
Industry experience, as documented in NPRDS, shows no history of j
problems with these valves. A company wide check valve evaluation addressing the "EPRI Application Guidelines for Check Valves in Nuclear Power Plants" revealed that the location, orientation and application of these valves are not conducive to the type of wear or degradation correlated with SOER 86-03 type failures.
(9997D/WPF/083094) 4.6 Page 7 of 74
Rev. 13 1
DRAFT l
EELIEF REOUEST VR-2.g 7.
Justification:
(continued) l l
The alternate test method, visual inspection of internals followed by the Technical Specification eductor flow test, at least once.every five years, is sufficient to ensure operability of these valves and is l
consistent with Generic Letter 89-04 guidelines.
The hardship involved j
l with the hazardous mixed waste disposal and handling caustic material with regards to personnel safety does not provide a compensated increase in safety of the CS system equipment.
(
8.
Aeolicable Time Period:
l I
'This relief is requested for the first inspection interval.
l 9.
Accroval Status:
a.
Since this relief is a new submittal and is not specifically addressed in NRC Generic Letter 89-04, it is HQI approved for use.
Formal written approval from the NRC is required prior to implementation. Review and approval are requested by 8/20/94, prior to Byron's next refueling outage.
)
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l (9997D/WPF/083094) 4,6 Page 8 of 74 l
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l Rev. 13
)
l RELIEF REOUEST VR-3 l
l 1.
Valve Number:
ISI8922A 2SI8922A 1SI8922B 2SI8922B 2.
Number of Items 4
3.
ASME Code Catecorv: C 4.
ASME Code.Section XI Recuirements:
Exercise check valves to the position required to fulfill their function i
(open = CT; closed = BT) unless such operation is not practical during plant operation, per IWV-3522.
t 5.
Basis for Relief:
l These check valves cannot be full flow tested during operation as the shut-off head of the Safety Injection pumps is lower than the reactor coolant system pressure.
Performance of this test with the RCS i
depressurized, but intact, could lead to inadvertent over-pressurization I
of the system. The alternate method of protecting against over-pressurization by partially draining the RCS to provide a surge volume is not considered a safe practice due to concerns of maintaining 3
i adequate water level above the reactor core.
i 1
6.
Alternate Testino:
These valves will be full stroke tested during refueling outages as a l
minimum, but no more frequently than once per quarter.
7.
Justification:
This alternative will adequately maintain the system in a state of I
operational readiness, while not sacrificing the safety of the plant, by i
testing the valves as often as safely possible.
8.
Aeolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
)
j 9.
Acoroval Status; a.
Relief granted per SER 9/15/88.
b.
Relief granted per NRC Generic Letter 89-04.
c.
Relief granted per SER 9/14/90.
(9997D/WPF/083094) 4.6 Page 9 of 74 l
Rev. 13 RELIEF REOUEST VR-4 1.
Valve Number:
1CS003A 2CS003A 1CS003B 2CS003B ICS008A 2CS008A j
1CS008B 2CS008B l
2.
Number of Items:
8 j
3.
ASME Code,Section XI Reauirementsr a.
Exercise check valves to the position required to fulfill their function (open - CT; closed = BT), unless such operation is not practical during plant operation, per IWV-3522.
b.
Exercise check valves at least once every 3 months, per IWV-3521.
l c.
Exercise check valves at least once every 3 months to the position required to fulfill their function, unless such operation is not practical during plant operation, per IWV-3412 (for 1/2CS008A, B only).
d.
When a valve has been repaired, replaced, or has undergone maintenance that could affect its performance and prior to the l
time it is returned to service, it shall be tested to demonstrate that the performance parameters, which could have been affected by i
the replacement, repair, or maintenance, are within acceptable limits, per INV-3200.
5.
Basis for Relief:
These valves cannot be full flow tested as a matter of course during unit operation or cold shutdown as water from the CS pumps would be discharged through the CS ring headers causing undesirable effects on system components inside containment.
Additionally, the full flow testing of these check valves during periods l
of cold shutdown, using the CS pumps, would fill the reactor refueling cavity with contaminated water from the refueling water storage tank.
i The filling of the cavity, via temporarily installed large bore piping, l
would require the removal of the reactor vessel head so as to preclude l
equipment damage from borated water. The erection of temporary piping from the CS line to the reactor cavity would take an estimated nine to twelve shifts, or longer compared to one to two shifts for valve inspection. This estimate does not take into account the time required to drain and remove the piping from containment.
i (9997D/WPF/083094) 4.6 Page 10 of 74 i
l
l Rev. 13 RELIEF REOUEST VR-4 (continued) 5.
Easis for Relief:
(continued)
Currently, full flow recirculation flow paths do not exist from the l
discharge of the CS pumps through these check valves to the refueling water storage tank. The addition of such flow paths would require extensive plant modifications to existing plant designs, including penetration of containment integrity.
Partial stroking of the 1/2CS008A, B valves using air does not provide adequate assurance of valve operability and may be detrimental for the following reasons:
a.
There is no correlation between air flow and angle of disc l
movement.
b.
Venting and draining the appropriate piping quarterly may cause deposition of boric acid residue which could in turn promote binding of the check valve internals.
6.
Alternate Testino The A and B train valves are of the same design (manufacturer, size, model number, and materials construction) and have the same service conditions, including orientation, therefore they form a sample disassembly group.
Group 1 Group 1 1CS003A 2CS003A 1CS003B 2CS003B-i Group 2 Group 2 1CS008A 2CS008A 1CS008B 2CS008B One valve from each two valve groups, on a per unit basis, will be tested each refueling outage.
If the disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of valve internals, the remaining valve on the affected unit will be j
inspected.
(9997D/WPF/083094) 4.6 Page 11 of 74
l l
Rev. 13 l
l RELIEF REOUEST VR-4 (continued) l l
7 Justification:
1 The 1/2CS008A,B and 1/2CS003A,B valves are removed from the system and visually examined per the strict detailed inspection requirements of the Station Check Valve Program. This inspection adequately verifies that the valves are maintained in a state of operational readiness. The valves are verified to be functional by performing a thorough visual j
inspection of the valve internals and by performing a full stroke test l
exercise of each disc.
Previous inspections of these particular valves at both Byron and Braidwood have repeatedly shown them to be in good condition.
The wafer type design of the valve body for these valves make their l
removal a simple process, with little chance of damage to their l
internals. Also, there is no disassembly of internal parts required; l
all wear surfaces are accessible by visual examination. After l
inspection and stroke testing, the valve is reinstalled.into the line l
and post maintenance testing is performed.
The 1/2CS008A, B valves l
receive a containment leakage test, and the 1/2CS003A, B-valves are partial flow tested. These tests verity proper installation of the check valves, and the valve inspection procedure requires post-inspection visual examination of the check valve to insure that the pin is oriented properly and that the flow direction is correct.
The alternate test frequency is justifiable in that maintenance history j
and previous inspections of these valves at Byron and Braidwood stations j
has shown no evidence of degradation or impairment.
Industry l
l experience, as documented in NPRDS, showed no history of problems with these valves. A company wide check velve evaluation addressing the
'EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" revealed that the location, orientation and application of these valves are not conductive to the type of wear or degradation correlated with SOER 86-03 type problems. However, they require some level of monitoring to detect hidden problems.
8.
Anolicable Time Period-This relief is requested once per quarter during the first inspection interval.
l (9997D/WPF/083094) 4.6 Page 12 of 74 i
Rev. 13 l
RELIEF REOUEST VR-4 (continued) l i
9.
Accroval Status:
a.
Relief to disassemble in place of full flow testing granted per SER 9/15/88 for 1/2CS003A, B; relief denied per SER 9/15/88 for 1/2CS008A.
b.
Revised to address NRC concerns in Byron SER response 12/16/88 (Byron Station Letter 88-1321).
c.
Relief to disassemble in place of full flow testing grartted per Generic Letter 89-04.
d.
Revised to address NRC concerns in Byron SER 9/14/90 and to l
i include both full flow (CT) and backflow (BT) test; relief granted per Generic Letter 89-04.
e.
Relief granted per SER 01/25/93.
i t
i (9997D/WPF/083094) 4.6 Page 13 of 74 l
Rev. 13 RELIEF REOUEST VR-5 1.
Valve Number (ASME Code Class)-
ISI8956A-D(1) 2SI8 956A-D (1) 2.
Number of Valves:
8 3.
ASME Code,Section XI Recuirementst j
Relief is requested from the 3 month test frequency for the full stroke (CT) and backflow (BT) test as stated in ASME Section XI, INV-3521:
" Check Valves shall be exercised at least once every 3 months, except as provided by INV-3522".
INV-3522 states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full-stroked exercised during cold shutdowns.
l 5.
Basis for Relief:
The 1/2SI8956A-D check valves are located inside the containment building missile barrier on the lines from the accumulator tanks to the Reactor Coolant System (RCS) cold legs.
These 8 check valves have safety functions in both the open and closed directions:
1/2SI8956A-D Closed 1
The 1/2 SIS 956A-D check valves' safety function in the closed direction is to maintain the Reactor Coolant Pressure l
Boundary (RCPB).
Open The 1/2SI8956A-D check valves' safety function in the open direction is to permit the injection of borated water into the reactor vessel cold legs during the passive injection phase of a safety injection.
Check valves 1/2SI8556A-D cannot be tested during unit operation due to
{
the pressure differential between the accumulators (650 psig) and the l
reactor coolant system (2235 psig).
Full stroke exercising of these valves could occur only with a rapid depressurization of the reactor coolant system.
(9997D/WPF/083094) 4.6 Page 14 of 74
l i
l l
l Rev. 13 RELIEF REOUEST VR-5 (continued) 6.
Alternate Testina:
These valves will be backflow tested (BT) on the same schedule as the Byron Station Technical Specifications leakage test as follows:
a.
At least once per 18 months, b.
Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months, c.
Prior to returning the valve to service following maintenance, repair or replacement work on the valve, or d.
Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to manual action or flow through the valve.
These check valves will be full stroke exercised (CT) during refueling outages when the accumulators are discharged into the reactor vessel.
7.
Justification:
These eight valves are part of the Passive Injection subsystem portion of the safety injection system. This subsystem is designed to inject borated water into the reactor cold legs only after Reactor Coolant System (RCS) pressure has decreased below the accumulator nitrogen gas pressure. Under normal plant conditions the RCS system pressure is 2235 psig and the accumulator pressure is 650 psig. Therefore, it is not possible to full stroke these valves unless there is rapid
(
depressurization of the Reactor Coolant System.
Full stroke testing (CT) of these valves during operation or at cold shutdown would require depressurization of the RCS.
Additionally, full stroking these valves during cold shutdowns, routine or forced, would impose hardship with no compensating increase in plant l
safety. To perform this test, the reactor coolant system (RCS) must be at approximately 40 psi with all 4 reactor pumps (RCPs) off and accumulator pressure at 100 psi over RCS pressure. The RCS boron l
concentration is low compared to the 2000 ppm concentration of the I
accumulators. This injection test requires that approximately 8 i
thousand gallons of this boron concentrated water be injected into the RCS.
This would result in a considerable increase in the boron concentration of the RCS.
The feed and bleed process required to restore desired RCS boron concentration would result in considerable increases in restoration time and in amounts of radioactive water rejected from the site.
l (9997D/WPF/083094) 4.6 Page 15 of 74 l
l
Rev. 13 l
RELIEF REOUEST VR-5 (continued) 7.
Justification:
(continued)
Successful completion of the seat leakage test will provide positive verification of closure (BT).
Therefore, backflow testing these valves on the same schedule as their required Technical Specification leak rate testing will adequately maintain the system in a state of operational readiness.
l 8.
Aeolicable Status:
l l
This relief is requested once per quarter during the first inspection l
interval.
9.
Accroval Status:
09/15/88 - Relief for full stroke test granted per SER.
09/14/91 - Relief for full stroke test granted per SER.
i 01/23/92 - Reorganized to indicate safety function of the 1/2SI8956A-D valves and to add backflow test.
l l
l (9997D/WPF/083094) 4.6 Page 16 of 74 r
1 Rev. 13 RELIEF REOUEST VR-6 1.
Valve Number:
1SI8926 2SI8926 2.
Number of Items:
2 3.
ASME Code Catecorv: C 4.
ASME Code,Section XI Recuirements:
Exercise for operability (CT) of check valves every 3 months, per IWV-3521.
5.
Basis for Relief:
Full stroke exercising of the Safety Injection pump suction check valves, 1SI8926 and 2 SIB 926 cannot be demonstrated during unit operation as the reactor coolant system pressure prevents the pumps from reaching full flow injection conditions.
Performance of this test with the reactor coolant system intact could lead to an inadvertent over-pressurization of the system. The alternate method of protecting against over-pressurization by partial draining of the reactor coolant system to provide
- erge volume is not considered a safe practice due to concerns of maintaining adequate water level above the reactor core.
6.
Alternate Testina:
i The 1SI8926 and 25I8926 valves will be partial stroke tested during periodic inservice tests with the SI pumps in the recirculation mode.
Full stroke exercising for the valves will be done during refueling outages as a minimum, but no more frequently than once per quarter.
7.
Justification This alternative will adequately maintain the system in a state of operational readiness, while not sacrific.4ng the safety of the plant, by testing the valves as often as safely possible.
B.
Acolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
9.
Accrova? Status:
a.
Relief grant *.' per SER 9/15/88.
b.
Relief granted per NRC Generic Letter 89-04.
c.
Relief granted per SER 9/14/90.
l (9997D/WPF/083094) 4.6 Page 17 of 74 I
Rev. 13 RELIEF REOUEST VR-7
" DELETED" Deleted relief request VR-7, Incorporated valves formerly covered by.VR-7 into VR-12 and VR-17.
Added maximum stroke times to the valve tables for all valves in VR-12 per EG & G request.
l
{
(9997D/WPF/083094) 4.6 Page 18 of 74 l
Rev. 13 RELIEF REOUEST VR-B j
1.
Valve Number (ASME Code Class)-
ICC685 (2) 2CC685 (2)
ICC9413A (2) 2CC9413A (2) 1CC9414 (2) 2CC9414 (2) 1CC9416 (2) 2CC9416 (2) 1CC9438 (2) 2CC9438 (2) 1CC9486 (2) 2CC9486 (2) 1CC9518 (2) 2CC9518 (2)
ICC9534 (2) 2CC9534 (2) 2.
Number of Valvea1 16 3.
ASME code cateoorv:
A, B, C 4.
ASME Code.Section XI Re7uirements:
a.
Motor operated valves:
1/2CC685, 1/2CC9413A, 1/2CC9414, 1/2CC9416, 1/2CC9438 Relief is requested from the 3 month test frequency for the stroke (ST) test as stated in ASME Section XI IWV-3521, " Category A and B valves shall be exercised at least once every 3 months, except as provided by INV-3412 (a), IWV-3415, and INV-3416".
IWV-3412 states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full-stroke exercised during cold shutdownJ.
b.
1/2CC9486, 1/2CC9518, 1/2CC9534 Relief is requested for check valves 1/2CC9518 and 1/2CC9534 from the 3 month test frequency for the full stroke (CT). test and backflow (BT) test as stated in ASME Section XI IWV-3521:
" Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522".
IWV-3522 state,s that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full-s*.roke exercised during cold shutdowns.
Relief is requasted for the 1/2CC9486 from the 3 month test frequency for t.he backflow (BT) test as stated in ASME Section XI IWV-3521:
" Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522".
IWV-3522 states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke
(
exercised during cold shutdowns.
l l
t i
l (9997D/WPF/083094) 4.6 Page 19 of 74 i
Rev. 13 1
RELIEF REOUEST VR-8 (continued) 5.
Basis for Relief-a.
Motor operated valves:
1/2CC685, 1/2CC9413A, 1/2CC9414, 1/2CC9416, 1/2CC9438 1/2CC685, 1/2CC9438 Closed These valves are located on the Component Cooling return line from the Reactor Coolant Pump (RCP) thermal barrier cooling coils. The safety function of these valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during post accident conditions after a postulated rupture of the thermal barrier heat exchanger.
Open The function of these valves in the open direction is to provide Component Cooling water return from the Reactor Coolant Pump thermal barriers.
1/2CC9413A Closed These valves are located on the Component Cooling supply line to the Reactor Coolant Pumps (RCP's).
The safety function of these valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the envircraent during accident conditions.
Open The function of these valven in the open direction is to supply Component Cooling water to the Reactor Coolant Pumps.
l l
(9997D/WPF/083094) 4.6 Page 20 of 74
4 i
r Rev. 13 RELIEF REOUEST VR-8 (continued) 1/2CC9414, 1/2CC9416 2
j Closed These valves are located on the Component Cooling
)
return line from the Reactor Coolant Pump (RCP) upper 4,
and lower motor bearing coolers.
The safety function of these valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident 4
conditions.
Open The function of these valves in the open direction is to provide Component Cooling water return from the q
Reactor Coolant Pumps upper and lower motor bearing coolers.
4 Component Cooling water flow to the reactor coolant pumps is required at all times while the pumps are in operation and for an extended period of time while in cold shutdown.
Failure of one of these valves in a closed position daring an exercise test would result in a loss of cooling flow to the pumps and eventual pump damage and/or trip.
b.
Check valves: 1/2CC9486, 1/2CC9518, 1/2CC9534 1/2CC9486 Closed These check valves are located on the Component Cooling supply line to the Reactor Coolant Pump motor bearings and thermal barrier.
The safety function of these valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during~ accident conditions.
Open The function of these valves in the open direction is to supply Component Cooling water to the Reactor Coolant Pump motor bearings and thermal barriers.
Component Cooling water flow to the reactor coolant pumps is required at all times while the pumps are in operation and after an extended period of time while in cold shutdown.
Failure of 1/2CC9486 in a closed position during an exercise test would result in a loss of cooling flow to the pumps and eventual pump damage and/or trip.
(9997D/WPF/083094) 4.6 Page 21 of 74
l l
Rev., 13 RELIEF REOUEST VR-8 (continued) l 1/2CC9518 Closed These valves are located on the Component Cooling water return line from the Reactor Coolant Pump thermal barrier. The safety function of these valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
open l
The function of these valves in the open direction is i
to provide pressure equalization between inside containment isolation valves 1/2CC9438 and outside containment isolation valves 1/2CC685, i
l 1/2CC9534 l
Closed These valves are located on the Component Cooling water return line from the Reactor Coolant Pump motor i
bearings. The safety function of these valves in the closed direction is to provide a leak-tight barrier I
between the containment atmosphere and the environment i
during accident conditions.
Open The function of these valves in the open direction is to provide pressure equalization between piping inside and outside containment.
Full stroke (CT) and backflow (BT) testing of check valves l
1/2CC9518 and 1/2CC9534 would interrupt flow from the RCP thermal l
barrier and motor bearings. Therefore, full flow testing of the l
1/2CC9518 and 1/2CC9534 is only possible with the RCP's shut down.
6.
Alternate Testinar a.
Motor operated valves:
1/2CC685, 1/2CC9413A, 1/2CC9414, 1/2CC9416, 1/2CC9438 l
These valves will be stroke tested (see VR-1 for leak testing frequency) during cold shutdowns, provided all of the RCP's are not in operation (RCP's will not necessarily be secured for the sole purpose of performing this test).
This testing period will l
be each refueling outage as a minimum, but no more frequently than once per quarter.
l (9997D/WPF/083094) 4.6 Page 22 of 74 l
. -.. ~ - -.
. ~..,
i Rev. 13 RELIEF REOUEST VR-8 (continued) b.
1/2CC9486, 1/2CC9518, 1/2CC9534 Check valves 1/2CC9518 and 1/2CC9534 will be full stroke tested (CT) and backflow (BT) tested and 1/2CC9486 will be backflow-(BT)
A tested during cold shutdowns provided all of the reactor coolant l
pumps are not in operation (RCP's will not necessarily be secured for the sole purpose of performing this test). This testing-period will be each refueling outage as a minimum, but not more frequently than once per quarter. Both these tests will be performed in conjunction with the seat. leakage' test.
7.
Justificationt l
This alternate test frequency has been previously approved for the motor l
operated valves contained in this relief request. Check valves 1/2CC9486 were previously approved for the backflow test to be performed at refueling frequency.
This alternate frequency will adequately maintain the system in a state
.of operational readiness by testing these valves as often as safely possible.
Shutting down.the RCP's and the-subsequent restarting incurs a reactor vessel overpressurization risk.
In addition, it is operationally undesirable due to the time and manpower involved in starting an RCP.
Also, an operator is required to observe the RCP shaft rotation upon starting. Stopping and starting RCPs_would add unnecessary radiation exposure (approximately 20 mrem).
l 8.
Anolicable Status:
j This relief is requested once per quarter during the first inspection interval.
i P
9.
Aceroval Status:
09/15/88 - Relief granted for motor operated valves and 1/2CC9486 back flow test i
01/23/92 - Reorganized to:
1.
Add safety function of all valves.
2.
Add full stroke (CT) and backflow (BT) for check valves 1/2CC9518 and 1/2CC9534 3.
Change from refuel frequency to cold shutdown with all i
RCPs off for the backflow (BT) test of 1/2CC9486 (9997D/WPF/083094) 4.6 Page 23 of 74 l
5 6
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CC, COMPONENT COOLING cc9s34 GENERAL DIAGR AM FOR INFORMATION ONLY O
Rev. 13 RELIEF REOUEST VR-9 i
l t
1.
Valve Number (ASME Code Class)-
1CV8100 (2) 2CV8100 (2) 1CV8112 (2) 2CV8112 (2) 1CV8113 (2) 2CV8113 (2) 2.
Number of Valves:
6 l
3.
ASME Code Catecorv:
A, AC 4.
ASME Code.Section XI Recuirements:
a.
Motor operated valves:
1/2CV8100 and 1/2CV8112 Relief is requested for these four (4) valves from the 3 month l
test frequency for the stroke (ST) test as stated in ASME Section XI IWV-3521, " Category A and B valves shall be exercised at least once every 3 months, except as provided by IWV-3412 (a), IWV-3415, and IWV-3416".
IWV-3412 (a) states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdowns.
l b.
1/2CV8113 Relief is requested for these two (2) valves from the 3 month test frequency for the full stroke (CT) and backflow (BT) test as stated in ASME Section XI IWV-3521, " Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522".
IWV-3522 states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdowns.
5.
Basis for Relief:
a.
Motor operated valves:
1/2CV8100 and 1/2CV8112 i
Open i
These motor operated globe valves are located in the Reactor Coolant Pump seal water return lines.
Their function in the open direction is to permit seal water return flow from the Reactor Coolant Pumps to the seal J
water heat exchanger.
l l
l l
(9997D/WPF/083094) 4.6 Page 24 of 74 l
l i
l i
l Rev. 13 RELIEF REOUEST VR-9 (continued)
Closed i
l The safety function in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
l These valves cannot be tested during unit operation as seal flow from the reactor coolant pumps is required at all times while the pumps are in operation.
Failure of one of these valves in the closed position during an exercise test would result in an abnormal seal water return flow being diverted to the Pressurizer Relief Tank (PRT) by lifting a relief valve (1/2CV8121) upstream of the isolation valves.
b.
Check valves: 1/2CV8113 Closed These are normally closed check valves located across containment isolation valves 1/2CV8112 inside containment. Their safety function in the closed direction is to maintain the integrity of the Reactor Coolant Pressure Boundary and to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
Open The safety function of these valves in the open direction is to relieve any pressure that may buildup between containment isolation valves 1/2CV8100 and 1/2CV8112.
These check valves function only when both the associated containment isolation valves are closed. Therefore, they cannot be full stroke tested without closing the 1/2CV8100 and 1/2CV8112 valves.
6.
Alternate Testinar a.
Motor operated valves:
1/2CV8100 and 1/2CV8112 These valves will be full stroke exercised during cold shutdown, provided all reactor coolant pumps are not in operation and seal leak-off can be isolated (RCP's will not necessarily be secured for the sole purpose of performing this test). This testing period will be each refueling outage as a minimum, but no more frequently than once per quarter.
4 (9997D/WPF/083094) 4.6 Page 25 of 74
Rev. 13 RELIEF REOUEST VR-9 (continuedl b.
1/2CV8113 Since the 1/2CV8113 valves cannot be full stroke tested without closing the 1/2CV8100 and 1/2CV8212, they will also be full stroke tested and backflow tested during cold shutdown provided all reactor coolant pungs are not in operation and seal leak-off can be isolated. This test frequency is the same as that of the 1/2CV8100 and 1/2CV8112, 7.
Justification:
This alternate frequency will adequately maintain the system in a state of operational readiness, by testing these valves as often as safely possible. Shutting down the RCP's and the subsequent restarting incurs a reactor vessel overpressurization risk.
In addition, it is operationally undesirable due to the time and manpower involved in starting an RCP.
Also, two operators are required to observe the RCP shaft rotation upon starting. Stopping and re-starting RCPs would add unnecessary radiation exposure (approximately 20 mrem).
8.
Acolicable Status:
This relief is requested once per quarter during the first inspection interval.
9.
Ag2roval Status:
09/15/86 - Relief granted per SER for valves 1/2CV8100 and 1/2CV8112 09/14/90 - ?elief granted per SER for valves 1/2CV8100 and 1/2CV8112 01/23/92 - Recrganized to indicate safety function of all valves and to add full stroke test and backflow test of check valves 1/2CV8113 (9997D/WPF/083094) 4.6 Page 26 of 74
1 i
i l
1/2 CV8113 i
CV8113
~
i FROM m
l RCP SEALS l
cvaioo cva112 I
I U
N T
S I
D D
E E
C C
N M
T T
GENERAL DIAGRAM FOR INFORMA110N ONLY M64-2
l Rev. 13 1
l RELIEF REQUEST VR-10 1.
Valve Number (ASME Code Class)-
IIA 066 (2) 2IA066 (2)
)
IIA 065 (2) 2IA065 (2)
)
l lIA091 (2) 2IA091 (2) 2.
Number of Valves:
6 3.
ASME Code Catecorv: A and AC 4.
ASME Code,Section XI Recuiremental l
a.
Air operated valves:
1/2IA065 and 1/2IA066 Relief is requested from the 3 month test frequency for the stroke test (ST) and fail safe test (FT) as stated in ASME Section XI IWV-3411, " Category A and B valves shall be exercised at least once every 3 months, except as provided by IWV-3412 (a), INV-3415, and INV-3416".
IWV-3412 (a) states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdown.
b.
1/2IA091 Relief is requested from the 3 month test frequency for the backflow (BT) test as stated in ASME Section XI, IWV-3521, " Check valves shall be exercised at least once every 3 months, except as provided by INV-3522".
IWV-3522 states that valves that cannot be exercised during plant operation shall be specifically identified l
by the owner and shall be full stroke exercised during cold shutdown.
5.
Basis for Relie[1 a.
Air operated valves:
1/2IA065 and 1/2IA066 l
The 1/2IA065 and 1/2IA066 valves are the outboard and inboard (respectively) containment isolation valves for Instrument Air supply lines to containment. The closed safety function of these l
valves is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
Stroke testing of the 1/2IA065 and 1/2IA066 valves during plant operation or cold shutdown would, by design, isolate the air to air operated instruments inside the containment building.
r (9997D/WPF/083094) 4.6 Page 27 of 74 i
i
Rev. 13 RELIEF REOUEST VR-10 (continued) b.
Check valves: 1/2IA091 The 1/2IA091 valves are located on the air supply lines to the 1/2IA066 valves, The 1/2IA066 valves are the inboard containment isolation valves for the Instrument Air supply lines to.
l containment. The safety function of the 1/2IA091 valves in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions. The function.in.the open direction is to. supply i
control air to the 1/2IA066 valves.
Stroke. testing of the 1/2IA091 valves cannot be performed'without actuating the 1/2IA066 which would result in the isolation of all Instrument Air to containment.
6.
Alternate Testinar a.
Air operated valves:
1/2IA065 and 1/2IA066 The 1/2IA065 and 1/2IA066 valves will be stroke tested. (ST) and fail safe tested (PT) during refueling outages.
b.
Check valves: 1/2IA091 The 1/2IA091 valves will be backflow tested (BT) during refueling outages. This backflow test will be-done in conjunction'with the seat leakage test.
7.
Justifications a.
Air operator valves:
1/2IA065 and 1/2IA066 l
The full stroke exercising of the 1/2IA065 and 1/2IA066 Instrument l
Air containment isolation valves during unit power operations or j
cold shutdowns, would introduce the possibility of major operating j
perturbations and/or personnel safety concerns should these valves fail to re-open during testing activities.
The failure of these valves in the closed position, as a result-of testing activities during plant operation or cold shutdown, would subsequently isolate the air operated instruments inside the containment building thus resulting in scenarios such as:
i 1.
Loss of Pressurizer Pressure Control -
The pressurizer spray valves 1/2RY455B & C and the pressurizer auxiliary spray valve 1/2CV8145 would fail closed and not be available for pressurizer pressure control.
1 (9997D/WPF/083094) 4.6 Page 28 of 74 i
i i
l
l l
l Rev. 13 I
RELIEF REOUEST VR-10 (continued) i 2.
Loss of Chemical Volume Control System Letdown Flow (both i
normal and excess) and Charging Flow -
l The loss of instrument air would cause a. disruption in the unit letdown flow paths resulting in pressurizer level increases. Such valves as the letdown orifice containment outlet header isolation valve 1/2CV8160, the letdown line isolation valves 1/2CV459 and 1/2CV460, the letdown orifice I
outlet. isolation valves 1/2CV8149A, B & C, the excess letdown heat exchanger inlet isolation valves 1/2CV8153A &
B, and the regenerative heat exchanger letdown inlet isolation valves 1/2CV8389A & B would go to their fail closed positions. Additionally, the ability to normally make-up reactor coolant inventory and adjust the reactor chemical shim (i.e. normal boration/ dilution) would also be lost as the regenerative-heat exchanger inlet isolation-valves 1/2CV8324A & B would fail to their respective closed positions.
3.
Loss of Component Cooling to Containment Penetrations -
The loss of instrument air supply would cause the penetration cooling supply flow control valve 1/2CC053 to go to its fail closed position..The loss of penetration cooling'would result in elevated temperatures being imposed l
on the penetrations being supported by the component cooling i
system.
l 4.
Loss of Personnel Breathing Air -
f The loss of Instrument Air supply to the Service Air downstream isolation valve 1/2SA033 would cause this valve to go to its fail close position. This loss of Service Air j
in the cantainment building would eliminate the normal source of supplied breathing air needed to support numerous maintenance and component inspection activities in a contaminated environment.
i b.
1/2IA091 l'
Check valves 1/2IA091 provide the air supply to maintain the 1/2IA066 valves in the open position. Testing of the 1/2IA091 valves in the closed position would force the 1/2IA066 valves to their fail closed position, by design, causing loss of instrument air to containment. Loss of Instrument Air would result in scenarios such as those previously listed.
I i
l t
(9997D/WPF/083094) 4.6 Page 29 of 74
l Rev. 13 RELIEF REOUEST VR-10 (continued) l 8.
Acolicable Statust This relief is request once per quarter during the first inspection interval.
9.
Acoroval Status:
09/15/88 - Relief denied per SER 12/16/88 - Revised (to address NRC concerns) in Byron response to SER (Byron Station Letter 88-1321) 09/14/90 - Relief for Part A granted per SER 01/23/92 - Reorganized to indicate safety function of all valves and to add backflow test-(BT) of check valves 1/2IA091 e
I l
i l
l (9997D/WPF/083094) 4,6 Page 30 of 74
{
i l
i 1/2 IA091 i
o l
Y a
i i
E e
Y U
T IA091 p'. _ _
+
O O
L\\ s t
8 g
IA066 IA065 Inboard Cnmt Outboard Cnmt isol Viv Isol Viv i
t GENERAL DIAGRAM FOR INFORMATION ONLY M55-4
l Rev. 13 f
RELIEF REOUEST VR-11
" DELETED" Deleted relief request VR-11 per EG & G recommendation. This was a request for extension of position indication tests from every two years to every three years.
l i
l (9997D/WPF/083094) 4.6 Page 31 of 74
Rev. 13 I
RELIEF REOUEST VR-12 1.
Valve Number: Valves that normally stroke in 2 seconds or less:
VALVE #
VALVE #
VALVE #
VALVE #
1CV8114 (open only) 2CV8114 (open ody) 1RE9157 2RE9157 1CV8116 (open only) 2CV8116 (open only) 1RE9159A, B 2RE9159A, B i
1MS018A-D 2MS018A-D 1RE9160A, B 2RE9160A, B 1PR066 2PR066 1RY8033 2RE9170 1PS228A, B 2PS228A, B 1SI8871 2RY8033 1PS229A, B 2PS229A, B 2SI8871 1PS230A, B 2PS230A, B 2SD002A-H 1PS9357A, B 2PS9354B 1RC014A-D 2RC014A-D 2.
Number of Items:
52 3.
ASME Code Catecorv: A&B 4.
ASME Code.Section XI Recuirements:
Verification, by trending of power operated valve times, that an increase in stroke time of 50% or more, from the previous test, does not occur, per IWV-3417 (a).
5.
Basis for Relief:
Minor timing inaccuracies, with small stroke times can lead to substantial increases (percent wise) in stroke times.
For example, a valve with a stroke time of 1 second in an initial test, and 1.6 seconds in the subsequent test, has experienced an apparent 60% increase in stroke time.
If the accuracy requirements of 1WV-3413 (b) are utiliz<ti, it could be argued that stroke times between 1 and 2 seconds could constitute as much as a 100% increase in stroke time when, in fact, only a 0.2 second increase occurred.
For instance, if the initial time was 1.4 seconds, (measured to the nearest second is 1.0 second) and if the next time is then 1.6 seconds, (measured to the nearest second is 2.0 l
seconds) the percent increase is 100%.
L (9997D/WPF/083094) 4.6 Page 32 of 74 l
Rev. 13 RELIEF REOUEST VR-12 (continued 6.
Alternate Testino:
Fast acting valves can be defined as those valves that normally stroke in 2 seconds or less. No trending of stroke time will be required, and upon exceeding 2 seconds, corrective action shall be taken immediately in accordance with IWV-3417(b).
7.
Justification:
i For small stroke times, the trending requirements are too stringent for the accuracies specified in the Code.
The alternative.specified will adequately maintain the cystem in a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
8.
Aeolicable Time Period
- This relief is requested once per quarter, during the first inspection interval.
j i
9.
Accroval Status:
a.
Relief denied per SER 9/15/88.
b.
Revised (to address NRC concerns) in Byron response to SER 12/16/88 (Byron Station Letter 88-1321),
c.
Relief granted per SER 9/14/90.
d.
Added 1/2CV8114 (open only); 1/2CV8116 (open only) ; 1PS9357A, B; 2PS9354B; 2RE9170 in Revision 13.
Relief granted per GL 89-04, Position 6.
l l
1 (9997D/WPF/003094) 4.6 Page 33 of 74
i Rev. 13 RELIEF REOUEST VR-13 1.
Valve Numbers:
1DG5182A,B 2DG5182A,B 1DG5183A,B 2DG5183A,B 1DG5184A,B 2DG5184A,B 1DG5185A,B 2DG5185A,B l
l 2.
Number of Items:
16 3.
ASME Code Cateoorv: B&C 4.
ASME Code Section XI Recuirements:
These valves are not within the scope of ASME Code,Section XI, Subsection IWV requirements.
However, the requirements for stroke timing and trending of the valves associated with the Diesel Air Start System are being mandated by the NRC as an augmented testing requirement pursuant to 10CFR50.55 (a) (g).
Therefore, valves associated with the Diesel Air Start System shall be exercised to the position required to fulfill their function during plant operation per IWV-3412 and IWV-3522.
Additionally, the stroke testing of power operated valves shall be measured to the nearest second and such stroke times trended to document continued valve operational readiness per IWV-3413(b) and IWV-3417.
5.
Basis for Relief:
The monthly Diesel Generator testing program, outlined in Byron Station's Technical Specifications and implemented by station operating procedures, exceeds the intent of the quarterly valve testing program which would be required by ASME Code,Section XI.
Additionally, the stroke timing of solenoid operated valves associated with the Diesel Air Start System is impractical due to the fast actuation of these valves.
6.
Alternate Testino:
The performance of Byron Station's Diesel Generator operability monthly surveillance will verify the operational readiness of the valves associated with the Diesel Air Start System.
This surveillance testing will require the recording of the air pressures contained in both trains A & B of the Diesel Generator Air Start Receiver Tanks both before and immediately after diesel generator start.
By the comparison of these valves between trains, the satisfactory cperation of the power operated and self-actuated check valves associated with the Diesel Air Start System can be adequately demonstrated.
(9997D/WPF/083094) 4.6 Page 34 of 74
i Rev. 13 RELIEF REOUEST VR-13 (continued) 1 7.
Justification:
l Proper valve operation will be demonstrated on a monthly basis by the verification of diesel generator air start capability.
Such verification will compare the air pressures contained in the receiver tanks both before and after the diesel generator start, thus verifying the operability of the air start control valves. The proposed testing methodology at the increased frequency satisfies the intent of the Section XI requirements without posing undue hardships or difficulties.
8.
Aeolicable Time Period This relief is requested once per quarter during the first inspection interval.
9.
Acoroval Status:
a.
Relief granted per SER 9/15/88.
I b.
Relief granted per NRC Generic Letter 89-04.
c.
Relief granted per SER 9/14/90.
i i
l i
(9997D/WPF/083094) 4.6 Page 35 of 74
Rev. 13 RELIEF REOUEST VR-14
" DELETED" Deleted relief request VR-14.
This was a request for exemption for position indicating tests for solenoid operated valves. Alternate testing allowed by the ASME Code will be used instead.
I l
(9997D/WPF/083094) 4.6 Page 36 of 74 l
l
Rev. 13 RELIEF REOUEST VR-15 1.
Valve Numbers:
1CV8481A, B 2CV8481A, B 1CV8546 2CV8546 ISI8815 2SI8815 ISI8819A-D 2SI8819A-D ISI8841A, B 2SI8841A, B 1 SIB 900A-D 2SI8900A-D 1 SIB 905A-D 2SI8905A-D 1SI8949A-D 2SI8949A-D 2.
Number of Valves; 44 3.
ASME Ccde,Section XI Recuirementst Check valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdowns per IWV-3412 and IWV-3522.
5.
Basis for Relief The full stroke exercising of check valves not stroked quarterly is required to be performed during cold shutdowns. However, the stroking of check valves 1/2SI8815, 1/2SI8900A-D, 1/2 SIB 949A-D, and 1/2SI8841A, B, associated with Emergency Core Cooling System, during cold shutdowns will induce thermal stresses on their respective reactor vessel nozzles as the Reactor Coolant System (maintained approximately 180*F) is injected with water from the Refueling Water Storage Tank (maintained approximately 65'F.
This also applies to the stroking of check valves 1/2CV8546 and 1/2CV8481A,B because the full stroke of these check valves causes stroking of 1/2 SIB 815 and 1/2SI8900A-D located in the full flow path.
Additionally, Byron Station Technical Specifications require all Safety Injection Pumps and all but one Charging Pump to be inoperable during Modes 4, 5, and 6, except when the reactor vessel head is removed.
This requirement minimizes the possibility of low temperature l
over-pressurization of the Reactor Coolant System. Therefore, check valves 1/2 SIB 819A-D, 1/2SI8905A-D, and 1/2 SIB 949A-D, cannot be full stroke exercised during routine Mode 5 cold shutdowns as required by IWV-3412 and INV-3522.
l In addition to the stroke test exercise used to verify operational j
readiness of these check valves, the act of such stroking cause the l
necessity for Technical Specification required leak rate testing of l
these valves prior to unit criticality. This testing, in conjunction j
with the stroke exercising of these check valves, adds approximately one l
week to the duration of any outage and additional radiation exposure to I
workers who must connect flowmeters and differential pressure gauges directly to pipes containing radioactive fluids.
(9997D/WPF/083094) 4.6 Page 37 of 74
~ ~ _ - -.
Rev. 13 RELIEF REOUEST VR-15 (continued) 6.
Alternate Testino I
Byron Station's Technical Specifications require routine leak rate testing to be performed on these Reactor Coolant System Boundary Isolation check valves if the unit is in Cold Shutdown for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and such leak rate testing has not been performed within.the i
previous nine months. Therefore, Byron Station will stroke' exercise check valves 1/2SI8815, 1/2SI8900A-D, and 1/2 SIB 841A, B on the same schedule. To prevent unnecessary stroking of check valves 1/2SI8815 and
- ! /2SI8 900A-D, check valves 1/2CV8546 and 1/2CV8481A, B will be stroke -
exercised on the same schedule as check valves 1/2SI8815, 1/2SI8900A-D l
and 1/2 SIB 841A, B.
Additionally, stroke exercising of check valves l
1/2SI8019A-D, 1/2 SIB 949A-D, and 1/2SI8905A-D can only be safely perforned in Mode 6 with the Reactor Vessel head removed.
Full stroke i
exercising of these check valves wi11 be performed at a minimum frequency of-once'each refueling outage.
7.
Justification:
[
r Stroke exercising the 1/2CV8481A, B, 1/2CV8546, and 1/2 SIB 815, 1/2SI8900A-D, and 1/2SI8841A, B check valves on the same schedule as their required Technical Specification Reactor Coolant System boundary l
Isolation leak rate testing will allow the coordination of testing a
activities without imposing additional check valve leak rate testing requirements. Such activity coordination will optimize testing efforts and resources while adequately maintaining the system in a state of operational readiness. Valves 1/2SI8949A-D, 1/2SI8905A-D and l
1/2SI8819A-D can not be stroked during cold shutdown without exceeding i
Technical Specification limiting condition for operation (LCO 3/4.5.3) since stroking these valves requires starting a SI pump. Stroke
{
exercising check valves 1/2 SIB 819A-D, 1/2SI8905A-D and 1/2 SIB 949A-D at i
least_once per Reactor Refueling mode of operation, will insure compliance with Byron Station Technical Specifications and minimize the
(
possibility of low temperature over-pressurization of the reactor' Coolanc System.
8.
Acolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
(9997D/WPF/083094) 4.6 Page 38 of 74 1
Rev. 13 RELIEF REOUEST VR-15 (continued) 9.
Anoroval Status:
a.
Relief granted per SER 9/15/88 for valves 1/2SI8819A-D, 1/2 SIB 905A-D, and 1/2 SIB 949A-D; relief denied per SER 9/15/88 for 1
valves 1/2SI8815, 1/2SI8841A, B, and 1/2SI8900A-D.
b.
Revised (to address NRC concerns) in Byron response to SER 12/16/90 (Byron Station Letter 88-1321).
c.
Relief granted per NRC Generic Letter 89-04, d.
Relief granted per SER 9/14/90.
l i
l (9997D/WPF/083094) 4.6 Page 39 of 74 l
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Rev. 13 DRAFT RELIEF REOUEST VR-15A 1.
Valve Numbers:
1CV8481A,B 2CV8481A,B CV Pmp Dsch 1CV8546 2CV8546 CV Pmp Comb Suction 1SI8815 2SI8815 CV Inject Comb Hdr 1SI8900A-D 2SI8900A-D CV Cold Leg Inject 2.
Number of Valves: 16 3.
ASME Code,Section XI Recuirements:
Relief is requested from both the quarterly and cold shutdown exercise frequencies for the full stroke (Ct) and backflow (Bt) tests for the above check valves as required by paragraphs IWV-3521 and IWV-3522.
5.
Basis for Relieft Safety Function 1/2SI8815 Open This valve is in the line from the Chemical'and Volume Control (CV) Centrifugal Charging pump.
Its safety function in the open direction is to permit flow of coolant from the centrifugal charging pump to the four lines which branch off and provide flow to the reactor. cold legs'during the high pressure injection phase of a safety injection.
Closed The safety function of this valve in the closed direction is to provide a redundant (back up to the 1/2SI8900A-D check valves) reactor coolant system pressure boundary (PIV).
1/2SI8900A-D Open These valves are in the four lines which branch off from the lines containing the 1/2SI8815 valves mentioned above.
Their safety function in the open direction is to permit flow of coolant from the chemical and volume control centrifugal charging pumps to the reactor cold legs during the high pressure injection phase of a safety injection.
Closed l
The safety function of these valves in the closed direction is to provide a reactor coolant pressure boundary.
(9997D/WPF/083094) 4.6 Page 40 of 74 i
l
Rev. 13
=====sr DRAFT i
RELIEF PEOUEST VR-15A (continued) 1/2CV8481A,B Open These check valves are located at the discharge of the Chemical and Volume Control charging pump. Their function is to prevent reverse flow from the charging header when the' j
pump is not in operation. The safety function in the open position is to permit flow of coolant during a safety injection.
1/2CV8546 Open This check valve is the combined suction of the charging pumps from the Refueling Water Storage Tank (RWST).
Their function is to prevent flow from the suction header.
The safety function in the open position is to' permit flow of coolant when the charging pumps.take suction from the.RWST during a safety injection.
Basis The full stroke exercising of check valves 1/2SI8815 and 1/2SI8900A-D associated with the Emergency Core Cooling System during operation would induce thermal stresses on their respective reactor vessel nozzles as the Reactor Coolant System (maintained at greater than 500
- F) is injected with water from the Refueling Water Storage Tank (maintained at i
approximately 65
- F). The 1/2CV8481A,B and 1/2CV8546 check valves are in series and cannot be full stroke exercised without causing stroking of 1/2SI8815 and 1/2SI8900A-D.
These valves cannot be exercised during cold shutdowns without increasing the possibility of low temperature over-pressurization (LTOP) of the Reactor Coolant System. The Byron Station Technical Specifications require that all Safety Injection Pumps and all but one Charging Pump be inoperable during Modes 4, 5 and 6, except when the reactor vessel head is removed to prevent this over-pressurization occurring while at low temperatures.
In addition, injecting large quantities of highly borated water from the RWST would likely delay reactor start up and the cost of processing the reactor coolant to restore the optimum boron concentration is consequential.
(9997D/WPF/083094) 4.6 Page 41 of 74
Rev. 13 l
DRAFT BELIEF REOUEST VR-15A (continued)
The 1/2SI8900A-D and 1/2 SIB 815 check valves can only be verified closed by performance of an individual leakage test or. each valve. These valves are simple lift check valves and are not equipped with an external operator or disk position indication.
It is impractical to verify them closed during power operation or during cold shutdowns.
System reconfiguration and connecting and disconnecting leak testing equipment during cold shutdowns would likely delay the return to power.
This would be costly and burdensome to the station. System redesign and i
modification would be necessary to allow testing these valves closed quarterly, which would also be costly and burdensome. Both of these t
t I
alternatives would provide no compensating increase in plant safety.
6.
Alternate Testino:
I l
Byron Station will full stroke exercise (open--Ct; close--Bt) the-1/2SI8815 and 1/2 SIB 900A-D on a refueling frequency test schedule.
These valves are verified closed in conjunction with the Technical Specification pressure isolation valve leakage test.
Check valves 1/2CV8481A, B; 1/2CV8546 cannot be full stroke exercised without causing stroking of 1/2 SIB 815 and 1/2 SIB 900A-D, therefore they will be full stroke exercised on the same schedule (refueling frequency) as the 1/2SI8815 and 1/2SI8900A-D valves.
7.
Justification Based on the guidance provided in question 24 of the "Public Meeting notes on Generic Letter 89-04":
check valves possessing safety functions in both the open and closed direction should be stroked to the open position and then tested in the closed position.
For the 1/2SI8815 and 1/2SI8900A-D valves, it is best to perform the backflow (Bt) test, which in this case is accomplished in conjunction with the leakage test (Lt), on the same frequency as the full flow (Ct) test, thus stroking them to their open position and then testing in their closed position.
Check valves 1/2CV8481A, B and 1/2CV8546 cannot be full stroke exercised without causing stroking of 1/2SI8815 and 1/2 SIB 900A-D because of the system configuration. Therefore,1/2CV8481A/B will be full flow (Ct) and backflow (Bt) tested in conjunction with the 1/2SI8815 and 1/2SI8900A-D full flow test (B train backflow tested during A train full flow and vice versa). The 1/2CV8546 will also be full flow (Ct) tested in conjunction with the full flow test of the 1/2SI8815 and 1/2SI8900s.
(9997D/WPF/083094) 4.6 Page 42 of 74
Rev. 13 r
IRELTEFREOUESTVR-15A(continued)
DRAFT 7.
Justification (continued)
In addition, the high pressure (from CV pumps) safety injection check valves will have their seat tightness demonstrated during the Byron Station Technical Specification testing required to verify the pressure isolation capability of these valves under the following conditions:
a.
At least once per 18 months.
b.
Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months.
c.
Prior to returning the valve to service following maintenance, repair or replacement work on the vr41ve, and d.
Within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to manual action l
or flow through the valve.
l l
The alternate test frequency will adequately maintain this portion of~
l the safety injection system in a state of operational. readiness, while not sacrificing the safety of the plant, by testing these check valves at each refueling outage, when the safety risks are minimal, 8.
Aeolicable Statusr i
This relief is requested for the first inspection interval.
i l
9.
Accroval Status:
i l
l a.
Braidwood has approval. Byron is submitting the same relief-
)
request anticipating a combined Byron /Braidwood program submittal in 1995. However, this is a new submittal for Byron and is not specifically approved for Byron. Approved VR-15 will be used in i
the interim.
)
(9997D/WPF/083094) 4.6 Page 43 of 74 i
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i l
Rev. 13 i
DRAFT I
RELIEF REOUEST VR-15B 1.
Valve Number:
1RH8705A,B 2RHB705A, B RH Suction Isolation Thermal / Pressure Relief 2.
Number of Valves: 4 3.
ASME Code Catecorv:
AC 4.
ASME Code.Section XI Recuirements:
Relief is requested from both the quarterly and cold shutdown exercise frequanciaa for the full stroke (Ct) and backflow (Bt) tests for the above check valves as required by paragraphs IWV-3521 and IWV-3522.
5.
Basis for Relief:
{
l Safety Punction.
1/RH8705A, B Open These valves are located on the 3/4" branch line between the 1/2RH8701A, B and 1/2RH8702A, B RH suction isolation valves.
Their safety function in the open direction is to relieve excess pressure due to thermal expansion back to the RCS when both suction isolation valves are closed in order to prevent over pressurization of the piping.
Closed i
The safety function of these valves in the closed direction is to maintain the integrity of'the reactor coolant pressure i
boundary.
The 1/2RHB705A,_B and 1/2RH8705A, B thermal / pressure relief check valves can only be verified closed by performance of an individual leakage. test'on each valve. These valves are simple spring loaded lift check valves and are not equipped with an external operator or disk position indication.
It is impractical to verify them closed during power operation or during cold shutdowns. System reconfiguration and connecting and disconnecting' leak testing equipment in conjunction with depressurizing the RCS during cold I
shutdowns would delay the return to power. This would be costly l
and burdensome to the station. System redes'ign and modification would be necessary to allow testing these valves closed quarterly,
(
which would also be costly and burdensome.
(9997D/WPF/083094) 4.6 Page 44 of 74
._~
i Rev. 13 DRAFT RELIEF RFOUEST VR-ISB (continued) 6.
Alternate Testino:
The 1/2RH8705A/B check valves will be operability tested in the open direction by verifying that the piping between the suction isolation valves is able to be depressurized through the applicable valve. The PIV leakage test will be used to verify valve closure and seat tightness.
Both of these (Ct-open, Bt-closed) tests will be performed at each reactor refueling outage.
7.
Justification Performing the exercise test requires placing the standby train of residual heat removal (RHR) in an inoperable condition and that the RCS be depressurized (requires all four reactor coolant pumps to be stopped).
This will delay reactor start up and return to power.
In addition, taking away the back/ redundant train of RHR reduces both the plant decay removal capability and the available safety margin regarding shutdown risk assessment.
Furthermore, these valves are also given specific exemption from being leakage tested (no closure test required) following flow through the suction isolations per Technical Specifications (regarding PIV testing).
l l
This alternate test frequency is adequate to maintain this portion of I
RHR in a state of operational readiness, while not sacrificing the safety of the plant, or causing undue hardship in returning to power with no compensated increase in safety.
l l
8.
Acolicable Status:
This relief is requested for the first inspection interval.
3 9.
Aceroval Status:
a.
Braidwood has approval. Byron is submitting the same Relief request anticipating a combined Byron /Braidwood program submittal i
in 1995.
However, this is a new submittal and is not specifically approved for Byron.
i l
l (9997D/WPF/083094) 4.6 Page 45 of 74
Rev. 13 DRAFT REMEF REOUEST VR-15C 1.
Valve Number:
ISI8819A-D 2SI8819A-D SI Cold Leg Inj 1SI8905A-D 2SI8905A-D SI Hot Leg Inj ISI8949B,D 2SI8949B,D SI/RH Hot Leg Inj 2.
Number of valves 20 3.
ASME Code.Section XI Recuirements:
Relief is requested from both the quarterly and cold shutdown exercise frequencies for the full stroke (CT) test and backflow (BT) test as stated in ASME Section XI IWV-3521:
" Check Valves shall be exercised at j
least once every 3 months, except as provided by IWV-3522."
5.
Basis for Relief:
Safety Function 1/2 SIB 819A-D open These valves are located in the lines going from the Safety Injection pumps to the reactor vessel cold legs. Their l
safety function in the open direction is to permit flow of j
coolant to the reactor cold legs during a safety injection.
I Closed The safety function of these valves in the closed direction is to maintain the reactor coolant system pressure boundary (PIV).
1/2 SIB 905A-D Open The safety function of this valve in the open direction is to permit flow of coolant from the Safety Injection pump to the reactor vessel hot legs during the Hot Leg Recirculation portion of a safety injection.
j Closed The closed safety function of this valve is to maintain the reactor coolant pressure boundary.
(9997D/WPF/083094) 4.6 Page 46 of 74
i I
Rev. 13 DRAFT HELIEF REOUEST VR-15C (continued) 5.
Basis for Relief:
Safety Punction (continued) 1 1/2SI8949B,D Open The safety function of this valve in the open direction is to permit flow of coolant from the Safety Injection pumps to the reactor vessel hot legs during the Hot Leg Recirculation portion of a safety injection.
Closed The closed safety function of these valves is to maintain the reactor coolant pressure boundary.
These valves cannot be full stroke exercised during operation or during routine Mode 5 cold shutdowns due to Byron Station Technical Specifications requirement that all Safety Injection Pumps and all but one Charging Pump be inoperable during modes 4, 5, and 6 (temperature less then 350' F), except when the reactor vessel head is removed (the reactor head is only removed during refueling outages). This requirement minimizes the possibility of low temperature over-pressurization (LTOP) of the Reactor Coolant System (RCS).
6.
Alternate Testina Full stroke exercising of these valves can only be safely performed in Mode 6 with the Reactor vessel head removed. Therefore, full stroke exercising and backflow testing of these valves will be performed at each refueling outage.
7.
Justification j
These check valves cannot be stroked during cold shutdown without I
exceeding Technical Specification limiting condition for operation (LCO
(
3/4.5.3).
Since stroking these valves requires starting an SI pump.
l Stroke exercising check valves 1/2SI8819A-D, 1/2 SIB 905A-D, and 1/2SI8949B,D during each reactor refueling outage, will insure compliance with Byron Station Technical Specification and will reduce the risk of low temperature over-pressurization of the Reactor Coolant System.
8.
Acolicable Status:
This relief is requested for the first inspection interval.
(9997D/WPF/083094) 4.6 Page 47 of 74 l
r Rev. 13 DRAFT RELIEF REOUEST VR-15C (continued) 9.
Acoroval Status:
a.
Braidwood has approval. Byron is submitting the same Relief l
i request anticipating a. combined Byron /Braidwood program submittal l
in 1995. However, this is a new submittal and is not specifically l
approved for Byron. Approved VR-15 will be used.in the interim.
i l
l i
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i
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i k
i f
i i
l t
i l
i i
(9997D/WPF/083094) 4.6 Page 48 of 74
(
Rev. 13 DRAFT RELIEF REOUEST VR-15D 1
i 1.
Valve Number:
1SI8841A,B 2 SIB 841A,B RH Hot Leg Inj 1SI8949A,C 2SI8949A,C SI/RH Hot Leg Inj i
2.
Number of Valves: 8 3.
ASME Code.Section XI Recuirements:
Relief is requested from both the quarterly and cold shutdown exercise frequencies for the full stroke (Ct) test and backlow (Bt) tests as stated in ASME Section XI INV-3521:
" Check Valves shall be exercised at l
least once every 3 months,.except as provided by IWV-3522."
5.
Basis for Relieft l
Safety Function 1/2SI8841A,B Open The safety function of the 1/2SI8841A,B check valve" in the open direction'is to permit flow of. coolant from th.
I Pumps to the reactor vessel hot legs during the Hot - 9 i
Recirculation phase of a safety injection.
Closed l
The safety function of these valves in the closed direction is to maintain the reactor coolant system pressure boundary (PIV).
l 1/2SI8949A,C Open The safety function of the 1/2SI8949A,C check valves in the open direction is to permit flow of makup water upon a safety injection from:
(1) the Safety Injection Pumps during the high pressure safety injection phase, or (2) the RHR Pumps during the Hot Leg Recirculation phase, to the reactor vessel hot legs.
Closed j
The closed safety function of these valves is to maintain the reactor coolant pressure boundary.
l l
(9997D/WPF/083094) 4.6 Page 49 of 74 i
\\
Rev. 13 DRAFT RELIEF REOUEST VR-15D continued 5.
Basis for Relief Safetv Function (continued)
Basis The full stroke exercising of check valves 1/2SI8841A,B and 1/2SI8949A,C, associated with the Emergency Core Cooling System (ECCS) and the Residual Heat Removal (RHR) System cannot be accomplished during normal reactor operation because of the low head developed by the RHR l
pumps (less than 250 psi) is not great enough to inject water into the (2235 psi).
j "oc In addition, the SI Pumps cannot be used to full stroke the 1/2SI8949A,C check valves at power due to:
(1) the high thermal stresses imposed on the reactor vessel nozzles, (2) the margin of safety is reduced for brittle fracture prevention, and (3) an unacceptable reactivity excursion would be created (high boron concentration and low temperature water).
Exercising these check valves in cold shutdowns is not practical, full l
or partial, because they are required by Technical Specifications to be l
leak tested if there has been flow through them. This leak rate testing l
I will cause a delay in returning the plant to power.
Flow testing and the resultant leak rate testing would cause unnecessary radiation exposure to test personnel.
6.
Alternate Testino:
These check valves will be exercised (CT-open), Bt-closed) during each refueling outage and is consistent with AMSE/ ANSI Part 10, 4.3.2.2 l
regarding deferral of check valve exercising until refueling outages, I
which was approved in rulemaking to 10CFR 50.55a effective September 8, 1992. The closure test is done in conjunction with the leak test.
l l
l l
I l
(9997D/WPF/083094) 4.6 Page 50 of 74
Rev. 13 DRAFT RELIEF REOUEST VR-15D continued 7
Justification:
Based on the guidance provided in question 24 of the "Public Meeting notes on Generic Letter 89-04":
" Check valves possessing safety functions in both the open and closed direction should be stroked to the open position and then tested in the closed position.
For the 1/2SI8841A,B and 1/2 SIB 949A,C valves, it is best to perform the backflow (Bt) test, which in this case is accomplished in conjunction with the leakage test (Lt), on the same frequency as the full flow (Ct) test, l
thus testing them to their open position and then to their closed position.
The alternate test frequency is adequate to maintain this portion of RHR l
in a state of operation readiness, while not sacrificing the safety of the plant, or causing undue hardship in returning to power with no l
compensating increase in safety.
8.
Acolicable Status This relief is requested for the first inspection interval.
9.
Accroval Status a.
Braidwood has approval. Byron is submitting the same Relief request anticipating a combined Byron /Braidwood program submittal in 1995.
However, this is a new submittal and is not specifically approved for Byron. Approved VR-15 will be used in the interim.
l l
l l
i (9997D/WPF/083094) 4.6 Page 51 of 74 l
Rev. 13 RELIEF REODEST VR-16 i
1.
Valve Numbers:
1SI8811A, B 2SI8811A, B 2.
Number of Valves:
4 3.
ASME Code Cateoorv: B 4.
ASME Code.Section XI Recuirements:
Valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdowns per IWV-3412.
i 5.
Basis for Relief:
i The full stroke exercising of valves not stroked quarterly is required to ha performed during cold shutdowns. However, the stroking of the Containment Sump Outlet Isolation Valves, 1/2SI8811A, B requires the suction of the Residual Meat Removal Pumps to be drained, thus rendering one train of the system inoperable.
For Cold Shutdown operations with the Reactor Coolant Loops filled and one train of Residual Heat Removal declared inoperable, 3yron Station's Technical Specifications require two steam generators with a secondary side narrow range water level greater than 41% (Unit 1) and greater than 18% (Unit 2).
However, if the cold shutdown was necessitated by a problem requiring draining of the secondary side of the Steam Generators (i.e. tube leaks), Byron Station's Technical Specification 3.4.1.4.1 would preclude the testing of the containment sump outlet isolation valves until such time as the affected steam generators had been refilled.
For Cold Shutdown operations with the Reactor Coolant Loops not filled (i.e. drained down to support Reactor Vessel Incore Seal Table, Loop Stop Valve, Reactor Coolant Pump and Seal Maintenance or primary leakage), Byron Station's Technical Specification 3.4.1.4.2 would preclude the testing of the Containraent Sump Outlet Isolation Valves as it mandates that "two residual heat removal (RHR) Loops shall be operable and at least one RHR Loop shall be in operation".
6.
Alternate Testino:
Byron Station will full stroke exercise the Containment Sump Outlet Isolation Valves, 1/2SI8811A, B during refueling outages vice cold shutdown.
(9997D/WPF/083094) 4.6 Page 52 of 74
Rev. 13 RELTEF REOUEST VR-16 (continued) 7 Justification; The full stroke testing of the 1/2SI8811A, B valves; in conjunction with system drainir,, filling and venting of each train, accounts for an additional six days (3 cays per train) of scheduling requirements and increased radiation dose to operators and radiological control personnel.
Processing of thousands of gallons of containment water, and J
subsequent required liquid effluent discharges would also result from the draining, refilling and venting of the RHR system. This time duration required to perform the surveillance testing of the Containment Sump Outlet Isolation Valves during Cold Shutdown activities, could, as a result, cause a violation of the action requirements for Byron Station's Technical Specifications 3.4.1.4.1 and 3.4.1.4.2.
The violations would occur since these action statements require (as noted in their respective foot note sections) the return of the inoperable residual heat removal loop to service within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, if such loop was removed for surveillance testing provided the other RHR Loop is operable and in operation.
In addition, NRC Generic Letter 88-17, Loss of Decay Heat Removal, highlights the consequences of a loss of RH during reduced Reactor Coolant System inventory (below three feet below the reactor vessel flange).
If the operating RH pump is lost due to air entertainment, and the other train is inoperable for the stroke test, then the " operable" train must be vented to restore decay heat removal. Under worst conditions, boiling in the core would occur in approximately 10 minutes, the core would be uncovered in approximately 30 minutes, and fuel damage would occur in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Given the apparent disparity between the Technical Specification time requirem.nts for an inoperable RHR Loop return to service (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and the time required to perform surveillance stroke testing of the Containment Sump Outlet Isolation valves (3 days) during Cold Shutdown, the proposed alternate testing frequency of refueling outage periodicity will adequately maintain the system in a state of operational readiness, while not imposing undue hardships or sacrificing the safety of the plant.
8.
Aeolicable Time Period:
This relief is requested once per quarter, during the first inspection interval.
9.
Accroval Status:
a.
Relief denied per SER 9/15/88.
b.
Revised (to address NRC concerns) in Byron response to SER l
12/16/90.
c.
Relief granted per SER 9/14/90.
(9997D/WPF/083094) 4.6 Page 53 of 74 l
l Rev. 13 RELIEF REOUEST VR-17 1.
Valve Numbers:
1SX101A 2SX101A 2.
Number of Valves:
2 3.
ASME Code Catecorv: B 4.
ASME Code. Sectinn XI Recuirements:
Stroke time and trend the stroke time for power operated valves per IWV-3413 and IWV-3417.
5.
Basis for Relief:
1/2SX101A are the essential service water outlet isolation valves for the Unit 1/2 motor driven auxiliary feedwater pump lube oil coolers.
Thece valves are completely encapsulated per design and do not have local or remote position indicators which could be used to time the valve stroke.
6.
Alternate Testina:
1/2SX101A will be verified to open during each quarterly ASME surveillance of the motor driven auxiliary feedwater pumps.
In addition, these valves are stroked monthly during auxiliary feedwater pump surveillance required by Byron Station Technical Specifications.
7.
Justification:
These valves will be stroke exercised to their required safety positions each month during the motor driven auxiliary feedwater pump surveillances. This testing will adequately maintain the system in a state of operational readiness, while not sacrificing the safety of the plant.
8 Acolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
9.
Aceroval Status:
a.
Relief granted per SER 9/15/88.
b.
Relief granted per NRC Generic Letter 89-04.
I c.
Relief granted per SER 9/14/90.
l 1
l l
l (9997D/WPF/083094) 4.6 Page 54 of 74 i
Rav. 13 RELIEF REOUEST VR-18
" DELETED" Deleted relief request VR-18 and re-organized into several new and existing relief requests per NRC suggestion:
VR-5, VR-8, VR-9, VR-10, VR-23, and VR-24.
l (9997D/WPF/083094) 4.6 Page 55 of 74
Rev. 13.
RELIEF REOUEST VR-19 1.
Valve Numbers:
1AF001A 2AF001A l
1AF001B 1AF001B 2.
Number of Valves:
4 3.
ASME code catecorv:
C 4.
ASME Code.Section XI Reauirement:
Exercise check valves to the position required to fulfill their function (Bt/ Closed, Ct/Open), unless such operation is not practical during plant operation, per IWV-3522.
5.
Basis for Relief:
The 1/2AF001A/B valves are the suction check valves to the AFW pumps from the condensate storage tanks, and function to prevent backflow of essential service water if that suction source is required.
It is undesirable to full stroke open these valves quarterly due to the transients placed on the feedwater system and the thermal stresses imposed on the steam generator (S/G) nozzles (refer to program note 12).
j With respect to acoustically testing these valves to prove closure, versus disassembly, the operating surveillance procedure used for the auxiliary feedwater (AFW) check valve cold shutdown full stroke test is written to test a single train of AFW at a time. With an AFW pump l
running on mini-flow recirculation, flow is initiated to each S/G on a l
gradual basis, while simultaneously reducing feedwater flow. As soon as the required flow data is obtained, AFW flow is gradually reduced, while simultaneously increasing feedwater flow, to minimize feedwater flow I
perturbations to the S/Gs. Due to this gradual change in flow, the open and close acoustical impacts cannot be observed from that of the flow noise.
l However, the acoustic data taken during the 18 month dual pump injection test, has provided sufficient data to determine valve disk closure (refer to SMAD Report M-6479-91, dated 10-28-91).
This test is scheduled during the shutdown process, preceding reactor refueling, due l
to the large transient placed on feedwater flow and the. thermal stresses l
imposed on the S/Gs.
The application of RCM (Reliability Centered Maintenance) to the AF system has both concluded and recommended that performing acoustic monitoring on a 3 year frequency is sufficient to detect if the check valves fail to close.
The failure analysis process required that the functional failures identified be evaluated using the failure modes and effects analysis (EMEA). The M3EA provides a format for identifying the dominant failure modes of component failures leading to a functional i
failure and the impact of each component failure locally at the component, on the system, and on the plant.
l i
(9997D/WPF/083094) 4.6 Page 56 of 74
- - ~ ~
Rev. 13 m.TEF REOUEST VR-19 (continued) 5.
Basis for Relieff (continued)
Additionally, the closure capability of these valves cannot be verified adequately by performing a back pressure test due to the multiple boundary isolation points. The system configuration makes it impossible to assign any observed leakage to any individual valve or component-using standard mass make-up or pressure decay. techniques.
6.
Alternate Testino:
The 1/2AF001A and 1/2AF001B suction check valves will be. acoustically tested for closure (Bt) at each refuel outage in conjunction with the l
AFW full flow test and equipment response time of the AFW pumps. The open stroke (Ct) test will be tested during cold shutdowns, or at least once during each refueling cycle (approximately 18 months),
7.
Justification:
Performing a pressure test to verify closure is impractical due to the system configuration. To perform this test it would be necessary.to attach a pump or some other type of pressure source to a test connection and pressurize the.line containing the valve. However, this line also contains many potential leakage paths (valves, pump seals, and instruments). It is not possible to assign a leakage value to any specific path using available methods of seat leakage testing.
Maintenance history and previous inspections of these valves at both Byron and Braidwood stations has shown no evidence of degradation or physical-impairments.
Industry experience, as documented in NPRDS, has j
shown no history of problems with these valves. A company wide et
,4 valve evaluation addressing the 'EPRI Application Guidelines for Check Valves in Nuclear Power Plants" revealed that the' location, orientation and application of these valves are not conducive to the type of wear or degradation correlated with SOER 86-03 type problems.
l Acoustic testing provides ample information relative to valve condition, without physically taking the valve apart for visual inspection to prove valve closure. These valves are of the same design (manufacturer, size, model, and materials of construction) and have the same service conditions, including orientation. Upon abnormaloor questionable acoustic test results, the valve will be scheduled for disassembly'and internal visual inspection.
The results of this inspection will be used to further evaluate the standby train valve as well, for possible action. This type of alternate testing provides more than' adequate assurance of both valve functional and operational requirements.
I The alternate test method is sufficient to ensure both functional and operational requirements are met based on RCM failure mode and effect analysis for these valves.
(9997D/WPF/083094) 4.6 Page 57 of 74 l
Ilev. 13 RELIEF REOUEST VR-19 (continued) 8.
Acolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
9.
Ancroval Status:
a.
Relief granted per NRC Generic Letter 89-04.
b.
Revised to include more detail on only AF valves in response to 5/7/91 NRC teleconference; relief granted per Generic Letter 89-04.
c.
Relief granted per SER dated 01/31/92, provided licensee complies with Generic Letter 89-04, Position 2.
d.
Per the NRCs recommendations in SER 01/31/92, non-intrusive diagnostic techniques have been incorporated in Revision 12, along with more descriptive information. Braidwood also has this relief.
Relief granted per Generic Letter 89-04.
l l
(9997D/WPF/083094) 4.6 Page 58 of 74
l Rev. 13 i
RELIEF REOUEST VR-20 l
1.
Valve Numbers:
1/2AF006A 1/2CV8116 1/2PS9357A,B 1/2 SIB 813 1/2AF006B 3/2CV8152 1/2RE1003 1/2SI8814 1/2AF013A-H 1/2CV8160 1/2RE9170 1/2SI8821A,B 1/2AF017A,B 1/2CV8804A 1/2RF026 1/2SI8835 1/2CC685 1/2FP010 1/2RF027 1/2SI8840 1/2CC9412A,B 1/2 FWO O 9A-D 1/2RH8701A,B 1/2 SIB 880 1/2CC9413A 1/2FWO35A-D 1/2RH8702A,B 1/2SI8888 1/2CC9414 1/2FWO39A-D 1/2RY455A 1/2 SIB 920 1/2CC9416 1/2FWO43A-D 1/2RY456 1/2SI8924 1/2CC9437A,B 1/21A065 1/2RY8000A,B 1/2SI8964 1/2CC9438 1/2IA066 1/2RY8025 1/2SX016A,B 1/2CC9473A,B 1/2MS001A-D 1/2RYB026 1/2SX027A,B 1/2CS001A,B 1/2MS101A-D 1/2RY8028 1/2SX112A,B 1/2CS007A,B 1/20G057A 1/2SA032 1/2SI114A,B 1/2CS009A,B 1/20G079 1/2SA033 1/2SX169A,B 1/2CS019A,B 1/2OG080 1SD002A-H 1/2SX173 1/2CV112B-E 1/2OG081 1/2SD005A-D 1/2SX178 1/2CV8100 1/20G082 1/2SI8801A,B 1/2VQ001A,B 1/2CV8104 1/2OG083 1/2SI8802A,B 1/2VQ002A,B 1/2CV8105 1/20G084 1/2SI8804B 1/2VQ003 1/2CV8106 1/20G085 1/2SI8806 1/2VQ004A,B 1/2CV8110 1/2PR001A,B 1/2SI8807A,B 1/2VQ005A-C 1/2CV8111 1/2PS9354A,B 1/2SI8809A,B 1/2WOOO6A,B 1/2CV8112 1/2PS9355A,B 1/2 SIB 811A,B 1/2 WOO 20A,B 1/2CV8114 1/2PS9356A,B 1/2SI8812A,B 1/2 WOO 56A,B l
2.
Number of Items:
340 3.
ASME Code Cateaorve A and B l
4.
ASME Code,Section XI Recuirementg i
Verification, by trending of power-operated valve stroke times, that an increase in stroke time of 25% or more from the previous test (for valves with full stroke times greater than 10 seconds), or 50% or more (for valves with full stroke times less than or equal to 10 seconds) does not occur, per IWV-3417 (a) (see Technical Approach and Position VA-04).
l l
r (9997D/WPF/083094) 4.6 Page 59 of 74
Rev. 13 RELTEF REOUEST VR-20 (continued) 5.
Basis for Relief; i
Trending stroke times, based on the percent change from the crevious test, as ASME Section XI requires, allows gradual degradation to occur over a long period of time without triggering the additional trending attention that increased testing frequency requires.
An improved method of component performance monitoring is proposed, which will require a valve to be placed on increased test frequency based on the percent change from the fixed reference value established via NRC Generic Letter 89-04, Attachment 1, Position 5.
6.
Alternate Testinar For all power-operated valves which normally stroke in greater than two seconds, an ALERT RANGE will be established based on reaching a given percent change from the reference value established via NRC Generic Letter 89-04.
The following table will be used as a startino coint in evaluation of this fixed ALERT RANGE:
VALUE REFERENCE REQUIRED ACTION TYPE STROKE TIME ALERT RANGE VALUE (TREF)
SOV's
> 10 sec.
(1.25) (Tref)-(1.75) (Tref)
> (1. 75) (Tref)
HOV's or or AOV's (Tref +10 sec)-(Tref +20 sec)
> (Tref + 20 sec)
MOV' s
> 10 sec.
(1.15) (Tref) - (1.25) (Tref)
> (1.25) (Tref) or or (Tref +10 sec)-(Tref +20 sec)
> (Tref + 20 sec)
Notes:
A.
Fast acting valves (valves which normally stroke in less than 2 seconds consistently) are included in Relief Request VR-12.
These valves are una assigned ALERT RANGES and are ng1 trended.
l B.
In all cases, the REQUIRED ACTION VALUE cannot exceed Technical Specification or UFSAR values, regardless of calculated values.
l l
l l
(9997D/WPF/083094) 4.6 Page 60 of 74 I
Rev. 13 RELIEF REOUEST VR-20 (continued)
C.
The above Table is a guideline and cannot cover all valves.
The ALERT RANGES and REQUIRED ACTION VALUES are selected based on the comparison between the REFERENCE VALUE, limiting value given in Technical Specifications /UFSAR, and calculated values using the table above:
l 1).
All values are rounded to the nearest whole second.
2).
Valves which serve the same function on dual trains (i.e., ICC9473A and ICC9473B) and dual units (i.e.,
ICC9473A and 2CC9473A) are assigned the same REQUIRED ACTION / ALERT RANGE VALUES based on human factors considerations, unless valve or system design difference exist between the trains / units.
Refer to IST Technical Approach and Position VA-04 for related information.
7.
Justification:
Using fixed ALERT RANGES based on the valve REFERENCE VALUE established when the valve was known to be operating acceptable will ensure that gradual valve performance degradation is monitored and evaluated, by placing the valve on increased testing frequency when the stroke time exceeds a fixed multiple of the REFERENCE VALUE. This method is superior to that required by the ASME Code in that the point of reference used to evaluate the performance trend on a valve remains fixed. This alternative utilizes the same stroke time percentage change values as required by the ASME Code to place a valve on increased frequency testing.
8.
Aeolicable Time Period:
This relief is requested once per quarter, during the first inspection interval.
9.
Acoroval Status; a.
Since this relief request is a new submittal and is not specifically addressed in NRC Generic 89-04, it is HQI approved for use.
Formal written approval from the NRC is required prior j
to implementation. Expeditious review and approval are requested.
b.
Relief granted per SER 1/31/92.
(9997D/WPF/083094) 4.6 Page 61 of 74 1
~... -....
.... -..~
.-..~.
I Rev. 13 DRAFT RELTEF REOUEST VR-21 i
- WITHDRAWN" This relief request was in draft form and was later withdrawn per SER i
9/14/90.
i i
f 4
i I
l 1
l l
I l
(9997D/WPF/083094) 4.6 Page 62 of 74
Rev. 13 INTERIM EELTEF RFOLIEST VR-22 The relief request was in interim form and was later withdrawn, l
I l
l (9997D/WPF/083094) 4.6 Page 63 of 74 i
Rev. 13 RELIEF REOUEST VR-23 1.
Valve Number (ASME Code Class)-
1RY8046 (2) 2RY8046 (2) (Primary Water supply to PRT) 1RY8047 (2) 2RY8047 (2) (Nitrogen supply to PRT) l 2.
Number of Valves: 4 1
3.
4.
ASME Code.Section XI Recuirements:
Relief requested from the 3 month test frequency for the backflow (BT) test as stated in ASME Section XI INV-3521:
" Check Valves shall be exercised at least once every 3 months, except as provided by IWV-3522".
IWV-3522 states that valves that cannot be exercised during plant l
cperation shall be specifically identified by the owner and shall be full stroke exercised during cold shutdowns.
5.
Basis for Relief:
a.
1/2RY8046 These valves are located on the Primary Water (PW) supply line to the Pressurizer Relief Tank (PRT) and to the Reactor Coolant Pump (RCP) standpipes. Their safety function in the closed direction is to provide a leak-tight barrier between the containment r
atmosphere and the environment during accident conditions. Their function in the open direction is to provide PW to the PRT and RCP standpipes.
Testing these valves to the closed position while the Reactor Coolant Pumps are in operation could result in a loss of seal flow to the pumps and eventual pump damage and/or trip.
i b.
1/2RYB047 These valves are located on the nitrogen supply line to the l
Pressurizer Relief Tank (PRT). Their safety function in the i
closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
Testing these valves to the closed position could cause the loss of the Nitrogen blanket maintained in the Pressurizer Relief Tank to prevent the creation of an explosive atmosphere.
(9997D/WPF/083094) 4.6 Page 64 of 74
Rev. 13 RELIEF REOUEST VR-23 (continued) 6.
Alternate Testina:
a.
1RY8046 These valves will be backflow tested (BT) at cold shutdown provided all of the Reactor Coolant Pumps are not in operation (RCP's will not necessarily be secured for the sole purpose of the performing this test). The testing period will be each refueling outage as a minimum, but no more frequently than once per quarter.
The backflow test will be performed in conjunction with their leakage test.
l b.
1/2RY8047 These valves will be backflow tested (BT) each refueling outage.
The backflow test will be performed in conjunction with their leakage test.
Justification:
a.
1/2RY8046 This alternate frequency will adequately maintain the system in a state of operational readiness, by testing these valves as often as safely possible. Shutting down the RCP's and the subsequent restarting incurs a reactor vessel overpressurization risk.
In addition, it is operationally undesirable due to the time and manpower involved in starting an RCP.
Also, an operator is required to observe the RCP shaft rotation upon starting.
Stopping and starting RCP's would add unnecessary radiation exposure (approximately 20 mrem),
b.
1/2RY8047 This alternate frequency will adequately maintain the system in a l
state of operational readiness, by testing these valves as often l
as safely possible. This frequency will avoid placing the plant j
in the unsafe condition which would result from removing the l
protective Nitrogen blanket from the Pressurizer Relief Tank.
I Removal of this blanket could result in the creation of an explosive mixture of Hydrogen and Oxygen.
8.
Acolicable Status:
This relief is requested once per quarter during the first inspection interval.
9.
Accroval Status:
Relief pending.
(9997D/WPF/083094) 4.6 Page 65 of 74
1 1/2RY8046,8047 n
NITROGEN i
'd M
Id SUPPLY RY8091 RY8034 RY8047 RY8033 A
PRIMARY WATER
.._. g M M UP RY8030 RY8046 RY8028 DISCHARGE w
l 0
N U
6 6
6 O
O -
O s
j D
1 E
D E
PRESSURIZER RELIEF TANK 0
c M
N T
M T
i TO
- 4..__
COOLANT PUMP STANDPIPES n
GENERAL DIAGRAM FOR INFORMATION ONLY M60-6 l
\\
i Rev. 13 RELIEF REOUEST VR-24 1.
Valve Number (Asme Code Class)-
1WOOO7A, B (2) 2WOOO7A, B (2) 2.
Number of Valves: 4 3.
f 1
4.
ASME Code.Section XI Recuirements:
Relief requested from the 3 month test frequency for the backflow (BT) test as stated in ASME Section XI IWV-3521:
" Check Valves shall be exercised at least once every 3 months, except as provided by IWV-3522".
IWV-3522 states that valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall i
be full stroke exercised during cold shutdowns.
l 5.
Basis for Relief:
These valves are located inside containment on the Chilled Water supply lines to the Reactor Containment Fan Coolers (RCFC) chilled water coils.
Their safety function in the closed direction is to provide a leak-tight barrier between the containment atmosphere and the environment during accident conditions.
l Testing these valves to the closed position on either a quarterly or cold shutdown frequency would cause undue hardship with no compensating return in plant safety.
6.
Alternate Testino:
These valves will be backflow tested (BT) each refueling outage. The backflow test will be performed in conjunction with their leakage test.
7.
Justification:
l This alternate frequency will adequately maintain the system in a state of operational readiness, by testing these valves as aften as is practical. Backflow testing of these valves during operation or at cold shutdown would involve removing this system from service for approximately three (3) days per valve to complete. This includes approximately two (2) days to drain approximately 3000 gallons of Chilled Water from the RCFC coils and approximately one (1) day to fill i
and vent the isolated portions of the piping. Therefore, the time j
required for test execution and preparation and the processing of such a large quantity of water make it impractical to perform this test on anything other than a refueling frequency.
l i
(9997D/WPF/083094) 4.6 Page 66 of 74
1/2WOOO7A/B n
O N
U s
r i
S o
i E
D E
c N
C M
N T
-M T
M
)d q
WOOO7A(B)
WOOO6A(B) i l
1 x
l I
!j l
CHILLED WATER sg.
l COILS l
3
{
E g:
Q I
X _.__._ _ %
WOO 56A(B) p WOO 20A(B) a f
l GENERAL DIAGRAM l
FOR INFORMATION ONLY l
M118-5 i
i
Rev. 13 RELIEF REOUEST VR-25 (continued) 1.
Valve Number:
1CS011A/B 2CS011A/B 2.
Number of Items:
4 3.
ASME Code Cateoorv: C 4.
ASME Code.Section XI Recuirements:
Exercise check valves to the position required to fulfill their function (open - Cts closed - Bt), unless such operation is not practical during plant operation, per IWV-3522.
5.
Basis for Relief:
The 1/2CS011A/B check valves are on the discharge of the edt'ctor and the safety function in the open direction is to allow flow from the discharge of the CS pump and the spray additive tank back to the suction g
of the CS pump.
They function in the closed direction to prevent backflow into the eductor from the CS pump suction side. These valves cannot be full or design flow (185 gpm is the design flow rate - 130 gpm eductor flow plus 55 gpm NaOH flow) tested as a matter of course during unit operation or cold shutdown as NaOH from the spray additive tank would be discharged throughout the CS system causing undesirable chemical effects on the reactor make-up supply (RWST) and associated systems.
Non-intrusive techniques (NIT) using acoustics and magnetics have not been successful in proving full stroke of the disk plates. The reason is that the critical flow rate is 10 feet per second (the amount of flow which is required to full-stroke the disks) and cannot be obtained based on current system design.
It is considered to be impractical and burdensome to attempt to disassemble valves in both trains every outage. Large amounts of reactor grade water needs to be reprocessed due to the need te drain the entire system before removing the valve from the system.
i (9997D/WPF/083094) 4.6 Page 68 of 74
Rev.
I I
RELIEF REOUEST VR-25 (continued) 6.
Alternate Testino The A and B train valves are of the same design (manufacturer, size, model n2mber, and materials of construction) and have the same service conditions, including orien:ation, therefore they form a sample disassembly group.
l l
One valve from each group, on a per unit basis, will be examined each i
refueling outage. If the disassembled valve is not capable of being l
manually full stroked exercised or if there is binding or failure of j
internals, the remaining valve on the affected unit will be inspected, l
In addition to the above, the 1/2CS011A, B valves will be partial stroke tested during the quarterly pump surveillance and af ter maintenance in order to verify that it was installed correctly.
7.
Justification:
The 1/2CS011A, B valves are removed from the system and visually l
examined per the strict detailed inspection requirements of the Station Check Valve Program. This inspection adequately verifies that the valves are maintained in a stete of operational readiness and that their performance parameters are adequately assessed. The valves are verified to be functional by performing a thorough visual inspection of the internals and by performing a manual full-stroke exercise of each disc.
The wafer type design of the valve body for these valves makes their removal a simple process, with little chance of damage to their internals. Also, there is no disassembly of internal parts required; all wear surfacers a*e accessible to visual examination. After inspection and strake testing, the valve is reinstalled into the line and post maintenance testing is performed.
l The alternate test frequency is justifiable in that maintenance history and previous inspections of these valves at both Byron and Braidwood stations has shown no evidence of degradation or physical impairments.
In addition, industry experience, as documented in NPRDS, show no history of problems with these types of valves in this service.
This data indicates that there is no significant decrease in plant safety by performing sample disassembly.
l The alternate test method is sufficient to ensure operability of these
(
valves and is consistent with Generic Letter 89-04, Position 2.
The hardship involved with full stroke exercising these check valves, if the Code requirements were imposed, does not provide a compensated increase in safety of these CS system check valves.
(9997D/WPF/083094) 4.6 Page 69 of 74 l
l I
i
Rev. 13 RELIEF REOUEST VR-25 (continued) 8.
Acolicable Time Period:
This relief is requested once per quarter during the first inspection interval.
9.
Accroval Status; a.
Relief is granted based on NRC Generic Letter 89-04, Position 2.
l l
l I
(9997D/hPF/083094) 4.6 Page 70 of 74 l
Rev. 13 RELIEP REOUEST VR-26 1.
Valve Number (Fire Protection - Inside Containment Isolation. Valve).
Check Valves IFP345 P&ID M-52-1 2FP345 P&ID M-52-1 1
2.
Number of Items: 2 3.
ASME Code Cateoorv (IWV-2200): BC i
4.
ASME Code Section XI Recuiremedit;,g IWV-3411 Test Frequency "Catagory A and B valves shall be exercised at least once every 3 i
j
' months, except as provided by IWV-3412 (a), IWV-3415, and IWV-l 3416."
i i
IWV-3412(a) Exercising Procedure i
.... Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns...."
i 5.
Basis for Relief:
The above listed valves are Fire Protection '(Water) to Containment Check valves and are designated Containment Isolation valves (CIVs). These valves are exempt from Local Leakage Rate testing of 10 CFR 50, j
Appendix J, but due to their designation as CIVs, they shall be tested in the Closed direction. The valves are physically located inside
{
containment.
Even though personnel access to the containment (outside 4
l the biological shield) while the reactor is operating is allowed, it is I
l not a routine practice. There is no flow through these valves during periods when the associated reacter is at power, and there is very l
seldom any flow through these valves during any mode of operation.
This valve is as passive as a check valve can be in the-closed position.
Testing these valves more-frequently than each associated refueling outage adds no additional confidence in the valve's closure capability but it does add to the occupational radiation exposure of those personnel required to perform the test.
6.
Alternate Testino:
The above listed valves will be tested on a refueling outage frequency to verify closure.
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Rev. 13 RELIEF REOUEST VR-26 (continued) 7.
Justification:
Testing these valves on a frequency of every three months during normal operation adds undue hardship without a compensating increase in the level of safety. Testing the valves every three months or on a cold shutdown basis adds to the occupational radiation exposure of the personnel required to perform the test.
There is normally no flow through this valve to result in the valve disc leaving the seat, therefore the valve remains passively closed during periods of normal operation.
No additional confidence in the ability of the valve to close is gained by subjecting this valve to quarterly or cold shutdown testing versus testing on a refueling outage frequency.
8.
Acolicable Time Period:
This relief request is requested to be effective immediately.
These l
valves were recently (June 1994) recognized as fitting the scope requirements as a result of an overall scope review of the Byron and Braidwood IST Programs.
9.
Accroval Status:
This is a new relief request and has not been approved.
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(9997D/WPF/083094) 4.6 Page 72 of 74 i
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i Rev. 13 RELIEF REOUEST VR-27 1.
Valve Number (Charging and Volume Control - Loop Fill Check Valve).
Check Valves 1CV8348 P&ID M-64-3B 2CV8348 P&ID M-138-3B 2.
Number of Items: 2 3.
ASME Code Catecorv (IWV-2200): BC 4.
ASME Code Section XI Recuirements:
IWV-3411 Test Frequency "Catagory A and B valves shall be exercised at least once every 3 months, except as provided by IWV-3412 (a), IWV-3415, and IWV-3416."
IWV-3412(a) Exercising Procedure
... Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns.
5.
Basis for Felief:
I The above listed valves are Reactor Coolant Loop Fill Check valves in the Chemical and Volume Control System (CV) and are designated Containment Isolation valves (CIVs). These valves are exempt from Local Leakage Rate testing of 10 CFR 50, Appendix J, but due to their designation as CIVs, they shall be tested in the Closed direction.
The i
valves are physically located inside containment approximately 14 feet l
above the floor, requiring scaffolding for access. Even though l
personnel access to the containment (outside the biological shield) while the reactor is operating is allowed, it is not a routine practice.
i There is no flow through these valves during periods when the associated reactor is at power, and there is very seldom any flow through these valves during any mode of operation. This valve is as passive as a j
check valve can be in the closed position. Testing these valves more j
frequently than every associated refueling outage adds no additional confidence on the valves clesure capability but it does add to the occupational radiation exposure of those personnel required to perform the test.
6.
Alternate Testino:
The above listed valves will be tested on a refueling outage frequency j
to verify closure.
(9997D/WPF/083094) 4.6 Page 73 of 74
Rev. 13 RELIEF REOUEST VR-27 (continued) l 7.
Justification:
Testing these valves on a frequency of every three months during normal operation adds to the occupational radiation exposure of the personnel required to perform the test.
Erection of scaffolding inside containment while at power presents unique hazards and requires j
extensive analysis and evaluation. There is normally no flow through this valve to result in the valve disc leaving the seat, therefore the valve remains passively closed during periods of normal operation. No additional confidence in the ability of the valve to close is gained by subjecting this valve to quarterly or cold shutdown testing versus
)
l testing on a refueling outage frequency.
8.
Acolicable Time Period:
This relief request is requested to be effective immediately. These valves were recently (June 1994) recognized as fitting the scope requirements as a result of an overall scope review of the Byron and Braidwood IST Programs.
9.
Accroval Status:
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This is a new relief request and has not been approved.
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(9997D/WPF/083094) 4.6 Page 74 of 74 1