ML20077K200

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Submits Justification to Extend Completion of Initial Testing Portion of GL 89-10 Re Motor Operated Valve Program at Plant
ML20077K200
Person / Time
Site: Cooper Entergy icon.png
Issue date: 01/08/1995
From: Horn G
NEBRASKA PUBLIC POWER DISTRICT
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-10, NLS950006, NUDOCS 9501100232
Download: ML20077K200 (33)
v • d • e


Text

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NEBRASKA PUBUC POWER DISTRICT P. O. BOX 499 W

W Nebraska Public Power District cOu%u's"S"AL

GUY R. HORN Vice-President, Nuclear (402) 563-5518 NLS950006 January 8,1995 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

Request for Schedule Extension; Generic Letter 89-10 Activities Cooper Nuclear Station NRC Docket 50-298, DPR-46

Reference:

1) letter (No. NLS940149) to U.S. NRC Document Control Desk from G. R.

Horn (Nebraska Public Power District) dated December 31,1994;

Subject:

Generic Ixtter 89-10 Testing Schedule

2) Generic Letter 89-10, Supplement 6, "Information on Scheduling and Grouping, and Staff Responses to Additional Public Comments"
3) Letter (No. NLS8900469) to U.S. NRC Document Control Desk from L G. Kunci (Nebraska Public Power District) dated December 28, 1989;

Subject:

Response to Generic Ietter 89-10 Gentlemen:

The Nebraska Public Power District (District) hereby submits its justification to extend the completion of the initial testing portion of the Generic Letter (GL) 89-10 Motor Operated Valve (MOV) program at Cooper Nuclear Station (CNS). The proposed schedule would extend the original completion date for the initial testing portion of the program from January 1,1995, to 120 days following completion of the next refueling outage, currently scheduled to commence October 1995. Completion within 120 days after the refueling outage will allow a sufficient period of time for the finalization of the GL 89-10 supporting documents without a significant impact on health and safety. In order to support startup from the current outage, the District requests prompt NRC review of this request.

As discussed in Reference 1, the District is submitting this extension request in accordance with the information requirements of Generic Letter (GL) 89-10, Supplement 6 (Reference 2). The District is requesting this extension as a result of several events which have resulted in a shift in the schedule for the next refueling outage (RE-16). In Reference 3, the District originally projected the completion of the CNS GL 89-10 MOV program to coincide with f 0(!

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LJ.S. Nuclear Regulatory Commission January 8,1995

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Page 2 of 4 the end to refueling outage number 16 (RE-16), planned on or about January 1,1995. Since the original schedule was developed, CNS experienced a longer than expected 1993 refueling outage (RE-15). On May 25,1994, CNS entered an unplanned shutdown which did not involve offload of the reactor fuel. This outage has involved a significant amount of unplanned high priority work.

The attachments to this letter provide the information needed to evaluate the District's justification for extending the GL 89-10 testing schedule. The attached information follows the format recommended in Supplement 6 to GL 89-10. The information is presented in three attachments.

Attachment I provides the status of GL 89-10 MOV testing as of January 1,1995.

Significant additional work will be completed prior to startup from the current outage.

Therefore, the information presented in Attachment II,in response to Supplement 6, Section 2, will only pertain to valves not dynamically tested as of January 1,1995. Attachment III provides a brief overview of the PSA ranking process. The NRC staff should note that the information provided in the submittal supersedes the information provided by the District in response to GL89-10, Supplement 3.

During initial program planning, GL 89-10 MOVs at CNS were divided into three groups in order to implement the testing during three outages. Testing during the first two outages, RE-14 and RE-15, focused on valves in high pressure or high flow systems. The systems scheduled for RE-16 include several MOVs that are operated at or near design basis conditions and in generally less severe conditions during normal plant operations.

As of January 1,1995, the work remaining in response to Generic Letter 89-10 represents a small portion of the total MOV activities undertaken at CNS. Modification work is planned to be completed prior to startup from the current outage, as delineated in Table 1 of the attachments. At the time of startup, all of the valves within the CNS GL 89-10 testing program will be reviewed against current industry information (e.g. vendor notices, Customer Service Bulletins, NRC information Notices and Part 21 Notices), set up with the best available plant data, and retested if necessary.

Based on the best available information, which is summarized in this letter and its attachments, the District has reasonable assurance that all MOVs, including those not dynamically tested by the conclusion of the current outage, will function under design basis conditions. The information provided in this submittal supports the requested schedule extension.

f

U.S. Nuclear R:gulatory Commission 2

l January 8,1995 l

Page' 3 of 4 i

If you have any questions or require additional information, please contact me.

Sincerely, l

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R. Horn i

Vic resident - Nuclear

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Attachments i

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RegioncJ Administrator USNRC Region IV t

NRC Resident Inspector-l Cooper Nuclear Station NPG Distribution i

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U.S. Nuclear Regulatory Commission Januay 8,1995 Page 4 of 4 STATE OF NEBRASKA )

)ss PLATTE COUNTY

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G. R. Horn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowle e and belief.

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f C G. R. Horn N)

Subscribed in my presence and sworn to before me this 8th day of January

,1995.

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M wep NOTAltY PUBLIC 4

f Attachment I to NLS950006 i

Page 1 of 2

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Generic Iatter 89-10 Supplement 6 Justification for Schedule Extension Supplement 6. Section 1 Information: Comoletion Status of GL 89-10 Program'at CNS l

Pmgram Overview

. As of Janua 1,1995 the status of actions reganiing GL 89-10 at the Cooper Nuclear Station is presented n the following section and Table 1. This information is presented in accordance with Supplement 6 to Generic letter 89-10.

By applying specific selection and exclusion criteria, as identified in GL 89-10 and its t

supplements, the population determined by the District to be within the GL 89-10 program consists of 82 motor-operated valves.

j An overview of the current status of the GL 89-10 pmgram at CNS is presented below:

j Total MOVs in the pmgram 82 j

' Design review completed 82 Static testing Total Required 82 l

Completed as of 01/01/95 52 Total completed by plant staitup 82 Dynamic Testing Total Required 52 Completed as of 01/01/95 33 Total to be completed by plant startup 35 Completed by the end of RE-16 52 As the above summary indicates, the current CNS MOV GL89-10 Pmgram calls for dynamic testing (DP testing) of 52 valves out of the 82 total GL 89-10 MOVs. To date 33 MOVs have been DP tested, with 19 initial DP tests remaining to be perfonned (Four previously performed

]

DP tests will require retests). All of the 82 MOVs have been ranked according to the relative j

risk significance in accordance with the methodology' described in Table 3.-

Of these 23 remaining tests, four involve MOVs having a "High" PSA ranking and four have a " Medium" ranking. Two of the "High" PSA ranked MOVs will be DP tested prior to restart from the current outage. The two remaining "High" ranked MOVs are globe valves which are required to open and are flow assisted in the open direction. These two "High" ranking MOVs and the four MOVs with " Medium" rankings are judged to have sufficient margin to provide confidence regarding their operability.

The approach used in the Pmbabilistic Safety Assessment (PSA) risk ranking is described in -

Table 3.

i

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P Attachment I to i

3 NLS950006 l

Page 2 of 2.

l Calculational Methodolorv Overview Detailed pmcedures addressing calculational methodologies used in the design-basis calculations, as well as in MOV capability / switch setting calculations, are contained in approved procedures.

Wedge type gate valves are set up using an industry accepted valve factor of 0.5, unless dynamic testing results on a specific valve justifies use of a lower valve factor. Globe valves are set up using an industry accepted valve factor of 1.1. Where applicable, these valve factors are verified i

during analysis of differential pressure (DP) testing.

The CNS calculational methodology addresses known uncertainties using the best information available, and include:

Rate of loading effects...........................

5 - 10 %

Stem lubricant degadation

.,.....................5%

i Torque switch repeatability 5 - 20 %

Springpack relaxation (where applicable)................ 4% (Typ)

Appropriate test equipment errors................... 9 - 18 % (Typ)

Comprehensive information for each of the progam MOVs is presented in Table 1, Coooer Nuclear Station GL _89-10 MOV InformeiQD. Those valves for which static testing is incomplete at this time will be statically tested by plant startup.

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Table 1 CNS GL 89-10 Supplement 6 Response i

G.L. 89-10 Motor Operated Valve Status Information as of Jan.1,1995

~

l Teming

% of MEDP Open Available Close Available MEDP Stem

Statu, Temed Valve Factor Valve Factor Valve Actuator Type of Closure Friction Valve Safety CIC No.

Type Sire Type Sire Contml Open Closed Factor Factor Directinn (Static /DP)

Open Closed MMor MaxCST MMor MatCST CS-MO5 A Gate 3*

SMB 00-5 Torque 3R5 379 0.2 0.5 Both 2-Both 8R.2 89.6 1.33 1.31 1.55 1.18 CS-MoiB Gate 3*

SMB 00-5 Torque 385 379 0.2 0.5 Both Both 97.3 95.8 1.33 1.31 1.55 1.15 CS-MO7A Gete 14*

SB 0-25 Torque 6

3R 0.2 0.5 Close a Both 1,680.0 265.26 11.02 10.59 2.17 1.65 CS-MO7B Gate 14*

SB 0-25 Torque 6

38 0.2 0.5 Close a Bmh 1,300.0 205.26 10.%

10.59 2.15 1.65 CS-M012 A Gate 10" SB 2-40 Tneque 454 350 0.2 0.5 Both a Both 105.7 0.59 0.54 0.82 0.R2 CS-Mol2B Gate 10*

SB 2 40 Torque 414 350 0.2 0.5 Both Static 0.55 0.55 0.86 0.36 HPCI.M014 Gate 10" SB 1-60 Torque 1091 0

0.15 0.43 Open 3-Both R4.72 0.50 0.50 HPCI-Mol 5 Gate 10*

SMB l-25 Tocque 1091 161 0.2 0.43 Clone Static 0.64 0.53 4.86 3.21 HTCI-Mol5 (H)

Gate 10*

SMB 1-25 Torque 1091 0.2 0.5 Close Static 0.78 0.78 HPCI-M016 Gate 10*

SMB 1-40 Torque 1091 161 0.15 0.41 Cinae 3-Static 0.73 0.62 3.11 3.11 HPCI-MOl6 (H)

Gate 10*

SMB l 40 Torque 1091 0.15 0.5 Close 3-static 0.61 0.61 HPCI-M017 Gate 16*

SMB 00-15 Torque 15 9

0.2 0.5 Close a Bah 26.22 67.63 5.80 3.18 9.62 5.26 HPCI-M019 Gate 14*

SB 3-150 Torque 1164 1164 0.2 0.5 Open 3-Static 0 57 0.57 0.59 0.52 HPCI-MO25 G%e 4*

SB 1-40 Torque 1300 1300 0.2 1.1 Both 3-Statie 2.30 1.85 1.85 1.54 HPCI-MO58 Gate 16*

SMB 00-15 Torque 95 3R 0.2 0.48 Open 4-Both 100.0 0.9 0.5 2.27 1.24 MS-MO74 Gate 3*

SMB 000-5 Torque 1107 1106 0.2 05 Clone 3-Static 0.R8 0.77 0.86 0.54 MS-MO77 (V)

Gete 3*

SMB 000-5 Tnniue 1107 1106 0.2 0.5 Close 5-Bah 24.82 R4.9 0.35 0.77 0.59 0.54 PC-230MV Butter 0y 24" SMB 00-15 Linst 17 43.7 CInse 1-None

  • 195.34 %
  • 195.34 %
  • I29.56 %
  • t 29.56 %

PC-231MV Butterly 24" SMB 00-15 Limit 17 60.9 Clone 1-None

  • 220.7 %

'205.54 %

  • l19.55 %
  • 113.44 %

PC-232MV Butterly 24*

SMB 00-15 Limit 1.75 46.2 Close 1-None

  • 255.48 %
  • 155.48 %
  • 130.61 %
  • 130.61 %

Page I of 5

Tabb 1 CNS GL 89-10 Supplement 6 Response G.L. 89-10 Motor Operated Valve Status Information as of Jan.1,1995 l

Testing

% of MEDP Open Available Close Available MGP Stem Status Tested Valve Factor Valve Feetor Valve Actuato' Type of l

Closure Frictico Valve Safety CIC No.

Type Sire Tvre Sire Control Open Cloned Factor Factor Direction (Static /DP)

Open Cloned Motor MaxCST Mcwor MaxCST PC-233MV Butterfy 24*

SMB on-15 13mit 62.7 29 Clone 1-None

  • 107.04 %
  • I07.04 %
  • 163.45 %
  • 163.45 4 l

PC-305MV Gate 2*

SMB 000-2 Torque 77.4 44 0.2 0.5 Chwe Both 1.18 1.18 4.80 4.80 11.01 10.49 l

PC-306MV Gate 2*

SMB 000-2 Torque 77.4 61 0.2 0.5 Clone Emh 0.59 0.R9 5.04 5.04 3.32 8.32 l

PC-130lMV Gste 1*

SMB 00rL2 Torque 1.75 29 0.2 0.5 Close a Both I.650.0 113.79

> 20

> 20

> 20

> 20 l

l PC-1302MV Gate l'

SMB 000-2 Torque 1.75 29 0.2 0.5 Close a B<wh 1550.0 106.9

> 20

> 20 -

> 20

> 20 PC-1303MV Gate 1*

SMB 000-2 Twque 29 29 0.2 0.5 Clo=e 1-None

> 20

> 20

> 20

> 20,

l PC-1304MV Gate 1*

SMB 000-2 Torque 29 29 0.2 0.5 Clone 1-None

> 20

> 20

> 20

> 20 PC-1305MV Gate 1*

SMB 000-2 Torque 46.2 46.2 0.2 0.5 Clone 1-None

> 20 13.99

> 20 13.51 PC.1306MV Gate 1*

SMB On0-2 Torque 46.2 46.2 0.2 0.5 Close 1-None

> 20

> 20

> 20

> 20 PV-130AMV Gate 1*

SMB 000-2 Torque 14.7 14.7 0.2 0.5 Clone 1-None

> 20

> 20

> 20

> 20 I

PC-1310MV Gate l'

SMB 000-2 Torque 14.7 14.7 0.2 0.5 Clone 1-None

> 20

> 20

> 20

> 20 l

PC-1311MV Gate 1*

SMB 000-2 Torque 1.75 46 0.2 0.5 Close a Both 2300.0 100.0

> 20

> 20

> 20 14.72 l

PC-1312MV Gate l'

SMB 000-2 Torque 1.75 46 0.2 0.5 Clone A Brah 2.325.0 101.00

> 20

> 20

> 20

> 20 RCIC-MO15 Gate 3*

SMB 000-5 Torque 1001 28 0.2 0.5 Clone 3-static 0.61 0.59 6.82 5.6 l

RCIC Mol5 00 Gate 3*

SMB 000-5 Torque 1091 0.2 0.5 Clone 3-Static 0.51 0.51 RCIC-moi 6 Gate 3*

SMB 000-5 Torque 1091 38 0.2 0.5 Close 3-Static 1.05 0.59 6.65 5.59 RCIC-MOl6 Of)

Gate 3*

SMB 00n-5 Torque 1091 0.2 0.5 Close 3-Static 0.76 0.76 1

RCIC-MOIR Gate 6*

SMB 000-5 Torque 30 9

0.2 0.5 Close A Both 27.67 292.22 3.44 3.44 10.95 10.95 RCIC-MO21 Gate 4*

SMB 00-10 Torque 1170 1170 0.2 0.5 Open 34tatie 0.71 0.71 0 69 0.69 RCIC.MO27 Globe 2*

SMB 00-15 Torque 1256 1256 0.2 0.2 Iwh 3-Statie 2.62 2.62 2.55 2.55 RCIC-MO41 Gate 6*

SMB 000-5 Toraue 88 39 0.2 0.5 Onen 3-s Both 100.L 1.62 1.62 3.44 3.44 Page 2 of 5

Table 1 CNS GL 89-10 Supplement 6 Response G.L. 89-10 Motor Operated Valve Status Information as of Jan.1,1995 l

Tesing

%cfMEDP Open Available Close Avei!able MEDP Stem Status Temed Valve Factor Valve Factor Valve Actuator Type of Closure Friction Valve safety CIC No.

Type Sire Type Sire Conernl Open Cloned Factor Factor Direction Static /DP)

Open Closed M Mor Max CST M< wor MetCST l

RCIC-Mol31 Globe 3*

SMB 00-10 Torque 1091 0

0.2 1.1 Open Static 1.36 1.36 RCIC-MO132 Globe 2*

SMB 000-5 Tontue 1260 36 0.2 0.2 Open Statie 3.29 2.44

> 20

> 20 REC 700MV Gate 10*

SMB 00-10 Torque 65 26 0.2 0.5 Close 1-None 1.99 1.90 1.83 1.61 R EC-702MV Gate S'

SMB 000-5 Torque 65 82 0.2 0.5 Clone 1-None 1.67 1.14 1.61 0 R6 REC 700MV Gate 8*

SMB 000-5 Torque 65 R2 0.2 0.5 Clone 1-None 1.67 0.97 1.61 0.72 REC-711MV Gate 6*

SMB 00lL5 Torque 27 100 0.2 0.5 Open I-None 1.26 1.26 1.23 1.16 REC-712MV (mfd)

Butterfly 12" SMB 000-2 Umit 65 108 Close 1-None

  • 18.78 %
  • l2.72 %

+4.65 %

'4.65 %

R EC-713MV (MID)

Butterfly 12*

SMB 000-2 Umit 65 108 Clo=e I-None

  • 18.27 %
  • 18.27 %

+4.19 %

'4.19 %

REC 714MV Gate 6*

SMB 000-5 Torque 87 109 0.2 0.5 Open I-None 1.25 1.17 1.22 0.87 REC-1329VV Gate 8*

1MB 00-15 Torque 65 53 0.2 0.5 Clone 1-None 4.24 1.09 4.10 1.46 R HR-MO13 A Gate 20" SMB 0-15 Torque 114 38 0.2 0.5 Open a Bah 87.19 261.58 0.86 0.60 3.13 1.76 RHR-MOI 3B Gate 20-SMB 0-15 Torque 114 38 0.2 0.5 Open a Bcwh 93.86 221.58 0.R6 0 60 3.14 1.76 RIIR-M013C tb 20*

SMB 0 15 Torque 114 3R 0.2 0.5 Open a Borb 88.95 266.84 0.R5 0.60 3.10 1.76 RHR-MOl3D Gate 20*

SMB 0-15 Torque 114 33 0.2 0.5 Open a Both 91.23 273.6%

0.R7 0.60 3.18 1.76 RHR-M016 A Gate 4*

SMB 000-5 Torque 320 303 0.2 0.5 BMh Both 87.13 92.01 1.14 0.95 1.36 0.26 RHR-Mol6B Gate 4*

SMB 000-5 Torque 320 303 0.2 0.5 Both 3-Bosh 98.8 104.3 1.0R 0.7' I.32 0.67 RHR-Mol?

Gste 20" SMB 240 Tongue 99 100 0.2 0.5 Close Static 0.8R 0.8R 0.79 0.79 RHR-Mo1R Gate 20" SMB 2 40 Torque 93 98 0.2 0.5 Clone Static I.36 1.36 1.81 1.81 R HR-MO25 A Gstt 24*

SB 3-30 Torque 164 75 0.2 0.5 Both Both 104.83 229.33 0.63 0.63 1.07 1.07 RHR.MO25 B Gate 24' SB 3-30 Torque 164 75 0.2 0.5 Bah 4-a Both 103.6 0.64 0.64 1.08 1.08 RHR-MO27A Globe 24*

SB 4-250 Toraue 385 303 0.2 1.1 Both 3-Both 72.49 92.11 1.57 1.57 2.80 2.25 Page 3 of 5

Tabl21 CNS GL 89-10 Supplement 6 Response G.L. 89-10 Motor Operated Valve Status Information as of Jan.1,1995

=

. - -- man Tening

% of MEDP Open Availasle Clone A&la MEDP Stem Status Tered Valve F= or Valve Factor Valve Actuator 77p, or Closure Fnctmn Valve Safety C1C No.

Type Si7e Type Sire Control Open Clmed Factor Feetor Direction (Static /DP)

Open C1med Mesor Max CST Motor MaxCST RHR-MO27B Gh+e 24*

SB 4-250 Torque 385 303 0.2 1.1 h4 4-Static 1.86 1.86 3.36 2.25 RHR-MO34A Globe 18" SMB 4-200 Torque 303 320 0.2 1.1 Bah he 104.6 99.0 4.57 3.24 5.74 2.89 RilR-MO34B Globe 18' SMB 4-200 Torque 303 320 0.2 1.1 Both Both 101.3 95.88 4.43 3.24 5.55 2.89 RHR-MO39 A (D)

Gate 18*

SMB 1-25 Torque 303 303 0.2 0.48 Both Bh 106.2 106.2 0.65 0.53 0.88 0.50 R HR-MO39B (D)

Gate 18' SMB 1-25 Torque 303 303 0.2 0.48 Both Both 104.55 104.55 0.63 0.52 0.87 0.49 R HR-MO66 A Globe 20*

SMB 3-150 Torque 25 25 0.2 1.1 Both Both

%.0

%.0

> 20 12.14

> 20 11.14 RHR-MO66B Globe 20*

SMB 3-150 Toraue 25 25 0.2 1.1 Both Static

> 20 12.14

> 20 11.14 RHR-920MV Gate 3*

SMB 00-10 Torque 1091 1091 0.2 0.5 Clone 6-Bath 59.76 59.76 1.02 1.02 1.01 1.01 RR-MO43 A (M'D)

Gate 28*

SB 3-100 Torque 10 232 0.15

+ 0.2 Clme 1-None 5.68 5.68 0.22 0.22 RR-MO53 B (MID)

Gate 28' SB 3-100 Torque 10 232 0.15 40.2 Close I-None 5.52 5.52 0.21 0.21 RWCU-M015 Gate 6*

SMB 00-15 Torque 1047 68 0.2 0.5 Clone Static 0.71 0.52 8.93 -

5.18 RWCU-M015 (H)

Gate 6*

SMB 00-15 Torque 1047 0.2 0.5 Clme Static 0.69 0.69 RWCU-MOIS Gate 6"

SMB 00-15 Torque 1041 62 0.2 0.5 Close 3-Static 0.84 0.53 7.42 5.69 RWCU-M018 (H)

Gate 6*

SMB 00-15 Torque 1041 0.2 0.5 Close 3-Static 0.63 0.63 SW-36MV Butter 0y 24*

SMB 00-10 Umit 78 78 Close 2-None

'84.93 %

+54.80%

+80.63 %

+54.80%

SW-37MV Butrerny 24*

SMB 00-25 Limit 78 78 Close 2-None

  • 170.49 %

'54.85%

  • 164.29 %

+54.85 %

SW-MO89A Globe 18" SMB 3-80 Torque 195 105 0.7 1.1 B.,th Both 102.26 102.26 2.00 1.73 2.87 1.80 SW-MO89B Globe 18*

SMB 3-80 Torque 195 195 0.2 1.1 Both Both 102.23 102.23 1.97 1.97 2.83 2.14 SW-650MV ButterHy 18*

SMB 000-5 Limit 68 68 Both 1-None

  • 78.03 %
  • 74.37 %
  • 73.24 %

+73.24 %

SW-65IMV Butterny 18*

SMB 000-5 Limit 68 68 Bath 1-None

  • 77.46 %
  • 74.37 %

'72.% %

+72.% %

SW-886MV Gate 4*

SMB 000-5 Tauue 69 69 0.2 0.5 Open 1-None

, 6.98 3.62 8.61 3 49 Page 4 of 5

Tabb 1 CNS GL 89-10 Supplement 6 Response G.L. 89-10 Motor Operated Valve Status Information as of Jan.1,1995 Testing

% of MEDP Open Available Close Available MEDP Stem Status Tested Valve Factor Valve Factor Valve Actuat" Type of closure Friction Valve Safety Cic No.

Type Sire Type Sire contml Open Closed Factor Factor Direction (Static /DP)

Open Cloned M< wor MaxCST Mewer MetCST SW-RR7MV Gare 4*

SMB 000-5 Torque 60 69 0.2 0.5 Open 1-None 5.75 2.77 7.13 2.62 SW-SARMV cme 4*

SMB 00n-5 Torque 73 78 0.2 0.5 Open I-None 6.19 3.21 7.62 3.08 SW-849MV Gste 4*

SMB 000-5 Torque 78 78 0.2 0.5 Open 1-Norm 6.16 3.21 7.59 3.0R SW-2I2RMV Glotvs 1.5*

SMB 000-2 Torque 79 79 0.2 1.1 Open 1-None 19.78 19.78

> 20

> 20 SW-21295W Glohe 1.5" SMB 000-2 Torque 79 79 0.2 1.1 Open 1-None

> 20

> 20

> 20

> 20 Torque margin between rnotor torque and min required torque, and unas allowable torque and min required torque.

(H)

Indicates HELB Calculation values.

(M)

Motor replacemera scheduled prior to restart.

(V)

Valve replacemera scheduled prior to restart.

(D)

Design change scheduled for RE16.

A Indicates auxiliary pressure source used.

Crane methodology uses a disc-to-seat friction coefficient.

Parallel disc gate valve.

Testing Status Notes:

Initial valve DP testing for REI6 is noted in Table 2.

1. Static test scheduled prior to restart.
2. DP test scheduled prior to restart.
3. Static retest scheduled for REl6.
4. DP retest scheduled for RE16.
5. DP retest scheduled prior to restart.
6. Existing DP test not valid. DP retest scheduled.

Page 5 of 5

_, ~. - _

Attachment II to NIE950006 Page 1 of1 Generic Letter 89-10 Supplement 6 L-Justification for Schedule Extension Supplement 6. Section 2 Information A numerical summary of MOVs not statically and/or DP tested as of January 1,1995 is presented in Table 2. This table also presents MOV description and functional information as well as an indication (*) of those MOVs which remain to be DP tested.

Table 2 presents the specific information requested in Supplement 6, Section 2 for those valves that have not been dynamically tested. This table lists two (2) valves scheduled for DP testing prior to restart from the current outage, seventeen (17) valves which will have new DP tests to be performed during RE-16, and four (4) valves which will require a repeat of their DP tests (one prior to restart and three during RE-16). It also includes information for thirty (30) valves which are not scheduled for DP testing because testing is either impmetical, would not yield meaningful results, or justification exists for exempting these valves from DP testing. This justification is contained in Table 3, "MOV Risk Considerations and Operability Justifications".

Table 3 also presents risk considerations and operability considerations in support of the CNS GL89-10 schedule extension justification.

Table 2 pr,sents descriptions and functional information. This table also indicates which valves are scheduled for dynamic testing.

The information which serves as the basis for confirming functionality of valves not dynamically tested (Section 2(b) of Supplement 6) is presented in the tables included in this submittal, including valve type, size, safety function, design-basis differential pressure and flow, and the available valve factor.

The general operability confirmation process involves, as a minimum, three steps:

Determination of valve design basis.

Determination of required MOV setpoints to reflect best available information.

Setting of control switches via diagnostic testing.

'Ihese three steps will be completed on all 82 program MOVs prior to plant restait.

d

11Na 2 CNS GL 89-10 Supplement 6 Response Valves NOt Dynamically Tested as Of January 1,1995 '

oeeign volse Open

-Open Casse Cemeo Beeto sirel Open Close Open Close Awe 5 VF Aved VF Aved VF Ave 8 VF PSA MOV C_,_..

Functione Type MEDP MEOP Flow Flow (Mert MenCST l Mar)

Men CST Monk CS-M0128 4

  • i Core Spray Loop B Open for CS infection 10" 454 350 6,000 6,000 0.55 0.55 0.86 0.86 Medium Inboard injection Close to terminate CS injection Gate GPM GPM (Throttle) Valve Close for conteinment isolation HPCI-MOIS HPCI Steam Supply Open for HPCI standby 10" 1,091 161 44.2 30.4 No Open No Open 4.86 3.21 High l

Inboard Isolation Valve Close for containment isolation Gate Ibs/sec lbs/sec Safety Safety Function Function Close for HELB isolation N/A 1.091 N/A 3,311 N/A N/A O.78 0.78 R>s/sec

}

HPCI-MO l 6 HPCI Steam Supply Open for HPCI standby 10*

1,091 161 44.2 30.4 No Open No Open 3.11 3.11 High Outboard Isolation Close for containment isolation Gate Ibs/sec lbs/sec Safety Safety Valve Function Function I

Close for HEL8 isolation N/A 1.091 N/A 3,311 N/A N/A O.61 1.11 lbs/sec HPCI-M019 HPCI triection Valve Open for HPCI injection 14*

1,164 1,164 4,250 4,250 0.57 0.57 h Close No Close Medium Gate GPM GPM Safety Safety function function HPCI.MO25 HPCI Pump Minimum Open for HPCI pump minflow 4*

1,300 1.300 450 450 2.30 1.85 1.88 1.54 Low Flow Recirculation Close to divert all flow to the irisction Ene Globe GPM GPM Valve -

MS-MO74 Main Steam Lines Drsin Remain open to drsin condensate from main 3"

1,107 1,106 50 50 No Open No Open O.86 0.54 Low inboard isolation Valve steam lines Gate GPM GPM Safety Safety close for containment isolation Function Function MS-MO77 (

1,107 1,106 50 50 No Open No Open 0.59 0.54 Low Outboard Isolation steam lines Gate GPM GPM Safety Safety i

Valve Close for containment isolation Function Function PC-305MV PC-MOV-230MV Open for containment pressure maintenance 2*

77 44 1,780 1,780 No Open N Open 11.01 10.49 Low Bypass Valve Close for containment isolation Gate CFM CFM.

Safety Safety Close for system isolation Function Function PC-306MV PC-MOV-231 MV Open for containment pressure maintenance 2"

77 61 1,780 1,780 No Open No Open 8.32 8.32 Low Bypass Valve Close for containment isolation Gate CFM CFM Safety Safety Close for system isolation Function Function PC-1303MV Torus letrogen Supply Open to place S8NI in service 1*

29 29 O

O No Open No Open Avail Avail Low System A Outboard Close for containment isolation Gate CFM CFM Safety -

Safety VF > 20 VF>20 Isotation Valve Function Function CNSMOV-1.XLS page 1 of 6 1/8/95,10:03 AM

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Tcbla 2 CNS GL 89-10 Supplement 6 Response Valves NOt Dynamically Tested as Of January 1,1995 oesign voave Open Open Close Cleo.

Basis Siref Open Close Open Close Ave 8VF Avs3 VF Ave 8VF Aves VF PSA MOV Description Functions Type MEDP MEDP Flow Flow (Mtrl MenCST (Mtrl MenCST fienk PC-1304MV Torus Nitrogen Supply Open to place SBN1 in service 1*

29 29 0

0 No Open No Open Avae Avail Low System A Inboard Close for containment isolation Gate CFM CFM Safety Safety VF>20 VF>20 Isolation Valve Function Function PC-1305MV Drywen Nitrogen Open to place SBNI in service 1*

46 46 0

0 No Open No Open Avad 13.51 Low Supply System A Close for containment isolation Gate CFM CFM Safety Safety VF>20 Outboard Isolation Function Function Valve PC-1306MV Dryweg Nrtrogen Open't, place S'.INI in service 1*

46 46 0

0 No Open No Open Avail AveN Low Close for co..arwnent isolation Gate CFM CFM Safety Safety VF>20 VF>20 Sur> ply System A r

Inboard Isolation Valve Function Function PC-1308MV Torus Vent isolation Open for scrus venting 1*

15,

15 0

0 No Open No Open Avail Avan Low Valve Close foe containment isolation Gate CFM CFM Safety Safety VF>20 VF>20 Function Function PC-1310MV Drywell Vent isolation Open for drywelt ventng 1*

15 S

O O

No Open No Open Avaa Avad Low Valve Close for containment isolation Gate CFM CFM Safety Safety VF > 20 VF > 20 Function Function RCIC.MO15 RCIC Steam Supply Open for RCIC standby 3*

1,091 88 4.56 1.67 No Open No Open 6.82 5.00 High inboard Isolation Valve Close for contamment isolation Gate Ibs/sec lbs/sec Safety Safety Function Function Close for HELB isolation N/A 1,091 N/A 78,9 N/A N/A O.51 0.51 lbs/sec RCIC-MO16 RCIC Steam Supply Open for RCIC standby 3*

1,091 88 4.56 1.67 No Open No Open 6.65 5.59 High Outboard Isolation Close for containment isolation Gate Ibs/sec bs/sec Safety Safety Valve Function Function Close for HELB isolation N/A 1,091 N/A 78.9 N/A N/A O.76 0.76 l

Ibs/sec RCIC-MO21 RCIC trgection Vatve Open for RCIC injection 4*

1,170 1,170 400 400 0.71 0.71 No Close No Close High Gate GPM GPM Safety Safety function function RCIC-MO27 RCIC Pump Mmimum Open for RCIC pump minflow 2"

1,256 1,256 40 80 2.62 2.62 2.55 2.55 Low Flow Recirculation Close to divert all flow to the injection line Globe GPM GPM Vaive F.CIC-M0131 ( * )

RCIC Turbine steam Open for RCIC 3"

1,091 0

4.56 0

1.36 1.36 No Close No Close High Admission Valve Close for RCIC turbine isolation Globe Ibs/sec lbs/sec Safety Safety function function CNSMOV.1.XLS Page 2 of 6 1/8/95,10 03 AM

,, ~

Tcbb 2 CNS GL 89-10 Supplement 6 Response

~

Valves NOt DynamicaNy Tested as Of January 1,1995 oesign voeve open open Cwee Casse Seele Sirol Open Close Open Close AvedVF Aved VF Aved VF Ave 8 VF PSA MOV C.41 -

Functione Type MEDP MEDP Flow Flow (Mtri desaCST (Mer)

Eden CST henk FCIC-M0132 ( * )

RCIC Turbine Auxiliary Open for RCIC turbine cooEng 2*

1,260 36 16 "I

3.29 2.44 Avad AvaE High Cooling Water Supply Close to isolate the RCIC turtHne frorn turbme Globe GPM G'4A VF>20 VF>20 valve ou coonno water REC-700MV ( * )

REC Non-Critical Remain open for REC service to non<ritical 10' 65 86 2.876 2,876 No Open No Open 1.83 51 Low Services Supply Valve loop Gate GPM GPM Safety Safety Close for REC line break Function Function REC-702 MV ( ' )

REC Drywed Supply Remain open for REC service to drywe5 8'

65 82 1,005 2,700 No Open No Open 1.61 0.86 Low isolation Valve Close for REC line break Gate GPM GPM Safety Safety Function Function REC-709MV ( * )

REC Drywell Retum Remain open for REC service to drywe5 8*

65 82 1,005 1,005 No Open No Open 1.61 0.72 Low leolation Valve Close for REC line break Gate GPM GPM Gafety Safety Function Function REC.711MV ( * )

REC North Criticalloop Open for REC criticalloop cooling 6*

87 109 2,700 3,800 1.26 1.26 1.23 1.16 Medium Supply Valve Close for SW backup to REC Gate GPM GPM REC.714MV ( * )

REC South Critical Open for REC critical loop coohng 6'

87 109 2,700 3,800 1.25 1.17 1.22 0.87 Medium Loep Supply Valve Close for SW backup to REC Gate GPM GPM REC-1329MV ( * ) REC Augmented Close to isolate the REC from Augmented 8"

65 83 1,000 GPM 2,700 No Open No Open 4.10 1.46 Low Radweste Supply Valve Radweste Gate GPM Safety Safety Function Function RHR-MO 17 RHR Shutdown Coohng Open for SDC 20*

99 100 15,400 50 No Open No Open 0.79 0.79 Low Supply Outboard Close for reactor isolation Gate GPM GPM Safety Safety isolation Valve Function Function RHR-MO18 RHR Shutdown CooEng Open for SDC 20" 98 98 15,400 50 No Open No Open 1.81 1.81 Low Supply Inboard Close for reactor isolation Gate GPM GPM Safety Safety isolation Valve Function Function RHR-MO278 (

  • I LPCI toop 8 Infection Remain open for LPCI 24*

385 303 8.000 15,400 1.87 1.87 3.37 2.25 Med Outboard Isolation Throttle to regulate LPCI flow Globe GPM GPM Valve Close to terminate LPCI RHR-MO668 t * )

RHR Heat Exchanger 8 Remain open for LPCI 20" 25 25 15,000 15,400 Avail 12.14 Avan 11.14 Med Bypass Throttle Valve Close for RHR heat exchanger operation Globe GPM GPM VF>20 VF>20 Throttle to very flow through RHR heat exchanger CNSMOV-1.XLS Page 3 of 6 1/8/95,10$3 AM

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Tcbla 2 CNS GL 89-10 Supplement 6 Response Valves NOt DynamicaHy Tested as Of January 1,1995 Design Vales Open Open Close Cleon Basio Siref Open Close Open Close Aee8 VF Ave 8VF Aved VF Aved VF PSA MOV Description Tunetlene Type MEDP MEDP Flow Flow quer)

MenCST quer)

MenCST flank RHR-920MV ( * )

Main Stearn to Open to align MS to AOG 3*

1,091 1,091 3.63 3.63 No Open No Open 1.01 1.01 Low Augmented Off 4as Close when AOG is not required Gate bs/sec hs/sec Safety Safet=

System Upstream Function Function Shutoff Valve RR-MO53A ( ' * )

Reactor Receculat6on Close to isolate rockculation Ene tweak 28" 10 232 9,944 19,000 No Open No Open 0.22 0.22 Low pump A Dscharge Gate GPM GPM Safety Safett Valve Function Function RR-MO538 t *

  • I Reactor Recirculation Close to isolate recirculation kne break 28" 10 232 9,944 19,000 No Open No Open 0.21 0.21 Low Pump B Dscharge Gate GPM GPM Safety Safety Valve Function Function RWCU-MO15 Reactor Water Cleanup Open for RWCU lineup 6*

1,047 68 0

23 No Open No Open 8.93 5.18 High Supply Inboard Close for contaewnent isolation Gate Ibs/sec lbs/sec Safety Safety isolat% Valve Function Function Close for HELB isolation N/A 1,047 N/A 1,448 N/A N/A O.69 0.69 lbs/sec RWCU-MO I S Reactor Water Cleanup Open for RWCU lineup 6*

1,041 62 0

23 No Open No Open 7.42 5.69 High Supply Outboard Close for containment isolation Gate Ibs/sec lbs/sec Safety Safety isolation Valve Ftex: tion Function Close for HELB isolation N/A 1,041 N/A 1,448 N/A N/A O.63 0.63 lbs/sec SW-886MV ( * )

SW Supply Valve to Open to crosstie SW to REC 4"

69 69 335 335 6.98 -

3.62 No Close No Close Low REC Critical Loop Gate GPM GPM Safety Safety function function i

SW-887MV (

  • I SW Supply Valve to Open to crosstle SW to REC 4"

69 69 335 335 5.75 2.77 No Close No Close Low REC Critical Loop Gate GPM GPM Safety Safety function function l

SW-888MV ( ' )

SW Return Valve fron.

Open to crosstie SW to REC 4"

78 78 335 335 6.19 3.21 No Close No Close Low l

REC Critical Loop Gate GPM GPM Safety Safety I

function function SW-889MV ( * )

SW Return VaAs from Open to crosstie SW to REC 4*

78 78 335 335 0.16 3.21 No Close No Close Low REC Criticalloop Gate GPM GPM Safety Safety function function l

i CNSMOV-1.XLS Page 4 of 6 1/8/95,1023 AM m.--..

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CNS GL 89-10 Supplement 6 Response Valves Not Dynamically Tested as Of January 1,1995 Design Velve Open Open Close Close Beets Siret Open Close Open Close Ase8 W Aved VF AveE VF Ave 4 W

. PSA MOV~

C;,...

Functione Type MEDP MEDP Flow Flow (Mtr)

MenCST (Mart Men CST henk SW-2128MV SW Gland Seal Water Open for backup seal water supply to SW 1.5" 79 79 ISO ISO Avell -

AvaR No Close No Close Medhan Backup Valve from SW pumps Globe GPM GPM VF>20 VF> 20 Safety Safety Pumps A/C function function SW-2129MV SW Gla'wt Seal Water Open for backup seat water supply to SW 1.5" 79 79 100 100 Avail Avell No Close No Close Modum Backup Valve froen SW pumps Globe GPM GPM VF>20 VF>20 Safety Safety Pumps B/D function function l

a CNSMOV-1.XLS Page 5 of 8 1/8/95,1023 AM

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TCble 2 CNS GL 89-10 Supplement 6 Response Velves Not Dynemicesy Tested es of January 1,1995 Desipi Open Ctese Open Casse Besie Valve Open Close Open Close MenCST MenCST Mer Teg Mar in PSA Ctc h r' _ _,

Funeteen Sime/ Type MEDP MEDP Flow Flow Margbo Margin -

Margin Marghe Itenk 5

PC-MOV-230MV Torus Exhaust inboard Open for torum puryng 24* Bfly 17 44 0CFM 6.000 CFM 195 %

129 %

195 %

129 %

Low leolation Valve Close for contenment isolation Close for system isolation i

1 PC-MOV 231MV Drywell Exhaust inhoens Open for drywet purgeng 24" Bfly 17 61 0CFM 7.000 CFM 206 %

113 %

221 %

120 %

Low toolation Vafve Close for w.ia

.; isolation Close for system isolation

?

PC-MOV-232MV Dryweg inlet inboard.

Close for contenment isolation 24* Bfly 2

46 0CFM 7.000 CFM 255%

131 %

255%

131 %

tow lealetion Valve Close for system isolation PC-MOV-233MV Torus inlet inboard Open for torus hard pipe venting 24* Bfly 63 29 0CFM 6.000 CFM 107%

163%

107%

163 %

High lsolation Valve (beyond design basis - basis for PSA ranki Close for conte;nment isolation Close for system isolation REC-MOV 712MV t *

  • I REC Heat Exchanger A Close to isolate non-eritical 12* Bfly 65 108 2.700 GPM 4.050 GPM 19%

5%

19%

5%

Low j

Outlet Velve header REC-MOV-713MV ( * * )

REC Heat Exchanger 8 Close to isolate norecritical 12* Bfly 65 108 2.700 GPM 4.050 GPM 18%

4%

18%

4%

Low Outlet Valve header SW-MOV-36MV (

  • I SW Pumps Creestie Close for train separation 24* Bfly 78 78 400 GPM 18,000 GPM 55%

55%

85 %

81 %

High Valve

]

SW-MOV 37MV (

  • I SW Pumps Crosetie Close for train separation 24" Bfly 78 78 400 GPM 18.000 GPM 55%

55%

170 %

164 %

High Valve Close to prevent control room basement flooding SW-MOV-650MV (

  • I REC Heat Exchanger A Open for REC heat exchanger 18* Bfly 68 68 6.590 GPM 3.590 GPM 74 %

73 %

78 %

73 %

Low Service Water Outlet service -

Valve SW-MOV 651MV (

  • l REC Heat Exchanger B Open for REC heat exchanger 18" Bfly 68 68 6.590 GPM 6.590 GPM 74 %

73%

77%

73 %

Low Sennce Water Outlet service Valve

(

  • I Valves scheduled for DP Testing

( *

  • l
  • Modifications scheduled prior to restart from current outage" cessuov.ns reen e et e its/ss,s:ss Am

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Attachment III to NLS950006 Page 1 of1 Overview of PSA Rankins Process All MOVs in the dynamic test scope have been prioritized based on safety significance. The >

prioritization process included:

A deterministic review approach.

A probabilistic review approach.

The deterministic approach involved identifying the design and licensing bases for each essential classified MOV, including listing the safety functions the valve is to perform.

The risk approach involved identification of the risk significance of each candidate MOV based on results of the CNS Pmbabilistic Safety Assessment (PSA). A review of the Level 1 and Level 2 models was performed to identify how each essential classified MOV was modeled.

For those MOVs not specifically modeled in the PSA, an assessment was made using deterministic methods to identify the effect of valve failure on core damage sequences.

The result of this review resulted in the classification of MOVs into the following risk groups:

High Those valves associated with relatively high frequency sequences in which valve failure (s) in combination with a single operator error or active system failure results in core damage. Failure of the MOVs severely limits the paths available for achieving safe shutdown. Criteria: > 1% Core Damage Frequency (CDF)

Fussell-Vesely (F-V) or > 2 Risk Achievement Worth (RAW)

Medium Valves that contribute less significantly to core damage, but still appear above the insignificant range in importance ranking. These valves typically perform a risk significant function, but the importance of these valves is reduced by factors such as the availability of other systems which perform the same function, availability of time for recovery, or low frequency of the initiating events. Criteria: 0.1 %

CDF < F-V < 1 % CDF or 1.11 RAW X 2 Imy Valves that have a low contribution to core damage. Failure of these valves does not significantly change the progression of any accident sequence. Factors, similar to the medium priority valves, are present to the extent that failure of the valve (s) does not significantly impact station risk. Criteria: < 0.1 % CDF (F-V) or < l.1 RAW The risk importance ranking is identified for the valves listed in Table 2.

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS 2D VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER' CS-MOV-M012B The Core Spray Inboard Injection Valve opens Static testing has been performed to verify acceptability of automatically in the presence of a CS initiation signal the valve switch settings in their "as-left" condition.

when the reactor pressure decreases to less than 450 psig,

~

to provide reactor inventory makeup.

Calculated available valve factor indicates that this valve has sufficient margin. This MOV will be dynamically The valve is closed to terminate system injection and to tested in RE-16.

provide reactor and containment isolation. The PSA risk ranking of this valve is medium because failure to open results in failure of Core Spray B loop and impacts low pressure makeup.

HPCI-MOV-MOIS The High Pressure Coolant Injection Pump Steam Supply Static testing has been performed to verify acceptability of HPCI-MOV-MOl6 Inboard and Outboard Isolation Valves have no auto-open the valve switch settings in their "as-left" condition.

interlocks. The valves are only opened remote manually by the control room operator, provided that no HPCI Calculated avadable valve factor indicates that these valves -

isolation signal or low steam pressure signal is present.

have sufficient margin.

The valves close automatically upon an HPCI isolation signal or when the reactor pressure is less than 100 psig.

The GL 89 10 failure mode was not modeled in the PSA.

The PSA risk ranking of this valve are: "high based on engineeringjudgement for a containment bypass condition and Level 2 concerns."

1 TABLE 3.M

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS

~

VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS.

NUMBER HPCI-MOV-MOl9

- This High Pressure Coolant Injection Isolation Valve Static testing has been performed to verify acceptr.bility of opens autorratically on either high drywell pressure or low the valve switch settings in their "as-left" condition.

reactor water level in order for the HPCI System to provide reactor inventory makeup. Failure to open upon Calculated available valve factor indicates that this valve demand would preclude High Pressure Coolant Injection has sufficient margin.

into the reactor.

l The capability to close is only required to satisfy a CNS operating procedure during manual shutdown of the HPCI pump. The PSA risk ranking of this valve is medium because failure to open results in failure of HPCI and impacts high pressure makeup.

h HPCI-MOV-MO25 The HPCI minimum flow bypass line isolation valve opens Static testing has been performed to verify acceptability of automatically on HPCI pump low flow and when either 1) the valve switch settings in their "as-left" condition.

HPCI pump discharge pressure is greater than 125 psig, or 2) a HPCI initiation signal is present, provided that Calculated available valve factor indicates that this valve there is no HPCI turbine trip signal present.

has sufficient margin.

This isolation valve opens to provide minimum flow pump protection. The GL 89-10 failure mode was not modeled in the PSA. The PSA risk ranking of this valve is low -

because HPCI will not be started without a flow path to the vessel or ECST.

'E

.2 TABLE 3.004.

-. ~.

... ~.

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER MS-MOV-MO74 These MOVs are normally open during power operation Static testing has been performed to verify acceptability of MS-MOV-MO77 and have a function to close automatically on a main steam the valve switch settings in their "as-left" condition.

line isolation event to provide containment isolation.

These valves have a non-safety related function to remain Calculated available valve factor indicates that these valves open during power operation to keep the main steam lines have sufficient margin.

MS-MOV-MO77 will be free ofcondensate. Closure of the MSIVs does not isolate dynamically retested prior to startup from the current i

these valves from the reactor. Failure of these valves outage. MS-MOV-MO74 will not be dynamically tested would not isolate the reactor for a downstream steam line due to plant and system configuration.

break. Flow through these valves passes through a dowrsm.w restricting orifice. The GL 89-10 failure mode was not modeled in the PSA. The PSA risk ranking of' these valves is low.

PC-MOV-230MV These valves are normally closed and have a safety Full flow / differential pressure testing of these valves is not 1

PC-MOV-231MV function to close for containment isolation. These valves possible due to plant system configuration. Therefore, PC-MOV-232MV have no safety related function in the opening direction.

dynamic testing will not be performed. Static testing will The GL 89-10 failure mode was not modeled in the PSA.

be performed to verify acceptability of the valve switch The PSA risk ranking of these valves is low.

settings in their "as-left" condition.

The calculated torque margin indicates that these valves have sufficient capability. These valves are normally in their safety position (closed). There is also an air operated valve downstream which is normally closed and is also a containment isolation valve.

3 TABLE 3.004

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER PC-MOV-233MV This valve is normally closed and its safety function is to Full flow / differential pressure testing of this valve is not close for containment isolation. This valve has a beyond possible due to plant system configuration. Therefore, design basis function to open to provide containment heat dynamic testing will not be performed. Static testing will removal when suppression pool cooling, torus sprays and be performed to verify acceptability of the valve switch drywell sprays have failed. For th% reason, the PSA risk settings in their "as-left" condition.

ranking of this valve is high.

The calculated torque margin indicates that this valve has suflicient capability. This valve is normally in its safety position (closed). There is also an air operated valve downstream which is normally closed and fails closed and is also a containment isolation valve.

PC-MOV-305MV These valves are normally closed and have a safety Static testing has been performed to verify acceptability of PC-MOV-306MV function to close for containment isolation. They have a the valve switch settings in their "as-left" condition.

normal function to close for system isolation or open to maintain primary containment at preset pressure and The calculated available valve factor indicates that these oxygen concentration. These valves have no safety related valves have sufficient margin. These valves are normally in function in the opening direction. The GL 89-10 failure their safety position (closed). There is also an air operated mode was not modeled in the PSA. The PSA risk ranking valve downstream which is normally closed and fails of these valves is low.

closed and is also a containment isolation valve.

PC-MOV-1303MV These valves are normally closed and have a safety Full flow / differential pressure testing of these valves is not PC-MOV-1304MV function to close for containment isolation. They have a possible due to plant system configuration. Therefore, PC-MOV-1305MV normal function to close for system isolation or open to dynamic testing will not be performed. Static testing will PC-MOV-1306MV place Standby Nitrogen Injection system in service. These be performed to verify acceptability of the valve switch valves have no safety related function in the opening settings in their "as-left" condition.

direction. The GL 89-10 failure mode was not modeled in the PSA. The PSA risk ranking of these valves is low.

The calculated available valve factor indicates that these valves have suflicient margin. These valves are normally in their safety position (closed).

4 raus. cot

r-TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER PC-MOV-1308MV This valve is normally closed and its safety function is to Full flow / differential pressure testing of this valve is not close for containment isolation. It has a normal function possible due to plant system configuration. Therefore, to close for system isolation or open to vent the torus dynamic testing will not be performed. Static testing will.

i (suppression chamber). This valve has no safety related be performed to verify acceptability of the valve switch '

function in the opening direction. The GL 89-10 failure settings in their "as-left" condition.

l mode was not modeled in the PSA. The PSA risk ranking of this valve is low.

The calculated available valve factor indicates that this l

valve has sufficient margin. This valve is normally in its safety position (closed).

PC-MOV-1310MV This valve is normally closed and its safety function is to Full flow / differential pressure testing of this valve is not close for containment isolation. It has a normal function possible due to plant system configuration. Therefore, to close for system isolation or open to vent the drywell.

dynamic testing will not be performed. Static testing will l

This valve has no safety related function in the opening be performed to verify acceptability of the valve switch -

direction. The GL 89-10 failure mode was not modeled in settings in their "as-left" condition.

the PSA. The PSA risk ranking of this valve is low.

The calculated available valve factor indicates that this valve has sufficient margin. This valve is normally in its safety position (closed).

RCIC-MOV-MOI 5 These valves are normally open to provide a steam supply Full flowliifferential pressure testing of these valves is not -

RCIC-MOV-MOl6 to the RCIC pump turbine. These valves are required to possible d e to plant system configuration and potential -

close on an RCIC isolation signal. The opening direction damage to punt components. Therefore, dynamic testing function is not safety-related. The GL 89-10 failure mode will not be performed. However, static testing has been was not modeled in the PSA. These nonnally open valves performed to verify acceptability of the valve switch are not required to stroke for RCIC operation. However, settings in their "as-left" condition.

HELBs on this steam line would result in containment bypass if valve failed to close. The PSA risk ranking of The calculated available valve factor indicates that these these valves is: "high based on engineering judgement for valves have sufficient margin. The valves have been set up a containment bypass condition and Level 2 concerns."

using the best available data.

S TABLE 3.004

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS' NUMBER RCIC-MOV-MO21 This valve is normally closed while the RCIC system is in Full flow / differential pressure testing of this valve is not standby. The valve has a safety function to open to allow possible due to plant system configuration and. potential RCIC flow into the reactor in the event that the reactor damage to plant components. Therefore, dynamic testing becomes isolated. The closing direction function is not will not be performed However, static testing has been safety-related. The PSA risk ranking of this valve is high.

performed to verify acceptability of the valve switch settings in their "as-left" condition.

The calculated available valve factor indicates that this i

valve has sufficient margin. The valve has been set up using the best available data.

RCIC-MOV-MO27 This valve is normally closed while the RCIC system is in Static testing has been performed to verify acceptability of

[

the standby mode. The valve must open to provide a the valve switch settings in their "as-left" condition.

minimum recirculation flow path when RCIC pump flow drops below 40 gpm. This valve must also close to ensure The calculated available valve factor indicates that this maximum flow to the reactor during system operation.

valve has sufficient margin.

The GL 89-10 failure mode was not modeled in the PSA.

The PSA risk ranking of this valve is low.

l RCIC-MOV-MOl31 This valve is normally closed while the RCIC system is in Static testing has been performed to verify acceptability of the standby mode This valve has a safety function to the valve switch settings in their "as-left" condition.

j open to start up the RCIC pump upon RCIC system initiation. The closing direction function is not safety The calculated available valve factor indicates that this related. The PSA risk ranking of this valve is high.

valve has sufficient margin. This MOV will be dynamically tested in RE-16.

RCIC-MOV-MOl32 This valve is normally closed while the RCIC system is in Static testing has been performed to verify acceptability of 7

the standby mode. The valve must open to provide the valve switch settings in their "as-left" condition.

cooling water flow for the RCIC pump turbine auxiliary systems. The closing direction function is not safety The calculated available valve factor indicates that this related. The PSA risk ranking of this valve is high.

valve has sufficient margin. His MOV will be dynamically tested in RE-16.

6 TABLE 3.004

TABLE 3-MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS

[

VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER REC-MOV-700MV This MOV is normally open and its function is to close Static testing will be performed on this valve and the valve e

automatically on a loss of REC system pressure resulting switch settings verified prior to restart.

from a REC system line break. This MOV can be opened or closed manually. The PSA risk ranking of this valve is The calculated available valve factor indicates that this low.

valve has sufficient margin. This MOV will be dynamically tested in RE-16.

1 REC-MOV-702MV These MOVs are normally open and have a close function Static testing will be performed on these valves to verify REC-MOV-709MV to prov:de manual isolation of the Class IS system piping switch settings prior to restart.

in the emit of a line break in the Class IIS system piping.

These MOVs can be opened or closed manually. The GL The calculated available valve factor indicates that these 89-10 failu.e mode was not modeled in the PSA. The valves have sufficient margin. These MOVs.will be PSA risk ranking of these valves is low.

dynamically tested in RE-16.

REC-MOV-71IMV These MOVs normal position is dependent upon plant Static testing will be performed on these valves and the REC-MOV-714MV conditions. They function to open to provide flow to the valve switch settings verified prior to restart.

4 loads in the critical loop during emergency and shutdown l

situations.

These MOVs can be opened or closed The calculated available valve factor indicates that these manually, and also close when the SW to REC system valves have sufficient margin. The torque switch is I

crosstie switch is placed to open. These MOVs are bypassed on opening and will. allow the full motor.

required to open during accident sequences. The PSA' capability to be applied to the valve during opening.

risk ranking of these valves is medium because of a These MOVs will be dynamically tested in RE-16.

i common mode failure.

l 1

E 7

DtBLE.1.004

-TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER

^

REC-MOV-712MV These MOVs are nonnally open and provide isolation of Static testing will be performed on these valves and the REC-MOV-713MV the non-critical header assuring REC cooling to safety valve switch settings verified prior to restart. The torque related equipment. The MOVs may be opened and closed switch settings on the butterfly valves are bypassed which manually from the control room and close if pressure will allow full motor capability to position the valve.

switch senses low system pressure. These MOVs have no safety function to open. The only required safety function The calculated torque margin indicates that these valves -

of these MOVs is to close to isolate a postulated line have sufficient but marginal capability. A design change break in the non-critical loop piping in order to provide will be implemented prior to plant restart to increase sufficient flow to the critical components. The PSA risk margin.

ranking of these valves is low.

l REC-MOV-1329MV This MOV is normally open and its function is to close on Static testing will be perfonned on this valve and the valve low REC system pressure to isolate the REC service to switch settings verified prior to restart.

the Augmented Radwaste system. This MOV can be opened or closed manually. The PSA risk ranking of this The calculated available valve factor indicates that this valve is low.

valve has sufficient margin. This MOV will be dynamically tested in RE-16.

RIIR-MOV-MOl7 This MOV is normally closed and must open to allow Static testing has, been performed to verify the RHR Pump (s) to take suction from a Reactor acceptability of the valve switch settings in their "as-left" Recirculation Line to initiate shutdown cooling. This condition.

t valve is required to close to terminate shutdown cooling.

It also automatically closes to isolate the reactor to The calculated available valve factor indicates that this prevent loss of inventory and to prevent valve has sufficient margin.

overpressurization of the low design pressure piping in the RHR system. The open direction requirement is not safety related. The PSA risk ranking of this valve is low.

1 8

TABLE 3.004

.l

.-~.

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER l

RHR-MOV-MOI 8 This MOV is normally closed and must open to allow Static testing has been performed to verify the RHR Pump (s) to take suction from a Reactor acceptability of the valve switch settings in their "as-left" Recirculation Line to initiate shutdown cooling. This condition.

valve is required to close to terminate shutdown cooling.

It also automatically closes to isolate the reactor to The calculated available valve factor indicates that this.

prevent loss of inventory and to prevent overpres-valve has sufficient margin surization of the low design pressure piping in the RHR system. The open direction requirement is not safety related. The PSA risk ranking of this valve is low.

RHR-MOV-MO27B This MOV is normally open and is used to throttle open or Static testing has been performed to verify the to close to regulate or terminate LPCI injection. The acceptability of the valve switch settings in their "as-left" MOV is not required to change position during accident condition.

conditions. Failure of this injection valve will fail one loop of LPCI injection. The PSA risk ranking of this valve is The calculated available valve factor indicates that this medium risk because of the redundancy and diversity of valve has sufficient margin. The torque switch is bypassed the Low Pressure Injection system.

on opening, thus the full motor capability is available in the opening stroke. This is a globe valve and the opening stroke will be assisted by the opening differential pressure.

The sister valve to this valve has been dynamically tested and found acceptable. This MOV will be dynamically tested during RE16.

9 TABLE 3.004

. _.-. -.. ~ - -,-...-..- - -., -. -.

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER RHR-MOV-MO66B This MOV is normally open and its function is to remain Static testing has been performed to verify the open in order for LPCI injection to bypass the heat acceptability of the valve switch settings in their "as-left" exchangers; close to maximize the RHR systems heat condition.

removal function; or throttle to vary flow through the heat exchangers. If the valve fails to close in heat removal The calculated available valve factor indicates that this modes of operation, the loop of heat removal will be valve has sufficient margin. This is a globe valve and the degraded. The PSA risk ranking of this valve is medium.

opening stroke will be assisted by the opening differential pressure.

The sister valve to this valve has been dynamically tested and found acceptable. This MOV will be dynamically tested in RE-16.

RHR-MOV-920MV This MOV is normally open and its function is to open to Static testing has been performed to verify the align Main Steam to the AOG system operation and to acceptability of the valve switch settings in their "as-lefl" close when AOG operation is not required. The safety condition.

function of this valve is to close to isolate Main Steam from the AOG system during HPCI operation; thus The calculated available valve factor indicates that this ensuring full steam flow to the HPCI turbine. There is no valve has sufficient margin. This MOV will be dynamically cafety related function for this valve to open. Inadvertent retested in RE-16.

closure with subsequent fhilure to reopen would not cause a degradation of any safety related function. The GL 89-10 failure mode was not modeled in the PSA. The PSA risk ranking of this valve is low.

10 TABLU004

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER R.R-MOV-MO53A These MOVs are normally closed when the RR system is Static testing will be performed on these valves and the RR-MOV-MO53B not in operation and normally open during power valve switch settings verified prior to restart.

operation. They function to close automatically to direct the LPCI makeup water to the reactor rather than out of Calculated available valve factor indicates that these i

l a possible recirculation line break. However, Core Spray MOVs have sufficient but marginal capability. A design remains redundant to LPCI. The non-safety related change will be implemented prior to plant restart to functions are to remain open during power operation and increase margin.

to close for recirculation pump isolation during I

maintenance.

The GL 89-10 failure mode was not modeled in the PSA.

The PSA risk ranking of these valves is low because frequency of occurrence of a large break recirculation piping event is low.

RWCU-MOV-MOI S These MOVs are normally open and have a function to Full flow / differential pressure testing of these valves is not RWCU-MOV-MOl8 cbse to isolate flow from the reactor in the event of a line possible due to plant system configuration and potential break in the RWCU system (HELB concern) and to close damage to plant components. Therefore, dynamic testing for containment isolation. There is no safety related will not be performed. However, static testing has been function for these valves to open. The PSA risk ranking performed to verify acceptability of the valve switch of these valves is: "high based on engineeringjudgement settings in their "as-left" condition.

for containment bypass condition and Level 2 concerns" The calculated available valve factor indicates that these valves have suflicient margin. These valves have been setup using the best available data.

SW-MOV-36MV This MOV is nonnally open and its function is to close to The calculated torque margin indicates that this valve has provide for train separation in the event of low SW sufficient margin. Dynamic testing will be performed on pressure. Failure to close inhibits the ability to isolate the this valve prior to restart.

loops of SW resulting in low header pressure. This would cause vital service water headers to have insuflicient flow during accident conditions. The PSA risk ranking of this valve is: "high based on common mode failure analysis."

1I TABLE 3.004

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER SW-MOV-37MV This MOV is normally open and its function is to close to The calculated torque margin indicates that this valve has provide for train separation in the event of low SW suflicient margin. Dynamic testing will be performed on pressure and to close to reduce the rate of flooding in the this valve prior to restart.

control room basement in the event of a pipe break. The PSA risk ranking of this valve is high.

SW-MOV-650MV These MOVs are normally open if the associated heat Static testing will be performed on these valves and the SW-MOV-651MV exchanger is in service and have a function to move to the valve switch settings verified prior to restart. The torque position required to allow service water to pass through switch settings on the butterfly valves are bypassed which the REC heat exchanger. Failure to open would fail the will allow full motor capability to position the valve.

REC heat exchangers; however, there is adequate operator time to manually open the valve. The PSA risk ranking of The calculated torque margin indicates that these valves these valves is low.

have sufficient capability. These MOVs will be dynamically tested in RE-16.

SW-MOV-886MV These MOVs are normally key-locked closed and have a Static testing will be performed on these valves and the SW-MOV-887MV function to open to allow service water to be supplied to valve switch settings verified prior to restart.

SW-MOV-888MV the REC system in the event of a failure in that system.

SW-MOV-889MV These MOVs are opened manually with a common key-The calculated available valve factor indicates that these lock switch which opens the four SW supply and retum valves have suflicient margin. The torque switch is valves and closes the associated normally open REC bypassed on opening and will allow the full motor valves. The PSA risk ranking of these valves is low.

capability to be applied to the valve during opening.

i These MOVs will be dynamically tested in RE-16.

l l

l 12 TitBLE3.001

TABLE 3 MOV RISK CONSIDERATIONS AND OPERABILITY JUSTIFICATIONS VALVE RISK SIGNIFICANCE CONSIDERATIONS OPERABILITY JUSTIFICATIONS NUMBER SW-MOV-2128MV These MOV are normally closed and have a function to Static testing will be performed on these valves and the SW-MOV-2129MV open to provide gland seal injection from the SW pumps.

valve switch settings verified prior to restart.

l These MOVs can be manually opened / closed from the Intake Stmeture. These MOVs can automatically open on The calculated available valve factor indicates that these low gland water system pressure. The PSA risk ranking.

valycs have sufficient margin. The torque switch is of these valves is medium based on multiple backups.

bypassed on opening and will allow.the full motor -

capability to be applied to the valve during opening.

These MOVs are globe valves and are flow-assisted (flow -

from under the seat to assist lift) in moving to their safety position and will be excluded from dynamic testing.

4 i

13 DtBLE3.004

.. ~..

\\

LIST OF NRC COMMITMENTS l ATTACHMENT 3 l Correspondence No: NLS950006 The following table identifies those actions committed to by the District in this document.

Any other actions discussed in the submittal represent intended or j

planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.

Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Complete the initial testing partion of the CL 89-10 conclusion of RE-16 Program at CNS upon completion of Refueling Outage No. 16 (RE-16).

Additional testing and modification work is planned to be Prior to startup from completed prior to startup from the current outage, as the current outage delineated in Table 1 of the attachments to the letter.

At the time of startup, all of the valves within the CNS CL 89-10 testing program will be reviewed against current Prior to startup from industry information, set up with the best available the current outage plant data, and retested if necessary.

Static testing will be completed on all 82 program MOVs Prior to startup from by plant startup. (Includes static tests from RE-14, RE-the current outage

15. and flow testing of SW 36 and SW 37)

Dynamic testing will be performed on 35 MOVs by plant Prior to startup from startup. (33 as of Jan 1,1995, 2 scheduled for Jan 95) the current outage Dynamic testing will be completed on 52 MOVs as of the By conclusion of RE-end of RE-16.

16 Complete documentation for closure of GL89-10 program and provide closure letter no later than 120 days following 120 days following completion of the next refueling outage.

completion of RE-16.

L PROCEDURE NUMBER 0.42 l

REVISION NUMBER 0 l

PAGE 10 0F 16 l

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