ML20092E561

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Submits Rev 10a of Inservice Testing Program for Pumps & Rev 13a of Inservice Testing Program for Valves for Units 1 & 2
ML20092E561
Person / Time
Site: Byron  
Issue date: 09/08/1995
From: Pontious H
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9509150227
Download: ML20092E561 (56)
v • d • e


Text

Commonwcalth Edium Company I Hrd Opm Place Downers Gnne. IIAM19 September 8,1995 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Revision 10a of the Inservice Testing Program for Pumps and Revision 13a of the Inservice Testing Program for Valves Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455

References:

1.

Robert A. Capra (USNRC) letter to D. L. Farrar (Comed),

Safety Evaluation of the Inservice Testing Program Relief Requests for Pumps and Valves, Byron Station, Units 1 and 2 (TAC Nos. M85884, M85885, M89037 and M89038), dated October 24,1994 2.

Robert A. Capra (USNRC) letter to D. L. Farrar (Comed),

Inservice Testing Program Relief Requests for Valves, Byron Station, Units I and 2 (TAC Nos. M90719 and M90720), dated February 17,1995 3.

Harold D. Pontious, Jr. (Comed) letter to USNRC Document Control Desk, Extension of the First Ten Year Inspection Interval for the Inservice Testing Program Byron Nuclear Power Station, Unit 1, dated July 5,1995 Ladies and Gentlemen:

Commonwealth Edison Company's (Comed's) Byron Nuclear Power Station, Units 1 and 2 (Byron), performs inservice testing (IST) in accordance with Section XI of the 1983 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code through the Summer 1983 Addenda (ASME Code), as required by L\\nla\\byninWt\\ploavl3a wpf\\t

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9509150227 950908 OM PDR ADOCK 05000454 O

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USNRC Document Control Desk September 8,1995 Title 10, Code of Federal Regulations, Part 50, Section 55a, Paragraph f, Subparagraph 3 [10 CFR 50.55a(f)(3)), except where alternatives have been authorized or relief has been requested and granted by the United States Nuclear Regulatory Commission (USNRC).

Revision 10a of the Byron IST Pump Program is provided in Enclosure 1.

Attachment A provides a summary of all of the changes associated with this revision.

The two major changes are discussed below.

The first major change is the elimination of Relief Request PR-7 regarding vibration measurements for the Essential Service Water Makeup Pumps, OSX02PA and OSX02PB. PR-7 is being replaced with a new Technical Approach and Position PA-l.

Due to the unique design of these pumps, the pump thrust bearings are physically located within the gearbox which houses the gear drive. ASME/ ANSI OMa-1988 Addenda to the OM-1987 Edition, Part 6, Paragraph 4.6.4(a) requires, in part, vibration monitoring of the pump thrust bearings but not the gear drive. PA-1 defines the approach to be taken discriminate the vibration attributable to the pump thrust bearings from the total vibration measurement.

The second major change is the addition of a new Relief Request PR-8 regarding the reference value tolerance for the Diesel Oil Transfer Pumps, ID00lPA-D and 2D00lPA D, discharge pressure. These pumps are positive displacement pumps. The discharge pressure from these pumps are considered to be constant and there are no throttling techniques or other methods available to adjust discharge pressure. It is impractical to establish a total tolerance ofi 2 % of the reference value (as allowed by Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants,"

dated November 1993 ) due to the small magnitude of the reference value and the readability of the installed gauges. PR-8 presents the basis for establishing a total reference value tolerance of

  • I psig.

i Revision 13a of the Byron IST Valve Program is provided in Enclosure 2.

Attachment B provides a summary of all of the changes associated with this revision.

The major changes are discussed below.

Revisions 12 and 13 of the Byron IST Valve Program included several new valves as a result of the 1994 Byron /Braidwood IST scope review. The initial testing of these valves, along with subsequent testing, has been completed, as required. However, Byron has come across a few cases in which it is felt that alternative test methods i

and/or frequencies would give an acceptable level of quality and safety. Therefore, the following relief requests are being submitted:

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i USNRC Document Control Desk 3-September 8,1995 1

1.

VR-28: Incorporates the disassembly plan'in accordance with Generic Letter l

(GL) 89-04 for the 1/2FWO79A-D check valves.

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2.

VR-29: Proposes performing acoustic testing for closure on the OSX028A,B check valves on an 18 month frequency.

3.

VR-30: Proposes performing the full flow test for the OSX127A,B cneck j

valves in accordance with the applicable portions of Byron Technical l

Specification 4.7.5.

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.As allowed by 10 CFR 50.55a(f)(4)(iv), Byron has utilized portions of ASME/ ANSI OMa-1988 Addenda to the OM-1987 Edition, Part 10 which allows the use of

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justifications for deferral of testing up to refueling outage frequencies The following refueling outage justifications are also being submitted:

i 1.

ROJ-1: Allows radiography testing to be performed for the OSX127A,B and a

OSX143A,B check valves for closure on a refueling outage frequency.

}

2.

ROJ-2: Allows full stroke testing of the SI8948A-D Check Valves (previously Cold Shutdown) and the SI8956A-D Check Valves (previously VR-5) on a i

refueling outage frequency. The acoustic sampling plan will also be used.

Additionally, the SI8948 check valves will be partially stroked on a Cold l

Shutdown frequency. Justification for not performing a partial stroke test on j

the S18956 Check Valves was documented in ROJ-2, as required by Reference 2.

i As stated in Reference 3, the Second Ten Year Inspection Interval for the Byron Unit 1 IST Program will begin July 1,1996 with its associated IST Program Plan being submitted to the USNRC for review and approval no later than December 31,1995. Therefore, Comed respectfully requests USNRC review and i

approval of Relief Requests PR-8, VR-29, and VR-30 no later than November 17,1995, such that any comments can be incorporated into the Byron Unit 1 Second Ten Year Inspection Interval IST Program Plan prior to its submittal.

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USNRC Document Control Desk September 8,1995 Please address any comments or questions regarding this matter to this office.

Very truly yours, N

Harold D. Pon ious;,Jr.

Nuclear Licensing Administrator Attachments (2)

Enclosures (2) cc:

11. J. Miller, Regional Administrator - RIII G. F. Dick Jr., Byron Project Manager - NRR H. Peterson, Senior Resident Inspector - Byron Office of Nuclear Facility Safety - IDNS 1

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s ATTACHMFsNT A

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Summary of Changes foc Revision 10a of the Inservice Testing Program Plan for Pumps Section 3.0 - Table of Contents 1.

Under Section 3.5, relief requests, PR-7 has been deleted 2.

Added in PR-8 for ilie Diesel Oil Transfer Pumps under Section 3.5 3.

Created Section 3.6 for technical positions and added technical position PA-1 for the SX Makeup Pump Vibrations Section 3.2 - P_rogram References 1.

Added SER, dated 10/24/94 Section 3.3 - Program Tables 1.

1/2D00lPA-1/2D00lPD: Added "PR-8" under the Remarks column 2.

OSX02PA/0SX02PB: Deleted "PR-7" and added in PA-1 under the Vibration column Section 3.5 - Pumn Relief Requests 1.

Deleted Relief Request PR-7 (incorporated in Technical Position PA-1) 2.

New Relief Request PR-8 was added for the Diesel Oil Transfer Pumps

>2% tolerance for reference value Section 3.6 - Pumn Technical Positions 1.

Added PA-1 concerning the SX Makeup Pump Vibrations

ATTACHMENTH Summary of Changes for Revision 13a of the Inservice Testing Program Plan for Valves Section 4.0 - Table of Contents 1.

Added Refueling Outage Justifications into Section 4.4 2.

Added Refueling Outage Justification ROJ-l concerning SX Cire Water and Deep Well Pump Discharge Check Valves and ROJ-2 conceming the SI Accumulator Outlet Check Valves 3.

Deleteo VR-2A and VR-5 4.

Deleted the term " DRAFT" associated with VR-15A, VR-15B, VR-15C, and VR-15D, VR-26, VR-27 5.

Added in VR-28 (concerning the main Feedwater Header Check Valves), VR-29 (concerning the SX makeup Pump Discharge Check Valves), and VR-30 (concerning the Deep Well Pump Discharge Check Valves).

Section 4.2 - Program References 1.

Added SERs, dated 10/24/94 and 02/17/95

Section 4.3 - Procam Tables 1.

1/2FWO79A-D: Changed Test Mode column from "CS" to "RR", added "VR-26" under the Relief Request column, and deleted note 46.

2.

1/2S18948A-D: Added "RR" under Test Mode column to reflect frequency for the full Stroke test (Ct), and added "ROJ-2" reference under the Notes column.

3.

1/2S18956A-D: Deleted VR-5 under the Relief Request column, and added "ROJ-2" reference under the Notes column.

4, OSX028A/B: Added "VR-29" under Relief Request coiumn and "Bt Relief Pending" under Remarks column 5.

OSX127A/B: Added "RR" under Test Mode column to reflect frequency of Bt test, "VR-30" under Relief Request Column, "ROJ-1 "

under Notes column, and "Ct Relief Pending" under Remarks Column.

6.

OSX143A/B: Changed "OP" to "RR" under Test Mode column and added "ROJ-1" under Notes column Section 4.4 - Valve Notes / Cold Shutdown Justifications /Refueline Outace Justifications 1.

Revised Note 42 to state that a partial flow test for the 1/2SI8948A-D valves would be performed at Cold Shutdown (not full flow test).

2.

Deleted Note 46 as Relief Request VR-28 now covers the testing requirements for the 1/2FWO79 Check Valves 3.

Added ROJ-l Refueling Outage Justification for the radiography testing of the OSX127A,B and OSX143A,B check valves 4.

Added ROJ-2 Refueling Outage Justification for the SI Accumulator Discharge Check Valves,1/2S18948A-D and 1/2S18956A-D

Section 4.6 - Valve Relief Reauests 1.

Deleted Relief Request VR-2A (denied in SER, dated 10/24/94) and VR-5 (incorporated in ROJ-2)

. 2.

New Relief Request VR-28 was added for the 1/2FWO79 sample disassembly Program 3.

New Relief Request VR-29 was added for the nonintrusive testing of the OSX028A,B check valve closure test 4.

New Relief Request VR-30 was added for the full flow testing of the OSX127A,B check valves J

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ENCLOSURE 1 Revision 10a of the Inservice Testing Program Plan for Pumps 4

SECTION 3.0 INSERVICE TESTING PROGRAM PLAN FOR PUMPS a

Ravision 10a Table of Contents 3.0 Inservice Testing Program Plan for Pumps 3.1 Program Description 3.2 Program References 3.3 Program Tables 3.4 Notes Note 1

" Deleted" Note 2 Pumps Lubricated by Pumped Fluid Note 3 Pump Idle Suction Pressure Note 4

" Deleted" (incorporated into PR-6)

Note 5 Essential Service Water Make Up Pumps Inlet and Differential Pressure Note 6

" Deleted" Note 7 Boric Acid Transfer Pumps 3.5 Relief Requests PR-1 Pump Vibration PR-2 Pump Bearing Temperatures PR-3

" Deleted" PR-4

" Deleted" PR-5 Use of Ultrasonic Flowmeters PR-6 Diesel Oil Transfer Pump Differential Pressure PR-7

" Deleted" PR-8 Diesel Oil Transfer Pump Reference Value Tolerance 3.6 Technical Positions PA-1 SX Makeup Pump Vibration (9678 AA/WPF/080795) 3.0 - page 1 of 1

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4 SECTION 3.2 PROGRAM REFERENCES

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Revision 10a f

REFERENCES

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1.

Title 10, Code of Federal Regulations, Part 50, Domestic Licensing of Production and Utilization Facilities, particularly Section 50.55a, a

Codes and Standards.

1 2.

ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1983 Edition, Summer 1983 Addenda.

3.

ASME/ ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, including 1989 Addenda, Part 6, Inservice Testing of Pumps in Light Water Reactor Power Plants.

1 4.

U.S. Nuclear Regulatory Commission, Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs.

5.

Byron /Braidwood Station UFSAR, Section 3.9.6.1, Inservice Testing of

Pumps, i

l 6.

Byron Station Technical Specification, 3/4.0.5, Generic ASME Program Requirement.

i 7.

Byron Technical Staff Procedure, BVP 200-1, ISI Requirements for Pumps.

f 8.

NRC Safety Evaluation Reports (SER's) :

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a.

09/15/88 (Initial Program Plan Review)

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b.

09/14/90 (Supplemental Program Plan Review) c.

01/31/92 (Supplemental Program Plan Review) d.

10/24/94 (Review of Rev. 9b and 10) a l

9.

Byron Station IST Pump Program Plan Review Responses (file:

3.11.0240):

l a.

Byron Letter 88-1321 (Initial Program Plan Review Response)

}

b.

Byron Letter 90-0724 (Supplemental Program Plan Review Response)

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c.

Byron Letter 93-0047 (Rev. 9b, Submitted in Response to SER 01/31/92) i I

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(9G78AA/WPF/080795) 3.2 - page 1 of 1

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1 SECTION 3.3 PROGRAM TABLES i

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NSERvlCE TESTING PROGRAM plt.N C18SS 1. 2. 3 Afe AUGMENTED f9AAPS 8v.,N NUCLEAR POWE2 STATION UNITS 0,1,2 Reveen 10a C

TEST PARAMETERS L

A S

INLET OFF FLOW BEANNG TEST LUBRCATION PUMP NUh4BER PUMP NAME S

PMD SPEED PfESS PRESS RATE VIBRATION TEMP MTERVAL LEVEL REMAFUCS 2CS01PA Contarvnera Spray 2

M-129 Yes Yes Yes PRI PR 2 Quarterly No Note 2 Pump 2CS01PB Contanment Ss:tay 2

4129 No Yes Yes Yes PR1 PS2 Quarter *y No Note 2 Pump ICV 01PA Centrdugd Charyng 2

M64 No Yes Yes PR5 PRr1 PS2 Quarterly Yes Pump ICV 01PB Centnfugd Charyng 2

4 64 No Yes Yes f%5 PR1 PS2 Quarterly Yes Purnp 2Cv01PA Centrdugd Chargmg 2

4 138 Yes Yes PB5 PR 1 8%2 Quarterfy Yes Pump 2CV01PB Centnfugal Chargmg 2

4138 Yes Yes PR5 PR1 PS2 Quarterly Yes Pump 1DOO1PA Dweel Od Transfer 3

M50 Yes PRS PBS PRI PS2 Quarterty Note 2 Pump PRS l

1DOO1PB Dneel Od Transfer 3

4 50 No Yes PR-6 PR5 PR1 PS2 Quarterly No Note 2 Pwnp l

PR8 1D001PC Omed 04 Transfw 3

M50 Yes f%6 PR5 PS1 PR2 Quarterly No

%te2 Pump Pne l

IDOO1PD Omeel Od Transtw 3

M50 No Yes PR-6 PR5 PRI PS2 Quartetty Wee 2 Pump PR-8 l

20001PA Desel Od Transfw 3

4130 No Yes PRrts PRS PRI PS2 Quarterly No

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Pwnp PRS 3.3 PUMP TABLES - Page 2 of 4 l

pdwpWocrnntepurnps.xis

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i INSEftVICE TESTING PROGRAM PLAN CLASS 1,2. 3 AND AUGMENTED PUMPS BYRON NUCLEAR POWER STATION l

UNITS 0.1,2 Reveson 10a i

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TEST PARAMETERS A

S

  1. EET DIFP R.OW SEANNG TEST LUBRCATION PUMP NUMBER PLAAP NAME P&O SPEED PNSS PESS RATE VIBRATION TBF e(TERVAL LEVEL
  1. 6AAFES 2DOO1PS Doest 08 Transfer 3

M-130 No Yes PRr0 P45 PS1 Pf42 Quarterly No

%te 2

Purr, s%g -

l 2DOO1PC Dioest Od Transfer 3

4130 Yes Pf46 fR5 PR1 PS2 harterly No Note 2 Purry PSg l

2OOO1PO Deeet 04 Trarmier 3

M130 No Yes Pf45 PR5 Pf41 Pf42 Quarterly Note 2 l

Pump Pna IfM01PA Rosaduad Heat 2

M62 No Yes Yes Yes Pf41 Pf42 Quarterly No

%te2 Removal Pwnp 1RH01PB Residual Heat 2

M62 No Yes Yes Yes PR1 Pf42 Quarterly

%te 2 Removal Pump 2RH01PA Reesdual Heat 2

M-137 No Yes Yes Yes PR1 Pl42 Quarteety No

%te 2 Removad Punp 2fH01PB Residual Heat 2

M137 No Yes Yes Yes Pf41 PR2 Quarterfy No Note 2 Removal Pump ISIO1PA Safety Won 2

M61 Yes Yes Yes Pnt Pf42 Quarterly Yes PunP IS401PB Safety Inpocton 2

4 61 No Yes Yes Yes PS1 PS2 Quarte 1y Yes Pimp 25801PA Safety kgectiers 2

M136 No Yes Yes Yes PS1 PS2 Quarterly Yes Pump 2S401PB Safety kvecten 2

M136 No Yes Yes Yes Pf41 PS2 Quarterly Yes Pump 3.3 PUMP TABLES-Page 3 of 4 i

p:1wpWocrnntd\\ pumps.xle

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l INSERVICE TE2 TING PROGRAM PLAN CLASS 1. 2. 3 AND AUGMENTED PtAAPS

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BYRON NUC11AR POWER STATION UNITS O,1. 2 Reveen 10a i

C TEST PARAMETERS L

A S

N.ET DE FLDW SEAfWeG TEST LtJ8MCATION PUMP NUhmER PUhr NAAK S

P&O SPEED PESS PESS RATE VBRATION TEMP INTERVAL LEVEL EMANCS OSXO2PA Essen. Service Wmw 3

M-4 2 Yes Yes Yes N5 PA-1 PR2 Quately Yes Mr:a 5 M eup %

ese.

OSXO2P8 Essen. Service Watw 3

M-42 Yes Yes Yes PR5 PA-1 PRr2 Quaterly Yes Note 5 Makeup Pump Doo+4 ISXO1PA Essente Service 3

M-42 No Yes Yes PR5 PRI PRr2 Quatetty Yes Note 3 Wmw Pwnp 1SXO1P8 Essentd Servh.e 3

M-42 No Yes Yes PR.5 PR1 PR 2 Quaterfy Yes Note 3 Water Pwnp 2SXO1PA Essential Service 3

M-42 No Yes Yes PR5 PR-1 PR2 Quaterly Yee Note 3 Water Pump 2SXO1P8 Essential Sennce 3

M-42 No Yes Yes PR5 PR.1 PS2 Quarterly Yes Note 3 Water Pwnp 1SXO4P 18 AFW SX 3

M-42-3 Yes Yes Yes Yes PR1 PR2 Quatetty Yes Soester Purno 2SXO4P 28 AFW SX 3

M.126-1 Yes Yes Yes Yes PR 1 PS2 Quarterly Yes Booster Pump OWOO1PA Control Room 3

M-118 No Yee Yes Yes PR.1 PRr2 Quatedy Yes Note 3 CMied Water Pwnp OWOO1P8 Control Roern 3

M-118 No Yes Yes Yes P41 PR2 Quarterly Yes Note 3 CMied Water Pump 3.3 PUMP TABLES - Page 4 of 4 p$wp\\dcH:rnntepumps.xle r

4 SECTION 3.5 i

RELIEF REQUESTS 4

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Ravision 10a i

RELIEF REQUEST NO. PR-7

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" Deleted" i,

(9678 AA/WPF/080795) 3.5 - page 11 of 13

s.

Revision 10m RELIEF REQUEST NO. PR-8 1.

PUMP NUMBER (S)-

1DOO1PA, 1DOO1PB, 1DOO1PC, 1DOO1PD 2DOO1PA, 2DOO1PB, 2DOO1PC, 2DOO1PD 2.

NUMBER OF ITEMS:

8 PUMPS 3.

ASME CODE CLASS:

3 4.

ASME CODE. SECTION XI REOUIREMENTS:

a.

IWP-3100 requires: The resistance of the system shall be varied until either the measured differential pressure (discharge pressure per approved PR-6] or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as directed in this subsection.

b.

NUREG 1482, section 5.3 states: A total tolerance of +/-2 percent of the reference value is allowed without approval from the NRC.

5.

BASIS FOR RELIEF:

The Diesel 011 Transfer pumps are positive displacement pumps which transfer diesel oil to the diesel generator day tanks. The discharge pressure (constant for positive displacement pumps) is considered the set value for the pumps and have indicated consistent values in the past.

The lowest discharge pressure reference value for a specific Diesel Oil Transfer Pump is currently 23 psig and the highest reference value is 25.5 psig. Numbers this low allow only a small tolerance for the discharge pressure when applying the +/-2% tolerance (as noted in NUREG 1482, section 5.3).

For instance, in considering a reference value of 23 psig, the +/-2% criteria allows only a +/- 0.46 psig tolerance.

The pressure indicators are 0-60 psig analog gauges with increments of 0.5 psig, allowing readability to the nearest 0.25 psig (readings are acceptable to a degree of precision no greater than one-half the smallest increment). To be within the +/-2% criteria, only a readability range of +/- 0.25 poig would be possible (next higher reading of +/-0.5 psig would represent a tolerance > 2%).

For the reference values of 25 psig or above, only a readability range of +/-

0.5 psig would be possible to remain within the +/-2% tolerance.

History indicates that there would be a few " acceptable" data points that would fall outside of these tight ranges. Byron proposes a more practical acceptable range of +/- 1 psig.

6.

ALTERNATE TESTING:

Byron will use a discharge pressure tolerance of +/- 1 psig from the reference value when testing the Diesel Oil Transfer Pumps. The Flow will be compared to Table IWP-3100-2 to ensure the measured value is within the necessary acceptable limits.

(9678AA/WPF/080795) 3.5 - page 12 of 13

Revision 10a a

7.

JUSTIFICATION:

Discharge pressure for these positive displacement pumps are considered to be constant.

There are no throttling techniques or other methods available to adjust the discharge pressure.

It would be impractical to set up strict ranges of +/-2% due to the small magnitude of the numbers involved.

In addition, the readability of the gauges are limited.

History has shown acceptable pump operation for values within the +/- 1 psig tolerance. The level of safety concerning the operation of these pumps will not be compromised by allowing a tolerance of +/-1 psig versus a strict +/-2% tolerance. Any deviations greater than 1 psig from the reference value would result in an investigation of the pump performance. To encompass all the pumps on a consistent basis, a +/-1 psig tolerance on the discharge pressure reference value is requested, which would represent a tolerance of +/-3.9% to +/-4.3% of the existing reference values.

8.

AEfLICABLE TIME PERIOD; This relief request is requested once per quarter during the remainder of the first inspection interval.

9.

APPROVAL STATUS:

Pending Approval T

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l (9678AA/WPF/080795) 3.5 - page 13 of 13 i

SECTION 3.6 TECHNICAL POSITIONS I

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Rsvision los 4

PA-01 TECHNICAL APPROACH AND POSITION PUMP NUMBER:

OSXO2PA, OSXO2PB pumps ASME CODE CLASS:

2&3 ASME CODE SECTION XI REOUIREMENTS:

ANSI /ASME OMa-1988 Part 6: Table 3a Ranges For Test Parameters, Paragraph 4.6.4 (a) Vibration Measurements, Paragraph 4.6.1.6 Frequency Response Range POSITION:

The Essential Service Water Makeup Pumps OSX02PA & B are of a very unique design (see Fig. 1 and Fig. 2).

The pump is attached to a horizontal diesel driver via a right angle gear drive, and the gear drive is located approximately 39 feet above the pump. This configuration assures pump operability during the design basis flooding of the Rock River.

The Essential Service Water Makeup Pumps OSX02PA & B are classified as centrifugal pumps. ANSI /ASME OMa-1988 Part 6 Paragraph 4.6.4 (a) requires that for centrifugal pumps, vibration measurements are to be taken in two directions on each accessible pump bearing housing and in the axial direction j

on each accessible pump thrust bearing housing. The OM Code does not require vibration monitoring of the gear drive.

For the Essential Service Water Makeup Pumps, however, the pump thrust bearings are physically located within the gearbox which houses the gear drive. This pump configuration is not addressed by OM Part 6.

With this unique configuration, the only means of collecting vibration readings for the pump thrust bearing is to physically take the vibration measurements on the gear box itself.

The limitations of taking the vibration readings at this location is that the resultant vibration readings are not solely attributable to the pump thrust bearing.,

The vibration readings obtained are the result of other factors such as the vibration induced by the gear drive itself.

When recording vibration results based on a frequency response range to 2000 Hz., which has been the customary practice at Byron for these pumps, the gear drive significantly contributes to the vibration which is measured at the gearbox location. The vibration induced by the gear drive is largely due to the gears meshing. Taking into account the pump running speed and the number of gear teeth, Byron has calculated the gear mesh frequency and hence a vibration frequency attributable to the gear drive. This frequency was calculated to be 1080 Hz.

By performing spectral analysis of the vibration data obtained at the gearbox locations, engineering personr_el were able to identify the vibration which was attributable to the gear drive, as there was an easily identifiable peak within this 1080 Hz frequency range.

This particular peak, associated with the gear mesh frequency, exceeded the acceptance criteria of Table 3a of OM Part 6.

The OM Part 6 Table 3a (9678AA/WPF/080795) 3.6 - page 1 of 2

s.

Revision 10a 14 -

i acceptance criteria applies to pump bearings and pump thrust bearings, and not to gear drives which induce vibration due to the gears meshing. Additionally,,

j Paragraph 4.6.1.6 of OM Part 6 states that the frequency response range of the vibration measuring transducers and their readout system shall be to at least 1000 Hz.

The 1080 Hz gear mesh frequency goes beyond what is required for the frequency response range of the vibration measuring transducers and their readout system. As a result, for the gearbox locations on these pumps, Byron will apply the OM Part 6 Table 3a acceptance limits in the frequency range of one third minimum pump shaft rotational speed up to and including 1000 Hz, and j

will not apply the OM Part 6 acceptance limits to the gear drive frequencies j

above 1000 Hz.

By applying a cutoff at 1000 Hz, the resulting peak reading is j

more applicable to the vibration from the pump thrust bearing..The 1000 Hz i

cutoff meets the requirements of OM Part 6 for frequency response range of the vibration measuring transducers and their readout system. Additionally, j

vibration measurements will continue to be taken at the lowest accessible bushing on the pump shaft. These vibration readings will be subject to the OM Part 6 Table 3a acceptance criteria.

j

.Both the A and B pumps have experienced vibration at the gearbox location in the vicinity of 0.4 - 0.45 in/see since installation, at which time they were verified by the vendor to be operating properly. They have continued to l

display such vibration levels throughout their service life.

In August of l

1992, the gearbox for pump OSXO2PA was replaced. The replacement was

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performed due to repair work which was performed on the pump and was not attributable to a gearbox problem.

It was felt that this was an opportunity to discover if a rebuilt gearbox would reduce the vibration levels.

Replacement with a rebuilt gearbox did not significantly reduce vibration levels at the gearbox location. Additionally, an inspection of the original gearbox revealed that it was in an acceptabla condition. Also, in 1995 the OSXO2PA gearbox was opened and visually inspected.

It should be noted that the OSX02PA pump has experienced slightly higher vibration levels at the gearbox location than the OSX02PB pump. The gearbox of the OSX02PA pump was found to be in excellent condition. Comed's conclusions are that the vibration levels recorded at the gearbox locations do not have a detrimental affect on the gearbox or the pump, and that this vibration level is normal for i

such a pump configuration. Although the OM Code vibration limits will not be applied to the vibration levels attributed to the gear mesh frequencies, Byron will continue to monitor these vibration levels, and take action as appropriate.

l (9678AA/WPF/080795) 3.6 - page 2 of 2

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ENCLOSURE 2 Revision 13a of the Inservice Testing Program Plan for Valves

i l SECTION 4.0 INSERVICE TESTING PROGRAM PLAN FOR VALVES i 4

e e Revision 13a TABLE OF CONTENTS 4.0 Inservice Testing Program Plan for Valves 4.1 Program Description 4.2 Program References 4.3 Program Tables - Units 1 and 2 4.4 Notes / Cold Shutdown Justifications / Refueling Outage Justifications Note 1 Main Steam Isolation Valves Note 2 CV Emergency Boration System Flowpath Valves Note 3 Main Feedwater Isolation Valves Note 4 CV System Letdown and Make-up Isolation 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 Valves 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 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 Note 24 Pressure Relief Check Valves Note 25 SI Pump Suction Check Valve (1/2 SI8926) Note 26 CV Pump Suction Check Valve (1/2 CV8546) Note 27 RH Pump Suction Check Valves (1/2 SI8958A/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 Checks (1/2 AF014A-H) Note 31 CV/SI Mini-Flow Recirculation Line Check Valve Full Flow Testing (1/2 CV8480A/B and 1/2 SIB 919A/B) Note 32 " Deleted" Note 33 SX Make-Up Pump Discharge Check Valves (OSXO28A/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) (9679AA/WPF/080795) 4.0 Page 1 of 3

~__ 0 Revision 13a 4.4 (Cont.) 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) Note 39 Nitrogen Supply to SI Accumulator Check Valves (1/2 SI8968) Note 40 Safety Injection Check Valves (1/2 SI8815, 1/2 SI8900A-D, 1/2 SI8818A-D, 1/2 SI8819A-D, 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) Note 42 Safety Injection Cold Leg Pressure Isolation Valves (1/2 SI8948A-D) Note 43 RH Crosstie Valves (1/2RH6716A,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 (1/2 FWO79A-D) VC-1 Safety Injection Accumulator Discharge MOVs (1/2SI8808A-D) VC-2 RCP Seal Injection Inlet MOVs & Check Valves VC-3 Blowdown Flow Control /High Energy Line Break (HELB) Isolation Valves I VC-4 Charging and Volume Control System Letdown Isolation and Letdown Orifice Isolation Valves ROJ-1 SX Circ Water and Deep Well Pump Discharge Check Valves ROJ-2 SI Accumulator Outlet Check Valves 4.5 Technical Approaches and Positions ] VA-01 Method of Stroke Timing Valves i VA-02 Method of Fail 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) VA-05 Justification for Exercising the U-0 CC Heat Exchanger and Pump Isolation Valves on a U-2 Cold Shutdown Frequency VA-06 Stroke Time Corrective Actions 4.6 Relief Requests VR-1 Appendix J Valves VR-2 Containment Spray NaOH Additive Check Valves i VR-2A " Deleted" VR-3 Safety Injection ECCS Check Valves (9679AA/WPF/080795) 4.0 Page 2 of 3 i

4 Revision 13a 4.6 (Cont.) VR-4 Containment Spray Discharge and Ring Header Check Valves VR-5 " Deleted" (Incorporated into ROJ-2) VR-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 VR-10 Instrument Air Containment Isolation Valves VR-11 " Deleted" (per EG & G recommendation) VR-12 Trending of Fast Actuating Valves 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 VR-15A CV Injection Related Check Valves VR-15B RH Suction Isolation Thermal / Pressure Relief Check Valves VR-15C SI Injection Related Check Valves VR-15D RH/SI Hot Leg Injection Related Check Valves VR-16 Containment Sump Outlet Isolation Valve Testing During Refueling i VR-17 Motor Driven Auxiliary Feedwater Pump L.O. Cooler Solenoid Valve Stroke Testing VR-18 " Deleted" re-organized into several relief requests VR-19 Auxiliary Feedwater Check Valves VR-20 Trending of Power-Operated Valve Stroke Times (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 Supply to PRT Check Valves VR-24 Chilled Water to RCFC Coils Check Valves VR-25 Containment Spray Eductor Discharge Check Valves VR-26 Fire Protection Inside Containment Isolation Valves VR-27 Charging & Volume Control Loop Fill Check Valves VR-28 Main Feedwater Header Check Valves VR-29 SX Makeup Pump Discharge Check Valves VR-30 Dry Well Pump Discharge Check Valves (9679AA/WPF/080795) 4.0 Page 3 of 3 i

i r e l l 1 e i I SECTION 4.2 PROGRAM REFERENCES 1

- = - Revision 13a PROGRAN REFERENCES '1. Title 10, Code of Federal Regulations, Part 50, Domestic Licensing of Production and Utilization Facilities, particularly Section 50.55a, Codes and Standards. I 2. ASME Boiler and Pressure Vessel Code, Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1983 Edition, Summer 1983 Addenda. 3. 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 Developing Acceptable Inservice Testing Programs. S. 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. i 7. Byron Station Technical Staff Procedure, BVP 200-2, ISI Requirements for Valves. 8. NRC Safety Evaluation Reports (SER's): a. 09/15/88 (Initial Program Plan Review) b. 09/14/90 (Supplemental Program Plan Review) c. 09/14/90 (Relief Requests VR-21 and VR-22 Review) 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) g. 10/24/94 (Review of Rev. 11 and 12) h. 02/17/95 (Rev. 13 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 (9679AA/WPF/080795) 4.2 Page 1 of 1

) 1. I 1 d. j i 1 i l l i l 1 5 SECTION 4.3 1 j PROGRAM TABLES u 4 s I i J 4 4 i i 1 I i f 4 i l I i i l em

INSERVICE TESTING PROGRAM PLAN CLASS 1,3,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13a 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 1/2FWO39A M-3 6-1 C 2 B 6.0 GA A.O. O C St CS 10 1 M-121-1 B lt RR Ft CS 10 2 1/2FWO398 M-36-1 A 2 B 6.0 GA A.O. O C St CS 10 1 M-121-1 B tt RR Ft CS 10 2 1/2FWO39C M-36-1D 2 B 6.0 GA A.O. O C St CS 10 1 M-121-1 A tt RR Ft CS 10 2 1/2FWO39D M-36-1 B 2 B 6.0 GA A.O. O C St CS 10 1 M-121-1 C it RR Ft CS 10 2 1/2FWO43A M 1 C 2 B 3.0 GL A.O. C C St OP 1 M-121-1 B tt RR Ft OP 2 1/2FWO43B M-36-1 A 2 8 3.0 GL A.O. C C St OP 1 M-121-1D it RR Ft OP 2 1/2FWO43C M 1 D 2 B 3.0 GL A.O. C C St OP 1 M-121-1 A it RR Ft OP 2 1/2FWO43D M-3 6-1 B 2 8 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 RR VR-28 3 M-121-1 B 1/2FWO 79C M-36-1 A 2 C 16.0 CK S.A. O C Bt RR VR-28 3 M-121-1D 1/2FWO79C M 1 D 2 C 16.0 CK S.A. O C Bt RR VR-28 3 M-121-1 A 1/2FWO79D M-3 6-1 B 2 C 16.0 CK S.A. O C Bt RR VR-28 3 M-121 -1 C 1/2FW510 M 1 C NONE B 10.0 AN A.O. O C Ft RR 16 2 M-121 1 1/2FW510A M-3 6-1 C NONE B 4.0 GA A.O. C C Ft RR 17 2 M-121-1 1 1/2FW520 M-36-1 A NONE B 16.0 AN A.O. O C Ft RR 16 2 M-121 1 ^ 1/2FWS20A M-36-1 A NONE B 4.0 GA A.O. C C Ft RR 17 2 l M-121-1 i ( (p:\\wp\\docmntd\\ valves 2.xts-090194) 4.3 - Page 14 of 41 l

INSERVICE TESTING PROGRAM PLAN CLAOS 1,2,3 AND AUGMENTED VALVES BYRON NUCLEAR POWER SVATION UNITS O,1,2 Revision 13a 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 REQtKST NOTES (VA) REMARKS 1/2Sle926 M-61 1 A 2 C 8.0 CK S.A. C O Ct/Xt RR/OP VR-6 25 3 M-136-1 1/2Sl8948A M-61-5 1 AC 10.0 CK S.A. C C Lt RR Bt CS 6,23,42 3 f M-136-5 0 Xt/Ct CS5tR 42, ROJ2 3 1/2Sl89488 M-61 -5 1 AC 10.0 CK S.A. C C tt RR et CS 6,23,42 3 l M-136-5 0 Xt/Ct CS!RR 42, ROS2 3 1/2S18948C M-61-0 1 AC 10.0 CK S.A. C C Lt RR Bt CS 6,23,42 3 M-136-0 0 Xt/Ct CS/RR 42, ROJ2 3 l 1/2S189480 M-61-6 1 AC 10.0 CK S.A. C C Lt RR Bt CS 6,23,42 3 M-136-6 0 Xt/Ct CS/RR 42, ROJ2 3 l 1/2S18949A 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 1/2S889498 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 i 1/2S18949C 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 1/2S189490 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 1/2S!8956A M-61-5 1 AC 10.0 CK S.A. C C Lt/Bt CS 6 3 M-136-5 O Ct RR ROS2 3 1/2Sl89568 M-61-5 1 AC 10.0 CK S.A. C C Lt/Bt CS 6 3 M-136-5 O Ct RR ROS2 3 1/2Sl8956C M-61-6 1 AC 10.0 CK S.A. C C Lt!Bt CS 6 3 M-136-6 O Ct RR ROS2 3 1/2Sl89560 M-61-6 1 AC 10.0 CK S.A. C C Lt/Bt CS 6 3 M-136-6 I O Ct RR ROJ2 3 i l i l l (p:\\wpidocmntd\\ valve s 2.xts-090194) 4.3 - Page 34 of 41

INSERVICE TESTING PROGRAM PLAM CLASS 9,2,3 CND QUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13a VALVE TECH. VALVE VALVE SIZE VALVE ACT. NORMAL STROKE TEST TEST RELIEF POS. NUMBER P&tD CLASS CATEGORY (tNJ TYPE TYPE POSITION DIRECT. METHOD MODE REQUEST NOTES (VA) REMARKS 1/2SXOO2A M-42-1 B 3 C 36.0 CK S.A. C O Ct OP 3 C Bt OP 3 1/2SXOO2B M-42-1 A 3 C 36.0 CK S.A. C O Ct OP 3 C Bt OP 3 1/2SXOO5 M-42-1 A 3 8 30.0 BF M.O. C O St CP 1 ft RR 1 OSXOO7 M-42-2A 3 8 24.0 BTF M.O. C O St OP 1 ft RR 1/2SXOl 6A M-4 2-5 B 2 B 16.0 BTF M.O. O O!C St OP 1 M-128-3 It RR 1/2SXOl 68 M-42-5A 2 B 16.0 BTF M.O. O O/C St OP 1 M-128-3 it RR 1/2SXO2 7A M-42-5 8 2 8 16.0 BTF M.O. O O,C St OP 1 M-128-3 It RR 1/2SXO27B M-42-5A 2 B 16.0 BTF M.O. O O/C St OP 1 M-12 6-3 It RR OSXO2BA M-4 2-6 3 C B.O CK S.A. C O Ct OP 3 Bt Rehef C Bt OP VR-29 3 Pending OSXO288 M-4 2-6 3 C B.O CK S.A. C O Ct OP 3 Bt Relief C Bt OP VR-2 9 3 Pending 1/2SX101 A M-42-3 3 8 1.5 GL S.O. C O St OP VR-17 M-12 6-1 Ft OP 2 1/2SX112A M-42-3 3 B 12.0 BIF A.O. O C St OP 1 M-126-1 ft RR Ft OP 2 1/2SX1128 M-4 2-3 3 8 12.0 BTF A.0-O C St OP 1 M-126-1 ft RR Ft OP 2 1/2SX114A M-4 2-3 3 B 12.0 BTF A.O. O C St OP 1 M-126-1 It RR Ft OP 2 1/2SX114B M-42-3 3 8 12.0 BTF A.O. O C St OP 1 M-126-1 It RR Ft OP 2 1/2SX116A M-42-2 8 3 C 3.0 CK S.A. O O Ct OP 3 M-4 2-28 1/2SX116B M-42-2A 3 C 3.0 CK S.A. O O Ct OP 3 M-4 2-2 A l' 5 (p:\\wp\\docmntd\\ valves 2.xis 090194) 4.3 - Page 36 of 41

INSERVICE TESTING PROGRAM PLAN CLASS 1,2,3 AND CUGMENTED VALVES BYRON NUCLEAR POWER STATION UNITS O,1,2 Revision 13a 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 OSX127A M-42-6 3 BC 8.0 CK S.A. C O/C Ct/Bt OP/RR VR-30 ROJ1 3 Ct Rebef Pending OSX1278 M-42-6 3 BC 8.0 CK S.A. C O/C Ct/Bt OP,HR VR-30 ROJ1 3 Ct Rehef Pending OSX143A M-42-6 3 BC B.O CK S.A. O C Bt RR ROJ1 3 OSX1438 M-4 2-6 3 BC B.O CK S.A. O C Bt RR ROJ1 3 OSX146 M-42-2 A 3 8 30.0 BTF M.O. C O St OP 1 It RR OSX147 M-42-2A 3 8 30.0 BTF M.O. C O St OP 1 It RR 1/2SX147A M-42-3 3 B 16.0 BTF S.O. N/A O Ft OP M-12 6-1 1/2SX147B M-42-3 3 B 16.0 BTF S.O. N/A O Ft OP M-126-1 OSX182A M-42-7 3 B 24.0 BF M.O. C O/C St OP lt RR OSX162B M-42-7 3 B 24.0 BF M.O. C O/C St OP lt RR OSX132C M 7 3 8 24.0 BF M.O. C O/C St OP lt RR OSX162D M-42-7 3 8 24.0 BF M.O. C O/C St OP tt RR OSX163A M-42-7 3 8 24.0 BF M.O. O O/C St OP tt RR OSX1638 M-4 2-7 3 B 24.0 BF M.O. O O/C St OP tt RR OSX163C M-4 2-7 3 8 24.0 BF M.O. O O/C St OP l It RR OSX1630 M-4 2-7 3 8 24.0 BF M.O. O O/C St OP i it RR l OSX163E M-42-7 3 8 24.0 BF M.O. O O/C St OP l tt RR t OSX163F M-42-7 3 8 24.0 BF M.O. O O/C St OP l tt RR OSX163G M-42-7 3 8 24.0 BF M.O. O O/C St OP tt RR OSX163H M-42-7 3 8 24.0 BF M.O. O O/C St OP i It RR I (p:\\wpWocmntd\\ valves 2.xts-090194 ) 4.3 - Page 37 of 41 i

9 i SECTION 4.4 NOTES / COLD SHUTDOWN JUSTIFICATIONS / REFUELING OUTAGE JUSTIFICATIONS l-I

Revision 13a NOTE 40 The following valves are' backflow tested by way of a seat leakage test. These 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. 1/2SI8815 1/2SI8900A-D 1/2SI8818A-D 1/2SI8905A-D 1/2SI8819A-D 1/2 SIB 949A-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 1/2SI8940A-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 partial flow and backflow tested at cold shutdown. NOTE 43 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 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, these valves will be tested at Cold shutdown with all 4 RCPs off. Refer to VR-8 for additional information. (9679AA/WPF/080795) 4.4 Page 9 of 16

Revision 13a NOTE 45 The feedwater tempering flow check valves (1/2FWO36A-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 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 l 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 l valve closure. NOTE 46 " Deleted" i i l l (9679AA/WPF/080795) 4.4 Page 10 of 16

Revision 13a 1 REFUELING OUTAGE JUSTIFICATION ROJ-1 l Valve (s)- OSX127A,B (Deep Well Pump Discharge Check Valves to SX Cooling Towers) OSX143A,B (Circ Water Makeup Discharge Check Valves to SX Clg Towers) ASME Code Class: 3 ASME Code Catecorv (IRV-2200) 9 BC Valve Function (s) 9 a. OSX127A,B: These check valves 221B (not covered in this justification) to provide a flow path for Deep Well Water to the Ultimate Heat Sink as a backup to the Emergency Makeup Pumps. In addition, these check valves are required to close to prevent loss of required Emergency Makeup water flow into the Deep Wells and not to the Ultimate Heat Sink when required. b. OSX143A.B: These check valves are required to close to prevent backflow into the circ Water Makeup (non-safety) supply line to the SX towers. These valves are located at the safety related/non-safety related boundary. Basis for Deferral of Backflow Testino to Refuelino Outaces: The OSX127A/B and OSX143A/B check valves were thoroughly investigated for l possible closure testing, and it was determined that the only way to determine closure would be through nonintrusive techniques. Traditional methods of measuring leakage, etc. were not possible. The initial testing on these valves occurred in March of 1995 (prior to the end date of B2R05). Initially, acoustic testing was investigated using various system lineups with limited results. Alternate testing methods, which would establish future repeatable tests, were investigated. Both radiography and UT testing were attempted. UT testing produced a wec.k backwall signal and is inadequate at this time. Radiography produced the most conclusive test results concerning valve closure. Subsequent test results with radiography have confirmed that it is the most conclusive and repeatable. Performing the radiography on these valves requires the use of outside contractor personnel. This is costly and impractical to perform on a J. quarterly basis. It is much more practical and less costly to perform the radiography on these valves during refueling outages, when radiography crews are available and on site performing other radiography associated with the refueling outage. This justification is consistent with NUREG 1482, section 3.1.1., in which deferral of testing to refueling is allowed without relief, provided the appropriate portions of OM-10 are followed. Test Frecuency: The OSX127A/B and OSX143A/B backflow radiography tests will be completed during each refueling outage (U-1 and U-2). (9679AA/WPF/080795) 4.4 Page 16a of 16 4 1

l 1 Revision 13a REFUELING OUTAGE JUSTIFICATION ROJ-2 Valve (S)* 1/2SI8948A-D (SI Accumulator 2nd Outlet Check Valves) 1/2SI8956A-D (SI Accumulator lat Outlet Check Valves) j ASME Code Class: 1 ASME Code Category: AC i Valve Function (s) ? The 1/2 SIB 948A-D and 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 16 check valves have safety functions in both the open and closed directions. This Refueling Outage Justification will address the check valve open test only. The 221D direction function of these check valves is to permit the injection of borated water into the reactor vessel cold legs during the passive injection phase of a safety injection. 1 Basis for Deferral of Full Flow Testina to Refuelino Outaces: Check valves 1/2SI8956A-D cannot be full or partial tested during unit operation due to the pressure differential between the accumulators (650 psig) and the reactor coolant system (2235 psig). Full or partial stroke exercising of these valves could occur only with a rapid depressurization of the reactor coolant system. Check valves 1/2SI8948A-D cannot be full or partial stroke tested during unit operation without depressurizing the RCS to 1600 psig (to stroke using Safety Injection pumps) or to 200 psig (to use the Residual Heat Removal pumps), e Full stroking these valves during cold shutdowns, routine or forced, would impose hardship with no compensating increase in plant safety. To perform this test, the reactor coolant system (RCS) must be at approximately 40 poi with all 4 reactor pumps (RCPs) off and accumulator pressure at approximately 100 psi over RCS pressure. The full stroke test is accomplished by opening the flowpath to the RCS by stroking the respective SI8808 valve open, and then closed. During this " burping" of the accumulators, strip chart recorders are used to obtain data that will be used to calculate the pressurizer level increase with time and verify that the flow that passed through the respective SI8956 and SI8948 i check valves is greater than a calculated full flow value for the check valves. In addition, nonintrusive testing, which has proven the full stroke for each valve in the past, is performed on one valve from each group, consistent with NUREG 1482, section 4.1.2 (this also eliminates high radiation exposures associated with the nonintrusive testing of all valves). i (9679AA/WPF/080795) 4.4 Page 16b of 16

^ Revision 13a i REFUELING OUTAGE JUSTIFICATION ROJ-2 (continued) A concern with testing is that at or near end-of-core life, the boron concentration of the RCS is low compared to the approximate t 2000 ppm concentration of the accumulators. This injection test ) requires that approximately 8 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. f The feed and bleed process required to restore desired RCS boron j concentration would result in considerable increases in j restoration time and in amounts of radioactive water rejected from the site. d The partial stroke exercising of the 1/2SI8948 valves will be completed during cold shutdowns using the RH or SI pumps since there are alternate flowpaths available and it can be done with little or no effect on the RCS system. Partial stroking of the d 1/2SI8956 valves will not be completed during cold shutdowns because the same test methodology used for the full stroke test j would be required to perform the partial test. ] This justification is consistent with NUREG 1482, Section 3.1.1, in which deferral of testing to refueling is allowed without relief, provided the appropriate portions of OM-10 are followed. Test Freauency: 1 Byron Station will full stroke exercise (CT) the 1/2SI8948A-D and 1/2SI8956A-D check valves during each respective U-1 or U-2 refueling outage and partially stroke the 1/2SI8948 valves during cold shutdowns. j The ISI8948A-D, 1SI8956A-D, 2SI8948A-D, and 2SI8956A-D valves each represent their own sampling group since each set of valves are of the same size, model number and system function. Under the sampling Program, one valve will be nonintrusively tested per group (one SI8948 valve and one SI8956 valve per outage), on a rotating schedule, while the balance of the plant groups will be flow tested with less than accident flow. If a problem is found with the nonintrusively tested valve, then the remaining three valves in that particular group will km checked using nonintrusives during the same outage ] I (9679AA/WPF/080795) 4.4 Page 16c of 16 1

4 8 SECTION 4.6 RELIEF REQUESTS l i 1 ) 4

....-...~ Revision 13a \\. 4 4 DRAFT 4 RELIEF REOUEST VR-2a 1 3 " Deleted" I i 4 d 1 Y l J s. e F '? 1 t s' i 4 4 r I i 4 1 e i 4 d l i j t 4 (9679AA/WPF/080795) 4.6 Page 6 of 74 5 --<y, m.

Ravision 13a RELIEF REOUEST VR-5 " Deleted" 1 1 1 (9679AA/WPF/080795) 4.6 Page 14 of 74

.~ ~.. -l Revision 13a j RELIEF REQUEST VR-28 i -1. Valve N"=her (Main Feedwater Header Check. Valves) 1FWO79A-D 2FWO79A-D 2. Number of Items: 8 3. ASME Code Cateoorv (IWV-2200) ? C-4. ASME Code Section XI Reauirements check Valves shall be exercised to the position required to fulfill-their function unless.such operation is not practical during plant operation. Valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be partial stroke exercised during power operations or full-stroke exercised during cold shutdowns. Normally open valves... shall be tested in a manner that proves the disk travels to the seat promptly on cessation or reversal of flow (IWV-3522). 5. Basis for Relieft The main feedwater header flow check valves are 16-inch tilting disk check valves built with a vertical piston and rod assembly that serves as an anti-slam mechanism; the valves do not have external position indicators. The valves are designed to have a delayed closure time of 2 to 3 seconds to isolate flow during a feedwater line break accident l without inducing significant water hammer transients. Their closed safety functions are to 1) mitigate a loss of secondary inventory and/or make-up, and 2) provide pressure integrity between the safety and non-safety related portions of piping, j These valves cannot be exercised to their closed position during power operations because feed flow to a steam generator would be isolated, causing loss of Steam Generator water inventory and a subsequent low S/G level Reactor Trip. Non-intrusive testing during cold shutdowns has been attempted at Braidwood and Byron Stations with still unproven results. Specifically, ultrasonic examination of the piston rod position has not conclusively demonstrated valve closure: The anti-slam mechanism prevents the disk from travelling completely to its seat after cessation of forward flow. In. fact, during normal feedwater system shutdown evolutions, the valves routinely come to rest at a partial open position -- substantial reverse flow or reverse differential pressure would be required to bring the disk into contact with the seat. l 1 (9679AA/WPF/080795) 4.6 Page 74a of 74 l i - ~... -.,., _ -, ,n

Revision 13a RELIEF REOUEST VR-28 (continued) Traditional backflow testing methods were considered, but it has been determined that reverse flow and/or differential pressure sufficient to close the valve cannot be obtained without major modification to the existing plant configuration. Clearly, acoustic testing techniques which require contact noise between disk and seat cannot be used for this application, either. Full-stroke exercising these valves by performing complete disassembly and inspection of each valve during cold shutdown conditions is undesirable and impractical because-

1) The main feedwater system would have to be drained.

This would both delay reactor start-up and eliminate a method of reactor decay heat removal. The latter, in particular, could adversely affect shutdown safety.

2) Complete disassembly often requires machining activities that remove metal from the valve walls which may jeopardize minimum wall thickness.

If minimum wall thickness is approached, then costly and difficult weld overlay techniques and associated machining would be required.

3) Scaffolding must be built and removed to allow examination of these valves.

Full-stroke exercising these valves by performing partial disassembly (i.e. removing only the actuator bonnets) of all four valves on a l refueling o,r cold shutdown frequency is burdensome because of the system draining necessary and the potential wall material loss associated with disassembly and inspection work. 6. Alternate Testina: The four valves on each unit are of the same design (manufacturer, size, model number, and materials of construction) and have the same service conditions, including orientation; therefore, they form a sample disassembly group. One valve from each group, on a per unit basis, will be fully disassembled and examined each refueling outage. If the initial disassembled valve is not capable of being full stroke exercised or if there is binding or failure of internals, subsequent disassembly and inspection of the remaining three group members will be commensurate with the initial valve's failure mode. (9679AA/WPF/080795) 4.6 Page 74b of 74

I Revision 13a RELIEF REOUEST VR-28 (continued) This means that the remaining three valves may be " partially" disassembled, which refers to the removal of the actuator [ upper) bonnet for inspection of the piston, piston seal ring, mating surfaces, and also for manual full stroke closing. A " fully" disassembled valve (minimum of one per outage) would additionally include removal of the valve body (lower] bonnet, giving access to the disk and seating

surfaces, The subsequent disassembly requirements would be satisfied through either " partial" or " full" disassemblies depending on what is found with the initial disassembled valve. This will both satisfy the testing requirements to demonstrate all four valves' ability to perform their safety function and minimize the potential concerns regarding minimum wall thickness discussed earlier. This approach is consistent with Generic Letter 89-04, position 2.

A partial stroke test following complete installation will not be required for these check valves since an "as left" stroke is performed prior to the installation of the actuator bonnet; installation of the actuator bonnet does not affect the stroke of the valve. In addition, the plant operatee with these valves in the open position and open stroke problems would be readily identified during plant startup. 7 Justification: Because major plant modifications would be required to establish enough reverse flow / pressure to fully close the valves, in-service testing in accordance with NRC Generic Letter 89-04 is justified. The Generic Letter allows valves of similar design, service conditions, etcetera to be classified in sample disassembly and inspection groups of up to four members with testing of one valve in the group during each refueling outage. In-service testing of the valves that close on a feedwater isolation signal, including the safety-related feedwater containment isolation valves (FWOO9A-D), the non-safety-related feedwater regulating valves (FW510, 520, 530, 540), and the feedwater regulating bypass valves (FW510A, 520A,...) helps ensure that the power operated valves and the system are capable of safely responding to an initiating feedwater line break accident regardless of FWO79 check valve position. The alternate test method is sufficient to ensure operability of these valves and is consistent with Generic Letter 89-04 sample disassembly and inspection program. The alternate test method in conjunction with other existing in-service testing of feedwater valves is more than sufficient to ensure the system's ability to safely respond to a feedwater line break accident. 1 2 i (9679AA/WPF/080795) 4.6 Page 74c of 74 ]

. ~.... -. -....... -...., - 4 ~ Ravision.13a' RELIEF REOUEST VR-28 (continued) i-l 1 8; Anolicable Time Period This relief is requested once per quarter during the first inspection 4 interval and will be implemented prior to NRR review. 1

9. Anoroval Status

) ij Relief granted'per Generic Letter 89-04, t i 1 l 4 } i-4 .l ~ I i f 4 s r-i d t 1 1 4 i .4 1 i ' (9679AA/WPF/080795) 4.6 Page 74d of 74 . ~.

. _ ~. _. i \\ Revision 13a RELIEF REOUEST VR-29 i I 1. Valve Number (Essential Service Water Makeup pump Discharge Check Valves) OSXO28A OSX028B 2. Number of Items: 2 I j 3. ASME Code Catecorv (IWV-2200) ! C 4. ASME Code Section XI Recuirements: I a. IWV-3522 States: Check Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation. Valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be partial stroke exercised during power operations or full-stroke exercised during cold shutdowns. 5. Basis for Relief: i ) The backflow test for the OSX028A/B check valves was added to the IST Valve Program in Rev 12 due to their closure function to prevent piping drain down from the basins to the river screen house. Since their i incorporation intt te program, the OSX028A and OSX028B check valves have been successfully tested for closure using acoustics during the a respective A or B makeup pump runs a minimum of once each quarter. Each valve has successfully been tested 7 consecutive times without any signs of degradation or failure. ( { 6. Alternate Testinc t Byron proposes to complete hgih of the OSXO28A/B backflow acoustic tests at a minimum of once per 18 months. 7. Justification Nonintrusive techniques are considered to be "other positive means" in accordance with ASME Section XI IWV-3522. As described in NUREG 1482, nonintrusive techniques may be used to verify the capability (of check valves]' to open, close, and fully stroke. The acoustic testing of both of these valves on an eighteen month frequency (at approximately the same time period) is justified for the following reasons: ) j a. Performing the acoustic test on both valves on an eighteen month frequency will ensure the operational readiness of the valves. l These valves have been in operation for approximately 10 years without falure and have successfully passed their acoustic testing for seven tests in a row since being added to the IST program. (9679AA/WPF/080795) 4.6 Page 74e of 74 i 3

__._._.-._....__._._._....m 4 Revision 13a RELIEF REQUEST VR-29 (continued) j i i l b. The A and B SX makeup pump surveillances will continue to be l executed for IST on a quarterly basis. During this testing, the l check valve will be experiencing the same evolution as it does when j the backflow acoustic test is completed. The check valve will be opened and then closed on cessation of flow. The full flow test i will be completed quarterly, verifying operability in the forward flow direction, 1 I c. In addition, this will reduce the amount of manhours required in i performing the acoustics at the river screen house a few miles from the Byron plant on the Rock River. For each test, approximately i one full day is expended by the qualified acoustic monitoring i individual to transfer the equipment to the river screen house, set up the equipment, record the data, transfer the equipment back to i the station, evaluate the data, and complete surveillances. l 8. Acolicable Time Periodt } This relief request is requested once per quarter during the remainder l of the first inspection period. } j 9. Anoroval Statust i l l Approval Pending. i i 1 i I i i t i i i i (9679AA/WPF/080795) 4.6 Page 74f of 74 --v-

4 Revision 13a RELIEF REOUEST VR-30 1. Valve Number: OSX127A,B (Deep Well Pump Discharge Check Valves to SX Cooling Towers) 2. Number of Itemst 2 3. ASME Code Catecorv (IWV-2200)r.BC i 4. ASME Code Section XI Recuirements a. IWV-3522 States: Check Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation. Valves that cannot be exercised during plant operation shall be specifically identified by the owner and shall be partial stroke exercised during power operations or full-stroke exercised during cold shutdowns. 5. Basis for Relieft The OSX127A and OSX127B check valves open to provide a flow path for Deep Well Water to the Ultimate Heat Sink as a backup to the Emergency Makeup Pumps. The nonsafety related, seismically qualified, Deep Well + Pumps (OWWO1PA/0WWO1PB) are physically inaccessible and were not designed or installed in accordance with ASME code and are not required as long as the Emergency SX Makeup Pumps are available. Although the pumps do not fit the requirements of the IST Program, they do have significant importance and are tested outside of the IST Program as required per Tech Spec 3/4.7.5. The safety related check valves referenced in this relief request were conservatively added to the IST Program in the open direction to acknowledge the importance of ensuring the deep well flow path is capable of transferring water to the ultimate heat sink. 4 In reference to the deep well pumps, per Tech Spec 4.7.5, the Ultimate Heat Sink shall be determined operable: at least once per 31 days by starting each deep well pump, operating it for at least 15 minutes and i verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct position and; at least once per 18 months by verifying each deep well pump will provide at least 550 gpm flow rate. (9679AA/WPF/080795) j 4.6 Page 74g of 74

~ Rsvision 13a RELIEF REOUEST VR-30 (continued) 6. Alternate Testinc t s Byron proposes to complete a full stroke test for check valves OSX127A and OSX127B at a minimum of once every eighteen months, as required by Technical Specifications. Testing on a more frequent basis would be completed in accordance with station committments. This test will be accomplished by executing the Byron Station deep well surveillance in which, first, the "A" pump is lined up to the "A" basin and an l ultrasonic flowmeter is attached to the makeup line (following the removal of a security barrier). The demand (throttling) valve is opened .up until a minimum flow reading of at least 550 gpm is obtained through i the line (and check valve OSX127A). In addition, the amperage of the pump is recorded. Then, the "A" pump is shut down and the valves are re-aligned to the "B" Basin, in which there is no accessible piping of l adequate length to attach an ultrasonic flowmeter. However, the same "A" pump is restarted and set to an amperage greater than or equal to i{ the amps just recorded for the A basin flowpath. Byron Station trends flow versus amps for the Deep Well Pumps to help track degradation with the pumps, as required through a station commitment to the NRC. This j should assure a full stroke test for the OSX127B check valve (using other " positive means"). In addition, the A and B basins overflow into each other at 64% level, minimizing the importance of knowing the exact flow through the "B" makeup line (although it should be the same as just f recorded through the "A" makeup line). Finally, the "B" pump is verified to generate an output greater than 550 gpm through the "A" train makeup line to satisfy the Tech Spec requirement. In addition to the above testing, Byron will ensure operability of the Deep Well Pumps by executing an operating surveillance monthly in which a the "A" pump is lined up to the "A" basis and the "B" pump is lined up to the "B" basin. In each case the demand for each pump will be at or l near 100%, which should assure a full stroke of each check valve every month. However, since flow is not measured, it will be considered a partial stroke each month. j 7. Justification The alternative testing requirements will not compromise the level of quality and safety when compared to quarterly code testing for the following reasons: l a. Byron Tech Specs are being satsfied through the eighteen month Deep Well Pump procedure and the monthly operating procedure. This testing will satisfy the operability requirements for the Deep Well Pumps and the flowpaths to the SX basin. In addition, the same or more flow is transferred through the check valves each month than during the procedure executed every eighteen months. The flowrates would be verified during the eighteen month procedure, i (9679AA/WPF/080795) 4.6 Page 74h of 74 J

_ -.. _ ~... f Revision 13a RELIEF REOUEST VR-30 (continued) b. An ultrasonic flowmeter cannot be used on the "B" basin makeup line due to the lack of accessible piping available. In addition, at this time, inconclusive acoustic results were obtained for the full stroke testing on these valves. Finally, flow versus amps is trended to help aid in determining any degradation in the Deep Well Pumps. 8. Aeolicable Time Period: This relief request is requested once per quarter during the remainder of the first inspection period. 9. Anoroval Status Approval Pending i (9679AA/WPF/080795) 46 Page 741 of 74}}

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