ML20093K980
| ML20093K980 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 10/18/1995 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20093K973 | List: |
| References | |
| PROC-951018, NUDOCS 9510250130 | |
| Download: ML20093K980 (261) | |
Text
fT 1
, McGuire Unit 1 l
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DUKE POWER COMPANY McGUIRE NUCLEAR STAllON - UNIT 1 l l PUMP INSERVICE TESTING PROGRAM )
ASME OM CODE-1987, OM Part 6 (OMa-1988 Addenda) ;
l INTRODUCTION The inservice testing of ASME Code Class 1,2 and 3 pumps provided with an emergency power source will be tested as required by ASME Operations and Maintenance Standards Part 6 (OM-6), OMa-1988, of the ASME Code for Operation and Maintenance of Nuclear Power Plants, as referenced in 10CFR50.55a (January 1,1993 Edition), except where specific written relief has been granted by the Nuclear Regulatory Commission. The effective date of the submittal is March 1,1994.
Technical Specification 4.0.5 requires inservice testing of ASME Code Class 1,2 and 3 pumps in accordance with Section XI of the ASME Boiler and Pressure Boiler Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i). Pumps were selected for inclusion in the IST Program (Section 1.2) which fall within this category, as required by this Technical Specification. Pumps within the above ASME categories which are required to mitigate the consequences of an accident, shutdown the reactor or maintain shutdown are included in the program. Testing requirements are j identified for each pump which ensure that the pump will perform as designed in response to )
an accident, in shutting down the reactor, or in maintaining shutdown. Acceptance criteria are j specified in accordance with ASME Boiler and Pressure Vessel Code Subsection IWP. The l safety functions of the pumps listed in Section 1.2 are included in the Design Basis Documents, and fall within the basic categories of accident mitigation, reactor shutdown, and maintaining shutdown. Post modification testing requirements are included in the applicable Nuclear System Directive; a modification test plan is required to be developed to verify proper operation. The Code requires the determination of new reference values after pump repair or replacement, or maintenance which could impact operation. These Code requirements and programmatic controls ensure that the pump inservice test program remains current following modifications performed under 10 CFR 50.59. The documents used in development of this program include the following:
. McGuire Technical Specifications.
. Safety Analysis Report.
. ASME Section XI, lWP (1980).
. ASME Operations and Maintenance Standards Part 6 (OM-6), OMa-1988.
. Genene Letter 89-04.
. Supplement 1 to Generic Letter 89-04.
. NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants.
. Safety Evaluation Report for the McGuire IST Program dated October 21, 1994.
10/18/95 SECTION 1.1 1 of 2 9510250130 951019 PDR 0 ADDCK 05000369 PDR
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McGuire Unit 1 ;
L A description of the Inservice Testing Program, Justification for Testing Deferral, as well '
l' as Specific Relief Requests from code requirements determined to be impractical,is described in the submittal.
r NOTES: 1)- OMa-1988 Part 6, Section 7.3 requires the signature of the [
L person or persons responsible for conducting and analyzing the test. The dated initials of the person or persons responsible for conducting and analyzing the test will be used in place of a signature in the record of tests, initials shall be construed as signatures to meet the intent of OM-6. ,
- 2) A Supplemental Test Program has been established, which '
inicudes components which have been determined important to ,
safety and prudent to test, but which are not explicitly under the l scope of ASME Codes and Standards.
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10/16/95 SECTION l.1 2 of 2
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UNIT 1 - McGUIRE NUCLEAR STATION Pump Inservice Testing General Data Pump 10.Numtwr Description Code Class Flow Diagram Applicable Rollef Requests Test Frequency Romerks 1KCPU0004 Component Cooling 3 MC-1573-1.0 RR-l.3.1, RR-l.4.3 Quarterly NONE Water Pump 1B2 1NDPU0001 Residual Heat Removal 2 MC-1561-1.0 RR-l.3.1, RR-l.4.4 Quarterly The ND Testing Plan Pump 1 A meets other code requirements unless otherwise specified.
l 1NDPU0002 Residual Heat Removal 2 MC-1561-1.0 RR-l.3.1, RR-l.4.4 Ouarterly The ND Testing Plan Pump 1B meets other code requirements unless otherwise specified.
i 1NIPU0009 Safety injection Pump 2 MC-1562-3.0 RR-l.3.1, RR-l.4.5 Quarterly The NI Testing Plan 1A meets other code requirements unless otherwise specified.
1NIPU0010 Safety injection Pump 2 MC-1562-3.0 RR-l.3.1, RR-1.4.5 Ouarterly The NI Testing Plan 1B meets other code requirements unless otherwise specified.
1NSPU0001 Containment Spray 2 MC-1563-1.0 RR-l.3.1 Quarterly NONE Pump 1 A SECTION l.2 10/12/95 3 OF 10
v UNIT 1 - McGUIRE NUCLEAR STATION Pump Inservice Testing Specific Data Discharge Differential Reference Pump 10. Number speed inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision l 1KCPU0004 Not Required RR-l.4.3 Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal Requirements Requirements Requirements 1NDPU0001 Not Required RR-l.4.4 Meets Code Meets Code RR-l.3.1 RR-l.4.4 Vertical Line 22 Requirements Requirements Shaft Centrifugal 1NDPU0002 Not Required RR-l.4.4 Meets Code Meets Code RR-l.3.1 RR-l.4.4 Vertical Une 22 Requirements Requirements Shaft Centrifugal 1NIPU0009 Not Required RR-l.4.5 Meets Code Meets Code RR-l.3.1 RR-l.4.5 Centrifugal 22 Requirements Requirements 1NIPU0010 Not Required RR-l.4.5 Meets Code Meets Code RR-l.3.1 RR-l.4.5 Centrifugal 22 Requirements Requirements 1NSPU0001 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal SECTION I.2 10/12/95 4 OF 10
- - - _ - . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ = __ -________________________ ____ _ _ ____.
UNIT 1 - McGUIRE NUCLEAR STATION Pump Inservice Testing General Data Pump ID. Number Description Code Class Flow Diagram Applicat:le Rollef Requests Test Frequency Remarks 1NSPU0002 Containment Spray 2 MC-1563-1.0 RR-l.3.1 Quarterly NONE Pump 1B i
1NVPU0015 Centrifugal Charging 2 MC-1554-1.0 RR-l.3.1, RR-l.4.6 Quarterty- The NV Testing Plan Pump 1 A Miniflow; meets other code Refueling-Full requirements unless Flow otherwise specified.
(RR-l.4.6) 1NVPU0016 Centrifugal Charging 2 MC-1554-1.0 RR-l.3.1, RR-l.4.6 Quarterfy- The NV Testing Plan Pump 1B Miniflow; meets other code Refueling-Full requirements unless Flow otherwise specified.
(RR-I.4.6) 1NVPUOO27 Boric Acid Transfer 3 MC-1554-5.0 RR-l.3.1 Ouarterly NONE Pump 1 A 1NVPU0028 Boric Acid Transfer 3 MC-1554-5.0 RR-l.3.1 Quarterly NONE Pump 1B 1RNPU0003 Nuclear Service Water 3 MC-1574-1.1 RR-l.3.1 Quarterly NONE Pump 1 A SECTION 12 I 10/12/95 S OF 10
UNIT 1 - McGUIRE NUCLEAR STATION ,
Pump Inservice Testing Specific Data Discharge Differential Reference Pump ID. Number speed Inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision 1NSPU0002 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 1NVPU0015 Not Required RR-l.4.6 Meets Code Meets Code RR-l.3.1 RR-l.4.6 Centrifugal Requirements Requirements +
r 1NVPU0016 Not Required RR-IA.6 Meets Code Meets Code R R-l.3.1 RR-l.4.6 Centrifugal i Requirements Requirements 1NVPU0027 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal Requirements Requirements Requirements Requirements F
1NVPU0028 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal f Requirements Requirements Requirements Requirements l
1RNPU0003 Not Required Meets Code Meets Code Meets Code R R-l.3.1 Meets Code Centrifugal 22 :
Requirements Requirements Requirements Requirements l
SECTION l.2 10/16/95 6 OF 10 [
UNIT 1 - McGUIRE NUCLEAR STATION ,
Pump Inservice Testing General Data j
Pump ID. Number Description Code Class Flow Diagram Applicable Relief Requests Test Frequency Remarks i 1RNPU0004 Nuclear Service Water 3 MC-1574-1.1 RR-l.3.1 Quarterly NONE ,
! Pump 1B l
1WNPUOO94 Diesel Generator Sump 3 MC-1609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 1 A2 dry sump pumps per OMa-1988, Part 6 section 5.5.
1WNPU0096 Diesel Generator Sump 3 MC-1609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 1A3 dry sump pumps per OMa-1988, Part 6 section 5.5. ;
1WNPUOO95 Diesel Generator Sump 3 MC-1609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 1B2 dry sump pumps per OMa-1988, Part 6 section 5.5. I 1WNPU0097 Diesel Generator Sump 3 MC-1609-7.0 RR-l.3.1 Two Year Two year frequency for ,
Pump 183 dry sump pumps per ,
OMa-1988, Part 6 section 5.5. i SWZPU0001 Groundwater Drainage 3 MC-1581-1.0 R R-l.3.1 Quarterly NONE Sump A Pump A ,
j sECTION 12 10/12/95 7 OF 10 -
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LINIT 1 - McGUIRE NUCLEAR STATION Pump Inservice Testing Specific Data Discharge Differential Reference Pump ID. Number speed inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision 1RNPU0004 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal 22 Requirements Requirements Requirements Requirements 1WNPU0094 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line ilequirements Requirements Requirements Requirements Shaft Centrifugal 1WNPU0096 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements ' Shaft Centrifugal 1WNPU0095 Not Required Meets Code Meets Code Meets Code RR-I.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 1WNPU0097 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 1WZPU0001 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line 21 Requirements Requirements Requirements Requirements Shaft Centrifugal SECTION I 2 10/16/95 8 OF 10
McGuire Unit 1 General Relief Reauest RELIEF REQUEST: 1.3.1 PUMPS: All pumps in the Inservice Test Program ,
TEST REQUIREMENTS: OMa-1988 Part 6 Section 6.1 (Table Sa) specifies the allowable range '
for acceptable operation of vibration measurements.
BASIS FOR RELIEF: Experience has shown that smooth operating pumps (Vr s 0.075 in/sec) often fall in the alert range of vibration measurement when compared to the acceptance criteria given in OMa 1988 Part 6, Table 3a. The Code does not include provisions for a fixed band acceptance criteria for these ,
pumps. The Altemative Testing provided below applies to all pumps in the Testing Program by establishing a threshold of vibration of s 0.075 ,
in/sec. In addition to this, OMa-1988 Part 6 does not specifically address different types of positive displacement pumps. Since McGuire has internal gear positive displacement pumps, the Alternate Testing ,
below will be used for these pumps.
ALTERNATE TESTING: In addition to the vibration specifed in OMa-1988 Part 6, Table 3a, the following ranges shall be used.
Acceptable Alert Required Range Range Action Range For all pumps when 0 to 0.19 in/sec > 0.19 5 0.45 in/sec > 0.45 in/sec Vr s 0.075 in/sec l
For centrifugal, vertical 5 2.5
- Vr > 2.5
- Vr to 6
- Vr or > 6
- Vr or line shaft and positive > 0.325 to 0.70 in/sec > 0.70 in/sec displacement pumps except reciprocating when Vr > 0.075 in/sec For reciprocating pumps, s 2.5
- Vr > 2.5
- Vr to 6
- Vr > 6
- Vr when Vr > 0.075 in/sec I
l Revised by revision 22 10/12/95 SECTION 1.3 1OF1
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McGuire Unit 1 SDeCific Relief Reauest RELIEF REQUEST: 1.4.4 PUMPS: 1NDPU0001,1 A Residual Heat Removal Pump 1NDPU0002,1B Residual Heat Removal Pump TEST REQUIREMENT: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly Residual Heat Removal Pump test will meet accuracy requirements for assuring Residual Heat Removal Pump operability per Technical Specifications.
ALTERNATE TESTING: The Residual Heat Removal Pumps will be tested according to the following program, which is consistent with Generic Letter 89-04.
These pumps have process instrumentation installed such that there are two suction pressure gauges (0-60 psig and 0-600 psig), and one discharge pressure gauge, ( 0-1000 psig). Each has a 0.5% accuracy. l This is done to provide accurate pressure indication in either the l recirculation or the heat removal condition of operation. As such, there are times when the 3 times the reference range requirements cannot be met.
Quarterly The Residual Heat Removal Pumps will be tested quarter 1y to verify Technical Specifications are met. The test measures difierential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1.
The test loop used in the test has a flow measuring orifice installed, however, the system resistance cannot be adjusted with the associated throttling valve without invalidating the Residual Heat Removal system )
flow balance (a Tech Spec balance of flow to all 4 cold legs.) Therefore, flow through this loop will be recorded for information only.
The instrumentation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. Since the instrumentation used to measure suction and discharge pressure is more accurate than code requirements (0.5% vs. 2%) using the process instrument for this test will yield results within the overall accuracy requirements of the code and will meet i applicable accuracy requirements for the determination of operability per l Technical Specifications. Typical values for ND suction pressure in mini-10/12/95 SECTION l.4 6 OF 12
McGuire Unit 1 Specific Relief Reauest RELIEF REQUEST: 1.4.4 (Continued) flow are 48-81 psig, and discharge pressures are in the 230-260 psig range. Therefore, the process range for discharge pressure (0-1000 psig) will not meet the three times criteria; the appropriate suction pressure loop can be used, which is within the three times requirement.
The accuracy of these process instruments (0.5%) is well below the requirements specified in Table 1 of OM-6 for instrument accuracy (2%).
The actual reading error at test pressure due to the process instrument is 2.2 % (0.5
- 1000/230) for discharge pressure at the low end of this range (ND pump procedures specify that instrumentation must meet the three times criteria), if a 0-690 psig gauge was used with 2% accuracy, the reading error would be 6% (2
- 690/230). When the requirements of Oma-1988 Part 6, Section 4.6.1.2.a and Table 1 are combined, the actual instrument error introduced into the test is less than the code allowable (2.2 % vs. 6 % at the low (conservative) end). Using the process instruments for suction and discharge pressure data does not degrade the quality of the test and meets the intent of the instrumentation requirements of the code.
Befuelina Outace Full flow vibration measurements will be taken during refueling outages as part of the IST Supplemental Program. ,
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Revised by revision 22 l
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10/12/95 SECTION 1.4 7 OF 12
McGuire Unit 1 Specific Relief Reaues_t RELIEF REQUEST: 1.4.5 PUMPS: 1NIPU0009,1 A Safety injection Pump 1NIPU0010,1B Safety injection Pump TEST REQUIREMENT: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly Safety injection Pump test will meet accuracy requirements for assuring Safety injection Pump operability per Technical Specifications.
ALTERNATE TESTING: The Safety injection Pumps will be tested according to the following program, which is consistent with Generic Letter 89-04.
Quarterly The Safety injection Pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration '
data will be trended. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1. The test loop has a flow measuring orifice installed, however, there is no means provided to vary the system resistance to set either the flow or differential pressure. Therefore, flow through this loop will be recorded for information only.
The instrumentation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications. The process instruments meet the three times criteria, however in the event a test instrument is to be used, based on available equipment, it may not meet the three times criteria. In these instances, the accuracy of the test instruments is 0.25%, and this accuracy applied over the range of the instrument will meet the uncertainty allowed by the code assuming an accuracy of 2%.
Typical values for Ni suction pressure are in the 25-51 psig range, and discharge pressures are in the 1500-1575 psig range. Test equipment used for suction and discharge pressures may not meet the three times 10/12/95 SECTION 1.4 8 OF 12
McGuire Unit 1 l
Specific Relief Reauest j RELIEF REQUEST: 1.4.5 (Continued) :
l criteria, however these instruments will have 0.25% accuracy. The NI i pump procedures specify that if a test instrument is needed for suction pressure, a 0-60 psig instrument is preferred, and that the range of the instrument must not exceed 0-100 psig. They also specify that it a discharge pressure test instrument is to be used,0-2000 psig range is ,
preferred, not to exceed 0-4500 psig. Using the low end suction l pressure of 25 psig with the high end allowable gauge, accuracy is 1% !
(0.25
- 100/25);if a 0-75 psig gauge was used with a 2% accuracy, the !
code allowable would be 6% (2
- 75/25), so that use of this gauge would ,
be within the code requirements. Using the low end discharge pressure >
with the Ngh end allowable gauge, accuracy is 0.75% (0.25
- l 4500/1500); this is at the three times range, and use of a 2% accuracy - !
gauge would produce a total 6% allowable error. Therefore, using these ,
test instruments for suction and discharge pressure data does not degrade the quality of the test and meets the intent of the ;
instrumentation requirements of the code.
Refuelina Outaoe !
Full-flow vibration will be recorded under the IST Supplemental Program. i i
t Revised by revision 22 '
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10/12/95 SECTION I.4 9 0F 12 .;
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l McGuire Unit 1 Specific Relief Reauest l
RELIEF REQUEST: 1.4.6 i
PUMPS: 1NVPUOO15,1 A Centrifugal Charging Pump 1NVPUOO16,1B Centrifugal Charging Pump !
t TEST REQUIREMENT: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each ;
instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The suction and discharge pressure gauges (0-60 psig and 0-3000 psig) installed for the pump have an accuracy of 0.5%. These pumps are aligned from the VCT for the quarterly test.
Since these pumps are tested with different levels of VCT pressure, the suction pressure may vary over a range of approximately 15 to 50 psig.
- Since the uncertainty associated with using the process gauge is better than that allowed by code requirements, (2% vs. 6% dcterm!ned by 0.5
- 60/15 vs. 2
- 45/15) the instrumentation used for the quarterly Centrifugal Charging Pump test will meet accuracy requirements for assuring Centrifugal Charging Pump operability per Technical Specifications.
Regarding instrument accuracy during the refueling outage testing (in Relief Request 1.4.6), the range of the h!ghest suction pressure test gauge allowed for the full flow point will be 0-450 psig, and the range of the highest discharge pressure test gauge allowed (for the full flow point) will be 0-4500 psig. Suction pressure is typically 140 to 160 psig, and discharge pressure ranges from approximately 1000 to 2700 psig, so that overall suction and discharge pressure reading accuracy are 0.8 %
(0.25
- 450/140) and 1.1 % (0.25
- 4500/1000), respectively. If a 0-420 psig suction pressure gauge was used with 2% accuracy, allowable accuracy would be 6 % (2
- 420/140), and if a 0-3000 psig discharge pressure gauge was used with 2% accuracy, allowable accuracy would be 6 % (2
- 3000/1000). Therefore, using these test instruments for suction and discharge pressure data (for the full flow point) does not degrade the quality of the test and meets the intent of the instrumentation requirements of the code. A 1% uncertainty is conservatively added for the flow orifice.
10/12/95 SECTION l.4 10 OF 12
McGuire Unit 1 Specific Relief Request i
RELIEF REQUEST: 1.4.6 (Continued) .
ALTERNATE TESTING: The Centrifugal Charging Pumps will be tested according to the following program, which is consistent with Generic Letter 89-04.
Quarteriv The Centrifugal Charging Pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrumentation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1. The flow through the miniflow line to the Volume Control Tank will be assumed to be constant at the orifice design conditions (60 gpm).
Refueling Outage During each refueling outage, a code pump test - including velocity vibration measurements - will be performed at a full flow test point.
The instrumentation used for the refueling outage tests is test instruments, with accuracy of 0.25%. When applied over the span on the instrument and the various range of outputs, in all cases the uncertainty of the overall loop will meet or exceed the code requirements of 2% over the instrument's range.
Revised by revision 22 10/12/95 SECTION l.4 11 OF 12
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McGuire Unit 1 Specific Relief Reauest l
RELIEF REQUEST: 1.4.7 l
' PUMPS: 1RNPU0003,1 A Nuclear Service Water Pump I 1RNPU0004,1B Nuclear Service Water Pump 1
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i Relief Request deleted by Revision 22 0
10/12/95 SECTION l.4 12 OF 12
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McGuire Unit 1 i
DUKE POWER COMPANY -
McuulRE NUCLEAR STATION - UNIT 1 VALVE INSERVICE TESTING PROGRAM i
r INTRODUCTION The inservice testing of ASME Code Categories A, B, C and D will be performed as required by ASME OM-Code-1987, Part 10 OMa-1988 addenda included, (Inservice Testing of Valves in Light-Water Reactor Power Plants), as incorporated in 10CFR50.55a. ,
These rules for IST were instituted by 1989 edition of ASME Section XI and will be adhered to, except where specific written relief has been granted by the Commission.
The effective date for this ten year submittalis March 1,1994.
Technical Specification 4.0.5 requires inservice testing of ASME Code Class 1,2 and 3 valves in accordance with Section XI of the ASME Boiler and Pressure Boiler Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i). Valves '
were selected for inclusion in the IST Program (Section h.2) which fall within this category, as required by this Technical Specification. Valves within the above ASME categories which are required to mitigate the consequences of an accident, shutdown the reactor or maintain shutdown, or,are pressure relief devices wnich protect systems or portions of systems which -
provide these functions, are included in the program. Testing requirements are identified for each valve which ensure that the valve will perform as designed in response to an accident, shutting down the reactor, or in providing relief protection. Valves are categorized in accordance with OM-10 Section 1,4, as Category A, B or C (there are no Category D valves in the program). Valves with remote position indicators are observed locally at least once ;
every 2 years in accordance with the Code. Acceptance criteria are specified in accordance l with ASME Boiler and Pressure Vessel Code Subsection lWV. The safety functions of the valves listed in Section 11.2 are included in the Design Basis Documents, and fall within the i
basic categories of accident mitigation, reactor shutdown or maintaining shutdown, or
. pressure relief for systems providing such. Post modification testing requirements are '
included in the applicable Nuclear System Directive; a modification test plan is required to be developed to verify proper operation. OM-10 requires the determination of a new reference value after valve replacement, repair or maintenance that could affect its operation. These i Code requirements and programmatic controls ensure that the valve inservice test program is ;
maintained current with modifications performed under 10 CFR 50.59. The documents used l in development of this program include the following l
. McGuire Technical Specifications.
. Safety Analysis Report.
. ASME Section XI, IWV (1986).
. ASME OM-Code-1987, Part 10 Oma-1988 addenda included.
)
. Supplement 1 to Generic Letter 89-04.
. NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants.
. Safety Evaluation Report for the McGuire IST Program dated October 21, 1994, 10/18/95 SECTION 11.1 1 of 2
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McGuire Unit 1 i
NOTES: 1) The dated initials of the person responsible for the action may be ,
used in place of a signature in the record of tests. initials shall be construed as signatures to meet the intent of OMa-1988, Section 6.3.
- 2) Category A and A/C valves include containment isolation valves i
(CIV) and pressure isolation valves (PlV). CIVs are leak tested in accordance with 10CFR50, Appendix J, and Section 4.2.2.3, i unless specific relief is requested.
- 3) Generic Letter 89-04, provides guidance for sample disassembly of check valves as an attemative to verify operability of check <
valves. The check valves where sample disassembly will be I
utilized will be specified in the contents of the program submittal l and performed according to the guidelines of Generic Letter 89-04.
- 4) A Supplemental Test Program has been established, which includes components which have been determined important to safety and prudent to test, but which are not explicitly under the scope of ASME Codes and Standards.
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10/18/95 SECTION 11.1 l 2 of 2 e.
Unit 1 - McGuire Nuclear Station Inservice Testing Program FLOW ILOW ASME VALVE ACT VALVE ACTUATOR TEST TEST RELIEF JUSTIF 0F TEST VALVE NUMBER DI.AGRAM COOR CLASS CATEGORY PAS TYPE TYPE REQ MT #1 REQ'MT #2 REQST DEFERRAL REMARKS ALTEILNATINTS REV CHEMICAL AND VOLUME CONTROL (NV) 1NV-CD06 1554-12 K-09 2 C ACT Relief -
SP - - - -
600 PSIG 22' 1NV-0007B 1554-12 J-10 2 B ACT Globe EMO ST-Q - -
1-MC-NV2 - - -
I Spring 1NV-C020 1554-12 E-02 2 C ACT Check -
SP - - -
Loaded Ck 50 PStG -
Valve I
INV-0021 A 1554-12 E-03 1 B ACT Control AOV ST-O - -
1-MC-NV3 - - -
1NV-0029 1554-1.0- C-01 2 C ACT Check -
MTO-O - - - - - -
1NV-00J1 1554-1.0 D42 1 C ACT Check -
MTO-O - - - - - -
1NV-0035A 1554-12 K-07 2 B ACT Gate AOV ST-O - -
1-MC-NV18 - - 22 1NV-0045 1554-1.0 C-08 2 C ACT Check -
MTO-O - - - - - -
1NV-0047 1554-1.0 D-08 1 C ACT Check -
MTO-O - - - - - -
1NV-0061 1554-1.1 C-01 2 C ACT Check -
MTOC - - - - - -
1MV-0063 1554-1.1 D-02 1 C ACT Check -
MTO-O - - - - - -
1MV-0077 1554-1.1 C-08 2 C ACT Check -
MTO-O - - - - - -
1NV-0079 1554-1.1 D-08 1 C ACT Check -
MTO-O - - - - - -
1NV-0093 1554-1.1 K-12 2 C ACT Relief -
SP - - - -
150 PSIG -
1NV-0094AC 1554-1.1 J-13 2 B ACT Gate EMO ST-O - -
1-MC-NV1 - - -
1NV-00958 1554-1.1 H-13 2 B ACT Gate EMO ST-O - -
1-MC-NV1 - - -
10/16/95 NV - 1 of 4
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. Unit 1 - McGuire Nuclear Station Inservice Testing Program 4
i H.OW ILOW ASME VALVE ACT VALVE ACTUATOR TEST TEST RELIEF JUSTIF 0F TEST VALVE NUMilER DIAGRAM COOR Cl. ASS CATEGORY PAS TYPE TYPE REQ'MT #1 REQ'MT #2 RrQST DEFERRAL REMARKS ALTERNATIVES REV f
1NV-0141 A 1554-2.0 B-08 2 B ACT Gate EMO ST-O - - 1-MC-NV4 - - -
1NV-0142B 1554-2.0 B-07 2 B ACT Gate EMO ST-O - -
1-MC-NV4 - - -
1NV-0143 1554-2.0 B-07 2 C ACT Check - MTC-O - -
1-MC-NV15 - - -
l 1NV-0150B 1554-2.0 F-02 2 B ACT Kerotest EMO ST-O - -
1-MC-NV8 - - -
INV-0151 A 1554-2.0 G-02 2 B ACT Kerotest EMO ST-O - -
1-MC-NV8 - - -
1NV-0155 1554-2.0 1-06 2 C ACT Rehef - SP - - - - 150 PSIG -
1NV-0156 1554-2.0 J-09 2 C ACT Rehef -
SP - - - -
255 PSIG -
l 1NV-0164 - - - - - - -
DELETED - - - - -
22 INV-0170 1554-2.0 C-08 2 C ACT Relief -
SP - - - -
75 PSIG -
1NV-0218 1554-3.0 J-05 2 C ACT Check - MTC-O - - - - - -
INV-0221 A 1554-3.1 H41 2 B ACT Gate EMO ST-Q - -
1-MC-NV6 - - -
1 1NV-0222B 1554-3.1 1-01 2 B ACT Gate EMO ST-O - -
1-MC-NV6 - - -
I 1NV-0223 1554-3.1 1-02 2 C ACT Check -
MTO.C-O -
1-MC-NV11 - - -
1NV-0225 1554-3.1 F-05 2 C ACT Check -
MTO.C-O - -
1-MC-NV10 - - -
1NV-0227 1554-3.1 E-06 2 C ACT Check -
MTO.C-O - - - - - -
1NV-0229 1554-3.1 1-12 2 C ACT Relief -
SP - - - -
220 PSIG -
10/16/95 NV - 2 of 4
Unit 1 - McGuire Nuclear Station Inservice Testing Program I' LOW IU)W ASME VALVE ACT VALVE ACTUATOR TEST TEST RELILF JUST1F OF TEST VALVE NUMBER DIAGRAM COOR CLASS CAT 11K)RY PAS TYPE TYPE REQ MT #1 REQ %1T #2 REQST DETERRAL REMARKS ALTERNATIVES REV 1NV-0231 1554-3.1 F-10 2 C ACT Check -
MTO C-O - -
1-MC-NV10 - - -
1MV-0233 1554-3.1 E-10 2 C ACT Check -
MTO.C-Q - - - - - -
1NV-0238 - DELETED 21 INV-0244A 1554-3,0 K-08 2 B ACT Gate EMO ST-O - -
1-MC-NV5 - - '-
1NV-0245B 1554-3.0 K-09 2 B ACT Gate EMO ST-O - -
1-MC-NVS - - -
1NV-0261 1554-3.1 J-03 2 C ACT Check -
MTC-O - -
1-MC-NV13 - - -
1MV-0263 1554-3,1 J-11 2 C ACT Check -
MTC-O - -
1-MC-NV13 - - -
1NV-0264 1554-3.1 J-10 2 C ACT Check -
MTO.C-O - -
1-MC-NV7 - - -
INV-0265B 1554-3.1 J-09 2 B ACT Globe EMO ST-O - -
1-MC-NV9 - - -
1NV-0383 1554-5.0 E-06 3 C ACT Check -
MTO,C-O - - - - - -
INV-0386 1554-5.0 C-06 3 C ACT Check -
MTO,C-O - - - - - -
1MV-0457A 1554-1.2 1-07 2 B ACT Control AOV ST-O - -
1-MC-NV18 - -
22 1NV-0458A 1554-12 J-07 2 B ACT Control AOV ST-O - -
1-MC-NV18 - -
22 1NV-0482 1554-2.0 D-07 2 C ACT Relief -
SP - - - -
150 PSIG -
1MV-0483 1554-2.0 D-11 3 C ACT Relief -
SP - - - -
150 PSIG -
1NV-0486 1554-3.1 J-09 2 C ACT Relief -
SP - - - -
150 PSIG :
10/16/95 NV - 3 of 4
. _ _ _ _ . _ - - - - _ - - _ _ - _ .= -
Unit 1 - McGuire Nuclear Station Inservice Testing Program ILOW ILOW ASME VALVE ACT VALVE ACTUATOR TEST TEST Ril!EF JUSTIF 0F TEST VALVE NUMBI.R DIAGRAM COOR CLASS CATI. GORY PAS TYPE TYPE REQ'MT #1 REQ'MT #2 REQST DI3T.RRAL REMARKS ALTERNATIVES REV 1RN-0299A 1574-1.0 K-02 3 B ACT Butterfly EMO ST-O - - - - - -
1RPSO442 1574-2.0 J-11 3 B ACT Butterfly AOV ST-O - - - - - -
1RN4445 1574-2.0 J-11 3 B ACT Butterfly AOV ST-O - - - - - -
1 RN-0457 1574-3.0 J-11 3 8 ACT Butterfly AOV ST-O - - - - - -
1RF50460 1574-3.0 J-11 3 B ACT Dutterfly AOV ST-O - - - - - -
1RN4891 - - - - - - -
DELETED - - - - -
22 1 RM-0892 - - - - - - -
DELETED - - - - -
12 1RN-0994 1574-3.1 C-07 3 C ACT Check -
MTC-O - - - - -
21 1RN-1006 1574-2.1 E-06 3 C ACT Check -
MTC-O - - - - -
21 10/16/95 RN - 5 of 5
McGuire Unit 1 Specific Relief Reauesj ltem Number: 1-MC-RR-NS1 -
Valve: 1 NS-13,1 N S-16,1 N S-30,1 NS-33,1 NS-41,1 NS-46 Flow Diagram: MC-1563-1.0 Code Category: C ASME Class: 2 Function: Open on flow from containment spray pumps.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Relief: Containment Spray valves 1NS-13,16,30,33,41, and 46 are Aloyco/Walworth model D-49300 cover hung, swing check valves. They are normally closed providing Category C interior containment isolation for Containrnent Spray and Auxiliary Containment Spray (valves 1NS-41 and 46 ). OMa-1988, Part 10, paragraph 4.3.2.1 requires quarterly exercising, deferrable to cold shutdowns or refueling outages. McGuire FSAR Table 6-112 identifies these valves as Leak Class 1 A valves not requiring leak rate testing due their inability to release containment atmosphere during a LOCA.
Full stroke operation of the check valves shall be verified by disassembly / inspection of the valves as no operational method exists without actuating containment spray (reference 1MC-NS2, NUREG-1482 Staff Position 2). As a supplement to the full stroke testing, part stroke and closed verification will be conducted upon reassembly and periodically by air test as described for the spray nozzle test in McGuire FSAR 6.5,4 (reference , NUREG-1482 Staff Position 2 ).
For valve disassembly / inspection, all six valves will be grouped into one group and inspected within a four cycle window ( six year interval), All six valves are identical in manufacturer and installation. Operationally, the valves are identical with respect to operational readiness. During system actuation, supply originates from the Containment Spray system for valves 1NS-13,16,30, and 33 and Residual Heat Removal system for Revised by Rev. 22.
10/12/95 SECTION 11.6 1OF7 l
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McGuire Unit 1 ,
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i Specific Relief Request i item Number: 1-MC-RR-NS1 (cont.)
{
t 1NS-41 and 46. In spray modes both systems have similar -l hydraulic characteristics. At McGuire's discretion the valves i may be disassembled / inspected sequentially, in sub-groups, or '
as one complete group every fourth outage ( six years ).
Diversion from the sequential disassembly / inspection represents an extension from the Code required frequency. l l
The relief request does not represent a decrease in quality nor !
safety. The valve disassembly / inspection will demonstrate ability !
of the valve to full stroke and fully close. As the valves do not j function except during testing and severe plant emergencies, no a operating degradation mechanisms exist. Potential degradation j mechanisms from the valves being in a static position will be
- identified by the part stroke test conducted each refueling outage on all valves.
Compliance with the Code requirements is impractical and would j impose unnecessary hardship. The valves are located within the {
containment dome volurne and are accessible by a temporary l cantilevered scaffold attached to the Polar Crane Scissors Jack.
This action, in accordance with the requirements of 29CFR 1910.28, 29CFR 1926.452, ANSI A10.81977, and McGuire's l Scaffold program places personnel in unsafe positions during the j erection / removal of the scaffold and valve testing. No additional j assurance of valve function is gained. In fact, although unlikely, frequent intrusion into the valves' internals and the inability to verify exact seat alignment during reassemble may degrade the valves' condition.
Pursuant to NUREG-1482 Staff Position 2, extension of the valve disassembly / inspection interval will be considered in cases of extreme hardship. Response to Question 19 of same implies
" extreme hardship" is proportional to the impact on plant safety.
The hardship impact is one of undue personnel safety risk and refueling outage extension. Yet the benefit from testing under the current scheme (reference 1MC-NS2 ) as compared to the proposed scheme is negligible at best. All valves will be disassembled / inspected once per four refueling outages (six years ).
Revised by Rev. 22.
l 10/12/95 SECTION 11.6 l 20F7
McGuire Unit 1 1
Specific Relief Reauest Item Number: _ 1-MC-RR-NS1 (cont.) j A review of McGuire's valves, similar industry valves, and the ,
"EPRI Applications Guidelines for Check Valves in Nuclear l Power Plants" was conducted. ;
I A review of the past 6 Unit 1 refueling outages, 7 Unit 2, identified part stroke testing of all valves every outage through ,
1/2EOC 9. Since 1/2EOC 6 each Containment Spray check !
valve has been disassembled / inspected once and Auxiliary I Containment Spray valves twice (due to the current grouping l scheme ). A comprehensive review of all valves identified no l
indication of wear, corrosion, or degradation. l A NPRDS search for Aloyco-Walworth and Walworth check valves provided a list of 34 Containment Spray check valve failures. A detailed review of the 34 failures identified 14 potentially related failures. Subsequent conversation with the respective plants' System Engineers resolved 11 of these potentially related failures as unrelated. Reasons for determining a valve failure was unrelated included the following; valves normally see flow during testing or other plant operation, and recent ISI disassembly / inspection of valves identified no degradation. The 3 remaining potentially related failures included 2 which could not be determined and 1 which was a result of valve disk misalignment. As stated earlier the potential for valve disk misalignment increases, although marginally, with repetitive disassembles.
A review of the "EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" primarily addressed degradation of check valves regularly in operation service. Design criteria for check valve application was also discussed. Comparison with the subject check valves did not reveal any design misapplication issues. The issue of valve sticking open/ closed was discussed in section 6.5.4, identifying improperly assembly as a potential cause. This issue would be addressed by the proposed part flow testing.
This Relief Request evaluation concludes adequate justification without compromise to safety or quality exist to warrant the proposed test methodology.
Revised by Rev. 22.
10/12/95 SECTION 11.6 3OF7
I 1
McGuire Unit 1 Specific Relief Requoit Item Number: 1-MC-RR-NS1 (cont.) j i
Test Alternative & Frequency: Containment Spray valves 1NS-13,16,30,33,41, and 46 will be .
grouped into a single test group. The valves may be l disassembled / inspected sequentially, in sub-groups, or as one complete group every fourth outage ( 6 years ). Each valve will ;
be disassembisd/ inspected once per four refueling outages ( 6 l years ). Each Containment Spray valve will be part stroke tested i during each refueling outage.
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Revised by Rev. 22.
10/12/95 SECTION 11.6 l 40F7
McGuire Unit 1 l
Justification of Deferral l
Item Number: 1-MC-CA1
- Valve: 1 CA-37,1 CA-41,1 CA-45.1 CA-49,1 CA-53,1 CA-57,1 CA-61, i 1CA-65 l
Flow Diagram: MC-1592-1.0 l Code Category: C l
! ASME Class: 2 Function: Check flow from the steam generators to Auxiliary Feedwater.
- Open to allow Auxiliary Feedwater supply to the Steam
(
t Generators. '
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Full stroke testing these valves would unnecessarily thermal shock the steam generators and feedwater piping. .
Test Alternative & Frequency: Valves will be full stroke exercised at cold shutdown. Closure will be verified quarterly.
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10/16/95 SECTION 11.7 1 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CA2 Valve: 1CA-165,1 CA-166 Flow Diagram: MC-1592-1.1 Code Category: C ASME Class: 3 Function: Prevents backflow from Auxiliary Feedwater System to Nuclear service Water System until the associated EMOs are closed.
EMOs are powered from the same train they serve. Must open to allow assured makeup flow to CA from RN system.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Neither full nor partial flow can be put through these valves without contaminating the Auxiliary Feedwater System with raw water. No means exist for alternate testing techniques using air or any other medium. No means exist to test for proper closure without contaminating the Auxiliary Feedwater System with raw water. These valves will not be tested during cold shutdown because sample disassembly is required.
Test Alternative & Frequency: At least one of these two valves will be disassembled and full stroked during each refueling outage, and both valves will have been disassembled and full stroked after two consecutive refu-eling outages. Failure of one valve to properly full stroke during a refueling outage will result in the remaining valves being disassembled and full stroked during that outage. Sample disassemble will also be used to verify proper closure of valves.
10/16/95 SECTION l1.7 2 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CA3 Valve: 1CA-8,1CA-10,1 CA-12 Flow Diagram: MC-1592-1.1 Code Category; C ASME Class: 3 Function: Auxiliary Feedwater Pump Suction Check valves to prevent diversion of assured auxiliary feedwater source.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa 1988 Part 10,4.3.2.1.
Basis for Deferral: These valves cannot be tested to close without contaminating the Auxiliary Feedwater System with raw water. These valves will not be tested during cold shutdown because sample disas-sembly is required.
Test Alternative & Frequency: Valves will be sample disassembled during refueling outages to verify valve closure capability.1CA-8 is disassembled every refueling outage,1CA-10 and 1CA-12 every other refueling outage on a staggered basis.
10/16/95 SECTION 11.7 3 OF 103 l
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CF1 Valve: 1 C F-26 AB, 1 C F-28 AB, 1 C F-30AB, 1 C F-35 AB Flow Diagram: MC 1591-1.1 Coae Category: B ASME Class: 2 Function: Provide feedwater and containment isolation.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of these valves would isolate the Steam Generator feedwater which could result in a severe transient in the Steam Generator, resulting in a Unit trip.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 4 OF 103 u _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
McGuire Unit 1 Justification of Deferral item Number: 1 MC-CF2 Valve: 1 C F-17AB, 1 CF-20AB, 1 C F-23AB, 1 C F-32 AB Flow Diagram: MC-1591 1.1 Code Category: B ASME Class: ANSI B31.1.0 (1967)
Function: Feedwater control.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of these valves would isolate the Steam Generator feedwater which could result in a severe transient in the Steam Generator, resulting in a Unit trip.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 5 OF 103 v
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CF3 Valve: 1CF-126B,1CF 1278,1CF-128B,1CF-129B Flow Diagram: MC-1591-1.1 Code Category: B ASME Class: 2 Function: Opens to provide startup feedwater supply to the steam gener-ators, j Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. !
Basis for Deferral: Cycling valves during power operation could induce unwanted transients in the steam generators. This would result in an increase in flow to the main feedwater nozzles causing vibrations in the preheater section of the steam generators.
Test Altemative & Frequency: Valve will be cycled and timed during cold shutdown.
i 10/16/95 SECTION 11.7 6 OF 103 I .l . . . . .. ., . . .. , .
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McGuire Unit 1 dygtification of Deferral l l
1 i
I Item Number: 1-MC-CF4 i
Valve: 1 C F-104AB,1 CF-105AB,1 C F-106AB,1 C F-107AB Flow Diagram: MC-1591-1.1 ;
Code Category: B ASME Class: ANSI B31.1.0 (1967)
Function: Provides tempering flow to the steam generators.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closing these valvas during operation would result in a ,
feedwater transient and could result in loss of Steam Generator level control, causing a Unit trip. These valves are normally {
open at power. 3 Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
i Revised by Rev. 22.
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10/16/95 SECTION 11.7 7 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CF5 Valve: 1CF-152,1CF-154,1CF-156,1CF-158 Flow Diagram: MC-1591-1.1 Code Category: C ASME Class: 2 Function: Opens to allow tempering flow to the Steam Generator auxiliary feedwater nozzles. Closes to form pressure boundary for auxiliary feedwater.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: During normal operation, there is constant flow through these valves to keep the auxiliary feedwater nozzles tempered. Test-ing these valves would require supplying the Steam Generators with cold water and thus thermally shocking these nozzles.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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l 10/16/95 SECTlON 11.7 8 OF 103 t
McGuire Unit 1 Justification of Deferral item Number: 1-MC-CF6 Valve: 1CF-118,1CF-119,1CF-120,1CF-121 Flow Diagram: MC-1591-1.1 Code Category: C ASME Class: 2 Function: Opens to allow feedwater flow to the Steam Generators.
Closes to form pressure boundary for maintaining Steam Generator inventory. The open function is not within the Scope of OM-10.
Test Requirement: Verify proper valve movement once per three months as re-quirod by OMa 1988 Part 10,4.3.2.1.
Basis for Deferral: During normal cperation, there is constant flow through these valves. The required test is performed while the Steam Generators are in wet-layup, with the main condensate system in service. The piping upstream of the check valve is depressurized, while the downstream side is pressurized. The check valves are verified to prevent gross diversion of flow.
These conditions cannot be obtained with the unit operating.
Test Alternative & Frequency: Valves will be full stroke exercised at cold shutdown.
Revised by revision 21 10/16/95 SECTION 11.7 9 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-FW1
. Valve: 1 FW-27A Flow Diagram: MC-1571-1.0 Code Category: B ASME Class: 2 Function: Isolates low pressure injection from the Refueling Water Storage Tank.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of this valve during normal power operation would render all low pressure injection inoperable. This valve is opened and power removed above Mode 4 per Tech Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION ll.7 10 OF 103
i 4
McGuire Un!!1 l 1
Justification of Deferral l
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i Item Number: 1-MC-FW2 l l
Valve: 1 FW-28 Flow Diagram: MC-1571 1.0 Code Category: C ASME Class: 2 Function: Opens to allow low pressure injection flow. Closes to prevents reverse flow to the Refueling Water Storage Tank, thereby pre-venting pressurization of the tank.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. i Basis for Deferral: Valve cannot be full stroked during power operation since the !
only full flow path is into the RCS by the Residual Heat Removal i pumps. These pumps cannot overcome RCS system pressure. l Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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l 10/16/95 SECTION ll.7 11 OF 103
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r- McGuire Unit 1 i i
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j" Justification of Deferral l
ltem Number: 1-MC-FW3 Valve: 1FW-74 Flow Diagram: MC-1571-1.0 Code Category: C l ASME Class: 3 :
Function: Must close to provide a pressure boundary for the assured makeup (Nuclear service Water) to the Spent Fuel Pool. ;
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. t Basis for Deferral: The system does not provide a means to verify valve closure.
Test Alternative & Frequency: Valve will be disassembled and inspected to verify closure at refueling outage frequency.
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1 Revised by revision 21 l
10/16/95 SECTION 11.7 12 OF 103
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i McGuire Unit 1 l Justification of Deferral i
item Number: 1-MC-IA1 Valve: 11A-5260,11A-5270,11A 5280,11A-5290,11A-5300, ilA-5310, i lA-5320,11A-5330,11A-5340,11 A-5350, i l A-5360,11 A-5370, ,
11A-5380,11A-5390 1 Flow Diagram: MC-1499-IA1 Code Category: A,C ASME Class: 2&3 i Function: 11A-5260,5270,5280,5290,5300,5310,5320 and 5330 pre-vent loss of air from receiver tank on each personnel airlock door in the event of loss of instrument air supply to door seals. These check valves form a pressure boundary for the inflatable seals.
11A-5340 and 5350 provide the inside containment isolation bar- !
rier in the event of a break on the flexible hose connection on the i air supply to the door seals. The outside isolation valves are 11A-5080 and 5160. These check valves are on the auxiliary building side of the airlocks.
11A-5360,5370,5380 and 5390 provide double isolation on the reactor building side of the airlocks for the pressure relief line.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
- 3) Leak test in accordance with Technical Specification 4.6.1.3.d. l
)
Basis for Deferral: These valves cannot be practically tested during operation due to the design of the system.
Test Alternative & Frequency: Valves will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at a six month frequency per Tech Spec 4.6.1.3.d.
10/16/95 SECTION 11.7 13 OF 103 l
1 l
l McGuire Unit 1 i
Justification of Deferral item Number: 1-MC-KC1 Valve: 1KC-4248,1 KC-425A j Flow Diagram: MC-1573-3.1 Code Category: A ;
ASME Class: 2 l i
Function: Provide containment isolation for penetration M-320.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
1 Basis for Deferral: Failure of either of these valves in the closed position during !
testing would inhibit the normal flow path from the reactor I coolant pump motor coolers. This action could result in damage
- to the NC pumps. Within 15 to 30 minutes, the NC Pumps v would be tripped on high bearing temperature, and an abnormal i shutdown (natural circulation) would be required.
]
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
I Revised by Rev. 22.
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10/16/95 SECTION ll.7 14 OF 103 l
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l McGuire Unit 1 Justification of Deferral ;
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I Item Number: 1-MC-KC2 ,
i Valve: 1KC-338B l Flow Diagram: MC-1573-3.1 i Code Category: A l l
ASME Class: 2 Function: Provide containment isolation for penetration M-327.
i Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of this valve in the closed position during testing could re-sult in damage to the NC pumps. Within 15 to 30 minutes, the NC Pumps would be tripped on high bearing temperature, and !
an abnormal shutdown (natural circulation) would be required. ,
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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1 Revised by Rev. 22.
l 10/1W95 SECTION ll.7 _
15 OF 103 ;
l McGuire Unit 1 Justification of Deferral i Item Number: 1-MC-KC3 Valve: 1KC-332B,1 KC-333A Flow Diagram: MC-1573-3.1 I
Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-355.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of one of these valves in the closed position during testing would inhibit flow through the reactor coolant drain tank heat exchanger. No alternate flowpath for cooling water to the ;
heat exchanger exists. Without flow to the heat exchanger, the drain tank would beenme over pressurized and steam would be released. Such a test would not be conservative, since Reactor Coolant would be released. This test would challenge the overpressure protection of a Reactor Coolant System ;
component. It is concluded therefore that per NUREG-1482 1 Section 3.1.1 that these valves should be excluded from quarterly testing.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
l Revised by Rev. 22.
10/18/95 SECTION 11.7 16 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-KC4 Valve: 1 KC-320A Flow Diagram: MC-1573-3.1 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-376.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of this valve in the closed position during testing would inhibit flow through the reactor coolant drain tank heat ex-changer. No alternate flowpath for cooling water to the heat exchanger exists. Without flow to the heat exchanger, the drain tank would become over pressurized and steam would be re-leased. Such a release of Reactor Coolant makes this test nonconservative and would challenge the overpressure protection of a Reactor Coolant System component. It is concluded therefore that per NUREG-1482 Section 3.1.1 that this valve should be excluded from quarterly testing.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22.
10/16/95 SECTION 11.7 17 OF 103
McGuire Unit 1 Justification of Deferral l
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Item Number: 1-MC-KC5 Valve: 1KC-280 Flow Diagram: MC-1573-3.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 1KC-332B and 1KC-333A on pene-tration M-355.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. '
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: This valve cannot be practically tested during operation due to the design of the system. Testing during power operation is ,
impractical for this valve since it is located inside containment, i as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor- i dance with 10CFR50 Appendix J at refueling outage frequency.
i Revised by Rev. 22.
10/16/95 SECTION 11.7 l 18 OF 103
McGuire Unit 1 E
Justification of Deterral i
Item Number: 1-MC-KC6 Valve: 1KC-322 Flow Diagram: MC-1573-3.1 Code Category: A,C l ASME Class: 2 Function: Provides containment isolation on penetration M-376.
Test Requirement: 1) Verify proper valve movement once per three months as ,
required by OMa-1988 Part 10,4.3.2.1. '
- 2) Leak test once per 2 years in accordance with OMa-1988 Part i 10,4.2.2.2.
Basis for Deferral: This valve cannot be practically tested during operation due to j the design of the system. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold
- shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency. j 1-I Revised by Rev. 22.
10/16/95 SECTION l1.7 19 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-KC7 Valve: 1KC-279 Flow Diagram: MC-1573-3.1 !
4 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 1KC-424B and 1KC-425A on pene-tration M-320.
Test Requirement:
- 1) Verify proper valve movement once per three months as i required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part l 10,4.2.2.2.
l Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION 11.7 20 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-KC8 Valve: 1KC-340 Flow Diagram: MC-1573-3.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-327.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4 3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16S5 SECTION 11.7 21 OF 103
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McGuire Unit 1 t
Justification of Deferral i i
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ltem Number: 1-MC-KC9 Valve: 1KC-47 f Flow Diagram: MC-1573-4.0 i
Code Category: A,C ASME Class: 2 i Function: Provides containment isolation on penetration M-322.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part j 10,4.2.2.2. !
Basis for Deferral: The system design does not provide a means of verifying valve ,
closure upon flow reversal. '
l Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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10/16/95 SECTION 11.7 22 OF 103
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McGuire Unit 1 J i
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Justification of Defenal '
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Item Number: 1-MC-NB1 l Valve: 1NB-262 !
l Flow Diagram: MC-1556-3.0 Code Category: A,C l 1
ASME Class: 2 ;
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Function: Provides containment isolation on penetration M-259. ]
Test Requirement: 1) Verify proper valve movement once per three months as i required by OMa-1988 Part 10,4.3.2.1.
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- 2) Leak test once per 2 years in accordance with OMa-1988 Part :
10,4.2.2.2. I I
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is ;
impractical for this valve since it is located inside containment, i as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Attemative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
I Revised by Rev. 22.
10/16/95 SECTION 11.7 ,
23 OF 103 l
McGuire Unit 1 Justification of Deferral item Number: 1-MC-NC1 Valve: 1NC-328,1NC-34A,1NC-36B Flow Diagram: MC-1553-2.0 Code Category: B ASME Class: 1 Function: Reactor Coolant System PORV. Opens to relieve pressure for the primary system.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.i.1.
Basis for Deferral: PORVs do not serve a safety function when unit is at eperating temperature and pressure. PORVs protect the Reactor Coolant .
System from over pressurization during LTOP conditions. !
Test Alternative & Frequency: Stroke time testing will be performed at cold shutdown and in all cases prior to entering LTOP conditions in accordance with Ge- ,
neric Letter 90-06. Testing will not be required more often than [
once per quarter as defined in OMa-1988 Part 10, 4.2.1.1.
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10/16/95 SECTION l1.7 24 OF 103
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- . McGuire Unit 1 l:
Justification of Deferral i i
i Item Number: 1-MC-NC2 I lJ Valve: 1 NC-272AC,1 NC-273AC,1 NC-274B.1 NC-275B !
Flow Diagram: MC-1553-2.1 Code Category: B ASME Class: 1 Function: Reactor vessel head vent. i l
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening these valves at full pressure could cause damage to the valve seating surfaces. A reactor coolant leak could be caused.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 25 OF 103 j r
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Justification of Deferral l 1
Item Number: 1-MC-NC3 I Valve: 1 NC-259, I NC-261 ;
I Flow Diagram: MC-1553-4.0 i Code Category: A,C AGME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 1NC-195B and 1NC-196A on pen- [
etration M-361, and line between 1NC-141 and 1NC-142 on !
penetration M-326 respectively.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. i
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is ,
impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold '
shutdowns, this testing would involve work inside containment, l possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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Revised by Rev. 22.-
b 10/16/95 SECTION 11.7 26 OF 103 i i
I McGuire Unit 1 Justification of Deferral i
Item Number: 1-MC-NC4 Valve: 1NC-59 ;
Flow Diagram: MC-1553-2.1 i
l Code Category: C I i ,
l ASME Class: 2 l
Function: Must open to allow various relief valves on ECCS systems to relive to the Pressurizer Relief Tank. '
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: The system design does not provide a sufficient means of verifying full opening of the check valve.
Test Alternative & Frequency: Valve will be disassembled and inspected to verify full stroke opening at refueling outage frequency.
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i Revised by revision 21 10/16/95 SECTION 11.7 27 OF 103 l
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F Justification of Deferral 3 1
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Item Number: 1-MC-NC5 Valve: 1NC-284 Flow Diagram: MC-1553-2.1 Code Category: C ASME Class: Duke Class E Function: Must open to allow various relief valves on ECCS systems to [
relive to the Pressurizer Relief Tank.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ,
i Basis for Deferral: The system design does not provide a sufficient means of .
verifying full opening of the check valve.
i Test Altemative & Frequency: Valve will be disassembled and inspected to verify full stroke opening at refueling outage frequency. .
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Revised by revision 21 ;
1 10/16/95 SECTION 11.7 28 OF 103 1
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McGuire Unit 1 1
Justification of Deferral Item Number: 1-MC-ND1 i
Valve: 1 ND-1 B,1 ND-2AC r i
Flow Diagram: MC-1561-1.0 j Code Category: A ASME Class: 1 Function: Provides suction for Residual Heat Removal pumps durir.g ;
normal cooldown.
Test Requirement: 1) Stroke time test in accordance with OMa-1988 Part 10, 4.2.1.1. .
- 2) Leak test once per 2 years in accordance with OMa-1988 Part !
10,4.2.2.3. !
Basis for Deferral: These valves have an interlock which prevents their opening i when the Reactor Coolant System pressure is greater than 385psig.
Test Altemative & Frequency: Valve will be cycled and timed during cold shutdown. Valve will be leak tested in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 29 OF 103
I McGuire Unit 1 Justification of Deferral l
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! tem Number: 1-MC-ND2 Valve: 1ND-58A Flow Diagram: MC-1561-1.0 1
Code Category: B l l
ASME Class: 2 Function: Provides suction to the Centrifugal Charging Pumps and Safety injection Pumps from the Residual Heat Removal system.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. ,
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Basis for Deferral: Opening 1ND-58A would seat check valve 1NV-223 (FWST to Charging Pump suction) closed, so that if 1ND-58A failed in the open position, both trains of NV would be inoperable.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. ,
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Revised by Rev. 22.
10/16/95 SECTION 11.7 30 OF 103 c_.-._.
McGuire Unit 1 !
i Justification of Deferral i
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i Item Number: MC-ND3 )
i Valve: 1ND-15B,1ND-30A l l
Flow Diagram: MC-1561 1.0 !
l Code Category: B ASME Class: 2 l Function: ND Heat Exchanger Outlet Crossover Block Valves.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: One of the ECCS safety analysis assumptions is that each train of ND can supply flow to all four cold legs. If either of these valves failed closed during testing then only two cold legs could be supplied by each train of ND. This would make both trains of ND inoperable.
Power cannot be removed from these valves, since at least one of them must be closed for cold leg recire. If power was removed from one valve, a single failure on the opposite train would disable isolation of ND to the cold legs when needed (this isolation is needed for adequate cold leg recirc flow).
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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Revised by Rev. 22.
10/16/95 SECTION l1.7 l
31 OF 103 l
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McGuire Unit 1 l
i Justification of Deferral l
Item Number: 1-MC-ND4 Valve: 1ND-70 Flow Diagram: MC-1561-1.0 )
Code Category: C ASME Class: 2 Function: Opens to provides suction to the Centrifugal Charging Pumps and Safety injection Pumps from the Residual Heat Removal system. Closes to provide suction pressure boundary for the Centrifugal Charging Pumps and Safety injection Pumps Test Requirement: Verify proper valve movement once per three months as re- ,
quired by OMa 1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full stroked during power operation since 1ND-58A would have to be opened, rendering both trains of ND ,
inoperable. Additiona!!y, the flow requirements to full stroke this !
valve cannot be achieved with the Reactor Coolant System l pressurized. I Opening 1 ND-58A would seat check valve 1NV-223 (FWST to Charging Pump suction) closed, so that if 1ND-58A failed in the open position, both trains of NV would be inoperable.
Manually closing 1ND-29, a fail-open valve, would be impractical. 1 Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valve will )
be partial stroked quarterly.
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Revised by Rev. 22.
10/16/95 SECTION 11.7 32 OF 103
McGuire Unit 1 L Justification of Deferral i
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Item Number: 1-MC-NDS Valve: 1ND-71 Flow Diagram: MC-1561-1.0 Code Category: C ASME Class: 2 Function: Opens to provides suction to the Centrifugal Charging Pumps and Safety injection Pumps from the Residual Heat Removal I system. Closes to provide suction pressure boundary for the Centrifugal Charging Pumps and Safety injection Pumps Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valvo cannot be full stroked during power operation since 1NI-136B would have to be opened, rendering both trains of ND inoperable. Additionally, the flow requirements to full stroke this l valve cannot be achieved with the Reactor Coolant System pressurized.
Opening 1ND-136B would seat check valve 1NV 223 (FWST to Charging Pump suction) closed, so that if 1ND-1368 failed in the open position, both trains of NV would be inoperable.
Manually closing 1ND-14, a fail-open valve, would be impractical.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
Revised by Rev. 22.
10/16/95 SECTlON 11.7 33 OF 103
McGuire Unit 1 Justification of Deferral i.
l Item Number: 1-MC-ND6 Valve: 1ND-8,1ND-23 Flow Diagram: MC-1561-1.0 l
Code Category: C ASME Class: 2 Function: Residual Heat Remova! pump discharge check valve.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valves cannot be full stroke exercised during power operation since the only full flow path is into the Reactor Coolant System and the ND pumps cannot overcome RCS pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valves will be partially stroked quarterly. The opposite train valves will be tested closed quarterly except when the opposite train of ND is in service.
i 10/16/95 SECTION 11.7 34 OF 103
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McGuire Unit 1 l
l j dustification of Deferral ,
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i ltem Number: 1-MC-NF1 l t
Valve: 1NF-229 i Flow Diagram: MC-1558-4.0 !
Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-373. !
Test Requirement: 1) Venty proper valve movement once per three months as required by OMa-1988 Part 10,4 3.2.1.
1
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 1 10,4.2.2.2.10CFR50 Appendix J requires measurement of localleak rate using air or nitrogen. i Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is I impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: 1) Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
- 2) Leak Rate testing of the valve will be performed per Tech Spec 4.6.1.2.d.4.
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l Revised by Rev. 22.
10/16/95 SECTION l1.7 35 OF 103
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1 McGuire Unit 1 )
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t Justification of Deferral l
l Item Number. 1-MC-N11 !
Valve: 1NI-9A,1NI-10B l l
Flow Diagram: MC-1562-1.0 1
l Code Category: B l ASME Class: 2 1
1 Function: Flowpath for Centrifugal Charging Pumps to Reactor Coolant System Cold Legs. ,
1 Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. !
Basis for Deferral: Opening either of these valves during operation would increase the charging flow into the Reactor Coolant System resulting in an ,
increase of pressure and a rapid change in the primary system I boron concentration. This could create a transient and possible unit shutdown.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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I 10/16/95 SECTiON 11.7 l 36 OF 103 l ,
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McGuire Unit 1 i
Justification of Deferral l t
item Number: 1-MC-NI2 ,
Valve: 1NI-100B r
Flow Diagram: MC-1562-3.0 Code Category: B ASME Class: 2 Function: Flowpath from the Refueling Water Storage Tank the Safety injection Pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferra.l: Closing this valve during operation would render both trains of Safety injection inoperable. This valve is opened and power removed above Mode 4 per Tech Spec 4.5.2.
Test Altemative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION 11.7 37 OF 103 w _ __ _ _ _ _
i McGuire Unit 1 l Justification of Deferral ttem Number: 1-MC-N13 ;
Valve: 1NI-147A,1N1115B l l
Flow Diagram: MC-1562-3.0 Code Category: B l
ASME Class: 2 Function: 1NI-147A provides flowpath for both trains of Safety injection ;
recirculation line to the Refueling Water Storage Tank.1NI-115B provides flowpath for A train of Safety injection re-circulation line to the Refueling Water Storage Tank.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closing either of these valve during power operation renders both trains of Safety injection inoperable.1NI-147A is open with power removed above Mode 4 per Tech Spec 4.5.2. !
In the event of a loss of offsite power with the loss of 18 diesel generator as the single failure,1NI-115B would not open, '
rendering A Train NI inoperable (due to loss of miniflow path). B Train NI would already be inoperable due to the single failure. !
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22.
10/16/95 SECTION 11.7 !
38 OF 103 '
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l McGuire Unit 1 Justification of Deferral .
i item Number: 1-MC-N14 ;
Valve: 1 NI-121 A,1NI-152B Flow Diagram: MC-1562-3.0
- Code Category
- B ASME Class: 2 Function: Isolates Safety injection flow to the hot legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves are closed with power removed above Mode 4 per '
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION l1.7 39 OF 103 1
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McGuire Unit 1 f
i Justification of Deferral f i
t Item Number: 1 MC-NIS ;
r Valve: 1NI-162A !
Flow Diagram: MC-1562-3.1 i
Code Category: B 4
ASME Class: 2 Function: Isolates Safety injection flow to the cold legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
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Basis for Deferral: This valve is opened and power removed above Mode 4 per :
Test. Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION l1.7 )
40 OF 103 !
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McGuire Unit 1 l I
Justification of De10Hal l l
l Item Number: 1-MC-NI6 l Valve: 1NI-103A l l
Flow Diagram: MC-1562-3.0 l Code Category: B l
ASME Class: 2 l i
Function: Provides A Train Safety injection Pump suction flow from the Refueling Water Storage Tar,4. Also provides a flowpath for B Train Residual Heat Rernoval pump discharge to B Train Chemical and Volume Control pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closing this valve during power operations degrades both trains of Chemical and Volume Control. In the event of a loss of offsite power with the loss of 1 A diesel generator as the single failure l when the valve was closed, B Train NV would be lost for sump recirc mode. Since that could happen as fast as 30 minutes and would then be inaccessible due to dose rates, credit could not be taken for manually opening 1N1-103A in this event. A Train NV i would already be inoperable due to the single failure.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22.
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10/16/95 SECTION 11.7 41 OF 103 l l
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i McGuire Unit 1 l
l Justification of Deferral i
l Item Number: 1-MC-N17 l
- Valve: 1NI-173A,1NI-178B l l
l Flow Diagram: MC-1562-3.1 Code Category: B ASME Class: 2 1
Function: Provides flowpath for Residual Heat Removal to the cold legs. -
l Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves are opened and power removed above Mode 4 per Tech Spec 4.5.2. ,
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 42 OF 103
McGuire Unit 1 Justification of Deferral :
Item Number: 1-MC-N18 Valve: 1NI-334B l Flow Diagram: MC-1562-3.0 Code Category: B ASME Class: 2 Function: Provides flowpath from B Train of Residual Heat Removal to B Train of Chemical and Volume Control, and from A Train of Residual Heat Removal to A Train of Safety injection.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. i Basis for Deferral: Closing this valve during power operation degrades both trains of '
Safety injection. With the single failure of 1B diesel generator, Train A of Safety injection, which is provided suction from Residual Heat Removal via 1NI-334B or 1NI-1368, would be inoperable (since 1NI-136B is normally closed). Train B of ,
Safety injection would already be inoperable due to the single ;
failure.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22.
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10/16/95 SECTION 11.7 43 OF 103 l
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McGuire Unit 1 i
i Justification of Deferral i
item Number: 1-MC-N19 j Valve: 1NI-183B Flow Diagram: MC-1562-3.0 Code Category: B ASME Class: 2 l Function: Isolates Residual Heat Removal flow to the hot legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: This valve is closed and power removed above Mode 4 per Tech Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 ;
44 OF 103 l
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i McGuire Unit 1 I
Justification of Deferral l
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item Number: 1-MC-NI10 l Valve: 1NI-184B,1NI-185A Flow Diagram: MC-1562-3.1 Code Category: B ASME Class: 2 Function: Provides flowpath from the Containment Sump to the Residual Heat Removal Pump and the Containment Spray Pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. )
l Basis for Deferral: Opening these valves during power operation would allow water !
to enter lower containment. To prevent this 1FW-27A would l have to be closed, rendering both trains of Residual Heat Removalinoperable. Voids in suction piping would be created requiring fill and vent operations to prevent ECCS pump dam-age.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION 11.7 45 OF 103 l
McGuire Unit 1 Justification of Deferral t
item Number: 1-MC-N111 Valve: 1NI-332A,1NI-333B Flow Diagram: MC-1562-3.0 Code Category: B ASME Class: 2 Function: Provides flowpath to Centrifugal Charging Pumps and Safety injection Pumps from Residual Heat Removal Pumps during recirculation phase.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening these valves during power operations requires 1N1-334B to be closed to prevent aligning FWST to the suction of the Centrifugal Charging Pumps. Injecting FWST boron con-centrated water into the Reactor Coolant System would induce a transient. Closing 1NI-334B degrades both trains of Safety injection (With the single failure of 1B diesel generator, Train A of Safety injection, which is provided suction from Residual Heat Removal via 1NI-334B or 1NI-136B, would be inoperable (since 1NI-136B is normally closed). Train B of Safety injection would already be inoperable due to the single failure).
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22.
l 10/16/95 SECTION ll.7 46 OF 103 1
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McGuire Unit 1 Justification of Deferral item Number: 1-MC-N112 Valve: 1 NI-15,1 NI-17,1 NI-19,1 NI-21, 1NI-347,1 NI-348,1 NI-349,1 NI-354 Flow Diagram: MC-1562-1.0 Code Category: C ASME Class: 1 Function: Opens to allow flow to the cold legs from the Centrifugal Charging Pumps.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Injecting flow through these valves from the Centrifugal Charging Pumps during power operations could result in unnecessary thermal shock to the injection nozzles.
Test Alternative & Frequency: Valve'will be full stroke exercised at cold shutdown. ,
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10/16/95 SECTION l1.7 47 OF 103
1 l
McGuire Unit 1 l
1 Justification of Deferral item Number: 1-MC-N113 Valve: 1NI-12 Flow Diagram: MC-1562-1.0 Code Category: C ASME Class: 2 Function: Flowpath for Centrifugal Charging Pumps to Reactor Coolant System cold legs.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Injecting flow through this valve from the Centrifugal Charging Pumps during power operations could result in unnecessary thermal shock to the injection nozzles.
Test Attemative & Frequency: Valve will be full stroke exercised at cold shutdown.
10/16/95 SECTION 11.7 48 OF 103
McGuire Unit 1 ,
Justification of Deferral item Number: 1-MC-N114 Valve: 1NI-101 Flow Diagram: MC-1562-3.0 Code Category: C ASME Class: 2 Function: Opens to allow flow from the Refueling Water Storage Tank to the Safety injection Pumps. Closes to provide suction pressure boundary for these pumps from the Residual Heat Removal ;
Pump discharge.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full stroke tested during power operation since the Safety injection Pumps cannot overcome Reactor Coolant ;
System pressure. Closure cannot be verified quarterly since both trains of Residual Heat Removal would be rendered inoperable.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valve will be partial stroked quarter!y.
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e 10/16/95 SECTION ll.7 49 OF 103 i
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1 McGuire Unit 1 1 Justification of Deferral l
Item Number: 1 MC-N115 Valve: 1NI-116,1NI-148 l l
Flow Diagram: MC-1562-3.0 '
Code Category: C l ASME Class: 2 i i
Function: Pump discharge check valve, opens to allow Safety injection Flow. Closes to prevent opposite train flow losses.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full or partial stroke tested during power oper-ation since the Safety injection Pumps cannot overcome Reactor Coolant System pressure.
t Test Attemative & Frequency: Valve will be full stroke exercised at cold shutdown. Valve will be verified closed quarterly.
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1 I 10/16/95 SECTION 11.7 50 OF 103 1 1
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Justification of Deferral l-Item Number: 1-MC-N116 Valve: 1 N1-124,1 NI-128,1 NI-156,1 NI-157,1 NI-159,1 NI 160 Flow Diagram: MC-1562-3.0 Code Category: AC ASME Class: 1 i
Function: 1) Opens on flow from the Safety injection Pumps to the hot legs.
- 2) Reactor Coolant System pressure boundary. ,
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
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- 2) Leak test once per two years in accordance with OMa-1988 Part 10,4.2.2.3.
Basis for Deferral: Valves cannot be full or partial stroke tested during power op-eration since the Safety injection Pumps cannot overcome Re- ,
actor Coolant System pressure. ,
l Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2. j
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I l 10/16/95 SECTION 11.7 51 OF 103
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l Justification of Qeferral 4
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item Number: 1-MC-N117 Valve: 1NI-165,1NI-167,1Ni-169,1NI-171 Flow Diagram: MC-1562-3.1 l
Code Category: AC i
ASME Class: 1 :
Function: 1) Opens on flow from the Safety injection Pumps to the cold i legs.
- 2) Reactor Coolant System pressure boundary. !
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ,
- 2) Leak test once per 2 years in accordance with OMa-1988 Part I l 10,4.2.2.3.
1 l Basis for Deferral: Valves cannot be full or partial stroke tested during power op-l erations since the Safety injection Pumps cannot overcome Reactor Coolant System pressure. ,
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
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10/16/95 SECTION 11.7 52 OF 103
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I McGuire Unit 1 1
1 Justification of Deferral '
Item Number: 1-MC-N118
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Flow Diagram: MC-1562-3.1 f
Code Category: AC ASME Class: 1 Function: 1) Opens on flow from the Residual Heat Removal Pumps to the cold legs, i
- 2) Reactor Coolant System pressure boundary. ,
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! Test Requirement: 1) Verify proper valve movement once per three months as re- '
quired by OMa-1988 Part 10,4.3.2.1.
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- 2) Leak test once per two years in accordance with OMa-1988 l Part 10,4.2.2.3.
Basis for Deferral: Valves cannot be full or partial stroke tested during power op-eration since the Residual Heat Removal pumps cannot over- ;
come Reactor Coolant System pressure. ;
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in I accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 l 53 OF 103 !
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McGuire Unit 1 !
Justification of Deferral ltem Number: 1-MC-N119 ;
Valve: 1NI-125,1NI-126,1NI-129,1NI-134 i Flow Diagram: MC-1562-3.0 Code Category: AC s
ASME Class: 1 Function: 1) Opens on flow from the Residual Heat Removal Pumps to the hot legs.
- 2) Reactor Coolant System pressure boundary,
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Test Requirement: 1) Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. :
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- 2) Leak test once per two years in accordance with OMa-1988 l Part 10,4.2.2.3.
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Basis for Deferral: Valves cannot be full or partial stroke tested during power op-eration since the Residual Heat Removal pumps cannot over-come Reactor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
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10/16/95 SECTION l1.7 54 OF 103
McGuire Unit 1 Justification of Deferral l
Item Number: 1-MC-N120 Valve: 1NI-136B Flow Diagram: MC-1562-3.0 Code Category: B ASME Class: 2 Function: Provides suction to the Centrifugal Charging Pumps and Safety ;
Injection Pumps from the Residual Heat Removal System.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening 1 NI-136B would seat check valve 1NV-223 (FWST to l Charging Pump suction) closed, so that if 1NI-136B failed in the i open position, both trains of NV would be inoperable.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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Revised by Rev. 22.
l 10/16/95 SECTION ll.7 .
55 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-NI21 Valve: 1 NI-48 Flow Diagram: MC-1562-2.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-330.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
i Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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I 10/16/95 SECTlON11.7 56 OF 103
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McGuire Unit 1 ;
I Justification of Deferral l
1 Item Number: 1-MC-N122 I
Valve: 1NI-59,1 NI-70,1NI-81,1 NI-93 j
Flow Diagram: MC-1562-2.0, MC-1562-2.1 Code Category: A,C l
ASME Class: 1 l
i Function: Opens on flow from the NI cold leg accumulator to the Reactor Coolant System. Reactor Coolant Boundary valve.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
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- 3) Leak test in accordance with Tech Spec 4.4.6.2.2.
l Basis for Deferral: Valves cannot be full or partial stroked during power operation :
since the accumulator pressure is -600 psig and cannot over-come RCS pressure. Valves will not be tested during cold shutdown since disassembly is required. Disassembly would i render one train of RHR inoperable for an extended period of time.
Test Alternative & Frequency: Valves will be full stroked at refueling by disassembly on a sample basis. All valves will be partial stroked at refueling.
Partial stroke will not be performed at cold shutdown since Tech Spec 4.4.6.2.2 requires leak testing after initiating flow through these valves and does not require leak testing more often than once per nine months. Valves will be verified closed by leak test performed in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 1 57 OF 103 i
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McGuire Unit 1 Justification of Deferral item Number: 1-MC-N123 Valve: 1NI-436 Flow Diagram: MC-1562-2.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection for penetration M 321.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve i closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION 11.7 58 OF 103
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McGuire Unit 1 Justification of Deferral item Number: 1-MC-N124 4
Valve: 1Ni-60,1 NI-71,1 NI-82,1 NI-94
, Flow Diagram: MC-1562-2.0, MC-1562-2,1 l
. Code Category: A,C 4
ASME Class: 1 -
Function: Opens on flow from the NI cold leg accumulator to the Reactor Coolant System. Reactor Coolant Boundary valve.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
. 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
- 3) Leak test in accordance with Tech Spec 4.4.6.2.2.
Basis for Deferral: Valves cannot be full or partial stroked during power operation since a driving head which can overcome RCS pressure does not exist. Instrumentation is not present to measure the flow through tb> Individual valves. Valves will not be tested during cold shutdown since disassembly is required. Disassembly would render one train of RHR inoperable for an extended period i of time. l Test Alternative & Frequency: Valves will be full stroked at refueling by disassembly on a sample basis. All valves will be partial stroked at refueling.
Partial stroke will not be performed at cold shutdown since Tech j Spec 4.4.6.2.2 requires leak testing after initiating flow through these valves and does not require leak testing more often than once per nine months. Valves will be verified closed by leak test performed in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION ll.7 59 OF 103
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McGuire Unit 1 Justification of Deferral l l
Item Number: 1-MC-NM1 l Valve: 1 NM-420,1 NM-421 l
Flow Diagram: MC-1572-1.0 Code Category: A,C ASME Class: 2 1
Function: Provides containment isolation and thermal over pressurization protection for penetrations M-235 and M-309 respectively.
Test Requirement: 1) Verify proper valve movernent once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternat:ve & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION l1.7 60 OF 103
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McGuire Unit i Justification of Deferral item Number: 1-MC-NS1 Valve: 1NS-38B,1NS-43A Flow Diagram: MC-1563-1.0 Code Category: B ASME Class: 2 Function: Auxiliary Spray Nozzle header isolation.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. I Basis for Deferral: Opening either of these valves during power operation renders both trains on Residual Heat Removal inoperable. With cross-connected trains of ND, flow would be diverted from both trains through a failed-open NS-38B or 43A. To isolate one train of ,
ND, it would be necessary to manually secure closed either ND- l 14 or 29, since these valves fail open on loss of air. This would be an impractical measure to perform the quarterly test.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev. 22. f l
10/16/95 SECTION 11.7 61 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-NS2 Valve: I N S-13,1 N S-16,1 N S-30,1 N S-33,1 NS-41,1 N S-46 Flow Diagram: MC-1563-1.0 Code Category: C ASME Class: 2 Function: Open on flow from containment spray pumps.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. j Basis for Deferral: . Full stroke exercising of these check valves is not practical since l
- l. there is no externalindication of disk movement. Full stroke !
I exercising would require for the pumps and spray nozzles to be l activated which would require a large scale cleanup effort.
l Valves will not be tested during cold shutdown since sample 1 disassembly is required. '
Test Alternative & Frequency: These valves will be verified to fully cycle by sample disassem- l bly at refueling outage frequencies.
Mole: Relief is being requested on these valves. Refer to relief request 1-MC-RR-NS1. When relief is granted, this Justification Of ,
Deferral will be deleted. l I
10/16/95 SECTION 11.7 62 OF 103
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McGuire Unit 1 l
i Justification of Deferral i
I Item Number: 1-MC-N'S3 Valve: 1 NS-4,1 NS-21 '
Flow Diagram: MC-1563-1.0 Code Category: C ASME Class: 2 Function: Opens to allow flow from the Refueling Water Storage Tank to .
the Containment Spray Pump suction. Closes to prevent flow I from the Containment Recirculation Sump to the Refueling .
- Water Storage Tank.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. t Basis for Deferral: Full atroke exercising with flow would require for the pumps and !
spray nozzles to be activated which would require a large scale !
cleanup effort. The system design does not provide any i indication for verifying closure upon flow reversal. [
Test Alternative & Frequency: Full stroke testing will be achieved by sample disassembly. At least one of these valves will be disassembled during each i refueling outage, and both valves will have been disassembled !
and full stroked after two consecutive outages. Sample disas- .
sembly will also verify closure. Failure of one of valve to prop- i erly full stroke during a refueling outage will result in the re-maining valve being disassembled and full stroked during that outage. Valves will be partial stroked quarterly.
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10/16/95 SECTION 11.7 i 63 OF 103 ;
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McGuire Unit 1 i
i Justification of Deferral item Number: 1-MC-NS4 Valve: 1NS-140,1NS-141 ,
t Flow Diagram: MC-1563-1.0 -
Code Category: A,C -
ASME Class: 2 ,
Function: Must open to allow Containment Spray to the spray ring head-ers. Must close to prevent column separation of water in the header after initial building spraydown and pump shutdown. ;
During this time, the column of water in the vertical piping up to the spray rings could separate, creating a void in the system at sub-atmospheric pressure. Upon pump restart, the collapse of ;
this void would damage the piping system.
Test Requirement: 1) Verify proper valve movement once per three months as ,
required by OMa-1988 Part 10,4.3.2.1.
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- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
Basis for Deferral: r ul stroke exercising of these check valves is not practical since there is no extemalindication of disk movement. Full stroke exercising would require for the pumps and spray nozzles to be l activated which would require a large scale cleanup effort.
Valves will not be tested during cold shutdown since sample disassembly is required.
Test Alternative & Frequency: Valves will be verified to full stroke open using sample disas-sembly every other refueling outage on a staggered basis. l Valves will be partial stroked quarterly. Valves will be leak tested at refueling outages. Leak testing will also verify closure l of these valves. j l 10/16/95 SECTION l1.7 !
64 OF 103 j 1
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I McGuire Unit 1 Justification of Deferral i
Item Number: 1-MC-NV1 Valve: 1NV-94AC,1NV-95B l
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Flow Diagram: MC-1554-1.1 Code Category: B ASME Class: 2 Function: 1) Provides flowpath for Reactor Coolant Pump seal water dis-charge line.
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- 2) Provides containment isolation for penetration M-256 Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. ,
Basis for Deferral: Closure of one of these valves during power operation would I inhibit normal seal water flow across the reactor coolant pump number 1 seal. This action could result in damage to the reactor >
coolant pump seals or the pump itself. Failure of this seal with NC flow out the seal would be a loss of NV system function, and is justification for deferral in accordance with NUREG-1482 Section 3.1.1.
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Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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Revised by Rev. 22.
10/16/95 SECTION 11.7 1 65 OF 103 !
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_ McGuire Unit 1 Justification of Deferral ,
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ltem Number: 1-MC-NV2 Valve: 1NV-78 i
Flow Diagram: MC-1554-1.2 Code Category: B j ASME Class: 2 i Function: 1) Provides flowpath for normal letdown.
- 2) Provides containment isolation for penetration M-347. ,
l Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. I l
Basis for Deferral: Failure of this valve in a closed position would result in a l significant event (letdown isolation), possibly resulting in loss of pressurizer level control, and possible Unit trip (not a normal shutdown).
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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l Revised by Rev. 22.
10/16/95 SECTION 11.7 66 OF 103
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McGuire Unit 1 i
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Justification of Deferral i
Item Number: 1-MC-NV3 l
t Valve: 1NV-21 A i Flow Diagram: MC-1554-1.2 Code Category: B ;
ASME Class: 1 I Function: Provides isolation for Pressurizer Auxiliary spray. l t
i Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening this valve during power operations could result in a re- ,
actor low pressure trip. t l
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown, j I
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r 10/16/95 SECTION 11.7 t 67 OF 103 .
McGuire Unit 1 ;
Justification of Deferral .
l Item Number: 1-MC-NV4 l Valve: 1NV 141 A,1NV 1428 Flow Diagram: MC-1554-2.0 Code Category: B ,
ASME Class: 2 Function: Provides isolation for Volume Control Tank upon Safety injection Signal.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of one of these valves during power operation would isolate the suction for the Centrifugal Charging Pumps. This action could result in damage to the pumps. Seal water to the Reactor Coolant pumps would be interrupted causing damage to the seals.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown, t
1 10/16/95 SECTION 11.7 68 OF 103
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i McGuire Unit 1 f
Justification of Deferral j Item Number: 1-MC-NV5 Valve: 1NV-244A,1NV-245B Flow Diagram: MC-1554-3.0 Code Category: B ASME Class: 2 '
Function: Isolates charging to the Reactor Coolant System upon Safety injection.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
s Basis for Deferral: If one of these valves were to failin the closed position while testing during power operation, normal and alternate charging would be lost. Total loss of charging flow would be a significant event, resulting in a possible loss of Pressurizer control, and a likely Unit trip (not a normal shutdown), as well as loss of NC ,
pump seal flow.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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Revised by Rev. 22.
10/16/95 SECTION 11.7 69 OF 103
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McGuire Unit 1 ;
6 Justification of Deferral i item Number: 1-MC-NV6 Valve: 1 NV-221 A,1 NV-2228 Flow Diagram: MC 1554-3.1 Code Category: B l
ASME Class: 2 l Function: Flowpath for Refueling Water Storage Tank to the suction of the Centrifugal Charging Pumps.
Test Requirement: Stroke time test in accordance witn OMa-1988 Part 10,4.2.1.1, Basis for Deferral: Opening these valves during power operation allows the Charging Pumps to inject highly borated water into the Reactor coolant System which could result in a unit shutdown. .
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Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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i 10/16/95 SECTION 11.7 70 OF 103
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1 McGuire Unit 1 Justification of Deferral I
I item Number: 1-MC-NV7 l l
Valve: 1NV-264 Flow Diagram: MC-1554-3.1 ;
Code Category: C '
l ASME Class: 2 i Function: Provides flowpath from the Boric Acid Tank to the Centrifugal Charging Pump suction. Closes to provide pump suction pres-sure boundary. ,
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ;
Basis for Deferral: To full stroke exercise this valve during power operations would f inject more than 30 gpm of boric acid into the Reactor Coolant System creating a transient. To verify closure, residual boric l acid would be injected causing a transient.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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l 10/16/95 SECTION 11.7 l 71 OF 103 l
L 1 McGuire Unit 1 Justification of Deferral ,
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l Item Number: 1-MC-NV8 Valve: 1NV-150B,1 NV-151 A ,
i Flow Diagram: MC-1554-2.0 Code Category: B ASME Class: 2 Function: Provides isolation for Centrifugal Charging Pump miniflow line to Volume Control Tank.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. !
Basis for Deferral; if either valve were to fail closed while testing, the Charging Pump miniflow protection line is isolated possibly causing '
damage to the pump. Closure of either of these valves would render both trains of NV inoperable, since on a spurious safety - ,
injection event (in which reactor coolant system pressure is :
increased above normal), this is a relief path back to the Volume Control Tank.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. s i
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Revised by Rev. 22.
10/16/95 SECTION 18.7 72 OF 103 l 1
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I McGuire Unit 1 Justification of Deferral l
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i Item Number. 1-MC-NV9 l- Valve: 1NV-2658 L
Flow Diagram: MC-1554-3.1 l Code Category: B i
ASME Class: 2 Function: Isolates the Boric Acid Tank from the suction of the Charging Pumps.
l Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
l Basis for Deferral: If valve is opened during power operations, boric acid could be l injected into the Reactor Coolant System causing a transient.
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j Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16M5 SECTION l1.7 73 OF 103 w
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McGuire Unit 1 !
Justification of Deferral i
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Item Number: 1-MC-NV10 Valve: 1 NV-225,1 NV-231 Flow Diagram: MC-1554-3.1 Code Category: C ASME Class: 2 Function: Pump discharge check valve. Opens to provide flowpath for Centrifugal Charging Pump. Closes to prevent opposite train flow losses. l Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ;
Basis for Deferral: Valve cannot be full stroke exercised during power operation since this would require an increase in Reactor Coolant System boron concentration which could result in unit shutdown. !
Normal letdown is not sufficient to verify full stroke, this must be.-
done when aligned to the FWST for suction.
Test Alternative & Frequency: Valve will be full stroke exercised during cold shutdown, partial stroked with normal use.
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10/16/95 SECTION ll.7 .
74 OF 103 I
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McGuire Unit 1 ;
Justification of Deferral i
item Number: 1-MC-NV11 Valve: 1NV-223 i
Flow Diagram: MC-1554-3.1 Code Category: C ASME Class: 2 Function: Provides open flowpath from the FWST. Provides closed pump suction pressure boundary when suction is from the Residual Heat Removal pumps.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Testing this valve during power operations would require opening of either 1NV-221 A or 1NV-2228. Opening these valves during power operation could result in a unit trip. See Justification # MC-NV6.
l Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. ,
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10/16/95 SECTION 11.7 75 OF 103 I
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McGuire Unit 1 i h
Justification of Deferral !
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item Number: 1-MC-NV12 i
Valve: 1NV-1046 '
Flow Diagram: MC-1554-3.0 i
Code Category: C ASME Class: 2 Function: Closes to provide pump suction pressure boundary for Centrif-ugal Charging Pumps. Open function is to protect the Positive Displacement Pump from over pressurization. This is not a safety related function.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Testing this valve during power operation would result in the addition of highly borated water into the Reactor Coolant System causing a transient. To place adequate test pressure on this valve, it would be necessary to use ND Pump discharge pressure, which would require opening 1ND-58A. This would ,
inject FWST water into the NC System via the Charging Pumps, which are also on the discharge of the ND Pumps (for cold leg recirc) via 1ND-58A.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. j 1
l Revised by Rev. 22. )
10/16/95 SECTION 11.7 76 OF 103
McGuire Unit 1 i
l Justification of Deferral l Item Number: 1-MC-NV13 1
Valve: 1 NV-261,1 NV-263 Flow Diagram: MC-1554-3.1 l l
Code Category: C i ASME Class: 2 Function: These valves shall close to provide pump suction pressure isolation for the Centrifugal Charging Pumps by preventing backflow to the Chemical Mixing Tank or the RMWST respec-tively.
l Test Requirement: Verify proper valve movement once per three months as i required by OMa-1988 Part 10,4.3.2.1. l' i
Basis for Dc:erral: Testing these valves requires 1NI-121 A to be opened. This 1 valve is closed with power removed above mode 4 per Tech -I Spec 4.5.2. ;
This testing would require opening valve 1ND-58A, which would render both trains of NV inoperable (by seating check valve 1NV-223 (charging pump suction from the FWST in-line check) closed).
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
l Revised by Rev. 22.
10/16/95 SECTION 11.7 77 OF 103
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l McGuire Unit 1 Justification of Deferral l
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Item Number: 1-MC-NV14 "
Valve: 1NV-1002 Flow Diagram: MC-1554-1.3 Code Category: A,C ,
i ASME Class: 2 Function: Provides containment isolation on penetration M-342.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part l 10,4.2.2.2. j l
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the ter.t connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels. I Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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Revised by Rev. 22.
10/16/95 SECTION 11.7 78 OF 103
L I-McGuire Unit 1 Justification of Deferral l
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Item Number: 1-MC-NV15 Valve: 1NV-143 t r
- i. Flow Diagram: MC-1554-2.0 i Code Category: C i
ASME Class: 2 i
Function: This valve shall close to provide Centrifugal Charging Pump suction pressure boundary during Recirculation alignment from .'
l RHR Pump discharge.
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l Test Requirement: Verify proper valve movement once per three months as re- i quired by OMa-1988 Part 10,4.3.2.1.
l Basis for Deferral: This valve is in the flowpath from the Volume Control Tank to the ,
Charging pumps. During normal system operation, this valve is open. To verify this valve closes properly requires the alignment from the RHR pumps, and would interrupt normal charging 3 activities. :
i l Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. '
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! 10/16/95 SECTION 11.7 l l 79 OF 103 !
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McGuire Unit 1 Justification of Deferral item Number: 1-MC-NV16 Valve: 1NV-164 l
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Justification deleted by Revision 22.
10/16/95 SECTION l1.7 80 OF 103
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i McGuire Unit 1 l
dystification of Deferral item Number: 1-MC-NV17 Valve: 1NV-1007,1NV-1008,1NV 1009,1NV-1010 Flow Diagram: MC-1554-1.3 Code Category: C ASME Class: 2 Function: These valves must close to maintain a pressure boundary for l normal Reactor Coolant Pump Seal Injection. '
- Test Requirement
- Verify proper valve movement once per three months as re-l- quired by OMa-1988 Part 10,4.3.2.1. 3 Basis for Deferral: In the event of failure of one of these valves during testing, the >
I seal injection water for that Reactor Coolant Pump would be diverted, thereby creating a loss of seal injection to that pump.
- This condition would result in destroying a seal for the pump, !
and possibly creating a small break loss of coolant accident. {
Test Alternative & Frequency: These valves will be tested for closure during cold shutdowns.
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( i Resived by revision 21 !
10/16/95 SECTION 11.7 81 OF 103
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d McGuire Unit 1 Justification of Deferral ltem Number: 1-MC-NV18 ;
Valve: 1 NV-0035A,1 NV-0457A,1 NV-0458A Flow Diagram: MCFD-1554-01.02 Code Category: B ASME Class: 2 Function: These valves must automatically close to isolate containment on a Phase A signal, and to isolate letdown on a Pressurizer Low Level signal. They can be operated from the Auxiliary Shutdown Panel, and cannot be opened unless valves 1NV-1 A and 1NV-2A are both open.
Test Requirement: Stroke time test quarterly in accordance with Oma-1988 Part 10, 4.2.1.1.
Basis for Deferral: Letdown neader relief valve 1NV-6 has experienced li' ting and subsequent seat leakage as a result of pressure t >nsients during orifice swaps for stroke time testing of the above valves.
Although the NV operating procedure specifically addresses the potential pressure increase that could occur when swapping from the 45 gpm to the 75 gpm orifice, the increase can occur so quickly that the operator and system controls cannot respond fast enough to prevent the pressure transient. The NV operating ,
procedure currently provides for simultaneous opening / closure of the above orifice isolation valves, and for backpressure reduction t using the downstream control valve, to prevent such a pressure transient; however, procedure effectiveness is problematic with respect to repeatablility due to the inability to achieve perfect coordination each time.
It is concluded that testing of these valves is impractical and nonconservative during power operation, since it results in pressure transients which have caused relief valve leakage.
This leakage is Reactor Coolant (NC) leakage, wnich is reflected in higher NC leakage values.
Finally, these valves have demonstrated a favorable test history.
Test Alternative & Frequency: Valves will be stroke time tested during cold shutdown.
Added by Rev. 22 ,
10/16/95 SECTION l1.7 82 OF 103
h McGuire Unit 1 Justification of Deferral item Number: 1-MC-RF1 Valve: 1RF-823 Flow Diagram: MC-1599-2.2 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-353.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, I as well as the test connection needed to test it. During cold I shutdowns, this testing would involve work inside containment, possibly with high radiation levels. l Test Attemative & Frequency: Valve will be verified closed by leak test performed in accor- !
dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22. I 10/16/95 SECTION 11.7 83 OF 103
._._ -. __ . . _ ~ . _ . ._ . _ _ - - _ . _ ._ _ . _ _.. - . _ >. . ._
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- l. McGuire Unit 1 l l !
l Justification of Deferral Item Number: 1-MC-RN1 ,
Valve: 1 RN-252B,1 RN-253A $
Flow Diagram: MC-1574-4.0 Code Category: A ASME Class: 2 Function: 1) Provides containment isolation for penetration M-307.
- 2) Provides flowpath for cooling water to the Reactor Coolant Pump Motor Air Cooler .
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. :
i Basis for Deferral: If one of these valves were to fail closed during testing, isolation of cooling water to the motor coolers could result in damage to the pumps. Closure of these valves would result in a Unit trip from NC Pump motors being manually shut down due to high ;
stator temperatures (within minutes). An abnormal (natural circulation) shutdown would be required.
Test Alternative & Frequency; Valve will be cycled and timed during cold shutdown.
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l Revised by Rev. 22.
10/16/95 SECTION 11.7 84 OF 103
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i McGuire Unit 1 ,
Justification of Deferral ,
i Item Number: 1-MC-RN2 Valve: 1 RN-276A,1 RN-2778 Flow Diagram: MC-1574-4.0 Code Category: A ASME Class: 2 Function: 1) Provides containment isolation for penetration M-315.
- 2) Provides flowpath for cooling water to the Reactor Coolant Pump Motor Air Cooler. ,
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: If one of these valves were to fail closed during testing, isolation of cooling water to the motor coolers could result in damage to the pumps. Closure of these valves would result in a Unit trip i from NC Pump motors being manually shut down due to high ;
stator temperatures (within minutes). An abnormal (natural ;
circulation) shutdown would be required. ;
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
I Revised by Rev. 22.
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! 10/16/95 SECTION l1.7 i 85 OF 103 1
i McGuire Unit 1 J_ustification of Deferral item Number: 1-MC-RN3 Valve: 1RN-42A l
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Justification deleted by Revision 21 10/16/95 SECTION 11.7 86 OF 103
1 McGuire Unit 1 Justification of Deferral l
Item Number: 1-MC-RN4 Valve: 1 RN-638,1 RN-64A Justification deleted by Revision 21 10/16/95 SECTlON l1.7 87 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-RN5 Valve: 1RN-214 l
Justification deleted by Revision 21 10/16/95 SECTION l1.7 88 OF 103
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McGuire Unit 1 i
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Justification of Deferral l
Item Number: 1-MC-RN6 Valve: 1 RN-891,1 RN-892 i
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I Justification deleted by Revision 22 10/16/95 SECTION 11.7 89 OF 103
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i l McGuire Unit 1 l
l Justification of Deferral l
Item Number: 1-MC-RV1 Valve: 1 RV-32A,1 RV-33B,1 RV-76A,1 RV-77B Flow Diagram: MC-1604-3.0 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-240 and M-279 respectively.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of one of these valves in the closed position during testing would isolate cooling flow to the Lower Containment !
Ventilation Units causing an increase in lower containment temperature which could exceed Tech Spec limits. Although the exact time depends on outside temperature, the Tech Spec limit i would be exceeded within minutes if cooling flow was isolated to these ventilation units.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
l Revised by Rev. 22. j l
10/16/95 SECTlON 11.7 90 OF 103 i
m McGuire Unit 1 Justification of Deferral !
Item Number: 1-MC-SA1 Valve: 1 SA-5,1 SA-6 Flow Diagram: MC-1593-1.2 Code Category: C ASME Class: 2 Function: Opens to allow steam supply to the turbine driven Auxiliary Feedwater Pump. Closes to prevent cross connecting steam generators 1B and 1C. !
i Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: System configuration and design do not provide a suitable means to prove the valve prevents reversal of flow. To test the close function of this valve on line would risk personnel safety l since high energy steam would be involved. i Test Alternative & Frequency: At least one of these two valves will be disassembled and full stroked during each refueling outage, and both valves will have been disassembled and full stroked after two consecutive out-ages. Sample disassembly will verify closure. Failure of one of
! valve to properly full stroke during a refueling outage will result in the remaining valve being disassembled and full stroked during that outage. Valves will be full stroked open quarterly.
10/16/95 SECTION ll.7 91 OF 103
i McGuire Unit 1 i
Justification of Deferral l
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l Item Number: 1-MC-SM1 Valve: 1 SM-1 AB,1 SM-3AB,1SM-5AB,1 SM-7AB Flow Diagram: MC-1593-1.0, MC-1593-1.3 Code Category: B ASME Class: 2 Function: Main Steam isolation Valves Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves cannot be fully cycled closed during power oper-ation since a unit shutdown would result.
Test Alternative & Frequency: These valves will be partially cycled closed while in Modes 1,2 and 3. These valves will be cycled and timed during cold shutdown, i
l 10/16/95 SECTION 11.7 92 OF 103
McGuire Unit 1 Justification of Deferral l Item Number, 1-MC-VB1 Valve: 1VB-50 Flow Diagram: MC-1605-3.1 ,
Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-215.
Test Requirement: 1) Verify proper valve movement once per three months as !
required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2. i Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
i Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION l1.7 93 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-VG1 Valve: 1VG-17,1VG-18,1VG-19,1VG-20 Flow Diagram: MC-1609-4.0 Code Category: C ASME Class: 3 Function: Provides flowpath for Diesel Generator control air from individual starting air banks.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Testing these valves requires the Diesel Generator to be started on a single bank of control air which is considered a degraded condition. This is not justified for quarterly starts. This test is required to be done on an 18 month frequency as committed to in our response to SOER 80-1.
Test Alternative & Frequency: Valve will be full stroke exercised with the diesel generator start on a single bank of control air and performed at refueling outage frequency, i
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l 10/16/95 SECTION l1.7 94 OF 103
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McGuire Unit 1 Justification of Deferral i
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- Item Number: 1-MC-Vl1 Valve: 1VI-368,1 VI-372,1VI-373,1 VI-374 l
Flow Diagram: MC-1605-1.3 l
I Code Category: C l ASME Class: ANSI B31.1.0 (1967)
Function: 1VI-368 and 1VI-373 must open to allow nitrogen to the PORV actuator.
1VI-372,1VI-374 must close to prevent loss of Nitrogen pres-sure if instrument air is lost.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: All four valves are tested with PORV stroke timing. PORVs are tested on a cold shutdown frequency. Refer to Justification # 1-MC-NC1 Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. )
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l 10/16/95 SECTION l1.7 95 OF 103
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l' McGuire Unit 1 i
Justification of Deferral item Number: 1-MC-Vl2 Valve: 1VI-124,1VI-149 Flow Diagram: MC-1605-1.2 l Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetrations M-317 and M-386 respectively.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Altemative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION 11.7 96 OF 103
i t
McGuire Unit 1 i 1
1 Justification of Deferral j i
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ltem Number: 1-MC-Vl3 I
Valve: 1VI-40,1VI-161 j l
Flow Diagram: MC-1605-1.3 Code Category: A,C j ASME Class: 2 Function: Provides containment isolation on penetrations M-220 and M- ,
359 respectively.
Test Requirement: 1) Verify pruper valve movement once per three months as -
required by OMa-1988 Part 10,4.3.2.1. I
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
, Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment,
, as well as the test connection needed to test it. During cold
- shutdowns, this testing would involve work inside containment, possibly with high radiation levels, r l i Test Alternative & Frequency
- Valve will be verified closed by leak test performed in accor-
, dance with 10CFR50 Appendix J at refueling outage frequency.
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Revised by Rev. 22.
10/16/95 SECTION 11.7 97 OF 103
r McGuire Unit 1 Justification of Deferral l
1 Item Number: 1-MC-Vl4 -
Valve: 1VI-129B,1VI-150B,1VI-160B ,
Flow Diagram: MC-1605-1.14; MC-1605-1.17 Code Category: A ASME Class: 2
- Function: Provides containment isolation on penetrations M-220, M-317 and M-359 respectively.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves isolate instrument air headers to the reactor building. In the past, to perform stroke timing of these valves, the containment air compressor was started to maintain an un-interrupted air supply to components inside containment. During the past refueling outage, the containment compressor was +
deleted. Should these valves be closed during power operation, ;
components inside containment would experience a loss of instrument air, resulting in unwanted transients. During cold shutdowns, personnel entry into containment may be made to manually align instrument air headers together, allowing these .
valves to be tested. Since this is a manual alignment, it is not possible to enter containment to make this alignment for quarterly testing. ;
1 Test Alternative & Frequency: Valves will be cycled and timed during cold shutdown. Leak l testing will be performed as per the requirements of 10CFR50, Appendix J. l Revised by revision 21 10/16/95 SECTION 11.7 ;
98 OF 103 l
l McGuire Unit 1 l
Justification of Deferral item Number: 1-MC-VS1 ,
Valve: 1VS-13 Flow Diagram: MC-1605-2.2 Code Category: A,C l ASME Class: 2 !
Function: Provides containment isolation on penetration M-219.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system de ,ign does not provide a means of verifying valve closure upon f )w reversal. Testing during power operation is impractical for ':his valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiabon levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22 10/16/95 SECTlON 11.7 99 OF 103
McGuire Unit 1
. J_ustification of Deferral I
, Item Number: 1-MC-VX1 Valve: 1VX-30 g Flow Diagram: MC-1557-1 Code Category: A,C 1
- ASME Class
- 2 Function: Provides containment isolation on penetration M-325. I Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
'l
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold j shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
1 Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION 11.7 100 OF 103
McGuire Unit 1 Justification of Deferral item Number: 1-MC-WL1 Valve: 1W1.-24 Flow Diagram: MC-1565-1.1 Code Category: A,C ASME Class: 2 i Function: Provides containment isolation and thermal over pressurization protection of line between 1WL-1B and 1WL-2A on penetration M-375. l i
Test Requirement: 1) Verify proper valve movement once per three months as l required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION l1.7 101 OF 103
L McGuire Unit 1 1.
l i-Justification of Deferral l
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Item Number: 1-MC-WL2 l
Valve: 1WL-385 t
(. Flow Diagram: MC-1565-7.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 1WL-3228 and 1WL-321 A on pen-etration M-221.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, i possibly with high radiation levels.
l Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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l-Revised by Rev. 22.
10/16/95 SECTION 11.7 102 OF 103
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l McGuire Unit 1 V
l Justification of Deferral i
Item Number: 1-MC-YM1 Valve: 1YM-116 Flow Diagram: MC-1601-2.4 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-337.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would invoive work insido containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev. 22.
10/16/95 SECTION ll.7 103 OF 103
i a McGuire Unit 2
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DUKE POWER COMPANY l McGUIRE NUCLEAR STATION - UNIT 2 1 PUMP INSERVICE TESTING PROGRAM ASME OM CODE-1987, OM Part 6 (OMa-1988 Addenda) 4 I
INTRODUCTION 4
The inservice testing of ASME Code Class 1,2 and 3 pumps provided with an emergency I power source will be tested as required by ASME Operations and Maintenance Standards
- Part 6 (OM-6), OMa-1988, of the ASME Code for Operation and Maintenance of Nuclear
! Power Plants, as referenced in 10CFR50.55a (January 1,1993 Edition), except where specific written relief has been granted by the Nuclear Regulatory Commission. The effective date of the submittalis March 1,1994.
Technical Specification 4.0.5 requires inservice testing of ASME Code Class 1,2 and 3 pumps in accordance with Section XI of the ASME Boiler and Pressure Boiler Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i). Pumps were selected for inclusion in the IST Program (Section 1.2) which fall within this category, as required by this Technical Specification. Pumps within the above ASME categories which are required to mitigate the consequences of an accident, shutdown the reactor or maintain shutdown are included in the program. Testing requirements are identified for each pump which ensure that the pump will perform as designed in response to an accident,in shutting down the reactor, or in maintaining shutdown. Acceptance criteria are specified in accordance with ASME Boiler and Pressure Vessel Code Subsection IWP. The safety functions of the pumps listed in Section 1.2 are included in the Design Basis .
Documents, and fall within the basic categories of accident mitigation, reactor shutdown, and maintaining shutdown. Post modification testing requirements are included in the applicable Nuclear System Directive; a modification test plan is required to be developed to verify proper 1 operation. The Code requires the determination of new reference values after pump repair or )
replacement, or maintenance which could impact operation. These Code requirements and i programmatic controls ensure that the pump inservice test program remains current fo!!owing !
modifications performed under 10 CFR 50.59. The documents used in development of this I program include the following: j I
e McGuire Technical Specifications.
- Safety Analysis Report.
. ASME Section XI, IWP (1986).
. ASME Operations and Maintenance Standards Part 6 (OM-6), OMa-1988.
. Supplement 1 to Generic Letter 89-04. j e NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants. j e Safety Evaluation Report for the McGuire IST Program dated October 21,1994 10/18/95 SECTION 1.1 1 of 2 l
McGuire Unit 2 A description of the Inservice Testing Program, Justification for Testing Deferral, as well as Specific Relief Requests from code requirements determined to be impractical,is described in the submittal. l 1
NOTES: 1) OMa-1988 Part 6, Section 7.3 requires the signature of the- i person or persons responsible for conducting and analyzing the !'
test. The dated initials of the person or persons responsible for
. conducting and analyzing the test will be used in place of a signature in the record of tests. Initials shall be construed as signatures to meet the intent of OM 6.
- 2) A Supplemental Test Program has been established, which includes components which have been determined important to i I
safety and prudent to test, but which are not explicitly under the scope of ASME Codes and Standards.
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10/18/95 SECTION l.1 2of2
E UNIT 2- McGUIRE NUCLEAR STATION Pump Inservice Testing . General Data Pump ID. Number Description Code Class Flow Diagram Applicable Relief Requests Test Frequency Remarks 2KCPU0004 Component Cooling 3 MC-2573-1.0 RR-l.3.1, RR-l.4.3 Quarterly NONE Water Pump 2B2 -
2NDPU0001 Residual Heat Removal 2 MC-2561-1.0 RR-l.3.1, RR-l.4.4 Quarterly The ND Testing Plan Pump 2A meets other code requirements unless otherwise specified.
2NDPU0002 Residual Heat Removal 2 MC-2561-1.0 RR-l.3.1, RR-l.4.4 Quarterly The ND Testing Plan Pump 28 meets other code requirements unless otherwise specified.
2NIPU0009 Safety injection Pump 2 MC-2562-3.0 RR-l.3.1, RR-l.4.5 Quarterly The NITesting Plan 2A meets other code requirements unless otherwise specified.
2NIPU0010 Safety injection Pump 2 MC-2562-3.0 RR-l.3.1, RR-l.4.5 Quarterly Tne NI Testing Plan 2B meets other code requirements unless otherwise specified.
2NSPU0001 Containment Spray 2 MC-2563-1.0 R R-l.3.1 Quarterly NONE Pump 2A .
SECTION l.2 10/12/95 3 OF 8 i
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UNIT 2 - McGUIRE NUCLEAR STATION Pump Inservice Testing Specific Data Discharge Differential Reference Pump ID. Number speed inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision -
2KCPU0004 Not Required RR-I.4.3 Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal Requirements Requirements Requirements 2NDPU0001 Not Required RR-l.4.4 Meets Code Meets Code RR-l.3.1 RR-I.4.4 Vertical Line 22 !
Requirements Requirements Shaft Centrifugal i
2NDPU0002 Not Required RR-l.4.4 Meets Code Meets Code RR-l.3.1 RR-l.4.4 Vertical Line 22 Requirements Requirements Shaft Centrifugal r 2NIPU0009 Not Required RR-l.4.5 Meets Code Meets Code RR-l.3.1 RR-l.4.5 Centrifugal 22 Requirements Requirements l 2NIPU0010 Not Required RR-l.4.5 Meets Code Meets Code RR-l.3.1 RR-l.4.5 Centrifugal 22 Requirements Requirements h
2 2NSPU0001 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal SECTION l.2 10/12/95 4OF8
UNIT 2 - McGUIRE NUCLEAR STATION Pump Inservice Testing General Data Pump 10. Number Description Code Class Flow Diagram Applicable Relief Requests Test Frequency Remarks 2NSPU0002 Containment Spray 2 MC-2563-1.0 RR-l.3.1 Ouarterly NONE Pump 2B i
2NVPU0015 Centrifugal Charging 2 MC-2554-1.0 RR-l.3.1, RR-l.4.6 Quarterly- The NV Testing Plan Pump 2A Miniflow; meets other coda ,
Refueling-Full requirements unless Flow otherwise specified.
(RR-l.4.6) 2NVPUOO16 Centrifugal Charging 2 MC-2554-1.0 RR-l.3.1, RR-l.4.6 Quarterly- The NV Testing Plan Pump 2B Miniflow: meets other code Refueling-Full requirements unless Flow otherwise specified.
(RR-l.4.6) 2NVPU0027 Boric Acid Transfer 3 MC-2554-5.0 RR-l.3.1 Quarterly NONE Pump 2A t
2NVPU0028 Boric Acid Transfer 3 MC-2554-5.0 RR-l.3.1 Quarterly NONE Pump 2B 2RNPU0003 Nuclear Service Water 3 MC-2574-1.1 RR-l.3.1 Quarterly NONE Pump 2A i
SECTION l.2 10/12/95 5 OF 8
UNIT 2 - McGUIRE NUCLEAR STATION Pump inservice Testing Specific Data Discharge Differential Reference Purnp ID. Number Speed inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision 2NSPU0002 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 2NVPU0015 Not Required RR-l.4.6 Meets Code Meets Code RR-l.3.1 RR-l.4.6 Centrifugal Requirements Requirements 2NVPU0016 Not Required RR-l.4.6 Meets Code Meets Code RR-l.3.1 RR-l.4.6 Centrifugal Requirements Requirements 2NVPU0027 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal Requirements Requirements Requirements Requirements 2NVPU0028 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal Requirements Requirements Requirements Requirements 2RNPUOOO3 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal 22 Requirements Requirements Requirements Requirements SECTION 1.2 10/16/95 6 OF 8
UNIT 2 - McGUIRE NUCLEAR STATION Pump inservice Testing General Data Pump ID. Number Description Code Class Flow Diagram Applicable Relief Requests Test Frequency Remarks 2RNPU0004 Nuclear Service Water .3 MC-2574-1.1 RR-l.3.1 Quarterly NONE Pump 2B 2WNPUOO94 Diesel Generator Sump 3 MC-2609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 2A2 dry sump pumps per OMa-1988, Part 6 l section 5.5. !
2WNPU0096 Diesel Generator Sump 3 MC-2609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 2A3 dry sump pumps per ,
OMa-1988, Part 6 section 5.5.
2WNPU0095 Diesel Generator Sump 3 MC-2609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 282 dry sump pumps per OMa-1988, Part 6 section 5.5.
2WNPU0097 Diesel Generator Sump 3 MC-2609-7.0 RR-l.3.1 Two Year Two year frequency for Pump 2B3 dry sump pumps per OMa-1988, Part 6 section 5.5.
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i SECTION 1.2 10/12/95 7OF8 4
E UNIT 2 - McGUIRE NUCLEAR STATION Pump Inservice Testing Specific Data Discharge Differential Reference Pump ID. Number Speed Inlet Pressure Pressure Pressure Vibration Flow Rate Pump Type Revision 2RNPU0004 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Centrifugal 22 Requirements Requirements Requirements Requirements 2WNPU0094 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirernents Requirements Requirements Requirements Shaft Centrifugal 2WNPU0096 Not Required Meets Code Meets Code Meets Code R R-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 2WNPUOO95 Not Required Meets Code Meets Code Meets Code RR-l.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal 2WNPU0097 Not Required Meets Code Meets Code Meets Code RR-I.3.1 Meets Code Vertical Line Requirements Requirements Requirements Requirements Shaft Centrifugal SECTION l.2 10/16/95 8OF8
McGuire Unit 2 l General Relief Requesj RELIEF REQUEST: 1.3.1 I
PUMPS: All pumps in the Inservice Test Program i i
TEST REQUIREMENTS: OMa-1988 Part 6 Section 6.1 (Table 3a) specifies the allowable range for acceptable operation of vibration measurements.
BASIS FOR RELIEF: Experience has shown that smooth operating pumps (Vr s 0.075 in/sec) often fallin the alert range of vibration measurement when compared to the acceptance criteria given in OMa-1988 Part 6, Table 3a. The Code i does not include provisions for a fixed band acceptance criteria for these l pumps. The Attemative Testing provided below applies to all pumps in l the Testing Program by establishing a threshold of vibration of s 0.075 ,
in/sec. In addition to this, OMa-1988 Part 6 does not specifically address different types of positive displacement pumps. Since McGuire has internal gear positive displacement pumps, the Altemate Testing i below will be used for these pumps.
ALTERNATE TESTING: In addition to the vibration specifed in OMa-1988 Part 6, Table 3a, the !
following ranges shall be used.-
Acceptable Alert Required Range Range Action Range For all pumps when 0 to 0.19 in/sec > 0.19 s 0.45 in/sec > 0.45 in/sec Vr s 0.075 in/sec For centrifugal, vertical 5 2.5
- Vr > 2.5
- Vr to 6
- Vr or > 6
- Vr or !
line shaft and positive > 0.325 to 0.70 in/sec > 0.70 in/sec ,
displacement pumps except reciprocating when {
Vr > 0.075 in/sec For reciprocating pumps, s 2.5
- Vr > 2.5
- Vr to 6
- Vr > 6
- Vr when Vr > 0.075 in/sec l Revised by revision 17 10/12/95 SECTION l.3 1 OF 1
McGuire Unit 2 Specific Relief Reauest RELIEF REQUEST: 1.4.4 PUMPS: 2NDPU0001,2A Residual Heat Removal Pump 2NDPU0002,2B Residual Heat Removal Pump TEST REQUIREMENT: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly Residual Heat Removal Pump test will meet accuracy requirements for assuring Residual Heat Removal Pump operability per Technical Specifications.
ALTERNATE TESTING: The Residual Heat Removal Pumps will be tested according to the following program, which is consistent with Generic Letter 89-04.
These pumps have process instrumentation installed such that there are two suction pressure gauges (0-60 psig and 0-600 psig), and one discharge pressure gauge, ( 0-1000 psig). Each has a 0.5% accuracy.
This is done to provide accurate pressure indication in either the recirculation or the heat removal condition of operation. As such, there are times when the 3 times the reference range requirements cannot be met.
Quarterly The Residual Heat Removal Pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1.
The test loop used in the test has a flow measuring orifice installed, howeve *, the system resistance cannot be adjusted with the associated throttling valve without invalidating the Residual Heat Removal system j flow balarx:e (a Tech Spec balance of flow to all 4 cold legs.) Therefore, flow through this loop will be recorded for information only.
The instrume'tation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. Since the instrumentation used to measure j suction and discharge pressure is more accurate than code requirements (0.5% vs. 2%) using the process instrument for this test will yield results within the overall eccuracy requirements of the code and will meet applicable accura'.:y requirements for the determination of operability per Technical Specifications. Typical values for ND suction pressure in mini-l 10/12/95 SECTION l.4 6 OF 12
't McGuire Unit 2 Specific Relief Reaues.t RELIEF REQUEST: 1.4.4 (Continued) flow are 49-81 psig, and discharge pressures are in the 230-260 psig range. Therefore, the process range for discharge pressure (0-1000 psig) will not meet the three times criteria; the appropriate suction pressure loop can be used, which is within the three times requirement.
The accuracy of these process instruments (0.5%) is well below the requirements specified in Table 1 of OM-6 for instrument accuracy (2%).
The actual reading error at test pressure due to the process instrument is 2.2 % (0.5
- 1000/230) for discharge pressure at the low end of this range (ND pump procedures specify that instrumentation must meet the three times criteria), if a 0-690 psig gauge was used with 2% accuracy, the reading error would be 6% (2
- 690/230). When the requirements of Oma-1988 Part 6, Section 4.6.1.2.a and Table 1 are combined, the actual instrument error introduced into the test is less than the code allowable (2.2 % vs. 6 % at the low (conservative) end). Using the process instruments for suction and discharge pressure data does not degrade the quality of the test and meets the intent of the instrumentation requirements of the code.
l Refuelina Outaae
]
i Full flow vibration measurements will be taken during refueling outages j as part of the IST Supplemental Program. J l
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Revised by revision 17 10/12/95 SECTION 1.4 7 OF 12
r i McGuire Unit 2 Specific Relief Reauest 4 l
i RELIEF REQUEST: 1.4.5 I
PUMPS: 2NIPU0009,2A Safety injection Pump 2NIPUOO10,2B Safety injection Pump j TEST REQUIREMENT: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly ,
Safety injection Pump test will meet accuracy requirements for assuring l
Safety injection Pump operability per Technical Specifications. l ALTERNATE TESTING: The Safety injection Pumps will be tested according to the following program, which is consistent with Generic Letter 89-04.
Quarterly The Safety injection Pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1. The test loop has a flow measuring orifice installed, however, there is no means provided to vary the system resistance to set either the flow or differential pressure. Therefore, flow through this loop will be recorded for information only.
The instrumentation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for l the determination of operability per Technical Specifications. The process instruments meet the three times criteria, however in the event a test instrument is to be used, based on available equipment, it may not meet the three times criteria. In these instances, the accuracy of the test instruments is 0.25%, and this accuracy applied over the range of the instrument w!U meet the uncertainty allowed by the code assuming an accuracy of 24.
10/12/95 SECTION l.4 8 OF 12 s
McGuire Unit 2 Specific Relief Reauest RELIEF REQUEST: 1.4.5 (Continued)
Typical values for Ni suction pressure are in the 25-51 psig range, and discharge pressures are in the 1500-1575 psig range. Test equipment used for suction and discharge pressures may not meet the three times criteria, however these instruments will have 0.25% accuracy. The NI pump procedures specify that if a test instrument is needed for suction pressure, a 0-60 psig instrument is preferred, and that the rango of the instrument must not exceed 0-100 psig. They also specify that if a discharge pressure test instrument is to be used,0-2000 psig range is ,
preferred, not to exceed 0-4500 psig. Using the low end suction '
pressure of 25 psig with the high end allowable gauge, accuracy is 1% i (0.25
- 100/25); if a 0-75 psig gauge was used with a 2% accuracy, the code allowable would be 6% (2
- 75/25), so that use of this gauge would be within the code requirements. Using the low end discharge pressure 1 with the high end allowable gaugo, accuracy is 0.75% (0.25
- l' 4500/1500); this is at the three times range, and use of a 2% accuracy gauge would produce a total 6% allowable error. Therefore, using these test instruments for suction and discharge pressure data does not degrade the quality of the test and meets the intent of the instrumentation requirements of the code.
Refuelina Outagg Full-flow vibration will be recorded under the IST Supplemeraal Program.
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Revised by revision 17 10/12/95 SECTION l.4 9 OF 12
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McGuire Unit 2 Specific Relief Reauest RELIEF REQUEST: 1.4.6
- PUMPS
- 2NVPUOO15,2A Centrifuga! Charging Pump 2NVPU0016,2B Centrifugal Charging Pump TEST REQUIRE:.1Ehi: OMa-1988 Part 6, Section 4.6.1.2.a specifies the range of each instrument shall be three times the reference value or less.
BASIS FOR RELIEF: Range requirements will be waived for the tests. The purpose of the quarterly test is to verify Tech Spec requirements are met and to obtain l vibration data for trending. The suction and discharge pressure gauges l (0-60 psig and 0-3000 psig) installed for the pump have an accuracy of 0.5%. These pumps are aligned from the VCT for the quarterly test.
Since these pumos are tested with different levels of VCT pressure, the suction pressure may vary over a range of approximately 15 to 50 psig.
Since the uncertainty associated with using the process gauge is better than that allowed by code requirements, (2% vs. 6% determined by 0.5
- 60/15 vs. 2
- 45/15) the instrumentation used for the quarterly Centrifugal Charging Pump test will meet accuracy requirements for assuring Centrifugal Charging Pump operability per Technical Specifications.
Regarding instrument accuracy during the refueling outage testing (in Relief Request 1.4.6), the range of the highest suction pressure test gauge allowed for the full flow point will be 0-450 psig, and the range of the highest discharge pressure test gauge allowed (for the full flow point) will be 0-4500 psig. Suction pressure is typically 140 to 160 psig, and discharge pressure ranges from approximately 1000 to 2700 psig, so that overall suction and discharge pressure reading accuracy are 0.8 %
(0.25
- 450/140) and 1.1 % (0.25
- 4500/1000), respectively. If a 0-420 psig suction pressure gauge was used with 2% accuracy, allowable accuracy would be 6 % (2
- 420/140), and if a 0-3000 ps%1ischarge pressure gauge was used with 2% accuracy, allowable awuracy would be 6 % (2
- 3000/1000). Therefore, using these test instruments for suction and discharge pressure data (for the full flow point) dees not degrade the quality of the test and meets the intent of the instrumentation requirements of the code. A 1% uncertainty is conservatively added for the flow orifice.
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10/12/95 SECTION 1.4 l 10 OF 12 L
l
t McGuire Unit 2 Specific Relief Reauest d
i RELIEF REQUEST: 1.4.6 (Continued)
ALTERNATE TESTING: The Centrifugal Charging Pumps will be tested according to the following
! program, which is consistent with Generic Letter 89-04.
i QuarterIV The Centrifugal Charging Pumps will be tested quarterly to verify Technical Specifications are met. The test measures differential pressure and velocity vibration data. The differential pressure and velocity vibration data will be trended. The instrumentation range requirements of OMa-1988 Part 6, Section 4.6.1.2.a will be waived. The instrumentation used to measure suction and discharge pressure will meet applicable accuracy requirements for the determination of operability per Technical Specifications. The instrument used to measure vibrations will meet the requirements specified in relief request 1.3.1. The flow through the miniflow line to the Volume Control Tank will be assumed to be constant at the orifice design conditions (60 gpm).
Refuelino Outaae During each refueling outage, a code pump test - including velocity l
vibration measurements will be performed at a full flow test point.
~
The instrumentation used for the refueling outage tests is test 3 instruments, with accuracy of 0.25%. When applied over the span on the instrument and the various range of outputs, in all cases the uncertainty of the overall loop will meet or exceed the code requirements of 2% over the instrument's range.
Revised by revision 17 10/12/95 SECTION l.4 11 OF 12
. . . . - . . . - . ~ _ . - . .- . . . - .. .- . . - . . . . . -
l i McGuire Unit 2 i Speelfic Relief Reauest ;
1 RELIEF REQUEST: 1.4.7 l
PUMPS: 2RNPU0003,2A Nuclear Service Water Pump -
l 2RNPU0004,28 Nuclear Service Water Pump l
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Relief Request deleted by Revision 17 l
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l 10/12/95 SECTION l.4 12 OF 12 i
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McGuire Unit 2 DUKE POWER COMPANY McGUIRE NUCLEAR STATION - UNIT 2 VALVE INSERVICE TESTING PROGRAM INTRODUCTION The inservice testing of ASME Code Categories A, B, C and D will be performed as required by ASME OM-Code-1987, Part 10 OMa-1988 addenda included, (Inservice Testing of Valves in Light-Water Reactor Power Plants), as incorporated in 10CFR50.55a.
These rules for IST were instituted by 1989 edition of ASME Section XI and will be adhered to, except where specific written relief has been granted by the Commission.
The effective date for this ten year submittal is March 1,1994.
Technical Specification 4.0.5 requires inservice testing of ASME Code Class 1,2 and 3 valves l in accordance with Section XI of the ASME Boiler and Pressure Boiler Code and applicable l Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief j has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i). Valves -
were selected for inclusion in the IST program (Section 11.2) which fall within this category, as l
required by this Technical Specification. , alves within the above ASME categories which are required to mitigate the consequences of an accident, shutdown the reactor or maintain 1 shutdown, or are pressure relief devices which protect systems or portions of systems which I provide these functions, are included in the program. Testing requirements are identified for l each valve which ensure that the valve will perform as designed in response to an accident, l shutting down the reactor, or in providing relief protection. Valves are categorized in 1 accordance with OM-10 Section 1.4, as Category A, B or C (there are no Category D valves j in the program). Valves with remote position indicators are observed locally at least once every 2 years in accordance with the Code. Acceptance criteria are specified in accordance with ASME Boiler and Pressure Vessel Code Subsection IWV. The safety functions of the valves listed in Section ll.2 are included in the Desigri Basis Documents, and fall within the basic categories of accident mitigation, reactor shutdown or maintaining shutdown, or pressure relief for systems providing such. Post modification testing requirements are included in the applicable Nuclear System Directive; a modification test plan is required to be developed to verify proper operation. OM-10 requires the determination of a new reference value after valve replacement, repair or maintenance that could affect its operation. These Code requirements and programmatic controls ensure that the valve inservice test program is maintained current with modifications performed under 10 CFR 50.59. The documents used in development of this program include the following:
. McGuire Technical Specifications.
. Safety Analysis Report. ;
- ASME Section XI, IWV (1986).
. ASME OM-Code-1997, Part 10 Oma-1988 addenda included.
. Supplement 1 to Generic Letter 89-04.
. NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants.
. Safety Evaluation Report for the McGuire IST Program dated October 21,1994.
10/18/95 SECTION 11.1 1 of 2
McGuire Unit 2 NOTES: 1) The dated initials of the person responsible for the action may be used in place of a signature in the record of tests. Initials shall be construed as signatures to meet the intent of OMa-1988, Section 6.3.
- 2) Category A and A/C valves include containment isolation valves (CIV) and pressure isolation valves (PlV). CIVs are leak tested in accordance with 10CFR50, Appendix J, and Section 4.2.2.3, unless specific relief is requested.
- 3) Generic Letter 89-04, provides guidance for sample disassembly of check valves as an alternative to verify operability of check valves. The check valves where sample disassembly will be utilized will be specifically referenced in the contents of the submittal and performed according to the guidelines of Generic Letter 89-04.
- 4) A Supplemental Test Program has been established, which includes components which have been determined important to safety and prudent to test, but which are not explicitly under the scope of ASME Codes and Standards.
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o l 10/18/95 SECTION ll.1
( 2 of 2 I
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Unit 2 - McGuire Nuclear Station ,
inservice Testing Program FLOW FLOW ASME VALVE ACT VALVE ACTUATOR TEST TEST RE1JEF JUSTIF OF TEST VALVE NUMBER DIAGRAM COOR CLASS CATEGORY PAS TYPE TYPE REQ'MT #1 REQ 11T #2 REQST DETERRAL REMARKS ALTERNATIVES REV STEAM GENERATOR BLOWDOWN RECYCLE (BB) 2BB-CD01B 2580-1.0 H42 2 B ACT Gate AOV ST-Q - - - - - -
2BB-CD02B 2580-1.0 H-04 2 B ACT Gate AOV ST-Q 22 2BB-CD03B 2580-1.0 H-12 2 B ACT Gate AOV ST-O - - - - - 22 2BB-CD04B 2580-1.0 H-10 2 B ACT Gate AOV ST-Q - - - - - -
, 2BB-CD05A 2580-1.0 7-02 2 B ACT Gate AOV ST-Q - - - - - -
2BB-CD06A 2580-1.0 F-04 2 B ACT Gate AOV ST-O - - - - - -
i 2BB-0007A 2580-1.0 F-12 2 B ACT Gate AOV ST-O - - - - - -
2BB-CD08A 2580-1.0 F-10 2 B ACT Gate AOV ST O - - - - - - =
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10/16/95 BB - 1 of 1
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- _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ - . . . . . . - . - . . - . - .- - . . . . . . . . . . - . , . . . . ~. - - - . _ _ _ _ _ _ _ _ _ _ .
Unit 2 - McGuire Nuclear Station Inservice Testing Program FLOW Il OW ASME VALVE ACT VALVE ACTUATOR TEST TEST RELIEF JUST!F 0F TEST VALVE NUMBER DIAGRAM COOR CLASS CATEGORY PAS TYPE TYPE REQAfT41 REQ'MT #2 REOST DLIERRAL REMARKS ALTERNATIVES REV CHEMICAL AND VOLUME CONTROL (NY) 2MV-0006 2554-12 K-08 2 C ACT Relief -
SP - - - -
600 PStG -
2MV-0007B 2554-12 J-11 2 B ACT Globe EMO ST-O - -
2-MC-NV2 - - -
Sgmg
,' 2NV-0020 2554-12 E-02 2 C ACT Check -
SP - - -
Loaded Ck 200 PSIG -
Valve 2NV-0021A 2554-1.2 E-03 1 B /*CT Contml AOV ST-O - -
2-MC-NV3 - - -
2WV-CD29 2554-1.0 C-02 2 C ACT Check -
MTO-O - - - - - -
2MV-0331 2554-1.0 D-02 1 C ACT Check -
MTO-O - - - - - -
2WV-0035A 2554-1 2 K-07 2 B ACT Gate AOV ST-O - -
2-MC-NV19 - -
17 2MV-C345 2554-1.0 C-08 2 C ACT Check -
MTO-O - - - - - -
2NV-0047 2554-1.0 D-08 1 C ACT Check -
MTO-O - - - - - -
2NV-0061 2554-1.1 C-02 2 C ACT Check -
MTO-O - - - - - -
2MV-0063 2554-1.1 D-02 1 C ACT Check -
MTO-O - - - - - -
2NV-0077 2554-1.1 C-08 2 C ACT Check -
MTO-O - - - - - -
2NV-C079 2554-1.1 D-08 1 C ACT Check -
MTO-O - - - - - -
2NV-0093 2554-1.1 K-12 2 C ACT Relief -
SP - - - -
150 PSIG +
2NV-0094AC 2554-1.1 J-13 2 B ACT Gate EMO ST-O - -
2-MC-NV1 - - -
2NV-0095B 2554-1.1 H-13 2 B ACT Gate EMO ST-O - -
2-MC-NV1 - - -
10/16/95 NV - I of 4
Unit 2 - McGuire Nuclear Station Inservice Testing Program I-LOW FLOW ASME VALVE ACT VALVE AcrUATOR TEST TLST RFLIEF JUSTlF OF T13T VALVE NUMBLR DIAGRAM CW)R CIASS CSTLGORY PAS TYPE TYPE REQMT #1 RI Q'MT *2 REQST DLIERRAL RE MARKS ALTE RNATIVES REV 2WV-0141 A 2554-2.0 B-08 2 B ACT Gate EMO ST-O - -
2-MC-NV4 - - -
2W-0142B 2554-2.0 B-07 2 B ACT Gate EMO ST-O - -
2-MC-NV4 - - -
2NV-0143 2554 2.0 B-06 2 C ACT Check -
MTC-O - -
2-MC-NV15 - - -
2NV-01508 2554-2.0 F-02 2 B ACT Kerotest EMO ST-Q - -
2-MC-NV8 - - -
2W-0151 A 2554-2.0 G-02 2 B ACT Kerotest EMO ST-Q - -
2-MC-NVB - - -
2NV-0155 2554-2.0 1-06 2 C ACT Relief -
SP - - - -
150 PSIG -
2W-0156 2554-2.0 J-09 2 C ACT Relief -
SP - - - -
255 PSIG -
2W-0164 - - - - - - -
DELETED - - - - -
17 2NV-0170 2554-2.0 C-08 2 C ACT Relief -
SP - - - -
75 PSIG -
2NV-0218 2554-3.0 J-05 2 C ACT Check -
MTC-Q - - - - - -
2W-0221 A 2554-3.1 H-01 2 B ACT Gate EMO ST-O - -
2-MC-NV6 - - -
2W-0222B 2554-3.1 1-01 2 B ACT Gate EMO ST-O - -
2-MC-NV6 - - -
2NV-0223 2554-3.1 1-02 2 C ACT Check -
MTO.C-O - -
2-MC-NV11 - - -
2W-0225 2554-3.1 F-05 2 C ACT Check -
MTO C-O - -
2-MC-NV10 - - -
2W-0227 2554-3 1 E-06 2 C ACT Check -
MTO.C-O - - - - - -
2W-0229 2554-3 1 1-12 2 C ACT Relief -
SP - - - -
220 PSIG -
10/16/95 NV - 2 of 4
Unit 2 - McGuire Nuclear Station inservice Testing Program FLOW ILOW ASME VALVE ACT VALVE ACTdATOR TEST TEST REllEF JUSTIF 0F TEST VALVE NUMBER DIAGRAM COOR CIASS CATEGORY PAS TYPE TYPE REQMT 81 REQMT 82 REQST DEFERRAL REMARKS . ALTERNAT&TS REV 2W-0231 2554-3.1 F-10 2 C ACT Check -
MTO.C-O - -
2-MC-NV10 - - -
2NU-0233 2554-3.1 E-10 2 C ACT Check - MTO,C-O - - - - - -
2W-0238 DELETED 16 2W-0244A 2554-3.0 K-08 2 B ACT Gate EMO ST-O - -
2-MC-NV5 - - --
2W-0245B 2554-3.0 K-09 2 B ACT Gate EMO ST-O - -
2-MC-NV5 - - -
2WV-0261 2554-3.1 J-03 2 C ACT Check -
MTC-O - -
2-MC-NV13 - - -
2NV-0263 2554-3.1 J-11 2 C ACT Check -
MTC-O - -
2-MC-NV13 - - -
2W-0264 2554-3.1 J-10 2 C ACT Check -
MTO.C-O - - 2-MC-NV7 - - -
2NV-02658 2554-3.1 J-09 2 B ACT Globe EMO ST-O - -
2-MC-NV9 - - -
2W-0383 2554-5.0 F-06 3 C ACT' Check - MTO,C-Ci - - - - - -
2NV-0386 2554-5.0 D-06 3 C ACT Check -
MTO.C-O - - - - - -
2W-0457A 2554-1.2 1-07 2 B ACT Control AOV ST-O - -
2-MC-NV19 - - 17 2W-0458A 2554-12 J-07 2 B ACT Control AOV ST-O - -
2-MC-NV19 - -
17 2W-0482 2554-2.0 D-07 2 C ACT Relief -
SP - - - -
150 PSIG .-
2NV-0483 2554-2.0 D-11 2 C ACT Refef -
SP - - - -
150 PSIG -
2W-0486 2554-3.1 J-09 2 C ACT Relief -
SP - - - -
150 PSIG ' -
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Unit 2 - McGuire Nuclear Station inservice Testing Program F1.OW H.OW ASME VALVE ACT VALVE ACTUATOR TEST TEST RELIEF JUSTIF OF TEST VALVE NUMBER DIAGRAM CDOR CLASS CA1T. GORY PAS TYPE TYPE REQ 1fT#1 REQ 1tT s2 REQST DEFERRAL REht\RKS AL1T.RNATIVES REV 2RN-02380 2574-3.1 1-07 3 B ACT Butterfly EMO ST-O - - - - - -
2RM-0240B 2574-3.0 F-13 3 B ACT Globe AOV ST-O - - - - - -
2RN-0252B 2574-4.0 E-02 2 A ACT Diaphram AOV ST-O LT-RF -
2-MC-RN1 ' - - -
2RN-0253A 2574-4.0 C-02 2 A ACT Diaphram EMO ST-O LT-RF -
2-MC-RN1 - - -
2RN-0276A 2574-4.0 J-02 2 A ACT Diaphram EMO ST-O LT-RF -
2-MC-RN2 - -- -
2RN-02778 2592-4.0 H-02 2 A ACT Diaphram AOV . ST-O LT-RF -
2-MC-RN2 - - -- -
' 2RN-0279B 1574-1.0 C-02 3 B ACT Butterfly EMO ST-O - - - - - -
2RN-0293 2574-3.1 1-05 3 C ACT Relief -
2RN-0294 2574-3.0 F-12 3 C ACT Relief -
SP - - - -
135 PSIG -
2RN-0295 2574-2.0 H-11 3 C ACT Relief -
SP - - - -
135 PSIG -
2RN-0296A 2574-1.1 L-13 3 B ACT Butterfly EMO ST-O - - - - - -
2RN-0297B 2574-3.0 L-05 3 B ACT .Ntterfly EMO ST-O - - - - - -
2RN-0299A 1574-1.0 C-02 3 B ACT Butterfly EMO ST-O - - - - - .-
2R40891 DELETED - - - - -
17 2RN-0892 - - - - - - -
DELETED - - - - -
17 2RM-0994 2574-3.1 C-07 3 C ACT Check -
MTC-O - - - - - 16 10/16/95 RN - 4 of 5
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McGuire Unit 2
. Specific Relief Reauest ;
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Item Number: 2-MC-RR-NS1 Valve: 2N S-13, 2N S-16, 2N S-30, 2N S-33, 2NS-41, 2NS-46 Flow Diagram: MC-2563-1.0 Code Category: C ASME Class: 2 Function: Open on flow from containment spray pumps.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Relief: Containment Spray valves 2NS-13,16, 30, 33, 41, and 46 are AloycoM/alworth model D-49300 cover hung, swing check valves. They are normally closed providing Category C interior ,
containment isolation for Containment Spray and Auxiliary l Containment Spray (valves 2NS-41 and 46 ). OMa 1988,.Part 10, paragraph 4.3.2.1 requires quarterly exercising, deferrable to cold shutdowns or refueling outages. McGuire FSAR Table 6-112 identifies these valves as Leak Class 1 A nivec not requiring leak rate testing due their inability to release containment atmosphere during a LOCA.
Full stroke operation of the check valves shall be verified by disassembly / inspection of the valves as no operational method exists without actuating containment spray (reference 2MC-NS2, NUREG-1482 Staff Position 2). As a supplement to the full stroke testing, part stroke and closed verification will be conducted upon reassembly and periodically by air test as described for the spray nozzle test in McGuire FSAR 6.5.4 (reference , NUREG 1482 Staff Position 2 ).
For valve disassembly / inspection, all six valves will be grouped into one group and inspected within a four cycle window ( six l year interval). All six valves are identical in manufacturer and installation. Operationally, the valves are identical with respect to operational readiness. During system actuation, supply originates from the Containment Spray system for valves 2NS-13,16,30, and 33 and Residual Heat Removal system for Revised by Rev.17.
10/12/95 SECTION 11.6 1 OF 8
I McGuire Unit 2 Specific Relief Reauest i
ltem Number: 2-MC-RR-NS1 (cont.)
2NS-41 and 46. In spray modes both tystems have similar hydraulic characteristics. At McGuire's discretion the valves may be disassembled / inspected sequentially, in sub-groups, or as one complete group every fourth outage ( six years ).
Diversion from the sequential disassembly / inspection represents i an extension from the Code required frequency.
The relief request does not represent a decrease in quality nor i safety. The valve disassembly / inspection will demonstrate ability of the valve to full stroke and fully close. As the valves do not function except during testing and severe plant emergencies, no operating degradation mechanisms exist. Potential degradation mechanisms from the valves being in a static position will be identified by the part stroke test conducted each refueling outage on all valves.
Compliance with the Code requirements is impractical and would l Impose unnecessary hardship. The valves are located within the I containment dome volume and are accessible by a temporary ,
cantilevered scaffold attached to the Polar Crane Scissors Jack. 1 This action, in accordance with the requirements of 29CFR I 1910.28, 29CFR 1926.452, ANSI A10.8-1977, and McGuire's Scaffold program places personnel in unsafe positions during the erection / removal of the scaffold and valve testing. No additional assurance of valve function is gained. In fact, although unlikely, frequent intrusion into the valves' internals and the inability to verify exact seat alignment during reassemble may degrade the valves' condition.
Pursuant to NUREG-1482 Staff Position 2, extension of the valve disassembly / inspection interval will be considered in cases of extreme hardship. Response to Question 19 of same implies
" extreme hardship" is proportional to the impact on plant safety. I The hardship impact is one of undue personnel safety risk and refueling outage extension. Yet the benefit from testing under the current scheme (reference 2MC-NS2 ) as compared to the proposed scheme is negligible at best. All valves will be ,
disassembled / inspected once per four refueling outages (six !
years ). '
l Revised by Rev.17.
10/12/95 SECTION 11.6 2OF8 l
McGuire Unit 2 Specific Relief Reaue_a1 Item Number: 2-MC-RR-NS1 (cont.)
A review of McGuire's valves, similar industry valves, and the "EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" was conducted.
A review of the past 6 Unit 1 refueling outages, 7 Unit 2 Identified part stroke testing of all valves every outage through 1/2EOC 9. Since 1/2EOC 6 each Containment Spray check valve has been disassembled / inspected once and Auxiliary Containment Spray valves twice (due to the current grouping scheme ). A comprehensive review of all valves identified no indication of wear, corrosion, or degradation.
A NPRDS search for Aloyco-Walworth and Walworth check valves provided a list of 34 Containment Spray check valve failures. A detailed review of the 34 failures identified 14 potentially related failures. Subsequent conversation with the respective plants' System Engineers resolved 11 of these potentially related failures as unrelated. Reasons for determining a valve failure was unrelated included the following; valves normally see flow during testing or other plant operation, and recent ISI disassembly / inspection of valves identified no degradation. The 3 remaining potentially related failures included 2 which could not be determined and 1 which was a result of valve disk misalignment. As stated earlier the potential for valve disk misalignment increases, although marginally, with repetitive disassembles.
A review of the "EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" primarily addressed degradation of check valves regularly in operation service. Design criteria for <
check valve application was also discussed. Comparison with !
the subject check vi'ves did not reveal any design l misapplication issues. The issue of valve sticking open/ closed I was discussed in section 6.5.4, identifying improperly assembly as a potential cause. This issue would be addressed by the proposed part flow testing.
This Relief Request evaluation concludes adequate justification without compromise to safety or quality exist to warrant the proposed test methodology.
I Revised by Rev.17.
1 10/12/95 SECTION 11.6 )
30F8 I
McGuire Unit 2 Specific Relief Reauest item Number: 2-MC-RR NS1 (cont.)-
l Test Alternative & Frequency: Containment Spray valves 2NS-13,16,30, 33, 41, and 46 will be '
grouped into a single test group. The valves may be disassembled / inspected sequentially, in sub-groups, or as one complete group every fourth outage ( 6 years ). Each valve will be disassembled / inspected once per four refueling outages ( 6 years ). Each Containment Spray valve will be part stroke tested during each refueling outage.
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Revised by Rev.17 10/12/95 SECTION 11.6 4OF8
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i McGuire Unit 2 1'
Justification of Deferral ,
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ltem Number: 2-MC-CA1 Valve: 2CA-37, 2CA-41, 2CA-45, 2CA-49, 2CA-53, 2CA-57, 2C A-61,
, 2CA-65 l
Flow Diagram: MC-2592-1.0 Code Category: C ASME Class: 2 Function: Check flow from the steam generators to Auxiliary Feedwater.
Open to allow Auxiliary Feedwater supply to the Steam Generators.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Full stroke testing these valves during power operations would ur:necessarily thermal shock the steam generators and feedwater piping.
Test Alternative & Frequency: Valves will be full stroke exercised at cold shutdown. Closure will be verified quarterly.
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-10/16/95 SECTION 11.7 1 OF 104
McGuire Unit 2 i
Justification of Deferral I
Item Number: 2-MC-CA2 l Valve: 2CA-165,2CA-166 Flow Diagram: MC-2592-1.1 Code Category: C l
ASME Class: 3 Function: Prevents backflow from Auxiliary Feedwater System to Nuclear service Water System until the associated EMOs are closed.
)
1 EMOs are powered from the same train they serve. Must open J to allow assured makeup flow to CA from RN system.
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Test Requirement: Verify proper valve movement once per three months as re- J quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Neither full nor partial flow can be put through these valves without contaminating the Auxiliary Feedwater System with raw water. No means exist for alternate testing techniques using air or any other medium. No means exist to test for proper closure j without contaminating the Auxiliary Feedwater System with raw ;
water. These valves will not be tested during cold shutdown '
because sample disassembly is required.
Test Alternative & Frequency: At least one of these two valves will be disassembled and full stroked during each refueling outage, and both valves will have been disassembled and full stroked after two consecutive refu-eling outages. Failure of one valve to properly full stroke during a refueling outage will result in the remaining valves being disassembled and full stroked during that outage. Sample disassemble will also be used to verify proper closure of valves.
10/16/95 SECTION 11.7 2 OF 104
i McGuire Unit 2 Justification of Deferral 9
item Number: 2-MC-CA3 Valve: 2CA-8,2CA-10,2CA-12 Flow Diagram: MC-2592-1.1 Code Category: C ASME Class: 3 Function: Auxiliary Feedwater Pump Suction Check valves to prevent diversion of assured auxiliary feedwater source.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: These valves cannot be tested to close without contaminating the Auxiliary Feedwater System with raw water. These valves will not be tested during cold shutdown because sample disas-sembly is required.
Test Alternative & Frequency: Valves will be sample disassembled during refueling outages to >
verify valve closure capability. 2CA-8 is disassembled every refueling outage,2CA-10 and 2CA-12 every other refueling outage on a staggered basis.
l 10/16/95 SECTION 11.7 3 OF 104 ,
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2 _ _ . . . .... . e a _....# ~u_ a a u
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i McGuire Unit 2 Justification of Deferral item Number: 2-MC-CF1 Valve: 2C F-26 AB, 2CF-28 AB, 2C F-30AB, 2C F-35 AB Flow Diagram: MC-2591-1.1 ,
Code Category: B l
ASME Class: 2 l
Function: Provide feedwater and containment isolation.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of these valves would isolate the Steam Generator feedwater which could result in a severe transient in the Steam Generator,' resulting in a Unit trip.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION 11.7 4 OF 104
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Justification of Deferral )
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item Number: 2-MC-CF2 Valve: 2C F-17AB, 2C F-20AB, 2C F-23AB, 2CF-32AB Flow Diagram: MC-2591 1.1 j l
Code Category: B I
ASME Class: ANSI B31.1.0 (1967) l Function: Feedwater control. j Test Reauirement: Stroke time test in accordance with OMa-1988 Par! 10,4.2.1.1.
l Basis for Deferral: Closure of these valves would isolate the Steam Generator f feedwater which could result in a severe transient in the Steam !
Generator, resulting in a Unit trip.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION 11.7 5 OF 104
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-1 Justification of Deferral I 1
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I Item Number: 2-MC-CF3 Valve: 2C F-1268, 2CF-1278, 2C F-128B, 2CF-129B Flow Diagram: ' MC-2591-1.1 Code Category: B ASME Class: 2 Function: Opens to provide startup feedwater supply to the steam gener-ators.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Cycling valves during power operation could induce unwanted transients in the steam generators. This would result in an increase in flow to the main feedwater nozzles causing vibrations in the preheater section of the steam generators.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION l1.7 l 6 0F 104 j
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McGuire Unit 2 J
Justification of Deferral Item Number: 2-MC-CF4 Valve: 2CF-104AB,2CF-105AB,2CF 106AB,2CF-107AB Flow Diagram: MC-2591 1.1 4
Code Category; B t'
ASME Class: ANSI B31.1.0 (1967)
Function: Provides tempering flow to the steam generators.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closing these valves during operation would result in a feedwater transient and could result in loss of Steam Generator level control, causing a Unit trip. These valves are normally open at power.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. ;
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Revised by Rev.17.
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10/16/95 SECTION 11.7 7 OF 104 I
I McGuire Unit 2 Justification of Deferral ,
i Item Number: 2-MC-CFS Valve: 2CF-152,2CF-154,2CF-156,2CF-158 Flow Diagram: MC-2591-1.1 i ,
Code Category: C ASME Class: 2 Function: Opens to allow tempering flow to the Steam Generator auxiliary feedwater nozzles. Closes to form pressure boundary for auxiliary feedwater.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: During normal operation, there is constant flow through theso ;
valves to keep the auxiliary feedwater nozzles tempered. Test-ing these valves would require supplying the Steam Generators with cold water and thus thermally shocking these nozzles.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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1 10/16/95 SECTION 11.7 8 OF 104 1
1 McGuire Unit 2 t
Justification of Deferral Item Number: 2-MC-CF6 h
Valve: 2CF-118,2CF-119,2CF-120,2CF-121 Flow Diagram: MC-2591-1.1 Code Category: C ASME Class: 2 Function: Opens to allow feedwater flow to the Steam Generators. '
Closes to form pressure boundary for maintaining Steam Generator inventory. The open function is not witbin the Scope l of OM-10.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
l Basis for Deferral: During normal operation, there is constant flow through these ;
valves. The required test is performed while the Steam l Generators are in wet-layup, with the main condensate system in service. The piping upstream of the check valve is depressurized, while the downstream side is pressurized. The j check valves are verified to prevent gross diversion of flow. !
These conditions cannot be obtained with the unit operating. J Test Alternative & Frequency: Valves will be full stroke exercised at cold shutdown.
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Revised by revision 16 10/16/95 SECTION l1.7 9 OF 104 1
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I-l McGuire Unit 2 l 0
Justification of Deferral ;
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I item P:Jmber: 2-MC-FW1 l Valve: 2FW-27A i Flow Diagram: MC-2571-1.0 Code Category: B ASME Class: 2 Function: Isolates low pressure injection from the Refueling Water Storage Tank. ,
1 Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closure of this valve during normal power operation would render all low pressure injection inoperable. This valve is opened and power removed above Mode 4 per Tech Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled anri timed during cold shutdown.
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McGuire Unit 2 Justification of Deferral 1
Item Number: 2-MC-FW2 i l
Valve: 2FW-28 i l
Flow Diagram: MC-2571-1.0 l Code Category: C ASME Class: 2 ,
l Function: Opens to allow low pressure injection flow. Closes to prevents reverse flow to the Refueling Water Storage Tank, thereby pre-venting pressurization of the tank.
l Test Requirement: Verify proper valve movement once per three months as re- i quired by OMa-1988 Part 10,4.3.2.1. l
)
Basis for Deferral: Valve cannot be full stroked during power operation since the only full flow path is into the RCS by the Residual Heat Removal pumps. These pumps cannot overcome RCS system pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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l 10/16/95 SECTION ll.7 110F 104 ;
McGuire Unit 2 i
s Justification of Deferral i
ltem Number: 2-MC-FW3 Valve: 2FW-74 Flow Diagram: MC-2571-1.0 Code Category: C 1
ASME Class: 3 Function: Must close to provide a pressure boundary for the assured makeup (Nuclear service Water) to the Spent Fuel Pool. ,
i Test Requirement: Verify proper valve movement once per three months as re- I quired by OMa 1988 Part 10,4.3.2.1.
Basis for Deferral: The system does not provide a means to verify valve closure.
Test Altemative & Frequency: Vaive wn be disassembled and inspected to verify closure at iefueling v:tage frequency, l
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. Revised by revision 16 1W1W95 SECTION l1.7 12 OF 104
Y McGuire Unit 2 Justification of Deferral P
ltem Number: 2-MC-IA1 Valve: 21A-5260, 2iA-5270, 2l A-5280, 2l A-5290, 21A-5300, 2iA-5310, 2] A-5320, 2iA-5330, 2lA-5340, 2lA-536.~1, 21A-5360, 21 A-5370, 1 21A-5380,2lA-5390 Flow Diagram: MC-2499-lA1 Code Category: A,C ASME Class: 2&3 Function: 2lA-5260,5270,5280,5290,5300,5310,5320 and 5330 prevent loss of air from receiver tank on each personnel airlock j door in the event of loss of instrument air supply to door seals.
These check valves form a pressure boundary for the inflatable seals.
21A-5340 and 5350 provide the inside containment isolation barrier in the event of a break on the flexible hose connection on the air supply to the door seals. The outside isolation valves are 21A-5080 and 5160. These check valves are on the auxiliary building side of the airlocks.
21A-5360,5370,5380 and 5390 provide double isolation on the reactor building side of the airlocks for the pressure relief line.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
- 3) Leak test in accordance with Technical Specification 4.6.1.3.d.
Basis for Deferral: These valves cannot be practically tested during operation due to the design of the system.
l Test Alternative & Frequency: Valves will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at a six month frequency per Tech Spec 4.6.1.3.d.
10/16/95 SECTION 11.7 13 OF 104
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McGuire Unit 2 Justification of Deferral item Number: 2-MC-KC1 Valve: 2KC-4248, 2KC-425A Flow Diagram: MC-2573-3.1 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-320.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of either of these valves in the closed position during testing would inhibit the normal flow path from the reactor coolant pump motor coolers. This action could result in damage i to the NC pumps. Within 15 to 30 minutes, the NC Pumps would i be tripped on high bearing temperature, and an abnormal I shutdown (natural circulation) would be required.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. ,
l OcWed by Rev.17.
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10/16/95 SECTION 11.7 14 OF 104 l
McGuire Unit 2 l
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Justification of Deferral j l
I Item Number: 2-MC-KC2 Valve: 2KC-338B Flow Diagram: MC-2573-3.1 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-327.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of this valve in the closed position could result in damage to the NC pumps. Within 15 to 30 minutes, the NC Pumps would bo tripped on high bearing temperature, and an abnormal shutdown (natural circulation) would be required.
l Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. !
l Revised by Rev.17.
10/16/95 SECTION 11.7 15 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-KC3 Valve: 2KC-332B, 2KC-333A Flow Diagram: MC-2673-3.1 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-355.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of one of these valves in the closed position during testing would inhibit flow through the reactor coolant drain tank heat exchanger. No alternate flowpath for cooling water to the l heat exchanger exists. Without flow to the heat exchanger, the drain tank would become over pressurized and steam would be released. Such a test would not be conservative, since Reactor Coolant would be released. This test would challenge the overpressure protection of a Reactor Coolant System cornponent. It is concluded therefore that per NUREG-1482 Section 3.1.1 that these valves should be excluded from quarterly testing.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev.17.
10/18/95 SECTION 11.7 16 OF 104
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McGuire Unit 2 dpstification of I eferral .
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ltem Number: 2-MC-KC4 l Valve: 2KC-320A Flow Diagram: MC-2573-3.1 Code Category: A ASME Class: 2 Function: Provide containment isolation for penetration M-376.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
i Basis for Deferral: Failure of this valve in the closed position during testing would inhibit flow through the reactor coolant drain tank heat ex-changer. No alternate flowpath for cooling water to the heat exchanger exists. Without flow to the heat exchanger, the drain tank would become over pressurized and steam would be re-leased. Such a release of Reactor Coolant makes this test nonconservative and would challenge the overpressure ;
protection of a Reactor Coolant System component, it is l concluded therefore that per NUREG-1482 Section 3.1.1 that I this valve should be excluded from quarterly testing.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev.17.
10/16/95 SECTION l1.7 17 OF 104
e l McGuire Unit 2 l 1
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Justification of Deferral l
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Item Number: 2-MC-KC5 i i
Valve: 2KC-280 l l
Flow Diagram: MC-2573-3.1 l
Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 2KC-3328 and 2KC-333A on pene-tration M-355.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: This valve cannot be practically tested during operation due to the design of the system. Testing during power operation is impractical for this vdve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency. j 1
Revised by Rev.17, 10/16/95 SECTION l1.7 18 OF 104
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Justification of Deferral '
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l Item Number: 2-MC-KC6 Valve: 2KC-322 Flow Diagram: MC-2573-3.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-376.
. Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: This valve cannot be practically tested during operation due to the design of the system. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
l Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
10/16/95 SECTION l1.7 19 OF 104
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McGuire Unit 2 ;
I Justification of Def9Eal l
Item Number: 2-MC-KC7 Valve: 2KC-279 Flow Diagram: MC-2573-3.1 .,
Code Category: A,C i
ASME Class: 2 '
Function: Provides containment isolation and thermal over pressurization protection of line between 2KC-424B and 2KC-425A on pene-tration M-320.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is '
impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17. !
10/16/95 SECTION l1.7 20 OF 104
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I l 1 Justification of Deferral i
I Item Number: 2-MC-KC8 Valve: 2KC-340 Flow Diagram: MC-2573-3.1 j Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-327.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2. i Basis for Deferral: The system design does not provide a means of verifying valve i closure upcr flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
10/16/95 GECTION 11.7 '
21 OF 104
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l Justification of Deferraj ltem Number: 2-MC-KC9 Valve: 2KC-47 Flow Diagram: MC-2573-4.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-322.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
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- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2. l Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
10/16/95 SECTION ll.7 22 OF 104 '
McGuire Unit 2 Justification of Deferral j Item Number: 2-MC-NB1 Valve: 2NB-262 Flow Diagram: MC-2556-3.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-259.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
i Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
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! 10/16/95 SECTION 11.7 l 23 OF 104 l
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McGuire Unit 2 l
l Justificatio_r1 of Deferral l l i
l' Item Number: 2-MC-NB2 ,
Valve: 2NB-438 ,
l Flow Diagram: MC-2556-3.0 Code Category: C ASME Class: 3 Function: Must close to provide a pressure boundary to prevent possible radiological releases caused by backflow from the pressurized sources downstream to the Unit 2 Reactor Makeup Water Storage Tank upstream.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal.
l Test Alternative & Frequency: Valve will be disassembled and inspected to verify closure at refueling outage frequency.
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Revised by revision 10 10/16/95 SECTION 11.7 I
24 OF 104 l
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McGuire Unit 2 Justification of Deferral Item Number: 2-MC-NC1 j Valve: ' 2NC-32B, 2NC-34A, 2NC-36B Flow Diagram: MC-2553-2.0 Code Category: B l ASME Class: 1 Function: Reactor Coolant System PORV. Opens to relieve pressure for the primary system.
i Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
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- Basis for Deferral
- PORVs do not serve a safety function when unit is at operating l temperature and pressure. PORVs protect the Reactor Coolant l
System from over pressurization during LTOP conditions. ,
Test Altemative & Frequency: Stroke time testing will be performed at cold shutdown and in all >
cases prior to entering LTOP conditions in accordance with Ge-neric Letter 90-06. Testing will not be required more often than once per quarter as defined in OMa-1988 Part 10,4.2.1.1.
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a 10/16/95 SECTION 11.7 25 OF 104 j
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g J 4 J-4_ 4h 4 .JuaL.J443 .M EaaBd--44--b-4 --E-M- a J: . da sh
-s - - ---.- I A _ s 4M S. 4--ca.---
t McGuire Unit 2 :
3 Justification of Deferral item Number: 2-MC-NC2 Valve: 2NC-272AC, 2 NC-273AC, 2N C-2748, 2N C-275B Flow Diagram: MC-2553-2.1 Code Category: B ASME Class: 1 Function: Reactor vessel head vent.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. .
i Basis for Deferral: Opening these valves at full pressure could cause damage to the l valve seating surfaces. A reactor coolant leak could be caused. l l
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 26 OF 104
_. . . _ _ _ _ = _ _ . _ . __ _ _ _ _ . . _ . . _ _ _ _ _ .
McGuire Unit 2 Justification of Deferral item Number: 2-MC-NC3 Valve: 2NC-259,2NC-261 Flow Diagram: MC-2553-4.0 Code Category: A,C ASME Class: 2 i
Function: Provides containment isolation and thermal over pressurization protection of line between 2NC-195B and 2NC-196A on pen-etration M-361, and line between 2NC-141 and 2NC-142 on penetration M-326 respectively.
Test Requirement: 1) Verify proper valve movement once per three months as !
required by OMa-1988 Part 10,4.3.2.1.
l
- 2) Leak test once per 2 years in accordance with OMa-1988 Part i 10,4.2.2.2. !
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, j possibly with high radiation levels. '
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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Revised by Rev.17.
10/16/95 SECTION 11.7 !
27 0F 104 1 i
McGuire Unit 2 Justification of Deferral item Number: 2-MC-NC4 j Valve: 2NC-59 Flow Diagram: MC-2553-2.1 !
l Code Category: C l ASME Class: 2 Function: Must open to allow various relief valves on ECCS systems to relive to the Pressurizer Relief Tank.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: The system design does not provide a sufficient means of verifying full opening of the check valve. ;
Test Alternative & Frequency: Valve will be disassembled and inspected to verify full stroke i opening at refueling outage frequency.
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Revised by revision 16 10/16/95 SECTION l1.7 28 OF 104
McGuire Unit 2 i
I dustification of Deferral !
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l Item Number: 2-MC-ND1 Valve: 2ND-1 B, 2ND-2AC
)
i Flow Diagram: MC-2561-1.0 Code Category: A ;
ASME Class: 1 Function: Provides suction for Residual Heat Removal pumps during normal cool down.
Test Requirement: 1) Stroke time test in accordance with OMa-1988 Part 10, 4.2.1.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
Basis for Deferral: These valves have an interlock which prevents their opening when the Reactor Coolant System pressure is greater than 385psig.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. Valve will be leak tested in accordance with Tech Spec 4.4.6.2.2. -
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l 10/16/95 SECTION 11.7 i 29 OF 104 l
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McGuire Unit 2 l
1 Justification of Deferral l
}
ltem Number: ' 2-MC-ND2 l
Valve: 2ND-58A Flow Diagram: MC-2561-1.0 ,
Code Category: B !
ASME Class: 2 Function: Provides suction to the Centrifugal Charging Pumps and Safety injection Pumps from the Residual Heat Removal system, i Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. ,
l Basis for Deferral: Opening 2ND-58A would seat check valve 2NV-223 (FWST to l Charging Pump suction) closed, so that if 2ND-58A failed in the !
open position, both trains of NV would be inoperable, ,
I Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
l Revised by Rev.17.
1 10/16/95 SECTION 11.7 !
30 OF 104
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McGuire Unit 2 Justification of Deferral j Item Number: 2-MC-ND3 Valve: 2ND-15B, 2ND-30A Flow Diagram: MC-2561-1.0 Code Category: B ASME Class: 2 Function: ND Heat Exchanger Outlet Crossover Block Valves.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: One of the ECCS safety analysis assumptions is that each train of ND can supply flow to all four cold legs. If either of these valves failed closed during testing then only two cold legs could be supplied by each train of ND. This would make both trains of ND inoperable.
Power cannot be removed from these valves, since at least one of them must be closed for cold leg recirc. If power was removed from one valve, a single failure on the opposite train would disable isolation of ND to the cold legs when needed (this isolation is needed for edequate cold leg recirc flow).
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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i Revised by Rev.17.
10/16/95 SECTION 11.7 31 OF 104 l
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McGuire Unit 2 Justification of Deferral item Number: 2-MC-ND4 Valve: 2ND-70 Flow Diagram: MC-2561-1.0 Code Category: C ASME Class: 2 Function: Opens to provides suction to the Centrifugal Charging Pumps and Safety injection Pumps from the Residual Heat Removal system. Closes to provide suction pressure boundary for the Centrifugal Charging Pumps and Safety injection Pumps
)
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full stroked during power operation since 2ND-58A would have to be opened, rendering both trains of ND inoperable. Additionally, the flow requirements to full stroke this valve cannot be achieved with the Reactor Coolant System pressurized.
Opening 2ND-58A would seat check valve 2NV-223 (FWST to Charging Pump suction) closed, so that if 2ND-58A failed in the open position, both trains of NV would be inoperable.
Manually closing 2ND-29, a fail-open valve, would be impractical. '
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
Revised by Rev.17.
10/16/95 SECTION l1.7 32 OF 104
- McGuire Unit 2
, Justification of Deferral 4 -
Item Number: 2-MC-ND5 Valve: 2ND-71 Flow Diagram: MC-2561-1.0 Code Category: C l ASME Class: 2 Function: Opens to provides suction to the Centrifugal Charging Pumps j and Safety injection Pumps from the Residual Heat Removal ;
system. Closes to provide suction pressure boundary for the !
Centrifugal Charging Pumps and Safety injection Pumps Test Requirement: Verify proper valve movement once per three months as re-
> quired by OMa-1988 Part 10,4.3.2.1.
i Basis for Deferral: Valve cannot be full stroked during power operation since 2NI-
- 136B would have to be opened, rendering both trains of ND 4
inoperable. Additionally, the flow requirements to full stroke this valve cannot be achieved with the Reactor Coolant System
!. pressurized.
- _ Opening 2ND-136B would seat check valve 2NV-223 (FWST to Charging Pump suction) closed, so that if 2ND-136B failed in the
- i. open position, both trains of NV would be inoperable.
i Manually closing 2ND-14, a fail-open valve, would be 1
", impractical, j
d Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
Revised by Rev.17, 4 10/16/95 SECTION 11.7 33 OF 104 4
. --. ._ - .- _ _- _ -- - . -. - - - . .. . . . _ _ - -- ._ ~
L l McGuire Unit 2 i
P t
Justification of Deferral '
l Item Number: 2-MC-ND6 Valve: 2ND-8,2ND-23 !
Flow Diagram: MC-2561-1.0 i
Code Category: C ASME Class: 2 Function: Residual Heat Removal pump discharge check valve.
Test Requirement: Verify proper valve movement once per three months es re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valves cannot be full stroke exercised during power operation since the only full flow path is into the Reactor Coolant System and the ND pumps cannot overcome RCS pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valves will be partially stroked quarterly. The opposite train valves will be tested closed quarterly except when the opposite train of ND is in service.
10/16/95 SECTION l1.7 34 OF 104 T
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l McGuire Unit 2 Justification of Deferral item Number: 2-MC-NF1 l
Valve: 2NF-229 1 l
Flow Diagram: MC-2558-4.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-373.
Test Requirement: 1) Verify proper valve movement once per three months as l required by OMa-1988 Part 10,4.3.2.1. l l
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.10CFR50 Appendix J requires measurement of local leak rate using air or nitrogen.
1 I
Basis for Deferral: The system design does not provide a means of verifying valve j closure upon flow reversal. Testing during power operation is i impractical for this valve since it is located inside containment, i as well as the test connection needed to test it. During cold j shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: 1) Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
- 2) Leak Rate testing of the valve will be performed per Tech Spec 4.6.1.2.d.4).
Revised by Rev.17.
10/16/95 SECTION 11.7 35 OF 104
McGuire Unit 2 Justification of Deferral Item Number: 2-MC-N11 Valve: 2Ni-9A,2NI-10B Flow Diagram: MC-2562-1.0 l'
Code Category: B ASME Class: 2 Function: Flowpath for Centrifugal Charging Pumps to Reactor Coolant i System Cold Legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
i Basis for Deferral: Opening either of these valves during operation would increase the charging flow into the Reactor Coolant System resulting in an increase of pressure and a rapid change in the primary system ,
boron concentration. This could create a transient and possible i unit shutdown. l Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 36 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-N12 l
Valve: 2NI-1008 Flow Diagram: MC-2562-3.0 Code Category: B ASME Class: 2 Function: Flowpath from ISe Refueling Water Storage Tank the Safety injection Pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. ,
l Basis for Deferral: Closing this valve during operation would render both trains of Safety injection inoperable. This valve is opened and power removed above Mode 4 per Tech Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 37 OF 104
. _ _ - . . - - - . . _ . ~ = - . -- .
i McGuire Unit 2 i
l Justification of Deferral l Item Number: 2-MC-N13 j Valve: 2NI-147A,2N1115B Flow Diagram: MC-2562-3.0 Code Category: B ASME Class: 2 Function: 2NI-147A provides flowpath for both trains of Safety injection recirculation line to the Refueling Water Storage Tank. 2NI-115B provides flowpath for A train of Safety injection re-circulation line to the Refueling Water Storage Tank.
Test Requirement: Stroke time test in accordance with OMa-1908 Part 10,4.2.1.1.
Basis for Deferral: Closing either of these valve during power operation renders both trains of Safety injection inoperable. 2NI-147A is open with power removed above Mode 4 per Tech Spec 4.5.2.
In the event of a loss of oilsite power with the loss of 28 diesel 6 ginerator as 2.e single failure,2NI-115B would not open, renderine A Train N1 inoperable (due to loss of miniflow path). B Train NI wwld already be inoperable due to the single failure.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev.17.
L 10/16/95 SECTION ll.7 38 OF 104 1
. . _ _ _ _ _ . ~ . . _ . . . . _ . . . - _.. . . . . _ . _ _ _.
l McGuire Unit 2 i
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Justification of Deferral Item Number: 2-MC-NI4 Valve: 2NI-121 A,2NI-152B Flow Diagram: MC-2562-3.0 ;
Code Category: B [
ASME Class: 2 Function: Isolates Safety injection flow to the hot legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves are closed with power removed above Mode 4 per Tech Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION ll.7 39 OF 104
r McGuire Unit 2 i
Justification of Deferral !
item Number: 2-MC-N15 ,
Valve: 2NI-162A Flow Diagram: MC-2562-3.1 Code Category: B ASME Class: 2 Function: Isolates Safety injection flow to the cold legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: This valve is opened and power removed above Mode 4 per ,
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION l1.7 40 OF 104 l
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I McGuire Unit 2 4
r Justification of Deferral item Number: 2-MC-NI6 Valve: 2NI-103A Flow Diagram: MC-2562-3.0 !
Code Category: B '
ASME Class: 2 Function: Provides A Train Safety injection Pump suction flow from the Refueling Water Storage Tank. Also provides a flowpath for B Train Residual Heat Removal pump discharge to B Train Chemical and Volume Control pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 'l0,4.2.1.1.
Basis for Deferral: Closing this valve during power operations degrades both trains of Chemical and Volume Control. In the event of a loss of offsite power with the loss of 2A diesel generator as the sing,e failure !
when the valve was closed, B Train NV would be lost .or
- sumprecirc mode. Since that could happen as fast 3s 30 minutes and would then be inaccessible due to dose rates, credit could not be taken for manually opening 2NI-103A in this event.
A Train NV would already be inoperable due to the single failure.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown, l
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10/16/95 SECTlONll.7 41 OF 104 l I
i McGuire Unit 2 Justification of Deferral Item Number: 2-MC-N17 Valve: 2NI-173A,2NI-178B Flow Diagram: MC-2562-3.1 Code Category: B ASME Class: 2 Function: Provides flowpath for Residual Heat Removal to the cold legs.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. !
Basis for Deferral: These valves are opened and power removed above Mode 4 per Tech Spec 4.5.2.
l Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. I l
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10/16/95 SECTION 11.7 42 0F 104 i
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McGuire Unit 2 1
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Justification of Deferral l l
1 I
lte 0 Number: 2-MC-NI8 l l
Valve: 2NI-334B Flow Diagram: MC-2562-3.0 Code Category: B ASME Class: 2 Function: Provides flowpath from B Train of Residual Heat Removal to B Train of Chemical and Volume Control, and from A Train of Residual Heat Removal to A Train of Safety injection.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Closing this valve during power operation degrades both trains of Safety injection. With the single failure of 2B diesel generator, Train A of Safety injection, which is provided suction from Residual Heat Removal via 2NI-334B or 2NI-136B, would be ,
inoperable (since 2NI-136B is normally closed). Train B of 1 Safety injection would already be inoperable due to the single l failure.
Test A!!ernative & Frequency: Valve will be cycled and timed during cold shutdown.
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Revised by Rev.17.
10/16/95 SECTION 11.7 ;
43 OF 104
McGuire Unit 2 i I
i h
Justification of Deferral ;
Item Number: 2-MC-N19 l l
Valve: 2NI-183B -
Flow Diagram: MC-2562-3.1 Code Category: B !
ASME Class: 2 l i,
Function: Isolates Residu?l Heat Removal flow to the hot legs. i Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. l t
Basis for Deferral: This valve is closed and power removed above Mode 4 per Tech i Spec 4.5.2.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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l 10/1995 SECTION 11.7 44 OF 104 1
. .- _. _ . _ _ -. . . _ . _ . _ _ . _ _ _ . . _ . _ ..__ -_ __ _ _ . _ _-._.m.
I McGuire Unit 2 i i
Justification of Deferral l
item Number: 2-MC-N110 Valve: 2NI-184B,2NI-185A Flow Diagram: MC-2562-3.0 Code Category: B ASME Class: 2 Function: Provides flowpath from the Containment Sump to the Residual Heat Removal Pump and the Containment Spray Pump suction.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening these valves during power operation would allow water to enter lower containment. To prevent this,1FW-27A would have to be closed, rendering both trains of Residual Heat Removal inoperable. Voids in suction piping would be created requiring fill and vent operations to prevent ECCS pump dam-age.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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10/16/95 SECTION 11.7 45 0F 104 l
l McGuire Unit 2 Justification of Deferral 1
4 ltem Number: 2-MC-N111 Valve: 2NI-332A,2NI-333B Flow Diagram: MC-2562-3.0 Code Category: B ASME Class: 2 Function: Provides flowpath to Centrifugal Charging Pumps and Safety injection Pumps from Residual Heat Removal Pumps during recirculation phase.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Opening these valves during power operations requires 2NI-334B to be closed to prevent aligning FWST to the suction of the Centrifugal Charging Pumps. Injecting FWST boron con-centrated water into the Reactor Coolant System would induce a transient. Closing 2NI-334B degrades both trains of Safety injection (With the single failure of 2B diesel generator, Train A of Safety injection, which is provided suction from Residual Heat Removal via 2NI-334B or 2NI-136B, would be inoperable (since 2NI-136B is normally closed). Train B of Safety injection would l already be inoperable due to the single failure).
]
l Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
I Revised by Rev.17. j 10/16/95 SECTION 11.7 46 OF 104 ;
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McGuire Unit 2 Justification of Deferral item Number: ' 2-MC-N112 Valve: 2NI-15, 2NI-17, 2NI-19, 2NI-21, 2NI-347,2NI-348, 2NI-349, 2NI-354 Flow Diagram: MC-2562-1.0 Code Category: C ASME Class: 1 Function: Opens to allow flow to the cold legs from the Centrifugal Charging Pumps.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Injecting flow through these valves from the Centrifugal Charging Pumps during power operations could result in unnecessary thermal shock to the injection nozzles.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
10/16/95 SECTION 11.7 47 OF 104
4 McGuire Unit 2 i Justification of Deferral 1
item Number: 2-MC-N113 ,
t Valve: 2NI-12 Flow Diagram: MC-2562-1.0 Code Category: C !
ASME Class: 2 i
Function: Flowpath for Centrifugal Charging Pumps to Reactor Coolant i System cold legs.
Test Requirement: Verify proper valve movement once per three months as re- !
quired by OMa-1988 Part 10,4.3.2.1.
' Basis for Deferral: Injecting flow through this valve from the Centrifugal Charging Pumps during power operations could result in unnecessary thermal shock to the injection nozzles.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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i 10/16/95 SECTION 11.7 l 48 OF 104 j
1 McGuire Unit 2 Justification of Deferral l l
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l Item Number: 2-MC-N114 Valve: -
2NI-101 Flow Diagram: MC-2562-3.0 Code Category: C ASME Class: 2 Function: Opens to allow flow from the Refueling Water Storage Tank to the Safety injection Pumps. Closes to provide suction pressure boundary for these pumps from the Residual Heat Removal l Pump discharge.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full stroke tested during power operation since the Safety injection Pumps cannot overcome Reactor Coolant J System pressure. Closure cannot be verified quarterly since both trains of Residual Heat Removal would be rendered inoperable.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valve will I I
be partial stroked quarterly.
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l 10/16/95 SECTION 11.7 49 OF 104
McGuire Unit 2 ,
h Justification of Deferral i
I item Number: 2-MC-N115 Valve: 2NI-116,2NI-148 Flow Diagram: MC-2562-3.0 Code Category: C ASME Class: 1 Function: Pump discharge check valve, opens to aliow Safety injection Flow. Closes to prevent opposite train fios losses.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full or partial stroke tested during power oper-ation since the Safety injection Pumps cannot overcome Reactor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Valve will be verified closed quarterly.
10/16/95 SECTION 11.7 50 OF 104
e-- 4--.- w -,Ar .e--.- a=,@* ,iIm am <cea 4 4A.-- Em-4Aa-e- t 4fl a musCem 4---- S- A-C A4 +am -- 4 l
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McGuire Unit 2 i 1
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i Justification of Deferral '
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Item Number: 2-MC-N116 i Valve: 2N I-124, 2N I-128, 2NI-156, 2N1-157, 2N I-159, 2N I-160 Flow Diagram: MC-2562-3.0 Code Category: AC l
l ASME Class: 2 l Function: 1) Opens on flow from tne Safety injection Pumps to the hot !
legs. I
- 2) Reactor Coolant System pressure boundary. l l
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1,
- 2) Leak test once per two years in accordance with OMa-1988 Part 10,4.2.2.3.
Basis for Deferral: Valves cannot be full or partial stroke tested during power op-eration since the Safety injection Pumps cannot overcome Re-actor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at ccid shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
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10/16/95 SECTION 11.7 51 OF 104
McGuire Unit 2
. Justification of Deferral item Number: 2-MC-N117 Valve: 2NI-165, 2NI-167, 2NI-169, 2NI-171 ,
Flow Diagram: MC-2562-3.1 Code Category: AC ASME Class: 1 Function: 1) Opens on flow from the Safety injection Pumps to the cold legs.
- 2) Reactor Coolant System pressure boundary.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
Basis for Deferral: Valves cannot be full or partial stroke tested during power op-erations since the Safety Injection Pumps cannot overcome Reactor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 52 OF 104 l
McGuire Unit 2 Justification of Deferral item Number: 2-MC-N118 Valve: 2NI-175,2NI-176, 2NI-180, 2NI-181 Flow Diagram: MC-2562-3.1 Code Category: AC ASME Class: 1 Function: 1) Opens on flow from the Residual Heat Removal Pumps to the cold legs.
- 2) Reactor Coolant System pressure boundary.
Test Requirement: 1) Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per two years in accordance with OMa-1988 Part 10,4.2.2.3.
Bas ls for Deferral: Valves cannot be full or partial stroke tested during power op-eration since the Residual Heat Removal pumps cannot over-come Reactor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 53 OF 104 l
4 McGuire Unit 2 Justification of Deferral t
l Item Number: 2-MC-N119 Valve: 2NI-125, 2NI-126, 2NI-129, 2NI-134 j
Flow Diagram: MC-2562-3.0 Code Category: AC ASME Class: 1 Function: 1) Opens on flow from the Residual Heat Removal Pumps to the hot legs.
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- 2) Reactor Coolant System pressure boundary.
Test Requirement: 1) Vetify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per two years in accordance with OMa-1988 Part 10, 4.2.2.3.
Basis for Deferral: Valves cannot be full or partial stroke tested during power op- 1 eration since the Residual Heat Removal pumps cannot over-come Reactor Coolant System pressure.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown. Leak test in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 54 OF 104
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McGuire Unit 2
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l Justification of Deferral ,
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t item Number: 2-MC-N120 Valve: 2NI-136B Flow Diagram: MC-2562-3.0 l Code Category: B ASME Class: 2 Function: Provides suction to the Centrifugal Charging Pumps and Safety !
Injection Pumps from the Residual Heat Removal System.
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Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. l l
Basis for Deferral: Opening 2NI-136B would seat check valve 2NV-223 (FWST to i Charging Pump suction) closed, so that if 2NI-136B failed in the open position, both trains of NV would be inoperable.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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1 Revised by Rev.17. l l
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10/16/95 SECTION 11.7 55 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-N121 Valve: 2NI-48 Flow Diagram: MC-2562-2.0 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-330.
Test Requirement: 1) Verify proper valve movement once per three monthe as required by OMa-1988 Part 10,4.3.2.1.
I
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal.
l Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor- !
dance with 10CFR50 Appendix J at refueling outage frequency.
B 10/16/95 SECTION 11.7 56 OF 104
l McGuire Unit 2 i
I Justification of Deferral l
l Item Number: 2-MC-N!22 1 Valve: 2NI-59,2NI-70, 2NI-81, 2NI-93 Flow Diagram: MC-2562-2.0, MC-2562-2.1 Code Category: A,C ASME Class: 1 Function: Opens on flow from the Ni cold leg accumulator to the Reactor !
Coolant System. Reactor Coolant Boundary valve.
)
Test Requirement: 1) Verify proper valve movement once per three months as l required by OMa-1988 'Part 10,4.3.2.1.
1
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
- 3) Leak test in accordance with Tech Spec 4.4.6.2.2.
l Basis for Deferral: Valves cannot be full or partial stroked during power operation since the accumulator pressure is -600 psig and cannot over-come RCS pressure. Valves will not be tested during cold shutdown since disassembly is required. Disassembly would render one train of RHR inoperable for an extended period of time.
Test Alternative & Frequency: Valves will be full stroked at refueling by disassembly on a sample basis. All valves will be partial stroked at refueling.
Partial stroke will not be performed at cold shutdown since Tech !
l Spec 4.4.6.2.2 requires leak testing after initiating flow through I these valves and does not require leak testing more often than once per nine months. Valves will be verified closed by leak test j
performed in accordance with Tech Spec 4.4.6.2.2.
l 10/16/95 SECTION l1.7 57 OF 104 l
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McGuire Unit 2 Justification of Deferral item Number: 2-MC-N123 Valve: 2NI-436 Flow Diagram: MC-2562-2.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection for penetration M-321.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve ,
closure upon flow reversal. Testing during power operation is )
impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency. ;
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l Revised by Rev.17.
10/16/95 SECTION l1.7 58 OF 104 i
1 1
McGuire Unit 2 Justification of Deferral l 1
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1 Item Number: 2-MC-N124 Valve: 2NI-60,2NI-71, 2NI-82, 2NI-94 Flow Diagram: MC-2562-2.0, MC-2562-2.1 )
j Code Cattegory: A,C ASME Class: 1 Function: Opens on flow from the Ni cold leg accumulator to the Reactor I Coolant System. Reactor Coolant Boundary valve.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3.
- 3) Leak test in accordance with Tech Spec 4.4.6.2.2.
Basis for Deferral: Valves cannot be full or partial stroked during power operation since a driving head which can overcome RCS pressure does not exist. Instrumentation is not present to measure the flow through the individual valves. Valves will not be tested during cold shutdown since disassembly is required. Disassembly would render one train of RHR inoperable for an extended period l of time. i l
Test Alternative & Frequency: Valves will be full stroked at refueling by disassembly on a )
sample basis. All valves will be partial stroked at refueling.
Partial stroke will not be performed at cold shutdown since Tech Spec 4.4.6.2.2 requires leak testing after initiating flow through these valves and does not require leak testing more often than once per nine months. Valves will be verified closed by leak test performed in accordance with Tech Spec 4.4.6.2.2.
10/16/95 SECTION 11.7 59 OF 104
I McGuire Unit 2 i
Justification of Deferral item Number: 2-MC-NM1 Valve: 2NM-420,2NM-421 [
Flow Diagram: MC-2572-1.0 Code Category: A,C ASME Class: 2 Function: ' 7vides containment isolation and thermal over pressurization
'* tection for penetrations M-235 and M-309 respectively.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-i dance with 10CFR50 Appendix J at refueling outage frequency.
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Revised by Rev.17. l 10/16/95 SECTION ll.7 l 60 OF 104
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l McGuire Unit 2 L
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Justification of Deferral i i
Item Number: 2-MC-NS1 .
Valve: 2NS-388,2NS-43A Flow Diagram: MC-2563-1.0 ;
Code Category: B ASME Class: 2 I I
Function: Auxiliary Spray Nozzle header isolation.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
I Basis for Deferral: Opening either of these valves during power operation renders both trains on Residual Heat Removalinoperable. With cross-connected trains of ND, flow would be diverted from both trains through a failed-open NS-38B or 43A. To isolated one train of ND, it would be necessary to manually secure closed either ND-14 or 25, since these valves fail open on loss of air. This would l be an impractical measure to perform the quarterly test.
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Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. I Revised by Rev.17. j 10/16/95 SECTION 11.7 610F 104 l 1
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McGuire Unit 2 Justification of Deferral n
-I Item Number: 2-MC-NS2
- Valve: 2N S-13, 2N S-16, 2N S-30, 2NS-53, 2N S-41, 2N S-46 Flow Diagram: MC-2563-1.0 Code Category: C ASME Class: 2 ,
Function: Open on flow from containment spray pumps. ,
i Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1. ,
Basis for Deferral: Full stroke exercising of these check valves is not practical since there is no extemal indication of disk movement. Full stroke -
exercising would require for the pumps and spray nozzles to be activated which would require a large scale cleanup effort.
Valves will not be tested during cold shutdown since sample disassembly is required.
Test Alternative & Frequency: These valves will be verified to fully cycle by sample disassem- !
bly at refueling outage frequencies.
Ngle: Relief is being requested on these valves. Refer to relief request 2-MC-RR-NS1. When relief is granted, this Justification Of Deferral will be deleted.
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10/16/95 SECTION 11.7 62 OF 104 l
McGuire Unit 2 ,
i Justification of Deferral 1
Item Number: 2-MC-NS3 Valve: 2NS-4, 2NS-21 Flow Diagram: MC-2563-1.0 Code Category: C ASME Class: 2 Function: Opens to allow flow from the Refueling Water Storage Tank to the Containment Spray Pump suction. Closes to prevent flow from the Containment Recirculation Sump to the Refueling Water Storage Tank.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Full stroke exercising with flow would require for the pumps and spray nozzles to be activated which would require a large scale ,
cleanup effort. The system design does not provide any :
indication for verifying closure upon flow reversal.
Test Alternative & Frequency: Full stroke testing will be achieved by sample disassembly. At least one of these valves will be disassembled during each refueling outage, and both valves will have been disassembled and full stroked after two consecutive outages. Sample disas-sembly will also verify closure. Failure of one of valve to prop-erly full stroke during a refueling outage will result in the re-maining valve being disassembled and full stroked during that outage. Valves will be partial stroked quarterly.
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l 10/16/95 SECTION l1.7 ;
63 OF 104
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l McGuire Unit 2 Justification of Deferral Item Number: 2-MC-NS4 Valve: 2NS-140, 2NS-141 Flow Diagram: MC-2563-1.0 Code Category: A,C ASME Class: 2 Function: Must cpen to allow Containment Spray to the spray ring head-ers. Must close to prevent column separation of water in the header after initial building spraydown and pump shutdown.
During this time, the column of water in the vertical piping up to the spray rings could separate, creating a void in the system at sub-atmospheric pressure. Upon pump restart, the collapse of this void would damage the piping system. i Test Requirement: 1) Verify proper valve movement once per three months as required by CMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.3. I I
Basis for Deferral: Full stroke exercising of these check valves is not practical since there is no externalindication of disk movement. Full stroke exercising would require for the pumps and spray nozzles to be activated which would require a large scale cleanup effort.
Valves will not be tested during cold shutdown since sample disassembly is required. j i
i Test Alternative & Frequency: Valves will be verified to full stroke open using sample disas- !
sembly every other refueling outage on a staggered basis.
Valves will be partial stroked quarterly. Valves will be leak ]
tested at refueling outages. Leak testing will also verify closure !
of these valves.
10/16/95 SECTION 11.7 64 OF 104 ;
McGuire Unit 2 A
Justification of Deferral Item Number: 2-MC-NV1 Valve: 2NV-94 AC, 2NV-95B Flow Diagram: MC-2554-1.1 Code Category: B ASME Class: 2 Function: 1) Provides flowpath for Reactor Coolant Pump seal water dis-charge line.
- 2) Provides containment isolation for penetration M-256 j Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
l Basis for Deferral: Closure of one of these valves during power operation would l inhibit normal seal water flow across the reactor coolant pump number 1 seal. This action could result in damage to the reactor coolant pump seals or the pump itself. Failure of this seal with NC flow out the seal would be a loss of NV system function, and is justification for deferral in accordance with NUREG-1482 Section 3.1.1.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
l Revised by Rev.17.
10/16/95 SECTlON 11.7 65 OF 104
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McGuire Unit 2 6
Justification of Deferral Item Number: 2-MC-NV2 Valve: 2NV-78 Flow Diagram: MC-2554-1.2 Code Category: B t
ASME Class: 2 Function: 1) Provides flowpath for normal letdown.
- 2) Provides containment isolation for penetration M-347.
l Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of this valve in a closed position would result in a significant event (letdown isolation), possibly resulting in loss of pressurizer level control, and possible Unit trip (not a normal shutdown).
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev.17.
10/16/95 SECTION 11.7 66 OF 104 i
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McGuire Unit 2 Justification of Deferral '
item Number: 2-MC-NV3 Valve: 2NV-21 A Flow Diagram: MC-2554-1.2 f
Code Category: B ASME Class: 1 Function: Provides isolation for Pressurizer Auxiliary spray.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. '
Basis for Deferral: Opening this valve during power operations could result in a re-actor low pressure trip.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION l1.7 67 OF 104
m ,
i McGuire Unit 2 1
Justification of Deferral item Number: 2-MC-NV4 Valve: 2NV-141 A, 2NV-142B '
Flow Diagram: MC-2554-2.0 Code Category: B ASME Class: 2 Function: Provides isolation for Volume Control Tank upon Safety injection Signal.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1, Basis for Deferral: Closure of one of these valves during power operation would isolate the suction for the Centrifugal Charging Pumps. This action could result in damage to the pumps. Seal water to the Reactor Coolant pumps would be interrupted causing damage to ,
the seals.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
l 10/16/95 SECTION 11.7 68 OF 104 I
l McGuire Unit 2 Justification of Deferral item Number: 2-MC-NV5 Valve: 2NV-244A,2NV-245B Flow Diagram: MC-2554-3.0 Code Category: B ASME Class: 2 i
Function: Isolates charging to the Reactor Coolant System upon Safety injection.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: If one of these valves were to fail in the closed position while i testing during power operation, normal and alternate charging would be lost. Totalloss of charging flow would be a significant j event, resulting in a possible loss of Pressurizer control, and a likely Unit trip (not a normal shutdown), as well as loss of NC i pump seal flow.
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Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
I Revised by Rev.17.
10/16/95 SECTION 11.7 69 OF 104 i
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McGuire Unit 2- l l
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Justification of Deferral l Item Number: 2-MC-NV6 -
Valve: 2NV-221 A,2NV-222B Flow Diagram: MC-2554-3.1 Code Category: B ASME Class: 2 Function: Flowpath for Refueling Water Storage Tank to the suction of the Centrifugal Charging Pumps.
Test Requirement: Stroke time test in accordance with OMa-1988 Par 110,4.2.1.1.
Basis for Deferral: Opening these valves during power operation allows the Charging Pumps to inject highly borated water into the Reactor coolant System which could result in a unit shutdown.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
10/16/95 SECTION 11.7 70 OF 104
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i McGuire Unit 2 Justification of Deferral l l
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Item Number: 2-MC-NV7 Valve: 2NV-264 Flove Diagram: MC-2554-3.1 Code Category: C ASME Class: 2 Function: Provides flowpath from the Boric Acid Tank to the Centrifugal Charging Pump suction. C:oses to provide pump suction pres-sure boundary.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: To full stroke exercise this valve during power operations would inject more than 30 gpm of boric acid into the Reactor Coolant System creating a transient. To verify closure, residual boric acid would be injected causing a transient.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
10/16/95 SECTION l1.7 71 OF 104 i.
1 McGuire Ur.it 2 i
Justification of Deferral j item Number: 2-MC-NV8 Valve: 2NV-1508,2NV-151 A Flow Diagram: MC-2554-2.0 Code Category: B ASME Class: 2 i
Function: Provides isolation for Centrifugal Charging Pump miniflow line to Volume Control Tank. '
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1. .
Basis for Deferral: if either valve were to fail closed while testing, the Charging Pump miniflow protection line is isolated possibly causing ,
damage to the pump. Closure of either of these valves would
, render both trains of NV inoperable, since on a spurious safety _
injection event (in which reactor coolant system pressure is increased above normal), this is a relief path back to the Volume Control Tank.
Test Altemative & Frequency: Valve will be cycled and tirned during cold shutdown.
Revised by Rev.17.
10/16/95 SECTION 11.7 72 OF 104
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l McGuire Unit 2 i
l V l Justification of Deferral I l
l item Number: 2-MC-NV9 Valve: 2NV-265B Flow Diagram: MC-2554-3.1 Code Category: B ASME Class: 2 Function: Isolates the Boric Acid Tank from the suction of the Charging .
Pumps.
Test Requirement: Stroke time test in accordance with OMa-1988 i' art 10,4.2.1.1, Basis for Deferral: If valve is opened during power operations, boric acid could be injected into the Reactor Coolant System causing a transient.
Test Alternative & Frequency: Valve will be cycled and timed dr:nng cold shutdown.
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l 10/16/95 SECTION l1.7 !
73 OF 104
I McGuire Unit 2 i
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Justification of Deferral I
Item Number: 2-MC-NV10 1 Valve: 2NV-225, 2NV-231 Flow Diagram: MC-2554-3.1 ,
l Code Category: C ASME Class: 3 Function: Pump discharge check valve Opens to provide flowpath for Centrifugal Charging Pump. Closes to prevent opposite train flow losses.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Valve cannot be full stroke exercised during power operation since this would require an increase in Reactor Coolant System boron concentration which could result in unit shutdown.
Normal letdown is not sufficient to verify full stroke, this must be done when aligned to the FWST for suction.
Test Alternative & Frequency: Valve will be full stroke exercised during cold shutdown, partial stroked with normal use.
l 10/16/95 SECTION l1.7 74 OF 104 I
McGuire Unit 2 Justification of Deferral item Number: 2-MC-NV11 Valve: 2NV-223 Flow Diagram: MC-2554-3.1 .
Code Category: C ASME Class: 2 Function: Provides open flowpath from the FWST. Provides closed pump suction pressure boundary when suction is from the Residual Heat Removal pumps. !
Test Requirement: Verify proper valve movement once per three months as f required by OMa-1988 Part 10,4.3.2.1. ;
Basis for Deferral: Testing this valve during power operations would require opening of either 2NV-221 A or 2NV-222B. Opening these !
valves during power operation could result in a unit trip. See ,
Justification # MC-NV6.
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
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10/16/95 SECTION 11.7 1 i
75 OF 104 I
McGuire Unit 2 Justification of Deferraj ,
i ltem Number: 2-MC-NV12 ,
Valve: 2NV-1046 Flow Diagram: MC-2554-3.0 Code Category: C ASME Class: 2 i i
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Function: Closes to provide pump suction prt ,ure boundary for Centrif-ugal Charging Pumps. Open function is to protect the Positive -
Displacement Pump from oer r,ressurization. This is not a safety relater function. '
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ,
Basis for Deferral: Testing this valve during power operation would result in the l addition of highly borated water into the Reactor Coolant System causing a transient. To place adequate test pressure on this ,
valve, it would be necessary to use ND Pump discharge l pressure, which would require opening 1ND-58A. This would inj9ct FWST water into the NC System via the Charging Pumps, i which are also on the discharge of the ND Pumps (for cold leg recirc) via 1 ND-58A.
Test Alternative & Frequenc/- Valve will be full stroke exercised at cold shutdown.
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I Revised by Rev.17. i l
10/16/95 SECTlON 11.7 l 76 0F 104 i l
1
4 McGuire Unit 2 .
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Justification of Deferral ,
l Item Number: 2-MC-NV13 Valve: 2NV-261,2NV-263 Flow Diagram: MC-2554-3.1 l Code Category: C l
ASME Class: 2 i Function: These valves shall close to provide pump suction pressure isolation for the Centrifugal Charging Pumps by preventing backflow to the Chemical Mixing Tank or the RMWST respec-tively.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. ]
I Basis for Deferral: Testing these valves requires 2NI-121 A to be opened. This I valve is closed with power removed above mode 4 per Tech Spec 4.5.2.
This testing would require opening valve 1ND-58A, which would render both trains of NV inoperable (by seating check valve 1NV-223 (charging pump suction from the FWST in-line check) closed).
Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
Revised by Rev.17.
i 10/16/95 SECTION ll.7 77 OF 104
McGuire Unit 2 ,
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Justification of Deferral i
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L ltem Number: 2-MC-NV14 i Valve: 2NV-1002 I Flow Diagram: MC-2554-1.3 1 i
i Code Category: A,C 1
ASME Class: 2 l l Function: Provides containment isolation on penetration M-342. i l Test Requirement: 1) Verify proper valve movement once per three months as j required by OMa-1988 Part 10,4.3.2.1.
- 2) Lezk test once per 2 years in accordance with OMa-1988 Part '
( 10, e.2.2.2.
l Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containme it, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-
- l. dance with 10CFR50 Appendix J at refueling outage fiequency.
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Revised by Rev.17.
e 4
10/16/95 SECTION 11.7 78 OF 104
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McGuire Unit 2 i
Justification of Deferral i
ltem Number: 2-MC-NV15 Valve: 2NV-143 Flow Diagram: MC-2554-2.0 Code Category: C ASME Class: 2 ,
Function: This valve shall close to provide Centrifugal Charging Pump suction pressure boundary during Recirculation alignment from RHR Pump discharge.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa- 188 Part 10,4.3.2.1.
Basis for Deferral: This valve is in the flowpath from the Volume Control Tank to the Charging pumps. During normal system operation, this valve is open. To verify this valve closes properly requires the alignment from the RHR pumps, and would interrupt normal charging j activities. !
l Test Alternative & Frequency: Valve will be full stroke exerci:,cd at cold shutdown. '
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l 10/16/95 SECTION 11.7 j 79 OF 104
i McGuire Unit 2 !
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1 1
l Justification of Deferral 1
item Number: 2-MC-NV16 )
Valve: 2NV-164 1
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Justification deleted by Revision 17. i 10/16/95 SECTION 11.7 80 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-NV17 Valve: 2NV-1007, 2NV-1008, 2NV-1009, 2NV-1010 Flow Diagram: MC-2554-1.3 Code Category: C ASME Class: 2 Function: These valves must close to maintain a pressure boundary for normal Reactor Coolant Pump Seal injection.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: In the event of failure of one of these valves during testing, the seal injection water for that Reactor Coolant Pump would be diverted, thereby creating a loss of seal injection to that pump.
This condition would result in destroying a seat for the pump, and possibly creating a small break loss of coolant accident.
Test Alternative & Frequency: These valves will be tested for closure during cold shutdowns.
Resived by revision 16 10/16/95 SECTION ll.7 81 OF 104
McGuire Unit 2 Justification of Deferral f
Item Number: 2-MC-NV18 ,
Valve: 2NV-1034 Flow Diagram: MC-2554-2.0 Code Category: C ASME Class: 3 Function: Must close to provide a pressure boundary to prevent possible radiological releases caused by backflow from the pressurized sources downstream to the Unit 1 Reactor Makeup Water j Storage Tank upstream.
Test Requirement: Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: The system design does not provide a means of verifying valve I closure upon flow reversal.
Test Alternative & Frequency: Valve will be disassembled and inspected to verify closure at refueling outage frequency.
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Revised by revision 16 10/16/95 SECTION ll.7 82 OF 104 j
McGuire Unit 2 t
Justification of Deferral item Number: 2-MC-NV19 Valve: 2NV-0035A,2NV-0457A, 2NV-0458A Flow Diagram: MCFD-2554-01.02 Code Category: B ASME Class: 2 Function: These valves must automatically close to isolate containment on a Phase A signal, and to isolate letdown on a Pressurizer Low Level signal. They can be operated from the Auxiliary Shutdwin Panel, and cannot be opened unless valves 2NV-1 A and 2NV-2A as both open.
Test Requirement: Stroke time test quarterly in accordance with Oma-1988 Part 10, 4.2.1.1. l l
Basis for Deferral: Letdown header relief valve 2NV-6 has experienced lifting and subsequent seat leakage as a result of pressure transients during
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orifice swaps for stroke time testing of the above valves. Although the NV operating procedure specifically addresses the potential pressure increase that could occur when swapping from the 45 gpm to the 75 gpm orifice, the increase can occur so quickly that the operator and system controls cannot respond fast enough to prevent the pressure transient. The NV operating procedure currently provides for simultaneous opening / closure of the above orifice isolation valves, and for backpressure reduction using the downstream control valve, to i prevent such a pressure transient; however, procedure effectiveness is problematic with respect to repeatablility due to the inability to achieve perfect coordination each time.
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!! is concluded that testing of these valv.es is impractical and l nonconservative during power operation, since it results in pressure transients which have caused relief valve leakage. This leakage is Reactor Coolant (NC) leakage, which is reflected in higher NC leakage values.
Finally, these valves have demonstrated a favorable test history.
Test Alternative & Frequency: . Valves will be stroke time tested during cold shutdown.
Added by Rev.17, 10/16/95 SECTION 11.7 83 OF 104
l McGuire Unit 2 l
Justification of Deferral l l
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Item Number: 2-MC-RF1 1
Valve: 1 RF-834 Flow Diagram: MC-1599-2.2 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-353.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1. j
- 2) Leak test once per 2 years in accordance with OMa-1988 Part j 10,4.2.2.2. '
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment,
. as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor- 1 dance with 10CFR50 Appendix J at refueling outage frequency. 1 l
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10/16/95 SECTION ll.7 84 OF 104 l l
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McGuire Unit 2 ;
T Justification of Defermi l Item Number: 2-MC-RN1 Valve: 2RN-252B,2RN-253A l
Flow Diagram: MC-2574-4.0 .
Code Category: A ASME Class: 2 !
Function: 1) Provides containment isolation for penetration M-307. '
- 2) Provides flowpath for cooling water to the Reactor Coolant Pump Motor Air Cooler Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: If one of these valves were to fail closed during testing, isolation of cooling water to the motor coolers could result in damage to the pumps. Closure of these valves would result in a Unit trip j from NC Pump motors being manually shut down due to high ,
stator temperatures (within minutes). An abnormal (natural l circulation) shutdown would be required.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown. l l
l Revised by Rev.17. i 10/16/95 SECTION 11.7 85 OF 104
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i Justification of Deferral l
item Number: 2-MC-RN2 l Valve: 2RN-276A,2RN-277B Flow Diagram: MC-2574-4.0 Code Category: A ASME Class: 2 l Function: 1) Provides containment isolation for penetration M-315.
- 2) Provides flowpath for cooling water to the Reactor Coolant !
Pump Motor Air Cooler.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: If one of these valves were to fail closed during testing, isolation of cooling water to the motor coolers could result in damage to the pumps. Closure of these valves would result in a Unit trip from NC Pump motors being manually shut down due to high stator temperatures (within minutes). An abnormal (natural circulation) shutdown would be required.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
Revised by Rev.17.
10/16/95 SECTION 11.7 86 OF 104
I McGuire Unit 2 1
4 Justification of Deferral Item Number: 2-MC-RN3 l Valve: 2RN-42A i 1
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Justification deleted by revision 16 10/16/95 SECTION 11.7 87 OF 104
1 McGuire Unit 2 Justification of Deferral item Number: 2-MC-RN4 Valve: 2RN-638, 2RN-64 A i
l Justification deleted by revision 16 10/16/95 SECTION 11.7 88 OF 104
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dustification of Deferral item Number: 2-MC-RN5 Valve: 2RN-113 Justification deleted by revision 16 l 10/16/95 SECTION l1.7 89 OF 104
McGuire Unit 2 Justification of Deferral I
Item Number: 2-MC-RN6 l
Valve: 2RN-891,2RN-892 i l
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Justification deleted by Revision 17 10/16/95 SECTION 11.7 90 OF 104
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McGuire Unit 2 Justification of Deferral item Number: 2-MC-RV1 Valve: 2RV-32A,2RV-33B,2RV-76A,2RV-77G Flow Diagram: MC-2604-3.0 Code Category: A ,
ASME Class: 2 I
Function: Provide containment isolation for penetration M-240 and M-279 respectively.
Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: Failure of one of these valves in the closed position during i testing would isolate cooling flow to the Lower Containment Ventilation Units causing an increase in lower containment temperature which could exceed Tech Spec limits. Although the exact time depends on outside temperature, the Tech Spec limit would be exceeded within minutes if cooling flow was isolated to these ventilation units.
Test Alternative & Frequency: Valve will be cycled and timed during cold shutdown.
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1 10/16/95 SECTION l1.7 91 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-SA1 Valve: 2SA-5, 2SA-6 Flow Diagram: MC-2593-1.2 Code Category: C ASME Class: 2 Function: Opens to allow steam supply to the turbine driven Auxiliary Feedwater Pump. Closes to prevent cross connecting steam generators 1B and 1C.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: System configuration and design do not provide a suitable means to prove the valve prevents reversal of flow. To test the close function of this valve on line would risk personnel safety since high energy steam would be involved.
Test Alternative & Frequency: At least one of these two valves will be disassembled and full stroked during each refueling outage, and both valves will have been disassembled and full stroked after two consecutive out-ages. Sample disassembly will verify closure. Failure of one of valve to properly full stroke during a refueling outage will result in the remaining valve being disassembled and full stroked during that outage. Valves will be full stroked open quarterly.
10/16/95 SECTION l1.7 92 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-SM1 Valve: 2SM-1 AB, 2SM-3AB, 2SM-5AB, 2SM-7AB Flow Diagram: MC-2593-1.0, MC-2593-1.3 Code Category: B ASME Class: 2 Function: Main Steam Isolation Valves Test Requirement: Stroke time test in accordance with OMa-1988 Part 10,4.2.1.1.
Basis for Deferral: These valves cannot be fully cycled closed during power oper-ation since a unit shutdown would result.
Test Alternative & Frequency: These valves will be partially cycled closed while in Modes 1,2 and 3. These valves will be cycled and timed during cold shutdown.
i 10/16/95 SECTION ll.7 93 OF 104 l
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McGuire Unit 2 Justification of Deferral item Number: 2-MC-VB1 Valve: 2VB-50 Flow Diagram: MC-2605-3.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetration M-215.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1,
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
10/16/95 SECTION 11.7 94 OF 104
McGuire Unit 2 Justification of Deferral i
Item Number: 2-MC-VG1 Valve: 2VG-17,2VG-18,2VG-19,2VG-20 Flow Diagram: . MC-2609-4.0 Code Category: C i ASME Class: 3 I i
Function: Provides flowpath for Diesel Generator control air from individual starting air banks.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: Testing these valves requires the Diesel Generator to be started on a single bank of control air which is considered a degraded condition. This is not justified for quarterly starts. This test is required to be done on an 18 month frequency as committed to in our response to SOER 80-1.
l Test Alternative & Frequency: Valve will be full stroke exercised with the diesel generator start on a single bank of control air and performed at refueling outage frequency.
Note: A separate relief request has been submitted for these valves.
This relief request was submitted on August 24,1993 as Docket No. 50-370, Relief Request 92-01.
10/16/95 SECTION ll.7 95 OF 104
7 McGuire Unit 2 Justification of Deferral item Number: 2-MC-Vl1 Valve: 2VI-368,2VI-372, 2VI-373, 2VI-374 Flow Diagram: MC-2605-1.3 Code Category: C ASME Class: ANSI B31.1.0 (1967)
Function: 2VI-368 and 2VI-373 must open to allow nitrogen to the PORV actuator.
2VI-372,2VI-374 must close to prevent loss of Nitrogen pres-sure if instrument air is lost.
Test Requirement: Verify proper valve movement once per three months as re-quired by OMa-1988 Part 10,4.3.2.1.
Basis for Deferral: All four valves are tested with PORV stroke timing. PORVs are tested on a cold shutdown frequency. Refer to Justification # 2-MC-NC1 Test Alternative & Frequency: Valve will be full stroke exercised at cold shutdown.
s 10/16/95 SECTION ll.7 96 OF 104
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McGuire Unit 2 Justification of Deferral ,
Item Number: 2-MC-V12 Valve: 2VI-124,2VI-149 l 1
i Flow Diagram: MC-2605-1.2 l l
Code Category: A,C l
ASME Class: 2
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Function: Provides containment isolation on penetrations M-317 and M- ,
386 respectively. i Test Requirement: 1) Verify proper valve movement once per three months as I required by OMa-1988 Part 10,4.3.2.1. i I
- 2) Leak test once per 2 years in accordance with OMa-1988 Part '
10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold i shutdowns, this testing would involve work inside containment, j possibly with high radiation levels. '
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17, 10/16/95 SECTION 11.7 97 OF 104
McGuire Unit 2 Justification of Deferral item Number: 2-MC-Vl3 Valve: 2VI-40,2VI-161 Flow Diagram: MC-2605-1.3 Code Category: A,C ASME Class: 2 Function: Provides containment isolation on penetrations M-220 and M-359 respectively.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17, 10/16/95 SECTION ll.7 98 OF 104
V McGuire U' nit 2 i
Justification of Deferral i i
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ltem Number: 2-MC-Vl4 l Valve: 2VI-129B,2VI-150B,2VI-160B Flow Diagram: MC-2605-1.2: MC-2605-1.3 Code c ategory: A ;
t ASME .ss: 2 I i
Function: Provides containment isolation on penetrations M-220, M-317 and M-359 respectively.
Test Requirement: Siroke time test in accordance with OMa-1988 Part 10,4.2.1.1. !
Basis for Deferral: These valves isolate instrument air headers to the reactor j building. In the past, to perform stroke timing of these valves, the containment air compressor was started to maintain an un- +
I interrupted air supply to components inside containment. During the past refueling outage, the containment compressor was i deleted. Should these valves be closed during power operation, I components inside containment would experience a loss of j instrument air, resulting in unwanted transients. During cold shutdowns, personnel entry into containment may be made to manually align instrument air headers together, allowing these ,
valves to be tested. Since this is a manual alignment, it is not possible to enter containment to make this alignment for .
quarterly testing. 1 4
Test Alternative & Frequency: Valves will be cycled and timed during cold shutdown. Leak testing will be performed as per the requirements of 10CFR50, Appendix J.
I Revised by revision 16 ;
1W16/95 SECTION 11.7 ,
99 OF 104 4
l, 1 l McGuire Unit 2 I I;
i Justification of Deferral l
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, item Number- 2-MC-VS1 l
l Valve: 2VS-13 Flow Diagram: MC-2605-2.2 Code Category: A,C MME Class: 2 Function: Providee. containment isolation on penetration M-219.
l Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part j 10,4.2.2.2. i l
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation ic impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
i-l Test Afternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
l Revised by Rev.17.
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10/16/95 SECTION 11.7 100 OF 104 l
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item Number: 2-MC-VX1 Valve: 2VX-30 Flow Diagram: MC-2557-1 l
Code Category: A,C j ASME Class: 2 1
Function: Provides containment isolation on penetration M-325.
Test Requirement: 1) Verify proper valve movement once per three months as required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2. s Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, '
possibly with high radiation levels. ,
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
10/16/95 SECTION 11.7 101 OF 104
McGuire Unit 2 Justification of Deferra_1 Item Number: 2-MC-WL1 Valve: 2WL-24 Flow Diagram: MC-2565-1.1 Code Category: A,C ASME Class: 2 Function: Provides containment isolation and thermal over pressurization protection of line between 2WL-1B and 2WL-2A on penetration M-375.
Test Requirement: 1) Verify proper valve moveinent once per three rnonths as required by OMa-1988 Part 10,4.3.2.1. !
- 2) Leak test once per 2 years in accedance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, {
as well as the test connection needed to test it. During cold I shutdowns, this testing would involve work inside containment, j possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
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10/16/95 SECTION 11.7 102 OF 104
l McGuire Unit 2 f
Justification of Deferral ,
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ll Item Number: 2-MC-WL2 '
Valve: 2WL-385 ;
Flow Diagram: MC-2565-7.0 i Code Category: A,C ASME Class: 2 .
Function: Provides containment isolation and thermal over pressurization protection of line between 2WL-322B and 2WL-321 A on pen- ;
etration M-221.
Test Requirement: 1) Verity proper valve movement once per three months as required by OMa-1988 Part 10,4.32.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part 10,4.2.2.2.
Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, ,
as well as the test connection needed to test it. During cold shutdowns, this testing would involve work inside containment, possibly with high radiation levels.
Test Alternative & Frequency: Valve will be verified closed by leak test performed in accor-dance with 10CFR50 Appendix J at refueling outage frequency.
Revised by Rev.17.
10/16/95 SECTION 11.7 103 OF 104
L McGuire Unit 2 i
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I Justification of Deferral ,
f Item Number: 2-MC-YM1 i
Valve: 2YM-116 Flow Diagram: MC-2601-2.4 l
Code Category: A,C l t
ASME Class: 2 t
Function: Provides containment isolation on penetration M-337.
j Test Requirement: 1) Verify proper valve movement once per three months as i required by OMa-1988 Part 10,4.3.2.1.
- 2) Leak test once per 2 years in accordance with OMa-1988 Part .
10,4.2.2.2.
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Basis for Deferral: The system design does not provide a means of verifying valve closure upon flow reversal. Testing during power operation is impractical for this valve since it is located inside containment, as well as the test connection needed to test it. During cold l shutdowns, this testing would involve work inside containment, i possibly with high radiation levels.
Test Alternative & Frequency: Valve will be venfied closed by leak test performed in accor- ,
dance with 10CFR50 Appendix J at refueling outage frequency. >
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'. Revised by Rev.17.
10/16/95 SECTION l1.7 104 OF 104 9
i Supplemental Test Program I
The 10CFR50, Appendix B Program (Supplemental Test Program) includes components which have been determined to be important to safety and judged to be prudent to test, but which are not explicitly under the scope of ASME Codes and Standards. Changes to test methods, frequency and acceptance criteria, as well as additions to or deletions from the program do not require Justification of Deferrals, Relief Requests, or or other forms of NRC notification. However, such changes should be approved by the IST program administrator, and documented in the IST Correspondence File.
The following items are currently being planned for addition to this program: 1
- 1) Full-flow vibrations will be recorded during each refueling outage for the ND and NI Pumps (Reference Pump Relief Requests 1.4.4 and 1.4.5, Memorandum to IST Correspondence File dated September 18,1995).
- 2) Leak-rate testing of the Hydrogen Analyzer / Post Accident Gas Sample loops will be performed during each refueling outage (Reference PIP l-M95-1622).
- 3) During refueling outages 1(2)EOC10, gross leakage will be monitored past the ND to Auxiliary Spray boundary valves (Reference PIP O-M95-643).
- 4) A gross diversion leak test of 1(2)NV-164 (hydrogen inlet to the VCT) will be performed (frequency to be determined).
Added by Rev. 22 (Unit 1), Rev.17 (Unit 2).
10/16/95 Section 111 1 of I u ,