ML20101H638

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Forwards Rev 11 to Revised Inservice Testing Program for Cps
ML20101H638
Person / Time
Site: Clinton Constellation icon.png
Issue date: 06/25/1992
From: Spangenberg F
ILLINOIS POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101H643 List:
References
U0601997, U601997, NUDOCS 9206300077
Download: ML20101H638 (12)
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llhnois Power Company Cknton Powei Station P.O. Box 678 Chnton, IL 61727 Tel 217 93Sf881 ma v.601997 POMR L30- 92(06-25)LP 8E.100c June 25, 1992 Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555 Subjects Clinton Power Station Response to NRC Safety Evaluation of Ineervice Testina Procram Dear Sirt By NRC letter dated September 30, 1991, Illinois Power (IP) received the i results of the NRC's review of the Clinton Power Station (CPS) Inservice Testing (IST) Program for the initial 120-month inspection interval. The NRC's September 30, 1991 Safety Evaluation (SE) concluded that, with the l exception of those relief requests which were denied, the CPS IST Program is acceptable for implementation provided the items (" anomalies")

identified in the SE are addressed within eight months of receipt (i.e.,

June 25, 1992). Resolution of the items identified in the SE was the subject of a meeting between IP and NRC staff personnel at the NRC's White Flint offices on January 23 and 24, 1992. A meeting summary, including a list of attendees, was issued by NRC letter dated March 3, 1992. In addition, IP submitted a letter as a follow-up to that meeting which provided a summary of IP's proposed course of action to resolve the items identified in the SE (reference IP letter U-601949 dated April 3,-1992).

In that letter it was noted that IP would be submitting a final response to the SE items by June 25, 1992. Accordingly, this letter is'being submitted to provide IP's responses to the 21 items identified in the NRC's SE. IP's responses to these itt;m are baset on IP's April 3, 1989 letter and a subsequent conversation * ' the NRC staf f on June 9, 1992.

IP's responses to tt.o SL items, . well as related information and details, are provided in the attachments to this letter. Attachment 1 provides a i

brief summary of each SE iton (anomaly) and IP's associated response.

Attachment 2 provides revised appendices (Appendix III and Appendix V) to the CPS IST Program which reflect resolution of the itens identified in the SE.

It should be noted that in IP's April 3, 1992 letter, IP requested continued relief (beyond June 25, 1992 as specified by the SE) from a number of ASME Code requirements. As a number of these requirements 9206300077 DR 920625 h ADOCK 05000461 PDR Ik(

U-601997

..nvolve testing which is performed on a quarterly basis or performed following corrective maintenance, IP is requesting that the NRC continue to give appropriate review priority to these requesta.

Sincerely yours,

/-

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F. A. Sp ngenb g, III Manager, Licen ng and afety DAS/alh TBE3:DAS8 Attachments cca NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Reg.On III, USNRC Illinois Departmeat of Nuclear Safety W 6

Attachmsnt 1-

-to U-601997 Page 1 of'10 Backcround By letter dated September SC ,fl991, Illinois Power (IP) received the results of-the NRC's review of the Clinton Power Station-(CPS)_ Inservice Testing (IST) Program for the initial 120-month inspection. interval. As identified in the NRC's September 30, 1991 Safety Evaluation-(SE), the CPS IST Program is acceptable fer implementation (except for those relief j requests which were denied) provided the items (" anomalies") identified in -l the SE are addressed within eight months of receipt. IP's responses to j these items or anomalies are provided below and are based-on the results of meetings with the NRC staff on January 23 and 24, 1992 (as documented in i IP's letter dated April 3, 1992) and a suboequent telephone conference on June 9, 1992. 1 Anomalv No. 1 (SE Section 2.1.2.11 Anomaly No. I addresses Relief Request No. 3006 regarding general relief from the ASME Code-specified allowable ranges for pump flow rate and differential pressure for all pumps contained in the CPS IST Program. IP proposed to use allowable ranges which'have less restrictive upper limite than the Code for.these pump parameters. The SE stated that general relief' from the allowable range limit requirements of the Code should not be granted. As a result, Relief Request No. 3006 was denied. .

I As a result of further discussion with the NRC staff in January 1992, Relief Request No. 3006 was revised to address only the-four water-leg pumps 1E12-C003, IE21-COO 2, 1E22-C003, and lE51-C003. This~ revised relief request provides additional justification for alternate acceptance criteria for these four pumps based on historical pump performance. Revised Relief Request No. 3006 was submitted for NRC review in IP's April 3, 1992 letter and is ref? muted in Attachment 2. As this testing is performed on a quarterly basis, IP's April 3,'1992 letter also requested priority review of this revised relief request.

Anomalv No. 2 (SE Secti.on 2.3.1.11 Anomaly No. O addresses Relief Request No. 3002 regarding relief from the Code-specified allowable ranges for the diesel generator-fuel oil transfer pump flow rate and a proposed alternate method for calculating the pump

' flow rate. IP proposed to use allowable' pump flow rate ranges which are based on the design requirements of the associated diesel generator-system. . '

The SE concluded that the proposed allowable ranges are not acceptable because they can allow substantial pump degradation without requiring corrective action to be taken. Therefore,, relief _from the Code-specified allowable pump flow rate ranges was denied. With respect to the proposed' method for calculating the pump flow rate, the SE concluded that the proposed method is acceptable.if the accuracy and repeatability is adequate to monitor pump hydraulic condition and detect pump degradation. As a result, the proposed method for. calculating the pump flow rate was granted with provisions.

As stated in IP's April 3, 1992 letter, the pump flow rate can be calculated-with sufficient accuracy and repeatability to meet-the code-

  • requirements. In addition, Relief Request No. 3002 was revised to provide additional justification for the allowable pump _ flow rate ranges proposed

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Attachmsnt 1 to U-601997 Page 2 of 10 for these pumps. This additional justification is based on historical pump performance. Revised Relief Request No.-3002 was subeitted for NRC review in IP's April 3, 1992 letter and is reflected in Attachment 2.- As this-testing is performed on a quarterly basis, IP's April 3, 1992 letter also-acquested prierity review of this revised relief request.

Anomalv No. 3 (SE Section 3.1.2.1)

Anomaly No. 3 addresses Relief Request No. 1002 which proposed that t sting of safety-related pumps or valves not be required to be performed whet the redundant subsyetem is out of service for maintenance or repairs. This relief request would require testing to be performed on the component-within seven days after the out-of-service subsystem is returned to service. The SE concluded that IP did not adequately demonstrate the  ;

impracticality of complying with the Code-specified testing fraquencies i under these circumstances. Therefore, Relief Pequest No. 1002 was denied.

Relief Request No. 1002 was withdrawn by IP's April 3, 1992 letter. As a result, IP will c.-ply with the Code-specified testing frequencies.

Enomalv No. 4 (SE Section 3.1.3.11 Anomaly No. 4 addresses Relief Request No. 2011 regarding relief from the Code requirement to individually leak rate test certain containment-isolation valves. IP proposed to leak test these valves in-groups. The SE concluded that when individual leak rate testing is impractical because of the lack of necessary test taps-and/or isolation valves, testing in groups is acceptable provided that group leakage limits are conservatively .

i established such that excessive leakage through any individual valve'in the group can be detected and the appropriate corrective action taken. As a result, Relief Reques*. No. 2011 was granted with provisions with respect to individual leak rate testing of containment isolation valves.

IP's April 3, 1992 retter identified that IP would implement the provisions identified in the SE. However, an extension to the required implementation date was necessary (beyond June 25, 1992 as specified in the SE). As a result, IP requested that an extension of the required implementation date be granted until the next test of the applicable valve (s)-is performed after August 26, 1992.

As a result of experience with leak rate testing gained during the most recent refueling outage (RF-3)., IP now believes that testing containment isolation valves in groups can provide sufficient information to detect individual valve degradation. The basis for this determination was.

discussed with NRC staff personnel on June 9,3 1992. As a result of IP's experience gained during the most recent refueling outage and the-discussions with the NRC staff on June 9, 1992, IP is providing a new relief ~ request (Relief Request No. 2034). This new relief: request is contained in Attachment 2 and provides specific justification for IP's determination that group le akage limits can be specified such that.

individual valve degradat- is detected.

IP no longer plans to cet ., plant procedures to implement the provisions identified in the SE. As a result, and based on-the' justification provided in new Relief Request No. 2034, IP requests that an extension of the date

_ _ _ _ _ _ _. _ _ . _ , . _ _ . -.&.._.-._.,.. , _ _ . , . _ - _ , . . . , _ . . . _ . _ , _ .-_-,_,4,,..-u...,,.___

Attachmsnt 1 to U-601997 Page 3 of 10 for which the SE provisions are required to be implemented for Relief Request No. 2011 be granted until NRC review of new Relief Request No.

2034 is complete. IP now requests priority review of new Relief Request No. 2034.

Anomalv No. 5 (SE_Sectipn.3.1.4.11 Anomaly No. 5 addresses Relief Request No. 2021 regarding relief from the code requirement to perform post-maintenance testing of valves under certain circumstances. Specifically, IP proposed that post-maintenance testing of valves which cannot be tested during power operation be deferred

't the maintenance performed consists only of valve st,m packing i..djustments within limits specified by the valve's manufacturer. The SE concluded that, due to the sensitive nature of this maintenance work and the pocJibility of introducing common mode failures, relief could only be granted from the Code requirements it certain guidelines for valve stem packing adjustments are followed. As a result, Rellof Request No. 2021 was granted with provisions.

As a rosult >f the complexity involved in implementing the guidelines provided in the SE, Relief Pequest No. 2021 was withdrawn by IP's April 3,

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1992 letter. Therefore, IP will comply witt. the Code requirements for performing post-maintenance testing of valves following valve stem packing adjustments.

Anomalv No. 6 (SE Section 3.1.6.1)

Anomal; No. 6 addresses Relief Request No. 2027 regarding relief from the Code requirement to individually leak rate test drywell isolation valves.

IP proposed to leak test these valves together by perto. ming a drywell bypass leakage test (which is currently required by the. CPS Technical Specifications). The SE concluded that the proposed alternate testing does not provide sufficient information to assure that these valves are individually capable of performing their Category'A leak-tight closure' function. However, the SE also concluded that adequate time should be allowed to develop procedures to individually leak rate test these valves.

As a result,-interim relief was granted until June 25,-1992.

As identified in IP's April 3, 1992' letter, IP has reevaluated these Salves and determined that they are not category A cornonents.- The IST Program hoe been revised to reflect that the drywell lu lation valves are now either Category B or C components. -Since these valves are no longer Category A enmponents, individual valve "v.e4 rate testing is not required by the Code and this relief request is no longer necessary.. As a result, IP is now withdt, wing Relief R Jest No. 2027. The revised IST Program-included in Attachment 2 reflects that drywell isolation valves are now considered to be either Category B or C components.

hnoma.lv No. 7 iSE Section 3 Q M ),

Anomaly No. 7 addresses-Relief Request No. 2011 regarding leak rate testing of excess fles " heck valves as required by the Code. Il proposed to verify that leakage nst u these valves is not excessive by performing an Integrated Leakage Pste ; cit (ILRT) once every 40 mpnths. The SE concluded that the prop 0#4:; testing is acceptable since these valves are not designed to be l

J Attachment 1 to U-601997 Page 4 of 10 leaktight. However, IP should also demonstrate that each excess flow check valve actuates to restrict flow when subjected to the set differential i pressure. As a result, Relief Request No. 2011 was granted with provisions with respect to testing of excess flow check valves.

As stated in IP's April 3, 1992 letter, the IST Program and implementing ,

procedures currently verify that each excess flow check valve actuates to restrict flow when subjected to the set differential pressure. As a i result, no further actions are required for Relief Request No. 2011 with respect to testing of excess flow check valves.

Anomalv No. 8.(SE Section 3.1.8.11 ,

'I Anomaly No. 8 addresses Relief Request No. 2008 (hev. 2) regarding relief from the exercising frequency requirements of the Code for water-leg keep-fill eneck valves 1E12-F065A, D, C; IE21-F034; and 1E22-F006. IP proposed t to satisfy this requirement for these valves by disassembling and ,

inspecting them on a sampaing basis during each refueling outage. The SE concluded that IP had not adequately demonstrated the impracticality of performing the required exercise testing of these valves. However, the SE also concluded that adequate time should be allowed to develop procedures to perform the required exercise testing. As a result interim relief was granted until June 25, 1992 for these valves with an aa,',tional requirement to disassemble and inspect each of these valves (rather t.Jn a sample) during the interim relief period.

l As discussed in IP's April 3, 1992 letter, Relief Request No. 2008 has been revised (Rev. 3) based on the results of the meeting with the NRC staff in January 1992. IP now proposes to satisfy the exercise testing requirement for these valves by testing the in-series check valves as a single unit on a quarterly basis. IP's April 3, 1992 letter requested extension of the interim relief period ( f or Relief Request No. 20( 8, Rev. 2) until NRC review of revised Relief Request No. 2008 (Rev. 3) is complete. IP's April 3, 1992 letter also provided: justification for continuing the sample-based "

refueling outage testing (as described in Relief A$m.'est No. 2008, Rev. 2) for these water-leg keep-fill check valves.rsther than; requiring disassembly and inspection of all these valves each refueling outage until NRC review of revised Relief Request 2008 (Rev. 3)'is complete.

IP's April 3, 1992 letter noted that Relief Request No. 2008 (Rev. 2) also.

addressed exercise testing of reactor water cleanup system eneck valves 1G33-F051 and 1033-F052A, B. IP also proposed to satisfy the exercise testing requirement for these valvec by disassenJ ling' and inspecting ~ them on a sampling basis during each refueling outage. This portion of Relief Request No.-2008.(Rev. 2)-was granted with-provisions. Based on discussions with the NRC' staff in January 1992, IP also-revised the alternate exercise testing for these valves to_ consist of testing the in-

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series check valves as a single unit on a quarterly basis. The alternate testing =for.these. reactor water cleanup system check valves has been addressed separately in new Rel'ief Request No. 2033 for clarity. As Relief Request No. 2033 is-a new relief request,-IP's April 3, 1992 letter requested that the proposed extension of.the interim relief period for-Relief Request No. 2008-(Rev. 2) also apply to the reactor water cleanup system check valves until NRC. review of-new Relief Request No. 2033 is complete. Further, IP's April 3, 1992 letter provided justification:forf

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Attachmsnt 1 to U-601997 Page 5 of 10  ;

continuing the sample-based roius..rg outage testing (as described in Relief Request No. 2008, Rev, 2) for tnese reactor wa+er cleanup system check valves (rather than requiring disassoc51y and inspection of each of these valves each refueling outage) until NRC review of new Relief Request ,

I No. 2033 is complete.

Revised Relief Request No. 200B (Rev.3) and new Relief Request No. 2033 are-reflected in the revised IST Program contained in Attachment 2.

Anomalv No. 9 ISE Section 3.2.1.11 Anomaly No. 9 addresses Relief Request No. 2012 regarding relief from the exercising frequency and stroke time measurement requirements of the Code for the main steam automatic depressurization system (ADS) valves.. IP proposed to exercise these valves during refueling outages but not to measure their stroke time. Ine SE concluded that relief should be granted from the exercising frequency requirements; however, the alternate testing  !

method should provide information sufficient to monitor for ADS valve  ;

degradation. As a result, Relief Request No. 2012 was granted with provisions As discussed in IP's April 3, 1992 letter, this relief request has been revised to be consistent with NRC Cenoric Letter 89-04 Position 6 regarding rapid-acting valves. Based on discussions with the NRC staff in January 1992, considering these valves to be rapid-acting and assigning a maximum stroke-time limit of two seconde satisfies the concerns identified in the SE. Revised Relief Request No. 2012 was provided in IP's April 3, 1992 letter and is reflected in Attachment 2. As the revised relief request is consistent with NRC Ceneric Letter 89-04, no further NRC review of this relief request is required. However. as further ;antified in IP's April ,

3, 1992 letter, additional time is required to complete the procedure f changes necessary to implement the revised relief request. As a tesult, IP requested that the required implementation date for Relief Request No. 2012 be extended until performance of the next test of the applicable ADS valve (s) following August 26, 1992. The next scheduled performance of these tests will be during the fourth refueling outage which is currently scheduled to begin in October 1993.

Anomalv No. 10 (SE Section 3.2.2.1)

Anomaly No. 10 addresses Relief Request No. 2031 regarding relief from the safety / relief valve (SRV) test method requirementa of the code for the main steam SRVs. 1P proposed to replace at least eight of the 16 main steam SRVs each refueling outaga with SRVs that have been refurbished.. Further, '

IP requested that-testing of additional SRVs not be required, regardless of the results of testing the SRyo which are removed. The SE concluded that the proposed alternate testing is not conservative'and does not appear to

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be warranted. As a result, Relief Request No. 2031 was denied.

Relief Request No. 2031 was withdrawn by IP's Aprli 3,'1992 letter._ As a result, IP-will comply with the Code requiremento for main' steam SRV testing.

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Attachmsnt 1 to U-601997 Page 6 of 10 Anom41v No. 11 ISE Sections 3.4.1.1.. 3.5.1.1. and 3.6.1.11 Anomaly No. 11 addresses Relief Request No. 2014 regarding relief from the Code-required exercise test frequency for emergency core cooling system (ECCS) testable check valves IE12-F041A, B, C1 1E21-F006; and lE22-F005.

IP proposed to perform a partial-stroke exercise test of these valves during cold shutdowns and perform a full-stroke exercise test each refueling outage. The SE concluded that IP did not provide sufficient technical justification to support this relief request. As a result, Relief Request No. 2014 was denied.

As discussed in IP's April 3, 1992 letter, Relief Request No. 2014 has been revised to provide more technical justification for not performing a full-stroke exercise test of these valves during cold shutdown conditions. IP's:

April 3, 1992 letter provided revised Relief Request No. 2014 and requested its priority review. This revised relief request provides the additional I justification required to address this anomaly. Revised Relief Request No. l 2014 is reflected in the revised IST Program contained in Attachment 2.

Anomalv No. 12 (SE Section 3.3.1.21-Anomaly No. 12 addresses Relief Request No. 2029 regarding an alternate method for verifying closure of check valves in air accumuistor supply lines by performing a pressure drop test of the accumulator. The SE concluded that the proposed test method is acceptable provided acceptance criteria are identified in the IST Program and implementing procedures for these pressure drop tests. As a result, Relief Hequest No. 2029 was  ;

granted with proc sions.

As stated in IP's April 3, 1992 letter, the IST Program and implementing procedures currently provide acceptance criteria for these pressure drop tests. As a result, no further actions are required for Relief Request No.

2029.

Anomalv No. 13 ISE Section 3.4.1.3)

Anomaly No.-13-addresses.Lalief Request Wo. 2030 regarding relief from the exercising frequency requirements of the Code for-verifying closure of valves 1E12-F050A and F0508. IP proposed to exercise these valves;to.the closed position once every two years in conjunction with the code-required leak rate test. -The SE concluded that IP had not demonstrated the impracticality of exercising these valves to the closed position at the Code-specified frequency. As a result, Relief Request No. 2030 was denied for these valves.

Relief Request No. 2030 was withdrawn by IP's April 3, 1992 letter. .As a result, "P will comply with the Code requirements for testing these valves.

-Anomalv No. 14 (SE Section 3.4.2.11 Anomaly No. 14 addresses Relief Request No. 2007.regarding relief from the stroke' time measurement requirements of the Code for valve.1E12-F095. 'IP-proposed to exercise this valve quarterly, but not measure its full-stroke-time. The SE concluded that the proposed testing is not sufficient to monitor for degradation of this. valve. However,-the SE also concluded that

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Attachment 1 to U-601997 Page 7 of 10 adequate time should be allowed to develop adequate means to monitor for degradation of this valve. As a result, Relief Request No. 2007 was granted on an interim basis until June 25, 1992.

As identified in IP's April 3, 1992 letter, IP hao revised the IST Program to reflect that valve IE12-F095 does not have an active safety function.

Since this valve does not have an active safety function, stroke-time testing of this valve is not required by the Code and this relief request is no longer necessary. As a result, IP is now withdrawing Relief Request No. 2007. The revised IST Program providsd in Attachment 2 rsflects that valve IE12-F095 no longer has an active safety function.

Anomalv No. 15 (SE Section 3.7.1.11 Anomaly No. 15 addresses Relief Request No. 2020 regarding relief from the Code requirement to perform a full-stroke exercise test of testable check valve 1E51-F066. As stated in IP's April 3, 1992 letter, Relief Request No. 2020 was previously withdrawn. Withdrawal of this relief request was acknowledged by the NRC in the $E. -As a result, IP will comply with the full-stroke exercise testing requirements of the Code for this valve.

Anomalv No. 16 - ( SE Seat ion 3. 7.1. jill Anomaly No. 16 addresses Relief Request No. 2030 regarding relief from the exercising frequency requirements of the Code for closure of valve 1E51-F040. IP proposed to exercise this valve to the closed position once every two years in conjunction with the Code-required leak rate test. The SE concluded that IP had not demonstrated the impracticality of exercising this valve to the closed position at the Code-specified frequency. As a result, Relief Request No. 2030 was denied for valve IE51-F040.

As discussed under IP's response to Anomaly No. 13, Relief Request No. 2030 was withdrawn by IP's April 3, 1992 letter. As a result, IP will comply with the Code requirements for testing thin valve.

Anomalv No. 17 (SE Section 3.8.1.21 Anomaly No. 17 addresses Relief Request No. 2030 regarding relief from the exercising frequency requirements of the Code for closure of valve 1C41-F006. IP proposed to exercise this valve to the closed position once-every.

two years in conjunction with the Code-required leak rate test. The SE concluded that IP should full-stroke' exercise this valve during cold shutdowns. However, the SE also concluded that adequate time should be allowed to develop procedures to verify closure of this valve during cold shutdowns. As a result, Relief Request No. 2030 was granted on an interim basis until June 25, 1992 for valve 1C41-F006.

As discussed under IP's responses to_ Anomaly Nos. 13 and'16, Relief Request No. 2030 was withdrawn by IP's April 3,_1992 letter._ As a result, IP will comply with the Code requirements for testing-valve IC41-F006.

Anomalv No. 18 (SE Section 3. 0.1.11-Anomaly No. 18 addresses Relief Request No. 2017 regarding_ relief'from the Code-required exercise test frequency for the reactor water cleanup system

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Attachmsnt I to Ua601997 Page 8 of 10 isolation valves. IP proposed to exercise these valven each refueling l wtagn. The SE concluded that IP had not demonstrated the impracticality )

of t r cising these valves at the Code-Jpecified frequency. As a result, Ra.T le f '1 guest No. 2017 was denied. l L

A&d %; qvguest No. 2017 was withdrawn by IP's Apri) 3, 1992 letter. IP  !

5;s etaply with the Code frequency requirements for testing these valves.

i Anomalv No. 19 (SE_Eggtion 3.12.1.11 ,

i Anomaly No. 19 addresses Relief Request No. 2026 regarding relief from the  ;

stroke-time measurement requirements of the Code for the diesel generator j air start valves. IP proposed to exercise these valves during diosol  !

generator tests and verify their proper operation by observing a decrease in the air receiver pressure. The SE concluded that IP had not provided acceptance criteria necessary to ensure that each of the redundant valves  !

is operating properly nor did the proposed test method provide a means to monitor for or deteet individual valve degradation. However,.the ,SE also'  !

concluded that adaquate time should be allowed to develvp a sceans of ,

monitoring for individual valve degradation. As a result, Relief Request No. 2026 was granted on an interim basis until June 25, 1992.

i As discussed in IP's April 3, 1992 letter, the diesel generator air start valves are not ASME Code Class 1, 2, or 3 components. As a result,-Relief Request No. 2026 was revised to indicate that it is ammoeiated with augmented testing requirements which are beyond the scope of 10CFR50.55a. ,

As testing of the diesel generator air start valves is outside the scope of ,

10CFR50.55a, no further NRC review of Relief Request No. 2026 is necessary.

Although not reyvired to be reviewed by the NRC, revised Relief Request No. .

2026 was provided for informational purposee in IP's April 3, 1992 letter and is reflected in the revised IST Program contained in Attachment 2. l Anomalv No. ?O ISE Section 3.9.3 11 .

5 Anomaly No. 20 addresses Relief Request No. 2024 regarding alternate testing for the control rod drive system hydraulic control unit (HCU) ,

valves. This anomaly notes that the justification provided in' Relief .

Request No. 2024 does not-specifically apply to the HCU No. 114 valves #

since they are Category C check valves which are not required to have their stroke times measured. This anomaly states that a'more specific technical justification should be provided for thece valves. Notwithstanding,-Relief  ;

Request No. 2024 was granted.

As discussed in IP's April 3, 1992 letter, the control 1 rod drive system-HCU valves are not ASME Code Class 1, 2,1or;3 components. As a resultp Relief Request No. 2024 was revised to indicated that it is associated with augmented testing requirements which are.beyond the-scope of 10CFR50.55a. '

As testing of the control rod drive system HCU valves is'outside the scope i of.10CTR50.55a, no'further NRC review of. Relief Request No. 2024 is necessary. -Although not required to be reviewed bylthe NRC, revised Relief Request No. 2024 was provided for informational purposes in.IP's April-3, 1992 letter and is reflected in the revised-_IST Program contained in .j Attachment-2.

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Attachm:nt 1 to U-601997 Page 9 of 10 Anomalv No. 21 ( S LQf_c t io n . 3 M,M Anomaly No. 21 addresses Relief Request No. 1001 regarding an allowable extension to the Codc-speelfied test intervals for all pumps and valves contained in the IST Program. IP proposed allowing an extension of up to 25% to the Code-specified test intervals. The SE noted that the test interval extension should not apply to safety and relief valves which are tested once every five years in accordance with the schedule established by Table IRV-3510-1. Notwithstanding, Relief Request No. 1001 was granted.

As identified in IP's April 3, 1992 letter, Relief Request No. 1001 was revised to apply only to those tests which are required on a quarterly or shorter testing frequency. As the scope of this revised rollef request is bounded by the scope approved in the SE, no further NRC review of revised Relief Request No. 1001 is required. Although not required to be reviewed by the NRC, revised Relief Request No. 1001 was included for informational purposes in IP's April 3, 1992 letter and is reflected in the revised IST l Program contained in Attachment 2. l FJLUna ry Based on the above discussion, a summary of the actions IP is requesting of the NRC in order to complete the review of the IST Program for CPS is provided below:

1. IP is requesting an extension to the required implementation date (beyond June 25, 1992) until the next test following August 26, 1992 for Relief Request No. 2012. (See Anomaly No. 9.) This extension is needed to allow sufficient time to complete procedure :hanges necessary to conform with NRC Generic Letter 89-04 per the revision to this relief request. This extension was previously requested in IP's April 3, 1992 letter.
2. IP is requesting an extension to the required implementation date (beyond June 25, 1992) for Relief Request No. 2011 until NRC review of new Relief Request No. 2034 is complete. (See Anomaly No. 4.) As described in Relief Request No. 2034 (see Attachment 2), IP believes that the current leak ate custing method for containment isolation valves (on a containment penetration basis rather than an individual valve basis) is sufficient tn ersure that individual valve degradation will be detected in sufficient time to implement appropriate corrective actions.
3. IP is requesting on extension to the interim relief period (boyond June 25, 1992) for Relief Request No. 2008 (Rev. 2) until NRC revikw of revised Relief Requent No, 2008 (Rev. 3) and r.ew Relief Request No. 2033 is complete. (See Anomaly No. 8.) IP believes that continued sampling-based refueling outage disassembly and inspection provides sufficient aneurance of valve operability until NRC review of these relief requests is complete. These extensions were previously agguested in IP's April 3, 1992 letter.

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Attachment 1 to U-601997  ;

Page lo-of 10 i

4. Priority review is belr.g requested for those relief requests which have bean revised as a result. ci furth.c discussion with the 14RC.

This request applies to revised Relief Request tios. 2008 (Rev. 3),  ;

2014 (Rev. 2), 3002 (Rev. 2), and 3006 (Rev. 1), and new Relief ,

Request tios. 2033 and 2034. These revised (and new) relief requests ,

are reflected in the revised IST Program contained in Attachment 2.

With the exception of new Relief Request tio. 2034, priority review of these relief requests was requested in IP's April 3, 1992 letter.

tio further action is being requested of the IJRC for Relief Request llos.

1001, 1002, 2007, 2017, 2020. 2021, 2024, 2026, 2027, 2029, 2030, 2031, and 2032. It ehould also be noted that Relief Request tJos. 2002, 2017, 2000, 2021, 2030, and 2031 were withdrawn by IP's April 3, 1992 letter an'. Relief Request tios. 2007 and 2027 are being withdrawn via this letter. liithdrawal of these relief requests is reflected in the revloed IST Program contained in Attachment 2.

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