ML20114B493

Forwards Issue 2 to Rev 7 to Beaver Valley Power Station Unit 1,Inservice Testing Program for Pump & Valves. Resolution of Provisional Relief Requests from Inservice Testing Program Discussed in Encl

ML20114B493
Person / Time
Site:	Beaver Valley
Issue date:	08/18/1992
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20114B496	List: ML20114B493 ML20114B508
References
NUDOCS 9208280275
Download: ML20114B493 (20)

Text

[ Be ver Valley Power Station Shippmgport, PA 15077-0004 (412) 393-5255 JOHN D SIEBER August 18, 1992 Vice President - Nuclear Group U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Updated Inservice Testing Program This submittal forwards:

1. The Duquesne Light Company (DLC) response to the Safety Evaluation Reports (SER) dated May 6, 1991 and January 24, 1992 which address the second ten-year in*erval Inservice Testing (IST) Prograia (Attachment 1).

2. Revision 7 of the IST Program (Attachment 3) and a list of changes representing revision 7 (Attacument 2).

3. Relief requests (Attachments 4 and T) which require NRC review prior -t o the Beaver Valley Power Station (BVPS)

Unit 1 ninth refueli ng outage (9R).

Response to SERs The relief requests which the Nuclear Regulatory Commission (NRC) granted per the SERs have been implemented. Other relief requests were also granted but contained provisions requiring resolution as detailed in the SER Technical Evaluation Report (TER) Appendix B. We have addressed the concerns and have either:

implemented those items tiirough procedure revisions, scheduled implementation during the ninth refueling outage (9R), which is scheduled to begin April 2, 1993, or revised the relief requests and have included them as Attachment 4, Unit 1 IST Program Proposed Revision IC.

Five other requests were granted on an interim basis for one year or the next refuelitig catage (9R), whichever is later. Th se were also ineDided in the SER-TER Appendix B. We have addressed each of thesc it 3 and have either se'eduled implementation during 9R or have intt.'ded them in Proposed Revision 1C. The resolution of each of the 1bove items is detailed in Attachment 1. One relief request was denied and it has been deleted from the IST Program.

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9208280275 DR 920818 ADOCK 05000334 .

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• Beaver Valley Power Station, Unit No. 1 Docket No.30-334, License No. DPR-66 Updated Inservice Testing Program Page 2.

SER Clarification Relief requests 5 and 6 requested relief from quarterly reverse flow testing and proposed a leak test at refueling outages as the alternate test. The TER states that an Appendix J, Type C leak rate test is performed. We wish to correct this since we do not perform a Type C leak rate test on these valves as the alternate test.

Technical Specification Amendment 65, March 22, 1983, approved use of a water leak test in place of Appendix J, Type C test requirements.

We consider this an acceptable test method and will continue testing in this manner.

IST Program, Rev. 7 Attachment 3 is Issue 2, Revision 7 to the BVPS Unit 1 IST Program. It is being submitted as required by Generic Letter No.

89-04, " Guidance on Developing Acceptable Inservice Testing Programs." Note that this revision incorporates Propored Revision 1A s which was approved in the SER for the Unit 1 IST Program second ten year interval by the NRC on May 6, 1991. Revision 7 incorporates the BVPS response to some of the issues addressed in the SER. None of the changes in Revision 7 requiro NRC approval prior to implementation. A list of changes made to the Unit 1 IST Program can be found in Attachment 2. The changes are either editorial in nature and are in compliance with the 1983 addition through summer 1983 addenda of the ASME XI Code or the positions delineated in Attachment 1 of Generic Letter No. 89-04, t

Included in his revision are the results from the NRC letter dated June 26, 1991, which approved the BVPS Unit 1 exemption request from the requirements of 10 CFR 50, Appendix A, General Design-Criteria (GDC) 57, as applied to the recirculation spray heat exchanger river water radiation monitor sample lines. In the enclosure to the letter, it is stated that the subject valves,

[1RW-615, -621, -626, and -633),-should be included in the Appendix J, Type C leak testing program. Prior to the receipt of this letter, the Unit 1 IST Program was revised to include chese valves as ASME-category B valves, which, by definition, do not equire a leak test.

When determining- the category for the above referenced valves, DLC evaluated. the recirculation spray heat exchanger river- water isolation valves, [MOV-1RW-105A, -105B,.-105C, and -105D], which are classified as ASME Category- B in the Unit 1 IST Program. The basis for this- -classification was -submitted to the NRC on February 19, 1988, following an on-site meeting with the NRC reviewers to discuss their Request for Additional Information, dated July 8, 1987. This-classification was accepted- by Lthe NRC per the'SER dated May 6, 1991. We consider the classification as. category'B for these river water- valves a consistant application of the- code. As such, Appendix J, Type C leak testing will not-be performed on the subject valves.

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Beaver Valley Power' Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Updated Inservice Testing Program Page 3 Chances Reauiring NRC Anoroval Proposed Revision 1C -of the BVPS Unit 1 IST Program (Attachment

4) consists of- eleven re:ief requests which require NRC approval prior to implementation per Generic Letter 89-04. Approval'for the relief requests will be needed to support 9R testing, scheduled to begin April 2, 1993. Nine of the relief requests are as a result of the BVPS Unit 1 Second Interval IST Program SER, dated May 6, 1991.

The other two are in response to Generic-Letter 90-06 " Resolution of Generic Issue 70, ' Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, 1 Additional Low-Temperature Overpressure Protection For Light-Water Reactors,' Pursuant to 10 CFR 50.54(f)."

Pump Relief Request No. 11- is being submitted in Proposed Revision 1D of the.BVPS Unit 1 IST Program (Attachment 5) for those pumps at BVPS Unit 1 whicn use a pump curve for inservice testing.

Anomaly No. 1 of Appendix A to the SER for the BVPS Unit 2 first interval IST Program stated that relief should be requested for each pump in the BVPS Unit 2 IST Program that uses a pump curve. At present no pump relief requests exist at either unit for those pumps which use- a pump curve for inservice testing. On April 8, 1992, we submitted Proposed Revision 2B to the BVPS Unit _ 2 IST Program requesting approval of the same change as included here for Unit 1.

We request that NRC review both Proposed Revision 1C and OLD to the BVPS Unit 1 IST Program by October 30, 1992, in order that procedure changes can be completed in time to support testing during the 9R outage. This will support the schedule for implementation requested by the NRC in the SER.

If you have any questions regarding this submittal, please contact Mr. Stephen Sovick at (412) 393-5211.

Sincerely,

. . Sieber Attachmtnts:

cc: Mr. L. W. Rossbach, Sr. Resident Inspector-Mr. T. T. Martin, NRC Region I' Administrator Mr. A. W. .De Agazio, Project Manager Mr. M. L. Bowling (VEPCO)

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ATTACHMENT 1-Page 1 of 8 Resolution of Provisional Relief Requests from BV-1 IST Program RRP-1 Requests relief from taking annual bearing temperature measurements and -from taking vibration readings- -in displacement units for almost all of the pumps in the IST Program. The proposed alternate test is to take vibration readings in velocity units.

Provision The SER states, " relief may be granted provided that the licensee complies with all of the vibration measurement requirements of ANSI /ASME OM-6, Draft 8 or later version."

Resolution All of the vibration measurement requirements of ANSI /ASME OM-6 were reviewed against the pump testing in place at BV-1. The requirements of the OM-6 are being met. This item is considered complete.

RRP-2 Requests relief- from measuring inlet -pressure for

[CH-P-2A, 2B], [SI-P-1A, 1B), [RS-P-1A, 1B), [RS-P-2A, 2B] and [WR-P-1A, 1B, 1C] and proposed using static-head from the suction source to calculate suction pressure.

Provision The TER states, " relief may be granted as requested provided the inlet pressure calculations are within the accuracy that would result from instruments meeting the Code accuracy requiremer.ts."

7esolution The inlet pressure calculations have been verified to be within the required accuracy for the pumps listed.

This item is considered complete.

RRP-3 Requests relief from measuring flow rate in accordance with the Code requirements- for [CH-P-2A, proposes the flow rate be calculated using a tank 2B] and level change during the refueling frequency test.

Provision The TER states, " relief _ may be granted provided that the licensee evaluate establishing vibration reference values at each test flow condition and that the flow calculations are within the accuracy that would result from instruments meeting the Code accuracy requirements."

Resolution Separate vibration- reference values will be utilized for each test flow condition in OSTs 1.7.1, 2 and OSTs 1.7.13, 14. The flow rate calculations have been verified to be within Code accuracy requirements. This item is considered complete.

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ATTACHMENT 1 Page 2 of 8 RRP-8 Requests relief from measuring fl'ow rate on [FW-P-2, 3A, 3B) in accordance with the Code requirements and proposes to measure flow rate on a refueling outage frequency.

Provision The TFR states that, " relief may be granted provided the differential pressure and vibration measurements are taken quarterly and that all pump parameters are measured during cold shutdowns."

Resolution The quarterly pump tests obtain both differential pressure and vibration measurements and compare them to reference values. The pumps are also tested-during cold shutdowns when the full-flow testing of the check valves is performed, even though no credit has been taken for the tests in the IST Program. Revision 7 of the IST Program, effective 6-7-91, referenced the cold shutdown testing for these pumps. This item is considered complete.

RRP-10 Requests relief from measuring flow rate on [EE-P-1A, 1B, 1C, 1D] and proposes calculating the flow rate by '

measuring day tank level rate of change.

Provision The TER states, " relief may be-granted provided the calculations are within the accuracy that would result from installed instrumentation meeting the Code accuracy requirements."

Resolution The flow rate calculations have ~ been verified to be within the required accuracy that would result from instruments meeting -the Code accuracy requirements.

This item is considered complete. ,

RR-7 Requests relief from assigning individual leak rates to

[TV-CH-200A, B, C] and proposes assigning afmaximum permissible leakage rate for the entire penetration.

Provision The TER states that " relief may be granted provided that the . limiting leak rate for the penetration is conservative and does' not allow excessive leakage through any particular valve in -the group to go uncorrected."

Resolution The allowable leakage rates for penetrations where individual leakage rates can not be obtained were evaluated. At BVPS, the maximum allowable' leakage rate assigned to the entire penetration .is the value normally assigned to the smallest valve in the group.

In this case, the 3 valves ~ are 8 inch valves. The individual allowable leakage rate for one 8 inch valve is 160 .sefd, therefore, the allowable leakage rate for this penetration complete.

is 160 scfd. -This item is considered

ATTACHMENT 1 Page 3aof 8 RR-16, 18 Request relief from stroking-various safety injection branch line check valves quarterly __and proposes verifying full-stroke opening capability by measuring total header flow.

Provision The TER states that it is unclear how the full-stroke is achieved and that the licensee should consider an alternate test such.as installing flow meters or using non-intrusive diagnostic test methods.

Resolution Per a conference call on .5-21-91 between Patricia Campbell of MEB, Al De Agazio, the BVPS Project Manager,- and DLCo personnel, j copies- of the- test <

procedure- and previous test results were sent to Ms.

Campbell for further review.

A " Supplement to Safety Evaluation Dated May 6, 1991 Regarding. the. Beaver Valley Unit 1 Second-Interval ,

Inservice Testing Program for Pumps and Valves (TAC '

M80470/M61257)" was issued on 1-24-92 concerning these -

relief requests. The SSER states: " Based on the uncertainties of the proposed alternative test methods, in verifying _ full-stroke opening of the subject-check valves, the licensee should revise the testing to meet either Position 1 or Position 2 of GL 89-04. ... The revised testing is to be implemented- by the next refueling outage."

The method of testing these valves will be revised to meet either Posit'on 1 or 2 of GL 89-04, and will be incorporated for use in 9R. If the relief requests need to be revised, they will be submitted to the NRC prior to 9R.

RR-21,22 Request relief from exercising _[SI-83, 84] and [SI-94,

95) and propose to full-stroke them.during refueling outages.

Provision The TER states that " relief _may be granted providad that the licensee investigates partial-stroke exercising these valves during cold shutdowns, and documents their findings."

Resolution [1SI-83, 84, 95] will be part-stroke exercised during cold shutdowns _in a- new test, OST 1.11.20. [SI-94),

however cannot be exercised. _ The only flow - path available is through the Boron Injection Tank. It1is not practical to introduce flow through that line-as documented in relief -request 24, granted in this SER.

- These relief requests have been submitted to the NRC as part of proposed Revision 1C, Attachment 4.

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ATTACHMENT 1 Page 4 Of 8 RR-20 Requests relief from' exercising-[SI-48, 49, 50, 51, 52,

53) and proposed a full-stroke test during refueling outages by blowing-down the Safety Injection Accumulators at the lower pressure and monitoring the system resistance.

Provision The TER states that it is unclear how a full-stroke test is performed and that DLCo should - consider installing flow instrumentation or using non-intrusive diagnostic test methods.

Resolution Per a conference call on 5-21-91 between Patricia Campbell of MEB, Al De Agazio, the BVPS Project Manager, and DLCo personnel, copies of the test procedure and previous test results were sent to Ms.

Campbell for further review.

A " Supplement to -Safety- Evaluation Dated May 6, 1991 Regarding the Beaver Valley Unit 1 Second-Interval Inservice Testing Program for Pumps and Valves (TAC M80470/M61.257)" was issucL1 on 1-24-92 concerning these relief requests. The ;SER states: " Based on the uncertainties of the proposed alternative test methods, in verifying full-stroke opening of the subject check valves, the licensee should revise the testing to meet either Position 1 or Poe'*lon-2 of GL 89-04. ... The revised testing is to t' implemented by the next refueling outage."

The method of testing these valves will be-revised to meet either Position 1 or 2-of GL 89-04, and will be- '

incorporated for use in 9R. One method under consideration is to measure a C y value during a blowdown at reduced accumulator pressure in conjunction i with a non-intrusive test, similar to the method used at Ft. Calhoun Nuclear Station. . If the relief requests need to be revised, they will be submitted to the NRC prior to 9R.

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ATTACHMENT 1 Page 5 of 8 RR-13, 25 Request relief from exercising [1SI-1, 2) and [1RS-158, 160] and propose to verify valve operability by check valve sample disassembly / inspection during refueling outages.

Provision The TER states that " relief may be granted provided the guidelines of Generic Letter 89-04, Position 2 on disassembly are followed and a partial stroke test is performed when reassembly is complete and prior to returning the valve to service."

Resolution The Guidelines of GL 89-04 were reviewed and are being met, except the part-stroke exercise requirement after valve reassembly cannot be performed.

[1SI-1, 2) - The only flow path available to test these valves is to fill the containment sump with water and start the Low Head Safety Injection pumps. This would result in contaminated / dirty water being introduced into the Refueling Water Storage Tank / Reactor Coolant System.

[1RS-158, 160) - The only flow path available for these valves would be to fill the Outside Recirculation Spray pump casing with water and start the pump. The manual isolation valves would than be opened and the test would verify flow through the check valves, using an ultrasonic flow meter, to the Charging system. This test could introduce air into the Charging / Reactor Coolant Systems.

Both of the relief requests have been revised and have been submitted to the NRC as part of Proposed Revision IC, Attachment 4.

RR-15 Requests relief from exercising valves [SI-6, 7) quarterly and proposes a part-stroke exercise quarterly and a full-stroke exercise during refueling outages.

Provision The TER states that it is unclear how the part-stroke exercise test is performed and that DLCo should review the test method and, if necessary, revise the IST Program to reflect actual testing.

Resolution The test method was reviewed. The valves had been considered to be part-stroke exercised by recording the pressure change in a dead leg of pipe down stream of the check valves before and after pump start. It was determined that this method dras not provide a true part-stroke of these valves. Therefore, this relief request has been revised tc delete reference to the part-stroke, and was submitted to the NRC as part of Proposed Revision 1C, Attachment 4.

ATTACHMEET 1 Page 6 of 8 RR-19 Requests relief from exercising [SI-27] and proposes to part-stroke exercise _this valve quarterly if the_ system configuration permits and to full-stroke exercise it during refueling outares.

Provision The .TER states th' . relief-may oe granted provided a part-stroke exercis be performed when shutting down to cold shutdown.

Resolution This valve will be part-stroke exercised quarterly if the system configuration permits. It will also be part-stroke exercised in accordance with UST 1.11.20 on a cold shutdown frequency and full-stroke exercised during refueling outages per OST 1.11.14. The relief request has been revised and submitted to the NRC as part of Proposed Revision 1C, Attachment 4.

RR-32 Requests relief from exercising [RW-110, 111, 112, 113]

and proposes verifying the full-stroke capability of these valves by check valve ' sample disassembly /

inspection every five years.

Provision The TER states that " sample disassembly and inspection may be acceptable provided that one valve of the group is inspected each refueling outage. The minutes from the public meetings in Generic Letter 89-04 regarding Position 2 further stipulate that a partial-stroke exercise test using flow is expected-to be performed after disassembly and inspection is completed but before the' valve is returned to service."

Reso?ation A Preventive Maintenance Program is established for these valves that ensures that at least one valve is inspected each refueling outage, with the entire group 1

inspected every five years. In addition, a partial-stroke is performed when the Diesel Generators are tested and during the River Water system flow test, prior to utation- startup. This item is considered complete.

RR-34 Requests relief from exercising [RW-197, 198] quarterly and proposes to verify valve operability by visually inspecting one valve per refueling outage. -

Provision The TER states that-relief may be granted provided the guidelines of GL 89-04, Position 2 are followed and the valves are part-stroke exercised following reassembly but prior _ to returning them to service. -The use of portable flow instrumentation or non-intrusive diagnostic testing techniques should be investigated.

Resolution The internals of check valve [RW-197] Lhave: been removed. Therefore, these check valves .have been removed from the IST Program and this relief request deleted in Revision 7, effective 6-7-91. This item is considered complete.

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AT.TACHMENT 1 Page 7 of 8 t

l Interim Approval for Relief Reauests

! RRP-2 Requests relief' from measuring . inlet pressure for

! [CH-P-1A,- IB, 1C).and (QS-P-1A, 1B] and proposes using l the static headL from a tank to- calculate suction pressure.

Provision The TER states that the use of permanent or temporary pressure gages- must- be investigated to measure pump inlet pressure during quarterly pump *ests. Interim relief is granted. In the interim, inlet pressure may be- calculated provided the calculations are within the i Code required accuracy requirements.

Resolution An evaluation is underway to investigate the use of permanent or temporary. pressure gages by 9R. In the J interim, the inlet pressure calculations have been verified t. be within the required accuracy. If gages will be installed, these pumps will be deleted from the ,

relief request.

RR Requests relief-from. assigning individual leak rates to  !

[TV-CC-110F1, F2) and proposes assigning- a maximum permissible leakage rate for the entire penetration. ,

Provision The TER states that "it appears that both valves can be indiv!nually leak tested. An interim . period is provided to allow for -procedure changes. Interim relief may be granted."

Resolution These valves cannot be individually leak rats tested.

The boundary valve downstream from [TV-1CC-110F1)'is a potentially open check valve leading to the Circulating-Water System. The- River Water Systen downstream of

[TV-1CC-110Fl], therefore cannot be isolated to provide i an accurate leakage rate for- (TV-1CC-110F2). This relief request has been revised and submitted to the NRC as part of Proposed Revision 1C, Attachment 4.

RR-30 Requests relief from exercising (MS-80, 81, 82) and proposes verifying- operability by. check valves-sample disassembly / inspection on a refueling outage frequency.

Provision The TER . states that "the licensee should-develop =a --

method to verify the reverse flow . closure of these valves other than- by sample disassembly and i inspection."

l Resolution These valves cannot be; tested to verify closure with reverse flow. These check valves are-the first valves:

downstream of the steam generators in parallel lines and cannot be isolated. Individual' leakage' . rates cannot be obtained. As ' an alternative, a:

partial-stroke of these valves will be performed after valve inspection / reassembly prior to placing them back in service. This relief-request has been revised and submitted to the NRC as part-of Proposed Revision 1C, Attachment 4.

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-ATTACHMENT 1 Page 8 of 8 a

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RR-33 Requests relief 'from exercising. [RW-135, 136) and 1

proposes verifying valve operability by full-stroke exercising these valves ~during refueling outages.

Provision The- TER states that " adequate technical basis for not

, testing these valves quarterly or during' cold shutdown j has not been provided. Interim relief is granted ~ .

1 During this interim period, a-test-should.be developed-to exercise.these valves quarterly."

l Resolution The internals. have been. removed from these valves.

These check valves were removed from the IST Program per Revision B effective-3/13/92. Revision 8-will be submitted to the NRC within thirty days of this ,

submittal. This item-is. considered complete.

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RR-37 Requests relief from exercising {TV-VS-101A,'B, C, D,-

I E] and proposes verifying valve operability by j full-stroke exercising these valves every 18 months, j Provision The TER states that " adequate technical justification i for not testing these valves quarterly during power

} operation or cold shutdown has not been provided.

Alternate methods to monitor valve degradation, such as

using non-intrusive valve diagnostics should be investigated."

Resolution These valves can be stroked quarterly by isolating the air bottles and simulating a high chlorine signal. The valves, however, cannot be timed. Stem movement will be observed to verify. valve actuation. This relief

, request has been revised and submitted to the NRC as j part of Proposed Revision 1C, Attachment 4.

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ATTACHMENT 2 Page 1 of 8- l List of Chances to the Unit 1 IST Procram (Rev. 7)

A) The following changes are " editorial" in nature:

1) The following are a list of general editorial changes made through the BVPS-1 IST Program: (NOTE: use of'sidebars to identify " general" whole page changes to the Unit 1 IST Program will not be -used, but " specific"- changes will-continue to be identified by sidebars.)

a) Each reference to an OST was revised to reflect che new Writer's Guide format (i.e., 10ST-11.14 versus the old format of OST 1.11.14). Pump and valve mark numbers were also upgraded to include the Unit "1" designation in front of the system abbre.viation. (Not identified by sidebars.)

b) The " System" title descriptions on-the Pump and Valve Outline Sheets (pages 6 - 37 and 55 - 118) were revised to better describe the individual systems / subsystems of

-pumps or valves listed on the sheets.

c) The format of the " Pump Testing Outline" sheets (page 6

37) was revised to also include each pump's " Drawing OM Number" and " Drawing Cooroinates" per_ NRC recommendations. The " Type" of pump (eg., Centrifugal, Vertical, or Positive Displacement) has also been added. In addition,. more detail was added to each sheet's " Comments" section to'better describe how and where the pump parameters would be obtained. '(Not identified by sidebars.)

d) The format of the " Valve Testing Outline" sheets (pages 55 -

118) was revised per NRC recommendations to also include each valve's " size" in inches and " valve type" (not identified by sidebars). .In addition, the valve drawings referenced were changed from RM drawings to OM drawing numbers (not identified by sidebars). The

" Comments" section for'each. valve was-also expanded to-include -the " safety position" for testing each valve, and whether a remote position verification (RPV) is performed. The " Valve. Testing Requirements" section

'ca s also revised to include a description of the above on pages-52 and 53.

e) The OM drawing numbers _ _and coordinates for all pumpsE and valves in the Program were reviewed against the new OM drawings issued- in April, and revised accordingly.

(Not identified by sidebars.)

ATTACHMENT 2

' Page 2 of 8 f) The " Alternate Test" section of each Cold Shutdown Justification and Re~~ef Request (pages 120 through 181) was also revised o be more consistent in wording, and to include more detail and the safety position for testing each valve.

2) "(CSD) -

Cold Shutdown Frequency" was added under Item 2 on l Page 4.

3) The " Remarks" section for Residual Heat Removal Pumps l [1RH-P-1A,B) (pages 11 and 12) was revised to say that each quarterly during cold shutdowns and

" pump is tested refueling outages." The " Frequency" in the "10ST" column was changed from (Q) to (CSD, R). Pump Relief Request No. 4 (page 42) was also revised to reflect this clarification under " Alternate Test."

4) The " Alternate Test" for Pump Relief Request No. 3 (page 41) was reworded to better describe when and how flow would be calculated for these pumps.

5) Deleted mention of the specific flowrate (32 gpm) given in the Basis for Relief in Pump Relief Request No. 5 (page 42) because a wide range of flows is permitted for these pumps to function properly.

6) Added the statement that remote position verifications would "normally be down at refue]ings" to the end of the fourth paragraph on page 48.

7) Under Item A.2. on page 52, "D - Damper" was added to the list of -valve actuator. types, and " Valve" was added after each abbreviation description.

8) Under Item A.3. on page 52, the following-normal system alignment abbreviations were deleted because theyEare no longer referenced on the Valve Testing Outline. Sheets: (ST

- Sealed Throttled, SO - Sealed Open, and SS -- Sealed Shut) .

9) Added the word " Frequency" after-each frequency listed under Item A.7 on page 53.

l 10) Added reference to "10ST-47.3B" in addition-to 10ST-47.3A in the " Comments" section throughout the Valve Testing outline sheets (pages 55 - 118).

11) Corrected the frequency for testing Pressurizer Power Relief l Isolation Valves (MOV-1RC-535, 536, and 537) (page 56) from monthly _(M) to quarterly (Q) in 10ST-6.6. This OST is performed monthly, but these valves are only stroked _each quarter per ASME XI.

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ATTACHMENT 2 Page 3 of 8 i

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12) Corrected the Corrective Maintenance Program title for i disassembly and inspection of Containment Sump to Low Head Safety Injection Pump Check Valves (1SI-1 and 2) (page 65) to "1 CMP-75-ALOYCO CHECK-1M", and on associated Relief Request No. 13 (page 150).

13) Changed the surveillance test used to quarterly stroke &

time Low Head Safety Injecticn Pump Refueling Water Storage Tank Suction Isolation Valves (MOV-1SI-862A and B) (page 70) from 10ST's 11.6 and 11.7 to 10ST-47.3A,3B per Operations request. ,

14) Corrected the Corrective Maintenance Program title for disassembly and inspection of Steam Generator Residual Heat Release Check Valves [1MS-80, 81, and 82] (page - .92 ) to-

"1 CMP-75-CRANE CHECK-1M", and on associated Relief Request No. 30 (page 166).

15) Revised the valve category for the Main Steam Isolation Valves [TV-1MS-101A, B, and C] (page 93) from category "B" to "B/C" since these valves are actually check valves installed backwards with an actuator to hold the disk open.

Also revised the valve . category __ listed in CSJ No. 24 to "B/C" (page 133). No additional testing is required.

16) Added reference to 10ST-24.14A, 14B, and 14C_for the Loop A,

, B, and C Feedwater Containment Isolation Check Valves l

[MOV-1FW-156A, B, and C] (pages 97 and 98) to verify closure by leak test at refuelings as already referenced in CSJ No.

26 (page 134).

17) Corrected the Normal System- Alignment position-referenced for the Main Feed Regulator Valves (FCV-lFW-478, 488, and 498) (page 98) from Throttled (T) to " Automatic-(A)."

18) Corrected the mark numbers for the Diesel Generator Air l Start Solenoid _ Operated Valve's from [SOV-1DA-101, 102, 103, and 104) to [SOV-1EE-101, 102, 103, and 104] on page 110 and in Valve Relief Request No. 36 on page 170. Also corrected the referenced Operation's Surveillance Test's for valves

[SOV-1EE-102 and 103) to 10ST-36.1 -and 10ST-36.2-respectively. In addition, the frequency for testing these valves was corrected - to "bi-monthly" _from monthly-cince these valves are stroked and timed on an alternating monthly frequency in the OST's.

19) _ Reworded the " Basis for Cold Shutdown Justification" in-Cold -

Shutdown Justification No's. 14, 15, 17, 22, 24, and 25 (pages 128, 129, 132, and 133) because:they wsre written like relief requests. Their intent has not been changed in any way.

20) The basis for Cold Shutdown Justification No. 23 (page 132) was revised per Independent ~ Safety Evaluation 1 Group recommendations to say that " full or partial stroking the pressure control valves at power coald cause reactor power transients."

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21) Corrected the additional surveillance testing referenced in Cold Shutdown Justification No. 26 (page 134) from OST 1.24.13 to "10ST-24.14A, 14B, and 14C" to verify check valve closure by a leak test. Also deleted reference to " Full- or

part-streke" t sting in the " Basis for CSJ" since this is

! taken exception to for Motor Operated Vai 1 3. The intent of

! the CSJ has tc been changed.

l B) The following changes are being made in accordance with the ASME l XI Code and Generic Letter No. 89-04:

! ~

I 1) The requirement to trend inservice test results in " graphic"

' The form was deleted from the first paragraph on page 4.

graph sheets were not being used -when trending pump degradation. The BVPS-2 IST Program, TSAP 3.10, and NGAP 8.2 have already been revised to delete this requirement.

ASME XI, Section IWP-6000 does not specify how trending is i to be performed. Inservice test results will continue _to be trended in tabular form.

, 2) Added full flow testing of the Low Head. Safety Injection-Pumps (1SI-P-1A and 1B] by OST 1.11.14 at refueling outages e to their Pump Testing Outline Sheets (pages 13 and 14) to 1

support the " Minutes of -the Public Meetings on Generic

, Letter No. 89-04," response to Question _No. 48. In the

response to this question, the NRC stated, "they would j prefer a more comprehensive test be performed. at some reduced frequency rather than relying only on the mini-flow test that is performed quarterly. This particular issue may be a topic of another generic-letter addressing inservice I testing in the future." The bumps -affected by' this j statement are the High. Head Safety _ Injection, Low Head l Safety Injection, and Auxiliary Feedwater-Pumps. All three i sets of pumps are already _being full flow tested during refueling outages to support this recommendation,

but ASME XI criteria is not being applied in; all cases. The l Auxiliary Feedwater Pumps [1FW-P-2, 3A, and- 3B]: .are l

presently applying ASME XI criteria for- both -quarterly i recirculation flow .and for full flow testing at cold shutdowns and refueling outages. The- Low- Head Safety i- Injection Pumps (1SI-P-1A, and 1B] are presently applying-i ASME XI criteria for quarterly recirculation flow and will l be- applying ASME XI criteria to full flow testing starting i

at 8R. The High' Head Safety' Injection Pumps [1CH-P-1A, 1B, and 1C] are presently applying ASME XI criteria for quarterly recirculation flow and will gatheriadditional-full flow data during 8R so that ASME XI criteria can be applied to full flow-testing.at refuelings starting with 9R.

3) The " Remarks" section for Low Head Safety Injection Pumps

[1SI-P-1A and 1B] (pages 13 and 14) was revised to'say that-each " pump is tested quarterly on recirculation and at full flow during refueling outages." In addition, the " Comments" section for Vibration (V) was revised to say,_" Portable monitoring equipment -

Fixed vibration probe"- since installed vibration pickups were permanently installed during 8R to measure pump _ shaft vibration per DCP-1532.

i ATTACHMENT 2 Page 5 of 8

4) Deleted reference to Pump Relief Request No. 2 for the 2A and 2B Outside Recirculation Spray Pumps [1RS-P-2A_and 2B]

on pages 23 and 24 since a temporary test gauge will now be t installed to read pump suction pressura (Pi) versus using

the level in the pump casing. Pump Relief Request No. 2

! (page 41) was also revised-to reflect this change.

I

5) Added the Main Feedwater Pump Discharge Isolation and Backup Feedwater Isolation Valves (MOV-1FW-150A and B] (see page to the Unit 1 IST Program ac category B, class 3 valves 97) per Independent Safety Evaluation Group recommendations. - In addition, Cold Shutdown Justification No. 31 (see page 136) i was added to test these valves during cold shutdown par j 10ST-1.10. Testing these valves _ at . power- cannot be performed since this would isolate feedwater resulting in a plant trip and shutdown.

' 6) Revised the method for-testing the river water supply to_the Control Room redundant cooling coils Check Valves [1RW-135 ,

. and 136) (page 104) to perform a " sample disassembly and-inspection per CMP 1-75-WAFER CHECK-1M" at each refueling.

, Relief Request No. 33 (page 168) was also revised to reflect this change. The test method was _ changed because the previous method for forward flow testing these check valves using a portable ultrasonic flow measurement device on-the existing piping could not verify a full stroke of the check valves. Following the disassembly and inspection, a partial stroke of the check valves will be performed in accordance with Generic Letter No. 89-04. A Station modification'to

add permanent ultrasonic flow measuring devices on stainless steel spoolpieces during 8R for Generic Letter No. 89-04 is

, being . evaluated as to whether forward full-flow measurements can be obtained through these check valves. This test method will be incorporated into a future revision to the Unit 1 IST Program if warranted.

I 7) Deleted river water return from the recirculation spray heat j exchangers parallel Check Valves-[1RW-197 and 198] on page 105 because the internals of the ch eck valves have been removed- during 8R. per minor modification DCP-1726. Relief

- Request No. 34 (page-169) was also " Deleted".

l 8) 'Added the manual -isolation -valves [1RW-615, 621,-627, and 633] to . the four radiation monitors loca'ed c foutside containment at the discharge of each recirculation spray.

heat exchanger to the Unit 1- IST Program' s category B,;

class 2_ valves per Licensing recommendations (see pages 105 i

and 106). These valves will be stroked closed quarterly per 10ST-47.3A(3B).

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ATTACHMENT 2 Page 6 of 8 C) The following changes are being incorporated following Nhc approval of Proposed Revision 1A:

1) Deleted the 2A and 2B Circulating Oil Pumps [1EE-P-2A and 2B] and associated Pump Relief Request No. 11 from the Unit 1 IST Program. Also deleted [1EE-P-2A and 2B] from Pump Relief Request No. 1 (page 39).- This is done following.NRC approval of Proposed Revision 1A for the Unit 1 IST Program.

2) Added reference to Valve Relief Request No. 42 for Emergency Airlock Valves (1VS-183 -and 184) (pages 118, 180 and 181) following NRC approval of Proposed Revision 1A for the Unit 1 IST Program. The relief request was needed since the piping and valve arrangement inside the emergency airlock _is such that individual leakage rates _for each valve cannot be measured. A leakage rate for'the entire emergency airlock will be assigned per 1BVT 1.47.10.

D) The following changes are being incorporated based on NRC comments made in the Technical Evaluation Report (TET for the Unit 1 IST Program second ten year interval:

1) The following wording was added to the " Comments" column-for "Pi" for the Charging Pumps [1CH-P-1A,B,C) and the_ Quench Spray Pumps [10S-P-1A,B] (pages 6, 7, 8, 15, and 16):

" Install temporary test gauge at pump suction (local) or calculate Pi using..." This was done to provide an option of installing test- gauges or calculating suction pressure (Pi). In the Unit 1 IST Program Technical Evaluation Report (TER), the NRC granted interim relief for calculating Pi until 9R per Pump Relief Request No. 2 (Page 41), and recommended the licensee investigate thn possibility. of installing a preesure gauge on the test ;onnection at each pump's suction. The option abo'e_-will allow for installation of test gauges until peimanent gauges can be installed per a DCP if approved by the Station. -At 9R, Relief Request No. 2 will no longer apply for these pumps, l

2) The " Remarks" section for the Turbine Driven Auxiliary Feedwater Pump. [ 1FW-P- 2 ] (page 28)-was revised to say that u each " pump is tested quarterly on recirculation and at full L flow when in Mode 3 during startup from cold shutdowns and refueling outages." In ' addition, the " Frequency" in the "10ST" column .for 10ST-24.9 was changed from (R) to (CSD, R). Pump Relief Request No. 8 (page 45) was also-revised to j reflect testing this pump during cold shutdowns and

refueling outages as recommended by the NRC'in the Unit 1 IST Program TER.

AITACHMENT_2 Page 7 of 8

3) The " Remarks" sections for the Motor Driven Auxiliary Feedwater Pumps (1FW-P-3A, and 3B] (pages 29 and 30) were revised to say that each " pump is tested -quarterly on recirculation and at full flow during cold shutdowns and refueling outages." In addition, the " Frequency" in the "10ST" column for 10ST-24.8 was changed from (R) to (CSD, R). Pump Relief Request No. 8 (page 45) was also revised to reflect testing these pumps during cold shutdowns and refueling outages as recommended by the NRC in the Unit 1 f-IST Program TER. -

4) Per the Unit 1 IST Program TER, Pump Relief Request No. 1 (page 39) was clarified for the NRC by stating that " relief is requested from measuring bearing temperatures annually and from measuring pump vibration in displacement units (mils)." Also by stating that we will "obtain pump vibration measurements in accordance with the vibration measurement requirements and corrective actions of ANSI /ASME OM-6, and measure vibration in velocity units (in/sec) using the ranges listed in OM-6 (revision 8) as acceptance criteria."

5) Added Ohio River " elevation" to the " Alternate Test" for f Pump Relief Request No. 2 (page 41), and identified which pumps have interim relief granted until 9R only as stated earlier in item D) 1) above.

6) Noted in the " Comments" for High Fead Safety Injection Pump Suction from Refueling Water Storage Tank Valve (1SI-27)

(page 67) that 10ST's 7.4, , or 6 Will only do a partial stroke (PS) in the forward di,ection (FD) quarterly (Q) "if the Refueling Water Storage tunk is supplying the charging pumps" as stated in Relief Request No. 19 on page 156.

Investigation into performing a partial stroke of this check valve at cold shutdown only is being evaluated per the Unit 1 IST Program TER recommendations, and will be incorporated into a future revision if warranted.

7) The NRC denied relief for Boron Injection Tank Inlet Valves

[MOV-1SI-867A and B] in the Unit 1 IST Program TER, and recommended that they be tested at cold shutdown. Relief Request No. 23 (page 159) was " Deleted", and converted irdo Cold Shutdown Justification No. 32 (page 137). The Valve Outline Sheet (page 71) for these valves was also revised to reflect this change.

8) Corrected the frequency for stroking the Control noom Area Ventilation Valves [TV-1VS-101A through E) (page 113) from Refueling ;c "every 18 months" in accordance with Relief Request No. 37 on page 171. Investigation into determining degradation of these valves and how it -ill be affected by this relief request is being evaluated per the Unit 1 IST Program TER recommendations, and will be incorporated into a future revision if warranted.

)

l ATTACHMENT 2 Page 8 of'8

9) The frequency for performing a sample disassembly' and .

inspection of the Diesel Generator Heat Exchanger-River.

Water Inlet Check Valves [1RW-110, - 111, 112, and 113] in i Relief Request No. 32 (page 167) was revised to read "One to two check valves _ will _be disassembled and inspected every refueling outage not to exceed a 5; year frequency por IE Bulletin 83-03" instead of only "5 years." This-was-done to clarify the sample number of check valves and total i allowable frequency per NRC recommendations in the Unit 1 j IST Program TER.

l HQII: The Technical Evaluation Report (TER) for the Unit 1 IST Program discussed the NRC's evaluation of each pump and l

valve relief request in the Unit 1 IST Program.

l The following relief requests were granted by the NRC:

l Pumps: 4, 5, 6, 7, and 9 Valves: 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 14, 17, 24, 26, 28, 29, 31, 35, 36, 38, 39, 40, 41, and-42. ,

l -

The following' relief requests were granted -with provisions by the NRC.

Pumps: 1, 2, 3, 8, and 10 Valves: 7, 13,. 15, 16, 18, 19, 20, 21, 22, 25, 32, and 34 t

- The Station has a 6 month period for evaluation of the NRC's comments. For some relief requests this evaluation has been completed and included in this revision to the Unit 1 IST Program. If revisions are warranted based on the evaluations of the NRC's

. comments for the remaining relief requests,'they will l be included in a future- revision to the Unit 1 IST Program.

l The following relief requests-have been granted interim relief until 9R while- the Station evaluates the comments made by the NRC:

Pumps: 2 (for [1CH-P-1A,B,C] & [1QS-P-1A,B]

only)- [See Item D) 1)]

Valves: -27, 30, 33, and 37 l -

Relief Request No. 23 was denied by the NRC and has I

been deleted in this : revision to the Unit l'- IST-Program. [See Item D) 7)]

A separate letter will discuss the' Station's evaluation of the NRC's comments in the Unit-1.IST Program TER.

Future revisions to the Unit 1 IST Program will be made based- on these_ evaluations, and within the time periods permitted by the NRC.

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