ML20127P662

Safety Evaluation Supporting Relief from ASME Code Section XI Inservice Testing Program Requirements W/Listed Exceptions

ML20127P662
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/20/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20127P644	List: ML20127P641 ML20127P662
References
NUDOCS 8507020482
Download: ML20127P662 (30)

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[ 'o,, UNITED STATES j? g NUCLEAR REGULATORY COMMISSION

{- G j .W ASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONCERNING INSERVICE TESTING PROGRAM

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FOR ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET N0. 50-368 ARKANSAS POWER & LIGHT COMPANY 8507020482 850620 PDR ADOCK 05000368 P PDR

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CONTENTS PAGE SEf. TION 1.0 Introduction 1

?,0 . Pump Testing Program 2

.a h code Requirements 2 2.2 Vibration Measurement 2 2.3 Flow Measurement 3

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1 3.0 Valve Testing Program 4 3.1 Code Recuirements 4 3.2 General Considerations 4 3.3 Chilled Water 9 3.4 Containment Spray 10 3.5 Component Cooling Water 11 3.6 Main Steam 12 3.7 Emergency Feedwater 13 3.8 Steam Getierator Secondary Side 14 -

3.9 Service llater 15 3.10 Fire Water 16 3.11 Reactor Coolant 17 3.12 Chemical and Volume Control 18 3.13 Safety In.iection 19 3.14 Service Air 23 3.15 Instrument Air 24 3.16' Heating, Ventilating, and Air Conditioning 24 3.17 Plant Heating 25 3.18 Fuel Pool 25 4.0 Conclusions 26 5.0 References 27 6.0 Appendix - Piping and Instrumentation Drawings Reviewed 28

J 1.0 Introduction As specified in 10 CFR Part 50, Appendix A, General Design Criterion 32,

" Inspection of Reactor Coolant Pressure Boundary," requires, in part, that components which are part of the reactor coolant pressure boundary shall be designed to pennit periodic inspection and testing of important areas and features in order to assess their structural and lecktight integrity.

Inservice Testing (IST) programs for safety class components must conform to the general requirements of 10 CFR Part 50.55a, " Codes and Standards." This rule requires, in part, that inservice testing of ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Boiler and Pressure Vessel Code and applicable addenda except where specific written relief has been granted by the Comission. Certain requirements of later editions and addenda of Section XI are impractical to perform on older plants because of constraints imposed by existing designs and materials. Thus, 10 CFR Part 50.55a(g)(6)(1) authorizes the Comission to grant relief

, from those requirements upon making the necessary findings.

and valve inservice This testingreport program providessubmitted our by safety Arkansas evaluation Power and of the Light pump (AP&L) for the Arkansas Nuclear One, Unit 2 (ANO 2) plant. The AP&L IST program and

, revisions thereto are contained in AP&L letters dated June 15, 1978 ,

(Ref. 1), October 29, 1980 (Ref. 2), and December 10, 1982 (Ref. 3). The program includes both baseline preservice testing and periodic inservice testing of ASME Code Class 1, 2, and 3 components. The program provides for both functional testing of components in the operating state and for visual inspection for leaks and other signs of degradation.

In accordance with the date of the AN0 2 construction permit (i.e.,

December 6,1972),10 CFR Part 50.55a(g)(2) requires compliance with the 1971 Edition through the Summer 1971 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code. However, IST requirements for pumps and valves were not included in the Code until the Summer 1973 Addenda of the 1971 Edition. AP&L has, therefore, optionally chosen to meet the requirements of the 1974 Edition through the Summer 1975 Addenda to the extent practical and has requested relief from certain core requirements.

In our letter of September 21, 1979 (Ref. 4), the NRC granted, based on our preliminary review, interim relief for those IST program aspects requested by AP&L. Since that time, AP&L has proposed previously(References revisions 2 and 3) to the ANO 2 program and EG&G has under contract to the NRC perfonned a partial review of the ANO 2 program. The EG&G technical evaluation report (Ref. 5) was dated July 1983.

Our review was limited to safety-related pumps and valves. Safety-related components are defined as those components that are needed to mitigate the consequences of an accident and/or shutdown the reactor and maintain the ,

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reactor in a safe shutdown condition. Components in this category would typically include certain ASME Code Class 1, 2, and 3 components and could include some non-code Class components.

Our evaluation, which ensues, sunnarizes the EG8G review, resolves open items identified in the EG&G review, discusses AP&L IST experience during the last AND P refueling (outage number 2R3), and accordingly supersedes NRC's interim approval given earlier.

2.0 Pump Testing Program 2.1 Code Requirements According to Subsections IWP-3300 and IWP-3400 of the Code, an inservice test shall be conducted on all safety-related pumps, nominally once each month during normal plant operation. Each inservice test shall include the measurement, observation, and recording of speed, inlet pressure, differential pressure, flow rate, vibration amplitude, lubrication level or pressure, and bearing temperature (see Table IWP-3100-1). (Bearing temperature needs to be measured only once each year.) _

2.2 Vibration Measurement 2.2.1 Relief Request The licensee has requested relief from measuring pump vibration on the bearing housing near the couplings of the service water pumps.

Basis for Requesting Relief These pumps are submerged in the fluid flow path. They have extended casings and shafts, and the radial bearings are water lubricated.

Therefore, direct reading of pump vibration is not feasible, and indirect readings obtained from upper casing areas would be more sensitive to flow noise than pump vibration. As an alternative, the licensee has proposed to measure motor driver bearing vibration (radial and axial) in lieu of pump vibration.

Evaluation ,

We agree with the licensee's basis and request that measuring motor driver bearing vibration is a practical means for analyzing pump mechanical condition. This proposed alternative surveillance method satisfies our interpretation of the intent of Section XI requirements to foresee possible pump failure. -

Based on the above considerations, we conclude that the alternate testing proposed will give reasonable assurance of pump operability intended by the Code and that relief is thus granted.

2.3 Flow Measurement 2.3.1 Relief Request The licensee has requested relief from measuring flowrate of the service water pumps.

Basis for Requesting Relief There were no flow transmitters included in the design of the service water pump discharge lines. To test the flow on these pumps, a flow orifice and differential pressure sensing instrumentation would have to be installed in each header prior to any line branching from the header. Any instrumentation would have to be ten pipe diameters upstream and seven pipe diameters downstream of straight pipe runs. In ANO 2, only one location exists for all three 20-inch diameter discharge lines. That ~

location is between the service water pump house and the wall of the w turbine auxiliary building. It is impractical to install differential

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pressure devices in that location because these lines are buried under ,

10 feet of earth and one-half to one foot of asphalt and concrete. To uncover these lines and install flow transmitters would require the construction of a concrete pit about 12 feet deep and at least six feet square. The pit would have to be lighted, sump pump supplied, and missile shielded.

Two service water headers are accessible as they pass under the turbine building through a pipe chase of seven and one-half feet wide by five feet high. This area is cramped and impractical for the installation of flow transmitters because the devices would have to be placed 12 feet back into the chase.

The licensee has proposed an alternate testing method, which is to measure differential pressure across the pumps and relate discharge pressure to manufacturer supplied pump curves in order to determine flow rates.

Evaluation The licensee has demonstrated that there is no practical means for installing flow instrumentation on the service water pumps. As an alternative means for monitoring pump degradation, AP&L has proposed to measure differential pressure across the pumps when the pumps are tested t) shutoff pressure.

We conclude that the licensee's proposal is acceptable and the relief requested is hereby granted.

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3.0 Valve Testing Program 3.1 Code Requirements Subsection IWV-3410(a) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). Subsection IWV-3520(a) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above cases of exceptions, valves may be tested at cold shutdown where:

a. It is not practical to exercise the valves to the position required to fulfill their function or the partial position during power operation.

b. It is not practical to observe the operation of the valves with failsafe actuators on loss of actuator power.

Subsection IWV-3410(c) requires all Code Category A and B power-operated valves to be stroke-time tested to the nearest second or 10 percent of the maximum allowable owner-specified time.

3.2 General Considerations Exercising Check Valves It is NRC's position that check valves whose safety function is to open are to be full-stroke exercised. Since the disc position is not always observable, an acceptable alternate to full stroke testing would be verification of the maximum flow rate (per the plant safety analysis) through the check valve. Any lesser flow rate would be considered indicative of a partial-stroke exercise unless it can be demonstrated that the disc position at the lower flow rate would permit maximum required flow through the valve. The reduced flow rate method of demonstrating full-stroke capability must be accompanied by the measurement of differential pressure across the valve.

Pressurizer Power Operated Relief Valves The NRC has adopted the position that pressurizer power operated relief valves should be included in the IST program as Category B valves and tested to the Section XI requirements. However, the NRC has concluded that routine exercising during power operation is not practical.

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% l i l The ANO 2 plant does not have pressurizer power operated relief valves, but does have pressurizer vent valves (2CV-4697 and 2CV-4698), which are included in the IST program and tested at each refueling outage.

Conditions for Valve Testing during Cold Shutdowns The licensee's program for cold shutdown testing shall conform to the following conditions in order to be acceptable,

a. Testing is to commence as soon as possible after the cold shutdown mode is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until completion or the plant is ready for startup. For scheduled cold shutdowns, where ample time will be available for testing all the valves identified for the cold shutdown test frequency in the IST program, exceptions to the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> requirement may be taken.

b. .The completion of all valve testing is not a prerequisite to return to power.

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c. All testing not completed during a cold shutdown should be performed during subsequent cold shutdowns that may occur before refueling outages thereby meeting as closely as possible the Code specified

- testing frequencies.

Application of Appendix J Testing to the IST Program The Appendix J program for ANO 2 is separate from the IST program.

However, should the Appendix J program be amended, the licensee has agreed to make a corresponding amendnent to the IST program as necessary.

Containment Isolation Valve Leak Test Requirements All containment isolation valves that are Appendix J, Type C, leak tested

should be included in the IST program as Category A or A/C valves. The i NRC has concluded that the applicable leak test procedures and l requirements for containment isolation valves are determined by

[ 10 CFR Part 50, Appendix J. Relief from the Code requirements of Paragraphs IWV-3420(a) through (e) for containment isolation valves presents no safety problem inasmuch as the intent of these Paragraphs is met by the Appendix J requirements. However, a licensee must comply with the analysis of leakage rates and corrective requirements of Paragraphs IWV-3420(f) through (g) unless specific relief is requested from these Paragraphs and subsequently approved by NRC.

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Valves Which Provide Pressure Boundary Isolation Several safety systems connected to the reactor coolant system have design pressures less than the reactor coolant system operating pressure.

Redundant isolation valves within the Class 1 boundary fonning the interface between these high and low pressure systems protect the low pressure systerr.s from exceeding their design limits. The redundant isolation provided by these valves assures that system integrity will be maintained in the event of a single valve failure. The following is a listing of valves that perform a safety-related pressure isolation function.

Valve No. Valve Designation 2CV-5084-1 Low pressure safety injection loop suction 2CV-5086-2 Low pressure safety injection loop suction 2SI-13A High pressure injection check valve 2SI-138 High pressure injection check valve 2SI-13C High pressure injection check valve

.- 2SI-13D High pressure injection check valve .

2SI-14A Low pressure injection check valve 2SI-14B Low pressure injection check valve 2SI-14C Low pressure injection check valve 2SI-14D Low pressure injection check valve 2SI-15A Safety injection combined discharge check valve 2SI-15B Safety injection combined discharge check valve 2SI-15C Safety injection combined discharge check valve 2SI-15D Safety injection combined discharge check valve 2SI-16A Safety injection tank outlet check valve 2SI-16B Safety injection tank outlet check valve 2SI-16C Safety injection tank outlet check valve 2SI-16D Safety injection tank outlet check valve 2SI-27A High pressure injection check valve 2SI-27B High pressure injection check valve 2SI-28A High pressure injection check valve 2SI-288 High pressure injection check valve Check Valve Disassembly to Verify Operability The NRC staff has concluded that a valve sampling disassembly inspection utilizing a manual full stroke of the disc is an acceptable method to verify : che:k V:lve's full stroke capability. The sampling technique requires that each valve in the group must be of the same design (i.e.,

manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disatsembled valve is capable of full stroking

- and that its internals are structurally sound (e.g., no loose or corroded parts).

A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each refueling outage until the entire group has been tested. If it is found that a disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must ce disassembled, inspected, and manually full-stroked at the same outage.

Following successful disassembly, inspection, and manual full-stroking of all the check valves in a group, a licensee may submit a relief request to the NRC requesting the lengthening of the surveillance frequency. This relief request should sununarize all pertinent maintenance data obtained on each valve. Photographs are requested of a valve's "as-found" internals, if any particular anomalies are encountered.

Valves Identified for Cold Shutdown Exercising It should be noted that NRC differentiates, for valve testing purposes.

-. between the cold shutdown mode and the refueling mode. That is, for

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valves identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and during refueling outages. However, when relief is granted to perform tests on a refueling outage frequency, testing is not required during cold shutdowns.

In addition, for extended refueling outages, tests perfonned are expected to be maintained as closely as practical to the Code specified frequencies.

The Code (Subsection IWV-3410(b)(1)) permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operations. The licensee has specifically identified such valves and is full-stroke exercising these valves during cold shutdowns and refueling outages. Since the licensee is meeting the requirements cf the Code, it is not necessary to grant relief for these valves. The valves which have been classified as Category A, B, or C and that are impractical to exercise every 3 months during power operation are identified below along with a brief explanation of the bases for unfeasibility.

a. Chilled Water The chilled water containment isolation valves designated 2CV-3850, 2CV-3851, and 2CV-3852 are Category A valves that cannot be exercised during power operation since closing them would isolate the cooling water to the control element drive mechanisms. The control element drive mechanisms would have to be deenergized to prevent damage from overheating during periods without cooling, and deenergization of the control element drive mechanisms would result in reactor shutdown.

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b. Steam Generator Secondary 1 The main steam isolation valves designated 2CV-1010 and 2CV-1060 are Category B valves that cannot be full-stroke exercised during power operation since a turbine and reactor trip would occur.

Consequently, these valves will be partial stroked during power operation and will be full stroked during cold shutdowns.

The feedwater to steam generator isolation valves designated 2CV-1024 and 2CV-1074 are Category B valves that cannot be exercised during power operation since a loss of steam generator level could occur which would then result in a reactor trip.

c. Service Water The auxiliary cooling water supply valves designated 2CV-1425 and 2CV-1427 are Category B valves that cannot be exercised during power operation since closing these valves would isolate the turbine and generator support systems thus resulting in turbine and reactor trip.

- - The cooling tower makeup supply valves designated 2CV-1542 and .

2CV-1543 are Category B valves that cannot be exercised during power operation because such action would isolate makeup to the cooling tower basin, which in turn would cause a loss of condenser vacuum resulting in a subsequent turbine and reactor trip.

The emergency pond makeup supply valves designated 2CV-1541 and 2CV-1560 are Category B valves that cannot be exercised during power operation because such action would divert service water makeup from the cooling tower basin causing a loss of condenser vacuum and a subsequent turbine and reactor trip.

d. Chemical and Volume Control The charging pump suction (from the volume control tank) valve designated 2CV-4823 is a Category B valve that cannot be exercised during power operation because a loss of suction would damage the charging pumps and result in a loss of pressurizer level with an ultimate reactor trip ensuing.

The charging pump suction (from the refueling water storage tank) valves designated 2CV-4950 and 2CVC-70 are Category B and C valves, respectively, that cannot be exercised during power operation without overborating the reactor coolant system resulting in reactor shetdown.

The charging pump suction (from the boric acid makeup tanks) valves designated 2CV-4920, 2CV-4921, and 2CVC-58 are Category B, B, and C 4

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I valves, respectively, that cannot be exercised during power operation without overborating the reactor coolant system resulting in reactor shutdown.

The charging pump discharge (to the reactor coolant system) valves designated 2CVC-28B and 2CVC-28C are Category C valves that cannot be exercised closed during power operation because such action would subject the charging line nozzles to thermal shock at the reactor coolant system connection points upon reopening of the valves.

e. Safety Injection The shutdown cooling (from the reactor coolant system) valves designated 2CV-5084 and 2CV-5086 are Category B valves that cannot be exercised during power operation. This is because there are no

< provisions for monitoring the pressure on the low pressure side of thesevalves;therefore,exercisingcouldresultinthelowpressure injection system being overpressurized. However, we disagree with the licensee's categorization of these valves as Category B valves.

This is because seat leakage in these valves is not inconsequential because they provide a pressure boundary isolation function for the

1. reactor coolant system. Therefore, they must be categorized as -

3 Category A valves.

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f. Heating, Ventilating, and Air Conditioning of the Containment

• Building The containment building purge valves designated 2CV-8284, 2CV-8286, 2CV-8289, and 2CV-8291 are Category A valves that cannot be exercised during power operation in accordance with requirements from NUREG-0737, " Clarification of TMI Action Plan Requirements."

3.3 Chilled Water 3.3.1 Relief Request 4

The licensee has requested relief from exercising the primary containment isolation valve designated 2AC-49, a Category A/C valve, in accordance with the Section XI requirements.

Basis for Requestirg Relief This check valve can be shown open by the known flow of chilled water to the control element drive mechanisms. The licensee has proposed to exercise this valve open quarterly and closed during refueling outages.

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Evaluation The safety function of this valve is to provide containment isolation.

The licensee has stated that there are no installed test provisions available for this valve and that closure can only be verified during Appendix J 1eak rate testing. Accordingly, we believe that exercising this valve in accordance with the Section XI requirements is impractical.

The licensee's proposed alternative testing frequency is sufficient to demonstrate proper valve operability. Therefore, the requested relief is granted.

3.4 Containment Spray 3.4.1 Relief Request The licensee has requested relief from exercising containment spray -

discharge header check valves designated 2BS-5A and 285-5B, Category A/C valves, in accordance with the Section XI requirements.

Basis for Requesting Relief 3 These valves cannot be full-stroke exercised without spraying down the -

containment building. Consequently, AP&L proposed (Ref. 3) to open and full stroke these valves manually during the third refueling outage.

Assuming both valves prove to be operable during the third refueling outage, then AP&L proposed to manually full stroke one valve during each refueling outage thereafter, alternating between the two valves.

Evaluation The licensee has demonstrated that full or partial-stroke exercising these valves during power operation or cold shutdown would result in spraying i the containment, with possible damage to plant equipment. We believe that manually full-stroke exercising these valves during refueling outages is consistent with present NRC positions and is an acceptable alternate testing method that will yield reasonable assurance of valve operability as intended by the Code. Furthermore, we believe that the proposed surveillance frequency for testing each valve during every other refueling outage is acceptable; however, AP8L should disassemble, inspect, and full stroke both valves at any time that one valve is found unacceptable unless a common-mode failure mechanism can be definitely dismissed. We, therefore, i grant the requested relief.

l In discussion (Ref. 6) with the licensee subsequent to the third refueling outage, we inquired as to the results of the testing performed on valves 2BS-SA and 28S-58. We were inforced that due to personnel changes made during the conduct of the IST program some scheduled valve testing was inadvertently omitted and valve 2BS-5B was among the valves not tested.

Valve 2BS-5A, however, was tested and found acceptable. We were also informed that the NRC would be formally notified of this deviation from a commitment.

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Basis for Requesting Relief Due to the size and function of these valves, they are partial flow-stroked monthly but never full-flow stroked. The licensee has stated that full flow-stroke exercising these check valves during power operation or cold shutdown is impractical inasmuch as this would require the simultaneous operation of one high pressure safety injection pump, one low pressure safety injection pump, and one containment spray pump at design accident flow rates. Therefore, as an alternate means of full-stroke exercising these valves, AP&L proposed to manually full-stroke exercise both valves during the third refueling outage; and, if both valves prove operable, AP&L will then manually full-stroke exercise one valve each subsequent refueling outage, alternating between the two valves.

Evaluation L'e agree with the licensee that full-stroke exercising these check valves during power operation or cold shutdown is impractical. In addition, we believe that manually full-stroke exercising these two valves in the manner and at the frequency proposed is consistent with current NRC positions and is an acceptable alternate means of demonstrating valve operability satisfying the intent of the Code. Therefore, the requested relief is granted.

However, similar to the evaluation discussion above in Section 3.4.1, valve 2BS-1A was tested during the third refueling outage and found acceptable but valve 2BS-1B was inadvertently omitted from the surveillance. AP&L has agreed (Ref. 6) to formally notify NRC of this deviation from a commitment.

The licensee should full-stroke exercise both valves at anytime that one valve is found unacceptable unless a common-mode failure mechanism can be definitely dismissed.

3.5 Component Cooling Water 3.5.1 Relief Request The licensee has requested relief from exercising primary containment isolation valves designated 2CV-5236, 2CV-5254, and 2CV-5255, Category A valves, in accordance with the Section XI requirements.

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Basis for Requesting Relief These valves cannot be closed during power operation because closure would isolate cooling water flow to the reactor coolant pumps. As an i alternative, AP&L has proposed to full-stroke exercise these valves during

cold shutdowns when the reactor coolant pumps are not running and during refueling outages.

Evaluation The safety position of these valves is closed in order to provide containment isolation. Inasmuch as valve closure would secure cooling water to reactor coolant pumps, which must be running during power operation, we conclude that it is impractical to exercise these valves at times other than those proposed by AP&L. Consequently, the requested relief is hereby granted.

3.5.2 Relief Request

. The licensee has requested relief from exercising the primary containment .

. isolation valve designated 2CCW-38, a Category A/C valve, in accordance

, with the Section XI requirements.

Basis for Requesting Relief This check valve is known to be in an open position by the normal flow of component cooling water to the reactor coolant pumps. The safety position of this valve is closed to perform a containment isolation function.

However, a leak rate test is required to verify closure and this test would secure reactor coolant pump cooling. As an alternate test, AP&L has proposed to exercise this valve open on a quarterly basis and closed during refueling outages.

Evaluation We agree with the licensee that the exerscing requirements of Section XI is impractical in that they would result in securing of cooling water to reactor coolant pumps, which must be running during power operation. We i conclude that the licensee's proposed alternate testing will enable

verification of the valve's operability; therefore, the requested relief is granted.

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3.6 Main Steam 3.6.1 Relief Request

! The licensee has requested relief from stroke timing the emergency feedwater pump turbine governor valve designated 2K3, a Category B valve, in accordance with the Section XI requirements.

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Basis for Reauesting Relief This valve is a modulating valve; consequently, stroke time is not an appropriate reference parameter. Proper valve operation is verified through normal system operation during the emergency feedwater test.

Evaluation The licensee has stated that stroke timing this modulating control valve will not provide meaningful data on valve degradation. We disagree. This valve is an active valve and its position may be required to change within a specified time period during the course of an accident. Therefore, we require that stroke timing measurements be performed per the Code requirements on this vahe to assure that its actual stroke time does not exceed its limiting stroke time. Based on the above consideration, relief as requested is denied. Consequently, AP&L should follow the ASME Boiler and Pressure Vessel Code for testing requirements applicable to this valve.

3.6.2 Relief Request The licensee has requested relief from exercising the emergency feed pump -

turbine trip throttle valve designated 2CV-0336, a Category B valve, in accordance with the requirements of Section XI.

Besis for Requesting Relief This valve is in its safety-related position and is not required to open or close to mitigate the consequences of an accident. Therefore, the operability of this valve is inconsequential with regard to the safety function it perfonns.

Evaluation We agree with the licensee's basic and conclude that quarterly stroke and stroke time measurements would be impractical in that they are meaningless.

The requested relief is thus granted.

3.7 Emergency Feedwater 3.7.1 Relief Request The licensee has requested relief from exercising the turbine driven emergency feedwater pump discharge stop check valve designated 2EFW-4A, a Category C/E valve, in accordance with the requirements of Section XI.

Basis for Requesting Relief The only practical method available to stroke this valve is with flow from the pump; however, during cold shutdown and refueling outages, there is no

. l steam available to run the turbine driven emergency feedwater pump. The licensee has proposed to full-stroke exercise this valve during power operation on a quarterly basis.

Evaluation We agree with the licensee that it is impractical to test this valve during cold shutdown or refueling outages due to lack of steam and conclude that the alternate test will adequately demonstrate proper valve operability. Consequently, the requested relief is hereby granted.

3.7.2 Relief Requested The licensee has requested relief from exercising the emergency feedwater pump suction (from the service water system) valves designated 2EFW-2A and 2EFW-28, Category B/C valves, in accordance with the requirements of Section XI.

Basis for Requesting Relief

. Full-stroke exercising of these valves would be detrimental to secondary plant chemistry. Therefore, AP&L has proposed to manually full-stroke exercise one of these valves each refueling outage, alternating between the two valves.

Evaluation We agree with the licensee's basis that partial or full-stroke exercising of these valves during power operation or cold shutdowns would be impractical in that they would create a chemical imbalance in the secondary coolant. We, furthermore, agree that manual stroking will serve as an acceptable means of determining valve operability. Therefore, the requested relief is granted. However, should the licensee determine as a result of testing one valve during a refueling outage that it is not performing acceptably, then the other valve should be tested also unless a common-mode failure mechanism can be definitely dismissed.

3.8 Steam Generator Secondary Side 3.8.1 Relief Reouest The licensee has requested relief from the exercising requirements of Section XI for the steam supply (to the emergency feedwater pump turbine) valves designated 2MS-39A and 2MS-39B, Category 8/C valves.

Basis for Requesting Relief These valves are located in the steam supply lines to the emergency feedwater pump turbine. The only method available to stroke these valves

- open is with steam flow to the turbine. However, during cold shutdown and refueling outages, there is no steam available to run the emergency feedwater pump. Consequently, the licensee has proposed to exercise these valves to the open position only during power operation.

Evaluation We agree with the licensee thta the exercising requirements of Section XI for these valves are impractical. In addition, we agree with AP&L's proposed testing scheme; however, AP&L has not proposed a testing frequency so we will require that the testing frequency be every three months (according to IWV-3520(a)) and it is understood that the testing is to be conducted only during power operation. Relief is thus granted.

Additionally, these two valves perform a safety function in the closed position by preventing flow between steam generators following a main ream of the main steam isolation valves. The steam licenseeline hasbreak ups[d to specify an exercise frequency for positive neglectE verification of check valve closure. This issue was discussed (Ref. 6) with the licensee. From that discussion and in accordance with IWV-3520(b)(1), it is our understanding that partial valve disassembly to

1. inspect the configuration of the internals is necessary in order to verify y closure. It is our position that the frequency for closure operability

. ~ verification should be one valve inspection each refueling outage, alternating between the valves. And, as stated previously, if the -

licensee determines that one valve perfonnance is unacceptable, then the other valve shall be tested during that refueling outage unless a common-mode failure mechanism can be definitely dismissed.

3.9 Service Water 3.9.1 Relief Request The licensee has requested relief from the exercising requirements of f

Section XI for the cooler isolation valves designated 2CV-1401, 2CV-1402, 2CV-1403, 2CV-1404, 2CV-1405, 2CV-1407, 2CV-1408, 2CV-1409, 2CV-1445, 2CV-1446, 2CV-1447, 2CV-1448, 2CV-1450, 2CV-1451, and 2CV-1452, Category B i valves.

Basis for Requesting Relief i

! These valves are passive, normally open valves that are not required to change position in the event of an accident.

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! Evaluation We agree with the licensee's basis and conclude that the exercising i requirements of Section XI for these valves are impractical in that tests

! perfonned to assure te operability of these valves are meaningless.

l Therefore, the requested relief is granted. However, the position of i these valves should be verified quarterly and each time the valves are cycled.

3.9.2 Relief Request The licensee has requested relief from the stroke timing requirements for the control room emergency condensing unit supply valves designated 2CV-1506 and 2CV-1509, Category B valves.

Basis for Recuesting Relief These valves are modulating control valves not designed to be operated full travel; consequently, stroke time is not an appropriate reference parameter. The valve circuitry does not allow an instantaneous comand to open or close in order to pemit stroke time measurement. Proper valve operation is verified through nonnal system operation.

Evaluation The licensee has stated that stroke timing these modulating control valves would be impractical in that they will not provide meaningful data on valve degradation. The most practical means for ensuring valve operability is simply through the monthly verification of proper system operation.

Based on the above considerations, relief as requested is granted. .

3.10 Fire Water 3.10.1 Relief Request The licensee has requested relief from the exercising requirements of Section XI for the primary containment isolation valve designated 2FS-37, a Category A/C valve.

_ Basis for Requesting Relief This check valve can be verified open by the flow of fire water to the containment fire protection systems during quarterly testing. To verify closure, an Appendix J type of leak rate test is required. Consequently, AP&L has proposed as alternate testing to exercise this valve closed during refueling outages.

Evaluation The safety position of this valve is closed to perform a containment isolation function. The only practical means for verifying valve closure is via leak rate testing. We conclude that the alternate testing proposed will provide reasonable assurance of valve operability intended by the Code. Therefore, the requested relief is granted.

4E

_ 17 _

3.11 Reactor Coolant 3.11.1 Relief Requested The licensee has requested relief from the Section XI exercising requirements for the primary containment isolation valve designated 2CVC-78, a Category A/C valve.

Basis for Requesting Relief This check valve is known to be open by the normal flow of reactor makeup water to the quench tank. To verify closure, an Appendix J type of leak-rate test is required. Consequently, AP&L has proposed a5 alternate testing to exercise this valve open quarterly and closed during refueling outages.

Evaluation The safety position of this valve is closed to perform a containment isolation function. The only practical means for verifying valve closure is via leak rate testing. We conclude that the alternate testing proposed will provide reasonable assurance of valve operability intended by the -

Code. Therefore, the requested relief is granted.

3.11.2 Relief Requested The licensee has requested relief from the Section XI exercising requirements for the pressurizer atmospheric vent valves designated 2CV-4697 and 2CV-4698, Category B valves.

Basis for Requesting Relief These valves cannot be exercised during power operation or cold shutdown because their opening would vent radioactive gas and contaminated water to the containment atmosphere. Such action would generate large amounts of radioactive waste and require extensive cleanup. Therefore, AP&L has proposed to exercise these valves during refueling outages.

Evaluation We agree with the licensee that exercising these valves during power operation or cold shutdown is impractical in that their opening would generate an excessive amount of waste and that testing these valves during refueling outages is a reasonable alternative. The requested relief is thus granted.

18 - ,

, 3.11.3 Requested Relief The licensee has requested relief from the full-stroke exercising requirements of Section XI for the high pressure injection -(to the reactor coolant system hot leg check valves) valves designated 2SI-27A, 2SI-278, l .

2SI-28A, and 2SI-288, Category A/C valves.

Basis for Requesting Relief These valves cannot be full-stroke exercised during power operation because the high pressure injection pumps' maximum discharge pressure is less than the reactor coolant system pressure during power operation.

Also, full-stroke exercising during cold shutdown is not feasible because the reactor coolant system does not have an adequate expansion volume to j accommodate the large volume of water required for full-stroke exercising.

Moreover, full-stroke exercising at cold shutdowns could exceed the i

reactor vessel pressure-temperature limitations. Consequently, AP&L has

proposed to full-stroke exercise these valves during refueling cutages.

Evaluation 1

Inasmuch as the . .ensee has demonstrated that the reactor vessel head must be removed to test these valves, we conclude that the only practical time for testing these valves is during refueling outages. Therefore, the j requested relief is granted.

3.12 Chemical and Volume Control

3.12.1 Relief Requested The licensee has requested relief from the Section XI exercising

! requirements for the reactor coolant pump seal water containment isolation valves designated 2CV-4846 and 2CV-4847, Category A valves.

i Basis for Requesting Relief l These valves cannot be closed during power operation because closure would isolate seal water leakoff from the reactor coolant pumps, an action which l

would require stopping the pumps and shutting down the reactor. As an alternative, AP&L has proposed to full-stroke exercise these valves during cold shutdowns when the reactor coolant pumps are not operating and during j refueling outages.

{ Evaluation i

!' The safety position of these valves is closed in order te provide containment isolation. The licensee has demonstrated that valve closure

, would result in reactor shutdown. Therefore, we agree 'vith the licensee's basis that testing is only practical when the reactor r,oolant pumps are j secured. Consequently, the requested relief is granted.

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1 3.13 Safety Injection 3.13.1 Relief Request The licensee has requested relief from the Section XI full-stroke exercising requirements for the high pressure injection valves designated

- 2SI-13A, 2SI-13B, 2SI-13C, 2SI-13D, 2SI-26A, and 2SI-268, Category A/C val ves.

Basis for Requesting Relief i

These valves cannot be full-stroke exercised during power operation because the high pressure injection pumps' maximum discharge pressure is less than the reactor coolant system pressure during normal operation.

Also, full-stroke exercising during cold shutdown is not feasible because the reactor coolant system does not have adequate expansion volume to acconnodate the large volume of water required for full-stroke exercising.

Moreover, full-stroke exercising at cold shutdowns could exceed the 4

reactor vessel pressure-temperature limitations. Consequently, AP&L has proposed to full-stroke exercise these valves during refueling outages. .

Evaluation Inasmuch as the licensee has demonstrated that the reactor vessel head must be removed to test these valves, we conclude that the only practical time for testing these valves is during refueling outages. Therefore, the requested relief is granted.

3.13.2 Relief Request The licensee has requested relief from the Section XI requirements for leak-rate testing of the safety injection check valves designated 2SI-13A, 251-138, 2SI-13C, 2SI-13D, 2SI-14A, 2SI-148, 2SI-14C, 2SI-140, 2SI-15A, 2SI-158, 2SI-15C, 2SI-15D, 2SI-26A, and 2SI-268, Category A/C valves.

Basis for Requesting Relief The absence of isolation valves on the downstream side of the safety injection check valves does not allow individual leak-rate testing of f

these valves. The licensee has proposed to monitor pressure on the low pressure side of these valves to assure valve integrity. Specifically, the low pressure side of valves 2SI-15A, 2SI-158, 2SI-15C, and 2SI-15D is continuously monitored in the control room to detect back leakage from the reactor coolant system to the common high-pressure / low-pressure discharge lines. Also, the low pressure side of valves 2SI-13A, 2SI-138, 2SI-13C, and 2SI-13D and 2SI-26A and 2SI-26B are monitored for back leakage by two other pressure detectors. These two latter detectors are monitored on an eight hour frequency.

Evaluation We conclude that due to the absences of isolation valves on the downstream side of the safety injection check valves, leak-rate testing in accordance with the Section XI requirements is impractical. We furthennore conclude that AP&L's proposal to monitor the low pressure side of these valves for indication of back leakage continuously or on a frequency not to exceed once every eight hours is an acceptable means for satisfying the intent of the Code for leak-rate testing. Therefore, the requested relief is granted.

3.13.3 Relief Request The licensee has requested relief from the Section XI requirements for exercising the primary containment isolation valve designated 2SI-17, a Category A/E valve.

Basis for Requesting Relief

'. This valve is nonnally closed and passive during power operation. The ,

safety function of this valve is to remain closed during an accident.

Evaluation This valve is not required to change position in order to mitigate an accident. We, therefore, conclude that the quarterly stroke and stroke-time measurements are impractical in that they are meaningless for this valve. The requested relief is thus granted. However, the position of this valve should be verified quarterly and each time the valve is cycled.

3.13.4 Relief Request The licensee has requested relief from the Section XI full-stroke

! exercising requirements for the safety injection tank outlet check valves designated 2SI-16A, 2SI-16B, 2SI-16C, and 2SI-16D, Category B/C valves.

Basis for Requesting Relief The safety injection tank check valves cannot be full-stroke exercised during power operation due to the pressure differential between the reactor coolant system and the safety injection tanks. Consequently, as an alternate means of full-stroke exercising these valves, AP&L has proposed to manually full-stroke exercise all four valves during the third refueling outage; and, if all valves prove operable, AP&L will then open and manually full-stroke exercise two of the valves each subsequent refueling outage, alternating among the four valves.

. 4t Evaluation We believe that the exercising requirements of Section XI for these valves are impractical in that they can not be full-stroke -exercised during power operation due to the pressure differential between the reactor coolant system and the safety injection tanks. In addition, we believe that manually full-stroke exercising these four valves at the frequency proposed is consistent with current NRC positions and is an i acceptable alternate means of demonstrating valve operability satisfying the intent of the Code. Therefore, the requested relief is granted.

l However, similar to the evaluation discussions above in Sections 3.4.1 and 3.4.2, valves 2SI-16A and 2SI-16B were tested during the third refueling

, outage and found acceptable but valves 2SI-16C and 2SI-16D were inadvertently omitted from the surveillance. Similar to the evaluation

-discussions above in Sections 3.4.1 and 3.4.2, this deviation from a

, comitment will be fbrmally reported to NRC.

The licensee should full-stroke exercise all valves at anytime that one valve is found unacceptable unless a comon-mode failure mechanism can be

[ -definitely dismissed. -

,. . Additionally, we disagree with the licensee's categorization of these l valves as Category B/C valves. This is because seat leakage in these -

valves is not inconsequential because they provide a pressure boundary isolation function for the reactor coolant system. Therefore, they must be categorized as Category A/C valves.

3.13.5 Relief Request The licensee has requested relief from the Section XI requirements ?or full-stroke exercising the high pressure injection pump check valves designated 2SI-7A, 2SI-78, and 2SI-12, Category B, B, and C valves respectively. ,

Basis for Requesting Relief These valves cannot be full-stroke exercised during power operation because the high pressure injection pumps' maximum discharge pressure is less than the reactor coolant system pressure during normal operation.

Also, full-stroke exercising during cold shutdown is not feasible because the reactor coolant system does not have adequate expansion volume to accomodate the large volume of water required for full-stroke exercising.

Moreover, full-stroke exercising at cold shutdowns could exceed the reactor vessel pressure-temperature limitations. Consequently, AP&L has proposed to full-stroke exercise these valves during refueling outages.

Evaluation Inasmuch as AP&L has demonstrated that the reactor vessel head must be removed to full-stroke exercise these valves, we conclude that the only practical time for testing these valves is during refueling outages. '

Therefore, the requested relief is granted.

- 3.13.6 Relief Request The licensee has requested relief from the Section XI requirements for full-stroke exercising the high pressure injection pump discharge stop check valves designated 2SI-10A, 2SI-108, and 2SI-10C, Cate' gory C/E valves.

Basis for Requesting Relief These valves cannot be full-stroke exercised during power operation because the high pressure injection pumps' maximum discharge pressure is less than the reactor coolant system pressure during normal operation.

Also, full-stroke exercising during cold shutdown is not feasible because the reactor coolant system does not have adequate expansion volume of water required for full-stroke exercising. Moreover, full-stroke exercising at cold shutdowns could exceed the reactor vessel pressure-temperature limitations. Consequently, AP&L has proposed to full-stroke exercise these valves during refueling outages.

Evaluation e ~

Inasmuch as AP&L has demonstrated that the reactor vessel head must be removed to full-stroke exercise these valves, we conclude that the only practical time for testing these valves is during refueling outages.

Therefore, the requested relief is granted.

3.13.7 Relief Request The licensee has requested relief from the Section XI requirements for exercising the low pressure safety injection check valves designated 2SI-14A, 2SI-148, 2SI-14C, and 2SI-14D, Category A/C valves.

Basis for Requesting Relief These valves can only be flow exercised by use of the low pressure injection system, which canr.ot be utilized during power operation because the maximum discharge pressure of the low pressure injection pumps is less than the reactor coolant system pressure during normal operation. Also, flow exercising during cold shutdowns is not feasible because such exercising might result in exceeding the reactor vessel pressure-temperature limitations. Consequently, AP&L has proposed to full flow-stroke exercise these valves each refueling outage.

Evaluation We conclude that it is impractical to test these valves at times other than refueling outages when the reactor vessel head is removed. The requested relief is thus granted.

( 3.13.8 , Relief Requested The licensee has requested relief from the Section XI requirements for exercising the cold leg safety injection check valves designated 2SI-15A, 2SI-158, 2SI-15C, and 2SI-15D, Category A/C valves.

Basis for Requesting Relief The licensee has proposed to full flow-stroke exercise these valves during each refueling outage by use of the low pressure injection pumps. The safety injection system cannot be used during power operation because the maximum discharge pressure of the low pressure injection pumps is less than the reactor coolant system pressure during normal operation. Also, full-flow exercising of these valves during cold shutdowns is inadvisable because such exercising could result in exceeding the reactor vessel pressure-temperature limitations.

Evaluation We agree with the licensee's proposed frequency for testing these valves.

However, we questioned (Ref. 6) the licensee on the hydraulic capacity of ~

the low pressure injection system (six-inch lines) to full flow-stroke exercise these check valves (12-inch valves). The licensee stated that the required testing was attempted during the third refueling outage, but that there was insufficient flow to permit a full stroke. Consequently, the licensee has informally proposed to continue partially stroking these valves at each refueling outage and to estimate the degree of stroking from the known flow rate.

We find that full-stroke exercising of these valves is not practical and that the licensee's alternate testing that has been informally proposed to be acceptable as an adequate method of demonstrating valve operability.

Similar to the evaluation discussions above in Sections 3.4.1, 3.4.2, and 3.13.4, this deviation from a commitment will be fonnally reported to NRC.

3.14 Service Air 3.14.1 Relief Request The licensee has requested relief from the Section XI exercising requirements for the primary containment isolation valve designated 2SA-69, a Category A/E valve.

Basis for Requesting Relief The safety position of this valve during an accident is clcsed. The valve is passive and normally closed during power operation. Consequently, it's operability is inconsequential with respect to accident mitigation.

Evaluation Based on the above discussion, we conclude that the quarterly stroke and stroke-time measurements are impractical in that they are meaningless for 2SA-69. The requested relief is therefore granted. However, the position of this valve should be verified quarterly and each time the valve is cycled.

3.15 Instrument Air 3.15.1 Relief Request The licensee has requested relief from the Section XI requirements for primary containment isolation valve 2IA-14, a Category A/E valve.

~

Basis for Requesting Relief The safety position of this valve during an accident is closed. The valve is passive and normally closed during power operation. Consequently, its operability is inconsequential with respect to accident mitigation.

Evaluation Based on the above discussion, we conclude that the quarterly stroke and stroke-time measurements are impractical in that they are meaningless for 2IA-14. The requested relief is therefore granted. However, the position of this valve should be verified quarterly and each time the valve is closed.

3.16 Heating, Ventilating, and Air Conditioning 3.16.1 Relief Request The licensee has requested relief from the Section XI exercising requirements for the primary containment isolation valves designated 2HPA-58 and 2HPA-59, Category A/C valves.

Basis for Requesting Relief To verify closure of these check valves, a leak-rate test is required.

Consequently, AP&L has proposed as alternate testing to exercise these valves closed during refueling outages.

. Evaluation The safety position of these valves is closed to perform a containment isolation function. Inasmuch as there are no installed test provisions available for these valves, the exercise requirements of Section XI for these valves are impractical in that closure can only be verified via leak rate testing. We conclude that the alternate testing proposed will provide reasonable assurance of valve operability intended by the Code.

Therefore, the requested relief is granted.

3.17 Plant Heating 3.17.1 Relief Request ,

The licensee has requested relief from the Section XI exercising requirements for the primary containment isolation valves designated 2PH-22 and 2PH-45, Category A/E valves.

Basis for Requesting Relief e The safety position of these valves during an accident is closed. These -

valves are passive and normally closed during power operation.

. Consequently, their operability is inconsequential with respect to accident mitigation.

Evaluation Based on the above discussion, we conclude that the quarterly stroke and stroke-time measurements are impractical in that they are meaningless for 2PH-22 and 2PH-45. The requested relief is therefore granted. However, the position of these valves should be verified quarterly and each time the valves are cycled.

3.18 Fuel Pool 3.18.1 Relief Request The licensee has requested relief from the Section XI exercising requirements for the primary containment isolation valves designated 2FP-34, 2FP-35, 2FP-36, and 2CV-5432, Category A/E valves.

Basis for Requesting Relief The safety position of these valves during an accident is closed. These valves are passive and normally closed during power operation.

Consequently, their operability is inconsequential with respect to accident mitigation.

i Evaluation Based on the above discussion, we conclude that the quarterly stroke and stroke-time measurements are impractical in that they are meaningless for 2FP-34, 2FP-35, 2FP-36, and 2CV-5432. The requested relief is thus granted.

However, the position of these valves should be verified quarterly and each time the valves are cycled.

4.0 gnclusions .

The licensee has submitted information to support determinations that certain ASME Section XI Code requirements for Inservice Testing are impractical to implement at the Arkansas Nuclear One, Unit 2 plant. The staff has evaluated the licensee's bases for these determinations and found that relief from specific Code requirements requested may be granted for the reasons given in the evaluation discussions of this document.

The results of the staff's review indicate that all appropriate safety-related pumps and valves are now included in the IST program, except those in the diesel generator auxiliary systems (i.e., the diese,1 generator fuel oil storage and transfer system, the diesel generator cooling water system, the diesel generator starting system, the diesel generator lubrication system, and the diesel generator combustion air intake and exhaust system). The staff recognizes the potential for certain Code test requirements to be impractical for some of these components and the existence of adequate alternate surveillance testino.

However, the staff position is that all safety-related pumps and valves in these systems be included in the IST program. The staff has discussed this need with AP&L personnel.

The amended program, along with any additional requests for relief, should be submitted to the NRC no later than 12 months from the date of issuance of this safety evaluation report. The staff concludes that allowing 12 months provides adequate time for proper program development and implementation and does not increase the probability or consequences of accidents or decrease the existing operational safety margin as identified in the Basis to the Technical Specifications. The rationale for this detemination is that most inservice testing activities required by the Code are in addition to other surveillance requirements identified in the Technical Specifications. As such, the formal IST program upgrades the operational surveillance program and further improvements in it will enhance safety.

Based on the foregoing, the staff has found, pursuant to 10 CFR Part 50.55a(g)(6)(i), that the relief requested excluding the relief request of SER Section 3.6.1 is authorized by regulations, will not endanger life or property or the common defense and security of the public, and is in the public interest considering the burden on the licensee that could result if the reliefs were not granted.

Date: June 20, 1985 Principal NRC Contributor: Dale A. Powers

5.0 References

1. Letter from D. H. Williams (AP&L) to J. F. Stolz (NRC), " Inservice  !

Testing," Docket No. 50-368, June 15, 1978. l 1

2. Letter from D. C. Trimble (AP&L) to R. A. Clark (NRC), " Inservice Testing Program," Docket No. 50-368, October 29, 1980.

3. Letter from J. R. Marshall (AP&L) to R. A. Clark (NRC), " Request for Additional Information Concerning the Inservice Testing Program for Arkansas Nuclear One, Unit 2," Docket No. 50-368, December 10, 1982.

~

4. Letter from R. W. Reid (NRC) to W. Cavanaugh, III (AP&L), Docket 50-368, September 21, 1979.

5. EG&G Report No. EGG-EA-6313. " Safety Evaluation P,eport, Pump and Valve Unit 2," by Inservice H. C. Rockhold Testing Program, and H. M. Stromberg, Arkansas Nuclear One, 'I July 1983.

6. Telecommunication .Fetween D. A. Powers and R. Lee (NRC) with D. Taylor and S. McGregor (AP&L), December 18, 1984 l 3

3

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6.0 Appendix - Piping & Instrumentation Drawings Reviewed System Number Revision Main steam sht-2 M-2102 21 Emergency feedwater sht-4 M-2204 12 Steam generator secondary M-2206 23 Service water sht-1 M-2210 17 Service water sht-2 M-2210 17 Service water sht-3 M-2210 17 Liquid radioactive waste sht-1 M-2213 20 Boron management sht-1 M-2214 22 Gaseous radioactive waste M-2215 17 Service air sht-1 M-2218 15 Instrument air sht-2 M-2218 13 Instrument air sht-3 M-2218 5 Fire water sht-2 M-2219 6 Plant heating sht-1 M-2220 20 Chilled water sht-1 M-2222 20 Reactor coolant M-2230 22 Chemical and volume control sht-1 M-2231 26 Chemical and volume control sht-2 M-2231 24 Safety injection M-2232 24 Component cooling water M-2234 21

-. 24 Fuel pool M-2235 Containment spray M-2236 25 Sampling system sht-1 M-2237 14 Reactor coolant pump connections M-2238 14 Hydrogen and nitrogen addition sht-1 M-2239 13 Heating, ventilating, and air conditioning-- M-2261 18 ~

containment building sht-1 Heating, ventilating, and air conditioning-- M-2261 10 containment building sht-2 Post accident hydrogen analysis sht-3 M-2261 8 Containment penetration rooms ventilation M-2264 10

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