ML20148A942

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Forwards Summary of Changes Highlighting Revs Made to Third Ten-Yr Interval Unit 1 IST Program.Issue 3,Rev 0 of Unit 1 Program for Pumps & Valves & Set of Drawings Referred to as Valve Operating Number Diagrams for Unit 1,encl
ML20148A942
Person / Time
Site: Beaver Valley
Issue date: 04/30/1997
From: Jain S
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20148A946 List:
References
NUDOCS 9705090174
Download: ML20148A942 (12)


Text

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Beaver Valley Power Station

, Shippingport. PA 150's.'-0004 SUSHIL C.JAIN (412) 393-5512 DMalon Vice President Fax (412) 643 8069

""Ir ucie *o*Nomsion April 30, 1997 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Ber.er Valley Power Station, Unit No.1 Do ken No. 50-334, License No. DPR-66 Insw. ice Testing Program Ten-Year Update l The purpose of this submittal is to fonvard to the Nuclear Regulatory Commission the Beaver Valley Power Station Unit No. I updated Inservice Testing (IST) Program.

This program is applicable for the third Ten-Year Interval update of the IST Program as j required by 10 CFR 50.55a.

Enclosure i provides a summary of changes highlighting the revisions made to the

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third Ten-Year interval Unit No.1 IST Program. Enclosure 2 is Issue 3, Revision 0 of the Unit No.1 IST Program for pumps and valves. Also, included as Enclosure 3 is a set of drawings referred to as valve operating number diagrams for Unit No. I which has the IST components identified by their equipment identificatie numbers. ,

1 Development of this program is based on the American Society of Mechanical Engineers (ASME) / American National Standard Institute (ANSI) Operational and Maintenance (OM) Standard, Part 6," Inservice Testing of Pumps in Light Water Reactor Power Plants" (OM-6), and Part 10, " Inservice Testing of Valves in Light Water Reactor Power Plants" (OM-10), OMa-1988 Addenda to the OM-1987 Edition, in accordance with the ASME Boiler and Pressure Vessel Code (B&PV),Section XI,1989 Edition.

Additionally, the guidance of Attachment I and Supplement 1 of Generic Letter No. 89-04, " Guidance on Developing Acceptable Insenice Testing Programs" has been followed in program development.

This submittal contains eight relief requests for components which cannot be tested in accordance with the above ieferences and, therefore, are submitted as proposed

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! ' Beaver Valley Power Station, Unit No. I

! Insenice Testing Program Ten-Year Update Page 2

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j relief requests under the provisions of 10 CFR 50.55a(a)(3)(i) for which Nuclear j Regulatory Commission approval is required. Several of these relief requests are supported with information describing the determination that conformance with certain  !

l code requirements is impractical per 10 CFR 50.55a(f)(5)(iii). In each case, the l proposed alternatives to the Code required testing will provide an acceptable level of j quality and safety as described in the specific relief requests.

j The current Ten-Year IST irt;rval ends September 20,1997. This date follows l

l the start of the Unit No. I twelfth refueling outage which has a start date of September 5, i j 1997. 10 CFR 50.55a(f)(4)(iv) states that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of this section, subject to Commission approval. It is undesirable to change implementing procedures during a refueling outage; therefore, it is requested that the NRC approve implementation of this third interval program earlier than the current interval expiration date. Implementation is requested for September 5, l 1997. This third interval program has been prepared following the requirements of the 1989 Edition of the ASME B&PV Code as stated above which is consistent with 10 CFR 50.55a paragraph (b). The expiration date would remain on the current schedule of O september 20,2007.

If you have any questions regarding this request, please contact Mr. J. Arias at (412) 393-5203.

Sincerely, Q -L l Sushil C. Jain Enclosures c: Mr. D. M. Kern, Sr. Resident inspector Mr. H. J. Miller, NRC Region 1 Administrator Mr. D. S. Brinkman, Sr. Project Manager O

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i ENCLOSURE 1 t

SUMMARY

OF CHANGES

! THIRD 10 YEAR INTERVAL UNIT 1 IST PROGRAM i

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.. ENCLOSURE 1

SUMMARY

OF CMANGES  :

THIRD 10 YEAR INTERVAL UNIT I IST PROGRAM  ;

O i The third 10-year interval for the BVPS Unit 1 IST Program will begin on September 20,1997.

l The new program is based on the following:  !

e American Society of Mechanical Engineers (ASME) / American National Standards Institute (ANSI) Operational and Maintenance (OM) Standard, Part 6, "Insersice Testing of Pumps in Light Water Reactor Power Plants"(OM-6), and Part 10,

" Inservice Testing of Valves in Light Water Reactor Power Plants" (OM-10), OMa-1988 addenda, in accordance with the ASME Boiler and Pressure Vessel Code Section XI,1989 edition.

  • Generic Letter No. 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," April 3,1989.

. NUREG-1482," Guidelines for Inservice Testing at Nuclear Power Plants," April 1995.

There were significant changes in the regulations between the 1983 edition of the ASME Code, (the present Code in effect) and the 1989 edition (the Code for the new program). These changes necessitated several changes to the IST Program. In addition, to support this 10-year interval O

undete, an iST erosram Besis oecument wes deveieved. The Basis oocument examined everv l Category 1 pump and valve to determine whether it should be included in, or excluded from the IST Program and if the testing performed is adequate. As a result of the review several other changes were also made to IST Program. The following is a summary of all of the changes made j to the Program.

, 1) The following are changes to Section I of the BVPS-1 IST Program " Pump Testing I Requirements." j l a) The new edition and addenda of the Code were referenced. In addition, where IWP or ASME had been referenced. OM-6 is now referenced and the correct tables from OM-6 have been incorporated, b) Specific mention is made that BVP5-1 is licensed Hot Shutdown as its safe shutdown condition. NUREG 1482, Section 2.2 states that this must be documented in the IST Program, because the current scope defined by the Code l includes pumps and valves required to achieve and maintain cold shutdown rather l than safe shutdown.

p l c) A " Cold Shutdown Justification" Section and a " Refueling Outage Justification" Section were added to the IS l' Program for those pumps tested only during cold l

}

l Q shutdowns or refueling outages e permitted by paragraphs 5.3,5.4 or 5.5 of( N-6.

I i

ENCLOSURE 1 i

SUMMARY

OF CHANGES

.O II) The following are changes to Section II of the BVPS-1 IST Program " Pump Outlines."

! a) All of the pump outline sheets were revised to delete the testing requirements for

} suction pressure (Pi), bearing temperature (Tb) and lubricant level observation l (L). OM-6 does not require these parameters to be measured.

b) The Remarks column for all of the pumps was expanded to state how the pump was tested. (i.e., Pump is tested on recire flow quarterly and with full flow during j refueling outages.) Any pump relief requests (PRRs), cold shutdown justifications (PCSJs) and refueling outage justifications (PROJs) that apply are

, also listed.

c) The Comments Column was expanded to include details on how the parameters

! are being measured and to specifically mention the sections of the Code, GL 89-04 and NUREG-1482 that apply.

4

III) Tt
: following are changes to Section III of the BVPS-1 IST Program " Pump Cold Shutdown Justifications."

a) Pump Cold Shutdown Justification No.1 (PCSJ1) was written for the Residual

)O Heat RemovaiPumps, tiRn-P-ix,1B), te documeni that the rumps wiii be tested quarterly during cold shutdowns. This is permitted by OM-6, paragraph

! 5.4," Pumps in Systems Out of Service." This PCSJ is RR4 in the current revision (Issue 2, Rev 14) of the IST Program.

l b) Pump Cold Shutdown Justification No. 2 (PCSJ2) was written for the Auxiliary

Feedwater pumps, [lFW-P-2,3A,3B], to document that the pumps will be tested quarterly on recirculation flow and at full flow during cold shutdowns or on j startup from cold shutdowns ([lFW-P-2] will be tested on start-up from cold l j shutdown), because there is no installed flow instrumentation on the recirc line.

i This is in accordance with GL 89-04, Position 9. This PCSJ is RR8 in the current ,

2 revision (Issue 2, Rev 14) of the IST Program.

IV) The following are changes to Section IV of the BVPS-1 IST Program " Pump Refueling Outage Justifications." I a) Pump Refueling Outage Justification No.1 (PROJ1) was written for the Boric Acid Transfer pumps, [1CH-P-2A,2B] to document that the pumps will be tested quarterly on recirculation flow and at full flow during refueling outages, because there is no installed flow instrumentation on the test line. This is in accordance with GL 89-04, Position 9. This PROJ is RR3 in the current revision (Issue 2.

O Rev 14) of the IST Program.

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ENCLOSURE 1

SUMMARY

OF CIIANGES O b) Pump Refueling Outage Justification No. 2 (PROJ2) was written for the inside Recirculation Spray cumps, [lRS-P-1 A, IB] to document that the pumps will be tested on recirculation flow during 'efueling outages, because a temporary dike must be installed in containment ar nd the sump. This is in accordance with OM-6, paragraph 5.5," Pumps Lackmg Required Fluid Inventory." This PROJ is RR6 in the current revision (Issue 2, Rev 14) of the IST Program.

, c) Pump Refueling Outage Justification No. 3 (PROJ3) was written for the Outside Recirculation Spray pumps, [1RS P-2A,2B] to document that the pumps will be tested on recirculation flow during refueling outages, because in order to test this pump the pump casing must be filled and then drained out after the test, requiring a containment entry. This is in accordance with OM-6, paragraph 5.5," Pumps Lacking Required Fluid Inventory." This PROJ is RR7 in the current revision l (Issue 2 Rev 14) of the IST Program.  !

i l

V) The following are changes to Section V of the BVPS-1 IST Program " Pump Relief  !

Requests."

a) Pump Relief Request No.1 (PRRI) is a new relief request written to allow the use of spectral analysis in lieu of placing a pump on double frequency testing when g the vibration levels are outside the acceptable range. This request is based on a V later edition of the ASME Code; ASME OMc Code-1994, Subsection ISTB, Paragraph 4.6,"New Reference Values," which would allow analysis.

b) Pump Relief Request No. 2 (PRR2) was written for various instruments which do not meet the requirements of OM-6, paragraph 4.6.1.2(a), " Range," however the accuracy of the instruments is more conservative than the requirements of OM-6, ,

paragraph 4.6.1.1," Quality." The combination of higher range and better

. accuracy for each instmment yields a reading at least equivalent to the reading achieved from instruments that meet OM-6. This is in accordance with NUREG-1482, Section 5.5.1," Range and Accuracy of Analog Instruments." This PRR is RR12 in the current revision (Issue 2, Rev 14) of the IST Program. ([FI-lCH-122A] was deleted from the relief request because it is no longer used in pump testing and [F1-lCH-943] was deleted because the test is now performed with the reference flow greater than one third of the range. )

c) Pump Relief Request No. 3 (PRR3) was written for the Component Cooling Water pumps, [lCC-P-1 A,1 B &1C] to allow the use of a pump curve. The basis for this request is NUREG-1482, Section 5.2,"Use of Variable Reference Values for Flow Rate and Differential Pressure During Pump Testing." This PRR is RR11 in the current revision (Issue 2. Rev 14) of the IST Program.

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ENCLOSURE 1 SU51 MARY OF CHANGES O d) Pump Relief Request No. 4 (PRR4) was written for the Diesel Generator Fuel Oil pumps, [1EE-P 1 A,1B. IC &lD) to allow the flow rate to be calculated based on the level change over time in the day tank. The basis for this request is NUREG-1482, Section 5.5.1," Range and Accuracy of Analog Instruments." This PRR is RRIO in the current revision (Issue 2, Rev 14) of the IST Program.

e) The following Relief Requests in the current revision (Issue 2, Rev 14) were deleted:

RR1 - OM-6 allows vibration measurements to be taken in velocity units and does not require bearing temperatures to be taken.

RR2 - NUREG-1482, Section 5.5.3 states that the use of tank level or river elevation to obtain the suction pressure for pump testing is permissible per OM-6.

RR5 & RR9 - OM-6 does not require AP to be measured for positive displacement pumps.

. VI) The following are changes to Section VI of the BVPS-1 IST Program " Pump Minimum Operating Point (MOP) Curves."

a) The MOP Curves for the HHSI pumps, [lCH-P-1 A, IT) & IC), were revised to g incorporate the most current calculation for the pumus (8700-DMC-3072, Rev 1.

V 3/29/96).

b) The MOP Curves for the k!ver Water, [1WR-P-1 A, IB & IC), pumps were revised to incorporate the most current calculation for the pumps (8700 DMC-3136, Rev 0,11/29/96).

c) MOP Curves were added for the Reactor Plant Component Cooling pumps, [lCC-4 P-1 A,1B & IC], based on calculation 8700-DMC-3052, Rev 0,5/14/96.

VII) The following are changes to Section Vl! of the BVPS-1 IST Program " Valve Testing Requirements."

a) The new edition and addenda of the Code were referenced. In addition, where IWV or ASME had been referenced, OM-10 is now referenced and the correct tables from OM-10 have t>een incorporated.

b) Specific mention is made that BVPS-1 is licensed Hot Shutdown as its safe shutdown condition. NUREG-1482. Section 2.2 states that this must be documented in the IST Program. because the current scope defined by the Code includes pumps and valves required to achieve and maintain cold shutdown rathcr than safe shutdown.

Oa

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ENCLOSURE 1

SUMMARY

OF CHANGES i The paragraphs describing the requirements of the Code for valves were revised to c) reflect OM-10. For example, the limits for stroke time testing have been changed

and are now based on a reference or baseline time instead of the previous stroke i time. In addition, double frequency testing has been eliminated and more l

stringent rules for declaring a valve inoperable are included.

- d) Relief valve testing is required to be conducted in accordance with the l requirements of OM-1," Requirements for Inservice Performance Testing of
Nuclear Power Plant Pressure Relief Devices."  :

I e) A " Refueling Outage Justification" Section was added to the IST Program for those valve iested only during refueling outages as permitted by paragraphs 4.2.1.2 and 4.3.2.2 of OM-10.

VIII) The following are changes to Section Vill of the BVPS-1 IST Program " Valve Outlines." i a) The Valve Cold Shutdown Justification, Valve Refueling Outage Justification and l Relief Request Nos, listed were revised to reflect the changes made.

b) The valve type column for the Pressurizer Code Safety Valves and the Main l O Steam Safety Valves was revised to say " Safety"instead of" Relief." In addition.

the test frequency for the safety valves was revised to 5 years and for relief valves to 10 years, per OM-1.

c) As a result of the Basis Document Review, manual valves, [1CH-25,26,27,158,  !

159 & 161], were changed to active valves and a quarterly stroke test was added.

l d) As a result of the Basis Document Review, a full-stroke test in the reverse direction was added for the following check valves: [lCH-75,76], [1S1-83, 84,94

& 95) [lQS-3,4], [1RS-100,101] and [1 AS-278]. A forward direction test for

[lCH-369) was also added. The valves have always been tested, but the test was not listed in the IST Program. i e) As a result of the Basis Document Review, [FCV-1CH-114A] was added to the IST Program'to be stroked and timed quarterly.

I f) The remote position verification (RPV) was deleted from manual valve [lCH-135] because the reach rod for this valve was disconnected.

g) The testing frequency listed for valves that are leak tested, not in accordance mth the Appendix J Program, was revised to 2 years. For PIVs the frequency listed n p -

2 year / CSD or R per Tech Specs. Containment Isolation Valves tested per the d Appendix J Program are tested at the frequency required by Option B of Appendix J. They are listed e a wreaal Frequency (SP)" in the IST Program

ENCLOSURE 1

SUMMARY

OF CHANGES 2

'O In addition, the test requirement for valves tested per the Appendix J Program was

- revised to "LTJ" to differentiate between the various leakage tests perfor
med.

t h) As a result of the Basis Document Review, deleted the following valves from the IST Program: [MOV-1CH-275A, B, C], [1SI-447,448,451,452), [MOV-1SI-( 864A, B], [RV-1CC-112A, A1, A2, B, B1, B2, C, Cl, C2] and [lVS-176,177, 178,179]. They do not perform a function in shutting down a reactor, in maintaining the shutdown or in mitigating the consequences of an accident.

i) As a result of the Basis Document Review, the following valves will be stroked and timed in both the open and closed directions: [MOV-lRH-700,701,720A &

720B], [MOV-1RW-103A, B, C & D], [MOV-1RW-106A, B] and [MOV-1RW-l 114A, B]. They have always been stroked in both directions, but only timed in j one direction.

j) The relief valves added in DCPs 2204 and 2205 were added to the IST Program to
be setpoint tested
[RV-1SI-894), [RV-1SS-605,606,607 & 608] and [RV-1CC-261,262,263 & 264]. All of these relief valves except [RV-ISI-894) will also be  !

leakage tested per the Appendix J Program.

O k) As a result of the Basis Document Review, the following valves have been

U designated as " Passive" in the IST Program
[MOV-lQS-100A, B] aad [TV.
1CC-128,130,132]. These valves are not required to change position in c.

accident.

j As a result of the Basis Document Review, the relief valves for the intake 1) structure door seals have been added to the IST Program to comply with the l " maintain the plant in shutdown condition" portion of the scoping requirements of

OM-10. This is a change from the previous Code requirements. The following
valves were added and will be setpoint tested
[RV-IIA-107A, B, C, D, E & F].

! m) As a result of the Basis Document Review, several editorial changes were made such as correcting the OM drawing referenced and the drawing coordinates for

various valves. Also, several valves were moved from System 44C to System 44A, from System 32 to System 30 and from System 27 to System 26. The testing performed is still the same.

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l IX) The following are changes to Section IX of the BVPS-1 IST Program " Valve Cold i Shutdown Justifications."

j a) All of the Valve Cold Shutdown Justifications were converted from the existing 4 Cold Shutdown Justifications. Specific references to the Code, GL89-04 and j

O NUREO-1482 were added to all of the justifications and additionaljustification was added to a few of them.

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i ENCLOSURE 1

SUMMARY

OF CHANGES b) Cold Shutdown Justifications CSJ6 & 7 were converted to Valve Refueling  !

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Outage Justification No. 7. The valves are the normal charging and letdown containment isolation valves. They are not able to be stroked at every cold

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shutdown. Therefore, justification for testing only during the cold shutdowns  !

, where the conditions permit stroking the valves was added to VROJ7.

i l c) The following existing Cold Shutdown Justifications were deleted: 1 CSJ8 - This was deleted in a previous revision.  :

} CSJ23 - The valves in this CSJ were made passive and stroke testing is no longer l 5

required. Therefore, the CSJ is no longer required.

! The Valve Cold Shutdown Justifications were renumbered to put them in the i order they appear in the Valve Outline Sheets and to delete the unnecessary CSJs.

i l X) The following are changes to Section X of the BVPS-1 IST Program " Valve Refueling i Outage Justifications."

1 I a) The following Valve Refueling Outage Justifications were written, convening i existing relief requests. Specific references to the Code, GL 89-04 and NUREG- ,

1482 were added to all of the justifications and additionaljustification was added  !

to them:

New Valve Existing Valve Number Basis for Justification Refueling Relief Outage Request A

__.stification No.

VROJ1 RR2 1RC-68 Valve Closure by leak test at a refueling i frequency is permitted by OM-10 and l NUREG-1482, Section 4.1.4.

VROJ2 RR3 1RC-72 Valve Closure by leak test at a refueling

frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4.

VROJ3 RR46 SOV-1 RC-455C1, C2, If exercising is not practicable during plant i Dl, D2, operation or cold shutdowns it may be

SOV-lRC-456-1, 2 limited to refueling outages, per OM-10.

VROJ4 RR4 1CH-22,23,24 If exercising is not practicable during plant operation or cold shutdowns it may be limited to refueling outages, per OM-10 and GL 89-04, Position 1.

VROJ5 RR5 ICH-31 Valve Closure by leak test at a refueling frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4.

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l ENCLOSURE 1

.i

SUMMARY

OF CHANGES j iO New vaive Refueling Existing Relief veive xumber sesis for Justirication Outage Request

Justification No.

VROJ6 RR6 ICH-181,182,183 Valve Closure by leak test at a refueling ,

i frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4.

VRO)7 CSJ6 & 7 TV-1 CH-204 If exercising is not practicable during plant MOV-1CH-289,310 operation or cold shutdowns it may be g LCV-l CH-460A, B limited to refueling outages, per OM-10 and NUREG-1482, Section 3.1.1.4. i F VROJ8 RR10 MOV-lCH-308A, If exercising is not practicable during plant

! B. C operation or cold shutdowns it may be ,

I j limited to refueling outages, per OM 10 l

and NUREG-1482, Section 3.1.1.4.

I VROJ9 RR8 ICH-369 Valve Closure by leak test at a refueling frequency is permitted by OM-10 and i NUREG-1482, Section 4.1.4.

l VROJ10 RR12 MOV-lCH-378,381 If exercising is not practicable duririg plant l

' l operation or cold shutdowns it may be p limited to refueling outages, per OM-10 and NUREG-1482, Section 3.1.1.4.

. VROJ11 RR14 ISI-5 If exercising is not practicable during plant operation or cold shutdowns it may be limited to part stoke at cold shutdowns and

full-stroke at refueling outages, per OM-10
and GL 89-04, Position 1.

VROJ12 RR15 I SI-6, 7 If exercising is not practicable during plant

operation or cold shutdowns it may be 3

limited to refueling outages, per OM-10

! and GL 89-04, Position 1.

VROJ13 RR16,18 I SI-10,11,12 If exercising is not practicable during plant 1SI-23,24,25 operation or cold shutdowns it may be  !

l

limited to refueling outages, per OM-10.

GL 89-04 Position 1 and NUREG-1482.

Section 4.1.4.

4 VROJ14 RR17 I SI-20, 21. 22 If exercising is not practicable during plant I

151-100,101.102 operation or cold shutdowns it may be

limited to refueling outages, per OM-10 l and GL 89-04, Position 1. l s

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ENCLOSURE 1 l

SUMMARY

OF CHANGES l

New Valve Existing Valve Number Basis for Justification j Refueling Relief l Outage Request

! Justification No.

VROJ15 RR19 1S1-27 If exercising is not practicable during plant i j operation or cold shutdowns it may be j i limited to part stoke at cold shutdowns and full-stroke at refueling outages, per OM-10, l

,1 GL 89-04, Position 1 and NUREG-1482, l Section 4.1.4.

{

VROJ16 RR21 I SI-83, 84. 95 Ifexercising is not practicable during plant i operation or cold shutdowns it may be

limited to part stoke at cold shutdowns and 1
full-stsoke at refueling outages, per OM-10. I GL 89-04, Position 1 and NLREG-1487 '

] Section 4.1.4.

l VROJ17 RR22 ISI-94 If exercising is not practicable during plant i operation or cold shutdowns it may be limited to refueling outages, per OM-10, GL 89-04, Position 1 and NUREG-1482, O VROJl8 RR50 1SI-l1 % !!6 sectioa 4 i 4.

If exercising is not practicable during plant operation or cold shutdowns it may be limited to refueling outages, per OM-10.

VROJ19 RR24 MOV-I SI-867C, D If exercising is not practicable during plant operation or cold shutdowns it may be limited to refueling outages, per OM-10.

VROJ20 RR26 TV-CC-103A, Al, B, if ex.ercising is not practicable during plant B 1, C, C 1, operation or cold shutdowns it may be TV-lCC-105D 1. D2, limited to refueling outages, per OM-10 El, E2, and NUREG-1482, Section 3.1.1.4.

. TV-lCC-107A. B. C, Dl, D2, El E2 VROJ21 RR28 1CC-289, 290, 291 Valve Closure by leak test at a refueling frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4, VROJ22 RR29 IMS-18,19. 20 if exercising is not practicable during plant operation or cold shutdowns it may be limited to part stoke at cold shutdowns anJ full-stroke at refueling outages, per OM 1m GL 89-04, Position 1 and NUREG-1482.

O Section 4.1.4.

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-- ENCLOSUREi

SUMMARY

OF Cil ANGES New Valve Existing Valve Number Basis for Justification )

Refueling Relief l Outage Request  ;

Justification No. l VROJ23 RR30 I MS-80, 81, 82 Sample valve disassembly and inspection  !

during refueling outages is permitted by OM-10, and GL 89-04, Position 2. l VROJ24 RR31 1 RW-106,107 Valve Closure by leak test at a refueling  !

frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4.

VROJ25 RR45 1RW-193,194,195, if exercising is not practicable during plant 196 operation or cold shutdowns it may be limited to refueling outages, per OM-10 and GL 89-04, Position 1.

VROJ.V RR35 1 RW-675,676,677 If exercising is not practicable during plant  ;

operation or cold shutdowns it may be limited to refueling outages, per OM-10.

VROJ27 RR48 i WT-382, 382, 387, Sample valve disassembly and inspection 388 during refueling outages is permitted by OM-10 and GL 89-04, Position 2.

O v ao328 na47 ii^-ii6 ii7 v=ive ciosure dr ie>' test t rerveti"8 frequency is permitted by OM-10 and NUREG-1482, Section 4.1.4.

XI) The following are changes to Section XI of the BVPS-1 IST Program " Valve Relief Requests."

a) Valve Relief Request No I (VRRI) was written for (ISI-1,2] to disassemble and inspect during refueling outages, and to request relief from a partial stroke after the valve is reassembled. This VRR is existing RR13 in the current revision (Issue 2 Rev 14) of the IST Program. The basis for this request is the im~ practicality of the part-stroke testing.

b) Valve Relief. Request No. 2 (VRR2) was written for [lSI-48,49,50,51, 52. 53 l to request the use of an alternate test method for full stroke testing of the SI Accumulator Discharge Check valves. The basis for this reliefis the SER for the Ft. Calhoun test method and NUREG-1482, Section 4.1.2. This VRR is existing RR20 in the current revision (Issue 2 'Rev 14) of the IST Program.

o-

.. ENCLOSURE 1

SUMMARY

OF CHANGES

/7 V

c) Valve Relief Request No. 3 (VRR3) was written for (1RS-158,160] to disassemble and inspect during refueling outages, and to request relief from a i partial stroke after the valve is reassembled. This VRR is existing RR25 in the i current revision (Issue 2 Rev 14) of the IST Program. The basis for this request is I

, the impracticality of the part-stroke testing.  !

d) Valve Relief Request No. 4 (VRR4) was written for (SOV-1EE-101,102,103, 104] to request to test the valve by starting the D/Gs. The basis for this is NUREG-1482, Section 3.4," Skid-Mounted Components and Component Subassemblies." This VRR is existing RR36 in the current revision (Issue 2 Rev l

14) of the IST Program. l e) The following Relief Requests in the current revision (Issue 2, Rev 14) were deleted:

RR1 - OM-10 allows containment isolation valves to be tested per the Appendix J Testing Program.

RR7 - Per OM-10 it is permissible to assign a maximum permissible leakage rate i for the entire penetration.

RR9 - Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR11 -This RR was deleted in a previous revision. l O RR18 -This RR was combined with RR16 and made into VROJ12.

RR23 -This RR was deleted in a previous revision.

RR27 -Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR32 - This RR was deleted in a previous revision.

RR33 - This RR was deleted in a previous revision.

RR34 - This RR was deleted in a previous revision.

RR37 - This RR was deleted in a previous revision.

RR38 - Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR39 - Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR40 - Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR41 -Per OM-10 it is permissible to assign a maximum permissible leakare rate for the entire penetration.

RR42 - Per OM-10 it is permissible to assign a maximum permissible leakage rate for the entire penetration.

RR43 - This RR was deleted in a previous revision.

RR44 - This RR was deleted in a previous revision.

RR49 -OM-10, Section 4.21.8. has specific instructions for Rapid Acting Vah es O

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