ML20150F279
| ML20150F279 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/26/1979 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7910010271 | |
| Download: ML20150F279 (24) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O BOX 8699 PHILADELPHI A. PA.19101 JOSEPH W. GALLAGHER TNm osranvisans, 1215)841-5003 atrevnic eno September 26, 1979 Mr. Thomas A.
Ippolito, Chief Operating Reactors Branch #3 Division of Operating Reactors U.S. Nuclear-Regulatory Commission Washington, DC 20555
Dear Mr. Ippolito:
Our submittal of November 22, 1978 proposing revisions in the Peach Bottom Atomic Power Station Inservice Inspection Program - Unit 2 and Common Plant, is presently pending before the Commission.
Experience in our implementa tion of the ISI Program indicates the need f or additional proposed revisions involving the inservice testing of pumps and valves.
These proposed revisions are requested for the following reasons:
1.
The testing' frequency jeopardizes equipment reliability.
2.
The testing requirements can not be accommodated by plant design.
3.
Alternative methods of implementing the requirements of Section XI are preferred.
4.
The testing specified in the progra'm exceeds the requirements of Section XI.
We have presented rationale and alternce.ive actioce to ensure that these revisiof.s do not compromise plant saict y.
The proposed changes are indicated on our submittal of Nou,caer 22, 1978 by a vertical bar in the' margin.
A description of the proposed changes are as follows:
1.
Add request for relief (section 5 3.11) to' provide an alternative method of monitoring pump performance trends by measuring discharge pressure rather than i
differential pressure in the event suction pressure varia.tions pre insignificant.
The alternative method will simplify t'esting procedures while still meeting I
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Mr.
T.
A.
Ippolito, Chief Page 2 the intent of Section XI.
Als o add note I to Table 5.2-1.
2.
Revise note 3-associated with valve Table 5.4-1 to provide alternative. me th ods of vertfying main steam relief' valve position.
This change does.not conflict with Section XI.
3.
Exclude MO-2-43 A,B (Recire. Suction valve), MO-2-65 A,B (Retire equalizing valve), MO-2-66 B (Recirc equalizing bypass valve) from note 4 in Table 5
- 1. - 1, and apply a new note (uote 22) to these valves, This change would reduce testing frequency based on the potent.ial for primary system leakage resulting from testing and the non-safety nature of valve operability.
4.
Revise Table 5.4-1 and note 5 to delete the_ testing requirements for VV-12-62, RFCU return Check valve.
Plant design does not accommodate testing of this valve as required by the ISI Plan.
This situation was not recognized during our preparation of the' original ISI Program.
The testable is ola tion valves on this 1
penetration are VV-6-28B (feedwater check and MD-12-68 (RWCU return).
The test status of this penetration parti, ally corrected in our submittal of November was 22, 1978 by adding MO-12-68 to the ISI valve testing requirements.
However, we neglected to exclude VV 62 at this time.
The revision is consistent with the Technical Specification requirements.
5.
Revise Table 5.4-1 to change the testing frequency on the LPCI system cross-tie valve MO-10-20 from quarterly to once per operating cycle.
Technical Specification 3.5.A.3^C requires the LPCI system cross-tie valve MO-10-20 to be electrically locked in the closed p osition.
Operability of the valve to the open position has no safety related function.
Opening the valve, however, removes'both LPCI loops and shutdown-cooling system from service.
.The only practical time to functionally stroke this' valve is during a refueling outage.
6.
System design prohibits testing the HPCI and RCIC vacuum relief valves (VRV-139,A,B,C,D and V3V-140 A, B,
C, D) individually.
The testing method proposed in note 24. to Table 5.4-1 and the availability of redundant ialves,
~
, provides, adequate reliability.
7.
Revise Table 5.4-I and add note (25) to change testing frequency for Standby Liquid Control injection explosive valves (XY-ll-14A,B) from once per operating 1
9 4
e 6
I..
y Mr.
T.
A.
Ippolito, Chief Page 3 cycle to once every other operating cycle, with one valve tested each operating cycle.
The proposed revisions excend the requirements of Section XI, Section IWV-3610 and are consistent with the Technical S p e cif i ca ti on s.
s In addition, we request your approval to apply the proposed revisions of this submittal, as well as those contained in the November 22, 1978 submittal, to the Unit 3 Inservice Inspection Program.
Should you have any questions on the above, please do t.ot hesitate to contact us.
Very truly yours, l
Attachment i
s 5
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PBISI-2 5.3.11 Request for Relief 5.3.11.1 Components RHR, SBLC, HPSW, ECW, ESWB Pumps c}.3.11.2 Requirement from which Relief Requested Measure and evaluate pump differential pressures in accordance with IWP-3100.
cl.3.11.3 Justification The suction pressure is a function of river level, torus level, tank level, or upstream system pressure for these pumps.
Procedural controls are utilized to maintain a constant test suction pressure, or the level variationc have an insignificant effect on differential pressure.
It is therefore possible to accurately monitor pump performance trends by measuring only the discharge pressure.
Testing h Lieu o_f, Section ]g Requirements f
o5.3.11.4
.The RHR, SBLC, HPSW, ECW, ESWB pump discharge pressure may be measured and evaluated in lieu of their differential pressures if the expected variation in suction pressure is less than 2 percent of the pumps differential pressure.
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5-8 November 1978 l
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PBISI-2 5.4 Inservice Testing Program for Class 1,
2 and 3 Valves The inservice testing program for Class 1,
2 and 3 valves is detailed in Table 5.4-1.
Table 5.4-1 identifies the valves to be
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tested, ASME Section XI category, test frequency, and type of test.
Categories of valves subject to the rules of this subsection are defined as:
Category A - valves for which seat leakage is limited in the closed position for fulfillment of their function.
Category B - valves for which seat leakage in the closed position'is inconsequential for fulfillment of their function.
Category C - valves which are self-actuating in response to some system characteristic, such as pressure (relief valves) or flow direction (check valves).
Category D - valves which are actuated by an energy' source capable of only one operation, such as rupture discs or explosive actuated valves.
i Category E - valves which are normally locked open or locked closed to fulfill their function.
Inservice tests on valves will be performed with the test frequencies specified in Table 5. 4-1.
Consistent with the treatment of surveillance tests in the Technical Specifications, these test frequencies may be adjusted plus or minus 25%.
In cases where the elapsed interval has exceeded 100% of the cpecified intarval, the next test interval shall commence at the end of the original specified interval.
valve exercising tests may be cancelled at the discretion of the Shift Luperintendent or his alternate when in his judgement the test could place the plant in an unsafe condition.
Examples of this~ situation include certain valves inside containment where a test failure could negate the safety function of a system, and cituations where a component is inoperable and testing of the i
redundant component may cause undesirable transients.
Table 5.4-1 specifies the type of local leak rate test required for category A valves.
~Another check or remotely operated valve i
in series with the pressure isolation valve designated in Table 5.4-1 may be substituted and leak tested in accordance with Section XI to satisfy the pressure isolation criteria.
5-9 November 1978 f
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PBISI-2
- 5. 5 REQUESTS FT)R RELIEF FROM ASME SECTION XI REQUIREMENTS (VALVES) 5.5.1 Request for Relief 5.5.1.1 components Category A Valves identified in Table 5.4-1
- 5. 5.1. 2 Requirement From Which Relief Requested Velve leak rate testing shall be performed in accordance with IWV-3420 of Section XI.
5.5.1.3 Justification Leak rate testing is already being conducted in category A valves that perform a containment isolation function in accordance with the plant Technical Specifications which conform as far as practicable to the Criteria of Appendix J to 10 CFR 50.
The NRC has reviewed and approved the existing Peach Bottom Atomic Power Station leak rate testing program.
Category A valves performing a pressure isolation function will meet Section XI requirements.
5.5.1.4 Testing in Lieu of Section XI Requirements Leak rate testing shall be performed and documented in accordance with the plant Technical Specification on category A valves that performs a containment isolation function.
Category A valves performing a pressure isolation function will be leak tested in accordance with Section XI of the applicable edition of the~ASME C de, as noted in Table 5.4-1.
i i
5.5.2 Request for Relief 5.5.2.1 components certain valves identified by notes indicated in Table 5.4-1 of the Inservice Testing Program for Class 1, 2, an'd 3 valves.
5.5.2.2 Requirement from Which Relief Requested Class 1, 2 and 3 valves shall lua tested in accordance 'with IWV-3000.
5.5.2.3 Justi fication Csitain valves cannot be practically tested in the manner or at the frequency 'r'equired in IWV-3000 based on plant design.
Existing plant surveillance tests and Technical Specifications 5-10 November 1978 i
.)
PBISI-2 already establish practical testing requirements which fulfill the intent of IWV-3000 within the constraints of plant design.
5.5.2.4 Testing in Lieu of Section XI Requirements Individual exceptions with alternatives identified as noted in Table 5.4-1.
5.5.3 Request for Relief i
5.5.3.1 components All valves identified in Table 5.4-1 of the Inservice Testing Program for Class 1, 2 and 3 Valves.
- 5. 5. 3. 2 Requirement from which Relief Requested corrective action for inoperable valves require condition be corrected before unit startup from a cold shutdown condition in cccordance with IWV-3410 (g) and IWV-3520 (c).
5.5.3.3 Justification c:nstraints on unit startup with an inoperable valve depend on many factors specific to individual plant design.
Limiting conditions for operation have been analyzed and are identified within the plant Technical Specifications.
5.5.3.4 Alternate to Section XI Requirements Inoperable valves will be evaluated within the constraints of the plant Technical Specifications to determine when an inoperable i
l valve will prevent plant startup from a cold shutdown condition.
5.5.4 Request for Relief 5.5.4.1 com'ponents Small control, solenoid, and check valves within class 1 exempt portion of Control Rod Drive Hydraulic System as identified on drawing ISI-M-357.
5.5.4.2 Requirement from which Relief Requested Class 1 valves shall be categorized in accordance with IWV-2000 and tested'in.accordance with IWV-3000.
5-11 November 1978
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PBISI-2 5.5.4.3 Justification These small valves cannot be practically tested to Section XI criteria.
They have not been categorized nor included in Table 5.4-1.
5.5.4.4 Testing in Lieu of Section XI Requirements Scram testing of control rods is the only practical method of t: sting these small valves.
Scram testing is performed on all control rods, consequently all the affected small valves are functionally tested as part of the safety portion of the CRD cystem, near the end of each refueling outage.
This frequency of testing is acceptable in accordance with plant Technical Specifications.
5.5.5 Request for Relief 5.5.5.1 components Category A and B Valves 5.5.5.2 Requirement from which Relief Requested Valve stroke time shall be compared with the previous test results in ' accordance with IWV-3410 (c) (3).
5.5.5.3 Justification Electrically driven motor operator stroke times do not vary cignificantly.
Excessive valve resistance results in motor overcurrent, and an electrical tripping of the motor operator.
P3rforming the evaluation to previous test data would therefore be meaningless.
5.5.5.4 Testing in Lieu of Secti'on XI Requirements An evaluation shall be performed by comparing the stroke time on clectrically driven valves with the more conservative of the following two limits:
(1) the limiting value of full stroke d:termined by the technical specification;.or by some, other technical evaluation that establishes the criteria for determining the operability status of the valve, and (2) increase in stroke time of - 25% or more from the normal or expected stroke time, with stroke times greater than ten seconds; or 50% or more for valves with stroke times less than or equal to ten seconds.
5.5.6 Request for Relief
- 5. 5. 6.'1 components i
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5-12 November 1978
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PBISI-2 All valves with remote position indicators.
5.5.6.2 Requirement from which Relief Requested All valves with remote position indicators, which during plant operation are inaccessible for direct observation, shall be visually observed in accordance with IWV-3300.
5.5.6.3 Justification our present program for the adjustment and verification of the limit switches on motor operated valves ensures that the remote valve indicators accurately reflect valve operations.
After maintenance on the valve or its operator, the limit switches are cdjusted in accordance,with a maintenance procedure, and the cctivity documented in the procedure.
The valve is stroked to verify proper operation after the adjustments and this fact is documented in our maintenance records.
This program satisfies the intent to IWV-3300.
5.5.6.4 Testing in Lieu of Section XI Requirements The maintenance program described in 5.5.6.3 above may be performed to satisfy the intent of IWV-3300 on motor operated valves.
5.5.7 Request for Relief 5.5.7.1 components category A valves 4
5.5.7.2 Requirement from which Relief Requested Method for determining valve seat leakage in accordance with IWV-3420 (d).
5.5.7.3 Justification The two method described do not permit leak rate testing during power operation, or presents a possible personnel safety hazard in the event a tell tale is opened.
5.5.7.4 Testing in Lieu of Section XI Requirements In addition to the two methods described the following method may be used to verify leak tightness.
One or more normally closed valves on the line shall be closed and the leakage. rate determined by measuring and evaluating the rate of pressure 5-13
. November 1978 l
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PBISI-2 increase in an isolated section of the line adjacent to the pressure isolation valves.
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'5-14 November 1978
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I PBISI-2 Table 5.2-1 INSEHVICC TESTING PHOGHAM FOR EQUIVALENT ASME CLASS 14_2_AND_2_ PUMPS FREQUENCY OF MEASUNEMENT FREQUENCY EQUIVALENT OF TEST PARAMETERS OF ASME OPERABILITY EMdB CLASE N
Pi AE Q1 lb V
(fE CH EQK I.D. No.
hHH 2
Nh M
M(1)
M NA M
M V
2( A,B,C,0 )P35 l
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HPCI 2
M M
NH M
NA A
M f.
20P( 33,38 )
HCIC 2
M M
NH M
NA A
M M
20P36 Core Spray 2
Nb M
NR M
NA M
M M
2(A,B,C,D)P37 Stanaoy Liquid Control 2
Nh A
A(1)
A NA A
A M
2(A,B)P40 l
Emergency Service Water J
NH Q
Q NA NA Q
Q Q
O(A,B)P57 M19h Pressure Service
+.ter (RHR S.W.)
3 NE M
M( 1 )
M NA M
M M
2(A,B.C,0)P42 Emer gency x_-l Cooling Water 3
NF A
A( 1 )
HA NA A
A.,
A OOP186 Emergency Service Water booster 3
NH A
A( 1 )
NA NA A
A A
O( A, B ) P16 3 l
t Note 1.
Discharge pressur e may be measured and evaluated in lieu of their differential presrurts 11 the expected variation in suction pressure is less than 2 percent of tne gumps dIfforential pressure.
-m
1 PBISI-2 11mge11_ lei _Inkit_hl:11 N
Rotative Speed Pi Inlet Pressure P
Differential Pressure V1 Flow Hate Tb Bearing Temperature V
Vibration Amplituce L/P Lubricant Level or Pressure NA Not Available NH Not Hequired M
Monthly 0
Quarterly
(,j A
Once Per Operating Cycle ss
9 PHISI-2 TABLE 5.4 -1 INSERVICE TESTING PROGRAM FOR EQUIVALENT ASME CLASS 1, 2 AND 3. VALVES Sheet 1 of 11 TEST VALVE _12Q2 CAILGQB1 F8[QUENCY TYPE OF IEST REMARK 1 IEL:U:lkL Main Steam O
A0-1-86(A,B,C,D)
A V
F/P Note (1 )
J AO-1-80gA,B,C,D)
A Q
F/P Note (1)
J~
HV-1-71(A,B,C b/C A Note ( 2 )
S/V Note ( 2 )6( 3 )
D,E,F,G,H,J,K,L)
MO-1-74 A
C Note ( 4 )
F J
MO-1-77 A
C Note ( 4 )
F J
HV-1-70( A,B )
C A flote( 2 )
S Note ( 2 )
1:eactor Recirculation MO-2-43(A,B) b A Note ( 22)
F MO-2-53(A,B) b C Note ( 4 )
F MO-2-65( A,b )
D
. A Note ( 22 )
F MO-2-SbA B
C Note ( 4 )
F MO-2-6bb b
A Note ( 22 )
F I
Feeowater VV-6-28( A,B )
A/C A. Note ( $ )
F J
VV-b-96( A,B )
A/C A Note ( 5 )
F J,
PI Mo-6-3 8( A,B )
A A. Note ( 6 )
F J
[
1 Pt3ISI-2
~
l TABLE 5.4-1 (Cont'd)
Sheet 2' of 11 TEST YakYh_1202 CaIEE981 EEEQMLNC1 11Eg_Q[_IESI E(M& beg 111:U:211 Heactor Water Cleanup MO-12-15 A
Q F
J MU-12-18 A
Q F-J
'~Tl VV-12-62 C
N Note ( 5 )
N HV-12-4 6 E
N N
MO-12-68 6
0 F
J j
ISI-H-357 Control Rod Drive VV-3-110 C
N Note (7 )
N V V-3 -113 C
N Note ( 7 )
N i
IE1:M-311 Standby Liquid Control VV-11-17 C
A Note ( 8 )
V
]
VV-11-16 A/C-A Note ( 8 )
V J.
PI rg H V-11-3 9( A,8 )
C A
S V V-11-4 3 ( A, b )
C Not e( 17 )
V X V-11-14( A, B )
C One each F
J,PI operating 4
cycle teote( 25 )
VV-11-15 L
N N
VV-11-26 L
N N
VV-11-13( A, b )
L N
e N
VV-11-12( A,b )
L N
N VV-11-25 E
N N
I VV-11-41 L
N N
JV-11-2u i
N N
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PDISI-2 TAllLE 5.4-1 (Cont'd)
Sheet 3 of 11 TEST YA(yg_13Q3 CAI(GOg1
[EggUENCY-TYPE OF TEST REMARKS VV-11-11 E
N N
1SI-M-319 HCIC MD-13-15 A
V F
J q
MO-13-16 A
V F
J,PI MO-13-21 A
Q F
J,.PI MO 41 A
V F
J MO-u24u B
Q F
AU-13-22 C
C Note ( 9 )
V AU-4240 A
Q Note (10)
F J
A0-4241 A
Q Note ( 10 )
F J
VV-13-50 A/C Q
V J
V V 2 9 C
Q V
VV-13-38 A/C Q
V J
MO-13-18 Q
F MO-13-20 A
Q F
J,PI M0-13-39 E
Q F
MD-13-30 A
V F
J,PI MD-13 -131 B
0 F
MO 2 7 b
V F
AO-13-32 E
Q F
O AO-1 J -3 4 li V
F AU-13-35 h
V F
VHV-13-13 9( A, C
V Note ( 24 )
V l
i B,C,b) i V V-13 -4 0 C
A Note ( 18 )
V VV-13-19 C
Q V
j VV-1J-9 F
N N
i VV-13-10 L
N N
VV-33-48 L
N N
l vv-13-u9 E.
N N
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PBISI-2 TABLE 5.4-1 -( Cont ' d )
Sheet 4 of 11 TEST YaLYL_120z CaIEURBI EBE2ME!!C1 IXEE_QE_IEEI BEbaEEE lEl:11-h1 HPCI MO-23-15 A
Q F
J MO-23-16 A
0 F
J,PI A0-23-18
'C C Note ( 9 )
F G
V V -2 3 -6 5 A/C Q
V J
VV-23-56 A/C Q
V J
MO-23-58 A
Q F
J M0-23-19 A
Q F
J, PI MO-23-25 b
Q F
MO-2 3-31 b
y F
MU-4244A B
Q F
A0-u247 A
Q Note (11)
F J
A0-4248 A
Q Note ( 11)
F J
MO-2 3 -17 b
Q F
MO-23-57 b
't F
MO-23-20 A
Q F
J,PI MO-23-14 E
Q F
MO-23-21 A
y F
J,PI MU-s3-24 P
y F
AU u 2 b
Q F
AU-23-4 3 b
Q F
Au-23-53 E
Q F
vhV -2 3-14 0( A,
C
.Q tiote ( 24 )
V l
h,C,0)
VV-23-32 C
Q' V
VV-23-61 C
A Note ( 18 )
V VV-23-22 C
Q V
VV-23-b2 C
V V
VV-23-12 L
N N
VV-43-13 L
N N
VV-23-51 L
N f4 l
VV-23-52 L
N N
i a
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0 Pi1I SI-2 TABLE 5.4-1 (Cont'd)
Sheet 5 of 11 1EST YAkik_1:D gal [ggh!
[BggUENCY TYPE OF TEST EEMARKS 3
Ik1:E:1k2 Core Spray MO-14-12( A,B )
A Q
F J,
PI MD-14-2b( A, B )
F Q
F A0-14 -13( A,It )
C C Note (12)
F
T MO-14-7 ( A,b, C, D )
b Q
F MO-14-11( A A )
A Q
F J,PI MO-14-S( B, A C.D )
b Q
F SV-4224 b
N Note (13) l SV-4225 E
N Note (13)
V V-14 -10( A, B, C, D )
C Q
V V V-14-2 2( A, b, C, D )
C N Note (13 )
VV-lu-2 3( A,b, C,D )
C N Note (13 )
MK-223 C
N_ Note (13)
MK-223 C
N Note (13 )
VV-14-8 ( A,B,0, D )
L N
N VV-14-6 3( A,B,C,D )
E N
N V V-14 -14 ( A, b )
E N
N ISI-M-361
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HMR MD-10-13( A, B, C, D )
b Q
F MU-10-2 5( A,b )
A V
F J,
PI A0-10-4 6( A,B )
C C Note (12)
P MU-10-32 A
C Note ( 14 )
F J
MU-10-33 A
C Note ( 14 )
F J,
PI MO-10 -17 A
C Note ( 14 )
F J,
PI MD-10-lo A
C Note (14)
F J
MD-10-34(A,P)
A V
F J
MU-10-31( A,E )
A Q
F J
MD-10-J o( A,I; )
A V
F J
j _
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Pb1SI-2 TABLE 5.4-1 (Cont'd)
Sheet 6 of 11 TEST YAkYE_1291 C61EE981
[EgguEtJCY TYPE OF TEST HEMARKS MD-10-15( A, B, C,D )
B Q
F MD-10-2 0 B
A Note ( 23 )
F l
MO-10-154 ( A,b )
b O
F J,PI MO-10-176 B
Q F
MO-10-174 6
Q F
A0-10-175 B
Q F
^
MO-10-39( A,B )
b U
F MO-10-2 6( A,B )
B Q
F MO-10-16( A, b,C,0 )
E Q
F SV-4221 5
N Note (13)
SV-4222 B
N Note (13)
SV-4223 b
N Note (13)
VV-10-N214M3 C
C Note ( 19 )
V V V-10-4 8( A,b,C,D )
C Q
V VV-10-51 C
N Note (13)
VV-10-63 C
f3 Note (13)
VV-10-64 C
N Note ( 13 )
VV-10-73 C
N Note ( 13 )
VV-10-18 3( A, B )
C N Not e( 13 )
VV-10-184(A,b)
C N tiote(13)
V V-10-2 8( A, b,C, D )
E N
N VV-10-160 E
N N
VV-10-b6 L
N N
VV-10-81( A,b )
t N
N VV-10-e8 L
tJ r4 ISL:E:110 Hign Pressure Service 1.oter l
MO-32-8 9( A,b,C,D )
b V
F MO-3 2-24 e 6 t:
O F
VV-3 2-11( A,b )
L
.f 4 N
VV-32-Slo (A,b)
L N
N V V-32-2 4( A,F,C,b )
E N
tJ I
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PBISI-2 TABLE 5.4-1 ( Cont'd )
Sheet 7 of 11 TEST YaLYE_L.lb.
CalE99El EhERMEEC1 11EE_0E_IESI BEMaBE1 Emergency Service Wa ter MO-049B B
Q F
MO-2972 B
Q F
MO-3972 B
Q F
AO-0241( A,B,C,D )
b Q
F AO-2334(A,B)
B Q
F m
AO-2335(A,B,C, b
Q F
D.E.F,G,H)
A0-2333( A,B )
B Q
F A0-2336(A,B,C
-b Q
F D. E.F,G,H )
VV-33-0-515A,6 C
0 V
VV-33-2-516 C
A Note (20)
V V V - 3 3 513 C
A Note (20)
V VV-33-2-514 C
A Note ( 20 )
V VV-33-506-E N
f4 Emergency Cooling MO-48 -280 4( A, b )
B A Note (15)
F MO-u8-3804( A, B )
B A Note (15)
F MO-08ul B
A Note (15)
F O
MO-0501(A,b,C) b A Note ( 15 )
F MO-0502(A,B,C) b A Note (15)
F MO-2bO3 h
Q F
MO-3803 B
Q F
VV-48-0-506 C
A Note (20)
V VV-46-0-504( A, B )
C A Note ( 20 )
V VV-uo-0-50 3( A,b )
E N
N VV-43-0-505(h,B)
L N
N 1
t
'I
PBISI-2 5
TABLE 5.4-1 ( Con t ' d )
Sheet 8 of 11 TEST yaLYE_lici caILGual EBEuRLEC1 IXEE_QE_IERI EEdaEEE ISL-M:1h3 Fuel Pool Cooling VV-19-MK237M3 C
No te( 21 )
V VV-19-MK 2 37M 3 C
No te( 21 )
V VRV-19-2204(C,D)
C A
V Note (16 )
'N VV-19-25 L
N N
EltkOLE A
Once per Operating Cycle (or during Hef uelino Outaue)
Q Quarterly C
Cold Shutdown Exceeding 48 Hours.
N Not App 12 cable or None P
Partial Strone F.xercise F
full Cycle Exercise, Includes Stroke Timing for Power Operated Valves V
Functional Check with Flow S
Set Point Check J
Leak rate tested in accordance with plant Technical Specifications wnich conforms as f ar as practical to the criteria of Appendix J to 10 CFR 50.
)
PI Leak rate tested in accordance with Section XI of the ASME Code.
+
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d.
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PBISI-2 NOTES FOR TABLE 5.4-1 (1)
In accordance with the plant Technical Specifications closure timing will be performed quarterly when the reactor is s
b21ow 75% power.
In the event that the under 75% power testing crnnot be performed at the quarterly frequency, partial closure of the valves will be performed as an alternate.
(2)
In accordance with the plant Technical Specifications at 1 cast one safety valve and five relief valves for the RPV will be tcsted or replaced with bench tested valves once per operating cycle.
All valves will be tested or replaced every two cycles.
(3)
In accordance with the plant Technical. Specifications each relief valve for the RPV shall be manually opened until steam flow is verified by discharge line temperature, turbine bypass valve closure, MW (electrical drop, or relief valve position '
indication once per operating cycle when reactor pressure is equal to or greater than 100 psig.
(4)
Exercisinch of these valves is not practical during power cperation.
These valves will be exercised during periods of cold chutdown exceeding 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> but not more often than once every three months.
Valves MO-1-74, 77 are steam line drain valves used during startup; as such,' these valves will be functionally cxercised but not stroke timed.
(5)
There is no practical way to test this normally open check valve during reactor operation or cold shutdown.
valves VV-6-28B (Feedwater check) a nd MO-12-60 *RWCU return) are leak tested in Eccordance with'the Technical Specifications to ensure isolation capabilities for tblo penetration.
(6)
These valves,are used only during startup for heat cycle long path recirculation-back to the main condenser, as such they are considered operating convenience valves and will be full ctroked once per operating cycle.
(7)
Due to thermal cracking in the CRD return nozzle at the RPV, flow in this line is blocked off during power operation.
Functional dencnstration of operability and leak rate testing of these check valves is therefore unnecessary.
(8)
Functional operability of this valve will be performed while injecting demineralized water to the RPV once per operating cycle in accordance with the plant Technical Specifications.
November 1978 l
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Y P3ISI-2 (9)
These valves are located in a high radiation area during power operation.
It is not practical to exercise the valve other than when the area is accessible should maintenance be required.
The valve will be exercised during cold shutdowns exceeding 48 s
hours.
(10)
These valves do not appear on ISI-M-359.
They are air cperated control valves in the turbine exhaust return line to the turbine gland seal condenser.
The exhaust return line is identified as class 2 exempt 13HB-2" in zone K-9 on ISI-M-359.
(11)
These valves do not appear on ISI-M-365.
They are air operated control valves on the turbine exhaust return line to the gland seal condenser.
The exhaust return line is identified as class 2 exempt 23HB-2" in zone K-6 on ISI-M-365.
(12)
These valves are within the drywell and are inaccessible during power operation.
It is not practical to exercise these valves during power operation.
The valve will be exercised when the drywell is de-inerted and accessible.
(13)
These small valves are not testable to IWV-3520 requirements by plant design, however, the valves are functionally checked continuously during plant operation in Eccordance with plant Technical Specifications.
Consequences of failure of any of the small valves does not prevent the safety function of the affected ECCS.
(14)
System design prevents exercising of these valves with rcactor pressure above 75 psig.
These valves will be exercised during a cold shutdown.
(15)
These valves will be exercised at the same frequency as the inservice testing of the emergency cooling water and emergency service water booster pumps.
Technical Specifications for the plant require system operability (pumps 5 valves included) to be checked once per operating cycle.
(16)
These vacuum relief valves will be tested by mechanically Gxercising the valve once per operating cycle to assure cperability.
. (1Ts Plant design does not allow exercising of these valves as required in IWV-3520.
These valves will be functionally checked to pass flow during monthly pump operability tests.
l l
l November 1978 l
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n C
C PBISI-2 (18)
Exercising of this valve will be performed once' per cperating cycle.
It is.not practical to exercise this valve by passing flow through it on a quarterly basis because of the potential for contamination of the condensate storage tank with r dioactive torus water.
Full flow testing of this valve is not practical since the test line return to the torus cannot pass full flow.
(19)
Functional exercising of this valve will be demonstrated during RPV head spray operation to accommodate cold shutdown.
Exercising of this valve during power operation is not practical.
(20)
Functional exercising of this valve is not practical during plant operation with the normal plant service water system in cervice.
The valve will be exercised once per operating cycle when the emergency cooling system is teated according to plant Technical Specifications.
(21)
Exercising of these valves will be demonstrated whenever this line is tested by providing flow with the RHR system intertie.
Normal periodic exercising as required in IWV-3520 is not practical due to valve and plant design.
Use of the RHR cystem intertie to inject into the spent fuel pool to exercise these valves would unnecessarily contaminate the spent fuel pool with corrosion products from the carbon steel piping within the RHR System.
(22)
Exercising of these valves is not practical during power 9
cperation, and stroking these valves of a quarterly frequency has a high probability of inducing packing leaks resulting in high drywell sump pump out rates.
MO-2-43 A and B (Recirc. Suction) have no safety function related to closure or opening.
Mo-2-65 A Gnd B (Recirc. equalizing), and MO-2-66B (equalizing valve bypass) are electrically blocked closed during power operation.
These valves will either be functionally exercised once/ operating cycle, or in the event the valves are permanently blocked in the l
closed position, all testing may be waived.
In the event the ctatus of valves MO-2-66A and MO-2-66B are reversed', this note chall apply to MO-2-66A, and note 4 shall apply to MO-2-66B.
j (23)
Technical specification 3.5.A.3.c requires the LPCI system cross-tie valve MO-10-20 to be electrically locked in the closed l
position.
Operability of the valve to the open position has no cafety related function.
Opening this valve removes both LPCI loops and shutdown cooling system from service.
The only l
practical time to f unctionally stroke this valve is during a refueling outage.
(24)
The HPCI and RCIC VRV's are piped in a 1 out 2 twice logic, and as such cannot as installed be individually tested.
The November 1978 l
l l
(
s PBISI-2 valves will be functionally' checked with flow as a group to casure that a vacuum relief flow path through the valve crrangement exists.
(25)
One XV-11-14 exposure valve will be fired each operating cycle (both A and B within the course of 2 operating cycles) in cccordance with Technical Specification 4.4. A. 2. (c).
This exceeds the requirements of IWV-3610 which requires at least 20%
of the charges to be fired every 2 years.
November 1978
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