ML20206T638
| ML20206T638 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/30/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206T643 | List: |
| References | |
| TAC-54682, NUDOCS 8607080197 | |
| Download: ML20206T638 (78) | |
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Nebraska Public Power District """"Nbk*hfbe*fei'**"""
June 30,1986 Office of Nuclear Reactor Regulation BWR' Project Directorate No. 2 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Daniel R. Muller Reference 1) Letter from W. O. Long to J. M. Pflant, dated February 12, 1986, " Request for Additional Information - Inservice Testing Program" ) Responses to NRC Request for Additional Information - IST Program
- 2) IST Relief Requests
Dear Mr. Muller:
Subject:
Cooper Second 10-Year Inservice Testing (IST) Program contains the District's response to the questions forwarded in Reference 1 and the open items identified in the April 15-16, 1986, meeting held at Cooper with the staff on the above subject. Note that the responses to 1. A.2,1.C.6, and 1.C.10 have changed due to additional evaluation of the function of the valves in question.
The various relief requests referred to in Attachment 1 are contained in along with various station operating procedures.
The Cooper IST program will be completely revised to incorporate the changes required by this submittal. Revision 5 of the IST Program will be submitted for review by the end of July,1986.
Sincerely, Jay M. Pilant l Technical Staff Manager Nuclear . Power Group JMP:dmrl/1(1A) cc: W. O. Long - NRC go41 W 22 8%
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r Resp:nza'to NRC . ATTACHMENT 1 RAI - Cotpar IST Program COOPER NUCLEAR STATION.
NEBRASKA'PUBLIC POWER DISTRICT RESPONSES TO NRC REQUEST FOR ADDITIONAL INFORMATION INSERVICE TESTING PROGRAM BASIS FOR THE INSERVICE TEST PROGRAM The base document from which the Cooper Nuclear Station (CNS) IST program and schedules are developed -is : 10CFR50.55a(g) . Accordingly, all the safety-related pumps and valves that are ASME Class 1, 2, or 3 are . tested in accordance with ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition through Winter 1981 Addenda. Additionally, there are four service water pumps, four service water booster pumps, and four service water check valves that are presently receiving Augmented Inservice Tests in accordance with 10CFR50.55a(g) (6) (11) .
1.A.I. NRC RAI - General Questions and Comments Provide a listing of the limiting values of full-stroke time for all power operated valves in the CNS IST program for our review.
District Response Normal values and limiting values of full stroke time for all power operated valves in the CNS IST program were provided to the NRC for review during the April 15-16, 1986, IST meeting at Cooper Nuclear Station - (see enclosure). As discussed at that meeting, relief (RV-04) will be requested from IWV-3417(a) for MSIV stroke timing.
1.A.2. NRC RAI - General Questions and Comments- '
Solenoid operated valves are not exempted ' from the ' stroke time-measurement requirements of Section XI; their stroke times must.be measured and corrective action ~ taken. if these times exceed the limiting value of full-stroke time. The NRC staff will grant relief from the trending requirements of Section XI Paragraph IWV-3417(a) for these rapid acting valves; however. in order to obtain this relief, the licensee must assign.a maximum limiting stroke time of two seconds to these valves.
District Response The District agrees that ASME Class 1, 2, and 3 safety-related solenoid operated valves are not erempted from the stroke time -
measurement requirements of Section XI. -Accordingly, any Class 1, 2, or 3 safety-related solenoid operated valves not exempted by Section XI will be included in the IST program. In addition, a relief request will be prepared to address stroke: time measurements of such solenoid operated valves.
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Responze to NRC RAI - Co:psr IST Program At the April 15-16, meeting, the District discussed including the following three solenoid operated valves in the IST program:
HPCI-SOV-SSV64 HPCI-SOV-SSV87 HPCI-SOV-SSV88 These are Class 2 Category B-active valves. They provide drainage from the High Pressure Coolant Injection (HPCI) turbine and receive signals from the level' control sensors on the' drip legs of the turbine. Their function is for level control and operate automatically during HPCI turbine operation. Valves used for system control (such as pressure regulating valves) are' exempt from testing in accordance with IWV-1200(a).
The three valves above are operated monthly during HPCI pump testing and should they fail to operate, a high condensate level alarm on the drip legs will sound. This alarm would demonstrate failure.of the valves to open in the required time.
Since these valves are exempted by -IWV-1200(a), have automatic operation, and an alarm upon failure, they will not be included in j the IST program.
The District does not consider Control' Rod Drive (CRD) Hydraulic Control Unit (HCU) directional control solenoid operated valves or -
CRD stabilizing solenoid operated valves to be safety-related.
1.A.3. NRC RAI - General Questions and Comments The NRC staff position is that the emergency diesel generators perform a safety-related function and the appropriate pumps and valves in the emergency diesel air start, service water cooling, and fuel oil transfer systems should be included in the IST program and tested in accordance with the Code. Engine mounted pumps are considered to be part of the diesel and need not be tested separately.
District Response The District position remains that pumps and valves associated with the above systems are not within the scope of ASME Section XI -
testing. However, the appropriate system pumps and valves are tested commensurate with emergency diesel generator surveillance testing required by CNS Technical Specifications. The District agrees to submit relief requests (RP-07, RV-08, RV-09, and RV-10) for pumps and valves in the above systems. These relief requests, contained in Attachment 2, explain. how existing Technical Specification and Surveillance Procedure testing ~ meets or exceeds Section-XI testing requirements.
J.A.4. NRC RAI - General Questions and Comments Are all valves that are Appendix J Type C leak-rate tested included in the Cooper IST program and categorized A or A/C7-
1.A.5. NRC RAI - General Questions and Comments The NRC has. concluded that the. applicable leak test. procedures and
- requirements for containment isolation valves are determined . by 10CFR50 Appendix J; however,- the -licensee must comply with the Analysis of Leakage Rates and Corrective Action. Requirements
.; Paragraphs of Section XI, IW-3426 and 3427. Does the current-4 Cooper IST program meet this NRC staff position?
i District = Response l
, The Corrective Actions Requirements of ASME Section IW-3427 will be included in the IST program via. the General IST Valve Test
- Procedure. The CNS IST program currently meets the requirements of j IWV-3426 " Analysis of Leakage Rates."
1.A.6. NRC RAI - General-Questions and Comments Are any valves at Cooper Nuclear Station currently leak-rate tested to verify a pressure boundary isolation function? Those valves that serve both a pressure boundary isolation function and a containment
- isolation function must be leak tested to both the Appendix J and Section XI requirements.
District Response i
No valves are. currently leak-rate tested to verify pressure boundary isolation. The District has evaluated the pressure boundary isolation function of the following valves.
CS-M0-12A RHR-MO-25A RHR-MO-32 CS-M0-12B RHR-MO-25B RHR-MO-33
! CS-AO-13A RHR-AO-68A RHR-MO-274A
- CS-AO-13B RHR-AO-68B RHR-MO-274B CS-M0-15A RHR-MO-17 CS-MO-ISB RHR-M0-18 i .
l The . District's position remains that Pressure Isolation Valves do -
not need to be leak tested to both Appendix J and Section XI requirements, and that this combined testing is not contained in any
, formal written NRC requirements to BWR licensees. The District will perform this testing if such written requirements are received,.
although various piping modifications would be required to-perform the Section XI testing. .
1- 1.A.7. NRC RAI - General Questions and Comments It is the NRC staff position that excess flow check valves perform a
- safety-related function and should be' included ~in the IST program?
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' Rasp:n23 to NRC.
. District Response Excess ' flow check valves .will be included in the IST program as category A/C active. A relief request (RV-ll).will.be submitted to i
perform a- modified leak test during refueling outages to verify operability.
l.A.8. NRC RAI'- General Questions and Comments When flow through a check valve is used to indicate a full-stroke exercise of the valve disk, the NRC ' staff position is that 4
verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adequate
, demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the: differential pressure across the valve), that the check valve's disk position at
, the lower flow rate would permit maximum required flow through the valve.
Do the licensee's testing procedures which are based on, observing
, "substantially free flow" (Cooper IST Program Rev. 4, l Section VIII.B.4.b.4) meet this staff position?
District Response
! CNS testing procedures for exercising check valves are in accordance 4
with ASME Section XI requirements. The system conditions under which the valves are exercised may be at the maximum flow rate as identified in the Updated Safety Analysis Report-(USAR).
1.A.9.a. NRC RAI - General Questions and Comments The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation and these i
valves are specifically identified by the _-licensee and are full-stroke exercised during cold shutdowns. The staff requires
- that the licensee provide a technfcal justification for each velve that cannot be exercised quarterly during power operation that clearly explains the difficcities or hazards encountered during that j testing. The staff will then verify that it is not practical to l exercio4 those valves and that the testing should be performed during cold shutdowns. Cold shutdown tesring of valves identified i- by the licensee is acceptable when the following conditions are met
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- -Tha licensee is to commence testing as soon as the cold shutdown condition 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 /> i af ter shutdown, and continue until complete or the plant is-ready to return to power.
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_Rnpunis to NRC RAI - Cocpar IST Program District Responsa Cooper . Nuclear Station Technical Specifications defines cold shutdown as follows:
1 l Cold shutdown means the mode switch is in the " Shutdown" or
" Refuel". position with reactor coolant temperature equal to or
~
- less than 212*F and the reactor vessel is vented.
i j Inservice valve testing at cold shutdown is defined as:
I Valve testing which commences not later than forty-eight (48) hours after cold shutdown and continues _until required testing is completed or plant startup, whichever occurs first.
I Completion of all required valve testing is not a prerequisite to plant startup. Valve testing which is not completed during a cold shutdown will be performed during . subsequent cold shutdowns to meet the code specified testing requirements. No valve will be tested more often-than once every 90 days.
- 1. A'. 9. b . NRC RAI - General Questions and Comments
. Completion of all valve testing is not a prerequisite to return to power.
District Response i Agree. Refer to District Response to 1.A.9.a.
2 1.A.9.c. NRC RAI - General Questions and Comments i
- Any testing not completed during one cold shutdown should be
! performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.
1 District Response i
I Agree. Refer to District Response to.l.A.9.a.
1.A.9.d. NRC RAI - General' Questions and Comments For planned cold shutdowns, where ample' time is available and testing all the valves identified for the cold shutdown test
. frequency in the IST program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
District Response -'
i Agree. Refer to District. Response to 1.A.9.a. l 1.A.10. NRC RAI - General Questions and Comments A relief request from the Section XI exercising requirements must be provided for Category A/C valves whose closed position can be . l verified only by leak testing. j
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Rasponto to NRC
- District Response CNS has four Reactor Feedwater check valves that are normally opened ,
and are verified closed by local leak rate testing. Relief request _ l RV-05 is included in Attachment 2. I l.A.ll. NRC RAI - General Questions and Comments
! Is Cooper Station required to have an operational safety grade post accident sampling system? If so, the associated valves should be 4 included in the . IST program and be tested in ' accordance with Section XI.
District Response Cooper Nuclear Station's Post-Accident Sampling System (PASS) is not-considered a safety-related ASME class 1, 2, or 3 system.
l.A.12. NRC RAI - General Questions and Comments I
Does the Control Room ventilation system perform any safety-related ;
function? If so, the appropriate support system valves should be l included in the IST program.
District Response Valves associated with the Control Room ventilation system are'not
! classified ASME 1, 2, or 3. However, the appropriate system valves are tested commensurate with Control Room ventilation system
- surveillance testing required by CNS Technical Specifications.-
- Consequently, the District's position remains that these' valves are i not required to be included in the CNS IST program.
l 1.A.13. NRC RAI - General Questions and Comments a
Review the safety-related function of the Reactor Building Closed Cooling System (REC) to determine if the ' system should be included i in the IST program - and the applicable components tested . in accordance with the requirements of Section XI.
District Response The District position remains that pumps and valves associated with the REC System are not within the scope of ASME Section XI testing.
However, the appropriate system ' pump and. valves are tested commensurate with surveillance testing required by CNS . Technical- -
Specifications. The District agrees to submit _ relief requests (RP-06, RV-12, and RV-13) for pumps and valves in the REC' system.
These relief requests' will explain, how ' existing Technical Specifications and Surveillance Procedure testing meets .or exceeds '
Section XI' testing requirements, i
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R2spunta to NRC RAI - Compar IST Program 1.B.I. NRC RAI - Core Spray System Review the safety function of valves CS-AO-13A and 13B to_ determine if they should be categorized A/C.
District Response Refer to the District Response to 1.A.6.
1.B.2. NRC RAI - Core Spray System Do valves CS-CV-12, 13, 14, and 15 perform a safety-related function in both the open and closed positions? How are these valves individually verified to perform their safety-related function?
District Response CS-CV-12, 13,14, and 15 are for pressure maintenance of the Core Spray System. These valves will be included in the IST program as Category C active valves and tested quarterly. Relief (RV-14) will i be requested to demonstrate that at least one of the two valves on each loop will close and to verify opening by observing Core Spray System pressure.
1.B.3. NRC RAI - Core Spray System Are the following valves ever required to change position in order to perform a safety-related function?
CS-M0-11A CS-M0-26A CS-MO-5A CS-MO-7A CS-MO-11B CS-M0-26B CS-MO-5B CS-MO-7B District Response CS-MO-llA and B are normally open outboard . containment isolation valves. They are not required to change position for initiation of the Core Spray System. They may be required ' to close for containment isolation, but receive no automatic initiation. These valves will be included in the IST program as Category A active for-exercising from the open to the closed position.
CS-MO-26A and B are required to change position in order to perform a safety-related function. These valves will be included in the IST program as Category B active and tested quarterly.
4 CS-MO-5A and B are normally open minimum recirculation isolation valves and are required to change _ position to fulfill their safety function. These valves will be included in the IST program as
- Category A active for exercising from the. open to the ' closed position.
CS-MO-7A and B are normally open pump suction valves. _They are not
, required to change position for initiation of the Core Spray System.
They may be required to close for containment isolation, but receive no automatic initiation. .These valves will be included in the'IST program as Category A active for exercising from the open to the -
closed position.
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Rsap:nza to NRC RAI - Coopar.
IST Program 1.B.4. NRC RAI - Core Spray System Review the safety-related function of valves CS-MO-15A and- 15B to determine if they should be included in the .IST program and categorized A.
District Response Refer to the District Response to 1.A.6.
1.C.I. NRC RAI - Residual Heat Removal System Provide a detailed technical justification for not full-stroke-exercising valves RHR-920-MV and 921-MV quarterly.
- District Response These 3" valves are the steam supply to the Augmented 0ff; Gas System
, which cannot be isolated during normal operation without causing i significant system transients. Relief request RV-02 will be deleted l to change testing frequency from every six months to cold shutdown testing.
1.C.2. NRC RAI - Residual Heat Removal System Review the safety function of valves RHR-AO-68A and 68B to determine if they should be categorized A/C.
District Response 4
! Refer to the District Response to l'.A.6.
4 r 1.C.3. NRC RAI - Residual Heat Removal-System How are valves RHR-CV-10, 11, 12, and 13 verified to full-stroke-exercise during the quarterly testing..
District Response These valves are exercised during the RHR pump operability tests and will be verified to open by opening the RHR minimum flow line block valve and observing a change in system flow.
4 1.C 4. NRC RAI - Residual Heat Removal System:
Do valves RHR-CV-18, 19, 24, and 25 - perform a safety-related l function in both the open and closed positions?- How is each valve l individually verified-to perform its safety-related function?
f District Response 4
RHR-CV-18, 19, 24, and 2:5 are for pressure maintenance of the RHR Syctem. These valves will ~ be included in - the IST program as Category C active valves and tested quarterly. Relief (RV-15) will be requested to demonstrate that at least.one of the two valves on each loop will close and to verify opening by observing IWR system pressure.
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R22ponsa to NRC RAI - Corpsr IST Program 1.C.S. NRC RAI - Residual Heat Removal System ,
l Provide a detailed technical justification for not full-stroke exercising valve RHR-CV-20 in accordance with the requirements of Section XI.
District Response The 14" RHR-CV-20 valve is the emergency service water (river water) supply for core flooding. During every refueling outage, this valve is disassembled and manually full-stroke exercised. A relief request (RV-17) will be provided to explain this test.- The relief request will contain previous inspection history and results to justify decreasing the test frequency from once per refueling outage to once every third refueling outage.
1.C.6. NRC RAI - Residual Heat Removal System Provide a detailed technical justification for not full-stroke exercising valves RHR-CV-21 and 22 quarterly in accordance with the requirements of Section XI.
District Response RHR-CV-21 and 22 are the RHR Heat Exchanger A and B drains to the RCIC. These valves, along with RHR-M0-38A and 83B, are used only for operating convenience during the steam condensing mode of the RHR Heat Exchanger. The steam condensing mode was designed to allow operators to maintain the reactor in a hot standby condition during an isolation event in anticipation of quickly resuming power operations. This mode of operation is not part of the safety-design basis of the RHR system.
Since these valves are only required for operating convenience, they will be deleted from the IST program. This response to the NRC will serve as the technical justification for deleting these valves and no reference will appear in the update IST program.
1.C.7. NRC RAI - Residual Heat Removal System What is the test interval designated IST-1?
District Response Test interval IST-1 is incorrect. The correct designation is IST-VI. This correction has been made as part of IST Program (Revision 4).
1.C.8. NRC RAI - Residual Heat Removal System What is the P & ID location of valves RHR-RV-10, 11, 12, and 13?
District Response RHR-RV-10,11,12, and 13 are on P & ID 2040 (at zones G5, G8, H5, and H8 respectively). The identifiers for these valves presently shown on Drawing 2040 are 10-41A, B, C, and D, respectively, and are incorrect. A drawing revision is being made to correct this.
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l R;ap:nts to NRC RAI - Csepar IST Program 1.C.9. NRC RAI - Residual Heat Removal System !
Are valves RHR-M0-17 and 18 ever required to change ~ position in order to perform a safety-related function?
District Response Refer to District Response to 1.A.6.
1.C.10. NRC RAI - Residual Heat Removal System Review the safety-related function of the following valves to determine if they should be included in the IST program and be categorized as indicated.
RHR-M0-15A A RHR-M0-274A RHR-M0-15B B RHR-M0-274B RHR-MO-15C C RHR M0-15D D District Response RHR-M0-15A, B, C, and D are RHR suction shutdown cooling supply valves. These valves are part of the power generation design basis and, as such, were not included in the original IST program. Based on this most recent review, CNS has included these valves in the IST program as Category B active to be full-stroke exercised and timed once every quarter. Surveillance Procedure 6.3.5.2 will be modified to include full-stroke exercising and time the valves from the open to closed and closed to open positions as part of the IST program.
In addition, 6.3.5.2 will be modified to include timing and full-stroke exercising RHR-MO-13A, B, C, and D.
Refer to the District Response to 1.A.6 for RHR-MO-274A and 274B.
1.C.11. NRC RAI - Residual Heat Removal System Review the safety-related function of valves RHR-FCV-43, RHR-LCV-71A, and RHR-LCV-71B to determine if they should be included in the IST program and tested in accordance with the Code. Do these valves have a required fail-safe position?
District Response RHR-FCV-43 valve will be removed during the fall 1986 oatage and will not be included in the IST program. Valves RHR-LCV-71A and B do not perform a safety-related function and therefore w131 not be included in the IST program.
1.D.I. NRC RAI-- Standby Liquid Control System Provide a detailed technical justification for not exercising valveo SLC-CV-12 and 13 quarterly in accordance with the requirements of Section XI.
R;ipanIG to NRC RAI - Corpsr IST Program District Response SLC-CV-12 and 13 are the outboard and inboard check injection valves respectively for the Standby Liquid Control System. These valves can only be exercised upon the initiation of squib valve SLC-14A or B. To test these valves would require manually valving out the sodium pentaborate (poison) suction to the SLC pumps, then flushing the system with demineralized water, and injecting cold demineralized water into a hot operating reactor. To perform this operability test would place the Standby Liquid Control System in an inoperative condition. Technical Specifications requires the reactor be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the Standby Liquid Control System is declared inoperative. Relief (RV-18 and RV-19) will be requested to verify opening each refueling during a system full flow test and to verify closure each refueling during Appendix J local leak rate testing.
1.D.2. NRC RAI - Standby Liquid Control System How is a full-stroke exercise verified for valves SLC-CV-10 and 11 quarterly?
District Response SLC-CV-10 and 11 are normally closed valves. These valves are verified open by observation of substantially free flow through _the valves indicated by appropriate pressure indications in the system.
This verification is performed quarterly during pump operability tests.
1.E.1. NRC RAI - High Pressure Coolant Injection System i.
Would failure of HPCI-M0-15 in a non-conservative position during testing render an entire safety system inoperable?
District Response HPCI-M0-15 is the steam supply in'ioard isolation valve for the HPCI System and is normally open. To have the valve fail in a most non-conservative position (closed) would stop the flow of steam to the HrC1 turbine and would render the system inoperable.
Accordingly, a Technical Specificetion change will be proposed to test HPCI-MO-15 and HPCI-MO-16 during cold shutdown. If approved, the IST program will be changed to reflect this.
1.E.2. NRC RAI - High Pressure Coolant Injection System Are there any adverse operational consequences that would result ,
from full-stroke exercising valve HPCI-MO-16 quarterly? Should l valves HPCI-MO-15 and 16 be tested during cold shutdowns? )
l District Response Refer to the District Response to 1.E.1.
l R2rpsngs to NRC RAI - Cocpsr IST Program 1.E.3. NRC RAI - High Pressure Coolant Injection System How is valve HPCI-CV-15 exercised quarterly during extended cold shutdown periods?
District Response HPCI-CV-15 is the HPCI' turbine exhaust check valve and is exercised quarterly. During cold shutdown periods.there is no reactor steam to exercise the check valve; hence there is no testing during cold shutdown periods. A note will be added to the IST program to indicate that this system is out of service during cold shutdown.
1.E.4. NRC RAI - High Pressure Coolant Injection System i Provide a detailed technical justification for not full-stroke exercising valve HPCI-CV-11 quarterly.
District Response
, HPCI-CV-11 is in the torus-to-HPCI pump suction line and is normally
, closed. To full-stroke exercise this valve quarterly would involve a system design which would permit recirculation to and from the torus. This is not possible with the existing system design.
Currently, full flow system testing is performed by recirculating flow to and from the emergency condensate storage tanks (ECST). This
- valve is disassembled and manually full stroke exercised during every refueling outage. A relief request (RV-20) will be submitted to explain this test. The relief request will contain previous
! inspection history and results to justify decreasing the test 4
frequency from once per refueling outage to once every third
- refueling outage.
1 1.E.5. NRC RAI - High Pressure Coolant Injection System
. Do valves HPCI-CV-18 and 19 perform. a safety-related function in both the open and closed positions? How are . these valves individually verified to perform their safety-related function?
District Response HPCI-CV-18 and 19 are for pressure maintenance of the HPCI System.
i These valves will be included ' in the IST program as Category C
, active valves and tested quarterly. Relief (RV-16) will be requested to deconstrate that at least one of the two valves will close and to verify opening by observing _HPCI system pressure.
1.E.6. NRC RAI - High Pressure Coolant Injection System What type of valves are HPCI-LVSC-44 and 50? How are these valves
!- exercised quarterly?
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R2sptnme-to NRC a RAI - Co: par IST Program District Response HPCI-LVSC-44 and 50 are stop check valves. These. valves are locked open and normally closed. HPCI-LVSC-44 and 50 are exercised open
, during HPCI pump operability tests. Relief (RV-21) will be requested to verify closure by leak testing during refueling outages because valve failure while testing with the manual handwheel would render HPCI inoperable.
1.E.7. NRC RAI - High Pressure Coolant Injection System What is the normal position of valve HPCI-MO-577 1
District Response HPCI-M0-57 is normally closed.
1.E.8. NRC RAI - High Pressure Coolant Injection System Review the safety-related function of the following valves to determine if they should be included in the IST program. If it is determined that these valves do perform a safety-related function, how will they be fail-safe tested?
Valves P&ID Coordinates
! PCV-69A 2041 F-1
- PCV-69B 2041 F-3 i
PCV-70A 2041 F-1 PCV-70B 2041 F-3 i District Response PCV-69A and B and PCV-70A and B are normally closed pressure control valves for the steam condensing mode-of RHR. These valves are fail safe closed. These valves do not perform a safety-related function and therefore will not be included in the IST program.
i 1.E.9. NRC RAI --High Pressure Coolant Injection System f
- Review the safety-related function of valves RFCI-MO-20, 21, and 24 to determine if they should be included in the IST program.
District Response l HPCI-i!0-20, 21, and 24 perform a safety-related function and, i accordingly, will be included in the IST program as Category B active valves and tested quarterly.
1.E.10. NRC RAI - High Pressure Coolant Injection System
- Review the safety-related function of valves HPCI-CV-24, 25, 26, and 27 to determine if they should be included in the IST program.
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Rupann to NRC ' ,
District Response !
1 HPCI-CV-24, 25, 26, and 27 are HPCI turbine exhaust vacuum breaker '
valves located inside the torus. These' valves will be included in i
- the IST program as Category C active valves. Relief (RV-22) will be requested to manually exercise these valves once per refueling outage. The relief request will explain that these valves are inaccessible during power operation and most cold shutdowns.
1.F.1. NRC RAI - Reactor Core Isolation Cooling System Would failure of RCIC-M0-15 in a non-conservative position during testing render an entire safety system inoperable.
District Response
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RCIC-MO-15 is the steam supply inboard isolation valve for the RCIC l System and is normally open. To have the valve fail in a most non-conservative position (closed) would stop the flow of steam to l the RCIC turbine and would render the system inoperable.
Accordingly, - a Technical Specification change will be proposed to test RCIC-M0-15 and RCIC-MO-16 during cold shutdown. If approved, the IST program will be changed to reflect this.
1.F.2. NRC RAI - Reactor Core Isolation Cooling System i Provide a detailed technical jus'tification for not full-stroke j exercising valve RCIC-CV-11 quarterly.
District Response t
i RCIC-CV-Il is in the torus-to-RCIC pump suction line and is normally closed. To full stroke exercise this valve quarterly would involve -
a system design which would permit recirculation to and from the torus. This is not possible with the existing system design.
Currently, full flow system' testing is performed by recirculating.
flow to and from the Emergency Condensate Storage Tanks (ECST).
- This valve is disassembled and manually full stroke exercised during every refueling outage. A relief request (RV-23)'will be submitted
, to explain this test. The relief request'will contain previous
~
inspection history and results to justify decreasing the test frequency from once per refueling outage to once every third refueling outage.
1.F.3. NRC RAI - Reactor Core Isolation Cooling System '
Do valves RCIC-CV-18 and 19 perform a safety-related function in i both the open and closed positions? How .are these valves ;
individually verified to perform their safety-related function?-
District Response i
RCIC-CV-18 and 19 are for pressure maintenance of'the RCIC system.
These valves will be included in the IST program as Category CL :
active valves and tested quarterly. Relief (RV-24) will be '
requested to demonstrate that at least one of the two valves will close and to verify. opening by observing RCIC system pressure. !
'Rszponga to NRC RAI -_Coopsr IST Program 1.F.4. NRC RAI - Reactor Core Isolation Cooling System 4
What type of valves are RCIC-LVSC-37 and 42 and _ how are they exercised quarterly?
District Response RCIC-LVSC-37 and 42 are stop check valves. These valves are locked open and normally closed. RCIC-LVSC-37 and 42 are exercised open during RCIC pump operability tests. Relief (RV-25) will be requested to verify closure by leak testing during refueling outages because valve failure while testing with the manual handwheel would render RCIC inoperable.
1.F.5. NRC RAI - Reactor Core Isolation Cooling System Review the safety-related function of the following valves to determine if they should be included in the IST program.
RCIC-CV-22 RCIC-MO-20 RCIC-CV-23 RCIC-MO-30 RCIC-CV-24 RCIC-M0-33 RCIC-CV-25 District Response RCIC-CV-22, 23, 24, and 25 are RCIC turbine exhaust vacuum breaker valves located inside the torus. These valves will be included in the IST program as Category C active valves. Relief (RV-26) will be requested to manually exercise these valves once per refueling
! outage. The relief request will explain that these valves are inaccessible during power operation and most cold shutdowns.
RCIC-MO-20, 30, and 33 perform a safety-related function and will-be included in the IST program as Category B active valves and tested accordingly.
l.G.I. NRC RAI - Reactor Feedwater System
~
Provide a detailed technical justification for not full-stroke exercising valves RF-CV-13, 14, 15, and 16 quarterly.
District Response RF-CV-13, 14, 15, and 16 are Reactor Feedwater Containment Isolation valves. To exercise these valves during plant operation could cause a plant trip due to the transitory nature of operating the feedwater pumps at low or no flow conditions. (Refer to District Response to 1.A.10.)
1.H.l. NRC RAI - Main Steam System Review the safety-related function of valves MS-RV-71A through H to determine if they should be categorized B/C and be tested in accordance with the Section XI requirements for power operated valves.
t
R;; pints to NRC RAI - Coopar IST Program District Response MS-RV-71A through H valves are main steam safety relief valves and will be re-categorized as Category B/C active. A relief request (RV-27) will be provided to explain that these valves will be c exercised once per cycle and tested in accordance with ASME PTC 25.3-1976 at least once every two years.
I 1.H.2. NRC RAI - Main Steam System It is the NRC staff position that the following valves be included j in the IST program.
Main Steam Safety and Relief-Valve Tail Pipe Vacuum Breakers MS-CV-10 MS-CV-16 MS-CV-24 MS-CV-30 MS-CV-11 MS-CV-17 MS-CV MS-CV-31 MS-CV-12 'MS-CV-20 MS-CV-26 MS-CV-32 MS-CV-13 MS-CV-21 MS-CV-27 MS-CV-33 MS-CV-14 MS-CV-22 MS-CV-28 MS-CV-34 MS-CV-15 MS-CV-23 MS-CV-29 MS-CV-35 Check Valves in the Air / Nitrogen Supply Lines to the ADS Valve Accumulators
- -CV-17 -CV-19 -CV-21
-CV-18 -CV-20 -CV-22 District Response i MS-CV-10 through 17 will be removed in the fall 1986 outage and,
. therefore, will not be included in the . IST . program. MS-CV-20 through 35 are located in the drywel.1 and will be included in the IST program as Class 2, Category C ac ive valves. Relief (RV-28) will be requested to exercise MS-CV-20 through 35 during refueling outages since they are inaccessible during normal operation and most cold shutdowns.
IA-CV-17 through 22 will be included in the IST program as Category A/C active valves. Relief (RV-29) will be requested to perform leak testing during refueling outages because the valves are inaccessible during normal operation and most cold shutdowns. The relief request will also explain that closure will be verified by a modified leak test procedure.
1.I.l. NRC RAI - Reactor Recirculation System Provide a more detailed technical justification for not exercising valves RR-MO-53A and 53B quarterly. ~The testing schedule on the valve table does not agree with the alternate testing described in relief request RV-03. i
ROrponto to NRC RAI - Coop r IST Program District Response RR-M0-53A and B are. recirculation pump discharge isolation valves.
To exercise these-valves during plant operation would require the shutdown of the recirculation loops. Failure of these valves in the closed condition could cause a plant shutdown because these valves are normally inaccessible (located in the drywell). These valves will be tested during each shutdown. '
Delete relief request RV-03.
l.I.2. NRC RAI - Reactor Recirculation System Valves RR-M0-54A and 54B should be deleted from the IST program.
District Response IST Program Revision 4 has deleced these valves.
l.J.l. NRC RAI - Reactor Water Cleanup System Provide a detailed technical justification for not full-stroke exercising check valve RWCU-CV-15 quarterly.
District Response RWCU-CV-15 is the RWCU return to the RPV and will be reclassified as Category A/C active. Relief (RV-30) will be requested to verify closure by leak testing during refueling outages.
$ 1.K.l. NRC RAI - Radweste System Review the safety-related function of valve RW-MO-93 to determine if it should be included in the IST program and be categorized A.
District Response RW-MO-93 is a drywell equipment drain discharge to radwaste valve and is not a containment isolation valve . RW-MO-93 closes and RW-MO-92 opens on high sump temperature. Sump inventory is then recirculated through a heat exchanger and cooled. At 120'F decreasing, RW-M0-93 and RW-M0-92 are automatically repositioned to their normal lineup.
1.L.l. NRC RAI - Primary Containment System Review the safety-related function of the motor operated bypasses for valves PC-MO-230 and 231 to determine if they should be included i in the IST program and be categorized A. ,
District Response >
The motor operated bypasses for valves PC-MO-230 and 231 are included in the IST Program Revision 4, as Category A active and exercised quarterly.
i
4 Razpongo to NRC--
RAI Cocpar IST Program 1.M.l. NRC RAI - Atmospheric Containment Atmosphere Dilution System Review . the safety-related ' function of . the following valves to 1
determine if they should be included in the IST program and be categorized C.
ACAD-CV-10 ACAD-CV-13 ACAD-CV-16 ACAD-CV-II' ACAD-CV-14 ACAD-CV-17 ACAD-CV-12' ACAD-CV-15 3
District Response The ACAD System is not presently licensed by the NRC, and approval is not expected since the NRC has discontinued it's review'of the system. The District does not expect that the. system will be used as a post-accident combustible gas control method as the existing nitrogen inerting system now serves this function.
1.N.I. NRC RAI - Control Rod Drive System
~
It is the NRC staff position that valves CRD-CV-126.and 127 and check valves 114, 115, and 138 perform a safety-related function and must be included in the IST program and be tested in accordance with the requirements of Section'XI.
District Response j CRD-CV-126, 127 Relief request RV-06 (Attachment 2) will be i expanded to explain why these valves cannot be stroke timed. CRD-CV-Il4 and 115 will be deleted from RV-06.
J .
i CRD-CV-Il4 Relief ~ (RV-07) will be requested to verify full j stroke exercising during' control rod drive scram .
- timing'as required by Technical Specifications.
CRD-CV-ll5 Relief (RV-07) will be requested to demonstrate check valve closure during accumulator pressure decay testing, at refueling, in accordance with Technical Specifications.
1 CRD-CV-138 It is the District's position that the CRD-CV-138 check valves do not perform a safety-
~
- - related function. - Accordingly, these- valves
- will not be included in the IST program, l.N.2. NRC RAI - Control Rod Drive System
. Review -the safety-related function of the following . valves to
- determine if - they should be included in the IST program and be j categorized as indicated.
5
,CRD-CV-13 (A/C) CRD-CV-19 (C) CRD-CV-21 (C)' I
- CRD-CV-15 (A/C) CRD-CV-20 (C) CRD-CV-22 (C).
w -- --m-*- gvw9 -t-- -=mm- v w -* @ v + ai-T h-y* 4 --gT7-W*
. _. _ _- .. . _ _ . , _ -_ _ ~ . . _ _ ____ -
R3cpinto to NRC RAI - Cocpar IST. Program District Response Valves CRD-CV-13 and CRD-CV-15 along with CRD-CV-14 and CRD-CV-16 are.the inboard and outboard containment isolation check valves on i the reactor recirculation pump seal purge lines. They will be added to the IST program and necessary system modifications will be made to accommodate leak-rate testing. These valves will be listed as .
. Category A/C active valves. Relief. (RV-31) is requested to verify l valve closure during .the leak-rate test performed each refueling outage.
i 1
CRD-CV-19, 20, 21, and 22 are the check valves on the vent of the -
scram discharge volume. These valves will be listed as Category C i Active and will be included in the CNS IST program and exercised quarterly.
1 1.0.1. NRC RAI - Service Water System l Provide P & ID 2077 for our review. Any service water valves on i this drawing that are required to- change position to support i emergency diesel generator operation must be included in the IST 4
program and be tested in accordance with Section XI. (Also see 4 question 1.A.3.)
i District Response P & ID 2077 was provided during the April 15-16, 1986, IST meeting with the NRC._ Refer to the District Response to 1.A.3..
I 1.0.2. NRC RAI - Service Water System Provide the test procedure used to verify operability of valves SW-CV-35, 36, 37, and 38.' Does this: test procedure meet the j requirements of IE Bulletin No. 83-03, " Check Valve Failures in Raw Water Cooling Systems of Diesel Generators"?
District Response Test Procedure 6.3.10.16 verifies operability of valves SW-CV-35, 36, 37, and 38. This procedure ' meets the requirements of IE.
Bulletin No. 83-03, " Check Valve Failures in Raw Water Cooling
- Systems of Diesel Generators."
1.0.3. . NRC RAI - Service Water System Are the following valves required to change position to pr'otect the
~
RHR service water _ booster pumps? -
SW-MV-104 SW-MV-97' SW-CV SW-CV-25 4
SW-MV-90 SW-MV-83 SW-CV-24 SW-CV-26 3
.-,,i+:..r , r_ ,
.c y, e t- , + - , - - . , - . . . . . , , c.,,-, ,-,.m-- -
i Raspsnmo.to NRC RAI - Cocp2r.
IST Program District Response Valves SW-MV-104, 90, 97, and'243 were at one time used to establish.
- a. minimum flow during pump starting. However, an alternate method is now used and the valves are presently electrically disarmed and blanked off. Consequently, the respective ~ minimum flow line check .
valves SW-CV-23, 24, 25, and 26 are not required-to change position to protect the RHR service water booster-pumps. Therefore, these i valves are not included in the IST program. ,
1.0.4. NRC RAI - Service Water: System Review the safety-related function : of the ~ following valves to determine if they should be included in the IST program.
SW-CV-19 SW-CV-21 SW-CV-27 SW-MO-650 SW-CV-20 SW-CV-22 SW-CV-28 SW-MO-651 SW-MO-89A SW-M0-886 SW-M0-888 'SW-CV-10 SW-MO-89B SW-MO-887 SW-M0-889 .SW-CV-11 SW-M0-37' SW-MO-117- SW-CV-13 SW-CV-12 District Response i
The - District position remains that valves associated with the Service Water System are not within the scope of ASME Section XI testing. However, the appropriate system valves are tested j commensurate with service water system testing required by CNS i Technical Specifications. The District ' agrees to submit relief I requests for valves in the above system. These relief requests (RV-32, RV-33, RV-34, and RV-35) will explain how existing Technical Specification and Surveillance Procedure testing meets or exceedsSection XI testing requirements.
1.P.I. NRC RAI - Miscellaneous Systems
! Provide P & ids that show the instrument air and/or service air containment penetrations.
District Response Instrument air and/or -service air containment penetration are found on P & ID 2010, 2027, 2028, 2031, 2040:and 2045. These drawings were provided during the' April 15-16, 1986, IST meeting 'with the NRC.
1.P.2. NRC RAI'- Miscellaneous Systems f
The NRC staff position is that the torus to drywell vacuum breakers.
t- perform a safety-related function and must be included in the IST program.
District Response
~
l The torus to drywell vacuum breaker valves NRV-20, 21, 22, 23, 24,- l 25, 26, 27, 28, 29, 30, and 31 will be included in the _ CNS IST .
program as Category-C active valves and exercised quarterly. !
R2sp:nta to NRC RAI - Conpsr IST Program 1.P.3. NRC RAI - Miscellaneous Systems Review the safety-related function of the Standby . Gas Treatment System valves to determine if they_should be included in the.IST program. These components need not be considered if they are simple air dampers rather than valves.
i
)
District Response !
The District position remains that valves associated with the SGT System are not within the scope of ASME Section XI testing.
However, the District agrees to submit a relief request (RV-37) for valves in the SGT System. This relief request will explain, how existing Technical Specifications and Surveillance Procedure testing meets or exceedsSection XI testing requirements.
1.P.4. NRC RAI - Miscellaneous Systems F
Review . the safety-related function of the TIP System valves to determine if they should be included in the IST prograr.
, District Response The ball valves in the TIP System will be categorized as ASME Class 1, Category B Active valves. They will be included in the CNS IST program and exercised quarterly.
The TIP System shear valves will be included in the IST program as Category D valves, and tested in-accordance with IWV-3610.
2.1. NRC RAI - Pump Testing Program.
Are lubricant levels / pressures observed during pump testing for all
, pumps in the CNS IST program? If no t , provide the specific technical justifications for not performing this testing.
District Response Lubricant levels / pressures are observed during pump testing for all pumps in the CNS IST program as per the January, 1986 Addenda to Revision 4 of the CNS IST program.
. 2.2. NRC RAI - Pump Testing Program How is the standby liquid control pump flow rate (Q) measured during each inservice test of these pumps?
District Response Standby liquid control pump flow rate is measured by a rate meter flow ~ element on the pump discharge line - to the. standby liquid control storage tank.
I
Razp:nta to NRC RAI - Crepar IST Program 2.3. NRC RAI - Pump Testing Program The NRC staff position is that measurement of vibration velocity is an acceptable alternate method to utilize to monitor pump vibration and has established a maximum velocity of 0.314 in/see as the Required Action limit. Exceptions to this staff position may be taken on a case by case basis provided that the licensee can adequately demonstrate that a particular pump historically exceeds this limit.
District Response The District agrees with the NRC staff position that measurement of vibration velocity is an acceptable alternate method to monitor pump vibration velocity. However, the District maintains that 0.450 in/sec is a meaningful required action range for those pumps in the CNS IST program (see Attachment 2 for RP-04, Revision 1).
2.4. NRC RAI - Pump Testing Program Does the RCIC pump perfonn a safety-related function at Cooper Nuclear Station?
District Response The RCIC pump at CNS does perform a safety-related function and will be included in the IST program.
2.5. NRC RAI - Pump Testing Program Do the reactor building closed cooling (REC) pumps perform a safety-related function? (Refer to question 1.A.13.)
District Response Refer to District Response to 1.A.13.
2.6. NRC RAI - Pump Testing Program
)
If pump parameter deviations fall within the Required Action Range
. of Table IWP-3100-2, the pump shall be declared inoperative regardless of whether it is also required to be declared inoperative by the Station Technical Specifications. The -IST program is implemented by and is, therefore, a part of the Station Technical Specification. Exceeding an IST program limit requires that'the 1
I Code mandated corrective actions be followed even if other Technical Specification limits have not been exceeded. _(Refer to Inservice Testing of Pumps General Procedure IV.B.S.C.2.)
District Response The District will follow the guidance given in IWP-3230 of Section XI which allows for retesting of the pump and an evaluation of various factors such Las coolant temperature, electrical l variances, etc., before a determination of inoperability'is made.
If pump inoperability is determined, then the pump will be declared ;
inoperable as required by CNS Technical Specifications. '
)
i
Rieponsa to NRC RAI - Comp 2r IST Program Additional NRC Questions as a Result of the April 15-16, 1986 Meeting NRC RAI - SA-CV-15, IA-CV-14, and M2-CV-15 Do these valves perform a containment isolation function and should they be included in the IST program?
District Response The District has reviewed the containment isolation function of these valves. These valves do not meet the criteria of 10CFR50, Appendix J requiring leak-rate testing. As such, these valves are not safety-related and will not be included in the IST program.
Additional IST Program Relief Request The District requests relief (RV-36) to exercise the two torus to Reactor Building Vacuum Relief valves once each refueling cycle instead of quarterly or during cold shutdown.
l
n Rmp::nga to NRC RAI - Coopr.r IST Program Enclosure.to ATTACHMENT 1 I
COOPER NUCLEAR STATION POWER OPERATED VALVES IN THE IST PROGRAM l LIMITING VALVE VALUE CIC SEC. BASIS PROCEDURE NORMAL OPERATING TIME CS-MO-12A. 1 60 Sec. Tech. Specs. 6.3.4.2 10.0 Sec.
CS-MO-12B 1 60 Sec. Tech. Specs. 6.3.4.2 10.0 Sec.
ACAD-1303MV i 15 Sec. Tech. Specs. 6.3.1.5 9.0 Sec.
ACAD-1304MV i 15 Sec. Tech. Specs. 6.3.1.5 7.0 Sec.
ACAD-1305MV i 15 Sec. Tech. Specs. 6.3.1.5 7.0 Sec.
ACAD-1306MV i 15 Sec. Tech. Specs. 6.3.1.5 7.0 Sec.
ACAD-1301MV , Tech. Specs. 6.3.1.5 6.0 Sec.
t -< 15 Sec.
ACAD-1302MV i 15 Sec. Tech. Specs. 6.3.1.5 9.0 Sec.
ACAD-1311MV i 15 Sec. Tech. Specs. 6.3.1.5 5.0 Sec.
ACAD-1312MV i 15 Sec. Tech. Specs. 6.3.1.5 8.0 Sec.
ACAD-1310MV i 15 Sec. Tech. Specs. 6.3.1.5 6.5 Sec.
ACAD-1308MV i 15 Sec. Tech. Specs. 6.3.1.5 8.0 Sec.
RHR-920MV 1 90 Sec. Tech. Specs. 6.2.6.3 14.0 Sec.
RHR-921MV 1 60 Sec. Tech. Specs. 6.2.6.3 12.0 Sec.
HPCI-A0-53 1 15 Sec. Tech. Specs. 6.3.3.2 3.0 Sec.
HPCI-AO-70 1 15 Sec. Tech. Specs. 6.3.3.2 1.0 Sec.
HPCI-AO-71 1 15 Sec. Tech. Specs. 6.3.3.2 1.0 Sec.
HPCI-MOV-M015 1 60 Sec. Tech.. Specs. 6.3.3.2 47.0 Sec.
HPCI-MOV-M016 1 60 Sec. Tech. Specs. 6.3.3.2 30.0 Sec.
HPCI-MOV-M017 i 80 Sec. Tech. Specs. 6.3.3.2 60.0 Sec.
HPCI-MO-M019 1 20 Sec. Tech. Specs. 6.3.3.2 17.0 Sec.
HPCI-MO-M025 1 10 Sec. Te.h. Specs. 6.3.3.2 4.0 Sec.
1 of 5
Rtap:nza to NRC RAI - Cooptr
'IST Program LIMITING VALVE VALUE CIC SEC. BASIS PROCEDURE NORMAL OPERATING TIME HPCI-M0-M058 1 90 Sec. Tech. Specs. 6.3.3.2 70.0 Sec.
HPCI-M0-M014 < 20 Sec. Tech. Specs. 6.3.3.1 18.0 Sec.
MS-A0-80A. 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-80B 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-80C. 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-80D 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-86A 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-86B 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
MS-AO-86C 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
i MS-AO-86D 3 <T <5 Tech. Specs. 6.3.9.4 4.0 Sec.
j MS-M0-74 1 30 Sec. Tech. Specs. 6.3.1.4 16.0 Sec.
MS-M0-77 1 30 Sec. Tech. Specs. '6.3.1.4 13.0 Sec.
RR-AO-740 1 15 Sec. Tech. Specs. 6.3.1.4 2.0 Sec.
RR-AO-741 1 15 Sec. Tech. Specs. 6.3.1.4 8.0 Sec.
RW-AO-82 1 15 Sec. Tech. Specs. 6.3.1.4 7.0 Sec.-
RW-AO-83 1 15 Sec. Tech. Specs. 6.3.1.4 ,10.0 Sec.
RW-AO-94 1 15 Sec. Tech. Specs. 6.3.1.4 5.0 Sec.
RW-AO-95 1 15 Sec. Tech. Specs. 6.3.1.4 5.0.Sec.-
RWCU-MO-15 1 60 Sec. Tech. Specs. 6.3.1.4 26.0 Sec.
RWCU-M0-18 i 60 Sec. Tech. Specs. 6.3.1.4 26.0 Sec.
I PC-230MV i 15 Sec. Tech. Specs. 6.4.8.3 6.0 Sec.
PC-231MV i 15 Sec. Tech. Specs. 6.4.8.3 5.0 Sec.
PC-232MV i 15 Sec. Tech. Specs. 6.4.8.3 3.0 Sec.
PC-233MV i 15 Sec. Tech. Specs. 6.4.8.3 3.0 Sec.
PC-237AV i 15 Sec. Tech. Specs. 6.4.8.3 6.0 Sec.
2 of 5
Racponsa to NRC RAI.- Coopar.-
IST Program LIMITING VALVE VALUE CIC SEC. BASIS PROCEDURE NORMAL'0PERATING TIME PC-238AV j[ 15 Sec. Tech. Specs. 6.4.8.3 9.0 Sec.
PC-245AV j[ 15 Sec. Tech. Specs. 6.4.8.3 12.0 Sec.
PC-246AV j[ 15 Sec. Tech. Specs. 6.4.8.3 11.0 Sec.
PC-305MV j( 40 Sec. Tech. Specs. 6.4.8.3 25.0 Sec.
PC-306MV f,40 Sec. Tech. Specs. 6.4.8.3 E20.0 Sec.
i RCIC-MO-15 f,25 Sec. IWV-3413 6.3.6.2 17.0 Sec.
RCIC-MO-16 f,25 Sec. IWV-3413 6.3.6.2 10.0 Sec.
I RCIC-MO-18 j[ 45 Sec. IWV-3413 6.3.6.2 25.0 Sec.
RCIC-MO-21 f,40 Sec. IWV-3413 6.3.6.2 28.0 Sec.
RCIC-MO-27 f,15 Sec. IWV-3413 6.3.6.2 6.0 Sec.
RCIC-MO-41 f,45Sec. IWV-3413 6.3.6.2 25.0 Sec.
I RCIC-MO-132 f,30 Sec. IWV-3413 6.3.6.2 17.0 Sec.
RCIC-AO-32 f,15 Sec. IWV-3413 6.3.6.2 3.0 Sec.
RCIC-M0-131 f,25 Sec. IWV-3413 6.3.6.1 13.0 Sec.
RHR-MOV-12A f,180 Sec. IWV-3413 6.3.5.2 84.0 Sec.
RHR-MOV-12B f,180 Sec. IWV-3413 6.3.5.2 82.0 Sec.
RHR-MOV-16A f,60 Sec. IWV-3413 6.3.5.2 20.0 Sec.
RHR-MOV-16B f,60 Sec. IWV-3413 6.3.5.2 20.0 Sec.
RHR-MOV-21A f,90 Sec. IWV-3413 6.3.5.2 20.0 Sec.
RHR-MOV-21B f,90 Sec. IWV-3413 6.3.5.2 23.0 Sec.-
RHR-MOV-25A f,24 Sec. IWV-3413 6.3.5.2 18.0 Sec.
RHR-MOV-25B f,24 Sec.- IWV-3413 6.3.5.2 18.0 Sec.-
.RHR-MOV-26A j[ 20 Sec. IWV-3413 6.3.5.2 11.0 Sec.
I RHR-MOV-26B < 20 Sec. IWV-3413 6.3.5.2 11.0 Sec..
RHR-MOV-27A f,35 Sec. IWV-3413 6.3.5.2 25.0 Sec.
3 of 5
- . . - ~ . .
'R22 pons 2.to NRC l RAI - Cooper
~ IST. Progrc:a
'l LIMITING
. VALVE -. VALUE CIC SEC. BASIS PROCEDURE NORMAL OPERATING TIME RHR-MOV-27B- .<'35 Sec. IWV-3413 '6.3.5.2- 25.0 Sec.
RHR-MOV-31A i 20 Sec. IWV-3413 6.3.5.2 11.0 Sec.
I RHR-MOV-31B < 20 Sec. IWV-3413 6.3.5.2 11.0 Sec.
RHR-MOV-34A < 60 Sec. -IWV-3413 6.3.5.2 20.0 Sec.
! RHR-MOV-34B < 60 Sec. 'IWV-3413 6.3.5.2 20.0 Sec.
4
, RHR-MOV-36A < 60 Sec. 'IWV-3413 6.3.5.2 20.0 Sec.
RHR-MOV-36B i 60 Sec. IWV-3413 6.3.5.2 20.0 Sec.
RHR-MOV-38A < 20 Sec. IWV-3413 6.3.5.2 11.0 Sec.
1 RHR-MOV-38B < 20 Sec. IWV-3413 ~6.3.5.2 11.0 Sec.
RHR-MOV-39A < 180 Sec. IWV-3413 6.3.5.2 94.0 Sec.
., RHR-MOV-39B < 180 Sec. IWV-3413 6.3.5.2 73.0 Sec.
RHR-MOV-65A < 180 Sec. IWV-3413 6.3.5.2- 85.0 Sec.
a RHR-MOV-65B ~< 180 Sec. IWV-3413 6.3.5.2 .04.0 Sec.
RHR-MOV-66A i 180 Sec. IWV-3413 6.3.5.2 89.0 Sec.
j RHR-MOV-166A 1 30 Sec. IWV-3413 6.3.5.2 -12.0 Sec.
i l RHR-MOV-66B < 180 Sec. .IWV-3413 6.3.5.2 86.0 Sec.
i l
RHR-MOV-166B i 30 Sec. IWV-3413 6.3.5.2 11.0 Sec.
I RHR-MOV-167A 1 30 Sec. IWV-3413 6.3.5.2 '11.0 Sec.
t
] RHR-MOV-167B < 30 Sec. IWV-3413 6.3.5.2 11.0 Sec.
CRD-A0V-CV-32A 1 30 Sec. Tech. Specs. 6.1.15 27.0 Sec.
1 to Close i
d' i; 100-500 IWV-3413 6.3.10.13 ~1 50.0 Sec;.
i Sec. to l Close
{
4 2-30 Sec.- IWV-3413 6'.3.10.13 5.0 Sec.
j to Open t.
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4 of 5
Rssponts.to NRC
+
RAI - Cooptr.
- IST Progros.
1 LIMITING
< VALVE: VALUE
! CIC SEC. BASIS ' PROCEDURE NORMAL OPERATING TIME CRD-A0V-CV-32B f,30 Sec. Tech. Specs. 6.1.15 27.0 Sec.
- . to Close 100-500 IWV-3413 6.3.10.13 150.0 Sec.
Sec. to close 2-30 Sec. IWV-3413 6.3.10.13' 5.0 Sec.
to Open CRD-A0V-CV-33 .f,30 Sec. Tech. Specs. 6.1.15 27.0 Sec..
to Close i
100-500 IWV-3413 6.3.10.13 130.0 Sec.
Sec. to Close j 2-30 Sec. IWV-3413 6.3.10.13 12.0 Sec.
{
to Open i
CRD-A0V-CV-34 < 30.Sec. Tech. Specs. 6.1.15 27.0 Sec.
l to Close j 100-500 IWV-3413 6.3.10.13 170.0 Sec.
i Sec. to Close
{
! 2-30 Sec. IWV-3413 6.3.10.13 8.0 Sec.
to Open PC-243AV < 20 Sec. Tech. Specs. 6.2.5.1 2.0 Sec..
- PC-244AV < 20 Sec. Tech. Specs. 6.2.5.1 3.0 Sec.
RR-M0-53A 20 f,Tf,26 Tech. Specs.-
6.3.10.7. 22.0 Sec..
RR-MO-53B 20 f,Tf,26 Tech. Specs. 6.3.10.7- 22.0.Sec.
J RHR-MO-17 f,40 Sec. Tech. Specs' . 6.3.10.7 36.0 Sec.
a.
RHR-MO-18 < 40 Sec. Tech. Specs. 6.3.10.7: 38'.0 Sec.
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RHR-MO-57 < 20 Sec. Tech. Specs. 6.3.10.71 19.0 Sec..
1 RHR-MO-32 f,60Sec. Tech. Specs. 6.3.10.7 . Valve De-energized .
per STP:85-08 a ,
, RHR-MO-33 < 60 Sec. Tech. Specs. 6.3.10.7 . Valve De-energized I
.per STP 85-08 RHR-MO-67 f,20 Sec. Tech. Specs. 6.3.10.7' 16.0 Sec.
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I~ . ATTACHMENT 2 y l .
The following Relief Requests have been previously submitted ~
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and are not included in this' attachment.
1 RP-01
} .RP-02
) RP-03 RP-05 l RV-01 j m 3
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RELIEF REQUESTS Tab RR No. Description 1 RP-01 Bearing Temperature Measurement .
2 RP-02 SLC Pump Inlet Pressure Measurement -
3 RP-03 SW Pump Vibration Measurement 4 RP-04 (Rev.1) Pump Vibration Measurement Method 5 RP-05 IIPCI Pump Test Method -
6 RP-06 REC Pump Testing ,
7 RP-07 DG-FOT Pump Testing ,
8 RV-01 Valve Leak-Rate Test Method and Criteria N/A RV-02 Replaced by Technical Justification TJV-01 N/A RV-03 Replaced by Technical Justification TJV-04 9 RV-04 Main Steam Isolation Valve Stroke Time, Required '
Action Relief 10 RV-05 Reactor Feedwater Check Valve Reverse Flow Test 11 RV-06 Valves CRD-CV-126 and CRD-CV-127 Testing Relief 12 RV-07 Check Valves CRD-114 and CRD-115 Testing Relief 13 RV-08 Diesel Generator Starting Air Valve Testing Relief 14 RV-09 Diesel Generator-Service Water. Inlet Check Valves (SW-CV-35, 36, 37, and 38) Testing Relief 15 RV-10 Diesel Generator-Fuel Oil Transfer Valve (DG-FOT-CV-10, 11, 12, and 13) Testing Relief 16 RV-11 Excess Flow Check Valves Testing Relief 17 RV-12 REC Check Valve Testing Relief 18 RV-13 REC Motor-Operated Valve Testing Relief 19 RV-14 Core Spray Pressure Maintenance Check Valves Testing to the Closed Position (CS-CV-12, 13, 14, and 15)
RELIEF REQUESTS (Cont'd)
Tab RR No. Description 20 RV-15 RHR Pressure Maintenance Check Valves Testing to the Closed Position (RHR-CV-18,19, 24, 25) 21 RV-16 HPCI Pressure Maintenance Check Valves Testing to -
the Closed Position (HPCI-CV-18 and 19) 22 RV-17 RHR/SW Core Standby Cooling Check Valve Testing i Relief (RHR-CV-20) 23 RV-18 SLC-CV-12 and SLC-CV-13 Testing Frequency 4
l 24 RV-19 SLC-14A and SLC-14B Squib Valves Testing Relief 25 RV-20 HPCI-CV-11 Testing Relief ,
26 RV-21 HPCI-LVSC-44 and HPCI-LVSC-50 Testing to the Closed Position 27 RV-22 HPCI-CV-24, 25, 26, and 27 Testing Frequency 28 RV-23 RCIC-CV-11 Testing Relief 29 RV-24 RCIC-CV-18 and 19 Testing to the Closed Position 30 RV-25 RCIC-LVSC-37 and RCIC-LVSC-42 Testing to the Closed Position
~
31 RV-26 RCIC-CV-22, 23, 24, and 25 Testing Frequency 32 RV-27 Main Steam Relief Valve Exercising Testing Frequency (MS-RV-71A to 71H) 33 RV-28 Main Steam Relief Line Vacuum Breaker Check Valve Testing Frequency (MS-CV-20 to 35) 34 RV-29 IA Accumulator Checks Test Frequency (IA-CV-17,18, 19, 20, 21, 22, 36, and.37) 35 RV-30 RWCU-CV-15 Test Frequency 36 RV-31 CRD-CV-13,14,15, and 16 Exercise Testing Frequency 37 RV-32 Service Water Motor-operated Valves Testing Relief 38 RV-33 Service Water Check Valves Testing Relief
RELIEF REQUESTS (Cont'd)
Tab RR No. Description 39 RV-34 Service Water Motor-operated Valves to RHR Testing Relief 40 RV-35 Service Water Check Valves to RHR Testing Relief
,.41 RV-36 PC-CV-13 and 14 Testing Frequency 42 RV-37 Standby Gas Treatment System Testing Relief TECHNICAL JUSTIFICATION Tab TJ No. Description 43 TJV-01 RHR-920-MV and RHR-921-MV Testing Frequency 44 TJV-02 RHk-MO-17 and RHR-MO-18 Testing Frequency 45 TJV-03 RHR-CV-23, RHR-M0-32, and RHR-M0-33 Testing Frequency 46 TJV-04 RR-MO-53A and 53B Testing Frequency
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Relief Request RP-04, Rev. 1 Pump: Core Spray Pumps lA, 1B Residual Heat Removal Pumps lA, IB, IC, ID High Pressure Coolant Injection Pump Service Water Pumps IA, IB, IC, ID Reactor Core Isolation Cooling Pump RHR-Service Water Pumps IA, IB, IC, ID Class: Core Spray - Class 2 Nuclear, ANSI B31.7 Residual Heat Removal - Class 2 Nuclear, ANSI B31.7 High Pressure Coolant Injection - Class 2 Nuclear, ANSI B31.7 Service Water - Class 4, ANSI B31.1, Safety-Related RHR-Service Water - Class 4, ANSI B31.1, Scfety-Related Reactor Core Isolation Cooling - Class 2, Nuclear, ANSI B31.7 Function: Core Spray - Emergency Core Cooling System Residual Heat Removal - Emergency Core Cooling System High Pressure Coolant Injection - Emergency Core Cooling System Service Water - Safety-Related Equipment Cooling RHR-Service Water - Residual Heat Removal Equipment Cooling I
Reactor Core Isolation Pump - Emergency Core Cooling System Test Requirements: IWP-4510, Vibration Amplitude, states that "At least one displacement vibration amplitude (V in mils (peak-to-peak composite) shall be read during each") inservice test.
Basis for Relief: IWP-4510 infers that an unfiltered displacement reading be taken which will be the sum of the individual vibrations occurring at different frequencies. This method evaluates displacement only and does not account for frequencies at which the displacements are occurring. This is significant because, for example, a vibration of five mils occurring at 10,000 cycles per second (cps) is much more severe than a vibration of five mils occurring at 1,000 cps.
Alternative Testing: The District proposes that vibration severity for the above pumps be determined by measuring vibration velocity (Vy ), which is a function of both displacement and frequency.
Acceptable, Alert, and Required Action ranges will be established using a combination of the " General Machinery Vibration Severity Chart" published by the American Society of Mechanical Engineers (67-PEM-14), see page 3.of 3 for chart, and from twelve years of proven satisfactory plant operating experience. The Section XI allowable ranges of vibration as given in Table IWP-3100-2 are based on pump reference values. 1 The District's proposed method will use absolute ranges which are independent of the original reference value.
Page 1 of 3 j
Accordingly, the specific action ranges for pump vibration velocity (V inches /sec.) in lieu of Section XI ranges will be -
as follows:"
Acceptable Range: V < .235 in/sec.
Alert Range: .235 in/sec < Vy < .450 in/sec Required Action Range: V > .450 in/see Again, this is based on proved satisfactory experf ence. -For example, reference values for the subject pumps at Cooper l Nuclear Station typically range _ from 0.10 in/see to 0.15 in/sec. An increase in a vibration level from 0.10 in/see to the upper limit of the proposed acceptable range of 0.235 in/sec is a 135% increase in vibration severity which meets or exceeds the 140% to 200% increase allowed by_
Section XI, Table IWP-3100-2.
It should be noted that the required IST vibration data taken and recorded are only a small portion of the station vibration monitoring program. Evaluations far and above the minimum requirements of Subsection IWP are performed routinely on the above pumps. These evaluations include monthly observation of multiple (not just single IST) vibration points and periodic
- real-time analysis of multiple pump vibration points over a broad range of frequencies. Further information on this program is available upon request. The District contends that
! the proposed alternative testing will meet or exceed the
] Section XI requirement to assess pump operability and operational readiness.
Vibration data will be evaluated in units of inches /sec. using the above action ranges.
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GENERAL MACHINERY VIBR ATION SEVERITY CHART For use as a GUIDE in judging vibration as a warning of impending trouble.
VIBR ATION FREQU ENCY CPM o 88 8 88g k k k kk .
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10.00 8.00 ~\ -- ZZ ..
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TZ f g 0.06 1 --~_ Z _ Q1 N 43 i
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$ 0.03 ____ __d
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2 Relief Request RP-06 Pumps: REC-1A REC-1B REC-1C REC-ID Class: ANSI B31.1 Function: Reactor Building Closed Cooling Water Pumps.
Required Test: Quarterly testing in accordance with Section XI.
Basis for .
Relief: Three pumps are typically in service 100% of the time.
Running pumps are shifted daily to distribute
, operation. Readings and observations of each pump are taken daily and during pump shifts.
Surveillance Procedure 6.3.16.1 requires monthly testing of these pumps. Since these pumps are essentially inservice continuously and operability evaluated monthly, additional Section XI testing would offer no benefits.
Alternative Test: Daily pump operational evaluation and monthly testing -
(per Surveillance Procedure 6.3.16.1) will serve in lieu of Section II testing.
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Relief Request RP-07 Pumps: DG-FOT-1A DG-FOT-1B Class: ANSI B31.1 Function: Diesel Generator Fuel Oil Transfer (DG-FOT) Pumps i Required Test: Quarterly testing in accordance with Section XI.
, Basis for Relief: Cooper Nuclear Station Technical Specification 4.9.A.2.a requires that a monthly ' test of each diesel generator be performed and that the operation of the diesel fuel oil i transfer pumps and fuel oil day tank level switches be demonstrated. If this test ~is not completed satisfactorily, 4
the diesel generator. is declared inoperable and a limiting
- condition of operation is entered requiring either equipment
- repair within a specified time or plant shutdown.
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These pumps are operated to refill the fuel oil day tanks every-t month during Surveillance Procedure 6.3.12.1 testing.
! Additionally,'each pump is functionally evaluated. each refueling cycle during DG-FOT pump testing per Surveillance j Procedure 6.3.12.8. Pump failure during the above testing j would require corrective actions to ensure fuel oil ' supply
- specifications are met.--
i Alternative Test: In lieu of Section XI testing, current CNS Surveillance Procedure testing will serve to assess pump ' operational
! readiness. CNS . Surveillance Procedures will meet or exceed Section XI requirements, i
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. _ . . _ , _ ___. ,_ _, . , _ _ _ . _ , . , _ . . . _ , , _ , . . . ~ . . _ , , _ _ _ _ - _ _ . , , - . . _ _ . _ , - . ...J,,.. . . . ,
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Relief Request RV-04 Valves: 24" MS-AO-80A 24" MS-AO-86A 24" MS-AO-80B 24" MS-AO-86B 24" MS-AO-80C 24" MS-AO-86C 24" MS-AO-80D 24" MS-AO-86D l Class: 1
- Function: Inboard and Outboard Main Steam Isolation Valves (MSIV) -
I for Loops A, B, C, and D. -'
i Required Test: IWV-3417(a) requires to increase the test -frequency to 1 once each month should the full-stroke time increase by 50% or more from the previous test time (for valves with a stroke-time less than 10-seconds).
i Basis for l Relief: Each MSIV is full-stroke timed each quarter.
Stroke-time specifications in seconds (T) are given below:
J l With Flow 3<T<5 j Without Flow 4 < T < 4.5 The normal operating time is 4-seconds. A 50%
deviation from the normal operating time would be 2-seconds or 6-seconds. This would exceed specification limits and corrective action would be required. Since corrective action is required before the 50% deviation is reached, an increase in test
- frequency would not serve any purpose.
1 Alternative l Test: Due to the short stroke-time specifications for the j MSIVs, no increase in test frequency will be performed if stroke-time exceeds 50% of the previous test value.
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Relief Request RV-05 Valves: 18" RF-CV-13 18" RF-CV-14 18" RF-CV-15 18" RF-CV-16 Class: 1 Function: Main Feed Check Valves .
Required Test: Test in accordance with IWV-3522(a), normally open valves. Valves that are normally open and.whose function is to prevent reverse flow shall be tested in a manner that proves that the disk travels to the seat promptly on cessation or reversal of flow. Confirma-
! tion that the disk is on the seat shall be by visual observation, by an electrical signal initiated by a position indicating device, by observation of appropriate pressure indications in the system, or by
, other positive means.. .
, Basis for
- Relief: These valves are normally open and must remain open I during reactor operations to ensure adequate feedwater flow. Feedwater provides normal reactor core cooling during operation. To exercise these valves during plant operation could cause a reactor scram due to the transitory nature of operating the feedwater pumps at i low-flow or no-flow conditions.
Alternative Test: These valves will be exercised to a closed position during refueling outages. The observation of specified leakage during local leak-rate testing provides the only means for verification to the closed position.
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-Relief Request.RV ,
Valves: 3/4" CRD-CV-126 (Typical of 137 each) i 3/4".CRD-CV-127 (Typical of 137 each)'
3/4" CRD-CV-114 (Typical of 137-each) i l Class: 2 i
i Function: Control Rod Drive . (CRD) Hydraulic System scram inlet (CRD-CV-126), and exhaust (CRD-CV-127) air-operated valves, and-exhaust check valve (CRD-CV-114)..
Required Test: Full-stroke exercise, observe proper operation of fail-safe j mechanism, and measure stroke-time quarterly or each cold
- shutdown.
! Basis for Relief: These valves are required to operate for rapid insertion (scram)'
, of control rods. Each valve is tested by scram-timing control rods in accordance with Technical Specification . Sections 3.3.
and 4.3 and Nuclear Performance Evaluation Procedure 10.9. The
- Technical Specifications require testing 10% of the CRDs every 16-weeks and 100% of the drives af ter each refueling outage.
The CRDs must fully insert within specified time limits.
i Should either the insert or exhaust valves fail, the CRDs may i not be able to meet Technical Specification requirements.
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- The air operated valves fail-open on loss of air or power.
Normal opening removes power to the pilot solenoid valve
, simulating a loss of power. On loss of power the solenoid i vents the air-operator and CRD-CV-126 and CRD-CV-127 are spring.
j driven open. Thus each time _a . scram signal is given, the j valves " experience" a loss of air / power to verify each valves j fail-safe open feature. In effect, scram testing meets or
- exceeds the functional testing-requirements of Section XI to assess operational readiness.-
4 Alternative Test: Scram testing per Technical Specification will be substituted
! for all Section XI requirements.- The test frequency will be 4
10% each 16-weeks and 100% after each refueling outage.
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_______..____________.________._._____.__.___..___m--____.._______._____..____________.__.________._______________._______.-..__m__ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _
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i Relief Request RV-07 i
. Valve: 3/4" CRD-CV-115 (Typical of 137 each)
Class: 2 l Function Control Rod Drive (CRD) Hydraulic System scram inlet check valve.
Required Test: Exercise quarterly or each cold shutdown.
Basis for Relief: This valve is required to operate for rapid insertion (scram) of control rods. It is partially tested by scram-timing control rods in accordance with Technical Specification-Section 3.3 and 4.3 and Nuclear Performance Evaluation Procedure 10.9. . Technical Specifications require testing 10%
of the CRDs every 16-weeks and'100% of the drives after each' i i refueling outage. The CRDs must fully insert within specified
- time limits. Should the check valve fail to close, the CRDs
] may not be able to meet Technical Specification requirements.
j This valve is tested in the reverse flow direction (closed i position) by Surveillance Procedure 6.4.1.8. This test isolates each CRD scram accumulator and vents pressure on the
! upstream side of the check valve.. Accumulator pressure decay l would be observed should the valve fail to close properly.
! Corrective action is required if any CRD accumulator inlet j check valve should fail to hold pressure in accordance with specifications.
Alternative Test: Testing per Surveillance Procedure 6.4.1.8 will be substituted for Section XI requirements. The test frequency will be each refueling cycle. ,
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Relief Request RV-08 Valves: DG-SA-CV-10 DG-SA-CV-14 DG-SA-CV-18 DG-SA-CV-11 DG-SA-CV-15 DG-SA-CV-19 DG-SA-CV-12 DG-SA-CV DC-SA-CV-20 DG-SA-CV-13 DG-SA-CV-17 DG-SA-CV-21 j Class: ANSI B31.1 Function: Provide sufficient starting air to start the diesel generators on loss of site electrical power.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These valves are required to operate to ensure sufficient air pressure to start the diesel generators (DG). Cooper Nuclear Station Technical Specification 4.9.A.2.a requires that a monthly test of each diesel generator be performed and that during this test the operation of the diesel generator starting
, air compressors are checked as well as the ability to recharge air receivers. If this test is not completed satisfactorily, the diesel generator is declared inoperable and a limiting condition of operation is entered requiring either equipment repair within a specified time or plant shutdown. Proper valve operability is verified at least monthly by Surveillance Procedure 6.3.12.1 or 6.3.12.2. These procedures test operability of the DG and the DG starting air (SA) compressors.
Failure of a DG to start during monthly testing, vould require corrective actions. This would include repair or replacement of starting air valves.
Alternative Test: In lieu of Section XI valve testing, current CNS Surveillance Procedure testing as required by the Station Technical Specifications will serve to assess valve operational readiness and serve as an alternate to Section XI requirements.
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Relief Request RV-09 l
Valves: 10"-SW-CV-35CV
- 10"-SW-CV-36CV i 10"-SW-CV-38CV 10"-SW-CV-35CV .
l
- Class
- ANSI B31.1
{ Function: Diesel Generators Service Water (DG-SW) inlet supply -
l check valves for engine cooling and diesel generator *
, room cooling units.
Required .
Test: Exercise to assess operational readiness every quarter.
Basis for Relief: These check valves are in the lines to supply cooling water to the emergency diesels. Diesel temperatures 2
are monitored during monthly testing. Should these
. valves fail to open or provide adequate flow for DG i cooling the problem would be observed during this monthly test. Should DG operational temperature exceed
- specification, corrective action would be required per i
Surveillance Procedure 6.3.12.1.
Currently Surveillance Procedure 6.3.10.16 is used to
- visually inspect the DG-SW check valves once every three years. This procedure meets the suggested
, requirements in IE-Bulletin 83-03.
- Alternative i Test
- In lieu of Section XI testing, each valve will be l disassembled and visually inspected every three years i
and operability assessed every month during DG
- operability testing. This combination of testing meets 1 or exceedsSection XI testing requirements.
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Relief Request RV-10 Valves: 2" DG-FOT-CV-10 2" DG-FOT-CV-11 2".DC-FOT-CV 2" DG-FOT-CV-13 Class: ANSI B31.1 Function: Diesel Generator Fuel Out Transfer (DG-FOT) Pump Outlet and Building Penetration Check Valves.-
Required Test: Exercise to assess operational readiness every quarter.
Basis for Relief: Cooper Nuclear Station Technical Specification 4.9.A.2.a requires that a monthly ' test of each diesel generator be -
performed and that the operation of the diesel fuel oil transfer pumps and fuel oil day tank . level switches be demonstrated. Proper operation of these check valves is necessary for satisfactory performance of this test. If this test is not completed satisfactorily, the diesel generator is declared inoperable and a limiting condition of operation is entered requiring either equipment repair within a specified time or plant shutdown.
These valves are operated to refill the fuel oil day tanks every month during Surveillance Procedure 6.3.12.1 testing.
Additionally, each valve is functionally evaluated each refueling cycle during DC-FOT pump testing per Surveillance Procedure 6.3.12.8.- Valve failure during the above testing would require corrective actions to ensure fuel oil supply specifications are met.
Alternative Test: In lieu of Section XI testing requirements, current CNS Surveillance Procedure testing will serve to assess valve operational readiness. CNS Surveillance Procedures.will meet.
or exceed Section X1 requirements.
Relief Request RV-11 Valves: Excess Flow Check Valves 10 DCV to 47 BCV (Drawing 2026) 10 CV to 13 CV (Drawing 2027) 15 CV to 18 CV (Drawing 2027) 27 CV to 28 CV (Drawing 2027) 30 CV to 33 CV (Drawing 2027) 48 BCV (Drawing 2028) 10 BCV to 11 BCV (Drawing 2041) 10 BCV and 11 BCV (Drawing 2041) 10 BCV to 13 BCV (Drawing 2041)
, 16 BCV and 17 BCV (Drawing 2045)
Class: 2 Function: These valves are installed in instrument lines that provide signals for operation of safety related valves and pumps. They prevent excess flow of reactor water should an instrument.line break outside containment.
4 Required Test: Test in accordance with Section XI.
Basis for Relief: Uninterrupted function of these valves is essential for continuous monitoring of reactor plant parameters and is hence necessary for proper plant operation. Routine testing in accordance with Section XI would cause instrument line interruptions. This would disable instruments required for safe plant operations, safety-system actuation, reactor
- shutdown, or sensing accident conditions.
The excess flow check valves are tested using a modified leak-rate test to assess operability. Testing is performed at least once each operation cycle per Surveillance Procedure 6.3.10.2 and Technical Specification 4.7.D.1.d.
Testing more frequently could jeopardize the safety of the reactor.
Alternative Test: In lieu of Section XI testing a modified leak-rate test will be performed. Surveillance Procedure 6.3.10.2 meets or exceeds 1 the intent of Section XI for testing excess flow check valves..
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Relief Request RV-12 Valves: 8"-REC-CV-10 8"-REC-CV-15 8"-REC-CV-11 12"-REC-CV-16 8"-REC-CV-12 8"-REC-CV-13 Class: ANSI B31.1 Function: 8"-REC-CV-10, 8"-REC-CV-11, 8"-REC-CV-12 and 8"-REC-CV-13 are the REC pump outlet check valves.
8"-REC-CV-15 is the REC cooling water to containment cooling unit check valve.
12"-REC-CV-16 is the REC pump suction check valve return from noncritical cooling.
Required Test: Exercise quarterly in accordance with Section XI.
Basis for Relief: Usually three of the four REC pumps are in service all the time. Pumps are shifted daily to ensure an equal distribution of use. Surveillance Procedure 6.3.16.1 requires the testing of each of the REC pumps monthly. This testing observes proper flow and no reversal of flow when a pump is stopped. Should any of these valves fail, inadequate flow rates would be observed and corrective action would be required.
Cooper Nuclear Station Technical Specification 4.12.B requires periodic testing of the REC system to verify operability of the REC loops. If this operability is not verified, a limiting condition of operation is entered requiring either equipment repair within a specified time or plant shutdown.
Alternative Test: In lieu of Section XI testing, each valve's operational readiness will be assessed during daily operations (pump shifting) and during monthly testing per Surveillance Procedure 6.3.16.1. The above evaluation will meet or exceed Section XI exercise testing requirements.
-Relief Request RV-13 Valves: 4"-REC-MO-694 10"-REC-MO-700 12"-REC-MO-712 4"-REC-MO-695 8"-REC-MO-702 12"-REC-MO-713 6"-REC-MO-697 8"-REC-MO-709 12"-REC-MO-721 6"-REC-MO-698 6"-REC-MO-711 12"-REC-MO-722-6"-REC-MO-714 12"-REC-MO-1329 Class: ANSI B31.1 Function: 4"-REC-MO-694 & 695 Loop A and B cross connections 6"-REC-MO-697 & 698 Critical Service Water Return 10"-REC-MO-700 Isolation to Noncritical Service Water 8"-REC-MO-702 & 709 Isolation to containment Cooling Units 12"-REC-MO-712 & 713 REC Heat Exchanger Inlet Isolations 6"-REC-MO-711 & 714 REC Heat Exchanger Outlet Isolations 12"-REC-MO-721 & 722 Noncritical Return to REC Pump' Suction Section Cross Connection 12"-REC-MO-1329 REC Isolation to Radweste Required Test: Full-stroke and stroke-time quarterly in accordance with Section XI.
Basis for Relief: The REC system is in operation continuously. The above valves are in the normal. position required for the system to perform-its safety related function. As required . by Technical' Specifications, each valve is ' exercised monthly .using Surveillance Procedure 6.3.16.2 and returned to its normal, position after testing. Should a valve fail.to demonstrate operability, corrective actions are required by the Technical Specifications.
Surveillance Procedure 6.3.16.2 will : serve to . assess the operational readiness of the REC motor operated valves.
4
t Relief Request RV-13 Page 2 Alternative .
Test: In lieu of Section XI testing these REC valves will be tested in accordance with Surveillance Procedure 6.3.16.2. These monthly operational tests will meet or exceed the requirements of Section XI. .
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Relief Request RV-14 Valves: 2" CS-CV-12 2" CS-CV-13 '
2" CS-CV-14 2" CS-CV-15 Class: 2 Function: Core Spray (CS) Loop A and Loop B pressure maintenance check valves from the condensate supply system.
Required
- Test
- Exercise each quarter or cold shutdown.
Basis for Relief: These valves are normally open check valves (with 2 in series).
They are required to be open to keep the CS system in a solid >
stand by condition. When the CS pumps start, these valves should close to ensure maximum flow to the test loop or reactor.
l Surveillance Procedure 6.3.4.1 for CS pump testing provides adequate testing to verify the open position for these valves.
Prior to pump testing, system vent valves are opened and flow is observed. This flow will verify the pressure maintenance valves are open and operating properly. This is required by Technical Specification 4.5.G.1 When a CS pump is started, required CS pump flow rate and discharge pressure would verify one of the two valves in series per loop has closed. Corrective action would be required if pump parameters were not within specification. In addition, should both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply side of the valves. The current system design does not allow to ensure both valves have closed.
Alternative Test: In lieu of Section XI valve testing, current CNS Surveillance Procedure testing will serve to assess valve operational readiness.
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Relief Request RV-15 ,
i Valves: 4" CS-CV-18 1
4" CS-CV-19
, 4" CS-CV-24 4" CS-CV-25 Class: 2 J
1 Function: Residual Heat Removal (RHR) Loop A and . Loop B pressure maintenance check valves from the condensate supply system.
Required Test: Exercise each quarter or cold shutdown.
Basis for -
Relief: These valves are normally open check valves (with 2 in series).
They are required to be open to keep the RHR system in a solid stand by condition. When.the RHR pumps start'these valves should close, to ensure maximum flow to the test loop - or
, reactor.
Surveillance Procedure 6.3.5.1 for RHR pump testing provides
! adequate testing to verify the open position for these valves.
Prior to pump testing, system vent valves are opened and' flow is observed. This flow will verify the pressure maintenance
- valves are open and operating properly. This is required by
- Technical Specification 4.5.G.1 When a RHR pump is started, required pump flow rate' and discharge pressure would verify one of the two valves in series per loop har closid. Corrective action would be required if
- pump parameters were not within specification. In addition,
! should both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply side of -
the valves.- The current system design does not allow to ensure both valves have closed.
Alternative Test: In lieu of Section XI valve testing current CNS Surveillance Procedure testing will serve to assess valve operational readiness.
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Relief Request RV-16 Valves: 2" HPCI-CV-18 2" HPCI-CV-19 Class: 2 Fenetion: High Pressure Coolant Inj ection (HPCI) pressure maintenance check valves from the condensate supply sys. tem.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These valves are normally open check, valves in series. They are required to be open to keep the HPCI system in a solid stand by condition. When the HPCI pumps start, these valves should close to ensure maximum flow to the test loop or reactor.
Surveillance Procedure 6.3.3.1 for HPCI pump testing provides adequate testing to verify the open position for these valves.
Prior to pump testing, system vent vcives are opened and flow is observed. This flow will verify the pressure maintenance ,
valves are open and operating properly. This is required by Technical Specification 4.5.G.1 When a pump is started, required pump flow rate and discharge pressure would verify one of the two valves in series has closed. Corrective action would be required if pump parameters were not within specification. In addition, should both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply side of the valves. The current system design does not allow to ensure both valves have closed.
Alternative Test: In lieu of Section XI valve testing current CNS Surveillance Procedure testing will serve to assess valve operational readiness.
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l Relief Request RV-17 Valve: 14" RHR-CV-20 Class: 2 Function: The 14" RHR-CV-20 check valve is the emergency Service Water (SW) (river water) supply for core flooding. This valve prevents RHR to SW backflow to help prevent radioactive contaaination of the SW system.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: Routine exercising with SW flow could potentially allow corrosive materials and sand to be introduced into the Reactor Coolant system via RHR. This could lead to chemical transients in the primary coolant allowing excessive corrosion and degradation of reactor internals, associated _ pumps, piping and valves. This could be conductive to reactor and or system damage, therefore, RHR-CV-20 can not be exercised with flow during operations or cold shutdown.
Inspection History: RHR-CV-20CV has been disassembled and manually stroked five times since 1980.
Date Results
' 3 April 1980 Satisfactory April 1981 Satisfactory June 1982 Satisfactory September 1983 Satisfactory i August 1985 Satisfactory i
A review of plant equipment history indicates no previous mechanical failure for RHR-CV-20CV. As such, the inspection frequency will be decreased to every third refueling outage.
Alternative Test: During every third refueling outage, this valve will be disassembled and manually full-stroke exercised. The history of previous inspection results justify decreasing the test frequency from once per refueling outage to once every third refueling outage.
o Relief Request RV-18 Valves: 1.5" SLC-CV-12 1.5" SLC-CV-13 Class: 1 Function: Inboard and outboard containment isolation valves which must open to allow injection of sodium pentaborate (poison) for reactivity control.
Required Test: Exercise each check valve quarterly or cold shutdown.
Basis for Relief: To test SLC-CV-12 and SLC-CV-13 quarterly would require manually valving-out the sodium pentaborate (poison) suction to the SLC pumps, flushing the system with demineralized water, and injecting cold demineralized water into a hot operating reactor vessel.
Injecting cold water into a hot reactor vessel could cause thermal stresses in the piping, nozzles, or the reactor vessel and could potentially lead to reactor damage, fuel damage, and potential release of radioactive material. Also, Technical Specification 3.4.D require the reactor to be in cold shutdown within 24-hours after the SLC system is declared inoperative (valving-out pump suction).
To test these valves during cold shutdown would require firing the squib valves or valve disassembly. It would also require flushing the SLC system lines to remove any trace of poison.
Introduction of residual poison could lead.to degradation of reactivity control and potential reactor damage.
Surveillance Procedure 6.3.8.4 tests both check valves for opening each refueling cycle. Also, both valves are verified as closing during leak-rate testing each cycle, should either valve fail to function corrective action would be required.
Alternative Test: In lieu of Section XI testing quarterly or each cold shutdown, SLC-CV-12 and SLC-CV-13 will be exercised each refueling outage.
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Relief Request RV-19 4
Valves: 1.5" SLC-14A 1.5" SLC-14B Class: 1 Function: Squib or explosive actuated valves for SLC injection of sodium pentaborate (poison) to the reactor vessel.
Required Test: Full-stroke exercise quarterly or each cold shutdown.
Basis for Relief: To open these valves routinely during operations or cold shutdown would allow concentrated sodium pentaborate to go past the valve and have the potential to enter the reactor coolant system. This could lead to a loss of reectivity control, system corrosion and potential damage to reactor internal components. Surveillance Procedure 6.3.8.4 requires explosively opening these 'ralves every other refueling cycle after system flushing. This test will ensure valve operability and serve to verify explosive actuator function in accordance with Section XI.
Alternative Test: Full-stroke exercised by firing the explosive actuator in place once every other refueling cycle.
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Relief Request RV-20 Valve: 16" HPCI-CV-ll Class: 2 Function: This valve is the HPCI pump suction line check valve from the torus and is normally closed.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: Partial or full-stroke exercising nis valve would involve a system design which would permit recirculation to and from the torus. This is not possible with the existing system design.
Inspection History: HPCI-CV-11CV has been disassembled and manually stroked seven times since 1978.
Date Results April 1978 Satisfactory May 1979 Satisfactory April 1980 Satisfactory April 1981 Satisfactory June 1982 Satisfactory September 1983 Satisfactory August 1985 Satisfactory-A review of plant equipment history indicates no previous mechanical failure for HPCI-CV-11CV. As such, the inspection frequency will be decreased to every third refueling outage.
Alternative Test: This valve will be disassembled and manually full-stroke
- exercised during every tnird refueling outage. .The history of previous inspection results justify the test frequency of once every third refueling outage.
Relief Request RV-21 Valves: 20"-HPCI-LVSC-44 2"-HPCI-LVSC-50 Class: 2 Function: 20"-HPCI-LVSC-44 is a containment isolation stop check valve from the HPCI turbine exhaust to the torus.
2"-HPCI-LVSC-50 is a containment isolation valve.from the HPCI turbine drain to the torus.
These valves are normally closed and locked open to allow free disk movement. They open during monthly HPCI pump operability testing, and are required to close for containment isolation..
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: Mechanically exercised to the closed position - quarterly or-during cold shutdown could result in failure or sticking of either valve. This would render the HPCI' system inoperable and a limiting condition of operation would be entered requiring.
either equipment repair within a specified . time or plant shutdown.
Alternative Test: The above valves will be verified as closing each refueling outage during leak-rate testing, and verified as opening during monthly HPCI pump testing.
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Relief Request RV-22 Valves: 2"-HPCI-CV-24 2"-HPCI-CV-25 2"-HPCI-CV-26 2"-HPCI-CV-27 Class: 2 Function: Check valves required to open for vacuum relief or the HPCI turbine exhaust line to the torus.
< Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: The HPCI turbine exhaust vacuum breaker checks are located in the torus area. These valves are inaccessible or access is extremely hazardous for mechanical exercising during operations and cold shutdowns. The torus is contaminated and filled with water.
Exercising each refueling cycle would serve to adequately assess valve operational readiness and not unduely expose personnel to excess radiation exposure and safety hazards.
Alternative -
Test: Mechanical exercising will be performed each refueling outage, e
d Relief _ Request RV-23 Valve: 6" RCIC-CV-11 Class: 2 4 -Function: This valve is.the_RCIC pump suction line check valve from the torus and is normally closed.
Required Test: Exercise each quarter or cold shutdown.
4 Basis for Relief: Partial or full-stroke exercising this valve would involve a
, system design which would permit recirculation to and from1the torus. This is not possible with the existing system design.
Inspection
- History
- RCIC-CV-11CV has been disassembled and manually stroked seven
! times since 1978.
I Date Results March 1978 Satisfactory May 1979 Satisfactory April 1980 Satisfactory April 1981 Satisfactory i June 1982 Satisfactory.
September 1983 Satisfactory
- August 1985 Satisfactory 1
j A review of plant equipment history indicates no previous mechanical failure for RCIC-CV-11CV. As such, the-inspection frequency will be decreased to every third refueling outage.
1 j Alternative i Test: This valve will be disassembled and manually ' full-stroke -
exercised during every third, refueling outage. The history of-
! previous inspection results justify the test frequency of once j every third refueling outage.
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Relief Request RV-24 Valves: 2" RCIC-CV-18 2" RCIC-CV-19 Class: 2 Function: Reactor Core Isolation cooling (RCIC) pressure maintenance check valves from the condensate supply system.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These valves are normally open check valves in series. They are required to be open to keep the RCIC system in a solid stand by condition. When the RCIC pumps starts, these valves should close to ensure maximum flow to the test loop or reactor.
Surveillance Procedure 6.3.6.1 for RCIC pump testing provides adequate testing to verify the open position for these valves.
Prior to pump testing, system vent valves are opened and flow is observed. This flow will verify the pressare maintenance valves are open and operating properly and is required by Technical Specification 4.5.G.1 When a pump is started, required pump flow rate and discharge pressure would verify one of the two valves in deries per loop has closed. Corrective action would be required if pump parameters were not within specification. In addition, should both valves fail to close a relief valve would lift or a pressure sensor would alarm on the condensate supply side of the valves. The current system design does not allow to ensure both valves have closed.
Alternative Test: In lieu of Section XI valve testing current .CNS Surveillance Procedure testing will serve to assess valve operational readiness.
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Relief Request RV-25 Valves: 8"-RCIC-LVSC-37 2"-RCIC-LVSC Class: 2 Function: 8"-RCIC-LVSC-37 is a containment isolation stop check valve from the RCIC turbine exhaust to the torus.
2"-RCIC-LVSC-42 is a containment isolation valve from the RCIC turbine drain to the torus.
These valves are normally closed and locked open to allow free disk movement. They open during monthly RCIC pump operability testing and are required to close for containment isolation.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: Mechanically exercised to the closed position quarterly or during cold shutdown could result in failure or sticking of either valve. This would render the RCIC system inoperable.
Alternative Test: The above valves will be verified as closing each refueling outage during leak-rate testing and verified as opening during monthly RCIC pump testing.
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Relief Request RV-26 Valves: 1.5"-RCIC-CV-22 1.5"-RCIC-CV-23 1.5"-RCIC-CV-24 1.5"-RCIC-CV-25 Class: 2 Function: Check valves required to open for vacuum relief of the RCIC
- turbine exhaust line to the torus.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: The RCIC turbine exhaust vacuum breaker checks are located in the torus area. These valves are inaccessible or access is extremely hazardous for mechanical exercising during operations and cold shutdowns. The torus is contaminated and filled with water.
Exercising each refueling cycle would serve to adequately assess valve operational readiness and not unduely . expose personnel to excess radiation exposure and safety hazards.
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, Alternative Test: Mechanical exercising will be performed each refueling outage.
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Relief Request RV-27 Valves: 6" MS-RV-71A 6" MS-RV-71E 6" MS-RV-71B 6" MS-RV-71F.
6" MS-RV-71C 6" MS-RV-71G 6" MS-RV-71D 6" MS-RV-71H Class: 1 Function: Main steam power operated safety relief valves.
Required Test: Full-stroke exercise and stroke-time each quarter or cold shutdown.
Basis for Relief: These valves are power actuated and serve as safety relief l valves for the main steam lines. Each valve is currently exercised in accordance with Surveillance Procedure 6.3.2.1.
Exercising these valves during reactor operations can cause pressure, temperature, and reactivity transients to the primary pressure boundary and containment system..
The valve supplier does not recommend exercising these valves
- below 150 psig steam pressure because of the risk of valve seat j damage and resultant leakage. Technical Specifications. require testing once each refueling cycle at a reactor pressure
> 100 psig which is adequate to assess the' operation readiness of these valves.
Relief valves are quick acting and their stroke-time cannot be measured by conventional means. Successful exercising will verify adequate stroke-time. Should a relief valve fail to i function as designed' corrective action is required.
Alternative Test: Exercise once each refueling cycle in -accor6.nce with Surveillance Procedure 6.3.2.1.
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Relief Request RV-28 Valves: 1"-MS-CV-21 1"-MS-CV-26 1"-MS-CV-31 1"-MS-CV-22 1"-MS-CV-27 1"-MS-CV-32 1"-MS-CV-23 1"-MS-CV-28 1"-MS-CV-33 1"-MS-CV-24 1"-MS-CV-29 1"-MS-CV-34 1"-MS-CV-25 1"-MS-CV-30 1"-MS-CV-35 Class: 2 Function: Check valves required to open for vacuum relief of the Main Steam Relief lines to the containment.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These vacuum breaker checks are located inside containment.
They are inaccessible or access is extremely hazardous ~for mechanical exercising during operations.
Exercising once each refueling cycle during cold shutdown would serve to adequately assess valve operational readiness and not unduely expose personnel to excess radiation exposure and safety hazards.
Alternative Test: Mechanical exercising will be performed each refueling outage.
Relief Request RV-29 Valves: 1" IA-CV-17 1"'IA-CV-21 1" IA-CV-18' 1" IA-CV-22 1" IA-CV-19 1" IA-CV-36 1" IA-CV-20 1" IA-CV-37 Class: ANSI B31.1 Function: Instrument Air accumulator inlet check valves for Main Steam relief valve operators.
Required Test: Exercise every quarter or cold shutdown.
Basis for Relief: These valves are inside containment and inaccessible or i
extremely difficult to access during normal operations or cold shutdown. An extended time / pressure decay procedure will be used to verify each valve closure. This will be done by venting the upstream side of the check valve and monitoring accumulator pressure to ensure each check valve functions properly.
Performance of this test during each cold shutdown would not significantly improve assessment of valve operability since the relief valves operated by these accumulators are only exercised each refueling cycle. Assessment of valve operability during each cold shutdown would significantly increase personnel exposure and not improve plant safety.
Alternative Test: The above valves will be tested to verify closure during each refueling outage in accordance with Surveillance Procedure 6.3.9.1.
- Relief Request RV-30 Valve: 4" RWCU-CV-15 Class: 1 Function: Normally open Reactor Wacer Clean Up (RWCU) return line check valve and containment isolation valve.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: This valve cannot be verified as being closed upon reversal or stopping of flow without opening and venting the line on the upstream side of the check valve. Opening or venting the line
' on the upstream side of the check valve. Opening or venting the RWCU line during operations could cause a leak of high pressure reactor coolant and potentially lead to the release of radioactive material.
An extended RWCU system outage during normal operations or cold shutdown would lead to a degradation of reactor water purity.
This would add to the radioactive contamination in the reactor coolant system, could lead to additional exposure of site personnel. It is essential that RWCU remain in operation as much as possible and RWCU-CV-15 closure verification be performed only during refueling outages.
Alternative Test: 4"-RWCU-CV-15 will be verified for - closing during leak-rate testing once each refueling cycle.
Relief Request RV-31 Valves: 3/4" CRD-CV-13 3/4" CRD-CV-14 3/4" CRD-CV-15 3/4" CRD-CV-16 Class: 2 Function: Containment isolation valves for Control Rod Drive seal injection water for the Reactor Recirculation (RR) pumps.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These valves cannot be exercised during operation. Stopping or reversal of flow would impose a severe thermal transient on the-RR Pump Seals, which could possibly lead to seal failure.
Alternative Test: Each valve will be verified as operating- properly (closing) during the leak-rate test performed each refueling cycle.
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Relief Request RV-32
! Valves: 24" SW-MO-37 4" SW-MO-886 ' 18" SW-M0-650 24" SW-MO-117 4" SW-MO-887 18" SW-MO-651 4" SW-MO-888 4" SW-MO-889 Class: ANSI B31.1 Function: SW-M0-37 and SW-MO-117 are the Service Water pump cross connections.
SW-MO-886, SW-MO-887, SW-MO-888, SW-MO-889 are the REC /SW system cross connect isolation valves.
SW-MO-650, SW-MO-651, are the REC heat exchanger outlet isolation valves.
Required .
Test: Full-stroke and stroke-time quarterly or each cold shutdown.
i Basis for .
Relief: Cooper Nuclear Station Technical Specification.4.12.C requires a monthly functional. test of system motor-operated valves to l demonstrate operability of the component and system. If this test is not completed satisfactorily,-the subsystem is declared inoperable and a limiting condition of operation is entered, requiring either equipment repair within a.specified time-or plant shutdown.
These valves are tested - in accordance with Surveillance Procedure 6.3.18.1. Assessing operational readiness has been performed-by CNS for over 10 years.
The SW system is continuously in service and each of the above valves is in the postion required to. support reactor shutdown.
The valves re in their normal position related to safety and are essentially passive. They are also easily accessible and i i should they fail to operate repair could be immediate.
Alternative Test: In lieu of testing these valves in accordance with Section XI,
, these valves will be -tested in accordance with Surveillance 4
Procedure 6.3.18.2. This testing meets or exceeds the 7
requirements of Section XI.
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Relief Request RV-33 Valves: 20" SW-CV-10 14" SW-CV-27 ,
20" SW-CV-11 14" SW-CV-28 '
20" SW-CV-12
-20" SW-CV-13 L
Class: ANSI B31.1 !
Function: SW-CV-10, SW-CV-11, SW-CV-12, SW-CV-13 are the-service water. :
pump outlet checks. 'f SW-CV-27, SW-CV-28 are check valves to the reactor building cooling water heat exchangers lA and IB. !
Required Test: Exercise each quarter or cold shutdown.
- Basis for .
Relief: Cooper Nuclear Station Technical Specification 4.12.C requires ;
a monthly system operability test to demonstrate both system ;
and component operability. If this test is not completed f'
satisfactorily, the subsystem is declared inoperable and a [
limiting condition of operation is ' entered, requiring either' !
i equipment repair or plant shutdown.
These valves perform a support function in shutdown or cooldown .
of the reactor. Assessing operational readiness - has been performed by CNS for over 10-years. Surveillance Procedure 6.3.18.3 is used to test these valves. Also, . the -
Service Water System is in continuous operation and the valves are exercised during daily operations.
Alternative Test: These valves will be exercised once every three months per- i Surveillance Procedure 6.3.18.3. Specified flow through each .
i pump and through the Reactor Equipment Cooling heat exchanges will verify operational readiness. This will meet or exceed :
4 the intent of Section XI.
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. Relief Request RV-34 Valves: 18" SW-MO-89A 18" SW-MO-89B Class: ANSI B31.1 Function: Loop A and B outlet flow control valve for the Service Water :
Booster pump cooling water to the RHR heat'exchangers.
Required Test: Full-stroke and stroke-time quarterly or each cold shutdown.
Basis for Relief: These valves are tested in accordance with Surveillance Procedure 6.3.20.1 and Technical Specification 4.5.B. This
, testing is performed quarterly. SW-MOV-89A and 89B are l throttling flow control type valves. For that reason
- measurement of the time the valve requires to travel. to the position required to fulfill its function is impractical. This valve position varies and is highly dependent upon valve trim i
condition, Service Water Booster Pump (SWBP) condition and flow instrumentation repeatability. Furthermore, these valves are interlocked with each SWBP on their respective loops to prevent starting the SWBP before the valve is a specified percentage of l full open. Control of the valve is then-transferred to the i maximum pump flow controller. This method of valve operation in not conductive towards repeatable stroke-time testing.
Alternative Test: These valves will be full-stroke exercised every three months in accordance with CNS Surveillance Procedure 6.3.20.1. This will meet or exceed the intent of Section XI testing requirements.
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Relief Request RV-35 Service Water Cooling System Valves SW Valves: 14" SW-CV-19 14" SW-CV-20 14" SW-CV-21 14" SW-CV-22 Class: ANSI B31.1
! Function: Service Water Booster Pump outlet checks for cooling water to the RHR heat exchangers.
Required Test: Exercise each quarter or cold shutdown.
Basis for Relief: These valves are tested in accordance with Surveillance Procedure 6.3.20.1 and Technical Specification 4.5.B. Flow through the check valve is used to indicate full-stroke exercising. This is in agreement with the NRC staff position that " verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adequate demonstration of the full-stroke requirement."
Alternative Test: Surveillance Procedure 6.3.20.1 will serve as the alternative i test to assess operational readiness of these valves.
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Relief Request RV-36 Valves: 20" PC-CV-13 20" PC-CV-14 Class: 2 -
Function: Torus Vacuum Relief Required '
Test: Exercise each quarter or cold shutdown.
Basis for Relief: Access to these valves is extremely difficult and hazardous. Despite the personnel hazard, they have been tested quarterly for over 10-years and have never experienced a failure. The valves do not experience excessive use or stress which could lead to valve degradation. For these reasons, the testing frequency will be changed to once each refueling cycle.
Alternative Test: Exercise once each refueling cycle instead of quarterly or cold shutdown.
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Relief Request RV-37 Valves: 12" SGT-249AV 10" SGT-252AV 12" SGT-250AV 10" SGT-255AV 10" SGT-251AV 10" SGT-256AV Class: ANSI B31.1 Function: 12" SGT-249AV and 250AV - Isolation for Fan / Filter Suction d
10" SGT-251AV and 253AV - Isolation for Fan / Filter Outlet 10" SGT-255AV and 256AV - Recirculation Bypass' for Fan / Filter Bank Required Test: Full-stroke and stroke-time quarterly or each cold shutdown.
Basis for Relief: Cooper Nuclear Station Technical Specification 4.7.B requires a monthly 10-hour system operability test to demonstrate both system and component operability. If this test is not completed satisfactorily, a limiting condition of operation is entered, requiring either equipment repair or plant shutdown.
The above valves are tested in accordance with Surveillance Procedure 6.3.19.1. This testing is conducted monthly during system operability testing. Air flow in all piping and duct work is observed to ensure full system functionality. Should one of these valves fail to allow specified flow, corrective action would be required.
Alternative Test: In lieu of Section XI testing, the SGT valves will be tested in accordance with Surveillance Procedure 6.3.19.1. This will meet or exceed the requirements of Section XI.
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Technical Justification TJV-01 Valves: 3" RHR-920-MV 3" RHR-921-MV Class: 2 Function: Provide redundant isolation of main steam to the Augmented Off Gas (A0G)~ system.
Basis for Technical Justification: The steam supply cannot be isolated during normal plant operation without causing significant A0G system transients.
Transients could include a fast or uncontrolled turn of hydrogen gas in the A0G piping buried under the plant. Also, routine quarterly testing of'_either of these two valves could cause a release of radioactive material several magnitudes above normal release activities.
Alternative Test: The test frequency will be during cold shutdown in accordance with IWV-3412(a).
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' Technical Justification TJV-02 Valves: 20" RHR-MO-17 20" RRR-MO-18 Class:
Function: Reactor vessel return to the RER pump suction and containment isolation during reactor operations. They '
are only opened for low pressure shutdown cooling.
Basis for Technical -
Justification: Valves RER-MO-17 and RHR-MO-18 are interlocked closed for pressure isolation during plant operation. Opening these valves during operations could possibly allow high pressure reactor coolant water into the low pressure suction lines of the RER system. Therefore, it is essential that these valves remain closed during plant operations.
Alternative Test: The test frequency will be during cold shutdowns in accordance with IWV-3412(a).
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Technical Justification TJV-03 Valves: 6" RHR-CV-23 6" RRR-MO-32 6" RHR-MO-33 -
Class: 2 Function: Pressure isolation for the RHR reactor vessel head '
spray line.
Basis for Technical -
Justification: Valves RER-MO-32 and RHR-MO-33 are pressure int'erlocked closed during reactor operations. It is essential these valves remain closed in order to help prevent an intersystem LOCA. Hince, these valves and RHR-CV-23 can only be exercised during cold shutdown.
Alternative Tese: These valves are exercised and stroke timed (as necessarf) during refueling outages in accordance with IWV-3522 and IWV-3412(a).
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Technical Justification TJV-04 Valves: 28" RR-M0-53A 28" RR-MO-53B Class: 1 Function: Reactor Recirculation Pump 1A and IB Discharge Isolation Required
. Test: Full-stroke and stroke-time quarterly.
Basis for Technical Justification: Closure of either of the RR pump discharge valves would reduce recirculation flow and result in reactor water temperature transients and reactivity transients. These transients would reduce control power distribution and fuel usage. This could lead to decreased fuel reliability and increase the possibility of a fuel element failure. In addition, failure of these valves during operation would require reactor shutdown due to inaccessibility.
Failure of either of the RR pump discharge valves in a nonconservative position during testing could result in the loss of a safety subsystem. The safety design basis of the RHR system requires'the RR pump discharge valves - to shut in a i specified time window so that LPCI injection flow is not short circuited through a postulated double ended RR pump suction line break.
Alternative Test: Valve full-stroke and stroke-time testing will be performed each cold shutdown 13 accordance with IWV-3412(a).
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Supplement to Amendment 2 Cooper Nuclear Station Operating Procedures Cited in Attachment 2 t
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