PY-CEI-NRR-0618, Submits Addl Relief Requests & Revs to 850821 & 860408 Relief Requests Re Pump & Valve Inservice Testing Program. ASME Section XI Program Upgraded to Comply W/Requirements of 1983 Edition W/Summer 1983 Addenda.Fee Paid

Submits Addl Relief Requests & Revs to 850821 & 860408 Relief Requests Re Pump & Valve Inservice Testing Program. ASME Section XI Program Upgraded to Comply W/Requirements of 1983 Edition W/Summer 1983 Addenda.Fee Paid

ML20209E384
Person / Time
Site:	Perry
Issue date:	04/15/1987
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
PY-CEI-NRR-0618, PY-CEI-NRR-618, NUDOCS 8704300039
Download: ML20209E384 (30)

Text

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i E THE CLEVELAND ELECTR P.O. BOX 5000 - CLEVELAND. OHIO 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLOG- - 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN SR VICE PRESCENT NUC M AR April 15,1987 PY-CEI/NRR-0618 L Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Pump & Valve Inservice Testing Program Gentlemen:

The Perry Nuclear Power Plant Unit 1 Inservice Testing (IST) Program for Pumps and Valves (document No. 80 A523 7 Rev. 1) was submitted by our letter dated August 21, 1985 (PY-CEI/NRR-0318 L). Initial surveillance testing identified the r.eed f or additional relief requests which were submitted by letter dated April 8, 1986 (PY-CEI/NRR-0445 L).

Subsequent testing and review has identified the need for new relief requests, and revision of several that were previously submitted. A listing of the new and revised relief requests is attacned.

In addition, we have upgraded our ASME Section XI program to comply with the requirements of the 1983 Edition with the Summer 1983 Addenda. The IST Program introduction (attached) further defines Code application, scope and references.

Pursuant to 10CFR 170.12, we have included an application fee of $150.00.

Please contact me i f you have any questions.

Very truly s

+ fO Murray R. Edelm6n

.,f&

Senior Vice President Nuclear Group MRE:nje 8704300039 870415 PDR ADOCK 05000440 d Attachment P PDR ,0k L j

cc: T. Colburn Ag K. Connaughton \

USNRC, Region III

Attachnent PY-CEI/NRR-0582L Changes and Additions to PNPP Ptunp and Valve IST Program Revision 3 Relief Request No. Ccenent (Changes and Additions)

PR-1 Changed- Identified vibration measurenent as alternate testing.

PR-2 Changed- Identified each pump.

PR-3 Changed- Added relief fran IWP-4520(b), Instr-unents to Measure Amplitude.

PR-4 Changed- Added relief fran IWP-3100, Inservice Test Procedure (suction pressure) and IWP-3300, Scope of Test (suction pressure stopped).

PR-6 Changed- Added ECCS pumps.

PR-13 New-PR-14 New-VR-10 Changed- Clarified basis for alternate testing.

VR-25 Changed- Clarified basis for alternate testing.

VR-26 Changed- Revised valve list.

VR-28 Changed- Clarified basis for alternate testing.

VR-30 Changed- Deleted lE22-F039 and 1E51-F090 fran relief request and clarified basis for alternate testing.

VR-31 Changed- Deleted lE21-F033 and lE21-F034 fran relief request.

VR-32 Changed- Added relief fran IW-3300, Valve Pos-ition Indicator Verification and revised testing to alternate refueling outage.

VR-37 Changed- Clarified basis for alternate testing.

VR-39 Changed- Ccrrected valve ntunber.

VR-40 Changed- Added valves 1G33-F039 and 1G33-F040.

I VR-41 Changed- Revised alternate testing per Technical Specification Amendment.

VR-42 Changed- Clarified basis for alternate testing.

VR-45 Changed- Clarified basis for alternate testing.

VR-46 Changed- Clarified basis for alternate testing, i VR-49 New-VR-50 New-VR-51 New-VR-52 New-l l

PNPP IST Program Revision 3

1.0 INTRODUCTION

The Perry Nuclear Power Plant ASME Inservice Testing Program for Pumps and Valves will be in effect through the first 120 month inspection period and will be updated in accordance with the requirements of 10 2R 50.55a(g).

This document outlines the inservice testing (IST) program based on the requirements of Section XI of the ASME Boiler & Pressure Vessel Code, 1983 Edition through the Summer 1983 Addenda. All references to IWP or IWV, respectively, of ASME Section XI, reflect the 1983 Edition through the Summer 1983 Addenda, unless otherwise noted.

The inservice inspection (ISI) classification boundaries are identical to the design classification or quality group boundaries shown on the plant piping and instrument diagrams (P& ids). Some pumps and valves within the ISI boundaries are identified as non-classed (NC). This IST program was developed using the ISI classification boundaries and the following documents:

Title 10, Code of Federal R<egulations, Part 50, Paragraph 50.55a(g).

NRC Regulatory Guides Division 1.

1 Sta dard Review Plan 3.9.6, " Inservice Testing of Pumps and Valves.:

Division 1 (draft) Regulatory Guide and Valve / Impact Statement,

( " Identification of Valves for Inclusion in Inservice Test Programs."

"NRC Staff Guidance for Preparing Pump and Valve Testing Programs and Associated Relief Request," November, 1981.

Final Safety Analysis Report, Perry Nuclear Power Plant.:

Technical Specifications, Perry Nuclear Power Plant.

The inservice tests identified in this program will verify the operation-al readiness of pumps and valves whose functions are required to mitigate the consequences of an accident or to bring the reactor to a cold shut-down condition or maintain the reactor in a safe shutdown condition.

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PNPP IST Program

. Revision 3 Pump Relief Request #

PR-1 System: As applicable Pumps: IC41-C001A 1E22-C003 1P42-C001B IR45-C002A 1C41-C001B 1E32-C001 1P45-C001A 1R45-C002B C41-C002A 1E32-C002B 1P45-C001B 1R45-C002C C41-C002B 1E32-C002F 1P45-C002 IE12-C002A 1E51-C001 P47-C001A 1E12-C002B 1E51-C003 P47-C001B IE12-C002C G41-C003A P49-C002A 1E12-C003 G41-C003B P49-C002B 1E21-C001 1M51-C001A 1R45-C001A 1E21-C002 1M51-C001B 1R45-C001B IE22-C001 1P42-C001A 1R45-C001C Class: ASME Class 2 and 3 Function: As applicable Test Requirement: IWP-4310, Bearings - temperature of all centrifugal pump bearings outside the main flow path and of the main shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperature of the bearing. Lubricant temperature, when

( measured after passing through the bearing, and prior to entering a cooler, shall be considered the bearing temperature.

Basis for Relief:

(a) Some of the pumps addressed in this relief request are cooled by their respective process fluid, " Main Flow Path." Thus, bearing temperature measurements would be highly dependent on I

the temperature of the cooling medium.

(b) Pump bearing temperature is taken at (1) one-year intervals, only, which provides very little data toward determining the incremental degradation of a bearing, nor does it provide any meaningful trend data.

(c) Except for: the Emergency Service Water Pumps IP45-C001A, B and C002; the Residual Heat Removal Pumps 1E12-C002A, IE12-C002B and 1E12-C002C; the Low Pressure Core Spray Pump IE21-C001; the High Pressure Core Spray Pump 1E22-C001; the ESW Screen Wash Pumps P49-C002A and P49-C002B which are submerged under water, all pumps addressed in this relief request will be subject to vibration measurements per subsection IWP-4500. Vibration measurements (displacement and velocity) are a significantly more reliable indication of pump bearing degradation than that of temperature measurements.

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PNPP IST Program

. Revision 3 Pump Relief Request #

PR-1 (Continued)

Alternate Testing:

Vibration measurements shall be taken on all pumps identified ,,

above as required by ASME Section XI Subsection IWP-4500, 4 except as noted in paragraph "c", above. Additionally, vibration measurements using velocity as a measured value shall be taken on each pump in the same locations as the required j displacement measured values.

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PNPP IST Program

. Revision 3 Pump Relief Request #

PR-2 System: As Applicable Pumps: IC41-C001A 1E22-C003 1P42-C001B 1R45-C002A 1C41-C001B 1E32-C001 1P45-C001A 1R45-C002B C41-C002A 1E32-C002B IP45-C001B 1R45-C002C C41-C002B 1E32-C002F IP45-C002 1E12-C002A 1E51-C001 P47-C001A 1E12-C002B 1E51-C003 P47-C001B IE12-C002C G41-C003A P49-C002A 1E12-C003 G41-C003B P49-C002B 1E21-C001 1M51-C001A 1R45-C001A 1E21-C002 1M51-C001B 1R45-C001B IE22-C001 1P42-C001A 1R45-C001C Class: ASME Class 2 and 3 i Function: As Applicable .

Test Requirement: IWP-3220, Time Allowed for Analysis of Tests - all test data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test.

, , Basis for Relief: Test acceptance criteria is contained within the test 4

( procedures, and the initial approval of equipment opera-bility is by on-shift personnel. The analysis of results for degradation requiring increased testing or engineering evaluation will then occur when the appropriate personnel are available for reviewing the inservice pump test data.

The appropriate personnel are not always readily available for this review effort.

Alternate Testing: Test data shall be reviewed within four (4) work days following the test, excluding weekends (Saturday & Sunday) and Holidays, within the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> time frame.

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PNPP IST Program

, Revision 3 Pump Relief Request #

PR-3 System: Standby I.iquid Control System Pumps: IC41-C001A and 1C41-C001B ,

Class: 2 Function: Provides a method of shutting down the reactor without use of the control rods.

Test Requirements: IWP-3300; Scope of Test - measurement and observation of inlet pressure (PI) and differential pressure (Pd) across the pumps.

IWP-4520(b); Instruments to Measure Amplitude - The frequency response range of the readout system shall be from one-half minimum speed to at least maximum pump shaft rotational speed.

Basis for Relief: The standby liquid control pumps are required to supply the necessary flow rate at a given system pressure. The inlet pressure (no installed test equipment) is equivalent to the static head provided by the test tank. Test tank level is established within the inservice test procedures.

( Also, the measurement of inlet pressure on a positive displacement pump is not a significant test parameter.

The system resistance is varied to establish the measured and observed discharge pressure as the reference value.

Flow rate is measured, observed and monitored to verify pump operability and degradation. y The SLC pumps are positive displacement with a shaft rotational speed of 360 revolutions per minute (RPM). The amplitude frequency response range is 180 RPM which corresponds to a frequency of 3 cycles per second (cps).

The International Research and Development (IRD) vibration instrument is calibrated to 5 cps even though it measures the entire frequency spectrum. The calibrated frequency l

range adequately covers pump induced inputs.

Alternate Testing: Utilize pump discharge pressure reading in lieu of pump differential pressure reading and verify test tank level to ensure adequate suction pressure. The IRD equipment shall only require calibration to as low as practical (approximately 5 cps).

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Pump Relief Request # >

PR-4 System: Waterleg Fill Pumps (RHR, LPCS, HPCS, and RCIC) t f

Pumps: lE12-C003, IE21-C002, IE22-C003, and IE51-C003 .,

Class: 2 <

Function: Waterleg pumps maintain the discharge piping of safety-related systems full to expedite flow during initiation, and to minimize the likelihood of system damage due to water hammer.

Test Requirements: IWP-3100; Inservice Test Procedure - measure, record, and compare inlet (suction) pressure Pi.

IWP-3300; Scope of Test - measurement and observation of inlet (suction) pressure Pi stopped.

p IWP-4600; Flow measurement (Accuracy), IWP-3230 (a) corrective action (alert range), and IWP-3230(b) corrective action (action range).

Basis for Relief: The securing of waterleg pumps (RHR, LPCS, HPCS and RCIC) to measure the suction pressure stopped would serve no

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useful purpose, since an adequate net positive suction head (NPSH) is verified by proper suppression pool or condensate storage tank level. These levels are maintained per Technical Specification requirements. r Also, securing these pumps will require filling and venting the safety-related system increasing the duration that the system is in a non-standby readiness mode.

The starting of the.waterleg pumps has shown no deviation in running or stopped pressure for RRR,,LPCS and HPCS.

The waterleg pumps have a capacity of 40 gym and a minimum flow design requirement of 10 gpm. Flow rate shall be measured with survey flowmeter (approximately iS%

accuracy). The pump can meet the design function with as much as 75% degradation. Therefore, relief from accuracy requirements and alert / action ranges adequately allows assessment of pump operability.

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Pump Relief Request #

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PR-4 (Continued)

Alternate Testing: The inlet suction pressure shall be measured using suppression pool level (RER and LPCS) and condensate storage tank pressure (HPCS). The suction pressure <

stopped shall not be measured or observed. Measurement of flow shall be performed with a survey flowmeter (approximately 15% accuracy) and corrective action ranges for flow shall be: 50% degradation alert range and 75%

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degradation action range.

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? PNPP IST Program

. Revision 3 s -

Nap Relief Request #

/ PR-6

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System: Emergency Core Cooling Systems (E12, E21, E22)  ! '

Emergency Service Eater System (P45) ,

s ESW Sdreen Wash (P49)

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Pumps: ',1 Elf-C0b2A, 1E12-C002B , JEI -C002C, 1E21-C001, 1E22-C001,

[IP45-C001A, IP45-C001B,1945-C002, P49-C002A, P49-C002B ,-

Class: 2 and 3 '

Function: Thd Emergency Service Water Pumps provide th;e cooling water to -

support the safety-related shutdown systems. ./ >

The,i$d Screen Wash Pumps provide clean water to'the spray nozzles for cleaning debris from the ESW traveling screens. The pumps also supply flushing water to the ESW screen tray. I

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'The Emergency Core Cooling Systems (RHR, LPCS HPCS) Pumps are used to supply water to the reactor vessel' during i plant abnormal conditions. ,

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s . - - t il Test Requirement:

y [IWP-4500; e on a bearingVibr,ation housing or its amplitude structural suppo,rt,- yocatica shal}' generally

>' provided it is pot separated free the puxp ty, any

( . resilient mounting. On a pump coupled to th6 driver, the measurement shall be taken oa the bedring }ousing near the coupling; on close-coupled pumps, the'reasurement point

/ shall be as clese as possible to the inboa d. bearing.

Basis for Relief: The Emergency Service Water Pumps, ESW Screen Wash Pumps, r!

and ECCS Pumps are totally submerged.under water, making

{ the required vibration testing impractical, however, the

. motor drivers are shaft crinnected to'the pumps and are

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accessible. .

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r Alternate Testing: The vibration measurements shs1 be taken, as scheduled on a quarterly basis, on the lower bearing or its structural ,,

., support, closest to the pump driver motor stuffing box

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PNPP IST Program Rtvision 3 Pump Relief Request #

PR-13 System: As Applicable Pumps: IC41-C001A 1E22-C003 IP42-C001B 1R45-C002A ,

1C41-C001B 1E32-C001 IP45-C001A 1R45-C002B C41-C002A 1E32-C932B IP45-C001B 1R45-C002C C41-C002B 1E32-C002F IP45-C002-1E12-C002A 1E51-C001 P47-C001A 1E12-C002B 1E51-C003 P47-C001B IE12-C002C G41-C003A P49-C002A 1E12-C003 G41-C003B P49-C002B 1E21-C001 IM51-C001A 1R45-C001A 1E21-C002 1M51-C001B 1R45-C001B 1E22-C001 1P42-C001A 1R45-C001C Class: ASME Class 2 and 3 Function: As Applicable  !

Test Requirements: IWP-4120; Range - the full-scale range of each instrument shall be three times the reference values or less.

Basis for Relief: The instrumentation (IRD) used to measure vibration

(~- amplitude has a range selector with multiples of .03, .1,

.3, 1, 3 and others for full-scale readings. When measuring reference values that fall between 0.031 to 0.033, 0.31 to 0.33, and 3.1 to 3.3, the full-scale range requirement can not be met. The minimal portion of scale usage,which does not comply, does not degrade monitoring of pump operational readiness. The scale indication is close enough to meeting three times or less to provide an accurate vibration reading.

Alternate Testing: The small range of reference values identified shall be measured on the appropriate scale.

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PNPP IST Program

- Ravision 3 Pump Relief Request #

PR-14 System: Control Complex Chilled Water Pumps: P47-C001A and P47-C001B Class: 3 Function: The Control Complex Chilled Water Pumps circulate cooling water to cooling Coils of the heating, ventilating and air conditioning (HVAC) systems which service the Control Room and other areas of the Control Complex.

Test Requirements: IWP-4600 Flow Measurement (accuracy), Table IWP-4110-1 12% acceptable instrument accuracy.

Basis for Relief: Flow rate will be measured and observed with a plant installed instrument which has an accuracy of i4%. A low chilled water flow alarm is provided to warn operators of insufficient system flow. The low chilled water flow alarm setpoint is at 964 GPM.

-Alternate Testing: Measurement of flow with plant installed instrument (approximately i4%) and corrective action ranges for flow

, shall be the same required by Table IWP-3100-2 allowable ranges of test quantities.

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PNPP IST Program Revision 3 Valve Relief Request #

VR-10 System: Nuclear Boiler (B21)

Valves: IB21-F022A, 1B21-F022B, 1B21-F022C, 1B21-F022D, ,

1B21-F028A, 1B21-F028B, 1B21-F028C, 1B21-F028D Category: A Class: 1 4

Function: Main Steam Isolation Valves Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power operated valves - full stroke time IWV-3415; Fail Safe - at least once every three months Basis for Relief: Full stroke exercising results in loss of steam flow from one main steam line to the turbine. Recent industry information indicates that closing these valves with high steam flow in the line may be a large contributing factor

(~ in observed seat degradation. The valves are designed for partial stroke exercising with full steam flow during plant operation by bleeding down the accumulator air supply to the operator. The partial stroke test will verify operability of the valve operator's fail safe function.

Alternate Testing: Partial exercise and fail safe test monthly, full exercise and stroke time test during cold shutdown.

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PNPP IST Program Rsvision 3 Valve Relief Request #

VR-25

' System: High Pressure Core Spray System (E22)

Valves: 1E22-F016 i

Category: C Class: 2 Function: High Pressure Core Spray Pump Suppression Pool Suction Line Check Valve Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: The HPCS suppression pool suction line check valve shall be partially exercised quarterly during suppression pool cleanup operation. The suppression pool is the alternate supply of water for the HPCS system and is not used during the HPCS pump operability testing. The design of the HPCS system precludes ease of valve exercising.

Alternate Testing: This valve shall be disassembled and manually exercised each refueling outage.

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PNPP IST Program Revision 3 4

Valve Relief Request #

VR-26 System: Safety-Related Instrument Air System Valves: IP57-F555A, IP57-F555B, IP57-F556A, 1P57-F556B c Category: C Class: 3 Function: Provide a flowpath for charging air to the ADS safety relief valve accumulators from the air compressors.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: These simple check valves are within the normal flowpath for supply air to the automatic depressurization system (ADS) accumulators. They are normally open during plant operation and require reverse flow exercising. This requires depressurization of portions of the safety-related instrument air system. A reverse flow exercise during refueling outages will ensure operability of the system to perform its design function.

k Alternate Testing: Exercise valve during refueling.

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PNPP IST Program

. Revision 3 Valve Relief Request #

VR-28 System: Primary Containment Isolation Check Valves Valves: IB21-F032A, 1B21-F032B, IC11-F122, IG41-F522, IN27-F559A, IN27-F559B, IP22-F577, IP43-F721, IP50-F539, IP52-F550, 1P54-F1098, "

1P57-F524A, IP57-F524B Category: AC Class: 1, 2 Function: System check valves for systems penetrating primary containment.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: These check valves are the inboard primary containment isolation valves for systems considered inservice during plant operation. The normally open check valves requirei an exercise in the reverse flow direction which can be verified by leak testing. Primary containment leak testing each refueling (i.e., 10 CFR 50, Appendix J) constitutes proper valve exercising.

C Alternate Testing: Exercise valves during refueling (at least once every two years).

PNPP IST Program

, Revision 3 Valve Relief Request #

VR-30 System: Safety Systems with Thermal Expansion Check Valves Valves: 1E12-F550, 1E12-F552A, IE12-F552B, 1G43-F508A, 1G43-F508B Category: C Class: 1, 2 Function: To relief pressure from thermal expansion between two normally closed valves Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly and IWV-3522(b) exercising proce-

., dure - normally closed valves.

Basis for Relief: These valves are installed as a small bypass path around a normally closed valve. During plant and system operations these check valves remain shut. Design of systems using thermal expansion check valves preclude testing in the normal manner and a thermal expansion check valve is not required to fully open to perform the design function.

[ Alternate Testing: Verification that these check valves relieve thermal expansion pressure transients shall be performed during refueling outages (at least once every two years).

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PNPP IST Program Revision 3 Valve Relief Request #

VR-31 System: War.er Leg Fill Pumps Valves: 1E12-F084A, IE12-F084B, 1E12-F084C, IE12-F085A, IE12-F085B, a IE12-F085C, IE22-F006, 1E22-F007, 1E51-F061, 1E51-F062 Category: C Class: 2 Function: The water leg discharge check and stop check valves perform a pressure isolation function during system operation.

Test Requirement: IWV-3522(a); Exercising Procedure - normally open valves.

Basis for Relief: Design of the water leg fill system inhibits individual verification of valve closure during normal operation.

Alternate Testing: These valves shall be exer.ised shut quarterly during the appropriate system functional test. The water leg discharge check valves shall be verified closed by venting the upstream side of the valves.

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PNPP IST Program Revision 3

. Valve Relief Request #

VR-32 System: Nuclear Boiler (B21)

Valves: IB21-F410A, 1B21-F410B, 1B21-F411A, 1B21-F411B, 1B21-F412A, i 1B21-F412B, 1B21-F413A, 1B21-F413B, 1B21-F414A, 1B21-F414B, 1B21-F415A, 1B21-F415B, 1B21-F416A, 1B21-F416B, 1B21-F417A, 1B21-F417B, 1B21-F420A, 1B21-F420B, 1B21-F421A, 1B21-F421B, 1B21-F422A, 1B21-F422B, 1B21-F423A, 1B21-F423B, 1B21-F424A, 1B21-F424B, 1B21-F425A, 1B21-F425B, 1B21-F440A, 1B21-F440B, 1B21-F441A, 1B21-F441B, 1B21-F442A, 1B21-F442B, 1B21-F443A, 1B21-F443B, 1B21-F444A, 1B21-F444B Category: B Class: 3 Function: Supply air to air operators of the nuclear boiler ADS and Safety / Relief valves.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months.

IWV-3413; Power operated valves - Full stroke time f'

IWV-3415; Fall Safe - at least once every 3 months.

IWV-3300; Valve Position Indicator Verification - at least once every two years.

Basis for Relief: These solenoid operated valves are proven operable during testing of the Nuclear Boiler ADS and Safety / Relief valves. Also, in a recent study (BWR Owners Group Evaluation NUREG-0737, Item II.K.3.16) the number of ADS and safety relief valve openings should be reduced as much as possible to minimize LOCA risk. The design of PNPP provides divisional separation of the solenoid valves for each Safety Relief Valve (SRV) such that SRV exercise would only exercise one of the two solenoid valves. Based on this study, and the potential for causing a LOCA condition, exercising these valves is delayed to refueling.

Alternate Testing: Exercising, stroke time, fail safe and position indication testing shall be accomplished on an alternating refueling outage basis as identified in PNPP Technical Specifications.

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PNPP IST Program Ravision 3 Valve Relief Request #

VR-37 System: Reactor Water Cleanup (G33)

Valves: 1G33-F052A, 1G33-F052B s Category: C Class: 2 Function: Normal return flow path for Reactor Water Cleanup (RWCU) water to the reactor vessel via feedwater.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: The reactor water cleanup system is inservice during p'. ant operation, maintaining the above check valves open.

. Testing requires the RWCU system to be in an inoperative -

status.

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Alternate Testing: Reverse flow exercising shall be performed during _

refueling as plant conditions allow.

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PNPP IST Program

. Rzvision 3 Valve Relief Request #

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VR-39 System: Standby Liquid Control Transfer System (C41) i Valves: 1C41-F520 (

Category: AC Class: 2 Function: To provide inboard containment isolation.

Test Requirements: IWV-3251; Test Frequency - Exercise at least once every three (3) months, quarterly.

Basis for Relief: This check valve provides containment isolation and allows a flow path from the SBLC transfer tank to the SBLC tank.

The SBLC tank is maintained in a constant state of readi-ness during plant operations. Testing the check valve requires draining borated solution from the SBLC tank while providing demineralized makeup water, thus reducing the system readiness condition.

Alternate Testing: Transferring water during refueling shall provide forward

( flow exercising when plant operational mode allows the SBLC system to be inoperable.

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PNPP IST Progrt.m

, R vision 3 Valve Relief Request #

VR-40 System: Reactor Water Cleanup System (G33) f Valves: 1G33-F001, 1G33-F004, 1G33-F039, 1G33-F040, 1G33-F053, 1G33-F054 1 1

Category: A Class: 1 Function: To provide containment isolation of the Reactor Water Cleanup System.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valves - Full stroke time.

Basis for Relief: The Reactor Water Cleanup System is inservice during normal plant operation and provides a backup in post

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accident analysis. This system ensures that reactor coolant pH, chlorides, and activity are maintained within specified limits. These limits are to prevent the likelihood of exceeding 10CFR100 guidelines or allowing i stress corrosion cracking of the stainless steel systems.

A closure of any valve during surveillance testing would cause a loss of the n,' ant 's ability to control chemistry.

Alternato Testing: The operational readiness of these valves shall be verified during cold shutdown. ~

PNPP IST Progrtm Revision 3 Valve Relief Request #

VR-41 System: Control Rod Drive Hydraulic System (C11)

Valves: IC11-115 (typical of 177) ,

r Category: C Class: 2 Function: Control Rod Drive Accumulator Supply Check Valve.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every (

three months .

Basis for Relief: This valve operates as an integral part of the hydraulic control unit to rapidly insert control rods. To allow proper testing (reverse flow exercise) of the accumulator supply check valve requires securing of the control rod drive pumps. The control rod drive pumps provide;

1) cooling water to hydraulic control units, 2) reactor vessel level control and 3) reactor coolant recirculation pump seal and purge water.

Alternate Testing: The reverse flow exercising of the check valve shall be

{ satisfied by performance of the accumulator pressure decrease test during each refueling.

PNPP IST Program Revision 3 Valve Relief Request #

VR-42 System: Residual Heat Removal System (F?'

Valves: 1E12-F054A, IE12-F054B Category: C Class: 2 Function: Residual Heat Removal Heat Exchangers Reactor Core Isolation Cooling Check Valves for Steam Condensing Fode.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months Basis for Relief: These valves are used during steam condensing mode resid-ual heat removal operation. The steam condensing mode is rarely used and requires loss of residual heat removal syt tem safety injection and shutdown cooling modes of operation.

Alternate Testing: These valves shall be forward flow exercised each refueling outage by removing and manually exercising.

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PNPP IST Progrcm Revision 3 Valve Relief Request #

VR-45 System: Fuel Pool Cooling and Cleanup (G41)

Valves: G41-F597A and G41-F597B c Category: C Class: 3 Function: The check valves prevent backflow from the Fuel Pool Cooling and Cleanup Surge Tanks (G41-A002A and G41-A002B) to the Fuel Transfer Tube Drain Tank (G41-A003).

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis of Relief: These check valves remain closed during reactor operation with the Fuel Transfer Tube Drain Tank secured. The functional operability of each check valve (i.e., forward flow exercising) shall be required during refueling outages for the purpose of pumping the Fuel Transfer Tube Drain Tank to the Surge Tanks. In addition, the Fuel Transfer Tube Drain Tank is isolated by a blank flange g (10CFR50, Appendix J, Type C Test) making the system

\ inoperable during reactor operation.

Alternate Testing: Exercising valves during refueling and/or prior to declaring valves operable.

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PNPP IST Program Revision 3 Valve Relief Request #

ft VR-46 System: Reactor Coolant Pressure Isolation Testable Check Valves (RHR, LPCS, RCIC and HPCS).

Valves: 1E12-F041A, IE12-F041B, IE12-F041C, IE21-F006, 1E22-F005, 1E51-F066 Category: AC Class: 1 Function: Provide pressure isolation of the reactor coolant pressure boundary between the high pressure reactor coolant system and other safe-ty-related systems containing low pressure designed components.

Test Requirements: IWV-3300 Valve Position Indicator Verification. Valves with remote position indicators shall be observed at least once every two (2) years to verify that valve operation is accurately indicated, l

Basis of Relief: These check valves have no external means of visually verifying actual valve position.

Alternate Testing: Verify actual valve open position by magnetic means and closed position during seat leakage tests. Valve open

position shall be verified by magnetic means and compared

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to indicator lights at least every two years.

PNPP IST Program Ravision 3 Valve Relief Request #

VR-49 Systems: Containment Atmosphere Monitoring System Valves: 1D23-F010A, ID23-F010B, ID23-F020A, 1D23-F020B, 1D23-F030A, c 1D23-F030B, ID23-F040A, ID23-F040B, ID23-F050 Category: A Class: 2 Function: Provide instrumentation isolation in case of an instrument line failure to maintain containment integrity.

Test Requirements: IWV-3411; Test Frequency - exercise at least once every three months and IWV-3413; Power Operated Valves - full stroke time IWV-3415; Fail Safe - at least once every three months Basis for Relief: The Containment Atmosphere Monitoring System provides highly reliable instrumentation for detecting abnormal conditions in the containment, drywell and the suppression pool, and for monitoring of these areas after postulated accidents. Their normal and ace,ident position is open.

Failure of these valves in a closed position during exercising could place the plant in a Limiting Condition for Operation. This would reduce the availability of indications to correct or analyze any abnormal condition.

Alternate Testing: Exercise, stroke time and fail safe testing during cold shutdown.

. PNPP IST Program Revision 3 Valve Relief Request #

(, VR-50 Systems: Combustible Gas Control System Valves: 1M51-F531A, IM51-F531B, 1M51-F532A, 1M51-F532B, IM51-F618A, ,

IM51-F618B Category: C Class: 2 Function: These sample line check valves allow automatic draining of condensate in sample lines and isolation to perform a localized sample.

Test Requirements: IWV-3521; Test Frequency - exercise at least once every three months.

Basis for Relief: These simple check valves are located inside the drywell and primary containment. To reverse flow exercise these check valves would require making the sample lines inoperable for installation of test equipment and requires entry into the drywell.

Alternate Testing: The reverse flow exercise shall be performed during each refueling.

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PNPP IST Program Revision 3 Valve Relief Request #

k, VR-51 Systems: Division 3 HPCS Standby Diesel Generator Starting Air (1E22)

Valves

1E22-F543A, IE22-F543B i

Category: B Class: 3 Function: Starting Air Valves supply starting air for the HPCS Diesel Generator.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and

! IWV-3413; Power Operated Valves - full stroke time t

IWV-3415; Fail Safe - At least once every three months 4

j Basis for Relief: Valve design does not provide valve position indication.

Failure of a valve to perform the required function will result in an increase in the starting time of the diesel

generator or failure to secure starting air, i

I Alternate Testing: Valves shall be verified operable during monthly diesel generator technical specification surveillance testing.

The starting time shall be monitored to determine valve operability.

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.PNPP IST Program o -

Revision 3 Valve Relief Request #

( VR-52 Systems: Control Rod Drive Hydraulic System Scram Discharge Volume Valves: 1C11-F010, IC11-F011, IC11-F180, 1C11-F181 Category: A Class: 2 Function: These vc1ves provide pressure isolation of the reactor coolant pressure boundary (RCPB) during a reactor scram condition.

Test Requirements: IWV-3424, Seat Leakage measurement a) measuring leakage through a downstream tell tale connection or b) by measuring the feed rate required to maintain pressure.

IWV-3426, Analysis of Leakage Rates. Leakage rate measurements shall be compared with previous measurements and with the permissible leakage rates specified by the owner for a specific valve.

IWV-3427, Corrective Action. Action for exceeding specified leakage rates.

Basis for Relief: These valves have been identified as Category "A" valves, k to address the concerns of IEN 85-72 involving failures of SDV Vent and Drain valves. The design of the Perry Nuclear Power Plant Unit i ensures: 1) integrity of the primary containment by venting to the drywell and draining to the suppression pool and 2) minimizing the potential of inadvertent isolation of the scram discharge volume.

These design considerations prohibit measuring seat leakage in accordance with Subsection IWV.

Alternate Testing: Identify seat leakage by external measurement (e.g., Sonic Flow Detector) at least once every two (2) years to commence during the first refueling outage.

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