ML20211B619
| ML20211B619 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/01/1986 |
| From: | Donohew J Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-86-14, TAC-11270, TAC-M51115, TAC-M51265, TAC-M52944, TAC-M55726, TAC-M55885, NUDOCS 8610170300 | |
| Download: ML20211B619 (51) | |
Text
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/f uoq*'o, UNITED STATES E 'y (j NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 3 -l \ ' .. E October 1, 1986
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- Docket No. 50-219 LICENSEE: GPU Nuclear Corporation Jersey Central Power'and Light Company FACILITY: Oyster Creek Nuclear Generating Station
SUBJECT:
JUNE AND JULY 1986 PROGRESS REVIEW MEETING ON LICENSING AC WITH'GPU NUCLEAR PLANT SITE PERSONNEL On Wednesday, August 27, and Thursday, August 28, 1986, meetings were held at Oyster Creek Station site with GPU Nuclear (the licensee) to discuss (1) the status of station licensino actions, (2) the draft Oyster Creek Integrated Living Schedule (ILS) and (3) the licensee's inservice testing program for
' the current 10 year cycle. Attachment 1 is the list of the individuals attending the meetings. The following is a summary of the significant items discussed and the actions taken or proposed. References may be made to Cycle 11 Refueling (Cycle 11R) outage .hich began in April 1986 and is scheduled to end in October 1986.
Attachment 2 is a marked up copy of the staff's Licensing Actions Report Extended (LARE) dated August 22, 1986, for Oyster Creek. The markup, to update the LARE, resulted from the discussion on each item or TAC number in this meeting. The status of each item is given in the column " STAT" on the The status in that column is the following:
r+ght-hand side of the LARE sheets."01" means licensee, "02" means staff's revie Manager, "04" means action completed and "05" means staff's Project Manager has the licensing action in concurrence.
Attachment 3 is handouts from the licensee on its presentation on the ILS for Oyster Creek. Attachment 4 is a copy of the report by the staff's contractor on.+.he licensee's pump and valve inservice testing program for the current 10-year cycle.
1.0 High Radiation Sianal to Isolate Drywell Purge / Vent Isolation Valves By late September 1986, the licensee will submit a letter showing the high radiation signal is not needed to isolate the 2-inch isolation valves. This will follow the staff's generic safety evaluation (SE) sent to the BWROG on the subject. The licensee stated that Oyster Creek meets the requirements in this SE for not having the signal to the 2-inch valves.
2.0 Safety Information Management Svstem (SIMS)
The licensee provided updates to the MPA implementation dates in its letter of June 27, 1986. The updates by TAC number are the following:
6610170300 861001 9 DR ADOCK 050 I
= .*
MPA Revised Implementation Date TAC M55885 D-19 10/85 C M55726 A-18 12/86 L M52944 B-78 7/86 C F-09 12/87 L M51265 A-17 12/88*L M51115
- Cycle 12R Outage 3.0 Cycle 11R Reload Aeolication The NRC approval of . fuel 299ZA and 2991 to be used in the Cycle 11R reload is in NRC letter dated March 26, 1986.
4.0 TSCR 126-Revise Containment Intearated Leak Rate Test (ILRT)
The licensee requested a meeting before Sep wmber 15, 1986, to discuss with the staff its application for TSCR 126 dated July 25, 1986. The meeting was held on September 10, 1986, and will be the subject of a separate meeting summary.-
5.0 Control Room Habitability The staff issued its SE on July 15, 1986, accepting the licensee's methodology to calculate chlorine gas and radiation exposure to the control room operators following an event. For chlorine gas,For theradiation, source is one of the 1-ton tanks in the onsite chlorine facility.
l l
the source of radioactivity is the desien basis loss-of-coolant accident.
The licensee stated that its tests of the minimum air inflow into the control room showed a minimum of 950 cfm which is greater than the airflow assumed in the licensee's analyses. As reported in the meeting sunrnary dated August 1,1986, the licensee plans to replace the 1-ton tanks of chlorine gas in the chlorine facility by sodium hypochlorite by April
-1987. There will then only be a much smaller tank.of chlorine gas stored Because near the intake structure for the new radwaste service water.
this will be farther away frc= the control room ventilation intake tSan the chlorine facility, this should then remove chlorine gas as a considera-
. tion for control room habitability. The licensee will submit a letter on this in September 1986 before the restart from the Cycle 11R' outage.
6.0 Generic Letter (GL) 86-14 Dated August 20, 1986 l
The licensee was given a copy of GL 86-14 which requested it to provide by October 1, 1986, its projected number of candidates and anticipated dates for operator licensing examinations for FY 1987 through FY 1990.
This GL also requested the'requalification examination dates by j
October 1, 1986.
7.0 TAC 08100, Radiological Effluent Technical Specifications (RETS1 The licensee's letter dated Augus't 13, 1986, on its software / hardware problems with its proposed RETS was discussed. The licensee proposed its RETS in its letter dated October 22, 1984. These problems were the subject of the separate meeting on July 31 and August 1, 1985, and reported in the meeting summary dated August 22, 1985.
The licensee agreed that the action statements for inoperable equipment in its proposed RETS will allow the licensee to operate Oyster Creek within the RETS. The NRC project manager stated that the RETS are i expected to be issued in late September or early October 1986. The RETS will be. effective on or after the restart from the Cycle 11R outage as requested in the licensee's letter dated August 13, 1986. This is for the reasons given in this letter.
i 8.0 Intecrated Livino Schedule (ILS) for Ovster Creek Attachment 3 is the handout from the licensee for its presentation un the ILS. The ILS is the subject of the staff's GL 85-07 and GL 83-20 in which the licensees were invited to submit an ILS for its plant. The licensee has had previous meetings with the staff on-this subject. The meeting summaries are dated January 23 and March 5,~1986.
The draft ILS 'was the logical outgrowth of the licensee's long range l
planning for Oyster Creek. This planning goes out 5 years through the Cycle I?.R outage expected to start in 1990.
The licensee explained that the long range planning process has been used at the site since June 1985. This was discussed with the long range planning representative at the site.
The draft license condition and ILS Plan that the licensee is considering to submit to the staff is the last 8 pages of Attachment 3.
The licensee stated that it planned to submit its ILS to NRC before October 31, 1986.
The staff suggested, by phone on September 17, 1986, the addition of a definition for the work projects in the liceTiee's plan and statement that the licensee's long range plan is a list of'these projects. The staff also suggested wording to clarify that, all things being equal, Category B-and C projects would be revised before Category A projects.
9.0 TAC 11270, Inservice Testino (IST) ,
This is important to resolve because it is a old TAC number and represents the staff's review of the licensee's reauest for relief from the ASME Code Attachment 4 is the Technical Evaluation for testing)
Report (TER pumps and valves.on the licensee's submittal dated October 1981 held earlier on September 23 and 24,1980. The TER is the contractor's
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review of the licensee's proposed tests of safety-related Class 1, 2 and 3 i pumps and valves against the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, through the summer of 1975 Addenda.
.These tests form the IST program for the second 10-year cycle of Oyster Creek since the plant was licensed in 1969. ;
The'following comments were made by the licensee on the~ attached TER:
(a) TER, page 19, Section 3.1: The licensee stated that it_does not need this relief because it can exercise these valves during power operation without valve failure in the closed position causing increased scram insertion times.
(b) TER, page 5, Section 1.3: The TER stated that the licensee agreed to modify its procedures on cold shutdown. The licensee stated that this has been done except for one procedure which is for the core spray testable check valves.
(c) TER, page 20, Section'4.1: The licensee stated that valve V-16-61
. should be included in Section 4.1 for completeness.
(d) TER, pages 9 and 10, Sections 3.1.1.3 and 3.1.2.3: The licensee stated that sea water is not used. The water comes from the fire protection pond. This is an outdoor pond with no control on the quality of the water collected in the pond.
(e) TER, page 9, Sectfon 3.1.1.2: The licensee stated that valves V20-60 and V20-61 are not~ exercised during refueling outages because the system configuation does not allow testing of these valves without .
injecting fire pond water into the core spray system and the RCS vessel. These valves allow water from the fire pond into the core spray system if this is needed.
(f) TER, page 10, Section 3.1.2.2: The licensee stated that valves V20-88 and V20-89 are not exercised during refueling outages for the same reason given in item (e) above.
(g) TER, page 4, Section 1.1: The licensee stated that valves V-31-5 and V-31-2 should not be in this table because these valves are Category A-1 valves not category A-3 valves. Also, the licensee stated that the remaining valves in the table are Appendix J tested or have pressure monitoring.
10.0 Updated NRR Licensing Action Report Extended (LARE) Dated 08/22/86
- --. Attachment 2 has the updated LARE for Oyster Creek. The updating was done during the discussion on each licensing action in this meeting. The licensing actions are listed by TAC number (left hand column of LARE).
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The LARE -is a print out from the BWD1 personal computer licensing action management tracking system. The LARE contains references to future licensing actions to be submitted by the licensee. These future actions have TAC number OCXXX.
11.0 Next Meetino The August / September 1986 Progress Review Meeting is expected to be held at NRR headquarters on October 8, 1986.
Original eirned br:
Jack N. Donohew, Jr.,-Project Manager '
BWR Project Directorate No. 1 Division of BWR Licensing .
Attachments:
- 1. List of Attendees
- 2. Staff's Updated LARE dated 6/14/86
- 3. Licensee's Handout on its ILS
- 4. ~TER on the Licensee's IST cc w/ attachments: .
R. Bernero/R. Houston G. Lainas/B.D. Liaw D. Vassallo/C. Grimes W. Hodges L.G. Hulman
.M. Srinivasan
/
- BRDeF:0BL- : : : :
0FG :BWD#1: DBL :BWyf t) DBL __________
_____:. _______ :.. 3 g.______:____________:-___________:-___________:-___________:
NAME :CJamerson :JD dDbw :JZwolinski :
_____:__________ :.. p._ ____:____________: ____ _____:....._______:.___________:.. : :
- 10/\ /86 : :
DATE :10/01/86' :10/61/86 OFFICIAL RECORD COPY
Das %
.' - The LARE is a' print out from the BWD1 personal computer licensing action management tracking system. The LARE contains references to future-licensing actions to be submitted by the licensee. These future actions have TAC number OCXXX.
~
11.0 Next Meeting The August / September-1986 Progress Review Meeting is expected to be held
-at NRR headquarters on October 8, 1986.
Original signet by:
Jack N. Donohew, Jr., Project Manager BWR Project Directorate No. 1 Division of BWR Licensing Attachments:
- 1. List of Attendees #'
- 2. Staff's Updated LARE dated 6/14/86
- 3. Licensee's Handout on its ILS
R. Bernero/R. Houston G. Lainas/B.D. Liaw D. Vassallo/C. Grimes W. Hodges L.G. Hulman M. Srinivasan
(./
, OFC :BWD#1: DBL :BWy# QDBL :BWD#V: DBL : : : :
_____:_______.. : __.gg. ______:____________:____________:____________: ___________:___________
NAME :CJamerson :JD( dD bw :JZwolinski : : : :
DATE :10/ 01/86 :..\
- 10/0p_1/86 :10/\ /86 : : : :
OFFICIAL RECORD COPY
Oyster Creek Nuclear Generating Station cc: Resident Inspector Mr. Ernest L. Blake, Jr.
Shaw, Pittman, Potts and Trowbridge c/o U.S. NRC 2300 N Street, NW Post Office Box 445 Forked River, New Jersey. 08731 Washington, D.C. 20037 J.B. Liberman, Esquire Commissioner Bishop, Liberman, Cook , et al . New Jersey Department of Energy 1155 Avenue of the Americas 101 Commerce Street New York, New York 10036 Newark, New Jersey 07107 Mr. David M. Scott, Acting Chief Pegional Administrator, Pegion I Bureau of Nuclear Engineering U.S. Nuclear Regulatory Commission Department of Environmental Protection 631 Park Avenue CN 411 King of Prussia, Pennsylvania 19406 Trenton, New Jersey 08625 BWR Licensing Manager GPU Nuclear 100 Interpace Parkway Parsippany, New Jersey 07054 Deputy Attorney General State of New Jersey Department of Law and Public Safety 36 West State Street - CN 112 Trenton, New Jersey 08625 Mayor Lacey Township 818 West Lacey Road Forked River, New Jersey 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.
P. O. Box 388 l-l Forked River, New Jersey 08731 Mr. P. B. Fiedler Vice President & Director Oyster Creek Nuclear Generating Station Post Office Box 388
' Forked River, New' Jersey 08731 I
1 October 1, 1986 Distribution for Meetina Summary Dated:
Facility: Oyster Creek Nuclear Generatina Station
- Docket File (50-219)
NRC PDR Local POR BWD1 Reading ,
R. Bernero/R. Houston J. Zwolinski J. Donohew C. Jamerson OGC-BETH (Info Only)
E. Jordan.
B. Grimes ACRS (10)
D. Vassallo C. Grimes G. Lainas/B. D. Liaw G. Hulman M. Srinivasan W. Hodges OC File .
- Copies sent to. persons on facility service list J
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Attachment 1
- 7-JUNE / JULY 1986 PROGRESS REVIEW MEETING' Auaust 27-28, 1986 Oyster Creek Site Name Affiliation NRC/NRR/ DBL J. Donohew GPUN*
M. Laggart GPUN J. Kowalski
- GPU Nuclear Corporation MEETING ON OYSTER CREEK INTEGRATED LIVING SCHEDULE AUGUST 28, 1986 OYSTER CREEK SITE Name Affiliation NRC/NRR/ DBL J. Donohew GPUN*
M. Laggart GPUN J. Kowalski GPUN J. Charlos GPUN E. O'Donnell GPUN P. Czaya GPUN A. Collado GPUN J. Maloney
- GPUN = GPU Nuclear Corporation
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8-MEETING ON OYSTER CREEK INSERVICE TESTING PROGRAM AUGUST 28, 1986 OYSTER CREEK SITE Affiliation Name NRC/NRR/ DBL J. Donohew GPUN*
J. Kowalski GPUN P. Crosby GPUN L. Leitman
- GPUN = GPU Nuclear Corporation
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AMD T33 NOT NEE:ED.
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- 44
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E Page 40. !
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IPSAR SECT!:N 4.10. SEE LER 86 ;0 (6/13/S6).
/
Yi. 5' 4981: IFS 4 $! T:04 4.!e - PP'%Rf C:0LAni inil 08/!!/8610/ 0/66T 101:0/E4T 01 4 4 6 GPUN TO SUD!T REVISH TS;R A:':VITY WWI:H Mc!T BE SHCLLIES.
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P
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8 RESPCNSE EVAL ACTICH A CATE DATE DATE T 56 CC 62077 iUPPLDENT ! CF THE OfiTD DEEK IMD1 // 10/30/E6T 10/30it4T 03 3 9 9 UPDATE IPSAR AS PREPARATION FCR FTOL CC#vDSICM A4D IPSAR DATED JANt4H 1983 DECIDING undi EIERPTIONS FRGt THE RESULATICMS ARE nEEEED TD CLCSE CUT SEP.
53 CC 6149 IPSaR 4.16.1 - FDCT;A BUILD!h5 RCS IMD1 // 10/33/84T
- 10/30/84T 03 6 9 9 IP5AR 4.16.1 - LICENSEE EIPta!NED VALUE OF A!RBPME LDr46E CETECTICN P40!ATICN SET! T:04 T2 !!TE:T RCS LEAKABE.
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- 0/31/sai. - - 03 6 5 5 artt in fa REScLvE !w o C: unE 1798 sE:T:a 4.:7m ar. m RCMTHLY REET!Mi CF ; . I\ th{h CII!CR!N3 IS%2T!?N AT THE Site.
DC 5:9441ALEM ATuS - !!EPS 3.1.1 L 3.1.2 RES! 09130/86T 10/31/86T 01 7 6 7 SEE TAC 53781. LICDSEE REQUESTED DATES BY PHC4! ,
M CALL. M La RE61 *>4Mo 09/30/86T 10/31/86T 01 7 5 8 STAFF RESTB, BY POE, DATES
/Il CC !!Tl! DLEP ATVS !TEPS 3.2.! l 3.2.2 T3 CORPLETE CERTAIN SALU i ATys !TERS. LICDSEE SAID /
CATES WILL IE PROVIDED If 4/:0186.
0 OC 54-)11 SAD A?WS - liEP 4.5.1 AE6108/09/85 04/30/I6T 10/31t!6T 02 6 5 8 CN 2-5-96 HAvDKA"P TCLD 841 SE W%'LD lE !!$UE2 4-30-16.
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! CC 577:3 EtTDS!:n 73 RTS CN 4/10/86. LETTER 5/5/it j 1;CFA50.44tti .4It!!Hai - TRI ITD
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inFS 06/16/96 04/30/86T 10/31/96T 02 2 2 7 SEE TAC 57758. ADD *L BtPS RA!
[:5 GC !!C18 SL 84-09 Elt'PTIC4 R:ST TO (1/21/86) CN 1/14/86 RESPCMSE
$0.44tCH31 RECC38 ITER R'AE TO RA!. RAI GIVD TO LICDSEE AT 4/10/86 #EITIN6. 40 REAL ,
SE CATE.
5 6 a'i OF 4/l!96, WELD 4I04/16 CC 493'! IP!AR !! TIC 4 4.11 - SE! SPIC CES!6n P81A 06/24/f6 !!/01/86T 12/31/E6T DISCUSSED02 308 Art TD !DT 1/9/96. GPL4 ElRITTED RESPCNSE. MEPO 73 SRI'ES FOR SE CCRPLETICR DATE.
l Pye to. 7 0!! 2,86 LICE 45146 A* TIM REPGRT EITDOE3 PROGRESS STATUS REPCRT BWR PRCJECT DIRECTORATE 11 DIVISICN OF isR LICDSING .
REV CURNDI CURRDT CURRENT S LIC BuC1 SS C3 Nuts Pi' CA TA: LICDS!h6 4CT!3 3 I St. RAI SAFETT LICDS!N6 i PRI PRI PRI RESPCNSE EVAL ACT!0N A DATE DATE DATE i
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/;4 OC560(4 CISCRI8ANCY It DRAe!MES USE3 !N SEP P914 12/01/f6T 12/31/B6T 01 3 1 2 6 PUN SDT 2MD SET OFhR. W INEL FIRST TD t/30/85.
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Be;$ 09/30/E611/30/86712/31/96T 01 1 3 2 LICENSEE TO SUBNIT REV! SED
- C 5H!! RD!!E L:n-LCW RCS mATB LEVEL 1 TSCR BY 04/30/f6 A40 THIS INSTRLPENT CPERABILITr FCR it!SEL PUSIIt DDLLID.
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CLCSED QUT). !!.E.4.2.7 IS TAC 61119.
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11/22I86: 5153 !TDS I GC CC01: CC!FICATICN TO nS!V BYPASS L!hE B0109/10/9611/10/86T 12/31/B6f 01 4 9 9 6 PUN TO EIPLAIN ILANKING CFF THE PS!V BYPASS LINES TO
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EPP SDI WITH LETIER.
F43fECI. FLAN 6 8 PES!CM ! TAST INTHFACE 4 OC !!422 SEP ACTION ITDS - IPSA# SUPPLEPENT BuDI // 12/11/d6T 01/31/877 03 5 A64EEPE4T (T!A) FCR T!A IMSPECTIC4 0F RES3LVE1 SE8 ITERS. P1 TO ASr EE613 TO 00 THE DSPECT!3hi.
OC CC009 P4 tic CRisELL TDFEPATURE ISCR tePS 09/30/9612/31/86T 01/31/B7f 01 9 5 7 SE REQUESTED ISCP BEFCRE
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EVALUATICu CATED 05/30/96 REC 32 RETuilCN.
I
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Pa;t H. 9 Cl'*;. !n LICDS:NB ACTICN REPCRT QTD E3 PROSPESS STATUS REPCR1 BWR PROJECT DIRECTCRATE 01 O!VISICN OF ItR LICE 45!N6 .
COMMENTS LICDSING ACTIC4 REV CURRDT CURRDT CU8'DT 5 LIC 85D1 55 TEC CR TA: SAFETY L!tE451NG T PRI PRI PRI IR. RAI 8 f RE3PCNSE EVAL.
A;TICN A DATE DTE T CATE 3 C; 61169 IsR STEADY STATE PHv510$ RELCA3 ItRS // I!/31/96T 01/31/87T 02 I 9 9PC:6ES. 4CRK REEEST F FM SENT TO REFCRT - TRS:t f
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~
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4 C; ;C01' *!:# ma'D 8 6Rl!Y A4 FES. l#PS 09/30/86 01/11/37T 02/2Sil7TFEVIEu 01 7CF9TABLE 9 LA CATED 11/21/85 REEESTD
- 1. F;CTCT!
ieI*E . 56 4. CF EEi. Gal:E 1.h TO PROPCSE mat. ?!*E OUT-GF-l?EC 14 A YEAR.
00; C C4 T! P - FIFE P5;TE;T!:N FPC6 RAM fuP510/I4/86 01/31/977 02!:f/37T 01 5 9 9 6PtX TO SUIMIT PLANT FIRE PROTECT!CM SY$tD CC4t!6CRATICN AND 50KVE!LLA4CE REE READTS FCR PLANT Ti AC TO FESPCMD TC K 86-10, 4 G; A43:4 tr' VEG-07:7 $J'8tE"E47 la IF'810/31/95 02/28/377 03/30/877THAT 0: 9TER 7 RAY I P.P!C)Crant i$/:9/86) SAID BE COMPLETED 14 E< :!<T OFERAT1%S PRD; CURE 5 Jp!.
(Wir PAE! 10/23/85 0;/;0/877 04/ 0/87T 02 I 8 5 l'PCRTANT SALD ATWS 170.
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$E DATE PER C.905315/15/86 REPQ TO 88D1, 6 8 ITF'?: 'ElR'tc ?Ents, $4g,M 3/31/37T 04/30/877 01 9 43 CC CC006 CCNTA1 Phi PUR$ini MING OPERATIGN P801 1ATICN 5;64AL TO M5-
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4 e 6
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- a;e 42. 9 C9'* lia LI:D51NG ACTICN PEP:RI EITEhtG PROGREl$ STATUS REFERT BNR PROJECT DIRECi3 ATE 81 O!VIII3 CF Id* LICD$tNG .
CCMENTS REV CURFDT CURRENT CURRENT 5 LIC In01 55
RESPCNSE EVAL ACTICN A DATI CATE T CATE M ,LA3OS N ** M 47 OC 00010 LCNi *US C RRECT!vt A".itCN F;R BuPS 09/!0/$6 04/M/87T 05/31/8775! QUESTED 01 ~ 7 BY 77 LONG-fDM C3RECTIVE ACTICN +
f LETTER DATED M e lELaa!NAT!:N OF :: Ail 46 FR3 E5a 81'145 (
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9 9 FOURTH CF FOUR RELOAD Edi 12/31/86 C5/31/177 06/30/87T 01 6 REFCRTS. TWO (TAC 633!9 &
I C* CC0:0 let 8EL3AD RE*3T NO. 4 611691 NAVE BED SUBMITTD.
Edl / / 03/3!/877 09/M/877 03 7 8 9UPDARD UPDATED FES 1530 0 4/10/96.
IPSAR (TAC 62077) lM
[3 CC 11:ai FAL TERM 08 DATING LI:D5E FREPARATI3. NED T3 WRITE SE AND 60 TO ACR$.
165 03/31/87 C6/;t/877 09/30/87T 02 6 4 2 6 PUN SUIMITTAL 310/4/85.
3 CC 5912 10;F55).62 CE ATai RULE REVID3 1806 6ESERIC IE (9/M/961 FCA 6P3 70 APPLY TD OYSTER '
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REV.1 LATE (9 REGAATCRY Shl:E I.97 ADISICN CONF. CRDER. CCPIES PAVE IID SDT TO C 4TRACTDA (E5n6 10AdQ, A. UQ11.
4/se/rk hDi insiste 12/31/97T 12/31/87T 01 3 6 7 !!E 02/12/86 PT8 Sit
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QVSTER 3!D 9 9 It AC RESICN SCHUULE OF
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ALL TWE LAR$ LICE 45ING STATUS SELECTG lA1:
. . - . - - - . . + . *.__
E ATTACHMENT 3 DRAFT (July 10,1986) a GPUN LONG RANGE PLANNING PROCESS 4
SD 1
0
- ~
1 l
TABLE OF COVIENTS PAGE 1
1.0 INTRODUCTION
1 2.0 SCOPE 2
3.0 ORGANIZATION 3
4.0 PLANNING PROCESS 3
4.1 ISSUE IDENTIFICATION 6 INITIAL SCREENING 3
4.1.1 RELATIONSHIP TO CORPORATE MISSION 4
4.1.2 ISSUE IDENTIFICATION 5
4.1.3 REGULATORY CATEGORIZATION OF ISSUES 6
4.1.4 INITIAL SCREENING 6
4.2 PROJECT DEFINIIION 6 PRIORITIZATION 7
4.2.1 PROJECT DEFINITION 7
4.2.2 PRIORITIZATION 8
4.3 PLAN DEVELOPMENT 6 IMPLEMENTATION 8 ,
4.3.1 PRELIMINARY CYCLE ASSIGNMENT 11 4.3.2 OPERATING /OlTTAGE PLAN DEVELOPMENT 12 4.3.3 CONTINGENCY PLANNING 13 4.3.4 RELKfIONSHIP TO BUDGET DEVELOPMENT 13 4.3.5 IMPLEMENTATION 14 4.3.6 UPDATING AND REVISION OF THE LONG RANGE PLAN 15 5.0 SUbHARY i
GPUN LONG' RANGE PIANNING PROCESS f
1.0 INTRODUCTION
In late 1984 GPUN established a long range planning function to fulfill the following objectives:
o Provide a means of defining and controlling work scope for each plant over a period of time of up to five (5) years encompassing at least the next two (2) planned operating / outage cycles.
o Provide visibility and coordination of Corporate planning activities necessary to accomplish the defined work scope.
o Provide a vehicle for establishment of a living schedule agreement with the NRC.
The primary product of this activity is the development of a Long Rang (LRP) for each plant which is maintained current and updated on a sem basis. The program used to develop the LRP is described in the following However, it is important to emphasize that this process is sections.
dynamic in nature and is expected to undergo further changes as pla tools and procedures are refined to meet developing Corporate needs, 2.0 SCOPE The long range planning process is ultimately intended to encompass a significant plant-related activities, other than routine functional work tasks, that are separately funded, authorized and managed and which are expected to be impicmented within the five year planning horizon o Range Plan.
This definition of scope includes all significant Oyster Creek m
.- ,-, , - - ..c- ,, - , - ~ . _ ,- . - _ . _ , . --.-----,,-.,_,,,,-_.-,_,,-n-
4 In general, this will exclude and W.I-l capital and specific 04M projects.
minor capital and specific 06M funding requests (under $50,000) unless the
[ project could have a critical impact on major planned activities (e.g.,
inspections with potential for adverse contingencies) or is mandated by NRC.
Individual funding requests for items such as minor tools, blarket -
purchases, furniture, etc. are also excluded from the process.
PresentJy, the Long Range Plans for both 0.C. and TMI-1 include only It is intended to expand tne present coverage of in-plant modifications.
future Plan updates to encompass the full scope of plant related capital and specific 06M projects, including non-hardware programs.
4 3.0 ORGANIZATION i
In view of the broad scope of the long range planning activities, a matrix l A Planning j
organization has been developed to implement the program.
~
Department has been established within the Tech Functions Division to l A full time, coordinate and manage the long range planning activities.
dedicated Manager of Long Range Planning with appropriate staff is assigned i
for each plant reporting to a Director of Planning who reports to the Vice As shown in Figure 1, the President / Director of Technical Functions.
Manager of Long Range Planning coordinates the activities of a Long Range Planning Group for each plant which includes representatives from the Plant, j
Tech Functions, MC6F, Radiological 6 Environmental Controls and Nu: lear f Assurance Divisions.
Participation by the Long Range Planning Group l
representatives from the various divisions is full or part-time, depending on the level of activity required.
l The LRP Group is responsible for development of the LRP which is a Corporate l Each- ,
document and must receive approval by the Office of the President.
divisional representative is responsible for providing divisional planning l
input and ensuring adequate review by division management of the bas l
and resulting content of the LRP.
l i
j l
~ ^ ~~ ^~
4.0 PLANNING PROCESS _
The long range planning process consists of three (3) major phases.
- 1. Issue identification and initial screening.
- 2. Project definition and prtoritization.
- 3. Plan development and implementation.
The activities involved in each of these phases are shown schematically on Figures ~2-4andaredescribedinthefollowingsections.
' 4.1 Issue Identification anf Initial Screening I
In order to maximize the effectiveness of the Long Range Plan, it is i
important that all issues which will require significant levels of Corporate resources be identified as early as possible so that the total work scope-can be assessed and planned against available resources and other constraints. Although the plan includes contingency allowances for a certain level of anticipated but presently unidentified events, any significant incompleteness of the plan or untimely identification of high priority issues could result in disruption of planned activities and To avoid this and in order inappropriate allocation of Corporate resources.
l
! to insure maximum completeness of the plan, a systematic approach to issue identification is necessary.
f 4'.1.1 Relationship to Corporate Missior.
t Generally, issues requiring significant resources and planning will be related directly to accomplishment of the GPUN mission and one or more i
As shown in Figure 2, these goals and the Corporate goals or objectives.
objectives are copcerned with the following four areas.
l
' 1. Safety Maintaining and improving plant safety in order to minimize risk to the public or plant personnel.
iI1 i
I T
- 2. Plant Performance Maintaining or improving plant performance to maximize generation consistent with safety requirements.
- 3. Resource Utilization Nhking most effective use of Corporate resources by improving productivity and cost control consistent with safety requirements.
- 4. Regulatory Compliance Ensuring compliance with all applicable regulatory requirements.
f 4.1.2 Issue Identification 4
i Responsibility for seeking out and identifying major issues which could affect (positively or negatively) fulfillment of these Corporate goals and i Nhny objectives is the responsibility of all levels of GPUN management.
issues emerge on a day-to-day basis from' plant operations, surveillances, inspections, engineering studies and regulatory analysis whose importance is self-evident. These are readily reflected in the planning activities as Other issues can only be identified they are identified and evaluated.
through detailed and systematic analysis.
i In addition to the normal means of identifying and reacting to important issues on a routine basis, GPUN has established, or is in the process of l
developing, a number of programs aimed at proactively identifying other significant issues which are candidates for improvements in one or more of These include probabilistic the areas of Corporate Goals or Objectives.
risk assessment (PRA) studies and AIARA and personnel safety programs, a plant availability improvement program, and various efforts aimed at GPUN involvement in industry-wide improving productivity and cost control.
activities such as INP0 and Owners Group programs will also provide a systematic means of issue identification. Systems are also in place for tracking and ensuring compliance with existing regulatory requirements and commitments and for assessing the potential impact of emerging regulatory issues. All of these programs are expected to result in candidate projects which will feed into the long range planning process.
i
. ,. . - - - - - , - ~ . _ - - - . . . - - , . - - - - - - - - - - - - - - - - , - , - - . - - ,
l I
i The LRP Group interacts on a day-to-day basis with the various groups within GPUN which are responsible for managing or implementing the various activities and programs to identify, as early as possible, issues that need Each LRP Group to be factored into the development of the Long Range Plan.
division representative is responsible for routinely providing divisional inpat to the Long Range Plan and for identifying potential work to be sponsored by the division.
Once identified, potential signi Ncant work tasks are listed on a major technical concerns / issues list which is maintained current and is a major source document for potential projects for inclusion in the LRP.
4.1.3 Regulatory Categori:ation of Issues From its Licensing Action Item (LAI) list, Licensing will identify all regulatory requirements or commitments along with *. heir mandated comple dates, if any. All identified issues or potential work tasks will be categorized as follows for purposes of defining the level of NRC notification / approval of proposed planning schedules required in accordance with the proposed Integrated Living Schedule (ILS) agreement:
Category A - All issues which have resolution dates mandated by NRC,
' rules, orders or. license conditions.
Category B - Issues identified by the NRC and/or GPUN for which commitments have been made by GPUN. The issue resolutions would result in either a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements.
i i
1 Category C - All other major issues, identified by GPUN or other regulatory agencies.
Extension in planned completion dates will require prior NRC approval for Planning Category A issues and prior notification for Category B issues.
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l information for Category C issues is provided to NRC for infomation only in order to place the regulatory issues in the context of the overall scope of
, the LRP.
The NRC interface is described more completely in the ILS Plan.
4.1.4 Initial Screening As indicated on Figure 2, following identification of potential issues or work tasks, an initial screening and technical evaluation is performed by the division potentially responsible for implementing or performing the work task.
F.xisting Corporate work request procedures and mechanisms (e.g., TFWR's) are used to describe the issue involved and to propose potential means of f
resolution. The division potentially responsible for undertaking the work request performs an initial evaluation to determine whether the proposed
' work task is 1) technically feasible and either 2) is likely to. yield net >
benefits to the public (safety) or to the Corporation and its customers, ol is necessary to meet a regulatory requirement. Proposed work requests not l
meeting these threshold criteria will be returned to the originator with an - >
explanation of the reasons for rejection. The proposed approach may then be modified to address the reasons for rejection or will be eliminated as a potential work task.
i 4.2 Project Definition and Prioritization For work tasks which are accerted after initial screening, an initial determination is made to determine whether separate funding is required to accomplish the work task.
If the magnitude of the effort involved is below l
I the threshold requirements of the LRP or can be accomplished within existing functional 06M budgets, the responsible division will. assign and schedule j Other the work and complete a work release document implementing the work.
-issues requiring significant funding as capital or specific 05M projects will be included in the Long Range Plan and will undergo project definition and prioritization as shown on Figure 3.
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4.2.1 Project Definition Development of a draft Request for Project Approval (RPA) is required to initiate inclusion in the long range planning process. The draft RPA should define the project scope, cost and schedule for planning purposes. It ,
should also include a discussion of reasons for undertaking the project, possible alternatives and an initial cost-benefit analysis if the project is judged to have any economic benefits. The information required includes planning estimates of schedule durations, including material /
contract lead times, and manpower and budgetary resources required for the engineering, procurement and installation phases of the project as ~
appropriate. For projects which are required to be implemented during an outage, the draft RPA will also identify what portion of the installation work, if any, may be accomplished prior to the outage. The Plant Division will review and concur in any determination on the type and extent of work which can be accomplished during operation. This initial determination should again be reviewed and confinned or modified at the Preliminary Engineering Design Review stage of the project. While the degree of detail in the draft RPA may be less than that required for LOSA approval, it should contain sufficient information for development of a preliminary project resource loading profile which is necessary for project prioritization and subsequent planning.
4.2.2 Prioritization
~
Following completion and sign-off of the draf t RPA by the responsible l
division, it is forwarded to the LRP Group for an initial review for l
completeness. The completed draft RPA is then scored and prioritized in accordance with the Corporate Prioritization Procedure (1000-ADM-7150.01).
This procedure involves an assessment of the impact of the project in the l-following four areas:
i
- 1. Public Safety
- 2. Personnel Safety
- 3. Capacity Factor or Plant Availability
- 4. Direct Economic Incentive Each project is scored against each attribute which are assigned appropriate relative weights. A total project score is developed by summing the individual weighted attribute scores.
1 All proposed projects, including Category A and B NRC-required and Category C non-NRC projects, are scored on the same basis.
Following initial scoring, a proposed ranking of all projects to be
- considered in the Long Range Plan is developed for review by a khnagement Review Committee consisting of all involved Division Directors or their designees. The WPC will approve the prioritization ranking of all projects for use in development of the Long Range Plan.
4.3 ' Plan Development and Implementation The process involved in development and implementation of the LRP is shown on Figure 4. Since the Long Range Plan will cover a period of up to five.
(5) years, it will typically encompass at least two (2) operating / refueling
~
outage cycles. The initial target durations a.] scheduling of these cycles will be derived from plant life cycle plans developed by the LRP~ Group based on fuel management plans and generation forecasts and any overall schedular constraints.
i 4.3.1 Preliminary Cycle Assignment Based on the prioriti:ation ranking of projects and consideration of their resource loading profiles, the Long Range Planning Group will develop
, preliminary cycle assignments for each project based on consideration of first order constraints which include:
- 1. Target total onsite manpower limits and planned outage durations.
- 2. Life cycle plan budgetary target forecast levels for the period of
.the Plan.
- 3. Required project lead times and other schedular prerequisites or requirements, including mandated (Category A) regulatory completion dates.
These constraints are intended to set reasonable guidelines for the total amount of work and resources that can be effectively and safely planned, managed and executed during the time period of the plan. As such, they are not absolute limits but targets for initial planning which are subject to adjustment as detailed planning proceeds.
Within these constraints, the scheduling of individual projects will be based on the project priority and its resource loading profile. In order to develop a manageable and efficient Plan, it is necessary to levelize available resources to complete the projects in an optimal sequence considering their relative importance and the given constraints. Figures 5 and 6 illustrate the process used to achieve this result. Typically, as shown in Figure 5, the resource loading profiles for the various projects will vary in duration (required lead time) and magnitude of resources required. In general, it will be a planning objective to have engineering released at least six months prior to start of construction to permit adequate time for detailed installation planning. Depending on the complexity of the project, this may require an overall schedule of several years. This required lead time is reflected in the project resource loading profile.
Figure 6 illustrates how the scheduling and levelizing of resources would be accomplished for the hypothetical projects shown on Figure 5. For each year of the Plan period, a target limit or constraint on resource availability ,
(dollars and manpower) is established. Although Figure 6 portrays this as a constant level, in actuality, the manpower or budget constraint will, of 9_
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course, vary depending on whether it is an outage or non-outage year. It is important that the resource constraints established provide contingency for presently unidentified issues which will develop and require high priority attention. As illustrated in Figure 6, this contingency is increased with time into the future, since the uncertainty is clearly greater for the future cycles than for the present or next cycle. Failure to allow for adequate contingency could be extremely disruptive if lower priority work is initiated prematurely simply because the resources appear to be available.
Interruption of that work to divert resources to unforeseen but higher priority activities would result in overall schedule delays, inefficiency and waste of total resources.
Having established the available resource levels, resources will be allocated to projects in accordance with their assessed priority ranking.
High~est priority projects would generally be initiated for earliest completion in accordance with their resource loading profile and schedule.
The total resource constraint in the.first year will determine how many projects of what priority can be initiated at that time. The resource loading profiles of these projects will then determine what level of resources will become available for other projects in the later years.
These available resources are then allocated to the remaining projects in accordance with their priority listing within the established contingency levels.
Any conflicts with mandated schedule completion dates for Category A regulatory projects must be resolved by modifying the proposed plan to confom to the existing regulatory constraint or by proposing changes in the l Category A completion dates if justified, based on project priorities. Any proposedchangestoCategorvAitemswhichinvgiveextendingcompletion dates require NRC approval. Therefore, no changes in existing project schedules for Category A items will actually be made until such approval is
! secured.
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This process is used to establish the preliminf[y cycle assignment for each project being considered in the Long Range Plan. Planning activities will then focus on further refining the total scope of work for the next scheduled operating and refueling cycle.
4.3.2 Operating / Outage Plan Development Development of plans for each operating and outage cycle will consider additional second order constraints including: #
- 1. Relationship of activities to major plant conditions (e.g.,
refueling).
- 2. Target outage duration.
- 3. Onsite manpower limitations (total and per shif t).
- 4. Area manpower limitations (e.g., containment or control room).
- 5. ALARA considerations.
Within these constraints the planning of operating or outage cycle work will proceed with the objective of minimizing outage duration and levelizing resource requirements. For the projects designated for these cycles, task sequence logic is developed to identify critical path activities. This may reveal that the proposed preliminary scope of work, as defined initially for the outage or operating cycle, is incompatible with the constraints applied. This will require modifying the scope of work or the constraint initially selected. Certain tasks that were originally envisioned to be performed entirely during a given outage may have to be accomplished partially during an operating cycle or over two outages. - Changes to -
regulatory constraints for Categories A or B items must be made in accordance with the ILS agreement.
As a result of the more detailed planning for the next outage and operating cycle, changes to the subsequent cycles may be necessary. Following these
adjustments to initial preliminary cycle assignments, the overall Long Range Plan is developed and submitted for review and approval to the Office of the President. Following approval, the Long Range Plan is issued P.s the operating / outage cycle scope control document for the plant. At the same time, a revised listing of all Category A, B and C projects is provided to NRC for review and/or approval. Following NRC concurrence, changes to Category A schedule constraints and project schedules are made where required.
4.3.3 Contingency Planning In addition to identifying and planning known work tasks, the long range planning process will seek to assess che likelihood and consequences of unplanned but reasonably expected events and to develop contingency plans to minimi::e the adv}erse impact of such developments. In particular, scoping of work associated'with planned major inspections, tests or surveillances will include scheduling and resource allowances for anticipated repairs. Where the potential exists for major impact on plant availability or extensive downtime to effect corrective action, alternative outage plans may be developed to accommodate the impact of the extended outage on planned activities. In , order to take advantage of potential lengthy forced outages during an operating lycle, work scopes will be defined for outages of opportunity whi'ch wi'11 permit completion of or progress on outage-required tasks which will 'redQce future planned outage workload.
The LRP will clearly define the extent of contingency planning for each operating er outage cycle plan. Activities such as development of engineering packages, installation planning, materials procurement or contractor selection, which are necessary to ensure readiness to perform a contingency task, will be considered part of the base scope for the cycle and must be reflected in the sched. ing and budgeting for the projects involved. Evaluation criteria, estimates, plans and schedules must be available to support timely decisions on implementing contingency tasks.
4.3.4 Relationship to Budget Development The approved Long Range Plan will identify when projects require initiation to support schedule completion dates for the various operating and outage cycles. For projects that require initiation within the current budget, the draft RFA must be finalized and submitted for LOSA approval in accordance with established Corporate procedures. Projects not requiring work at present are considered approved for planning and for budget input to be used for future year budget development based on their proposed schedules.
The Corporate objective will be to utilize the LRP as a basis for the annual budget review and development process. Since the LRP will be maintained current with issuance of semiannual updates, it should provide the best oasis for development of overall Corporate and divisional capital and specific 06M_ budgets for 0.C. and TMI-1. As the budgeting process proceeds each year, from initial submittal to final approval, any incompatibility between the LRP and the approved budget should be resolved, such that the work planned in future budget years to support current or future operating or outage cycles is achievable within the budgetary constraints, including allowance for contingency. Any significant inconsistency must be resolved by modifying-the scope of work included in the LRP or by obtaining approval to modify the budgetary constraint. It must be emphasized that any future LRP activities beyond the current approved budget year are subject to and contingent upon approval of the GPUN annual budget by the GPUN Board of Directors. Individual projects over $2.5 million also require specific Board approval.
4.3.5 Implementation As noted, projects identified in the Long Range Plan as requiring initiation will.be assigned a project sponsor and will proceed through LOSA approval in accordance with established Corporate and divisional procedures. A project schedule will be developed which may include, where appropriate, schedule
. 13 -
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milestone dates for contractor selection, engineering, material procurement and delivery dates, construction planning and production, as shown on Figure 7. Progress against these milestone dates will be tracked by the
. responsible division.
The Long Range Planning Group will be responsible for controlling the scope for each operating and outage cycle and for reporting on changes in scope and status of completion of planned activities and readiness for planned outages. The Division Directors and the Office of the President will periodically review progress against the current plan and readiness for upcoming outages. The control of scope for the outage will be transferred from Long Range Planning to the Plant Division 3 - 6 months prior to the outage start date. This should correspond to the point in time when engineering and materials procurement have progressed to a point that there is a high degree of. confidence that the plan can be implemented without significant modification.
After turnover of scope control, the Plant and MC6F Divisions through their representatives on the Long Range Planning Group will be responsible for providing feedback on the status of implementation against the plan. Major variances from work scope accomplished or in basic planning assimiptions shall be considered in the. development of plans for future cycles as.they affect planned work scopes or durations. .
4.3.6 Updating and Revision of the Long Range Plan Long range planning.is a continuous, ongoing process. As new issues and projects are identified, they are individually scored and prioritized and, depending on their importance relative to other planned or ongoing activities, adjustments to the total plan will be made to accommodate new projects and changes to existing project scopes or schedules. On a semiannual basis, the overall plan will be revised to reflect changes which have occurred in the six month period since the last revision. Each semiannual revision will be reviewed and approved by the Office of the President to insure that planning activities reflect management direction.
In conjunction with each semiannual update of the Long Range Plan, the Integrated Living Schedules provided to the NRC will be updated and NRC
~
approval will be sought where necessary.
It is recognized that on occasion certain high priority developments may' occur which require immediate major modification of planned work scopes or priorities. In such cases, based on Office of the President approval, such projects may be added to or deleted from the Plan prior to going through the evaluation and planning process described above. However, the process will be upplied following project initiation to document and confirm project priorities and the next revision of the LRP will reflect the required modifications to work scope and schedule necessary to accommodate such new developments.
5.0 SUWARY The GPUN long rang ~e planning process has evolved substantially since 1984
~
and it will continue to develop as experience is gained in its application.
The'Long Range Plans for Oyster Creek 10M and 11R outages and for the TMI-1 SM and 6R outages were prepared as individual stand alone outage plans whose scopes and durations were controlled primarily by existing mandated regulatory requirements. Thus, it was not practical or meaningful to apply the complete process as described herein to those planning cycles. The ,
process will be used in planning for Oyster Creek beyond 11R and for TMI-1 beyond 6R, recognizing that a transitional period is necessary to synchronize the scope and timing of long range planning activities with related budget development and project authorization and implementation processes. During this transitional period, discussions will also be underway with NRC regarding the development -of an ILS agreement. The ability to fully apply the intended process will therefore be constrained in the near term by these factors. However, the major elements of the planning process will be applied to the extent practical during the interim period.
i In any event, the long range. planning process is intended to be dynamic and is expected to undergo additional modification to accommodate changing Corporate needs. This do.ument will be revised periodically to reflect those required process changes.
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! DIVISION AND FAC. DIV. REP. DIVISION ENVIRON. DIV. REP.
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LICENSE AMENDMEVT 2.C.8 Long Range Planning Program The " Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" submitted on is approved.
- a. The Plan shall be followed by the licensee from and after the effective date of this amendment.
- b. Chgan es to dates for completion of items identified in(Categories '
B.and'Clof the plan do not require a~ license amendment.- Dates specif'ied in Category A shall be changed only in accordance with applicable NRC procedures.
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, N :s 3436f
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e PLAN FOR THE LONG RANGE PIANNING PROGRAM - OYSTER CREEK NUCLEAR GENERATING STATION I. ' Introduction GPU Nuclear Corporation (GPUN) has developed a comprehensive program which will enable GPUN to effectively. manage implementation of significantchangestotheOysterCreekNuclearGeneratingStation(@
which have been identified by GPUN or other agencies. The program is identified as the "GPUN Long Range Planning Process". This program was developed to assess, coordinate and schedule major work tasks or projects at 0.C., including those mandated or proposed by the NRC, or identified by GPUN and others. The satisfy regulatory requirements; (2)provide program objectives sufficient leadare to (1) times for modifications; (3) minimize changes for operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed projects and' associated schedules. This will be accomplished within the overall objective of plant safety and availability.
This program reflects the recognition by GPUN and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary. The program integrates a significant portion of presently planned work at 0.C. over a nominal five-year period to
. ensure that tasks associated with issue resolution are properly assessed and effectively scheduled and coordinated. It provides a means for new requirements to be accommodated taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program. It describes how the program functions, mechanisms for changing the program and updating it, the interactions and responsibilities d the NRC and licensee staffs under the program, and its resultant assessments and. schedules.
II. SUSNARY OF PROGRAM DEVELOPMENT %,
The program is based on a list of projects and their completion dates each of which is assigned a priority resulting from an' established assessment method. The assessment method involves ranking each project based on its importance relative to public safety, personnel safety, plant availability / capacity factor and economic incentive.
3436f
-The scheduling of projects takes into account projections for budgets and site manpower and engineering support requirements for up to five years, on an item-by-item basis covering all significant plant
' modification activities. The list represents that significant portion of the O.C. work list and commitment list which is regularly modified and updated.to meet changing conditions, including new NRC regulatory requirements. The final product of this program is the assessment of projects and the development of associated schedules as discussed below.
III. ASSESSMENT AND SCHEDULING i A first step in the' development of this program involves the
- identification of significant open issues and their associated resolutions. Following initial screening and evaluation of all identified issues,'.those whose proposed resolution will require 4 significant planning or resources are defined as~ proposed projects to t
be considered ~in development of the Long Range Plan. An assessment of roposed projects is required to determine their appropriate all value worth and relative priority. Upon completion of the project p/
prioritization and subsequent ranking, the tasks are scheduled based on i their assigned priority and available resources. The projects are organi:ed into Categories A, B and C based upon their origin.
Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. The three categories are briefly-described below:
Category A - All regulatory issues which have resolutions and/or issue resolution dates mandated by NRC rules, orders or license conditions.
Category B . Issues identified by the NRC and/or GPUN for which commitments have been made by GPUN. The issue resolutions l~
would result in significant a) plant modifications, j b) precedure revisions, or c) changes in facility staffing
- 4 requirements.
l Category C - All other major issues, identified by GPUN or other
- regulatory agencies.
( Projects and/or implementation dates in Category A may be modified or
/ deleted only with prior approval of the NRC, in accordance with existing NRC regulations. Changes to project scope and/or completion dates in Categories B and C require notification to the NRC as <
described in Section V. Categories A, B and C, takcn together, provide f
a basis for assessing the overall effects of changes to projects and/or schedules, and a departure point for discussion between the NRC and the ,
licensee regarding such changes, as discussed below.
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3436f
IV. ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS An important aspect of GPUN's planning effort is the recognition that l projects and scheduled completion dates will need to be modified or deleted at times to reflect changes in regulatory requirements, to accommodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investigations into issues, and to take into account delays resulting from events beyond GPUN's controll .
V. GPUN AND NRC RESPONSIBILITIES The proper functioning of the Long Range Plan requires that GPUN apply consistent criteria to the assessment of projects, monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act promptly to take'necessary actions when a project scope or schedule change is needed. As set forth herein the NRC will treat all Long Range Plan projects consistently and recognize that, when necessary, ranking, project scope, and/or scheduled completion date changes are based on a comparison of the project scope and/or completion date being changed to all the Long Range Plan projects, and also account for resource constraints.
A. PERIODIC UPDATING GPUN will update Categories A, B and C semi-annually and submit the revised listing of scheduled completion dates to the NRC, beginning six months following NRC approval of this plan. The information provided will include the following:
o Summarize progress in completing or implementing projects.
o Identify changes since last uplate report.
o Summarize the reasons for project scope and/or schedule changes associated with regulatory requirements.
1The listing of projects in Categories A, B and C will contain sufficient detail to identify those projects with tasks and/or completion dates keyed to refueling outages. In such cases, a change in outage period (i.e., initiation or duration) sh;11 not be considered a schedule change.
3436f
B. CHANGES TO ISSUE RESOLITTIONS AND/OR SCHEDULES Changes to the Long Range Plan may arise from a variety of reasons, such as new projects-identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (e.g., PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or GPUN actions.
Where it is necessary to add a new project or to change the schedule for a project, the following general guidance will be utilized to the extent appropriate:
o Assess the priority of the project relative to all existing Long Range Plan projects.
o Schedule the new or changed project to avoid rescheduling other projects, if it can be reasonably achieved.
o Select a schedule for the new or changed project which will help in maintaining an optimum integrated program of work.
Addition of activities to Category A requires GPUN to propose appropriate projects and/or completion dates and requires NRC approval of such proposals. Any conflicts with previously established schedule completion dates for Category A regulatory projects must be resolved by modifying the proposed plan to conform to the existing regulatory constraint or by preposing changes in the Category A completion dates if justified, based on project priority. As with proposals to add Category A activities, proposals to change previously existing Category A activities also requires NRC approval.
GPUN will inform the NRC Project Manager when serious consideration is given to requesting a change in Category A. When GPUN determines ~that a change in Category A is necessary, it will submit a written request for NRC approval in accordance with applicable regulations.
Projects in Category B or C may be modified, deleted or rescheduled, or new projects may be added to Category C by GPUN without NRC approval; however, GPUN will inform the NRC Project l
3436f
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Manager once a change, deletion, or addition to Category B is necessary. GPUN will provide the NRC with written notification of changes or deletions of Category B projects or completion dates associated with NRC initiated issues at a minimum in each semi-annual update but in any event et least 30 days prior to the Plan-scheduled completion date. Such notification will also include the reasons for the change and describe any compensatory actions which GPUN determines to be appropriate.
The change, addition or deletion in Category B will go_into effect upon evaluation by GPUN, unless the NRC, in writing, requests further explanation or discussion. NRC. requests will be made within 15 days of receipt of GPUN written notification. In this event, discussions will be initiated to promptly develop a project scope and/or schedule which is mutually acceptable to GPUN and the NRC Project Manager while considering overall program impact. The written notification by the NRC will serve to extend the schedule date for the period of time required for such discussion. If a revised project. scope and/or schedule is established in these discussions, such project scope and/or schedule will supersede the project scope and/or schedule set forch.in Category B. The revised project scope and/or schedule will be incorporated in a revised Category B in the next update submitted to the NRC. If a revised project scope and/or schedule cannot be established in these discussions, GPUN changes to projects scope and/or schedule dates will be effective unless subsequently modified by NRC Order.
In the event of unplanned delays, delays which become manifest within 30 days of the Plan-scheduled completion date or in the event of circumstances beyond GPUN's control, GPUN shall provide timely notification to the NRC Project Manager of the revised project and/or schedule date and incorporate it in a revised Category B in the next update submitted to the NRC.
GPUN will provide notification of changes, deletions, additions or rescheduling of Category C projects to NRC semi-annually. This is for information purposes.
VI. NRC REVIEW As pointed out in Section V.B above, changes to projects scope and/or schedules are inevitable. Action required by the NRC is discussed below:
A. GPU NUCLEAR ORIGINATED CHANGES
- 1. Upon receipt from GPUN of a request for modification of Category A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request.in accordance with applicable procedures.
3436f
- 2. If the request for a modification of Category A is denied, NRC shall~promptly inforn GPUN and provide the reasons for denial.
- 3. NRC consideration of GPUN changes to non-Category A projects and/or schedules is covered by Section V.B. /
B. NRC ORIGINATED CHANGES (CATEGORY A)
It is recognized that formal NRC regulatory actions (i.e., NRC rules, orders,, or license conditions) may: (1) impose a new regulatory requirement with a fixed date, or (2) establish a firm date for a previously identified regulatory requirement. In
.taking any such action, the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on GPUN:s ability to complete effectively the projects in Categories A, B, and C, in consultation with GPUN, will try to minimize such impact. Although any formal regulatory action (i.e., regulatory rule, order, or license condition) taken by the NRC will be effective in accordance with its terms without inclusion in Category A, the NRC and GPUN recognize the desirability of incorporating such action into Category A, particularly in order to incorporate at the same time any other 1
appropriate changes in the total integrated assessment program.
i Accordingly', once such form &1 regulatory action is taken (or-earlier, if practicable), the NRC will provide GPUN a reasonable opportunity to propose overall changes in the total integrated assessment program which would-most effectively accommodate such requirements. Any resulting changes in projects in Category A will be (1) reviewed by the NRC, taking in account the overall objective of the Long Range Planning Program to use available resources effectively, and (2)' approved by.the NRC in accordance with established procedures, and will thereupon be reflected in a revised Category A submitted by GPUN. GPUN will inform the NRC of any resulting changes in Categories Bsand C in accordance with Section V above. m.
C. NEW NRC ISSUES (CATEGORY B)
The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure revision or development, or (c) changes in facility staffing requirements. With respect to major issues which the NRC requests (1) scheduling infomation or (2) responses by a certain date, these issues c:ay be included in Category B in accordance with the project priority. Projects and/or schedule date commitments
.3436f
resulting from GPUN evaluation will form the basis for discussions between the NRC and GPUN. As for the case of NRC-originated changes to Category A issues, the NRC will provide GPUN a reasonable opportunity to propose overall changes in the. total integrated plan program which would most effectively accommodate such issues. Any resulting changes in the integrated plan program will thereupon be reflected in a revised Category B or C list submitted by GPUN.
D. Inspections and Audits The Plan and the Long Range Planning Program implementation processas and procedures do not fall within the scope of GPUN's Quality Assurance Program on the requirements of 10CFR50 Appendix B. The existence of the Plan does not change the extent or nature of NRC inspection or audit activities which would be applied in the absence of the Plan. Specifically the management processes by which resources limits are established and allocated are not subject to detailed audit or inspection. GPUN will provide information as discussed in Section V for review and/or approval by NRC of the basis for the Category A and B project schedules.
Implementation of those projects are subject to inspection and audit as required by GPUN QA Program and NRC Regulations.
VII. MODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, all Plan revisions will be submitted for prior NRC approval in accordance with existing NRC regulations. The revisions will be made effective upon amendment issuant oy the NRC.
l 3436f
ATTACHMENT 4 0070j SAFETY EVALUATION RIPORT PUMP AND VALVE INSERVICE TESTING FROGRAM OYSTER CREEK NUCLEAR GEhERATING STATION April 1982 H. C. Rockhold Reliability and Statistics Branch Engineering Analysis Division EG&G Idaho, Inc.
t Docket No. 50-219 i
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ABSTRACT
~This EG&G Idaho, Inc. report presents the results of our evluation of the Oyster Creek Nuclear Generating Station Inservice Testing Program for safety-related pumps and valves.
FOREWORD This report is supplied as part of the " Systems Engineering Support" Program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Enigneering, by EG&G Idaho, Inc., Reliability and Statistics Branch.
The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20 19 01 09, FIN No._A6258.-
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CONTENTS I. INTRODUCTION .................................................. 1 II. F U MP T E ST I N G P ROGR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-
- 1. Safety-Related Pumps ...................................... 2 III. VALVE TESTING PROGRAM EVALUATION .............................. 4
- 1. General Considerations .................................... 4 1.1 Testing of Valves which Perform a Pressure Isolation Function ................................... 4 1.2 Stroke Testing of' Check Valves ....................... 5 1.3 Test Frequency of Check Valves Tested at Cold Shutdowns ....................................... 5 1.4 Licensee Request for Relief to Test Valves at Cold Shutdowns ................'.................... 5 1.5 Safety-Related Valves ................................ 5 1.6 V alve Testi ng at Cold Shutdowns . . . . . . . . . . . . . . . . . . . . . . 6-1.7 Category A Valve Leak Check Requirements for Cont ainment I solation Valves (CIVs) . . . . . . . . . . . . . . 6 1.8 Application of Appendix J Testing to the IST Program .......................................... 6
- 2. Ge ner ic R el ie f R eque s t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
~2.1 Category A and A/C Valves ............................ 7'
- 3. Core Spray System ......................................... 9 3.1 C a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4 ~ Liquid Poison System ...................................... 10 4.1 C a t eg o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 5. Control Rod Drive Hydraulic System ........................ 11 5.1 C atego ry B V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.2 Category C Valves .................................... 11
- 6. F e ed w a t e r Sy s t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.1 Category A/C Valves .................................. 12 M a i n S t e am Sys t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7'.
7.1 Categcry B/C Valves .................................. 12 1
7.2 C a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13u iii
- 8. Closed Cooling Water System ............................... 13 8.1 Category A and A/C Valves ............................ 13 8.2 Category C Valves .................................... 14
- 9. Miscellaneous Systems ..................................... 14 9.1 Category A and A/C Valves ............................ 14 9.2 Category C Valves .................................... 15 IV. APPENDIX A .................................................... 17
- 1. Code R equi remen t--V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 V. ATTACHMENT I .................................................. 18 VI. ATTACHMENT-Il ................................................. 19
- 1. C o r e S p r ay Sy s t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
- 2. Reactor Shutdown Cooling System ........................... 19
- 3. Control Rod Drive Hydraulic System ........................ 19
- 4. Clean-up Demineralizer System ............................. 20 VII. ATTACHMENT III ................................................ 21 3
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l I. INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Jersey Central Power and Light-Company (JCP&L) for its Oyster Creek Nuclear Generating Station.
The working session with JCP&L and Oyster Creek representatives was 4 conducted on September 23 and 24, 1980. The licensee resubmittal was
- received by EG&G Idaho, Inc., on October 13, 1981, and reviewed to verify.
compliance of proposed tests of safety-related Class 1, 2, and 3 pumps and valves with requirements of ~the ASME Boiler and Pressure Vessel Code, Sec-tion XI, 1974 Edition, through the Summer of 1975 Addenda. JCP&L ha.s also requested relief from the ASME Code from testing specified pumps and valves because of practical reasons. These requests have been evaluated individ-ually to determine whether they have significant risk implications and whether the tests, as required, are ~ indeed impractical.
1The evaluation of the pump testing program and associated relief requests.is contained in Section II; the evaluation of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.
A summary of valve-testing requirements is provided in Appendix A.
Appendix J exemption requests for Category A valves that should be
, reveiwed by the NRC are contained in Attachment I.
Category A, B, ar.d C valves that meet the requirements of the ASME Code Section XI and are not exercised every three months are contained in Attachment II.
A listing of P& ids used for this review are contained in Attach-ment.III.
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II. PUMP TESTING PROGRAM The IST program submitted by Oyster Creek was examined to verify that Class 1, 2, and 3 safety-related pumps were included in the program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review fcund that all Class 1, 2, and 3 safety-related pumps were included in the IST program and, except for those
~
pumps identified below for which specific relief from testing has been requested, the pump tests and frequency of testing comply with the code.
Each Oyster Creek basis for requesting relief from testing pumps and the EG&G evaluation of that request is sumarized below.
- 1. Safety-Related Pumps
.1.1 Relief Request Relief is requested from the requirements of Section XI to measure pump bearing temperatures in accordance with IWP-3300.
1.1.1 Code Requirement. IWP-3300 states bearing tem be measured ouring at least one inservice test each year. peratures shall
.l.1.2 Licensee's Basis for Requesting Relief. Vibration measurements taken on a quarterly basis are trended. Significant increases in these readings will necessitate further vibration measurement with the use'of a real time spectrum analyzer to define the source of the increase. Use of the real time analyzer is a method to determine mechanical condition.
Bearing temperature measurements therefore contribute a redundant measure of bearing condition and thus need not be performed. A yearly vibration frequency spectrum analysis will be performed on all pumps.
1.1.3 Evaluation. The licensee has demonstrated that the vibration measurements obtained by the proposed pump testing program would more accurately indicate the condition of the pump bearings than annual bearing temperature measurements. Therefore, we feel relief should be granted from the code specified method of pump testing. We feel the use of quarterly vibration measurements and annual use of the real time spectrum analyzer will adequately demonstrate pump mechanical condition and should predict pump failure.
1.2 Relief Request.
Relief is requested from the requirements of Section XI for performing monthly inservice pump tests. a 1.2.1 Code Requirement. IWP-3400 states an inservice test shall be run on each safety related pump, nominally each month during plant opera- ,
tion.
1.2.2 Uicensee's Basis for Requesting Relief. The intent of imposing the pump testing program is to provide assurance of an increased level of u plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, 2
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monthly testing also requires additional run times and _ unusual operation of the equipment necessary to drive the pump and to align the system. for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would pro-vide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves 'concerning the optimization of the test frequency. The investigation has resulted in a revision to the code which requires a. pump test frequency of nominally once every 3 months.
Pumps will be tested monthly by starting and measuring either flowrate or differential pressure. During a quarterly pump test all identified parameters shall be measured.
1.2.3 Evaluation. We agree with the licensee's basis for quarterly pump testing with monthly pump starts and measurement of either flowrate or differential pressure since this is in accordance with the current NRC posi-tion on pump testing. Therefore, we feel relief should be granted from the monthly pump testing requirements as specified in Section XI. We feel the licensee's proposed alternate test will adequately demonstrate proper operability and will be effective in discovering or predicting pump-failure.
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III. VALVE TESTING PROGRAM EVALUATION The IST program submitted by Oyster Creek was examined to verify that all Class 1, 2, and 3 safety-related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that all Class 1, 2, and 3 safety-related . valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and frequency of
- testing comply with the code requirements and the NRC positions and guide-lines listed in Section 1. Also included in Section 1 is the NRC position and valve listings for the leak testing of valves that perform a pressure ,
isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each Oyster Creek basis for requesting
- specific relief. from testing valves and the EG&G evaluation of that request is summarized below and grouped according to each specific system.
- 1. General Considerations
-1.1 Testing of Valves Which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high- and low-pressure systems prevent the
, low-pressure systems from experiencing pressures which exceed their design limit. In this role, the valves perform a pressure isolation function.
The NRC considers the redundant isolation provided by these valves to be important. The .NRC considers it necessary to assure that the conditior, of-each of these valves is adequate to maintain this redundant isolation and system integrity. For these. reasons, EG&G and the NRC believe that some method, such as pressure monitoring, leak testir.g, radiography, or ultra-
- sonic testing, should be used to assure that the condition of each valve is
- satisfactory in maintaining this pressure isolation function.
If leak testing is selected as the appropriate method for achieving this objective, the NRC and EG&G Idaho, Inc., believe that the following valves should be categorized as A or A/C and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:
NZO2-A V-31-5 NZO2-B V-31-2 NZO2-C B-2-72 NZO2-D V-2-71 V-20-40 V-2-73 V-20-21 V-2-74~
V-20 V-16-62
- V-20-41 The NRC end EG&G Idaho, Inc., have discussed this matter with the '
licensee and identified the valves listed above. The licensee agreed to.
I consider testing and categorizing each of these valves with the appropriate 4
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i designation, depending on the testing method selected. .Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC, for avaluation, the details of the testing method which clearly demonstrates the condition of each valve.
1.2 Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only limited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valve shall be partial stroked. Since
- disk position is not always observable, the NRC staff stated that verifica-i tion of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement.
Any flow' rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or-greater than the design flow rate through the valve. The licensee agreed to conduct flow tests to satisfy l the above position.
1.3 Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold ' shutdowns, valve testing need c.at be performed more often than once every three months for Category A and i
B valves and once every nine months for Category C valves. It is the NRC's position that the Code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has .,
L ' agreed to modify his procedures on cold shutdowns to read, "In the case of [-
- frequent cold shutdowns, valve testing need not be performed more often ;-
than once every three (3) months for Category A, B, and C valves." Q 7
1 .4 Licensee Request for Relief to Test Valves at Cold Shutdowns i
j The Code permits valves to be tested at cold shutdowns, and the condi-tions under which this is permitted are noted in Appendix A. These valves
- are specifically identified by the-licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that u was not practical to exercise these valves during power operation and that we agree i with the licensee's basis. It should be noted that the NRC differentiates, for valve testing purposes, between the cold-shutdown mode and the refuel-ing mode. That is, for testing purposes, the refueling mode is not con-sidered as a cold shutdown.
j 1.5 Safety-Related Valves
! This review was limited to safety-related valves. Safety-related valves are refined as those valves that are needed to mitigate the conse- -
t quences of an accident and/or to shut down the reactor and to maintain the .
reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some t
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non-code c ass valves. It should be noted that the licensee may have included non-safety-related valves in their IST program as a decision on the ' licensee's _part to expand the scope of their program.
4 1.6 Valve Testing at Cold Shutdowns Inservice valve testing at' cold shutdowns is acceptable when the fol-lowing conditions are met:
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- 1. It is understood that the licensee is to commence testing as soon as'the cold-shutoown 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 />'after shutdown, and continue until complete or the plant ,
is ready to return to power.
- 2. Completion of all valve testing-is not a prerequisite.to return
. to power.
- 3. IAny testing not completed at one cold- shutdown should be performed during any subsequent cold shutdowns that may occur before refuel-ing to meet the code-specified testing frequency.
- 4. For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold-shutdown mode, 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.
1.7 Category A Valve Leak Check Requirements for Containment Isolation
. Valves (ClVs)
) ~
! All CIVs shall be classified as Category A valves. The Category A
+ . valve-leak rate test requirements of IWV-3420(a-e) _ have been superseded by
' Appendix.J requirements for CIVs. The NRC has concluded that the appli-cable leak-test procedures and requirements for CIVs are determined _by 10 CFR 50, Appendix J. Relief from Paragraph IWV-3420(a-e) for CIVs pre-l- sents no safety problem since the intent of IWV-3420(a-e) is met by l Appendix J requirements.
i l The licenste shall. comply with Sections f and g of IWV-3420 until
- relief is requested from these paragraphs. It should be noted that these l paragraphs are enly applicable where a Type C, Appendix J 1eak test is l performed. Based on the considerations discussed above, the NRC concludes j that the alternate testing proposed above will give the reasonable assur-I ance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public. ,
1.8 Application of Apr mdix J Testing to the IST Program f
I The Appendix J review for this plant is a completely separate review from the IST program review. However, the determinations made .y that review are directly applicable to the IST program. Our review has deter-mined that th% current IST program, as submitted by the licensee correctly .
reflects th: NRC's interpretation of Section XI vis-a-vis Appendix J. The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
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- 2. Generic Relief Requests l
2.1 Category A and A/C Valves l
- 2. l ~.1 Relief Request. Relief is requested from the leak' testing requirements of Section XI for all Category A containment isolation valves.
2.1.1.1 Code Requirements. Refer to Section XI Paragraph IWV-3420.
2.1.1.2 Licensee's Basis for Requesting Relief.- The low pres-
. sure seat leak test required by IWV-3420 is redundant to the seat leak test required by 10CFR50, Appendix J. Type C for valves performing a containment isolation function. Performing two separate-tests would provide no addi-
- tional useful data. As an alternate, the seat leak test required by 10CFR50, Appendix J, Type C will be performed, in lieu of the low pressure Secti.on XI IWV-3420 seat leak test. The high pressure seat leak test
- required for pressure isolation valves will still be performed in accordance with IWV-3420.
! 2.1.1.3 Evaluation. The NRC has concluded that the applicable
! leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J (refer to Section 1.7 of this report).
2 Therefore, we feel relief should be granted from the requirements of Sec-
, tion VI, Paragraph IWV-3420 for containment isolation valves. We feel the licensee's proposed alternate test of leak testing per Appendix J will adequately demonstrate the leak tight integrity of these valves.
- 2.1.2 Relief Request. Relief is requested from the requirements of
! Paragraph IWV-3410(c)(3) for all valves that are tested on a cold shutdown or refueling frequency.
, 2.1.2.1 Code Requirement. Paragraph IWV-3410(c)(3) requires that if an unacceptable increase in stroke time is observed, the valve test frequency shall be increased to once per month until corrective action is taken. ,
2.1.2.2 Licensee's Pisis for Requesting Relief. Valves are i tested on a cold shutdown or refueling frequency because there is a defined basis. for not testing on a quarterly frequency during power operation (e.g.,
t the plant is put in an unsafe condition, system design does not permit test-ing). Accordingly,'the basis for not testing these valves quarterly would
! also apply to monthly testing. As an alternate, the test frequency will i remain unchanged. The requirements contained in the Oyster Creek Technical i Specifications will govern plant operations regarding out of service valves.
! 2.1.2.3 Evaluation. The licensee has demonstrated that the j - plant's Technical Specificati_ons have limiting conditions for operation i
which identify systems and components out of service and the operational consider ~ations for those conditions. Therefore, we feel relief should be granted Trom the requirements of Paragraph IWV-3410(c)(3) of Section XI for -- .
all valves that are identified for exercising during cold shutdown or refueling outages.
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2.1.3 Relief Reauest. Relief is requested from the requirements of Section XI, Paragraph IWV-3410(f) for testing of valves in systems out of '
service. f 2.1.3.1 Code Requirement. Paragraph IWV-3410(f) requires all valves in systems out of service to be exercised immediately prior to the return of the system to service.
t 2.1.3.2 Licensee's Basis for Requesting Relief. The Limiting Conditions for Operation presently contained in the Oyster Creek Technical Specifications along with the Oyster Creek Plant Procedures adequately cover all such situations. As an alternate, the requirements contained in . .
the Oyster Creek Technical Specifications and Plant Procedures will govern plant operation in such situations.
2.1.3.3 Ev aluation. We agree witn the licensee's basis and feel the plant's Technical Specifications more adequetely determine what equip-ment needs to be tested when a system is returned to service. Therefore, we feel relief should be granted from the requirements of Section XI, Para-
. graph IWV-3410(f).
2.1.4 Relief Reouest.
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Relief is requested from the ret,uirements of Paragraph IWV-3410(g) of Section XI.
2.1.4.1 Code Requirement. IWV-3410(g) states when corrective action is required as a result of tests made during cold shutdown, the co'ndition shall be. corrected before startup.
2.l.4.2 Licensee's Basis for Requesting Relief. The Limiting Conditions for Operation presently contained in the Oyster Creek Technical Specifications along with ~the Oyster Creek Plant Procedurer; adequately cover the situation of out of service valves and plant operations. The requirements contained in the Oyster Creek Technical Specifications and Plant Procedures will govern plant operation regarding out of service valves.
2.1.4.3 Evaluation. We agree with the licensee's basis and feel the plant -Technical Specifications adequately determine what equipment /
systems must be in operation prior to plant startup and during power opera-tion. Therefore, we feel relief should be granted from the requirements of Section XI, Paragraph IWV-3410(g).
2.1.5 Relief Request. Relief is requested from the exercising and leak testing requirements of Section XI for the excess flow check valves ,
listed below.
V-130 V-1-184 V-37-70 V-37-16 '
V-130-26 V-1-185 V-37-71 V-37-17 V- 130 V-37-7 V-37-72 V-37-27 V-130 V-37-8 V-37-73 V-37-28 V-130-21A V-37-18 V-37-74 V-37-38 u V-130-1 V-37-19 V-37-75 V-37-39 V-130-2A V-37-39 V-14-49 V-37-49 8
V-130-28 V-37-30 V-14-50 V-37-50 V-130-6A V-37-40 V-14-52 V-130-9 V-130-6B V-37-41 V-14-53 V-130-10 V-130-7 V-37-51 V-14-55 V-20-172 V-130-8 V-37-52 V-14-56 V-20-173 V-130-218 V-37-66 V-14-54 V-37-59 .
V-1-180 V-37-68 V-37-5 V-1-181 V-37-69 V-37-6 2.1.5.1 Code Requirement. Refer to Appendix A.
2.1.5.2 Licensee's Basis for Requesting Relief. Instrumentation lines connected to the reactor coolant pressure boundary and which pene-trate primary containment are designed in accordance with USNRC Regulatory Guide 1.11 which permits a flow restricting orifice inside containment and an excess flow check valve outside containment for isolation. This design configuration does not permit valve exercising or local seat leak tests to
. be performed. These excess flow check valves are demonstrated to be func-tional (i.e., close with differential pressure across the valve) during the refueling outage as required by Plant Procedure 604.3.008.
2.1.5.3 Evaluation. The licensee has demonstrated that the excess flow check valve design configuration does not permit exercising during power operation. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these small check ' valves. We feel the licensee's proposed alternate test of verifing proper valve opera-tion (closure) during refueling outages when the instrumentation is avail-able for testing will adequately demonstrate the ability of the valves to perform their safety related functions.
- 3. Core Spray System 3.1 Category C Valves 3.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V20-60 and V20-61, fire protection system to core spray check valves.
3.1.1.1 Code Requirement. Refer to Appendix A.
3.1.1.2 Licensee's Basis for Requesting Delief. V20-60 and V20-61 are category C normally shut check valves. These valves cannot be exercised open during power operation or cold shutdown since initiating flow through these valves could result in putting fire protection system water into the reactor. These valves will be full stroke exercised during refueling outages.
es 3.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation or cold shutdown could result in injecting sea water from tne fire protection system througn the core spray system into the reactor. Injection of this water could result in degrada-tion of the reactor coolant system (i.e. cloride stress corrosion). There-fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate 9
test of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve operability.
3.1.2 _ Relief Request. Relief is requested from the exercising requirements of Section XI for valves V20-88 and V20-89, fire protection system to core spray check valves.
3.1.2.1 Code Recuirement. Refer to Appendix A.
3.1.2.2 Licensee's Basis for Requesting Relief. These valves '
are normally shut check valves. These valves cannot be exercised open during power operation or cold shutdown since initiating flow through these -
valves could result in putting fire protection system water into the reactor. These valves will be full stroke exercised during refueling outages.
3.1.2.3 Evaluation. The licensee has demonstrated that exercising these valves during power operation or cold shutdown could result in injecting sea water from the fire protection system through the core spray system into the reactor. Injection of this. water could result in degrada-tion of the reactor coolant system (i.e. cloride stress corrosion). There-fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve operability.
4 Liquid Poison System 4.1 Category C Valves 4.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves Vl9-16 and Vl9-20, poison system to the reactor vessel check valves.
4.1.1.1 Code Requirement. Refer to Appendix A.
4.1.1.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation since flow thru these valves requires pumping highly concentrated sodium pentaborate into the RCS, causing plant shutdown. Performing this test during cold shutdowns l requires flushing the poison system for up to 3 days, possibly causing a delay in startup. These valves will be full stroke exercised during the l liquid poison system full flow injection test at refueling.
1 4.1.1.3 Evaluation. The licensee has demonstrated that exercis-l ing these check valves during power operation would require injecting I highly concentrated sodium pentaborate into the RCS causing reactor shut- *
! down. Additionally, during cold shutdowns injectio.1 of the sodium penta-borate into the iCS would cause extensive chemical and radioactive waste l
generation since all this chemical would have to be flushed from the RCS
- prior to reactor operation. Therefore, we feel relief should be granted .
from the exercising requirements of Section XI for these valves. We feel l
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the licensee's proposed alternate test-of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve
- operability.
S. Control Rod Drive Hydraulic System l
5.1 Category B Valves 5.1.1 Relief Request. Relief'is requested from the exercising requirements of Section XI for valves CV-126 and CV-127 (137 valves each),
- scram inlet / outlet control valves. ,
f 5.1.1.1 Code Requirement. Refer to Appendix A.
5.1.1.2 Licensee's Basis for Requesting Relief. CV-126 and 127 cannot be exercised during power operation since exercising these valves scrams the associated control rod. - Withdrawl 'of this rod at power could cause fuel. damage to the core. Per. Technical Specification requirements, a
, sample of 8 of these valves (137 of eadi) are tested during cold shutdown if the sample has not been tested in the previous 6 months. All valves are tested at refueling.
5.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves would cause the associated control rod to scram which could result in reactor fuel damage if performed during power operation.
Therefore, we feel relief should be granted from the exercising require-1, ments of Section XI for these valves. We feel the licensee's proposed j alternate of testing these valves per Technical Specifications will
- adequately demonstrne proper valve operability.
i 5.2 Category C Valves 5.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves 108 (137 valves), scram water to
5.2.1.1 Code Requirement. Refer to Appendix A.
5.2.1.2 Licensee's Basis for Requesting Relief. These valves (137) can only be verified open during the actual scram testing. Per Tech-nical Specification requirements, a sample of 8 of the 137 valves are tested during cold shutdown if the sample has not been tested in the pre-vious 6 months. All valves are tested at refueling.
5.2.1.3 Evaluation. The licensee has demonstrated that the only method of verifying valve opening is actual scraming of the associated con-trol rod _ and scram testing of individual control rods during power operation could result in fuel damage. We feel the plant's current Technical Specifi-l- cation r.equirements will adequately demonstrate proper valve operability therefors we feel relief should be granted from the exercising requirements of Section XI for these valves. All these valves will be full stroke u exercised at least each refueling outage.
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- 6. Feedwater System 6.1 Cat,egory A/C Valves 6.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V2-71, V2-72, V2-73 and V2-74, main feedwater to reactor isolation valves.
6.1.1.1 Code Requirement. Refer to Appendix A.
6.1.1.2 Licensee's Basis for Requesting Relief. Exercising these valves during power operation would require isolation of the feed- .
water system, which results in plant shutdown. Two of these valves are inaccessible during cold shutdown when the containment atmosphere is inerted. These valves will be verified shut (which is their safety related ,
position) during their Seat Leak Test each refueling outage.
6.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would result in isolation of the feedwater to the reactor resulting in plant shutdown. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of verifica-tion of valve closure during the leak rate testing performed during each refueling outage will adequately demonstrate proper valve operability.
- 7. Main Steam System 7.1 Category B/C Valves j 7.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves NR-108A, NR-1088, NR-108C, NR-108D and NR-108E, ADS / reactor safety valves.
7.1.1.1 Code Requirements. Refer to Appendix A.
7.1.1.2 Licensee'.s Basis for Requesting Relief. Exercising these relief valves during power operation or cold shutdown would simulate a small-break transient, subjecting the RCS to large and unnecessary shocks.
In addition, in keeping with the views put forth in NUREG 0737,Section II.K.3.16 concerning reducing challenges to safety and relief valves, these valves should be tested at a reduced frequency. As an alternate, these valves will be full stroke exercised during startup following a refueling outage, i.e., on a refueling outage frequency.
l 7.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would appear to be a loss of cool-ant accident to the engineered safety features systems and would result in ;
injecting relatively cold water into the RCS resulting in severe thermal transients to the piping and components. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these v alves . We feel the licensee s proposed alternate test of exercising these ,_
l ADS / relief valves during startup following refueling outages will adequately demonstrate proper valve operaoility.
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7.2 Category C Valves 7.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves Vl-178, V1-179, Vl-180 and Vl-181, 3 ADS discharge headers vacuum breakers.
7.2.1.1 Code Requirement. Refer to Appendix A.
7.2.1.2 Licensee's Basis for Requesting Relief. These valves are located inside the drywell and are not accessible while the containment is inerted. These valves will be exercised at refueling, when conditions allow access to the drywell, i.e., when the containment is de-inerted.
7.2.1.3 Evaluation. The licensee has demonstrated that since these valves are located inside containment, they are not accessible for
> manual exercising. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the i licensee's proposed alternate test of full stroke exercising _these valves.
l during refueling outages when the containment is de-inerted will adequately demonstrate proper valve operability.
- 8. Closed Cooling Water System 8.1 Category A and A/C Valves l 8.1.1 Relief Request. Relief is requested from the exercising l
requirements of Section XI for valves V5-147, V5-166 and V5-167, closed cooling water containment isolation valves.
8 .1.1.1 Code Requirement. Refer to Appendix A.
8.1.1.2 Licensee's Basis for Requesting Relief. Full stroke exercising of these valves isolates cooling water flow to 'the recirculation pumps. Isolation of cooling water during normal plant operation can cause possible damage to these pumps, thus requiring plant shutdown. During cold shutdown these valves will be full stroke exercised providing all recircu-lation pumps are turned off. The recirculation pumps will not be secured l to perform testing. These valves will be full stroke exercised at least on a refueling outage frequency.
8.1.1.3 Evaluation. The licensee has demonstrated that exercis-ing these valves during power operation would isolate cooling water flow to i
the reactor recirculation pumps which could result in pump damage requiring l plant shutdown for repairs. Therefore, we feel relief should be granted from the exercising recuirements of Section XI for these valves.. We feel the licensee's proposed alternate test of full stroke exercising these l
valves during cold shutdown, providing all reactor recirculation pump are turned 6ff, and during refueling outages will adequately demonstrate proper valve operability.
8.1.2 Relief Request. Relief is requested from the exercising ,
t requirements of Section XI for valve V5-165, closed cooling water contain I ment isolation check valve.
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8.1.2.1 Code Requirement. Refer to Appendix A.
8.1.2.2 Licensee's Basis for Requesting Relief. The only method available to verify that this valve shuts (which is its safety related function) is via the Seat Leak Test performed during refueling outages. As an alternate, this valve will be exercised during the Seat Leak Test at refueling.
8.1.2.3 Evaluation. The licensee has demonstrated that the only currently available means of verifying closure of this check valve is via leak testing. Therefore, we feel relief should be granted from the exer-cising requirements of Section XI for this ' check valve. We feel the licensee's proposed alternate test of verifying valve closure during refueling outages when the Appendix J leak rate testing is performed will adequately demonstrate proper valve operability.
8.2 Category C Valves 8.2.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves V-5-153 and V-5-154, closed cooling water pumps discharge check valves.
8.2.1.1 Code Requirement. Refer to Appendix A.
8.2.1.2 Licensee's Basis for Requesting Relief. ~These valves cannot be exercised shut during power operation since both CCW pumps are required for heat removal during months of high service water temperature or during periods of RBCCW high heat loads. Exercising these valves would require shutting down one of these pumps. As an alternate, V5-153/154 will be exercised during cold shutdown only on those occasions when one CCW pump can handle the heat removal load. These valves will be exercised at least each refueling outage.
8.2.1.3 Evaluation. The licensee has demonstrated that these check valves cannot be exercised during power operation since both CCW pump are required for heat removal during periods of high service water temper-ature or high RBCCW system heat loads. Therefore,_we feel relief should be granted from the exercising requirements of Section XI for these check valves. We feel the licensee's proposed alternate test of full stroke exercising these check valves during cold shutdown providing the heat removal capabilities of the system can be accomplished with one CCW pump.
These valves will be full stroke exercised at a minimum of each refueling eutage.
Miscellaneous Systems (
9.
9.1 Category A and A/C Valves .
9.1.1 Relief Request. Relief is requested from the excecising ard leak testing requirements of Section XI for valves V31-2 and V31-5, reactor l head cooling Tontainment isolation valves. ,
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9.1.1.1 Code Requirement. Refer to Appendix A.
9.1.1.2 Licensee's Basis for Requesting Relief. These passive valves are not required to open to fulfill their safety related function,
.thus U1ey need not be stroked open. No valve full stroke exercise test will be performed. Position of- valves will be verified closed during valve l in eup. As an alternative to the Section XI Leak Test an Appendix J, Type A Leak Test will be performed on the combination.
9.1.1. 3 Evaluation. The licensee has demonstrated that 'these valves are normally closed passive containment isolation valves. There-i fore, we feel relief should be granted from the exercising requirements of Section XI for these valves. Additionally, we feel the leak testing i performed per Appendix J is a suitable alternative to the Section XI leak testing requirements (see Paragraph 1.8 of Section III of this-report).
9.1.2 Relief Request. Relief is requested from the exercising requirements of Section XI for valve V16-84, relief valve V16-76 discharge from reactor water cleanup system to torus check valve. .
9.1.2.1 Code Requirement. Ref er to Appendix A.
9.l.2.2 Licensee's Basis for Requesting Relief. Operation of
- 'this valve is not verifiable except during the annual Type A test. This valve is functionally tested in the closed position during the ~10CFR50 Appendix J, Type A test conducted during refueling.
9.1.2.3 Evaluation. The licensee has demonstrated that the only way to verify valve closure (its safety related position) is by leak rate testing and this valve is normally leak rate tested during the Appendix J 4
Type A leak tests performed during refueling outages. Therefore, we feel relief should be granted from the exercising requirements of Section XI for i
this valve. We feel the licensee's proposed alternate test of verifying valve closure during each refueling outage will adequately demonstrate proper valve operability.
9.2 Category C Valves 9.2.1 Relief Request. Relief is requested from the exe* :ising requirements of Section XI for valves V3-62 and V3-63, service water pumps discharge check valves.
9.2.1.1 Code Requirement. Refer to Appendix A.
9.2.1.2 Licensee's Basis for Requesting Relief. V3-62 and V3-63 cannot be exercised quarterly since both service water pumps are typically required to handle the heat removal load during months of high service water temperature or during periods of RBCCW-high heat loads. As an alternate,
, these valves will be exercised on a cold shutdown frequency only on those occasions when one service water pump can handle the heat removal load.
These valves will be exercised at least each refueling outage. ,
9.2.1.3 Evaluation. The licensee has demonstrated during months of high service water tenperatures and during periods of high RBCCW heat 15
. a loads, both service water pumps are typically required to be operating.
Therefore, we feel relief should be granted from the exercising require-ments of Sect"1 XI for these valves. We feel the licensee's proposed alternate test of exercising these check valves during cold shutdowns when one service water pump can supply the flow required for adequate system heat removal and during each refueling outage will adequately demonstrate proper valve operability.
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IV. APPENDIX A
- 1. Code Requirement--Valves Subsection IWV-3410(a) of the 1974 Edition of the Sectio XI ASME Code (which discussed full stroke and partial ' stroke requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). IWV-3520(a)-(which discusses full stroke and partial stroke requirements) requires that Code Category C valves be~ exercised once every three months, with exceptions as defined in IWV-3520(b). In the above cases of exceptions, the Code permits the valves to be tested at cold shutdown where:
- 1. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
- 2. It is not practical to observe the operation of the valves (with failsafe actuators) upon. loss of actuator power.
Subsection IWV-3410(c) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time.
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a V. ATTACINENT I The following is a list of valves that we feel should be reviewed by the NRC to determine if these valves meet the Appendix J criterion for containment isolation. If any of these valves are determined to be Appendix J valves then they should be included in the IST program and categorized A, A/C or A/E as applicable.
V-15-27 CRD Hydraulics to the reactor vessel ' !
V-15-28 CRD Hydraulics to the reactor vessel
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VI. ATTACittENT II The following are Category A, B, and C valves that meet the require-ments of the ASME Code,Section XI, and are not full stroke exercised every three months during plant operation. These valves are specifically identi-fied by tne owner and are full stroke exercised during cold shutdowns _ard refueling outages. EG86 has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operaticn is not possible, due to the valve type and location, system design, or .
because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.
- 1. Core Spray System 1.1 ~ Category A/C Valves NZO2-A', NZO2-B, NZO2-C and NZO2-D, core spray to reactor check valves, annot be exercised during power operation since the core spray pumps cannot develop sufficient discharge head to pump into the RCS. Addition-ally, zero differential pretsure must exist across the valves for the valve test operators to move the valve discs. These valves will be full stroke exercised during cold shutdowns and refueling outages using the valve test-oper ators.
- 2. Reactor Shutdown Cooling System 2.1 Category B Valves V 1, V- 17-2, V- 17-3, . V-17-19, V-17-54, V- 17-55, V-17-56, and V-17-57, rhutdown cooling system isolations from the RCS, cannot be exerciseo during power operation since opening these valves could result in an overpressurization of the low pressure shutdown cooling system. Addi-tionally, valves V-17-19 and V-17-54 are interlocked to remain closed when 1 the reactor coolant temperature is greater than 350*F. These valves will be full stroke exercised during cold shutdowns and refueling outages.
- 3. Control Rod Drive Hydraulic System 3.1 Category B Valves V-15-119, V-15-120 and V-15-121, seram discharge yolume yent and drain valves, cannot be exercised during power operation since valve failure in the closed position could increase the scram insertion times to greater than acceptable limits. These valves will be full stroke exercised during cold shutdowns and refueling outages.
3.2 Category C Valves
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Valves 106 (137 valves), scram accumulator charging line stop chek u valves, cannot be exercised during power operation since this e.ould require depressurizing the scram charging header which could result in delayed 19
4 recharging of the accumulators if a scram occurred. These valves will be exercised during cold shutdowns and refueling outages.
V-15-27 and V-15-28, control rod drive hydraulic system to reactor vessel check valves,- cannot ce exercised shut during power operation since the CRD hydraulic system must remain operable during power operation.
These valves will be exercised during cold shutdown when recirculation system temperature and pressure permit safe inspection. These valves will be exercised at least on a refueling outage frequency. '
- 4. Clean-Up Demineralizer System 4.1 Category A Valves V-16-1, V-16-2 and V-16-14, clean-up demineralizer system isolation valves, cannot be exercised during power operation since stopping and restarting this system would result in thermal transients on the RCS piping and components. These valves will be full stroke exercised during cold shutdowns and refueling outages.
4.2 Category A/C Valves V-16-62, clean-up demineralizer system return to reactor coolant sys-tem check valve, cannot be exercised shut during power operation since stopping and restarting the flow through this system would result in ther-mal transients on the RCS piping and components. This valve will be verified shut during cold shutdowns (with pressure gage at sample station) and refueling outages (via leak testing).
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't VII. ATTACINENT III 4
Below is a list of drawings and P&ID's utilized during the course of this review.
I Drawing System Nunber Revision Is'olation Condenser IP-19418 0 Poison XP- 19419 0
.Containnent Spray IP-19420 0 Reactor Recirculation JCP-19421 0 j Core Spray IP-19422 0 Main Steam JCP-19423 0 Condensate Transfer System XP-19424 0
' Fire Protection JCP-19425 . O Misc. Class 1 and 2 System Penetrating Cont. IP-19426 0 Service and Emergency Service Water JCP-19427 0 L ,
Closed Cooling Water IP-19428 0 f
Hydraulic Control Unit JCP-19429- 0 Fuel Pool Cooling XP-J9430 0 l
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