ML20212D543

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Forwards Resolution of Inservice Testing (IST) Issues for Second 10-yr Interval & Description of IST Program for Pumps & Valves,In Response to 861027 Meeting.Requests Response by 870115 Re Whether or Not NRC in Agreement W/Approach
ML20212D543
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/24/1986
From: Hukill H
GENERAL PUBLIC UTILITIES CORP.
To: Stolz J
Office of Nuclear Reactor Regulation
References
5211-86-2201, NUDOCS 8701020053
Download: ML20212D543 (95)


Text

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GPU Nuclear Corporation Nuclear

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Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 64 2386 Writer's Direct Dial Number; 5211-86-2201 December 24, 1986 Office of Nuclear Reactor Regulation Attn:

J. F. Stolz, Director PWR Projects Directorate No. 6 US Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Stolz:

Three Mile Island Nuclear Station Unit 1 (THI-1)

Operating License No. DPR-50

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Docket No. 50-289

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Inservice Testing (IST) of Pumps and Valves This letter is in response to our meeting of October 27. 1986 concerning the second 10-year IST program and supplements our letters of July 10, 1984 and March 3, 1986. Expeditious NRC review is necessary since GPUN is unable to carry out IST at specified in the NRC's Safety Evaluation Report (SER) dated October 3, 1986. GPUN is unable to fulfill certain aspects of the program described in the SER for a variety of reasons, including insufficient time to design and complete modifications to plant equipment during the 6R Outage.

This outage is currently in progress.

Appendix D of the NRC's SER lists the item; which need to be resolved. GPUN requested the October meeting in order to resolve the items where we felt the staff's position indicated that more information was needed to justify additional relief. The meeting focused on just those items needing additional discussion. Attathment i lists each of the items from Appendix D of the SER and describes GPUN's proposed resolution.

It should be noted that GPUN has accepted the staff's position on many of these unresolved items. is a revision of GPUN's IST program description which incorporates the necessary changes and corrections.

Changes to the IST program implementing procedures required to incorporate the changes included in this re-submittal will become effective no later than six months from the will be dateofthisletter,exceptthatallcoldshutdown/refuelingtesting/

implemented prior to startup for Cycle 6 operation.

Table B-3 of the program description has been revised to include th additional valves which have been added, to update the limiting stroke times which have changes as a result of modifications and to correct an error in the previous submittal. HDL-V304 should have been assigned a limiting stroke time 8701020053 861224 PDR ADOCK 05000289 P

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3 of 2.0 seconds since the' actual stroke time is less than i second. All of

these changes are consistent with the NRC staff position on rapid-acting power Loperated. valves'as described in Appendix A of the SER.

It should be noted y

Lthat._ Table 8-3:1s a typical listing and may need to be revised to reflect the

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icharacteristics of installed plant equipment.

GPUN does not feel that any

revision to this-table during the IST interval'needs to be submitted to the s

NRC where GPUN's program meets the staff's position and is consistent with the relief granted in,the SER.

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-Your letter of October 23, 1984 (Item A-1) granted interim relief to allow for s

installation of flow instrumentation for the Control Building Chilled Water

. Pumps (AH-P3A/8) and'the Screen House Ventilation Equipment Pumps (SW-P2A/B) during the'7R refueling outage. The SER (Sections 2.1.1 and 2.9.1) grants interim relief until the startup for Cycle 7 operation, but it is not clear from the wording in the SER that these modifications are not being required

' prior. to startup for _ Cycle 6.

During the meeting in_ October,1986 the NRC staff stated that it was not their intent to require these modifications prior to' Cycle-7.

For documentation purposes, we request that this be confirmed in-

a. supplement to;the SER.

Although it was_ not at all apparent from your letter of October 3, 1986, we understand from the October meeting that the NRC did not intend to require completion of any IST modifications during the current outage. We understand that the NRC had intended that they be completed p" lor to the end of the next outage (Outage 7R).

It is also our understanding from the meeting that while we are. working toward a resolution of the few issues which are yet unresolved, specific modifications required by the SER are being placed on hold pending resolut;'n.~ In order to assure compliance, a supplement to the SER will be

'needed by-February 20, 1987, prior to the startup for Cycle 6 granting either relief.or interim relief until startup for Cycle 7 operation.

If an additional: submittal will be needed for the NRC to complete its supplemental SER by February 20, 1967 GPUN must know by January 15, 1987 to allow sufficient time for preparation of the submittal or any changes in the

. program prior to startup. We request your help in expediting the staff's review of this transmittal-and letting us know by~ January 15, 1987 whether or not you are in agreement with the approach we have described.

Sincerely, I

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H. D.

k 11 Vice President & Director, TMI-1 HDH/MRK/spb:0716A cc: - J. Thoma R. Conte Attachments

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RE50LifTION OF INSERVICE TESTING (IST)' ISSUES '

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FOR THE SECOM TEb VEAR INTERVAL Licensee's Required Action Items:

D.I (Summarized from Appendix D of the-NRC's SER on IST dated 10/3/861 GPtAl*1 on-me i

i D.I.1 AH-P3A/B

GPUN accepts the staff's position on AH-P3A/B'as discussed.in the October 1986-I The licensee has proposed to install flow
meeting. The modification to' install flow instrumentation fer AH-P3A/S is instrumentation on the control building chilled

' scheduled for completion prior to Cycle 7 operation. ' This is in accordance' with..

i water pumps. AH-P3A/B prior to startup for Cycle 7.

the relief provided by the NRC's letter of October 23 1984 (Item A-1).

The SER j

(SER Section 2.1.1)

.also grants interim relief until the startup for Cycle 7 operation, but-it is. net l

. clear from the wording in the SER that modifications are not being required prior to startup for Cycle 6.

During the October 1986 meeting, NRC clarified that it.

was not their. intent to require the<e modifications prior to Cycle 7.

For documentation purposes, GPUN requests that this be reconfirmed in a supplement-to

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the SER.

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0.l.2 CA-PIA /B It is GPUN's position that the plant modifications to install recirculation piping-

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The licensee will be required to perform system and instrumentation which would be required in order to test CA-P1A/B in li modifications in order to test the boric acid accordance with Section XI on.a quarterly frequency would not result in a l

pumps. CA-PIA /B in accordance with Section XI.

substantial increase in the overall protection of the public health and sasety.

(SER Section 2.2.1)

-over that afforded by the refueling interval test program. The primary source of.

emergency boration is from the Borated Water Storage Tank ~(BWST). The safety related function of CA-PIA /S is to provide one of the alternate sources of 2

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. emergency boration. That is, to provide borated water from the Boric Acid Mix i

Tank (SAMT) to the RCS via the Makeup Tank (MUT).

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. During the October 1986 meeting. the NRC suggested that GPUN investigate the l

feasibility of using other flow paths to test CA-PIA /B as an alternative to plant modifications. Specifically. NRC suggested that batch volumes pumped from the j

BAMT to the 4% tank might allow quarterly testing of the CA-PIA /B. GPUN has i

determined that pumping to some alternate tank (other than the Makeup Tank) is not practical for the following reasons:

1.

Pumping to the Spent Fuel Pool or BWST would require large. volumes to detect a i

j level change for determining flowrate. Also, moving large volumes from the l

BAMT would, by level decrease, disqualify this tank as the T.S. backup -

emergency boration source tank.

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ATTACMMENT 1 PAGE 2 of 11 0.1.2 CA-PIA /B (Cont'd.)

2.

Pumping to the 4% tank presents a high potential for disabling the design function of this tank. Because the 47, tank is designed for Core Flood Tank makeup, the boric acid concentration is much less than the concentration of the BAMT. Also, a test that pumps the BAMT to the 4% tank may cause crystallization of the solution in the 4% tank and disable our ability to R

provide makeup to the Core Flood Tanks because the 4% tank, piping and pump -

are not heat traced.

3.

Batch pumping from the BAMT into some other container was also considered.

However, there are no drain valves close to the pump, and any selected drain remote from the pumps could provide misleading information since the observed flow could be more of a result of system draining rather than indicative of pump performance. Also, whatever batch size is required to perform the test, this quantity would have to be discarded as radwaste.

Therefore, we find that there is no practical flowpath that will allow the, measurement of CA-PIA /B flowrate on a quarterly test f requency.

In a memorandum to J.F. Stolz dated April 8, 1982 MEB addressed the relief that had been requested for CA-PIA /B.

The memorandum stated that relief should be granted for P', T, and refueling interval testing, but the licensee should calculate a P and ficwrate. This memorandum was distributed as an attachment to the Meeting Notice for our May 15, 1984 meeting on IST. The position ooscribed in this memorandum was presented as the position of the NRC staff during rar March 1984 meeting and was transmitted to GPUN on May 29, 1984 as an enclosure to the NRC's Meeting Summary along with the transcripts. At the time of the meeting in March 1984, GPUN was of the opinion that CA-PIA /B could possibly be removed f rom the IST program. Subsequent to the meeting in March,.984, GPUN has accepted the inclusion of CA-PlA/B in the IST program. This meets the NRC staff's position in 1984 except that Pg and A P will not be calculated. See Footnote 12 of Table A-2 for the reason for not calculatirg P5 and a P.

The IST program description ( Atta&**nt 2) includes all of the meaningful testing which can be performed using the existing system design as requested by the NRC in the meeting of September 4-5, 1985. This is consistent with the agreement reached during the September 4-5, 1985 meeting and recorded in the tran cripts on pp. 232-252. We request that the NRC reconsider its current position that modifications be required and provide a Supplement SER which accepts the 1994 NRC Staff Position and the position given in the September 4-5, 1985 eeeting transcripts. As stated in the ccver letter, GPUN cannot possibly comply with the SER modification schedule as currently written. GPUN believes that the test program provided is adequate to assure the operational readiness of CA-PIA /B.

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ATTACleENT.1; PAGE 3 of 11:

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.GPUN accepts the staff's/ position on W P2A/5'as diicassed in the'0ctober 1906' The licensee has proposed to irstall flow '

meeting. The modification to install flow instrumentation for E P2A/S is.

-instrumentation on the screen house ventilation

. scheduled for. completion prior:to Cycle 7 operation.' This is in accordance with' equipment pumps (SW-P2A/B). prior to startup for the relief provided by the NRC's letter of October 23, 1984 (Item A-1)..The SER 4

Cycle 7. -(SER Section 2.9.1) grants interim relief until the startup for Cycle 7 operation, but 'it is not l'

clear from the wording in 'the SER that modifications.are not being required prior s

J-to startup.for Cycle' 6.

During the October 1986 meeting, the NRC stated that it j

' was net their intent. to require these modifications prior to_ Cycle 7.

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documentation purposes, GPUN requests that this be confirmed in a supplement to'*

the SER.

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It is' GPUN's position.that plant modifications to install flow instrumentation'-

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D.I.4 WDL-P13A/B which would be required.in order to test WDL-P13A/S on a quarterly frequency -

The licensee will be required to perform system modifications.in order to test the boric acid in accordance with Section XI would not result in a substantial increase in the '

recycle pumps in accordance with Section XI.

. overall protect on of the public health and safety over that' afforded by GPUN's i

(SER Section 2.10.1)'

test program which includes-certain quarterly: tests in addition to the refueling interval tests.' This is essentially the same issue as D.I.2.

The safety function' of WDL-P13A/8 is to provide another emergency boration source as backup to the BWST. That'is,'to provide borated water from the Reclaimed Boric Acid Tank (RBAT)'.

to the RCS via the Makeup' Tank.(MUT).

t During"the October 1986 meeting'the NRC suggested that pumping from one R8AT'to i

another would provide test capabilities to satisfy the quarterly test i

requirements. However, if a RSAT is being used as the T.S. backup boration source, the balance of concentration and volume will be adversely af fected by 4

pumping the T.S. RBAT to the other RSAT. Since this testing would disqualify the tank as a backup boration source, this test method is not considered to be a i

practical alternative.

As discussed in the response to D.1.2, MEB recommended granting the relief from quarterly test requirements-for CA-PlA/B in a docketed memorandum. The NRC's position at that time did not specifically address WDL-P13A/B because WDL-P13A/B has been added to the IST program subsequent to the March 1984 meeting. 'The IST program description (Attachment 2) reflects a test program for WDL-P13A/B which meets the NRC's position from 1984 on testing CA-PlA/S. The test program described in Attachment 2 is consistent with the agreement reached and recorded in i

the transcripts from the September 4-5, 1985 meeting (pp. 232-252). that is, to perform all.meaningf ul tests that can be performed using the installed equipment.

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ATTACMMENT 1 PAGE 4 of 11-D.l.4 ~WDL-P13A/B (Cont'd.)

We request that the NRC reconsider its current position that modifications be required and provide a supplement SER which accepts the 1984 staff position for pumps performing a similar function. As stated in the cover letter, GPON cannot possibly comply with the SER modification schedule as currently written. GPUN believes that the test program we are providing is adequate to assure the operational readiness of WDL-P13A/B.

-"+w D.'.S MU-P1A/B/C The SER states that the licensee his not adequately explained the use of a The licensee will be required to perform system reference value flowrate. The ISi program description has been revised to modifications in order to test the makeup and provide a better description of the use of a reference value flowrate for purification pur.ps in ac6urpance with Section XI.

the test of MU-PIA /B/C. This confirms that the recirculation flow test of (SER Section 2.11.1)

MU-PIA /B/C is truly a fixed reference flow test, as requested by the NRC in the October 1986 meeting. The NRC also soggested that GPUN consider measuring stem positions for MU-V32 and MU-V17 to assure that the flow resistance will remain.

cor..iaat f rom test to test. Due to the inaccuracies involved in stem position measurements, GPUN does not believe that the additional time and exposure of the operators is warranted in attempting this technique for MU-V32 and MU-V17.

If erosion or cavitation were to result in significant wear to the' minimum recirculation orifice, the pump's flowrate would increase and the a P would decrease causing the IST pump data to f all in the " alert" or " required action" range of ASME Section XI, Taole IWP-3100-2. This would require action to resolve,.

and wurk would be perf ormed to determine the cause and solution of any pump or - -

orifice wear problem. Radiography could be used to verify degradation of the orifice. Since pump discharge pressure and flow are measured (except for the fixed minimum recirculation orifice fiow), GPUN feels that the existing test as described in the program description is repeatable and provides for adequate monitoring of MU-PIA /B/C performance.

In addition to the quarterly test program, MU-PIA /B/C's accident design flowrate is verified by Surveillance Procedure 1303-11.8 each refueling.

D.I.6 DH-V14A/B The current maximum stroke test of DH-V14A/B demonstrates that these valves will The licensee will be required to disassemble allow 2/3 of the design basis flowrate as described in the IST program description.

valves DH-V14A/B. decay heat removal and reactor GPUN has agreed to a valve disassembly program f or DH-V14A/B. However, we feel building spray pumps borated water storage tank that disassembly of one valve every refueling interval is too f requent due to the suction check valves, during refueling outages risk of defeating Decay Heat Removal Capability. Disassembly of one of the DH-V14 on a sampling basis to verify valve operability.

valves would take a train of Decay Heat Removal (DHR) out of service during the (SER Section 3.4.3.2) refueling outage when DHR capability needs to be maintained in accordance with

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-PAGE 5 of 11' D.l.6 DH-V14A/B (Cont'd.)'

T.S. 3.4.2.1.

GPUN feels that because of the risk to Decay Heat Removal Capability. and the exposures which would result from disassechly, the oppropriate -

J frequency of disassembly should be one valve each ten years. J GPUN intends to disassemble both of these valves during the current refueling outage and report -

the results to the kRC following the outage. These valves see little service, sot the possibility of service wear as exhibited in recent industry experience with check valve failure is minimal. Results of DH-V14 disassembly during this outage should provide further information to support GPUN's proposed ten year disassembly inspection frequency.

D.4.7 FW-V12A/B GPUN's commitment to develop and implement a test method to verify operability of-The licensee will be required to leak-rate test the FW-V12A/B has been met. The IST program description (Attachment.2) has been main feedwater header check valves FW-V12A/B during rewised to include a full closure test of FW-V12A/B on a refueling interval basis.

refueling outages to verify valve closure capability, lhe test of.fW-V12A/B is adequate to verify the valves closure capability and (SER Section 3.6.1.1) provides assurance of their operability.

D.I H MS-V9A/B MS-V9A was disassembled during the current 6R Refueling Outage. A report of the The licensee will be required to disassemble the disassembly results will be sent to the NRC by separate letter, emergency feedwater pump turbine steam supply check valves during refueling outages on a sampling basis to verify operability. (SER Section 3.8.2.1)

D.l.9 MU-V14A/B (SER Section 3.9.2.1)

Design flow testing of the HPI system is performed each refueling in accordance D.I.10 MU-V73A/B/C (SER Section 3.9.3.1) with T.S. 4.5.2.1.

This test results in a full-stroke of each of the HPI check D.I.ll MU-V86A/8/C (SER Section 3.9.3.2) valves listed in D.I.9 through D.I.15.

The test involves an injection to the RCS D.1.12 MU-V94 (SER Section 3.9.3.3) through the HPI injection nozzles. Each injection through an HPI nozzle results D.I.13 MU-V95 (SER Section 3.9.3.4) in a thermal cycle to the nozzle. Currently only 48 thermal cycles of these D.1.14 MU-V107A/B/C/D (SER Section 3.9.3.5) nozzles are allowed. Quarterly testing of the HPI check valves D.I.15 MU-V220 (SER Section 3.9.3.6) would not be appropriate because testing at power would result in additional The licensee will be required to full-stroke exercise thermal cycles to the injection nozzles. Nor would testing of the HPI check the above listed HPI check valves during cold shutdowns valves on a cold shutdown frequency be appropriate because this would not with the exception of MU-V94.

The licensee will be eliminate the imposition of additional thermal cycles to the injection nozzles required to full-stroke exercise MU-V94 quarterly in due to Technical Specification limitations. In order to prevent overpressurization accordance with the requirements of Section XI.

of the RCS T.S. 3.1.12.3 requires that the HPI injection valves (HU-V16A/B/C/D) be closed unless the reactor vessel head is removed or the RCS temperature is

>275'F.

T.S. 4.5.2.1.c further limits the ability to test the HPI check valves without resulting in additional thermal cycles of the HPI injection nozzles by requiring RCS temperature to be >320'F for any test that requires flow through MU-V16A/B/C/D unless the reactor vessel head is removed. Therefore. HPI-check valve testing can only be performed during refueling outages.

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ATTACH' MENT l-PAGE 6 of 11 D. l.9 - D. l.15 (Cont 'd. )

MU-V94 cannot be full-stroke. exercised' each quarter because this' would be disruptive to normal plant operation and would create the potential for an unsafe'

' pressure tra9sient-during power operation. Normal RCS makeup.through MU-V94 is

. 40 gpm.

Increasing this to accident design flowrate may.. create an.

overpressure transient and challenge the RPS high pressure trip setpoint or the.

PORV. In additioni if MU-V94 were to be tested each quarter, an additional' Letdown Cooler would be placed into. service. This would cause a thermal cycle on the cooler.,Therefore, in accordance with ASME Section XI IWV-3412, MU-V94 will-be part-stroked each quarter.

D.I.Ib RR-V6 GPUN has accepted the staff's pos'ition on this issue. The IST program description The licensee will be required to trend the stroke has been revised to' include trending of stroke time measurements of RR-V6 and our time measurements of valve RR-V6. Reactor Building request for relief has been withdrawn.

cooling units backpressure control valve, in accordance with Section XI.

(SER Section 3.11.1.1) 0.1.17 SS-V30A/B GPUN intends t'o disassemble one of these valves during the current 6R Refueling The licensee will be required to perform a sample Outage and submit a report on the results following the outage. These valves see disassembly / inspection of valves BS-V30A/B, the very little service. Therefore, the susceptibility of BS-V30A/B to service related Reactor Building spray header check valves, at a wear, as exhibited in recent industry experience with check valve failures, is refueling outage frequency. (SER Section 3.12.1.1) minimal. GPUN believes that the results of disassembly of one of the BS-V30 valves during 6R will provide additional information sufficient to justify less frequent disassembly than each refueling outage on a sampling basis as required by the SER.

GPUN intends to disassemble one of these valves during the current 6R Refueling D.I.18 BS-V52A/B The licensee will be required to perform a sample Outage and submit a report on the results following the outage. These valves see disassembly inspection of valves BS-V52A/B, Sodium very little service. Therefore, the susceptibility of BS-V52A/B to service related Hydroxide Tank Supply to the Reactor Building spray wear, as exhibited in recent industry experience with check valve failures, is pumps. at a refueling outage frequency. (SER Section minimal. GPUN believes that the results of disassembly of one of the BS-V52 3.12.1.2) val /es during 6R will provide additional information sufficient to justify less f requent disassembly than c*e valve each ref ueling as required by the SER.

GPUN has accepted the staff's position to test the PORV as discussed with the NRC D.I.19 RC-RV2 The licensee will be required to test the PORV, during the October 1986 meeting. The IST program description (Attachment 2) has RC-RV2. in accordance with the requirements of been revised to inc?cde the additional testing.

Item A.9 of the SER at least once each refueling cycle.

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5 ATTACHMENT 1 PAGE 7 of.11 0.1.20 Soent Fuel Coolina System As discussed with 'the NRC during the October 1986 meeting and a (nnference call on -

The staf f will require that the Spent Fuel Cooling November 10,'1986, GPUN believes that suf ficient reliable, redundant and diverse Syster flow path valves be included in the IST ' '

means are'available for makeup to the spent fuel pools to eliminate the need for program and tested in accordance with Section XI.

adding the Spent Fuel Cooling System valves to the IST Program or installing an Providing a safety grade source of makeup water to -

additional safety grade source of makeup water.

. the spent fuel _ pools would be an acceptable alternative to adding this system to the IST program.

The following reliable sources of water are available at the spent fuel pools for (SER Section 2.8.1) makeup to compensate for boil-of f which might result from a sustained total failure of_both Spent Fuel Cooling System trains:

1.

The Reclaimed Water Storage System is piped to the Spent Fuel Pool. This-system is relied upon to provide makeup to the spent fuei pools under normal conditions of evaporative losses. Because of its other system support functions (i.e., RCP No. 3 seal purge,:and radweste precoat filter processes) for continued ' power operation,' this system should be available for sekeup to the spent fuel pools.

2.

As a backup to the Reclaimed Water System, the three Reactor Coolant Bleed Tanks (RCBTs) normally contain collectively at least 80,006 gallons of water suitable for makeup to the spent fuel pools using a waste transfer pump.

Although the Liquid Waste Disposal System is not included in *.he IST program, the operability of this system is necessary to process radwaste and therefore necessary to assure. continued power operation.

3.

The fire service system is available at the spent fuel pools through FS-V143 and the hose reel station as the ultimate backup source of makeup water. The fire service system, including this hose reel station, are required to be operable during all operating conditions (T.S. 3.18).

As discussed in the FSAR, section 9.4.7, in the event both spent fuel Cooling service simultaneously, commencing with the pool temperature loops were out o[F, approximately 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> would elapse before the initially at 147 temperature would heat up to 212 F..This is a conservative estimate and normally the time available would be much longer, but 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> would provide enough time to restore one of the loops before any boil-of f could occur.

Considerably more time would then need to elapse before a significant quantity of water could boil away.

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'PAGE 8 of 11 0.l.20' Soent Fuel Coolina Svstem (Cont'd.)

In conclusion, GPUN believes that the spent fuel pool makeup capability from the existing Reclaimed Water System,' Reactor Coolant Bleed Tanks and the Fire Service System provides reliable, redundant, and diverse _ sources of makeup capability in the-event of boiling. Therefore, the Spent Fuel System Valves need not be included in the IST program.

D.l.21 MU-V10 and MU-VilA/B GPUN accepts the staf f's position on %V10., The IST program description has been The ' licensee will-be required to include valves -

revised to include %V10. ' MU-VilA/B, however,- are not required for emergency HU-VIO, acid return from deborating demineralizers, boration since one %V11 is open for normal operation. MU-VllA/B have no safety and MU-VilA/B, makeup and purification filter inlets, related function. MU-VilA/B are used for operating convenience to switch between in the IST Program and test them in accordance with filters, MU-FlA/B. The first choice for emergency boration would be the BWST '

Section XI because these valves are in an emergency not using the MU filter flow path. Under emergency boration f rom the backup source boration flow path and the appropriate valves tanks, the Makeup filters can be bypassed. Procedural guidance'on bypassing these upstream of these three valves have been included filters for emergency boration is provided in EP 1202-37.

in the program.

D.l.22 NS-V108A/B fand AH-VilA/B1 GPUN accepts the staff's position on control valve testing as discussed in the The licensee has failed to include NS-V108A/B, October, 1986 meeting. NS-V108A/B, and AH-VllA/B have been.added to the IST program control building air conditioning cooling water (see Attachment 2). Also, GPUN has developed a test method for testing NS-V54A/B, outlet valves, in the IST program. These valves NS-V55A/B, NS-V56A/B and SW-V24A/B and our request for relief from IWV-3413 stroke should be included in the program, timing of these valves has been withdrawn.

D.I.23 D. G. Fuel Oil Transfer Pumos and Anoropriate Valves GPUN believes that the current test program for the Emergency Diesel Generators is and Air Start Svstem from Air Receivers to the Enaine adequate to assure high reliability of the Emergency Diesel Generators. Also, we do The staf f position is that these auxiliary systems not believe that the ASME Section XI Code was intended to be applied to these diesel-should be included in the IST program and tested in auxiliary systems. However, as discussed with NRC during the meeting on October 27, accordance with Section XI.

1986 and in a conference call'on November 10, 1986, GPUN would be willing to add the-following component tests to the IST program if the NRC would consider this program as described below to be a satisfactory resolution of this issue and grant the relief which would be needed.

1.

The Fuel Oil Transfer Pumps [DF-PIA ( AC-powered) DF-PIB(DC-powered),

DF-PIC( AC-powered), and DF-PID(DC-powered} } and associated discharge check -

valves would be added to the IST Program.

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- i ATTACHPENT 1 PAGE 9 of.11:

D.1.23 D. G. Fuel Oil Transfer Pumos and' Anorooriate Valves.

- ' Inlet pressure (Pg) would not be measured since there are no existing and Air Start Svstem from Air Receivers to the Enaine pressure gages.

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(Cont'd.)

Differential pressure (A'P) would not be measured since there are no installed discharge pressure gages.

Flow rate (Q) would not be measured since there are no installed flow meters. During the monthly diesel generator surveillance test, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> run which verifies design power output, the flow rate would be verified by confirmation of the ability of the pump to maintain the day tank within.

acceptable level' limits.

A

- ' Pump lubricant level would not be observed since the pump is lubricated by the pumped fuel. oil and there is no external lubrication mechanism.

Pump bearing temperature would not be measured. The pump and motor are a si ngl e. uni t.

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Allowing 5 minutes run time prior to taking d.ita may not be possible since the pump is controlled by a level switch in the day tank.

Pump inboard vibration readings would not be taken since there are no pump bearings.

2.

The diesel generator air start valves. (EG-V16A/A, 8/A, A/B, and B/8) would be added to the IST program.

These valves are fast acting solenoid valves for which percent increase in stroke time would not be calculated.

These valves would be verified to open by placing a hand on the valve and feeling it actuate, and by acknowledging that the diesel rolls over.

'GPUN wishes to point out that THI-l diesel generators have demonstrated a high reliability. The reliability of THI-1 diesel generators, as reported to the NRC in response to Generic Letter 84-15, docunients this performance.

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't ATTACHMENT 1-

'PAGE j0 of..ll-The internals of EF-V3 have been removed during the Eddy Current Outage in U.1.24 -EF-V3 March, 1966. The IST program description (Attachment 2) has been revised to reflect -

The licensee has stated in the IST program that the internals will be removed from valve EF-V3, this change, emergency feedwater peeps river water supply check, and they will delete this valve from the IST program.

This item will require verification because no information has been received that addresses this revision.

D.2 Omissions and Errors Observed Durina Review of the Licensee's Prooram D.2.1 The check valves CF-V4A/B do not isolate the The valve numbers which were given in note 3 on page 2 of 37 of the IST program Reactor Coolant System f rom the Decay Heat Removal description submitted to NRC on March 3,1986, were incorrect.. This has been' System as stated by the licensee in Table B-1, corrected in the revised IST program description (Attachment 2), and also a note 4 Footnote 3, page 2 of 37.

has been added in order to clarify the intent.

Other:

DH-V16A/B As discussed with NRC during the. meeting on October 27,-1986, the rationale for The SER granted relief f rom full-stroke testing of requesting clarification of the relief which has been granted in the SER is both DH-V16A and B each cold shutdown, but requires essentially the same as that stated in our previous IST program description.

that each valve. DH-V16 A and B be full-stroke What our request did not point out was that current requirements for the DHR System tested every other cold shutdown.

valve alignment have been changed and this has resulted in the "B" DHR loop being favored during a shutdown.

For power operation, the current DHR Swstem operating procedure requires DH-V12B to be locked open and DH-V12A to be locked closed. This is for protection against boron precipitation following a LOCA and is part of the resolution of NUREG 0737, Item II.B.2 shielding issues as described in the NRC's SER dated December 24, 1934.

The f ull-stroke test for the idle DH-V16 would require a deliberate shif t' of Decay Heat Removal (DHR) Trains. For cold shutdowns of short duration, it is impractical to require a complete system realignment to the opposite DHR system for the sole purpose of cycling this single check valve at design system flow rate. The basis for this conclusion is that:

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.4l ATTACHMENT I PAGE 11 of 11 uther: DH-V16A/B (Cont'd.)

(1) ' The system realignment requires manipulation of several large manual valves

-(DH-V12A and 8).inside radiation areas where doserate could be as high as 500 mR/hr. Stay time in the radiation area to' cycle one DH-V12 is 15 minutes for.

1 three men. The extra radiation exposure and rad waste generation to cycid this one check valve (DH-V16A or B).is not consistent with ALARA principles.

(2) The system realignment may be critical path time on a recovery from a forced outage. The cost of delaying startup'in order to stroke this one check valve makes testing at each cold shutdown impractical.

(3) A requirement to full-stroke this check valve each cold shutdown (if not-performed within the last 3 months) would require the start of a large Engineered Safeguards (E.S.) pump and mator for the sole purpose of full-stroking this one check valve. The extra wear on this E.S. system merely to full-stroke one check valve is undesirable.

(4) For normal planned cold shutdowns. routine maintenance activities have and will require that each DHR system be operated while the other is down for maintenance. When this occurs both DH-V16A and B will be full-stroked.

Therefore in order to eliminate the need for. switching DHR loops every other

~

shutdown which would result in unnecessary exposure and radwaste generation. GPUN requests that the relief granted in the SER be expanded in a supplement to the SER.

DH-V168 will be tested each cold shutdown and both DH-Y16A/B will be tested each refueling outage. In addition, both valves will be part-stroked each quarter.

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THREE MILE' ISLAND NUCLEAR STATION I i

i UNIT 1-t 1

INSERVICE' TESTING (IST) 0F PLMPS AND VALVES PROGRAM DESCRIPTION'

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THREE MILE ISLAND UNIT NO. I:

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. PERIODIC. INSERVICE' INSPECTION PROGRAM - (PUMPS).

I.

SCOPE AND OBJECTIVES

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This table describes the Inservice Inspection Program for all Class,1, 2, and.3 pumps which are.

i provided with an emergency. power source. :The objective of-this program is.to' provide assurance of the operational readiness of these pumps during their service life.

II.

APPLICABLE ASME CODE EDITION AND. ADDENDA' In accordance with 10 CFR 50.55a(g)(4)(11), the applicable Code. Edition and' Addenda are the 1980 j

Edition with Addenda through Winter, 1980.

III.

PERIOD OF APPLICABILITY In accordance with 10 CFR 50.55a(g)(5)(iv), this program is applicable'.from September, 1984 to-1 September, 1994.

IV.

INSPECTION PROGRAM The inspection program, which is ' detailed 'in Table A-1, will be carried out in accordance with ASME Code Section XI,1980 Edition with Addenda through Winter,1980.

Specific. exceptions to the ASME Code 2

i Section XI requirements for each component are identified'in Table A-2 along with the basis for each exception requested.

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'THREE MILE ISLAND UNIT NO.;l 4

PERIODIC-INSERVICE INSPECTION PROGRAM

-(PUMPS)

PAGE-l'of;3.

PUMP FLOH ISI TEST-00ANTITIES MEASURED

  • TEST:

T **

-INTERVAL-De PUMP NAME NUMBER (S)

DIAGRAM DRAHING N

Pj AP Q.

- V _-.LUBR.

b LEVEL CONTROL AH-P3A C-302-847 1D-ISI-FD-011 X

.X

.X QUARTERLY BUILDING AH-P3B CHILLED HATER Y

BUILDING BS-PIA C-302-712 1D-ISI-FD-012 X

X X-X X.

X-QUARTERLY SPRAY BS-PIB BORIC ACID CA-PIA C-302-670 1D-ISI-FD-021 X

X X

' PLANT REFUELING l

CA-PIB INTERVAL 1

DECAY HEAT DC-PIA C-302-645 ID-ISI-FD-003 X

X X

X X

X QUARTERLY CLOSED COOL-DC-PIB ING HATER DECAY HEAT DH-P1A C-302-640 1D-ISI-FD-005 X

X X

X X

X QUARTERLY l

REMOVAL DH-PIB l

DECAY HEAT DR-PIA C-302-202 10-ISI-FD-002 X

X X

QUARTERLY-RIVER HATER DR-PIB SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES

    • BEARING TEMPERATURES WILL BE MEASURED YEARLY PER ASME SECTION XI, INP-3300.

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%r TABLE A-1 THREE MILE-ISLAND UNIT'NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM (PUMPS)

PAGE 2~of 3 PUMP FLOH

.ISI-TEST QUANTITIES MEASURED

  • TEST-PUMP NAME NUMBER (S)

DIAGRAM DRAHING N

Pj.

AP Q

V

.LUBR.

T **

INTERVAL b

LEVEL EMERGENCY EF-P1 C-302-082

!D-ISI-FD-009 X

X X

X X

X X

QUARTERLY.

FEEDWATER.

(TURBINE DRIVEN)

EMERGENCY EF-F2A C-302-082 10-ISI-FD-009 X

X X

X X

X QUARTERLY FEEDWATER EF 2B (MOTOR DRIVEN)

MAKL-UP AND MU-PIA C-302-661 10-ISI-FD-017 X

X X

X X

QUARTERLY PURli: Cal 10N MU-P1B

,MU-P1r NUCLEAR SERV.

NR-P1A C-302-202 10-ISI-FD-002 X

'X 00ARTERLY RIVER WATER NR-PIB NR-PIC X

X X

PLANT REFUELING INTERVAL NUCLEAR SERV.

NS-P1A C-302-610 1D-ISI-FD-010 X

X X

X X

X QUARTERLY, TH0 PUMP CLOSED NS-PIB COMBINATION TESTING COOLING WATER NS-PIC X

X X

X X

PLANT REFUELING INTERVAL, SINGLE PUMP TESTING SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES.

BEARING TEMPERATURES HILL BE MEASURED YEARLY PER ASME SECTION XI, IWP-3300

7m TAB'E A-1 L

THREE MILE ISLAND UNIT:NO.'l.

PERIODIC INSERVICE INSPECTION PROGRAM - (PUMPS) l PAGE 3 of'3-PUMP FLOH ISI TEST QUANTITIES MEASURED

  • TEST.

PUMP NAME NUMBER (S)

DIAGRAM DRAHING N

Pt AP Q.

V;

[LUBR.

T **

INTERVAL b

LEVEL REACTOR BLDG.

RR-P1A C-302-202 1D-ISI-FD-002 X

X OUARTERLY EMERGENCY RR-PIB COOLING X

X X.

PLANT REFUELING INTERVAL-SPENT FUEL SF-PIA C-302-630 1D-ISI-FD-018 X

X X

X X.

QUARTERLY COOLING SF-P2A SLREEN HOUSE SW-P2A C-302-203 ID-ISI-FD-002 X

X QUARTERLY VENTILATION SH-P2B EQUIPMENT X

X X

X OUARTERLY BORIC ACID WDL-P13A C-302-692 1D-ISI-FD-021 RECYCLE WDL-P13B X

.X X

PLANT REFUELING l

INTERVAL

l SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES
    • BEARING TEMPERATURES WILL BE MEASURED YEARLY,PER ASME SECTION XI, IWP-3300 NOTE: GPUN has determined that the Screen Wash and Sluice Pumps (SW-PIA /B) are not needed to achieve cold shutdown or mitigate the consequences of an accident since AP across the screen is alarmed and if necessary manual means can be employed to wash the screens.

Therefore, these pumps have been deleted from this submittal.

SH-PIA /B are supplied with emergency power but this is a convenience since the only power available in the Screen House is emergency power.

Therefore, per ASME Section XI, IWP 1200(b), they are excluded from IST.

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TABLE A-2

.THREE MILE ISLAND - UNIT NO. 1 PERIODIC. INSERVICE INSPECTION PROGRAM' -(PUMPS)

EXCEPTIONS TO ASME XI REQUIREMENTS

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PAGE 1 of 10 ASME III ASME XI CODE CLASS ASME XI EXCEPTION TESTING PERFORMED IN LIEU' PUMP NAME PUMP NO.

CODE CLASS EQUIVALENT REQUESTED

  • JUSTIFICATION OF CODE REQUIREMENT CONTROL BUILDING AH-P3A 3

Non-Nuclear Q

See Note 3 Flow metering will.be CHILLED NATER AH-P3B installed prior to startup-for Cycle 7.

Tb See Note 13 None Lubr. Level See Note 13 None BUILDING SPRAY BS-PIA 2

N-2 None N/A N/A~

BS-PIB i

BORIC ACID CA-PIA 3

Non-Nuclear Quarterly Testing See Note 12 Refueling interval testing.

CA-PIB Q

See Note 12 Q will be calculated.

Pi See Note 12 None AP See Note 12 None Tb See Note 5 None Five Minute runtime See Note 12 Run until system is stable.

DECAY HEAT DC-PIA 3

Non-Nuclear None N/A N/A CLOSED COOLING DC-PIB NATER DECAY HEAT DH-PlA 2

N-2 None N/A N/A REMOVAL DH-PlB DECAY HEAT DR-PlA 3

Non-Nuclear V

See Note 1 Motor vibration will be RIVER HATER DR-PIB measured.

Tb See Note 2 None Lubr. Level See Note 2 None j

SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES

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TABLE A-2 THREE MILE. ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - (PUMPS)

EXCEPTIONS TO ASME XI REQUIREMENTS PAGE 2 of 10 ASME III ASME XI CODE CLASS ASME XI EXCEPTION TESTING PERFORME0 IN LIEU PUMP NAME PUMP NO.

CODE CLASS EQUIVALENT REQUESTED

  • JUSTIFICATION OF CODE REQUIREMENT EMERGENCY FEED-EF-P1 2

Non-Nuclear Scale Range for See Note 9 Flowrate will be a measured HATER (TURBINE-flow meter test quantity using the in-DRIVEN) stalled flow meter.

l EMERGENCY FEED-EF-P2A 2

Non-Nuclear Scale Range for See Note 9 Flowrate will be a measured HATER (MOTOR-EF-P2B flow meter test quantity using the in-DRIVEN) stalled flow meter'."

MAKE-UP AND MU-P1A 2

N-2 Q

See Note 8 Q will be measured except for the fixed flowrate through the PURIFICATION MU-PIB 4

MU-PIC pump minimum recirculation orifice.

NUCLEAR SERVICE NR-P1A 3

Non-Nuclear Q

See Note 6 Hill be measured during RIVER WATER NR-PIB plant refueling outages.

NR-PIC V

See Note 1 Motor vibration will be measured.

Tb See Note 2 None Lubr. Level See Note 2 None NUCLEAR SERVICES NS-PIA 3

Non-Nuclear Single Pump See Note 10 Single pump testing will be CLOSED C00LINC NS-PIB Testing performed during each NS-PIC refueling outage.

REACTOR BUILDING RR-PIA 3

Non-Nuclear Q

See Note 11 Q will be measured during EMERGENCY COOLING RR-PIB plant refueling outages.

V See Note 1 Motor vibration will be measured.

Tb See Note 2 None Lubr. Level See Note 2 None

  • SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES h

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TABLE A-2 THREE MILE: ISLAND - UNIT NO..l'.

PERIODIC INSERVICE INSPECTION PROGRAM.- (PUMPS).

EXCEPTIONS TO ASME.XI REQUIREMENTS

,PAGE 3 of 10 ASME III ASME XI CODE CLASS ASME XI EXCEPTION TESTING PERFORMED.IN LIEU.

PUMP NAME PUMP NO.

CODE CLASS EQUIVALENT REQUESTED

  • JUSTIFICATION ~

' 0F-CODE REQUIREMENT 4

SPENT FUEL SF-P1A 3

N-3 Pt.

See Note 4 Pi will be calculated.

SF-PIB AP.

See Note 4 AP will be calculated.

Tb See Note 5 None SCREEN HOUSE SH-P2A 3

Non-Nuclear Q.

See Note 3 Flow metering will b'e.in3 tall-VENTILATION SH-P2B ed prior to startup.for EQUIPMENT Cycle 7.

V See Note 1 Motor vibration will be measured.

Tb See Note 2 None Lubr. Level See Note 2 None BORIC ACID WDL-P13A 3

Non-Huclear Q

See Note 12 Q will be calculated on a re-RECYCLE WDL-P138 fueling interval.

Pg See Note 12 Pt will be calculated during the quarterly test.

l AP See Note 12 AP will be calculated during the quarterly test.

Tb See Note 5 None 5 Minute runtime.

See Note 12 Run until system is stable.

Throttling to a See Note 12 AP and flow rate data will reference value.

be compared to the manufact-I urer's capacity curve.

f.

  • SEE ASME SECTION XI FOR DEFINITION OF TEST QUANTITIES

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TABLE A-2

'THREEMIL'EISLAN0!'UNITTNO.~'l 3

^

PERIODIC INSERVICE INSPECTION PROGRAM

'(PUMPS)~~

EXCEPTIONScTO ASME XI-REQUIREMENTS-PAGE ' 4 of.

' JUSTIFICATION NOTES Note 1

.e, This is a verti' cal deep well type pump with the' pump submerged under water lat all times.

Itvis not practical to measure pump vibration in this type of installation.. Past operating experience.has.shown that motorH

~

vibration is indicative of pump mechanical. problems in this type of installation.

Therefore, motor vibration will be measured.in lieu of pump vibration.

Note 2 This is a vertical deep well type pump with the pump submerged under water at all times.

Pump bearings are-lubricated by the fluid being pumped.

There are no installed means of measuring ~ bearing temperature and.the pump design and installation makes it impractical to measure in any other manner.

2 Note 3 There are no flow meters installed in the flow path of this pump.

Therefore test quantity "Q" cannot be.

measured. Prior to start-up for Cycle 7, GPUN will install flow metering for these pumps.

Note 4 For SF-PIA /B there is no pump inlet pressure gage tap.

Test quantities Pt and'AP cannot be measured.

SF-PIA (B) take suction from the Spent Fuel Pools.

The pool water level is alarmed high at 40 feet (347' elevation) and alarmed low at 38.5 feet (345.5' elevation).

This is only a 1.5 foot (0.65 psi) difference.

Therefore, SF-PIA /B suction pressure is nearly constant (can vary only by a maximum of'0.65 psig and this maximum difference in level is less than a 1 psig typical minor scale division)..Since Pt cannot be '

measured, it is calculated based on the water level in the pools.

Since suction pressure is relatively constant and can be calculated with reasonable accuracy, a suction pressure gage is not needed to determine the operational readiness of SF-PIA /B.

This method of testing meets the intent of the ASME Code Section XI test requirements and ensures the operational readiness of these components without directly measuring AP or Pj..aP and Pj will be calculated based on the water level in the pools.

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^ TABLE A-2 THREE MILE ISLAND - UNIT.NO.11 PERIODIC INSERVICE INSPECTION' PROGRAM _(PUMPS)

EXCEPTIONS TO ASME XI. REQUIREMENTS PAGE 5 of 10 JUSTIFICATION NOTES 'iCont'd)'

Note 5 Pump bearing temperature cannot be measured on this pump since'the bearings are located deep inside the pump casing and are. surrounded by an oil reservoir.. An exception is requested per 10 CFR 50.55a(g)(5)(111). in that measurement of parameter Tb is not practical within the limits of the design of.this. pump.

Note 6 Flow metering for this system is located in the common discharge lines from all three pumps.

Plant operating heat loads require the operation of at least two Nuclear Service River Water pumps during normal plant operation, thereby making it impossible to measure flow for a single pump.

Pump flow will be measured for each sump during plant refueling catages when operation of only one pump is required.

Note 7 (Note 7 has been deleted)

Note 8 MU-PIA /8/C are tested using a combination of fixed flow rate and measured flow rate.

Flow through RC Pump Seal Injection and Normal Makeup to the RCS is measured but flow through the minimum recirculation orifices (MU-FO-1/2/3) is held constant. MU-FO-1/2/3 are multiple plate orifices and the flow is held at a constant' design value for the head at which the MU pumps operate.

Testing is conducted by throttling to a reference seal injection flow rate and a reference Normal Makeup rate to the RCS.

Test flow rate is determined by the addition of the seal injection flow rate and Normal Makeup flow rate.

If errosion or cavitation causes.the orifice holes or plates to wear, MU-P1A/B/C's flow rate will increase, delta P will decrease, and the pump test data will fall in the alert or required action range of ASME Section XI, Table INP 3100-2.

The deviation will be determined and the condition corrected per ASME Section XI, INP 3230.

This is conservative since work will be performed to determine the cause and solution to either the pump problem or the orifice-wear problem.

If necessary, the orifice will be radiographed to verify degradation.

In addition, Surveillance Procedure 1303-11.8 verifies MU-P1A/3/C's accident design flowrate each refueling.

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59 TA'BLE ' A -2

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THREE MILE ISLAND: : UNIT NO:;1)..

PERIODIC INSERVICE: INSPECTION PROGRAM.- (PUMPS);

1 EXCEPTIONS-TO ASME XI; REQUIREMENTS PAGEE6;of 10l 1

JUSTIFICATION NOTES (Cont'd).

Note 9-B

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The Emergency Feedwater Pumps- (EF-PI: and EF-P2A/8) are tested on recirculation to:the Condensate Storage-Tanks.

Installed orifices.11mit flow rate-to a fixedfvalue.of ~190 gpm for EF-P1 and ~90' gpm for _ EF--P2A :,

and B. _Q is the independent. variable and-AP is the-dependent _ variable.

For:EF-Pl', flow rate is read on-l Flow Indicating Switch 78 (FIS-78).

FIS-78 scale range.is 0 to;1000 gpm._For EF-P2A'and B,; flow rate isi l

read on FIS-77 and FIS-79.

FIS-77 and 79' scale range:1s 0 to'500.gpm.

FIS-78, 77,'.and 79 do not meet.ASME-I Section XI, INP-4120 which. states ~"The full-scale range of each' instrument:shall'be three, times the reference:

i value or less." Relief is requested from INP-4120,.which states that: flow instruments-are to be calibrated to 22% of full scale rance.

The basis for' requesting relief is that FIS-78,.77 and 79.w111 be calibrated' j

such that one of the calibration points will be 200 gpm for.FIS-78 and 100 gpm for-FIS-77 and 79. This will insure that 22% accuracy.is achieved at the reference value of ~190 gpm for EF-P1 and ~90 gpm for.

1 EF-P2A and B.

All other code calibration requirements per INP-4000 will be met.

FIS-73,,77 and 79_are' located on the suction piping to'EF-Pl~and EF-P2A/B. -It is' impractical to reduce:the scale range of-FIS-78,.

77 and 79 since emergency feedwater flow rates when feeding the OTSG(s) are much greater than thetIST 4

reference flow rate values.

If.the FIS scale range were sized for:IST testing purposes, the_FISs would be-over-ranged and damaged when EF-P1 or EF-P2A/B were used to feed the OTSG(s). 'In conclusion, calibrating such that one of the calibration points is at 200 gpm for FIS-78 and 100 gpm for FIS-77 and 79_ insures that:

the acc @ ble accuracy of 22% is achieved for the IST Test.

Note 10 i

Flow metering for this system is located in the common discharge lines from all three' pumps. -Plant _ operating i

heat loads require the operation of at least two Nuclear Services Closed Cooling Hater Pumps during plant j

operation thereby making it impossible to measure flow for a single pump.

Therefore, two-pump testing will l

be conducted on a quarterly frequency.

Three two-pump tests will be performed as follows:

1.) pumps A and B' 2.) pumps B and C, and 3.) pumps A and C.

Two-pump, testing will be conducted in accordance with the j

requirements of ASME Section XI, Subsection IHP except that a reference va'ue for Q or AP will'not be established per IHP-3100 and 3110. Also Tacle IHP-3100-2 will not be useo.'or acceptance criteria. Two pump testing will be conducted such that Q will be measured.

This data point of AP and Q will then be compared to the pump manufacturer's capacity curve. Acceptance criteria will be 210% of the manufacturer's curve.

If the 2107. criteria is not achieved, an analysis will be made to demonstrate that pump operability is not 3

impaired and the pump will still fulfill its safety function.

If tr.

analysis cannot support the operability of the pump, the pump will be repaired or replaced.

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, u-m q TABLE A-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC-INSERVICE INSPECTION PROGRAM - (PUMPS)

EXCEPTIONS TO ASME XI REQUIREMENTS PAGE 7 of 10 4

JUSTIFICATION NOTES (Cont'd)

The two pump test is performed during normal plant operation and it is impractical to establish, reference

~

values because the Nuclear Services Closed Cooling Hater System (NS) is>a very large system-(52 component coolers) that is operated over a. range of flow rates.

By procedure (OP 1104-11) the NS;flowrate is varied to maintain the-water temperature >70*F but <95*F.

The lower limit is to prevent condensation on the NS piping and the upper limit is to prevent component cooler overheating.

River water temperature, and outside ambient temperature require the number of NS Heat Exchangers and component coolers to be throttled or varied..In addition, plant operations such as processing radwaste may require additional NS heat exchangers.

These operational conditions make it impractical to establish a reference value since the reference value must be established such that operational parameters are not upset.

In addition,.several sets of references valves may not cover all of the operating modes for the NS system.

Testing with several. sets of-reference values would be cumbersome.

Therefore,-the above testing will be conducted as an alternative; and technically, this testing is equivalent to the code requirements.

Single pump testing will be performed during each refueling outage using single pump reference values.

Note 11 The Reactor Building Cooling Water Pumps (RR-PIA /B) supply river water to the Reactor Building Emergency Cooling Colls.

These pumps will be tested during normal plant operation using a fixed resistance flow path that bypasses the cooling coils.

This test will not measure flow rate.

The testing during normal plant operation will not pump river water through the cooling coils because after the test, the cooling coils must be drained and then flushed with Nuclear Service Closed Cooling Water.

The drain and flush water is drained to the Reactor Building Sump and this produces large quantitles of water that must be processed through the Liquid Haste Disposal System.

However flow rate will be mersured during' refueling outages, when river water is pumped through the cooling coils in accordance with Technical Specification requirements.

Note 12 A.

CA-P1A/B For CA-PIA /B. GPUN requests relief from quarterly testing and the measurement of Q, Pg, AP,'and the five minute run time.

The following testing will be conducted:

1 I

7g TABLE'A-27 THREE MILE ~ ISLAND ' UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - (PUMPS)

LEXCEPTIONSJTO.ASME XI. REQUIREMENTS 1 PAGE 8 of:10 JUSTIFICATION. NOTES (Cont'd)'

1.) Testing CA-PIA /B will be conducted each refueling' interval'. "CA-PlA/B does not.have'a' recirculation flow path.

Without recirculation capability, the only method of testing these pumps is to inject into the Reactor Coolant Makeup System.

The resulting reactivity changes would affect plant operations adversely ~and would result.in significant. volumes of radioactive waste. 'During normal operation, testing one pump would generate 1,300 gallons of radwaste at the beginning of core life, 3,000 gallons at middle of core life and 32,000 gallons at end of~ core life. This much radwaste is.

generated becase injecting concentrated boric acid requires dilution of the RCS.

For these reasons it is impractical to test the subject pumps during operation.

The appropriate test. interval'is each refueling due to the large quantitles of liquid radwate. generated.

2.) Flow rate (Q) will be calculated using Makeup Tank. level change over time, since installed flow measuring instruments do not exist.

3.) Inlet pressure (Pg) is not available.

There are no existing pressure gage taps. Since AP.is not calculated as stated below, there is no benefit to calculating Pj based on suction tank level.

4.) For CA-PIA /B pump differential pressure (AP) will not~be calculated since CA-PIA /B are positive displacement pumps.

Relief is requested from the ASME Section XI, IHP-3110 requirement to calculate AP for CA-PIA /B.

The calculation of AP for CA-PIA /B would not be meaningful since the flow rate is fixed solely'by the displacement of the-cylinder and the speed of the pump, both of which are held constant, while AP is only a function of system resistance (backpressure).

Therefore, such a calibration would be an unnecessary exercise for the operator.

5.) ASME Section XI IWP-3500 states that pumps under test sbould be run for at least five minutes under conditions as stable as the system permits prior to taking data.

To minimize radioactive waste, the subject pumps will be run until the system has stabilized and then data will be recorded. GPUN believes this meets the intent of IHP-3500.

In conclusion, the test of CA-PIA /B each refueling verifies the required flowrate for CA-PIA /B while pumping to the Makeup Tank.

This demonstrates that CA-PIA /B can perform its safety function by providing the required boric acid capacity at normal Makeup Tank backpressures.

For this test, the Makeup Tank will be pressurized to its normal operating range.

Pump vibration will be measured while pumping to the Makeup Tank.

m

~ TABLE A-2.

1' THREE MILE ISLAND -. UNIT NO. 1; PERIODIC INSERVICE. INSPECTION PROGRAM - (PUMPS)

EXCEPTIONS TO ASME XI REQUIREMENTS PAGE 9 of.10-JUSTIFICATION NOTES (Cont'd)-

B.

HDL-P13A/B ASME Section XI, IWP-1100 states-that emergency powered pumps.should be. included in-the IST Program.

HDL-P13A/B are not emergency powered, but are included in the IST Program as requested by NRC.

The' addition of HDL-P13A/B in the program provides further assurance of the capability to supply concentrated boric acid to the Reactor Coolant Makeup System.

For HDL-Pl3A/B, GPUN requests relief from the measurement of Q, Pj, AP, and the'five minute run time.

Testing will be conducted each refueling interval for.the same radwaste concerns expressed above for CA-P-1A/B:

1.) Flow rate (Q) will be calculated using Makeup Tank level change over time, since installed flow measuring instruments do not exist.

This test will verify the accident design flowrate.

2.) Inlet pressure (Pj) is not available.

There are no existing pressure gage taps. Since AP is not calculated as stated below, there.is no benefit to calculating Pt based on suction tank level.

3.) HDL-P13A/B's discharge valve is a diaphragm operated valve that is either open or closed.

There is no handwheel on the valve.

Instead of throttling to a AP reference value, HDL-P13A/B will be tested unthrottled while pumping to the pressurized Makeup Tank.

Since HDL-P13A/B is tested while pumping to the pressurized Makeup Tank, pump AP is variable'(it increases over pumping time).

This makes it impractical to establish a AP reference value.

4.) ASME Section XI IHP-3500 states that pumps under test should be run for at least five minutes under conditions as stable as the system permits prior to taking data.

To minimize radioactive waste, the refueling test will be run until the system has stabilized and then data will be recorded.

GPUN believes this meets the intent of INP-3500.

In addition to the refueling interval tests, when WDL-P13A/B is required to be operable by Technical Specifications, the following tests will be performed on recirculation quarterly:

1.) Pt will be calculated using suction tank level.

2.) AP will be calculated.

. - ~

. TABLE A-2' THREE MILE ISLAND - UNIT NO. 1:

. PERIODIC INSERVICE-INSPECTION PROGRAM

.(PUMPS)

EXCEPTIONS TO ASME'XI REQUIREMENTS' PAGE 10 of 10

' JUSTIFICATION NOTES (Cont'd)--

Note 13 The pump and motor form an integral unit.

The pump bearings are located in the motor.

There is no lubrication level on the pump.that can be checked. Also yearly bearing temperatures'will not.be measured.

since the bearings are deep inside the motor end caps.

4 4

4 4

l l

i 4

g-J TABLE 8-

~

TTHREE MILE: ISLAND UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)-

Page 1 of 3 I

Scooe and Objectives This table describes-the Inservice Inspection Program.for all Class 1, 2, and 3 valves. The' objective'of-this program is to provide assurance of the operability of.these valves during.their. service life.

II.

Applicable ASME Code Edition and Addenda In accordance with 10 CFR 50.55a(g)(4)(11), the applicable Code Edition and Addenda are the 1980' Edition with-Addenda through Winter, 1980.

III.

Period of Applicability In accordance with 10 CFR 50.55a(g)(5)(iv), this program is applicable from September, 1984 to September, 1994.

IV.

Inspection Program The inspection program, which is detailed in Table B-1 will be carried out in accordance with ASME Section XI, 1980 Edition with Addenda through Winter, 1980.

Specific exceptions to the ASME Code Section XI requirements for each component are identified'in Table B-2 along with the basis for each exception requested.

In addition to tests indicated in Table B-1, all valves listed in Table B-1 with remote position indicators shall be observed at least once every two years to verify that valve operation is accurately indicated per ASME Section XI, IWV-3300.

V.

Limiting Stroke Time for Power Operated Valves Table B-3 provides a list of limiting values of full-stroke time for all the power operated valves in the IST Program.

Please be advised that this limiting str(ke time is subject to change. When limiting stroke times are changed, appropriate analysis per ASME Section XI, INV-3413 and 10 CFR 50.59 will be performed to demonstrate applicable Code and safety standard compliance.

s

-TABLE B 7

THREE MILE ISLAND' UNIT'NO. 1-PERIODIC. INSERVICE INSPECTION. PROGRAM -:(VALVES):

Page 2'ofe3 SYMBOLS Symbols which appear in the respective columns of Table B-l=are as follows:

CLASS The ISI system classification of the portion of.the system in which the valve is located.

CATEGORY

~

As defined in ASME Code,Section XI, 1980 Edition through 1980 Winter Addenda, Paragraph'INV-2200.

TYPE OF TEST T-Full stroke valve exercise and time measurement for power operated valves.

F-Full stroke functional check of valve operation.

P-Partial valve stroke exercise.

(Partial stroke times will not be measured).

L-Valve seat leak test.

SP - Set point test.

FS - Fall Safe test.

a-Leak test. These check valves are Wash-1400 Event V configuration valves.

The valves separate high and low pressure systems and they perform a pressure barrier function ~ insuring that the low pressure system is not l

subjected to pressures which exceed their design limits.

f 0-Disassembly and visual examination.

l FT - Functional test of valve operation I

TEST FREQUENCY l

l Q-Quarterly test frequency.

1 TABLE B'

'THREE MILE ISLAND UNIT NO.-1

" PERIODIC INSERVICE' INSPECTION PROGRAM - (VALVES)

Page 3'of.3.

SYMBOLS (Cont.)

C-Cold shutdown test frequency (when shutdown exceeds 48' hours and more than 92' days have elapsed since' test?

was performed during last previous shutdown period).

This testing will' continue until complete or.the plant q'

is ready to return to power. Completion of any' valve testing will'not be'a prerequisite to return to

~

power. Any testing not completed at one cold shutdown will be performed at; subsequent cold shutdowns.

(This is per a NRC staff position presented during a meeting on October 18, 1978).

C' - Cold shutdown test frequency.

C* is only applicable'to DH-V16 A/B.where either A or B valve is tested on a' cold shutdown frequency by the' normal operation of providing Decay Heat Removal flow rate of >3000 gpm.

In; addition, both A and B valves will be tested each refueling interval.

R-Refueling outage test frequency.

RC-Following a Refueling or a Cold Shutdown When Cold Shutdown exceeds 30 days.

SY - Tests of valves are distributed over a 5. year period per ASME Section XI, Table INV-3510-1.

9M - Prior to achieving hot shutdown following a cold shutdown of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> duration unless testing has been performed within the previous 9 months, and prior to achieving hot shutdown.after returning the valve to service following maintenance repair or replacement work.

10Y-Each 10 years (at or near the end of the 10 year 'SI interval).

NOTE:

Roman numerals in parenthesis found in Table B-1 refer to the Roman numerals in Table B-2 which correspond to specific requests for relief from ASME Section XI test requirements.

i 4

4

T t

t

.T. ',

i

-TABLE B-1:

-THREE MILE ISLAND UNIT.NO. 14.

m

~

' PERIODIC INSERVICE INSPECTION PROGRAM '-D(VALVES) -

.PAGE 1:of.38-l SYSTEM /

TYPE TEST'

~

'(ISI ORAWING NO.)

VALVE NO.

TYPE SIZE 0PERATOR CLASS ~

-CATEGORY OF TEST FREQUENCY :

~

i SYSTEM

.48" PNEU.

2

.A'

. L'/T(IX)/FS.

.R/Q/Q.

i v.

AIR HANDLING AH-VIA/D B' FLY.

H (ID-ISI-FD-023)

AH-V1B/C B' FLY-.

48" MOTOR'.

2' A;

L/T R/Q

AND A

(1D-ISI-FD-011)

AH-VilA/B CONTROL

~6" PNEU.

3-B

. T/FS-

..Q/Q--

i NOTE:

All valves listed in Table B-1 with remote indicators shall be observed at least once every two.

years to verify that valve operation is accurately indicated per ASME Section XI IWV-3300.

I i

l 1

1 i

I l

m.

~

2

< L*@h ',

~

LTABLEL8 %

of 4

g 3

' s

.THREE MILEilSLAND UNITJNO.41 s

.*s y

PERIODICiINSERVICELINSPECTIONLPROGRAM -:(VALVES)!

_d' 4

.PAGE 2 of 38-3

^ SYSTEM /:

TYPE' TEST-(ISI DRANING NO.)'

VALVE'NO.

TYPE

.. SIZE' OPERATOR

' CLASS CATEGORY ?OF'TESTi.,,

FREQUENCY-L CORE FLOOD

CF-V2A/B' GLOBE:

ti"-

. MOTOR:

2 3 J5

L/Ti

' 'R/Q -

SYSTEM h/P(VI)/D( b 9M(V)/C(4)/10Y:

f,

^

(ID-ISI-FD-004)

CF-V4A/B CHECK-114"s

'l.

?A/C 0 l

'A/C-h/P(XII)/D(2) 9M(V)/C(3)/10Y.

CF-VSA/B

'CHECKi 14" i

i CF-V12A/BiLCHECK 1"-

~,2 J A/C1 L/F:

fR/C(I) l l

CF-V19A/B GATE 1"

DIAPHRAGMi :2 '

~A,

.L/T/FS

,R/Q/QL CF-V20A/B GAT E --

1"-

DIAPHRAGM 2

A L/T/FS:

R/Q/Q i

Footnote:

(l) l In accordance with ASME Section XI INV-3522,'.CF-V12A/B.will be~ tested at each cold shutdown since j

testing CF-V12A/B involves changing the position of,other, valves (CF-V28A/B).that are listed in Operating Procedure Number 1101-3, " Containment Integrity and Access Limits".

In accordante with Operating procedure 1101-3, the position of CF-V28A/B may not:be' changed during normal' reactor operation.

(2)

CF-V4A/B and CF-VSA/B are the same size, manufacturer and catalog number. -CF-V4A, or CF-V48,or CF-VSA, or CF-V5B (1 of the four) will be disassembled each 10 years for'an inspection.. If-.

degradation which would make the valve's full. stoke capability questionable is found, then the' remaining three valves will be disassembled and inspected during that outage.

(3)

Check valve CF-VSA/B isolates the RCS from the low pressure Decay Heat Removal ~ System and the Core Flood Tanks, CF-TIA/B.

During normal plant operations, CF-VSA/B will not'be tested on a quarterly frequency because there is no method of opening.these valves. CF-VSA/B is on the discharge side of DH-PIA /B and CF-TIA/B.

DH-PlA/B only produce ~200 psig and CF-TIA/B are caly pressurized to 600225 psig.

Therefore, it is not possible to overcome normal RCS pressure (2155 psig) with DH-PIA /B or CF-TIA/B.

(4)

Check valve CF-V4A/B isolates the RCS from the CF-TIA/B, Core Flood Tanks.

During normal plant operation, CF-V4A/B will not be tested on a quarterly frequency because;there is no method of opening CF-V4A/B.

CF-V4A/B is on the discharge side of CF-TIA/B which is pressurized to 600225 psig.

Therefore, it is not possible to overcome normal RCS pressure (2155 psig) with CF-TIA/B.

3

.y:

' -yt 4

TABLE'B-1 N

1THREE MILE ISLAND UNIT NO..l.

~

J PERIODIC INSERVICE INSPECTION PROGRAM -L(VALVES) 1 m

~PAGE93 %f 38 A

y

-SYSTEM /

TYPES,.

.TtST f

(ISI DRANING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS-

' CATEGORY' -OF-TEST

_ FREQUENCY-2 :.

u CHEMICAL

'CA-V1 "Y" GLOBE 1"

MOTOR

.1

" A" L/T 4 TR/Q

~~q w4 SAMPLING f,

T Q yq {'

SYSTEM CA-V2 "Y" GLOBE ~

l" -PNEU.

1

-A

.- L/ T(IX) / FS -

LR/Q/Q '

o (10-ISI-FD-020)

~

-CA-V3 "Y" GLOBE-1" MOTOR 1 ~.

AL L/T.Y

.R/Q (ID-ISI-FD-021)

~'

3

.CA-V4A/B "Y" GLOBE.

1" MOTOR

. 2 A-1

'L/T' R/Q N

t CA-V5A/B "Y" GLOBE 1"

PNEU.

2

?

.A L/T(IX)/FS

.R/Q/Q1 A

CA-V13 GLOBE 1/2" MOTOR 1

A

,' t/T s

R/Q -

' :f,

CA-VI??

CHECK l'

3 C

F

'R(IV)

CA-V189 GATE 2"

PNEU.

2 A-L/T/FS R/Q/Q

~ [--(l)(XI)

R/-

CA-V192 CHECK 2"

2

'A/C1 '

L Footnote:

(1)

CA-V192 supplies demin. water purge to the RC pump No. 3 Seal..CA-Vl92 is not needed to maintain No. 3 seal integrity.

However, during normal plant operation, purge supply cannot be isolated without some risk to the reliability of the No. 3 seal; therefore, CA-V192 will not be tested for. closed function on a quarterly interval.

CA-Vl92's only safety function is to close to provide containment. isolation.

The containment isolation function of CA-Vl92 will be verified each refuell'ng by leak-testing in accor. dance with T.S. 4.4.1.2.1.b per Surveillance Procedure 1303-11.18.

I t

.. s

- a-

- :#g=j

. TABLE B-1.

A7 4

THREE-MILE ISLAND UNIT NO..)

PERIODIC INSERVICE INSPECTION; PROGRAM' -(VALVES)A.

~'

PAGE 4'of 38 e'- ;-

s.mp SYSTEM /:

TYPE-TEST

'(ISI DRAHING NO.)-

VALVE NO.

TYPE

SIZE OPERATOR ~

CLASS!

CATEGORY OF-TEST' FREQUENCY CHILLED WATER CH-V22A/B CHECK 4"

3 C

F Q-SYSTEM (10-ISI-FD-011) 9 O

7,

+q39 m; :>

f

-TABLELB-1

-THREE. MILE ISLAND: UNIT.NO.t.1-PERIODIC INSERVICE:-INSPECTION PROGRAM'-l-(VALVES):

PAGE-5 of-38 r

SYSTEM /

TYPE:

TEST -.

(ISI DRAWING NO.)

-VALVE NO. eTYPE' SIZE OPERATOR CLASS-

-CATEGORY OF TEST-FREQUENCY-CONDENSATE CO-V16A/B' CHECK 10" C.

. P/F Q/RC(II)

SYSTEM (lD-ISI-FD-009)

N i

7 s

+c l TABLE Bi '

- 79@

l e_

THREE MILE' ISLAND UNIT.NO.11.

. PERIODIC.INSERVICELINSPECTION. PROGRAM' f(VALVES)

.PAGE 6fof 38, SYSTEN/

TYPE TEST

~

(ISI DRANING NO.)

VALVE NO.

TYPE SIZE? OPERATOR CLASS-

' CATEGORY' 0F TEST-FREQUENCY CONTAINMENT CM-VI BALL' 1"

PNEU.

2-A-

L/T(IX)/FS' R/Q/Q MONITORING :

(ID-ISI-FD-023)

CM-V2 BALL

'1" PNEU.

2 AL L/T.(IX)/FS-

.R/Q/Q.

CM-V3 BALL 1"

.PNEU.

2 A-LIT (IX)/FS lR/Q/Q CM-V4

-BALL 1"

PNEU.

2 A

L/T(IX)/FS R/Q/Q O

a

~

~

m-i W '=

I NJ

-TABLE B-1.

J

+

THREE MILE: ISLAND-UNIT NO.;.1J.

+

PERIODIC ~ INSERVICE: INSPECTION. PROGRAM -;(VALVES)-

PAGE 7.of 38.-

s SYSTEM /.

(ISI DRAWING NO.)-

VALVE NO.

TYPE' SIZE OPERATOR

< TYPE TEST.

~ F-TEST JFREQUENCY' iCLASS-CATEGORY-O DECAY HEAT DH-V1 GATE-12" MOTOR

-l ~

'B T

C(2h REMOVAL SYSTEM DH-V2 GATE 12" MOTOR-1 B-J

C(2)

(lD-ISI-FD-005)

DH-V3 GATE-12" MOTOR

.2-

.B LT

-Q i

DH-V4A/B GATE 10"-

MOTOR 2

B T

Q DH-VSA/B GATE 14" MOTOR 2

B-T~

Q.

DH-V6A/B. GATE 14"

MOTOR 2

.8 T'

R(I)

DH-V7A/B GATE 4"

MOTOR 2

B T.

Q DH-V14A/B CHECK 14" 2

C

'P/P(XII)

.Q/R(III)'

DH-V16A/B CHECK 10" 2

C-P/F Q/C*(XIII)

DH-V22A/B CHECK 10" 1

A/C A/F 9M(V)/C(3)

DH-V38A/B GATE 6"

MANUAL 2

B

'F Q.

DH-V64 GLOBE 2"

MANUAL 2

A L/F

.R/Q DH-V69 STP-CK 1-1/2" MANUAL 2

A!C L/F R/C(l)

Note: Manual valves DH-V12A/B were included in the first revision of this submittal. They have b'een deleted because they are now passive locked valves.

During criticality DH-V12A is locked closed and DH-V12B is locked open for boron precipitation concerns.

No meaningful information would be obtained by exercising these manual valves that are already in their~ required safety related position (during criticality).

}

-h 1 TABLE 8-l'

'THREE-MILE ISLAND-UNIT NO. 12 t

PERIODIC' INSERVICE INSPECTION PROGRAM - (VALVES).

PAGE'8 of'38 i

. SYSTEM /

.. OPERATOR CLASS' CATEGORY-OF' TEST :

' FREQUENCY.

(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE:

. TYPE.

TEST Footnotes:

(I)

During normal plant operation, locked open manual stop check valve'DH-V69 will not be tested'for disk opening function on a quarterly frequency because there is no method of opening the' disk. DH-V69 is on the dischargeL side of DH-PIA /B.

DH-PI A/B only produce - 200 psig; therefore, it is not possible' to overcome normal RCS-pressure (2155 psig) with DH-PIA /B.

In. addition,' DH-V69 is locked open for its safety function ~ (long-ters :

n core circulation-to prevent boron concentration).

Therefore, it is passive and a quarterly functional test ~

will not be performed.

(2)

DH-V1 and DH-V2 are the two high pressure valves in the Decay Heat drop line.(suction lineLto LPI' pumps).

During normal plant operation, these valves cannot be cycled because this would reduce redundancy by:

providing only one high pressure valve between the RCS and the low pressure Decay Heat Removal System.

In addition, DH-V1 and 2 are interlocked with RCS. pressure such that they cannot be opened unless'RCS pressure is <400 psig.

This Engineered Safeguard Feature interlock is verified during ESAS testing-in accordance with T.S. Table 3.5-1, item C.2.c.

Therefore, per ASME Section XI'IHV 3412, these valves will be tested on a cold shutdown frequency.

(3)

During normal plant operations check valve DH-V22A/B will not be tested on a quarterly frequency because there is no method of opening DH-V22A/B.

DH-V22A/B are on the discharge side of DH-PIA /B.

DH-PIA /B only produce ~200 psig; therefore, it is not possible to overcome normal RCS pressure (2155 psig) with DH-PIA /B.

i 4

4 i

i i

L

d TABLE = B-l '-
THREE MILE ISLAND UNIT NO.-1

. PERIODIC' INSERVICE'! INSPECTION: PROGRAM.-(VALVES)-

d SYSTEM /

TYPE

. TEST-(ISI DRANING NO.)

VALVE NO. -TYPE

' SIZE ~ OPERATOR CLASS CATEGORY

'0F TEST =

' FREQUENCY DECAY HEAT DR-VIA/B B' FLY 20" MOTOR.

3-B T:

.Q.

RIVER HATER SYSTEM DR-V7A/B CHECK-2" 3

C F

Q' (1D-ISI-FD-002)

DR-V21A/B CHECK 1"-

3 1C

'F Q-(1D-ISI-FD-014)

DR-V22A/B CHECK 1"

3 C

F.

Q.

DR-V26A/B CHECK.

2" 3

C' F

.Q DR-V37A/B CHECK 3/8" --

3

C F

'Q-

n v,

g,e my 1ABLE B-l'

[,

j

THREE MILE
ISLAND UNIT NO,1 1;

.a.-

3 t"

PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 10 of'38 SYSTEM /

TYPE

. TEST (ISI DRANING NO.)

VALVE NO.

TYPE' SIZE 10PERATOR

-CLASS CATEGORY OF TEST-FREQUENCY EMERG. FEED EF-V3(I)

HATER SYSTEM i

(ID-ISI-FD-009)

EF-V4 GATE 6"-

MOTOR-3

'B T

R(I)

(ID-ISI-FD-010)

EF-V5 GATE 6"-

MOTOR 3

B T

R(I)

EF-VilA/B CHECV-4"

'3.

C F

'RC{2)(gy)

EF-V12A/B CHECK 6"

2 C

F RC(II)

EF-V13 CHECK 6"

3 C

P/F Q/RC(II)

EF-Vl9A/B CHECK-1-1/2"-----

3 C

F Q

EF-V21 CHECK 2"

3

.C F

Q EF-V30A-C(3) CONTROL 3"

PNEU.

3 B

T/FS

.Q/Q Footnote:

(I)

The internals of EF-V3 have been removed by DRF 039002 during the Eddy Current Outage in March 1986.

Therefore, EF-V3 has been deleted from +he IST Program.

(2)

EF-VilA/B are the discharge check valves on EF-P2A/B.

EF-P2A/B is tested on recirculation with the OTSGs isolated from EF-P2A/B by EF-V10A/B.

The recirculation line is upstream of EF-VilA/B; therefore, there is no flow through EF-VilA/B.

It is not possible to initiate flow through EF-VilA/B on a quarterly frequency due tc the limited number of thermal cycles allowed (40) for the Auxiliary Feedwater Nozzles.

(3)

TMI-l is adding redundant EF-V30 control valves.

Therefore, EF-V30C and D are being added to the IST program upon their placement into service.

J

- + i +ii

! TABLE B-1:

THREE-MILE ISLAND' UNIT NO.' l PERIODIC INSERVICE. INSPECTION PROGRAM (VALVES)'

PAGE 11 of 381

..Q-

.1

. SYSTEM /

TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR ' CLASS

-CATEGORY.. OF TEST FREQUENCY EMERGENCY EG-V31A/B(3). CONTROL S"

3 C-F/D

-Q/10Yf

~

DIESEL GENERATOR EG-V32A/A, CHECK 4"

3 C

F/D(I)'

Q/10Y A/B(2)B/A, COOLANT B/B SYSTEM EG-V34A/B CHECK S"

3 C

F/D(I)

Q/10Y EG-V47A/B(3) CONTROL 4"

3 C

F/D Q/10Y EG-V48A/B CHECK 4"

3 C

F/D(I)

Q/10Y EMERGENCY DIESEL EG-V16A/A, GATE l-1/2" SOLENOID 3 S

T(IX)

Q GENERATOR SERVICES B/A, A/B, B/B (ID-ISI-FD-006)

(DRAFT)

Footnotes:

(I)

These valves will be disassembled each 10 years per I.E.Bulletin 83-03.

(2)

EG-V32A/A, A/B, B/A and B/B are located downstream of the Diesel Generator Jacket Coolant Radiator.

These valves must o;;en to allow coolant to be pumped out of-the two S07.' capacity each radiators. Their function is verified open during the monthly performance of SP 1303-4.16 which verifies acceptable engine coolant temperatures.

If one of the two check valves did not open, acceptable engine coolant temperatures would not be obtained.

SP 1303-4.16 verifles acceptable engine coolant temperatures and that the diesels are capable-of providing their design rating of 3 1 0.1 MW for one hour.

9

TABLE B-1.

THREE: MILE ISLAND UNIT NO..I-PERIODIC' INSERVICE' INSPECTION PROGRAM - (VALVES)

PAGE 12iof 38' Footnotes (Cont'd):

(3)

EG-V31A/B and EG-V47A/B are self-contained thermostatic valves that use an expanding wax type of temperature sensing element.

There are no external actuators or-operators.

These valves are siellar to the thermostat in an automobile.

EG-V31A/B are.4". valves and have four internal elements that: start to open at 100*F and:

are full open at 115'F.

EG-V47A/B are 5" valves and have six internal elements that start to open at 155*F and are full open at 170*F.

EG-V31A/B and EG-V47A/B are categorized C per ASME Section.XI, INV-2200 since the valves "are self-actuating in response to some system characteristic, such as. pressure...".

For EF-V31A/B and V47A/B, the system characteristic is temperature.

EG-V31A/B cpen to allow cooling water from the diesel generator intercooler to be diverted to the engine radiator and EG-V47A/B open to allow cooling:

water from the diesel generator's jacket to be diverted to the engine radiator..The operability of these valves is verified in the monthly performance of SP 1303-4.16 since acceptable intercooler air receiver temperature and acceptable jacket water temperature is verified.

SP 1303-4.16 verifles design load of 3.0 1 0.1 MW for a minimum of one hour.

In addition, EG-V31A/B and 47A/B will be disassembled / inspected on a 10 year interval. During-the 10 year disassembly / inspection the temperature elements will be replaced or the elements will be verified to open and close at the correct temperatures.

i i

i I

i a

1 1

g- +

my: 3 7

TABLE B-1

~

THREE MILE ISLAND UNIT NO. 1-

PERIODIC.INSERVICEfiNSPECTION. PROGRAM

.(VALVES)'-

~ '

,PAGE-13 of 38 SYSTEM /

. TYPE TEST.

(ISI DRAWING NO.)~

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY

+

\\'

FLUID BLOCK (ID-ISI-FD-015)

Note:

Technichl Specification Amendment No. 93,-issued May 18, 1984,' d'eletes the Fluid Block Valves'from Appendix J leak rate-testing requirements. 'GPUN has disabled the-Fluid Block System to the. gate type CIVs by positive means. Therefore,;.the Fluid Block Check Valves have been deleted,from-the.

IST Program.

I

'l i

s I

e

't I

e i

H 3-

=--,=:-

e'9pgj

.a t

.TA8LE.B-1

- THREE MILE ISLAND UN;T NO. 1-N PERIODIC' INSERVICE INSPECTION PROGRAM

.(VALVES) c.....

g

.. PAGE~-14 of'38-SYSTEM /

. TYPE

. TEST =

(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE ' OPERATOR

' CLASS CATEGORY i 0F TEST FREQUENCY ~

FEEDWATER FN-V12A/B CHECK 20" 2

C F-R(I)(III)

'l SYSTEM (1D-ISI-FD-009)

Footnote:

(I) During plant operation these valves are always open supplying feedwater to'the OTSGs.

Therefore it is not possible to part-stroke or full-stroke these valves closed during plant operation.

5

==---. ym I

.TA8LE B-11

.THREE MILE ISLAND UNIT NO -1 PERIODIC INSERVICE INSPECTION PROGRAM.- (VALVES)

V

- PAGE 15 of 38' SYSTEM /

TYPE-TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE-OPERATOR CLASS CATEGORY OF TEST-

- FREQUENCY =

HYDROGEN HM-VIA/B GLOBE l/2" SOLENOID 2

A:

L/T(IX)/FS

R/Q/Q MONITORING SYSTEM HM-V?A/B GLOBE 1/2" SOLENOID 2

A-L/T(IX)/FS R/Q/Q (ID-ISI-FD-023) s.

HM-V3A/B GLOBE 1/2" SOLEN 0ID 2

A L/T(IX)/FS-R/Q/Q HM-V4A/B GLOBE-1/2" -SOLENOID 2

A L/T(IX)/FS-R/Q/Q O

,=

=-

.n n gy ; 9 c

-TABLE:8-1 '

- m e-

.THREE MILE' ISLAND UNIT NO,--1: 1 a :,

PERIODIC INSERVICE INSPE/. TION PROGRAM - (VALVES) '

(PAGE 16 of 38

~-

SYSTEM /

. TYPE TEST-(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS-CATEGORY OF. TEST-FREQUENCY-HYDROGEN HP-V1 GATE 6"

MANUAL.

'2

'A L/-(I)

'R/ '

PURGE i

(ID-ISI-FD-023)

HP-V6 GATE 6"

MANUAL-

'2; A'

-L/ Cl)

.R/ -

i i

Footnote:

i (I)

Amendment No. 108 to TMI-l's Technical Specifications-has approved the use of the Hydrogen Recombiner System; therefore, these valves no longer by design will be used to purge. hydrogen from l

the Reactor Building.

The quarterly functional test has been discontinued for these passive valves.

The only safety function of HP-VI and HP-V6 is to remain closed and act as a Containment Isolation Valve (CIV).

1

~o

)

I i

1 l

i i

't i

_y y -- cg TABLE B-1~

THREE MILE ISLAND l UNIT NO. 1.

PERIODIC. INSERVICE' INSPECTION PROGRAM - (VALVES)

+ - -

PAGE 17 of.38--

SYSTEM /

TYPE.

TEST-(ISI DRAWING NO.)

VALVE NO.

TYPE-SIZE OPERATOR CLASS:

CATEGORY: OF TESTA FREQUENCY--

HYDROGEN HR-V2A/B GLOBE 2"

MANUAL' 2

A.

L/F

-R/Q' RECOMBINER o

SYSTEM HR-V4A/B GLOBE-2" MANUAL-2

.A L/F R/Q (ID-ISI-FD-015)

HR-V22A/B GATE' 2"

SOLEN 0ID 2

A L/T(IX)/FS~

.R/Q/Q i

HR-V23A/B GATE-2" SOLEN 0ID 2

.A L/T(IX)/FS' R/Q/Q.

I 1

l e

w__

TABLE B-1 THREE MILE ISLAND UNIT-NO, 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)-

PAGE.18'of 38' SYSTEH/

TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY INSTRUMENT IA-V6 GLOBE 2"

HANUAL 2

A L/-(I)

R/--

AIR SYSTEM (ID-ISI-FD-023)

IA-V20 GLOBE 2"

HANUAL 2

A L/-(l)

R/-

STATION SERV.

SA-V2 GLOBE 2"

HANUAL 2

A L/-(l)

R/-

AIR SYSTEM (ID-ISI-FD-023)

SA-V3 GLOBE 2"

HANUAL 2

A L/-(I)

R/-

Footnote:

(I)

This CIV is passive (a closed valve whose function is tog omain closed).

Therefore, this valve is r

exempted from the quarterly functional stroke requirement of IWV-3412 per NRC staff guidelines since no meaningful information would be gained.

_w +

=,..

m.

y TABLE B-1.

s THREE! MILE ISLAND' UNIT NO.L1 I

PERIODIC INSERVICE INSPECTION: PROGRAM - (VALVES)-

PAGE!l9'of.38$

SYSTEM /

. TYPE-

. TEST (ISI DRAWING NO.)

VALVE NO. -TYPE SIZE OPERATOR CLASS CATEGORY :0F TEST ~

FREQUENCY INTERMEDIATE IC-VIA/B(2) GATE 4"

. MOTOR

-3

'B-

-T

C(l)'

COOLING SYSTEM IC-V2 GATE 6"

MOTOR 3;

'A-L/P/T R/Q/Cf3)

(ID-ISI-FD-022)

IC-V4 GATE 6"

PNEU.

2 A

L/P/T/FS R/Q/C(3)/C IC-V6 GATE' 3"

PNEU.

2.

A L/P/T/FS

'R/Q/C(3)/C IC-V16 CHECK 3"

2 A/C'

'L/F R/R(III)

IC-Vl8 CHECK 6"

2 A/C L/F R/R(III)

Footnotes 1 i

(I)

IC-VIA/B supplies cooling water to the Primary System Letdown Coolers.

In accordance-with B&W guidance and the failure history of the Letdown Coolers it is not advisable to thermal cycle the Letdown Coolers by 1

isolating cooling water to an operating Letdown Cooler. Thermal cycles increase thermal stress which increases the potential for tube leakage.

Therefore, per ASME Section IWV-3412, IC-VIA/B will be tested at cold shutdown frequency.

(2)

These non-safety related valves do not provide an essential safety function and are not safety related.

However, IC-VIA or 8 may be used during certain abnormal conditions to place a second letdown cooler in-service to maximize letdown flowrate.

(3)

These valves are in the supply or return lines to the Primary Letdown Coolers, Control Rod Drive Cooling Coils, Reactor Coolant Pump Heat Exchangers and/or R.C. Drain Tank Heat Exchanger.

It is not possible to stop flow in these lines to test these valves without upsetting the reactor plant.

Therefore, in accordance with ASME Section XI, IWV-3412, these valves will be tested on a cold shutdown frequency.

l 4

o

^ "q7P'"""*#4%

~ ~

7 0

7<

u; -

y y

e y

.,[,

.e 2 TA8LE B-1

.THREE MILE,: ISLAND UNIT NO. l

' PERIODIC INSERVICE INSPECTION PROGRAM

=(VALVES)

'^^ "

SYSTEM /

> TYPE.

TEST.

(ISI DRAWING NO.)

VALVE NO.

TYPE:

SIZE OPERATOR:

CLASS ~

CATEGORY' 0F TEST

-FREQUENCY" i

LEAK RATE LR-Vl il) -

GATE ~

6" MANUAL

-2 A-L/-

DR/-

-n TEST SYSTEM (ID-ISI-FD-015)

LR-V4 GLOBE-3/4" MANUAL 2

A-L/_(2)

- R/--

LR-V5 GLOBE 2"

MANUAL' 2

A..

L/-(2)i R/-:

LR-V6

GLOBE

'2" MANUAL 2

A

~L!-(2) gf_ :

LR-V10 GLOBE 1"

MANUAL

2' A-L/-(2) ~

R/-<

LR-V49(l) GATE 6"

MANUAL 2

A L/-

R/-

l 1

Footnotes:

(I)

Technical Specification Amendment No. 108 has approved the use of the Hydrogen Recombiner System; therefore, l

these valves no longer.by design will be used to supply air for hydrogon purging after an accident.

l Therefore, the quarterly functional test has been discontinued for these passive valves.

The only safety-1 function of LR-VI and LR-V49 is to remain closed and act as CIVs.

a l

(2)

This CIV is passive (a closed valve.whose function is to remain closed).

Therefore, this valve is exempted j

from the quarterly functional stroke requirement of IWV-3412 per NRC staff guidelines since no meaningful information would be gained.

4 J

I 4

l

TABLE B-1 THREE MILE ISLAND UNIT NO, 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 21 of 38 SYSTEH/

-TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY MAIN STEAM MS-VIA-D STOP-CK 24" MOTOR 2

B/C P(4)/T Q/C SYSTEM (lD-ISI-FD-001)

MS-V2A/B GATE 12" MOTOR 2

B T

C(l)

MS-V4A/B CONTROL 6"

PNEU.

3 B

T/FS Q/Q MS-V6 CONTROL 4"

DIAPHRAGM 3

8 P(XIV)/FS Q/Q MS-V8A/B GATE 12" MOTOR 3

B T

C(3)

MS-V94/B CHECK 6"

3 C

P(VI)/D Q/10Y MS-V10A/B GATE 6"

MOTOR 3

B T

C(2)

MS-V13A/B GLOBE 2"

DIAPHRAGM 3

B T/FS Q/Q MS-V17A-D RELIEF 6"x10"-----

2 C

SP SY MS-V18A-D RELIEF 6"x10"-----

2 C

SP SY MS-VISA-D RELIEF 6"x10"-----

2 C

SP SY MS-V20A-D RELIEF 6"x10"-----

2 C

SP SY MS-V21A/B RELIEF 3"x6" -----

2 C

SP SY Footnotes:

(l)

MS-V2A/B isolate the six turbine bypass valves. MS-V2A isolates three turbine bypass valves and likewise MS-V2B isolates the remaining three turbine bypass valves.

Technical Specification 3.4.1.c requires four of the six turbine bypass valves to be operable.

If MS-V2A/B stuck closed during a quarterly test, this would limit the ability of the plant to cooldown.

Normal cooldown decay heat removal is by the steam generator then to the condenser.

Therefore, per ASME Section XI throughMS-V2A/Btotheturbinebypassvalvesan(hutdownfrequency.

IWV-3412, these valves will be tested on a cold s I

.g TABLE B THREE MILE ISLAND UNIT'NO. 1 '

-PERIODIC-INSERVICE INSPECTION PROGRAM-- (VALVES).

PAGE-22 of'38 SYSTEMi

. TYPE.

TEST i

(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF-TEST FREQUENCY (2)

MS-V13A/B is a 2" valve in parallel with MS-V10A/B, which is a 6" valve. Upon loss of both Main Feedwater.-

Pumps or upon loss of all four RC pumps, MS-V13A/B opens to supply steam from the OTSGs to the Turbine Driven Emergency Feedwater Pump (EF-P1). Then at approximately 300 psig steam pressure, MS-V10A/B is jogged open to maintain steam pressure to EF-Pl.

To preclude the possibility of challenging the safety relief. valves for EF-Pl's turbine (MS-V22A/B), M3-V10A/B.will only be tested at cold shutdowns, in accordance with ASME Section:

XI IWV-3412.

(3)

Technical Specification 3.4.1.c requires four of the six turbine bypass valves operable.when RCS temperature' is >250*F.

MS-V8A or B isolate: three of the turbine bypass valves. Cycling MS-V8A.or B during normal plant operation would violate T.S. 3.4.1.c; therefore, MS-V8A/B will be stroke timed on a cold shutdown. frequency.

(4)

Full-stroke testing during power operation is not practical because of the potential for possible turbine pressure instabilities downstream of the valves and possible unnecessary challenges to safety valves upstream of the MS-Vis. Also, Abnormal Procedure 1203-42 requires the reactor to be tripped if MS-VIA/B/C or D completely close during power operation in order to prevent damage to the OTSG that was not isolated.

o z.

TABLE-B-1 THREE-MILE ISLAND UNIT'NO., 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 23 of.38 SYSTEM /

TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY MAKEUP MU-VIA/B(4) GATE 2-1/2" MOTOR 1

B T

C(I)

SYSTEM (ID-ISI-FD-016)

MU-V2A/B GLOBE 2-1/2" MOTOR 1

A L/P(5)/T R/Q/C (ID-ISI-FD-017)

MU-V3 GATE 2-1/2" PNEU.

2 A

L/P(5)/T(IX)/FS R/Q/C/C MU-V10 GATE 2-1/2" PNEU.

3 B

T Q

MU-V12 GATE 4"

MOTOR 2

B T

C(2)

MU-V14A/B STOP-CK 6" MOTOR 2

B/C T/F Q/R(III)

MU-V16A-D GLOBE 2-1/2" MOTOR 2

B T

Q MU-V18 GATE 2-1/2" PNEU.

2 A

L/T(IX)/FS R/C(3)/C MU-V20 GATE 4"

PNEU.

2 A

L/T/FS R/C(2)/C MU-V25 GLOBE 4"

MOTOR 2

A L/P(6)/T R/0/C MU-V26 GATE 4"

PNEU.

2 A

L/P(6)/T/FS R/Q/C/C MU-V36 GATE 2"

MOTOR 2

B T

Q MU-V37 GATE 2"

MOTOR 3

B T

Q MU-V47 STOP-CK 4" 2

C F

Q MU-V51 DIAPH.

1" PNEU.

3 B

T(IX)/FS Q/Q MU-V73A-C CHECK 3"

2 C

P(7)/F Q/R(III)

MU-V86A/B

' CHECK 2-1/2" -----

1 C

F R(8)(III)

MU-V94 CHECK 2-1/2" -----

1 C

P(10)/F Q/R(III)

MU-V95 CHECK 2-1/2" -----

1 C

F R(8)(III)

=

gp _. _ 3 y

' TABLE-8-1:

.THREE MILE : ISLAND UNIT.NO.1:

PERIODIC INSERVICE' INSPECTION ~ PROGRAM - (VALVES)'

PAGE 24.ofc38 SYSTEM /

TYPE

. TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY-OF TEST' FREQUENCY-MU-V107A-D CHECK ~ 1/2" 1

C F~

/R(8)(III)

MU-V116

-CHECK 1/2" 1

.A/C L/F R/R(XIF MU-V217(9)

GLOBf

'2-1/2" MOTOR

'2 B

P/T

-Q/C MU-V219 CHECK 2-1/2" -----

1 C

F Q-MU-V220 CHECK 2-1/2" 1-

.C F-R(8)(III)l Footnotes:

(I)

MU-VIA/B is the upstream valve at the Primary Letdown Cooler. ~In.accordance with B&W guidance and'the failu're history of the Letdown Coolers it is not advisable to thermal cycle the Letdown Coolers by closing MU-VIA/B.

Thermal cycles increase thermal stress which increases the potential for tube leakage.

Therefore, in accordance with ASME Section XI IHV-3412, these valves will be tested on a cold shutdown frequency.

(2)

MU-V12 1solates the Makeup Tank from the suction of the Makeup Pumps. Part-stroking this' valve during normal plant operation would jeopardize the continued operation of the running Makeup Pump if this valve completely closed due to valve operator malfunction.

Likewise, part-stroking MU-V20 would' jeopardize the' continued operation of the Reactor Coolant Pumps, since this valve supplies seal injection water to-the Reactor Coolant Pumps.

Therefore, in accordance with ASME Section XI INV-3412, these valves will be tested on a cold shutdown frequency.

(3)

MU-V18 is in the normal makeup supply leg to.the Reactor Coolant System.

During normal plant operation, MU-V18 cannot be closed due to the limited number of allowable thermal cycles (40) on'the high pressure injection nozzles.

Therefore, in accordance with ASME Section XI, IHV-3412, MU-V18 will.be tested on a cold shutdown frequency.

(4)

HU-VIA/B are in the Primary Letdown piping to the Letdown Coolers.

Normally one coole'r is inservice.

These non-safety related valves do not provide an essential safety function. MU-VIA/B may be used during certain abnormal conditions to place a second Letdown Cooler in service to maximize letdown flow.

1-y 4

TABLE B-1 THREE MILE ISLAND UNIT NO.El' PERIODIC INSERVICE ' INSPECTION PROGRAM

-(VALVES) '

PAGE 25 off38 SYSTEM /

TYPE-

. TEST.

(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY-(5)

MU-V2A/B and MU-V3 are part-stroked each quarter per ASME Section_XI, INV-3412(a) requirements. IA. full-strokel test is not required because it is impractical to isolate Letdown.during power operation as thisimay preclude ^

timely restoration of letdown flow.

If letdown flow is totally isolated,_the Reactor Coolant' System loses-its normal means of purification and. compensation for volume addition due'to design-RC Pump Seal Injectina in-leakage and may lead to reactor shutdown. Also thermal cycle considerations on~the Letdown Coolers do:notf allow full closure of MU-V2A/B or MU-V3 during normal plant operation.

(6)

MU-V25 and MU-V26 are in the RC Pump Seal Return'line and are part-stroked each quarter.

Isolation'of tiie RCL Pump Seal Return Line at power risks permanent damage to the RC Pump Seals and Reactor Coolant System leakage, and may result in reactor shutdown.

(7)

MU-V73A/B/C are the discharge check valves on MU-PlA/B/C. During normal operation,10-PI A or B or' C supplies ;

normal makeup to the RCS, RC Pump seal injection, and recirculation flow.

The total of these flow rates is much less than accident design flow rate and this is considered a partial stroke test of MU-V73A/B/C.

No other testing method is practical during normal plant operation, because of thermal shock to the injection nozzles.

(8)

Consideration of thermal shock to the injection nozzles prohibits testing these valves each quarter since the piping configuration provides no other-flow path except pumping through these check valves to the injection nozzles.

(9)

HU-V217 is non-safety related and has no essential safety function.

However, it provides high makeup flow by manual actuation from the Control Room in the event of a reactor trip or other abnormal transient, thereby avoiding unnecessary challenges to the HPI system.

(10)

MU-V94 cannot be full-stroke exercised each quarter because this would be disruptive to normal plant operation and creates the potential for an unsafe pressure transient during power operation.

Normal RCS makeup through-MU-V94 is ~40 gpm.

Increasing this to accident design flowrate may create an overpressure transient and challenge the RPS high pressure trip setpoint or the PORV.

In addition, if MU-V94 were to be tested each quarter, an additional Letdown Cooler would be placed into service and this would cause a thermal cycle on the cooler.

Therefore, in accordance with ASME Section XI INV-3412, HU-V94 will be part-stroked each quarter.

.my=g: x y

~-TA8tE = B-1 3

'THREE MILE ISLAND UNIT NO. 1 a

-PERIODIC' INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 26.of 38.'

SYSTEM /

TYPE TEST-(ISI DRANING NO.)

VALVE NO. ' TYPE SIZE OPERATOR

' CLASS-CATEGORY OF TEST FREQUENCY-NITROGEN NI-V26 GLOBE-1" MANUAL 2

A

' L/-( l ) --

R/-

SUPPLY (ID-ISI-FD-023)

NI-V27 GLOBE 1"

MANUAL 2

A

-L/-(l)'

R/-

Footnote:

(I)

This CIV is passive (a closed valve whose function is to remain closed).

Therefore.'this valve is exempted from the quarterly functional stroke requirement of INV-3412 per NRC staff guidelines since no meaningful information would be gained.

TABLE B-1 THREE MILE ISLAND UNIT NO 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 27 of 38 SYSTEM /

TYPE TEST (ISI DRANING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY NUCLEAR NR-VIA-C B' FLY 16" MOTOR 3

B T

Q SERVICE RIVER WATER NR-V4A/B B' FLY 30" MOTOR 3

8 T.

Q SYSTEM (ID-ISI-FD-002)

NR-V20A-C CHECK 16" 3

C F

Q (lD-ISI FD-014)

NR-V22A-C CHECK 2"

3 C

F Q

NR-V44A-C CHECK 2"

3 C

F Q

NR-V4SA-C BALL 2"

PNEU.

3 B

T(IX)/FS Q/Q NR-V47A-C CHECK I"

3 C

F Q

NR-V48A-C CHECK 1"

3 C

F Q

NR-V66A-C CHECK 3/8" -----

3 C

F Q

5

,3;.

_m

" i'

~ TABLE 8-1 x

THREE MILE' ISLAND UNIT NO.~.1'

. PERIODIC INSERVICE INSPECTION = PROGRAM - (VALVES)'

PAGE 28 of'38 SYSTEM /

TYPE

.. TEST.

(ISI DRAWING NO.)

VALVE NO.

TYPE-SIZE OPERATOR-CLASS' CATEGORY:

OF' TEST

' FREQUENCY' 4

NUCLEAR SERV.

NS-V4-GATE-8" MOTOR 2

A L/P(2)/T R/Q/C CLOSED COOLING NS-V10A-C CHECK 12" 3

~C

~F' Q.

(ID-ISI-FD-010)

NS-V11 CHECK 8"

2 A/C L/F R/R(XI)

NS-V1S GATE 8"

MOTOR 2-A-

L/P(2)/T R/Q/C NS-V35 GATE 8"

MOTOR 3

A L/P(2)/T R/Q/C' NS-V52A/8/C GATE 1"

PISTON 2

B T(IX)/FS

'C(l)/C NS-V53A/B/C GATE 1"

PISTON 2

B T(IX)/FS

'C(I)/C NS-V54A/B CONTROL I-1/2" DIAPH 3

B T/FS Q/Q NS-V55A/B CONTROL 3"

DIAPH 3

8 T/FS Q/Q NS-V56A/B CONTROL 2"

DIAPH 3

8 T/FS Q/Q NS-V108A/B CONTROL 6"

DIAPH 3

B T/FS Q/Q Footnotes:

(I)

During normal plant operation, all three Reactor Building Coolers are inservice with NS-V52A/B/C and NS-V53A/B/C open supplying cooling water to Reactor Building Fan Motor Coolers.

If for testing purposes these valves were closed and in the unlikely event that they were not able to be reopened, this would jeopardize the continued cooling of the Reactor Building atmosphere since the fan motor would trip on high temperature.

Therefore, in accordance with ASME Section XI IHV-3412 and NRC letter to Met-Ed dated November 17, 1976, Enclosure 2, paragraph 1, these valves will be tested on a cold shutdown frequency.

(2)

NS-V4, V15, and V35 supply or return cooling water for the RC Pump Motor Coolers.

If, for testing purposes, these valves were closed and they were not able to be reopened, this would shortly require de-energizing all four Reactor Coolant Pump Motors.

Therefore, in accordance with ASME Section XI, IHV-3412 and NRC Ictter to Met-Ed dated November 17, 1976, Enclosure 2, Paragraph 1, these valves will be full stroke tested on a cold shutdown frequency and part-stroked each quarter.

,~

,y

-TABLE B-1 ~

, U[

}

-THREE MILE ISLAND UNIT NO. 1 y PERIODIC INSERVICE. INSPECTION PROGRAM (VALVES)'

~

.PAGE 29'of.38-M SYSTEM /

-TYPE TEST-(ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR-CLASS CATEGORY OF TEST-FREQUENCY PENETRATION PP-V100 DIAPH.

1" DIAPH.

2

8 T/FS Q/Q i

PRESSURIZA-TION SYSTEM PP-V101 CHECK 1"

2 C

F

'Q (ID-ISI-FD-015) 9 PP-V102 CHECK 1"

==

2 C

F Q:

PP-V103~

DIAPH.

2" DIAPH.

2 B

T/FS Q/Q.

PP-V132 DIAPH.

2" DIAPH.

2

-B T/FS Q/Q j

PP-V133 CHECK 2"

2 C

F Q.

PP-V134 CHECK 2"

2 C

'F Q

'd,

~~

g PP-V135 DIAPH.

1" DIAPH.

2 B

T/FS Q/Q I'

1

~

O i

2

TABLE B-1

-THREE MILE ISLAND UNIT NO. I PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 30 of 38 SYSTEM /

TYPE TEST (ISI DRAHING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS' CATEGORY OF TEST FREQUENCY REACTOR BLDG.

RR-VIA/B B' FLY 16" MOTOR 3

B T

Q EMERGENCY COOLING RR-V3A/B/C GATE 12" MOTOR 2

B T

Q SYSTEM (1D-ISI-FD-002)

RR-V4A-D GATE 12" MOTOR 2

B T

Q (10-ISI-FD-010)

RR-V5 B' FLY 10" MOTOR 3

B T

Q (10-ISI-FD-014)

RR-V6 CONTROL 10" DIAPH 3

8 T/FS Q/Q VALVE RR-V7A/B CHECK 16" 3

C F

Q RR-V8A/B CHECK 20" 3

C F

R(III)

RR-V9A/B/C CHECK 12" 3

C F

R(III)

RR-V10A/B PLUG 2"

DIAPH 3

B T/FS Q/Q RR-V12A/B CHECK 2"

3 C

F Q

RR-V20A/B CHECK 1"

3 C

F Q

RR-V21A/B CHECK 1"

3 C

F Q

RR-V29A/B CHECK 2"

3 C

F Q

RR-V39A/B CHECK 3/8" 3

C F

Q p

IBM D

=
p TABLE B-1

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-THREE MILE ISLAND UNIT NO. 1-PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 31 of 38 SYSTEM /

TYPE-

TEST, (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY ~ OF TEST-FREQUENCY-REACTOR BLDG.

RB-V7 GATE 8"

MOTOR

-2 A

L/P(l)/T.

' R/Q/C; NORMAL COOLING SYSTEM RB-V2A GATE 8"

MOTOR 2

A L/P(I)/T-R/Q/Ci (ID-ISI-FD-010)

(I)

RB-V7 and 2A are part-stroked each quarter.

They are not full stroke tested because this would isolate normal cooling water to the Reactor Building atmospheric cooling coils.

If in the unlikely event RB-V7 or 2A are not reopened, this could quickly lead to violation of Reactor Building air.

temperature Limiting Condition for Operation (Tech. Spec. 3.17) requiring plant shutdown..This agrees with the NRC staff position (Letter, R. H. Reid to R. C. Arnold, November 17, 1976) which-states " valves whose failure in a non-conservative position during the cycling test would cause a loss of system function should not be exercised."

4 e

4

_.s.w-_._____._<___,____

_i E

_ - -s TABLE B-1 THREE MILE ISLAND UNIT NO. 1 PERIODIC' INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 32 of 38 SYSTEM /

TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY t

REACTOR BS-VlA,"B "Y" GLOBE 8" MOTOR 2

B T

Q

5 BUILDING g

SPRAY SYSTEM BS-V2A/B GATE 4"

HOTOR 2

B T

Q (ID-ISI-FD-012)

,f BS-V3A/B GATE 10" MOTOR 2

B T

Q BS-V23A/B CHECK 10" 2

C F

Q BS-V30A/B CHECK 8"

2 C

P(VIII)/D Q/10Y<I)

BS-VS2A/B CHECK 4"

2 C

D(VII) 10Y(2)

Footnotes:

E (I)

If disassembly / inspection reveal that the full stroke capability of the disassembled valve may be h

in question, the other valve (BS-V30A or B) will be disassembled and inspected at the same outage.

(2)

If disassembly / inspection reveal that the full stroke capability of the disassembled valve may be in question, the other valve (BS-V52A or B) will be disassembled and inspected at the same outage.

3 E

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TABLE B.

4

-THREE MILE ISLAND UNIT NO. 1

~

6 PERIODIC-INSERVICE INSPECTION PROGRAM

-(VALVES)

.PAGE.33 of.38

. SYSTEM /

TYPE

-TEST (ISI DRAWING NO.)

VALVE NO.

TYPE.

SIZE. OPERATOR-CLASS CATEGORY OF TEST FREQUENCY-REACTOR RC-VI(4)- GLOBE 2-1/2" MOTOR 1

B ~.

P/T

-Q/C COOLANT SYSTEM RC-V2-GLOBE 2-1/2" MOTOR 1

B.

T

'Q (10-ISI-FD-019)

-RC-V3(4)

GLOBE 2-1/2" MOTOR 1

B T

~C(I)

RC-V4 "Y" GLOBE 2-1/2" MOTOR 1'

B T

C(2) 4 RC-V23 CHECK 2-1/2" -----

1 C

F C(2)

RC-RVIA/S RELIEF 2-1/2" -----

1 C

SP SY RC-RV2(5) RELIEF 2-1/2" SOLEN 0ID 1

C SP/T(5)(IX)

SY/R

]

RC-V28 GLOBE 1"

MOTOR 1

B T

C(3)

RC-V40A/B GLOBE 1/2" SOLEN 0ID 1

B T(IX)

C(3) l RC-V41A/B GLOBE 1/2" SOLENOID 1

B-T(IX)

C(3)

RC-V42 GLOBE 1/2" SOLEN 0ID 1

B T(IX)

C(3)

RC-V43 GLOBE 1/2" SOLENOID 1

B T(IX)

C(3)

RC-V44 GLOBE 1"

SOLEN 0ID 1

B T(IX)

C(3)

Footnotes:

(I)

RC-V3 is the block valve for the pressurizer spray line. Part-stroking RC-V3 during normal operation would jeopardize the ability to spray the pressurizer and reduce pressure if RC-V3 stuck closed. Therefore, in accordance with ASME Sec.tlon XI IWV-3412, RC-V3 will be tested on a cold shutdown frequency.

TABLE-B THREE MILE ISLAND UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 34 of 38-SYSTEM /

TYPE TEST (ISI DRANING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY (2)

RC-V4 and RC-V23 are the two high pressure valves in series that supply Auxiliary Spray to the Pressurizer.

These valves are used only during cooldown of the pressurizer. RC-V4 and RC-V23 will not be part-stroked during normal plant operation because the margin of safety would be reduced by opening either of these two pressure barrier valves.

See NRC letter to Met-Ed dated November 17,'1976, Enclosure 2, paragraph 3.

Therefore, per ASME Section XI.INV-3412.and INV-3522, these valves will be tested on a cold shutdown frequency.

(3)

RC-V28 and RC-V44 are the two 'in-series Pressurizer Vent Valves. RC-V40A/B' cod RC-V41A/B are the two High Point Vent valves in series.

RC-V42 and RC-V43 are t5e two Reactor Vessel Head Vent valves in series. All of the valves are closed during normal plant operation.

These valves will not be part-stroked during normal plant operation because failure of one of the valves in a non-conservative position (open) during the cycling test would cause a loss of double barrier isolation for the RC System.

Therefore, per ASME Section XI l

INV-3412, all of these valves will be tested on a cold shutdown frequency.

(4)

RC-VI's function is control of RCS pressure. During a transient which increases RCS pressure, RC-VI opens to allow for cooler water to spray into the pressurizer, thus condensing steam and reducing RCS pressure.

Should the RC-VI valve fall open, cooler water would continue to flow into the pressurizer, reducing pressure to below the normal operating point.

For this reason, the line also contains RC-V3, which can be used to control the flow of cooler water to the pressurizer should the RC-VI valve fall open. These non-safety related valves have no essential safety function but are important to plant operation.

(5)

The PORV will be tested once per fuel cycle not to exceed a period of 24 months. During each refueling outage, one of the following three types of testing will be performed:

1)

Actuate during shutdown conditions, or 2)

Remove and bench test, or 3)

Remove and replace with a spare valve, previously bench tested within the last 3 years.

In addition, as-found and as-left visual examination will be performed.

For in-place testing, the stroke i

time will be determined by the use of the acoustic monitors, For bench testing, stroke time will be determined by observation.

Fall safe testing is to be determined by valve closure upon removal of the open actuation signal.

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. TABLE B-1 4

.THREE MILE ISLAND UNIT'NO. I a

PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES) 0

'y

'PAGEi35'of 38 SYSTEM /

TYPE TEST (ISI'DRANING NO.,)

VALVE NO.

TYPE-SIZE OPERATOR-CLASS CATEGORY OF TEST FREQUENCY SCREEN HOUSE SH-V4A/B CHECK 6"

3 C

F Q

VENT SYSTEM (ID-ISI-FD-002)

SH-V6A/B CHECK 2"

3 C_

F Q

SH-V17A/B BALL 2"

PNEU.

3-B T(IX)/FS

Q/Q SH-V19A/B CHECK 1"

3-C F

'Q-SH-V20A/B CHECK 1"

3 C

F Q

SH-V24A/B CONTROL 4"

DIAPH.

3 B

T/FS Q/Q

[

SW-V28A/B CHECK 2"

3 C

F Q

NOTE: GPUN has determined that the Screen Wash and Sluice Valves are not needed to achieve cold shutdown or mitigate the consequences of an accident since AP across the screen is alarmed and if necessary manual means can be employed to wash the screens.

Therefore, these valves have been deleted from this submittal.

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TABLE B-l'.

THREE MILE ISLAND UNIT.NO. 1:

PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

'PAGEL36 of'38-0 SYSTEM /

TYPE TEST (ISI DRAWING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST-.

7 FREQUENCY-SPENT FUEL SF-V23 GATE 8"

MANUAL 2'

.A'-

L/3I)

RI-COOLING SYSTEM (ID-ISI-FD-018)

Footnote:

i (I)

This CIV is passive (a closed valve whose function is to remain closed).

Therefore, this valve is exempted from the quarterly functional stroke requirement of IHV-3412 per NRC staff guidelines'since no meaningful d

information would be gained.

l

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TABLE B-1

' "~"

THREE MILE ISLAND UNIT NO. 1 PERIODIC INSERVICE IICPECTION PROGRAM - (VALVES)

PAGE 37 of 38 SYSTEH/

TYPE TEST (ISI DRAHING NO.)

VALVE NO.

TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY HASTE HDG-V3 GLOBE 2"

MOTOR 2-A L/T R/Q DISPOSAL GAS (ID-ISI-FD-023)

HDG-V4 GLOBE 2"

SOLEN 0ID 2

A L/T(IX)/FS R/Q/Q 1

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TABLE B-1:

o 1

THREE MILE ISLAND UNIT'NO. 1:

PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)

PAGE 38 of-38~

SYSTEM /-.

' TYPE TEST-(ISI DRAMING NO.)

VALVE NO.

TYPE SIZE.J

' CATEGORY' 'CF TEST

' FREQUENCY OPERATOR.

CLASS HASTE HDL-V49-DIAPH.

1-1/2" DIAPH.

3.

B T(IX)/FS-Q/Q.

DISPOSAL' LIQUID SYSTEM HDL-V50 DIAPH.

1-1/2"~DIAPH.

3 B

T(IX)/FS

.Q/Q-(1D-ISI-FD-021)

HDL-V61 DIAPH.

1" DIAPH.

3 B;

T/FS-Q/Q (10-ISI-FD-023)

HDL-V62 DIAPH.

1"

'DIAPH.

3-B.

T/FS Q/Q WDL-V89 DIAPH.

2" DIAPH'.

3-B T/FS

.Q/Q' WDL-V90 DIAPH.

2" DIAPH.

3 B

T/FS.

Q/Q WDL-V91 DIAPH.

2" DIAPH.

3-B T/FS Q/Q HDL-V92 DIAPH.

2" DIAPH.

3 B.

T/FS Q/O WDL-V303 GATE 3"

MOTOR 2

A L/T-

~R/Q-WDL-V304 GATE 3"-

DIAPH.

2 A

L/T(IX)/FS.

.R/Q/Q WDL-V353 CHECK 1-1/2" -----

3 C

F-

.Q WDL-V354 CHECK 1-1/2" --- -

3 C

F Q

WDL-V361 CHECK 1"

3 C

F R(IV)

WDL-V362 CHECK 2-1/2" -----

3 C

F R(IV)

WDL-V534 GATE 6"

PISTON 2-A L/T/FS R/Q/Q-WDL-V535 GATE 6"

PISTON 2

A L/T/FS R/Q/Q

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S TABLE B <

zTHREE MILE ISLAND - UNIT!NO.;1' y

6 PERIODIC '.4 SERVICE INSPECTION PROGRAM

. VALVES-

' ~

REQUEST FOR RC'IEF FROM'ASME CODE SECTION XI REQUIREMENTS PAGE 1 of 20 GENERIC REQUEST-FOR RELIEF 1

~

l 4

I.

Corrective Action for Inoperative. Valves.

i 1

A.

Valve Identification All the Class 1, 2, and 3 valves identified in Table.B-1. TMI-1 Valves Requiring Periodic Inservice Inspection.

B.

ASME Code Section XI Requirement From Which Relief is Requested Corrective action for inoperable valves require condition be corrected before unit j

startup from a cold shutdown condition in accordance with paragraphs INV-3417(b).

C.

Basis for P.equesting Relief-Constraints and limits on plant startup with an inoperable valve depend on many specific j

plant design features and conditions.

The limiting conditions for startup and operation.

have been analyzed and are described.in the TMI-1 Technical Specifications.

Inoperable j

valves will be evaluated considering the TMI-1 Technical Specifications to determine when j

an inoperable valve will limit plant startup from a cold shutdown condition.

i l

II.

Leak Testing of Category A Valves i

i A.

Valve Identification l

All the Category A valves identified in Table I as L in the type of test column. These valves are containment isolation valves.

B.

ASME Code Section XI Requirement From Which Relief is Requested i

l Relief is requested from paragraph INV-3420, " Valve Leak Rate Test" through INV-3425.

l i

l

TABLE B-2 THREE MILE' ISLAND -' UNIT.NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM'- VALVES ~

REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS i

PAGE 2 of 20 C.

Basis for Requesting Relief.

All' Appendix J, Type C valves are included in the IST Program and they are categorized A or A/C. All the ASME Code Category A, Containment Isolation Valves (CIVs) will meet Appendix J to 10 CFR Part 50 leak testing requirements in lieu of ASME Code Section XI requirements..CIVs are listed in TMI-l's Technical. Specifications and existing requirements and exemptions listed therein shall apply to the IST Valve Program.

Appendix J 1s equivalent to and meets the intent of the code requirements. Therefore, valve operability is assured.

Furthermore, a procedure is in place that meets the requirements ~of IWV-3426 and INV-3427 concerning individual valve leakrate limits and trend analysis of leakrate, respectively.

3

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4 a

TABLEB-2f J

i

_ THREE MILE ISLAND -' UNIT NO.'1; PERIODIC ~ INSERVICE INSPECTION. PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION'XI REQUIREMENTS-e

'PAGE-3 _of:20; SPECIFIC REQUESTS FOR RELIEF I.

Category B - Valves That Will Be Tested Only During Refueling Outages ts A.

Valve Identification Valve Name and Function Valve Number Reactor Bldg. Sump Recirc. Suction DH-V6A/B River Water to EF Pumps EF-V4 River Water to EF Pumps EF-V5-B.

ASME Code Section XI Requirement From Which Relief is Requested Paragraph IHV-3412(a) states that valves that cannot be operated during normal plant operation shall be full-stroke exercised during each cold shutdown. In case of frequent. cold shutdowns these valves need not be exercised more often than once every three months.

C.

Basis for. Requesting Relief Prior to cycling DH-V6A and B the Reactor Building Sump must be drained, then blank flanges weighing ~140 lbs. must be installed in the sump on the piping leading to DH-V6A/B.

In order to install the blank flange, considerable time and effort is required (i.e., maintenance personnel must enter the sump to install the blank flanges. After the test the blank flanges must be removed.

There are no isolation valves other than DH-V6A/B that isolate the Reactor Building Sump from the DH System. The blank flanges are installed to prevent water in the DH piping from flooding the Reactor Building when DH-V6A/B is opened for stroke timing.

If the blank flanges were not installed, water would flow through the 14" line for ~140 seconds while DH-V6A/B is opened and then closed.

Because of ALARA concerns (~300 MR for installation and removal of the flanges), the proper frequency for stroke timing DH-V6A/B is refueling.

Tiierefore, it is impractical to test DH-V6A/B on a cold shutdown frequency.

In addition, a refueling interval stroke time test since 1978 has not shown any problem with DH-V6A/B.

~

ITABLE B-2 THREE MILE ISLAND'- UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES-REQUEST FOR RELIEF.FROM ASME CODE SECTION XI. REQUIREMENTS.

. PAGE 4 of 20 a

EF-V4 and EF-V5 supply river water as a-last resort to;the: Emergency'Feedwater Pumps (EF-P1, i

2A/8). The function of the EFW System is to remove heat from the RCS when.the main feedwater system is not available.

Per Operating Procedure (OP:1106-6) EF-V4 and 5 are chained and locked shut and the breakers for the motor operators ~are open at-the 480 volt power' supply.

EF-V4 and 5 are opened by manual action if 1.) the Condensate Storage. Tanks, 2.) Condenser Hotwell, 3.) Demineralized Water Storage Tank-(Million Gallon Tank) are. exhausted. :The stroking of EF-V4'and 5 introduces river water, silt and corrosives into the suction of the-EF-P1,'2A/B.

It can be seen:from the piping configuration in Figure B-2.1 that it is difficult to remove all river water from the suction piping once it has passed through EF-V4-and 5.

The flush involves a slow fill and drain procedure using small. vent and drain lines and valves.

The numerous batch fill and drain operations (fill through EF-V14, drain'through EF-V24 and vent through EF-V28A), which are required to minimize river water, silt and i

corrosives, would not be completely effective in removing the contaminants.

The appropriate j

interval for this evolution is refueling.

II. Category C - Valves Which Will be Full Stroke Tested Following A Refueling or A Cold Shutdown When l

Cold Shutdown Exceeds 30 Days.

l A.

Valve Identification Valve Name and Function Valve Number Condensate Storage Tank to EF Water Pumps CO-V16A/B Notor Driven EF Water Pump Discharge EF-VilA/B l

EF Water Pumps to OTSG EF-V12A/B

]

Turbine Driven EF Hater Pump Discharge EF-V13 B.

ASME Code Section XI Requirement From Which Relief is Requested i

Paragraph IWV-3522 states that check valves that cannot be operated during normal plant operation shall be full-stroke exercised during each cold shutdown.

In case of frequent cold j

shutdowns these valves need not be exercised more often than once every three months.

i l

1-y TABLE B-2 THREE MILE ISLAND ' UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM -. VALVES REQUEST FOR RELIEF FROM.ASME CODE SECTION XI REQUIREMENTS PAGE 5 of 20 C.

Basis for Requesting Relief The above valves will be full service tested on a refueling basis in conjunction with Tech.

I Spec. 4.9.1.6 in accordance with Surveillance Procedure ra. 1303-11.42.

This procedure injects oxygenated water from the Condensate Storage Tanks through the' Emergency Feed Water pumps to the OTSGs and verifles the accident design flow rate.

THI-1 must. limit the exposure of the secondary side of the OTSGs to oxygentated water.

It-is not acceptable to challenge i

the OTSG tubes with oxygenated water in order to test the above. valves more frequently than the Technical Specification requirement.

The Technical Specification testing frequency meets i

the intent of ASME Section XI requirements.

The basis of Tech. Spec. 4.9.1.6 states that refueling or cold shutdown when cold shutdown exceeds 30 days. testing is adequate to insure that overall EFW system functional capability is maintained.

l III. Category C Valves Which Will Be Full Stroke Tested Only During Refueling Outages A.

Valve Identification Valve Name and Function Valve Number i

BHST to BS and DH (LPI) check valve DH-V14A/B(I)

Main Feedwater to OTSGs FN-V12A/B HPI Pump Suction Stopcheck Valve From BHST MU-V14A/B HPI Pump Discharge Check Valve MU-V73A/B/C 2

l HPI Check Valve MU-86A/B HPI Check Valve MU-V94 HPI Check Valve MU-V9S i

HPI Check Valve MU-V107A-D HPI Check Valve MU-V220 l

R. B. Emergency Cooling Pump Discharge Check RR-V8A/B l

R. B. Emergency Cooling Coll Outlet Check RR-V9A/B/C' Intermediate Cooling Water to CRD Cooling Coil CIV IC-V16 Intermediate Cooling Water to Letdown Cooler CIV IC-V18 (I) Full-stroke tested only for LPI (See Relief Request XII)

TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 6 of 20 B.

ASME Code Section XI Requirement From Which Relief is Requested Paragraph IWV-3522 states that check valves that cannot be operated during normal plant operation shall be full-stroke exercised during each cold shutdown.

In case of frequent cold shutdowns these valves need not be exercised more often than once every three months.

C.

Basis for Requesting Relief DH-V14A/B:

These valvec will be tested each refuelin'g interval per Surveillance Procedure No.

1303-11.54 in accordance with Technical Specification 4.5.2.2b.

The refueling test frequency assures that the LPI System can supply equal or greater flow than the flow assumed in the Safety Analysis.

This Technical Specification test frequency should be adequate for ASME Section XI. See Table B-2.1 for a tabular presentation of the testing for DH-V14A/B.

All HPI valves listed above: When the MU Pumps (HPI Pumps) are racked in, Technical Specification 3.1.12.3 requires the RCS average temperature to be >275'F prior to opening the HPI block valves (HU-V16A/B/C/0).

This is to prevent overpressurizing the RCS.

In order to test the above valves, the piping configuration requires pumping through the MU Pumps to the HU-V16's and to the HPI nozzles at the RCS cold legs.

Therefore, the only testing method allowable by Technical Specification 3.1.12.3 is to pump to the RCS when the RCS temperature is >275'F.

This uses one or more thermal cycles on the HPI nozzles.

Recent B&W guidance allows only 48 cycles on these nozzles. At present THI-l has had more than 20 thermal cycles.

Therefore, it is not advisable to test the above valves at a cold shutdown frequency.

The appropriate testing frequency is refueling.

To date no testing failures have occurred:

THI-l has always been able to deliver the accident design flow rate through the above listed valves.

RR-V8A/B and RR-V9A/D: During the functional test of these check valves river water, silt, and corrosives are introduced into the Reactor Building Emergency Cooling Colls. After the test these cooling coils must be first drained and then flushed with Nuclear Service Closed Cooling Hater.

The drain and flush water is drained to the Reactor Bu11 ding Sump and this produces large quantitles of water that must be processed through the 11guld waste disposal system.

Therefore, a quarterly or cold shutdown test is not practical.

Per Technical Specification 4.5.2, these check valves will continue to be tested on a refueling frequency (approximately every 12 months).

1

9 TABLE.B-2 THREE MILE ISLAND - UNIT NO.-1.

PERIODIC INSERVICE' INSPECTION PROGRAM ~- VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 7 'of 20

~

IC-V16 and IC-V18:

These check valves are CIVs that rema1n open'during normal plant operation to supply cooling water to the CRD cooling coils and the Letdown coolers.

It is not possible to stop flow in these lines for a test of IC-V16 and IC-V18 without upsetting the-reactor plant. The safety function of IC-V16 and IC-V18 is to close and act-as CIVs.

Therefore, a leak rate Appendix J test of these valves will be conducted each refueling outage.

FN-V12A/B:

For short cold shutdowns, condenser vacuum is maintained, if at all~possible.

Testing of FN-V12A/B however requires Main Condenser vacuum to be. broken.. After acceptable chemistry samples are obtained, the secondary side of the OTSG must be fed to the wet layup i

condition.

Several operators are required for at least one shift.

In addition, the Main Steam hangers must be blocked and pinned.

This requires approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for 4 to 5 men.

Then, for the closed test of FN-V12A/B, approximately 150 psig of nitrogen pressure is applied to the secondary side of the OTSGs.

It is not practical to perform this evolution on a cold shutdown frequency.

The appropriate frequency is each refueling outage.

L

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L TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME. CODE SECTION'XI REQUIREMENTS PAGE'8e of 20 IV. Concentrated Boric Acid Injection Valves That Will Be Tested On a ' Refueling Interval Basis A.

Valve Identification Valve Name and Function Valve Number CA-PIA /B to MU System CA-Vl?7 CA-PIA /B and WOL-P13A/B to MU System WDL-V361 l

Isolation for CA-PIA /B and WOL-P13A/B to MU WDL-V362 B.

ASME Code Saction XI Requirement From Which Relief is Requested i

Relief is requested from paragraph INV-3412 and INV-3522 which states that if only limited operation is practical during plant operation, the valve shall be pret-stroke exercised during plant operation and full-stroked during each cold shutdown.

l C.

Basis for Requesting Relief The only method of functionally testing check valves CA-V177, WOL-V361, and WOL-V362 during normal operation is to inject concentrated boric acid into the Reactor Coolant Makeup System producing reactivity changes.

This would adversely affect plant operation and result in 4

significant volumes of additional radioactive waste.

Testing these valves during each cold shutdown is not warranted because of the radioactive waste generated, All of the above valves.

are associated with the concentrated boric acid system. Also the system for these valves is not relled upon for accident mitigation in Chapter 14 of the THI-1 FSAR. The Borated Water Storage Tank is the accident source of Borated Water via LPI or HPI. However, general design criteria does require a concentrated boric acid injection system.

In conclusion, GPUN believes that refueling interval testing will assure the operational readiness of the above valves.

i 1

J

i TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIDOIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 9 of 20-V.

Pressure Isolation Check Valves That Hill Be Tested On A Frequency Per Technical Specification 3.1.6.10.

A.

Valve Identification Valve Name and Function Valve Number Core Flood Tank to Reactor Vessel CF-V4A/B Core Flood Tank /LPI to Reactor Vessel CF-VSA/B LPI Pumps to Reactor Vessel DH-V22A/B B.

ASME Code Section XI Requirement From Which Relief is Requested Paragraph INV-3522 states that valves that cannot be operated during normal plant operation shall be full-stroke exercised during each cold shutdown.

In case of frequent cold shutdowns these valves need not be exercised more often than once every three months.

C.

Basis for Requestina Relief The Reactor Safety Study (RSS), NASH-1400, identified a PHR intersystem loss of coolant accident (LOCA) which is a significant contributor to risk or core melt accidents (Event V).

The design examined in the RSS contained in-series check valves isolating the high pressure Primary Coolant System (PCS) from the Low Pressure Injection (LPI) System piping. The scenario which leads to the Event V accident is initiated by the failure of these check valves to function as a pressure isolation barrier.

This causes an overpressurization and rupture of the LPI low pressure piping which results in a LOCA that bypasses containment.

Valves CF-VSA/B and DH-V22A/B are inside containment and are located in the supply line from the LPI pumps to the Reactor Vessel.

Therefore, these two valves are of the Event V configuration. Valves CF-VSA/B and CF-V4A/B are in the line from the Core Flood Tanks to the l

Reactor Vessel. A pressure isolation failure of CF-V4A/B does not lead to a LOCA outside containment.

Therefore, CF-V4A/B is not included in Technical Specification 3.1.6.10.

However, THI-l has elected to test these valves for the pressure isolat'.on function on the same frequency as CF-VSA/B and DH-V22A/B.

M Ess BIERFf E N

w-l

_ TABLE B THREE MILE ISLAND - UNIT.NO. I' PERIDOIC INSERVICE INSPECTION PROGRAM - VALVES

-REQUEST FOR RELIEF FROM ASME CODE SECTION XI. REQUIREMENTS:

PAGEi 0? of 20 1

The NRC's Technical Evaluation Report (TER)' prepared by Franklin Institute statesLthat.the i

. testing frequency of CF-VSA/8 and DH-V22A/B.shall be prior to achieving hot shutdown following a cold shutdown of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> duration unless testing has been performed within-the previous 9 months, and prior to achieving hot shutdown after returning the valve to service.

following maintenance repair ~or replacement work.

The TER provides a comprehensive study and evaluation of the. specific problem'related to pressure 1 solation.

Since the TER has specified and judged adequate the above testing frequency, there is reasonable assurance that these valves'w111 perform their pressure barrier function.

1 VI. Valves That Will Only Be Part-Stroke Tested i

A.

Valve Identification Valve Name and Function Valve Number il Core Flood Tank to Reactor Vessel CF-V4A/B j

Main Steam to EF-U1 MS-V9A/B B.

ASME Code Section XI Reautresent From Which Relief is Requested i

i Relief is requested from paragraph IHV-3522 which states that if only limited operation is practical during plant operation, the check valve shall be part-stroke exercised during plant j

operation and full-stroke tested during each cold shutdown.

1 i

C.

Basis for Requesting Relief CF-V4A/B:

These valves are part-stroke tested each cold shutdown per Surveillance Procedure 1303-11.21.

Both CF-V5A/B and CF-V4A/B are of the same design and manufacturer. CF-VSA/B are in operation whenever the plant is on Decay Heat Removal and are normally closed during power operation. CF-V4A/B are in operation whenever Core Flood is required and are normally closed during power operation and during Decay Heat Removal System operation. CF-VSA/B are also in operation whenever Core Flood is required.

Therefore, CF-VSA/B are in operation more than CF-V4A/B and have a greater potential for degradation during operation.

The refueling l

i

e s

y; w cp JA8LE _ B-2.

THREE MILE ISLAND - UNIT NO. 1_

I

-PERIODIC INSERVICE INSPECTION PROGRAM -lVALVES REQUEST FOR RELIEF FROM ASME C00E1SECTION.XI REQUIREMENTS PAGE'll; of.20 l

m l

Interval full-flow LPI System testing of CF-VSA/B showing no degradation during service can be applied to CF-V4A/B because the service for.CF-V4A/8.is less severe than that of.CF-VSA/8..

CF-VSA/B are full stroke tested per the code and-CF-V4A/B are the same. valve catalog number as 1

CF-V5A/8.

Therefore we feel confident that our proposal to only part-stroke CF-V4A/8~should be adequate. Additionally, one'of these valves-(CF-V4A/B'or-CF-VSA/8) will be' disassembled.

for visual examir.Ttion at or neer-the end of the 10 year.ISI interval.per Table.-IN8-2500.

MS-V9A/8:

These check-valves supply steam from the OTSGs.to EF-UI.

EF-U1 is the turbine-l drive unit for the Steam Driven Emergency Feedwater Pump (EF-P1). During a cold shutdown, it is impractical to stroke test these valves (full-stroke or partial-stroke) since the steam which would be needed to operate these valves'is not available during cold shutdown conditions.

i Full-stroke testing of MS-V9A/B is also impractical.due to other limitations during' plant conditions when steam is available.

EF-P1 must be tested using the recirculation line to the Condensate Storage Tank bypassing the OTSG.

This is to prevent degradation of the OTSGs by excessive thermal stress cycling of the emergency feedwater nozzles.

The number of thermal cycles on the emergency feedwater nozzles.ls limited to (40) cycles over the life of the 4

plant. Due to the small size of the recirculation line, EF-PI cannot be tested at full capacity (MS-V9A/B will not open fully). Under these. restrictions it is only possible to

- i l

obtain approximately.48% flow which corresponds to about.36% opening of MS-V9A/B.

1 Plant modifications which would be required to perform full stroke tests of MS-V9A/B either by piping in auxiliary steam or by replacing the recirculation piping with larger piping capable of recirculating the full EFH pump capacity would introduce exorbitant cost.' GPUN has not fully examined the cost and safety impact of modifications which would be required to full j

stroke MS-V9A/B, however, we do not feel that such modifications would be beneficial.

MS-V98 was disassembled for IST examination purposes in late 1984 and found to be in excellent condition.

Since no indication of potential degradation was found, this provides additional assurance of the continued capability of MS-V9A/B to open fully when needed.

In addition, MS-V9A will be disassembled and inspected at the next refueling outage (end of cycle 5 refueling outage).

Thereafter, either MS-V9A or B will be disassembled / inspected on a 10 year basis (next inspection due -1994) if the inspection of MS-V9A proves satisfactory.

If degradation is fouad which would make the valve's full stroke capability questionable, then the other valve (MS-V9A or B) would be disassembled and inspected during that same outage.

y,

TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 12 of 20 It is impractical to test MS-V9A/B when steam is not available and it is also impractical to.

perform a full stroke test on MS-V9A/8. GPUN concludes that quarterly testing of MS-V9 at 48%

flow (36% open) when steam is available and disassembly each 10 years meets the intent of the ASME Code Section XI and the relief which'is being requested is therefore justified.

VII. Check Valves That Will Be Disassembled Once Each Ten Years A.

Valve Identification Valve Name and Function Valve Number Sodium Hydroxide Tank Supply to Reactor Building BS-V52A/B Spray Pu.1ps B.

ASME Code Section XI Requirement From Which Relief is Requested Relief is requested from paragraph IWV-3522 which states that if only limited operation is practical during plant operation, the check valve shall be part-stroke exercised during plant operation and full-stroked during each cold shutdown.

C.

Basis for Requesting Relief Given the pipe geometry there is no method of part-stroking or full-stroking these check valves without contaminating the RCS with Sodium Hydroxide and other chemical contaminants in the dead leg of piping from these valves to the Sodlum Hydroxide Tank. During January, 1984 (Surveillance Procedure No. 1300-3P and Job Ticket Nos. CC818 and CC819) these valves were disassembled and visually examined with satisfactory results. The valve internals were found to be in "like new" condition.

Disassembling each of these valves at or near the end of the ten year ISI interval provides reasonable assurance of the operational readiness of BS-V52A/B.

=

W mmmA m

o x

TABLE B-2.

THREE MILE ISLAND --UNIT N0l 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES

.y REQUEST FOR RELIEF FROM ASME CODE SECTION.XI' REQUIRE >ENTS PAGE 13 of 20:

VIII. Check Valves That Will Be Given A Part-Stroke' Test Each Quarter and Disassembled Once Each1 Ten Years

)

A.

Valve Indentification Valve Name and tnction

. Valve Number

~

Reactor Bldg. Spray Header Check Valve BS-V30A/B I

B.

ASME Code Section XI Requirement From Which Relief 15 Requested Relief is requested from paragraph INV-3522 which states that if only limited operation is practical during plant operation, the check' valve shall be part-stroke exercised during plant l

operation and full-stroked during each cold shutdown.

1 i

C.

Basis for Requesting Relief

)

The full-stroke of BS-V30A/B would require initiation of Reactor Building Spray. This would i

entail spraying the Reactor Building with' borated water.

On 6-20-84 (Job Ticket CE-154) BS-V30A was disassembled for visual examination purposes. The examination was satisfactory (no unusual degradation and valve disc was free to open).

BS-V30A has approximately 10 years of in-service time and this is the first time that the valve has been opened. GPUN will continue to disassemble either of these static valves (alternating between A and B) during each ten year inspection interval. BS-V30A/B are i

stainless steel and therefore, not subject to corrosive attack. GPUN is of the opinion that quarterly partial-stroke testing and disassembly, as described, will provide reasonable assurance that BS-V30A/B would open if needed.

In addition, if disassembly / inspection reveals that the full-stroke capability of the disassembled valve may be in question, the other valve will be disassembled and inspected at the same outage.

I i

l 1

m_._m__u---__-.x.-__----......,-.-_...---.-

TABLE'B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS

'PAGE 14 of 20 IX. Valves Where Percent Increase In Valve Stroke Time Hill Not Be Calculated A.

Valve Identification Valve Name and Function Valve Number Containment Purge CIV AH-VIA/D Reactor Coolant Sampling CIV CA-V2 OTSG Shell Side Sampling CIV CA-VSA/B Containment Monitoring CIV CH-VI Containment Monitoring CIV CM-V2 Containment Monitoring CIV CM-V3 Containment Monitoring CIV CM-V4 Diesel Generator Air Start EG-V16A/A, B/A, A/B, B/B Hydrogen Monitoring CIV HM-VIA/B Hydrogen Monitoring CIV HM-V2A/B Hydrogen Monitoring CIV HM-V3A/B Hydrogen Monitoring CIV HM-V4A/B Hydrogen Recombiner CIV HR-V22A/B Hydrogen Recombiner CIV HR-V23A/B Makeup Letdown CIV MU-V3 Boric Acid Injection to MU Tank MU-V10 Normal Makeup CIV MU-V18 Boric Acid Mix Tank to MU Tank MU-V51 Lube Hater Pump NR-P2A/B/C Suction NR-V45A/B/C High Point Vent Isolation RC-V40A/B High Point Vent Isolation RC-V41A/B Cooling Hater to Reactor Building Coolers NS-V52A/B/C Cooling Hater from Reactor Building Coolers NS-V53A/B/C Pressurizer Pilot Actuated Relief Valve RC-RV2 Reactor Vessel Head Vent Isolation RC-V42 Reactor Vessel Head Vent Isolation RC-V43 Pressurizer Vent Isolation RC-V44 Lube Hater Pump SH-P4A/B Suction SH-V17A/B Haste Gas RC Drain Tank CIV HDG-V4 HDL-P13A Discharge HDL-V49 HDL-P13B Discharge HDL-V50 RC Drain Tank CIV HDL-V304 L

ME M Y

<n

. TABLE B-2.

xp THREE MILE ISLAND - UNIT NO. 1

^

PERIODIC INSERVICE INSPECTION' PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE-SECTION XI REQUIREMENTS PAGEl15..of 20 8.

ASME Code Section XI Requirement From Which Relief Is Requested Paragraph IWV-3417(a) which states that if a specified percent increase in stroke-time.is exceeded, test frequency shall be increased to once a month until corrective actionbisLtaken.

C.

Basis for Requesting Relief The above valves have actual full-stroke tints of less than one second.

Thus, the valve stroke time cannot effectively be measured using normal test equipment'such as'a stopwatch.

Also it is considered. impractical to reliably measure chances in valve stroke times for valves which stroke open or closed in less than one-(1) second.

For very short stroke times, the.

variation in measured stroke times can be a'large fraction of the established stroke time limit.

Thus it is not practical to meaningfully' identify or evaluate the stroke time changes considering human reaction times and the normal timing equipment used.

In accordance with ASME Section XI INV-3413, the maximum acceptable full-time stroke value for each of the above valves will be specified.

This will ensure the operational. readiness of these valves.

X.

Deleted l

i l

ll-l l

p&

R y

m.

m

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1 y'

1 TABLE B.

-d

- THREE MILE' ISLAND - UNIT NO.'l-

~

PERIODIC INSERVICE INSPECTION PROGRAM - VALVES:

RiOUEST FOR RELIEF FROM:ASME CODE SECTION W ' REQUIREMENTS l

- PAGE:)16 L of '20 :

.i.

XI.

Category A/C Valves That Will Be Tested. Closed On A Refueling Interval: Basis A.

Valve Identification Valve Name and Function Valve Number

.Demin. Water CIV-CA-Vl92 RC Pump Seal Injection CIV

.MU-Vil6 NS' Cooling Water CIV

.NS-Vil i

B.

ASME Code Section XI Requirement From Which Relief Is-Requested l

Relief is requested from INV-3522 which states "If only limited operation is practical during.

plant operation, the check valve shall be part-stroke. exercised during cold shutdown."

i l

C.

Basis for Requested Relief CA-V192 I

j During normal plant operation, check valve CA-Vl92 1s.open supplying 100 cc/ min reclaimed water purge to the No. 3 seal of each Reactor Coolant Pump.

This purge supply was provided in the original design to enhance RC Pump seal reliability but is not required to maintain seal integrity and is therefore isolated on Reactor Building containment isolation signals.

CA-Vl92's only safety function is to close to provide containment isolation. The containment l

1 solation function will be verified each refueling by leak testing per SP. 1303-11.18.

i MU-V116 i

i During normal plant operation, check valve MU-V116 is open supplying ~32 gpm of seal l

injection to the four RC Pumps.

RC Seal Injection'cannot be stopped to, verify MU-Vil6 closes each quarter without damaging the RC Pump Seals. MU-Vil6's only safety function is to close to provide containment isolation.

The containment isolation function will be verified each refueling per SP 1303-11.18.

1 g

-w

3 m

TABLE'B-2 THREE MILE ISLAND.- UNIT.NO..1~

PERIODIC INSERVICE INSPECTION PROGRAM -. VALVES' REQUEST FOR RELIEF FROM ASME' CODE SECTION XI REQUIREMENTS PAGE.:17 of 20 l

I NS-Vil j

During normal plant operation, check valve NS-Vil is open supplying cooling water to:the RC Pump motor coolers. Cooling water to the RC Pump motor coolers.cannot be isolated.to verify NS-Vil's closed function. Without motor cooling the RC Pump Motor would overheat and trip the-plant.

NS-Vll's only safety function.is to close to provide containment 1 solation.

The l

containment isolation function will be verified each refueling per SP 1303-11.18.

XII.

Dual Function Valves That Are Full Stroke Tested For Only One Function A.

Valve Identification Valve Name and Function Valve Number.

I j

BWST to DHR and BS System DH-V14A/B i

DHR and CF to Reactor Vessel CF-VSA/B' B.

ASME Code Section XI Requirement From Which Relief Is Requested Relief is requested from INV-3522 which states that check valves shall be full stroked exercised during cold shutdown.

C.

Basis for requested Relief DH-V14A/B Check valve DH-V14A/B supplies borated water from the Rorated Water Storage Tank (BHST) to the Decay Heat Removal Pumps (DH-PIA /B) and the Reactor Building Spray Pumps (BS-PIA /B). DH-PlA/B are TMI-l's Low Pressure Injection (LPI) Pumps.

Each refueling, Surveillance Procedure 1303-11.54 verifies LPI flowrate of 23000 gpm through DH-V14A/B.

The accident design flow rate through DH-PIA /B is 3000 gpm and the accident design flow rate for BS-PIA /B is 1500 gpm.

Therefore, SP 1303-11.54 verifles that DH-V14A/B can pass 2/3 - 3000 gpm/4500 gpm of total DH and BS ficu rate.

It is impractical to structure a test where 1.) a DH pump is injecting 3000 gpm from the BHST through DH-V14A/B to the reactor vessel, 2.) a BS pump is recirculating the BHST through DH-V14A/B at 1500 gpm, and 3.) the second DH pump is providing its decay heat

4 Y

d 4

~ TABLE B-2'

^

THRE'E MILE ISLAND - UNITfMO.11 '

PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME-CODE SECTION TI REQUIREMENTS PAGE 18 'of'20 i

removal function by recirculating the reactor vessel.: The complexity of this evolutt'on,-t'ine:

and effort do not warrant this; type of testing. Conceivably, this; testing could be....

m accomplished by filling the' transfer canal part way then, switching to.the.next.loopfto'be i

tested.

The risk _of incorrect valve-lineup leading to pump damage and hours-spent switching loops'and verifying valve lineups do not make such testing desirable. There are ALARA-concerns when switching loops (see Relief Request XIII). An additional concern is refueling

- 1 water clarity / cleanup due to crud that:will:be broken. loose during.the 3000 gpa injection into the reactor vessel..GPUN believes the burden of such testing is not warranted and that such i

testing is impractical.

The refueling (2/3) flow rate test demonstrates that DH-V14A/B has-the capability to open fully, if needed.

J CF-VSA/B i

CF-VSA/B's dual function is to provide LPI and core flooding.

Immediately upstream of l

CF-VSA/B is CF-V4A/B. CF-V4A/B and CF-VSA/B see essentially the same service condition'and..

they are the same size, manufacturer and catalog number. CF-V4B was disassembled in November i

1983 and was found to be in satisfactory condition.

This disassembly of CF-V48, provides 1

further evidence that CF-VSA/B can open fully if needed.

j CF-V4A or CF-V4B or CF-VSA or CF-V5B (1 of the four) will be. disassembled each 10 years for an inspection.

If degradation which would make the valve's full-stroke capablitty questionable l

1s found, then the remaining three valves will be disassembled and inspected during that j

outage.

See Table b-2.1 for a tabular presentation of the testing for DH-V14A/B and CF-VSA/B.

XIII.

DH-V16A/S A.

Valve Identification Valve rame and Function Valve Number LPI (DH) to Reactor Vessel DH-V16A/B l

I

=

- - - - - - =

g 3 4

1

-TABLE B THREE MILE ISLAND - UNIT NO 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES-REQUEST FOR RELIEF FROM ASME CODE SECTION XI. REQUIREMENTS-PAGE 19.of 20-4

_SME Code Section XI Requirement From Which Relief Is-Reauested-B.

A INV-3412 states that valves shall-be full stroked during each cold shutdown.

C.

Basis for Requesting Relief Both DH-V16A and B will be full-stroke tested each refueling interval.

During Power Operation the DHR System Operating Procedure requires DH-V128 to be locked open and DH-V12A'to be locked closed.

This is for-protection against boron precipitation in the event of a LOCA and is part of the resolution of NUREG 0737,. Item II.B.2 shielding issues as described in the NRC's.SER dated December 24, 1984. 'This results in the "B" DHR loop being favored for shutdowns.

Therefore, DH-V16B will be full-stroke tested each cold shutdown by the normal operation of 4

providing Decay Heat Removal flow of >3000 gpm.

See Table'B-2.l.for a tabular presentation of testing for DH-V16A/B.

The full-stroke test for the idle DH-V16 would require a deliberate shift of Decay Heat Removal (DHR) Trains.

For cold shutdowns of short duration, it is impractical to require.a complete system realignment to the opposite DHR system for the sole purpose of cycling this single check valve at design system flow rate.

The basis for this conclusion is.that:

(1) The system realignment requires manipulation of several large manual valves (DH-V12A and l

B) inside radiation areas where doserate could be as high as 500-mR/hr. Stay. time in.the radiation area to cycle one DH-V12 is 15 minutes for three men. The extra radiation exposure and rad waste generation to cycle this one check valve (DH-V16A or B) is not consistent with ALARA principles.

(2) The system realignment may be critical path time on a recovery from a forced outage.

The cost of delaying startup in order to stroke this one check valve makes testing at each i

cold shutdown impractical.

(3) A requirement to full-stroke this check valve each cold shutdown (if not performed within the last 3 months) would require the start of a large Engineered Safeguards (E.S.) pump and motor for the sole purpose of full-stroking this one check valve. The extra wear on this E.S. system merely to full-stroke one check valve is undesirable.

(4)

For normal planned cold shutdowns, routine maintenance activities have and will require that each DHR system be operated while the other is down for maintenance. When this occurs both DH-V16A and B will be full-stroked.

j

-EBIERE' ia-magEMiisEMIERHib MBE

, ' ' ?#

l TABLE B-2 THREE MILE ISLAND - UNIT NO. I PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 20 of 20 XIV.

MS-V6 A.

Valve Identification Valve Name and Function Valve Number EF-P1 Main Steam Control Valve MS-V6 8.

ASME Code Section XI Requirement From Which Relief Is Requested INV-3412 and 3413 which state that valves shall be full-stroke exercised and that the limiting value for full-stroke time of each power operated valve shall be specified by the Owner.

C.

Basis for Requesting Relief It is not possible to full-stroke and time MS-V6 since its stroke has been mechanically set to open no frore than 651 to protect EF-UI.

EF-UI is the steau drive unit for the Emergency Feedwater Pump (EF-PI). MS-V6 is the steam control supply valve to EF-UI.

The only method of opening MS-V6 to 65% open is to change the setpoint of the Pressure Controller (PC-5) for MS-V6.

It is impractical to change the setpoint of an Important to Safety component on a quarterly frequency. Changing the setpoint of PC-5 could place the plant in an unsafe condition by the loss of EF-P1 if the controller was not returned to the correct setpoint.

GPUN believes it impractical to change the setpoint of PC-5 on a quarterly frequency.

Therefore, MS-V6 will be part-stroke tested and fall safe tested each quarter when main steam is available to run EF-Pl. As an alternative to stroke timing MS-V6, the startup time of EF-P1 will be measured each quarter to assure that the startup time is within the time specified in the FSAR (~40 seconds).

This w111 assure the operational readiness of MS-V6.

XV.

Deleted XVI.

Deleted

-n=ng -

' TABLE B-2.l ?

TESTING FREQUENCY AND METH0'D OF SEVERAL DH.'8S AND CF' VALVES VALVE VALVE FUNCTION OUARTERLY

COLD SHUTDONN(I)

REFUELING DH-V14A/B BHST to Reactor Build-Part'lal for both A&B None (See Relief-Full' stroke test for LPI(2) ing Spray & DH (LPI) valve (~1750 gpm)

Request III) for both A&B valve (3000 gpm)~

DH-V16A/B DH (LPI) to Reactor Partial for both A&B Full stroke' test

~ Full stroke test for both' i

Vessel valve (~925 gpm)-

for DH-V168 A&B valve (3000 gpa)

(3000 gpm)(4)

DH-V22A/B DH (LPI) to Reactor None (See Table B-1, Full stroke test

' Full' stroke test for 't>oth Vessel Decay. Heat Removal, for both A&B valve A&B valve (3000 gpm)-

Footnote 3)

(3000 gpm)

Full str e test Full stroke test for LPI(2),(3)

CF-VSA/B Core flood & DH (LPI)

None (See Table B-1, forLPI(p) for for both A&B valve (3000 gpm) to Reactor Vessel Core flood System, Footnote 3) both A&B valve (3000 gpm)

Footnotes:

(1)

Cold shutdown test frequency as defined at the beginning Table B where " Symbols" are defined.

(2)

Full stroke test for LPI.

See Relief Request XII.

(3)

Also disassembled / visual examiaed per Relief Request XII.

(4)

See Relief Request XIII.

s

TABLE B-3 Page-1 of 5 Limiting Value of Stroke Time for IST Power Operated Valves l

4

~

VALVE LIMITING STROKE TIME (Sec.)

OPEN or CLOSE

1. AH-VIA

<l.0 CLOSE 2'.AH-VID-

<1.0 CLOSE

3. AH-VIB

<2.0 CLOSE

4. AH-VIC

<2.0 CLOSE

'5. BS-VIA 20 OPEN 6..BS-VIB 20 OPEN

7. BS-V2A 27 OPEN i
8. BS-V2B 25 OPEN 9.'BS-V3A 65-OPEN
10. BS-V3B 60 OPEN
11. CA-V1 27.8 CLOSE 12..CA-V2 2

CLOSE

13. CA-V3.

20.5 CLOSE

14. CA-V4A' 25.5 CLOSE
15. CA-V4B 22.8 CLOSE

-16. CA-VSA 2

CLOSE

17. CA-V5B 2

CLOSE

18. CA-V13 8.6 CLOSE
19. CA-V189 5.9 CLOSE
20. CF-V2A 23.3 CLOSE
21. CF-V2B 18.3 CLOSE t
22. CF-V19A 3.0 CLOSE
23. CF-V19B 3.0 CLOSE
24. CF-V20A 3.0 CLOSE 25.'CF-V208 3.0 CLOSE
26. CM-VI 2

CLOSE

27. CM-V2 2

CLOSE

'28. CM-V3 2

CLOSE

29. CM-V4 2

CLOSE

30. DH-V1 144 OPEN
31. DH-V2 144 OPEN 132. DH-V3 120 OPEN
33. DH-V4A 24 OPEN
34. DH-V4B 24 OPEN m:

p(

TABLE B-3 Page 2 of 5 Limiting Value of Stroke' Time for IST Power Operated Valves

[

VALVE

. LIMITING STROKE TIME (Sec.)

OPEN or CLOSE

35. DH-VSA 24 OPEN

~

36. DH-V5B 24 OPEN 137; DH-V6A~

86.25 OPEN

38. DH-V6B-83.75 OPEN 39.'0H-V7A 25.4 OPEN
40. DH-V78 26.3 OPEN
41. DR-VlA 188 OPEN

.42. DE:VlB 188 OPEN

43. EF-V4.

39 OPEN

44. EF-V5 41 OPEN
45. EF-V30A 7.5 OPEN 146. EF-V308 7.5 OPEN 47.'EF-V30C TBD*

OPEN

48. EF-V300 TBD*

OPEN

'49. EG-V16A/A 2

OPEN

50. EG-V168/A 2

OPEN

51. EG-V16A/B 2

OPEN

52. EG-V168/B 2

OPEN

53. HM-VIA 2

OPEN

54. HM-V1B 2

OPEN

55. HM-V2A 2

OPEN

56. HM-V2B 2

OPEN

57. HM-V3A 2

OPEN 58.-HM-V3B 2

OPEN 59.Hk-V4A 2

OPEN

60. HM-V4B 2

OPEN 61.HRbV22A 2

OPEN

62. HR-V228 2

OPEN

63. HR-V23A' 2

OPEN

64. HR-V23B 2

OPEN 65..IC-VIA 31 OPEN

66. IC-V1B 28 OPEN
67. IC-V2 38.0 CLOSE

-68. IC-V3 18.0 CLOSE

  • Valve scheduled to be installed during the 6R Refueling Outage.

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l TABLE B-3 Page 3 of 5 R.:

Limiting Value of Stroke Tom for IST Power Operated Valves l

-VALVE.

LIMITING STROKE TIME (Sec.)

OPEN or CLOSE

~69. IC-V4 15.0' CLOSE

70. IC-V6 3.0 CLOSE 71.-MS-VIA

<120 CLOSE

72. MS-VIB (120 CLOSE
73. MS-VIC.

<120 CLOSE

'74. MS-VID

<120 CLOSE

75. MS-V2A 74 CLOSE
76. MS-V2B 74 CLOSE

~

77. MS-V4A 5

OPEN t.

78. MS-V4B-5 OPEN
79. MS-V10A 33 OPEN
80. MS-V10B 33 OPEN
81. MS-V13A 23 OPEN 82..MS-V13B 23 OPEN 83." MU-V1A 36 OPEN
84. MU-V1B 37 OPEN
85. HU-V2A-31.3 CLOSE 31.7 CLOSE
86. MU-V2B
87. MU-V3

.2.0 CLOSE

88. MU-V10-2.0 OPEN
89. MU-V12 26 CLOSE 90.1tJ-V14A 14 OPEN
91. MU-V148 15 OPEN
92. MU-V16A 13.7 OPEN
93. MU-V16B 13.7 OPEN
94. MU-V16C 13.7 OPEN

.95. MU-V16D 13.7 OPEN

96. MU-V18 2.0 CLOSE
97. MU-V20 6

CLOSE

98. MU-V25 19.33 CLOSE

~99. MU-V26 3.0 CLOSE i

100. MU-V36' 10 CLOSE 101. MU-V37, 11 CLOSE 102. MU-V51 2.0 OPEN v w 4

n e

w 4

m n--my.

m y

e e

m-

--e---

ww--

hN NlN TABLE B Page 4 of 5

.!1 Limiting Value of Stroke' Time for IST Power Operated Valves LVALVE.

LIMITING STROKE TIME (Sec.)

OPEN or CLOSE 1103. MU-V217 9.0 OPEN

'104.-NR-VIA.

183 OPEN

,105. NR-V1B 188 OPEN

-106. NR-VIC 176 OPEN

'107. NR-V4A 196 CLOSE

-108..NR-V4B 198 CLOSE 109.-NR-V45A 2

.0 PEN

.110.-NR-V45B 2

OPEN 111.'NR-V45C 2.

OPEN

~112.-NS-V4 33.0 CLOSE 113. NS-V15 54.0

.CLOSE g.

.114. NS-V35 36.0 CLOSE 115. NS-V52A 2.0 OPEN

._116..NS-V52B 2.0 OPEN 117.',NS-V52C 2.0-OPEN

.118. NS-V53A 2.0 OPEN 119. NS-V538 2.0 OPEN 120. NS-V53C 2.0 OPEN 112:1. PP-V100 4.5 OPEN o

122. PP-V103 17.0 OPEN 123. PP-V132 18.0 OPEN 124. PP-V135 4.65 OPEN 125..RB-V2A e

47.0 CLOSE 126. RB-V7 36.0 CLOSE 127. RC-V1 7

OPEN 128. RC-V2.

13.8 CLOSE 129.-RC-RV2 2

OPEN 130.-RC-V3 38 OPEN

~

131; RC-V4 32 OPEN

.132. RC-V28 9.5 OPEN

.133. RC-V40A 2.0 OPEN 134. RC-V408 2.0 OPEN

-135. RC-V41A 2.0 OPEN 136. RC-V41B 2.0 OPEN c

4

k '

TABLE B Page 5 of 5 Limiting Value of Stroke Time for IST Power Operated Valves VALVE LIMITING STROKE TIME (Sec.)

OPEN or CLOSE 137.-RC-V42' 2.0 OPEN 138. RC-V43 2.0 OPEN 139. RC-V44 2.0 OPEN 140. RR-VIA 183.

- 0 PEN j

141.:RR-VIS 181 OPEN

-142. RR-V3A 75' OPEN 143. RR-V3B 75 OPEN 144.-RR-V3C 75 OPEN 145. RR-V4A 73 OPEN 146. RR-V4B 73 OPEN

.147. RR-V4C 74 OPEN 148. RR-V4D 74 OPEN 149. RR-V5 191 OPEN 150. RR-V10A 25 OPEN 151. RR-V10A-29 CLOSE

-152.' RR-V108 29 OPEN 153. RR-V108 31 CLOSE 154. SH-V17A' 2

OPEN

'155. SH-V17B 2

OPEN 156. NDG-V3 10.5 CLOSE 157. HOG-V4 2

CLOSE 158. HDL-V49 2.0 OPEN 159. HDf.-V50 2.0 OPEN 160. HCt-V61 5.25 OPEN 161. HOL-V62 2.90 CLOSE 162. HDL-V89 14.5 OPEN

-163. HDL-V90 7.4 OPEN 164. HOL-V91 11.4 OPEN 165. HDL-V92 8.5 OPEN 166. HOL-V303 19.5 CLOSE 167. HDL-V304 2.0 CLOSE r

168. NDL-V534 11.1 CLOSE 169. HDL-V535 5.9 CLOSE 1

--,,---nr.,,~

-