ML20216G157

Rev 2.1 to Third 10-Yr Interval Inservice Insp Program

ML20216G157
Person / Time
Site:	Cooper
Issue date:	09/05/1997
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20216G155	List: ML20216G151 ML20216G157
References
PROC-970905, NUDOCS 9709120236
Download: ML20216G157 (48)

Text

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- Att:chment 2 to NLS970162 47 Pages Total Revision 2.1

~

to the Third Ten Year Interval Inservice Inspection Program rP n 88= ::8:8ive PDR

COOPER NUCLEAR STATION TillRD TEN YEAR INTERVAL INSERVICE TESTING PROGRAM Revision 2,1 This revision of the Third Ten-year Interval inservice Testing Program addresses the NRC comments on RV-14. Due to repagination pages 95 to 135 have been reprinted.

SECTION PAGE(S) DESCRIPTION Table of 11 Renumbered Contents V 17 Changed RV-14 to ROJ-21 V 51 Changed RV-14 to ROJ 21 V 95 Added ROJ-21 V 117 Added ROJ-21 V 118 Withdrew RV-14 V 135 Withdrew RV-14 J

NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION THIRD INTERVAL INSERVICE TESTING PROGRAM REVISION 2.1 i

COOPliR NUCLliAR STATION TillRD INTL!RVAL INSliRVICl? TliSTING PROGRAM V. VALVII SUMM ARY 1 lSTING l%GE A. Notations 1 IL Valve Summary Tables 4 C. Cold Shutdown Justifications 80 D. Refueling Outage Justifications 94

11. Valve Relief Requests 118 F. Augmented Valve Cold Shutdown Justifications 136 G. Augmented Valve Refueling Outage Justifications 144

11. Augmented Valve Relwf Requests 151 I

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Revision 2.1 Pageii

COOPER NUCLEAR STATION TIIIRD INTERVAL INSERVICE TESTING PROGRAM VALVE

SUMMARY

TABLES SYSTE3I: IIIGli PRESSURE COOLANT INJECTION (IIPCO

^ ^ ' NOTES / DESCRIPTION VRVE CIC P&lD CLASS CAT SIZE TYPE TYPE POS RQNIT FREQ COOR 2044 D9 2 AC 20 CK-S SA C 13-1 RF IIPC! TURBINE EXII AUST. ROJ4)3 IIPCI-CV-15CV FSO Q FSC RF 2044 F9 2 C 2 CK-P SA C I-SC RF IIPCI TURBINE EXIIAUST DRAIN TO llPCI CV-16CV SUPPRESSION POOL, ROJ4G i

l 2044 D6 2 C 4 CK-S SA C PSO Q IIPCI PUMP SilNIMUSl FLOW LINE.

l IIPCI CV-17CV I FSO RF ROJ4)3. ROJ-20 FSC RF B8 2 C 2 CK-P SA C FSC Q CONDENSATE SUPPLY TO IIPCI llPCI-CV-18CV 2044 SYSTEM. RV-07 A C 2 CK-P SA C FSC Q CONDENSATE SUPPLY TO IIPCI IIPCI-CV-19CV 2N4 B8 SYSTEM. RV417 2M4 E10 2 C 3 CK-S SA C VBT RF llPCI VACUUM BREAKER. ROJ-2i IIPCI-CV-24CV 2044 El1 2 C s CK-S SA C VBT RF IIPCI VACUUM BREAKER. ROJ-21 IIPCI CV-25CV 2M4 E10 2 C 3 CK-S SA C VBT RF If PCI VACUUM BREAKER. ROJ-21 l IIPCI-CV-26CV 2044 El1 2 C 3 CK-S SA C VBT RF IIPCI VACUUM BREAKER. ROJ-21 ilPCI.CV-27CV 2044 C9 i A/C 14 CK-S SA C LI-I RF INJECTION CllECK VALVE. CSI-02 11PCI-CV-29CV FSO CS j FSC CS PIT 2Y G3 2 B 10 GT MO C FSO Q STEAM SUPPLY TO TURBINE llPCI-MOV-M014 2041 PIT 2Y l

Section V Page 17 of 155 Revision 2 l

COOPER NUCLEAR STATION TIIIRD INTERVAL INSERVICE TESTING PROGRAM VALVE

SUMMARY

TABLES SYSTE31: REACTOR CORE ISOIATION COOLING (RCIC)

NOR VALVE CIC P&lD I I ^ ^ ^ 51 NOTES /DESCRIPI1ON COOR CLASS CAT SIZE TYPE TYPE RQNfT FREQ POS RCIC-CV-21CV 2N3 117 2 C 2 CK-P SA C PSO Q RCIC CONDENSATE PUh1P FSO RF DISCil ARGE, ROJ-17 FSC RF RCIC-CV-22CV 2N3 E10 2 C I 1/2 CK-L SA C VBT RF RCIC VACUUNI BREAKER. ROI-21 RCIC-CV-21CV 2N3 E10 2 C 11/2 CK-L SA C VBT RF RCIC VACUUh1 BREAKER. ROJ-21 RCIC-CV-24CV 2(M3 E10 2 C 11/2 CK-L SA C VBT RF RCIC VACUUNI BREAKER. ROJ-21 RCIC-CV-25CV 2(M3 E10 2 C 1 1/2 CK-L SA C VBT RF RCIC VACUUNI BREAKER. ROJ-21 RCIC-CV-26CV 2(M3 C9 I A/C 4 CK-S SA O U-l RF INJECTION CllECK VALVE. CSJ4)2 FSO CS FSC CS PIT 2Y RCIC-h10V-51015 2041 D6 1 A 3 GT A10 O LI-I RF RCIC STEAh11NBOARD ISOLATION 4

FSC Q PIT 2Y RCIC-510V-h1016 2041 D7 I A 3 GT 51 0 O U-l RF RCIC STEAh! OUTBOARD FSC Q ISOLATION PIT 2Y Revision 2 Section V Page 51 of 155

- COOPliR NUCLliAR STATION

TillRD INTliRVAL INS!!RVICli TliSTING PROGRAM ROJ 16 SLC-CV-12CV and St.C CV-13CV Testing Frequency ROJ-17

RCIC-CV-20CV and RCIC-CV-21CV Testing Frequency ROJ 18 RilR CV-10CV, RilR-CV llCV, RilR-CV-12CV, and RilR-CV-13CV-Testing Frequency

. RO' 19 'PC-CV-13CV and PC-CV-14CV Testing Frequency ROJ 20 llPCI-CV-17CV Testing Frequency ROJ-21 IIPCI CV-24CV, IIPCI-CV 25CV, llPCI CV-26CV, IIPCI-CV-27CV, RCIC-CV-22CV, RCIC-CV-23CV, RCIC-CV-24CV, and RCIC-CV-25CV f

7 Revision 2.1 - Section V Page 95 of 155

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COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAM REFUELING OUTAGE JUSTIFICATION ROJ-01 VAINE: CRD-CV-13CV, CRD-CV-14CV, CRD-CV-15CV, and CRD-CV-16CV CLASS: 1 CATEGORY: A/C FUNCTION: Containment isolation valves for Control Rod Drive (CRD) seal water injection for the Reactor Recirculation (RR) pumps.

REQUIRED

_ TEST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

HASIS FOR DEFERRAL: Exercising these valves to the closed position during normal plant operation would require stopping or reversal of seal water flow which would impose a severe thermal transient on the reactor recirculation pump seals resulting in premature seal failure. Drywell entry during cold shutdown would be necessary to facilitate testing, thereby requiring deinerting which could potentially delay restart. Valve exercising during cold shutdown when the drywell is deinerted, could also delay plant restart due to the necessity of using portable test equipment inside the drywell. The additional test activity during cold shutdown represents an unusual burden without a compensating increase in the level of quality and safety.

AllfERNATE TEST: The closure capability of these valves will be verified during refueling outages by performing a Type C local leak rate test per the requirements of OMa Part 10, 4.3.2.4 and the CNS Appendix J Program.

Revision 2.1 Section V Page 96 of 155

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i COOPliR NUCl.l!AR STATION

'lillRD INTliRVAL INSliRVICli TliSTING PROGRAM Ri!FUlil.ING OUTAGli.lUSTIFICATION ROJ-02 VAINil: llPCI CV.llCV CLASS: 2 CATl! GORY: C FUNCTION: Normally closed ilPCI pump suction line check valve from the suppression pool.

IUiQUIRl!D TEST-. OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DIIFliRRAl.: The IIPCI pump normally takes suction from the limergency Condensate Storage Tanks (liCST). When the !!CSTs reach low level the pump suction is automatically realigned to the suppression pool and llPCI CV-11CV opens. The i vahe is not equipped with position indication or a remote manual operator for exercising. The only method for exercising the valve during operation is to test it with flow. During performance testing the IIPCI pump discharges to the IICSTs.

Testing this valve with flow would result in a reduction of suppression pool inventory and the mixing of relatively impure water in the suppression pool with the liCST water.

Al.TF.RNATli TliST: The valve will be partially disassembled and manually exercised to the full open and closed positions during each refueling outap in accordance with the requirements of OMa Part 10, 4.3.2.4.

Revision 2.1 Section V Page 97 of 155 l

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l COOPliR NUCLliAR STATION TillRD INTL!RVAL INS!!RVICli TilSTING PROGRAM Ri!FUl! LING OUTAGliJUSTIFICATION ROJ-03 VALVII: IIPCI CV-15CV, ilPCI CV-16CV and IIPCI CV-17CV CLASS: 2 CATl! GORY: A/C and C FUNCTION: IIPCI CV 15CV - Opens to provide an exhaust path for the llPCI Turbine; closes for primary containment isolation, llPCI CV-16CV Water scaled coritainment isolation valve, llPCI-CV 17CV - Opens to provide a flowpath for llPCI pump minimum flow; closes to prevent diversion of RilR suppression pool cooling.

Rl!QUIRiiD I TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DliFl!RRAL: These valves are simple check valves, and thus, have no mechanism by which valve closure can be verified. Thus. the only practicable method of testing in the closed position is to impose a reverse differential pressure on the valve seat to verify closure capability or to measure the seat leakage.

Perfonning such a test renders the llPCI system inoperable, thus it is impracticable to perform during plan: operation. Performing such a test at cold shutdowns could increase and complicate the outage work scope considerably and prove to be an undue burden on the plant staff without a compen ating increase in the level of quality and safety.

ALTliRNATli TilST: The closure capability of these valves will be verified each refueling outage during the performance of leak rate testing (15CV) per the CNS Appendix J Program or by demonstrating the ability to maintain a differential pressure across the valve seat (16CV and 17CV).

Revision 2.1 Section V Page 98 of 155 p

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COOPIIR NUCl. EAR STATION TillRD INTL!RVAL INSI!RVICE TliSTING PROGRAM REFUEL.ING OUTAGli JUSTIFICATION ROJ-04 VALVil: IIPCI V-44 and IIPCI V 50 CLASS: 2 CATEGORY: A/C FUNCTION: IIPCI V-44 is a containment isolation globe stop check from the llPCI turbine exhaust to the suppression pool.

IIPCI V 50 is a water scaled containment isolation globe stop check valve from the llPCI turbine drain to the suppression pool.

These valves are normally closed and the manual operators are locked in the open position to allow free disk movement. They open during IIPCI pump eperation and are required to close for containment isolation.

RiiQUIRiiD /

TEST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4,3.2.5.

IIASIS FOR DiiFERRAL: The operators on these valves are manual operators. Exercising these valves closed

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during plant operation or cold shutdown could result in undetened valve failure.

Since the valve disk is not connected to the valve stem, the disk cannot be moved to the open position by stem manipulation. The disk can, however, be forced shut by the manual operator, if the disk should stick shut, the failure would go undetected until the turbine was operated. This would result in llPCI being unavailable to perform its safety function. llaving IIPCI unavailable, should an accident occur, could lead to reactor damage and potential release of radioactive material.

ALTERNATE TEST: The closure capability of these valves will be verified each refueling outage during the perfonnance of leak rate testiig (V-44) per the CNS Appendix J Program or by demonstrating the ability to maintain a differential pressure across the valve seat (V-50).

Revision 2.1 Section V Page 99 of 155

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COOPliR NUCl.IIAR STATION TillRD INTIIRVAl, INSIIRVICl! TliSTING PROGRAM  ;

I RI!FUlit.ING OUTAGl! JUSTIFICATION ROJ 05 VAINiiS: IA CV-65CV and IA CV-78CV ,

-1 CI A S: 2 CATliGORY: A/C  ;

FUNCTION: These check valves have an active safety function in the closed position to provide ,

containment isolation on the instrument air / nitrogen line which is the pneumatic

supply to the MSIVs and SRVs h>cated inside primary containment.

RI!QUIRl!D .

Tl!ST

OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and i

4.3.2.5.

HASIS FOR Dl!Fl!RRAl.: These check valves are not provided with position indication. Therefore, exercising these check valves to the closed position would require isolating the ,

downstream piping and applying an outside pressure source while venting the ,

upstream piping. This test method would allow establishing a differential pressure -

across the valve seat to verify closure. This is not practicable during normal plant operation or cold shutdoi ns due to the hwation of the manual valve provided for downstream isolation, which is kicated inside the drywell, lintry into the drywell during power operation is not possible due to an inerted atmosphere and high levels of radiation. Valve exercising during cold shutdown, when the drywell is de-inerted, could potentially delay plant restart due to the installation of temporary test equipment.

ALTliRNATl!

TI!ST: The closure capability of these valves will be verified during refueling outages by performing a Type C, local leak rate test per the requirements of OMa Part 10,

- 4.3.2.4 and the CNS Appendix J Program,  ;

Revision 2.1 Section V Page 100 of 155

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C00Plift NtJCI.liAlt STATION TillitD INTliitVAl, INS!!!(VICli TliSTING PiloGitAh!

Ill!FlJI!1.ING Ol1TAGl! JtJSTIFICATION 110J-06 VAINii: Nill-CV-4911CV, Nill CV 50llCV, Nill CV-5111CV, Nill CV-52!!CV Nill SOV SSV738, and Nill SOV-SSV739 CIASS: 3 CATl!GoltY: C and 11 FlJNCTION: The reference leg injection check valves and solenoid operated valves have an active safety function in the open position to inject Core Spray water to the r; actor vessel level instmmentation lines in case the reference leg water has flashed or boiled off due to accident wnditions in the drywell.

Ill!QlJIRl!D TliST: Ohia Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

Ohia Part 10,4.2.1 requires Category A and 11 power operated valves to be individually full stroke exercised and stroked timed nominally every 3 months, except as provided by paragraphs 4.2.1.2, 4.2.1.5, and 4.2.1.7.

Ohia Part 10,4.2.1.6 requires valves with fail safe actuators shall be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of paragraph 4.2.1.1.

IIASIS Folt Dl!FliitRAl.: This system provides the capability for the Core Spray System to supply a backfill of water for maintaining inventory of the Nuclear lloiler Instrumentation System cold reference legs (condensing chambers 3A and 311) during accident conditions in the drywell where the reference leg inventory could be compromised. lixercising these valves to the open position, full or partial, would require manually isolating and venting the Cold iteference Ixg llackfill System. This is not practicable during power operation or cold shutdown, other than refueling, due to the possible introduction of air into the system. This could cause a spurious reactor vessel level indication which could cause a reactor trip during powr: operation. During cold shutdown spurious level indications could interrupt the operation of systems required for decay heat removal, thereby placing the reactor in an unsafe condition. During refueling outages, sufficient time exists for decay heat to be reduced to llevision 2.1 Section V Page 101 of 155

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COOPliR NUCLIIAR STATION TillRD INTliRVAl, INS!!RVICl! TliSTING PROGRAM RiiFUlil.ING OUTAGl! JUSTIFICATION ROJ-06 (Continued) a level which minimites the impact of momentary interruption in the operation of systems required for decay heat removal such that testing can be performed.

ALTliRNATl!

Tl!ST: lixercis,ing these check valves to the full open position, and full exercising with stroke timing to the open position of the solenold operated valves, shall be perfonned during refueling outages.

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7 I

Revision 2.1 Section V Page 102 of 155

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C00PliR NUCl. liar STATION TillRD INTliitVAl.

INS!!RVICl! TliSTING PROGRAM HliFtliii. LNG 011TAGli JtJSTIFICATION ROJ-07 VAIN!!(s): Nill CV 55CV and Nlll CV-56CV CIASS: 3 CATl! GORY: C FtJNCTION: These Cold Reference leg Continuous llackfill System check valves have an petive safety function in the closed position to isolate the Class 3 instrumentation piping from the Seismic ilS non-class CRD piping.

RiiQUIRl!D TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and ,

4.3.2.5.

I IIASIS FOR DliFl?RRAl.: This system provides for a continuous flow of water from the CRD drive water pumps to prevent noncondensible gases from building up in the Nuclear lloiler instrumentation System cold reference legs (condensing chambers 3A and 311).

I!xercising these valves to the closed position would require manually isolating and venting of the Cold Reference Ixg Continuous llackfill System upstream of the check valves. This is not practicable during power operation or cold shutdown, other than refueling, due to the possibility of causing a spurious reactor vessel level  !

indication from entrained air in the system. False level indications resulting from entrained air in the system may either cause a reactor trip during power operation or interrupt the operation of systems required during cold shutdown for decay heat removal, thereby placing the reactor in an unsafe condition. During refueling outages, sufficient time exists for decay heat to be reduced to a level which minimizes the impact of momentary interruption in the operation of systems required for decay heat removal such that testing can be performed.

AIX11RNATl!

TliST: lixercising these check valves to the closed position shall be performed during refueling outages, lixercise testing shall be accomplished by perfonning a seat leakage test.

Revision 2.1 Section V Page 103 of 155

COOPlill NUCLliAlt STATlON Tilll(D INTliitVAl.

INSliitVICl! TliSTING PI(OGitAM ltlil:Ulil.ING OUTAGl! JUSTil lCATION 1(03-08 VAI.VI!: PC-CV 21CV, PC-CV 22CV, PC CV-23CV, PC-CV-25CV, PC-CV-26CV, and PC-CV 27CV Cl ASS: 2 CATl!GoltY: A/C ,

1: UNCTION: The drywell 11/0 2 2monitors nitrogen purge supply check valves perform an active safety function in the closed position to maintain primary containment integrity.

These valves function in the open position only to supply nitrogen or oxygen to the 11/0 2 2monitors for calibration and functional testing which is not a safety function.

1(l!QUll(lid TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 7

4.3.2.5.

IIASIS 1:011 Dlil lillitAl.: li.v.ercising these check valves to the closed position would require isolating the 11/0 2 2monitors from the drywell and suppression chamber atmosphere and applying an outside pressure source downstream of the check valves while venting the upstream piping. Performing this test activity during normal plant operation or cold shutdowns would require the removal of the 11/0 2 2 Monitoring System from k service during conditions when primary containment integrity is required. Plant Technical Specifications Tables 3.2.1: and 3.2.11 identifies the 11/02 2 monitors as surveillance instmmentation required for the assessment of the containment atmosphere by monitoring the hydrogen and oxygen concentrations. Testing these valves during conditions when 11/0 2 2 operability is required would result in a reduction in safety and would not provide a significant increase in assurance of continued operability.

Alll'liltNATl!

TIIST: The closure capability of these check valves will be verified by local leak rate testing them as a group at least once each refueling outage or whenever the system is opened. if the system is opened, the 11/0 2 2 monitoring system shall be local leak rate tested prior to resumption of service, llevision 2.1 Section V Page 104 of 155 l

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COOPlift NUCl.liAlt STATION Tilll(D INTliRVAL INS!!RVICli TliSTING PROGRAM Rlil Ulil.ING OUTAGli JUSTil lCATION ROJ-09 VAINE: RCIC-CV-IICV CLASS: 2 CATl! GORY: C I; UNCTION: Normally closed 1(Cic pump suction line check valve from the suppression pool.

l(l!QUIRl!D Tl!ST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS 1 OR Dlil 1!RRAl.: The RCIC pump normally takes suction from the limergency Condensate Storage .

Tanks (liCST). When the !!CSTs reach low level the pump suction is /

automatically realigned to the suppression pool and 1(CIC.CV-1 ICV opens. The valve is not equipped with position indication or remote manual operators for exercising. The only method for exercising the valve during operation is to test it with flow. During performance testing the RCIC pump discharges to the liCSTs.

Testing this valve with 110w would result in a redaction of suppression pool inventory and the mixing of relatively impure water in the suppression pool with the !! CST water.

Al TliRNATl!

Tl!ST: The valve will be partially disassembled and manually exercised to the full open and closed positions during each refueling outage in accordance with the requirements of OMa Part 10, 4.3.2.4.

Revision 2.1 Section V Page 105 of 155

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l COOPl!R NUCLliAR STATION TillRD INTL!RVAI, i INSliRVICl! TliSTING PROGRAM  ;

Rl!FUl! LING OUTAGliJUSTil lCATION ROJ 10 l VALVliS: RCIC CV-12CV, RCIC-CV-13CV, and RCIC CV-15CV CLASS: 2 CATl! GORY: C and A/C FUNCTION: RCIC-CV-12CV water scaled valve; closes for containment isolation.

RCIC-CV-13CV - Opens to provide a 110wpath for RCIC pump minimum flow:

rioses to prevent diversion of RilR suppression pool cooling flow.

RCIC CV 15CV - Opens to provide an exhaust path for the RCIC turbine; closes for primary containment isolation.

RiiOUIRl!D TliST: OMa Part 10, 4.3 2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

i ilASIS FOR DliFliRRAL: These valves are simple check valves, and thus, have no inechanism by which valve closure can be verified. The only practicable method of testing in the closed position is to impose a reverse differential pressure on the valve seat to verify closure capability or to measure the seat leakage.

Perfonning such a test renders the RCIC system inoperable, it is impracticable to perfonn this test during plant operation. Performing such a test at cold shutdowns could increase and complicate the outage work scope considerably and prove to be an undue burden on the plant staf f without a compensating increase in the level of quality and safety.

ALTl!RNATl!

TliST: The closure capability of these valves will be verified each refueling outage during the perfonnance of leak rate testing (15CV) per the CNS Appendix J Program,0:

by demonstrating the ability to maintain a differential pressure across the valve seat (12CV and 13CV).

I Revision 2.1 Section V Page 106 of 155 o

COOFER NUCl. liar STATION TillRD INTERVAL INSliRVICl! Tl! STING PROGRAM Ri! FUEL.ING OUTAGliJUSTIFICATION ROJ 11 VALVE: RCIC-V-37 and RCIC V-42 CLASS: 2 CATEGORY: C FUNCTION: RCIC-V-37 is a containment isolation globe stop check from the RCIC turbine exha/.st to the suppression pool.

RCIC V-42 is a water scaled containment isolation globe stop check valve from the RCIC vacuum pump to the suppression pool.

These valves are normally closed and the manual operators are locked in the open position to allow free disk movement. They open during RCIC pump operation and are required to close for containment isolation.

REQUIRl!D OMa Part 10, 4.3.2.1 requires check valves to be individually exercised TEST: nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3, i 4.3.2.4, and 4.3.2.5.

IIASIS FOR DliFERRAl.: The operators on these valves are manual operators. fixercising these valves closed during plant operation or cold shutdown could result in undetected valve failure. 1 Since the valve disk is not connected to the valve stem, the disk cannot be moved to the open position by stem manipulation. The disk can, however, be forced shut by the manual operator, if the disk should stick shut the failure would go undetected until the turbine was operated. For RCIC-V-37 this would result in RCIC being unavailable to peiform its design function. Although RCIC does not have a safety function, it does provide cooling water when feedwater is unavailable. Failure of RCIC-V-42 to open would not prevent the RCIC system from operating, but would prevent the reqmval of noncondensible gases from the barometric condenser.

Alli'ERNATl!

TEST: The closure capability of these valves will be verified each refueling outage during the performance of leak rate testing (V-37) per the CNS Appendix J Program or by demonstrating the ability to maintain a differential pressure across the valve seat (V-42).

Revision 2.1 Section V Page 107 of 155

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COOPliR NUCl. EAR STATION l TillRD INTliRVAl,  !

, INSERVICE TliSTING PROGRAM i i

Rl! FUEL.ING OUTAGE JUSTIFICATION ROJ 12 VALVE: REC-CV-16CV Cl. ASS: 3 CATliGORY: C FUNCTION: This valve closes to prevent back flow into the non-critical Reactor Equipment Cooling (RiiC) return header from the suction of the REC pumps.

Rl!QUIRl!D TEST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DEFERkAL: Testing this valve in the closed direction requires depressurization of the non-critical REC return header, This, in turn, would interrupt cooling to important equipment, including the CRD pumps, RWCU pumps and heat exchangers, drywell ventilation coolers, reactor recirculation pumps, and the recirculation pump motor generator sets. This could not be done during normal operation without subjecting major equipment to damage from overheating. Exercising this check valve during cold shutdown would require the intermption of equipment operation which is normally maintained in service, e.g. RWCU, which is required to maintain water chemistry. Otherwise, testing during cold shutdown when component operability is not necessary would still require depressurization of the non-critical header which could delay plant restart and represents an unusual burden without a compensating increase in the level of quality and safety.

AlifliRNATl!

TEST: The closure capability of this valve will be verified at least once cach reactor refueling outage.

Revision 2.1 Section V Page 108 of 155

C00PliR NUCI. liar STATION TillRD INTliRVAL INSI!RVICl! TliSTING PROGRAhl Rl!FUIII. LNG OUTAGli JUSTIFICATION ROJ 13 VAIN!!: Ria-CV-13CV, RF-CV-14CV, RF CV 15CV, and RF-CV-16CV Cl. ASS: 1 CATl! GORY: A/C FUNCTION: hiain Feedwater check valves open to allow normal feedwater flow. Additionally, 14CV and 16CV open to allow IIPCI and RCIC flow, respectively. These valves must be capable of closure to provide containment isolation. Additionally,13CV and 15CV must be capable of closure to prevent diversion of IIPCI and RCIC flow, respectively.

RiiQUIRl!D TliST: Ohia Part 10, 4.3.2.1 requires check valves to b.: individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DliFl!RRAl.: These valves are normally open and must remain open during reactor operations to ensure adequate feedwater flow. Feedwater provides normal reactor core cooling during operation. lixercising these valves during plant operation could cause a transient in reactor water level resulting a reactor scram. The observation of specified leakage during hical leak rate testing provides the only means for verification to the closed position.

Al.TliRNATl!

TliST: These valves will be exercised to the closed position during the Type C leak rate test performed each refueling outage in accordance with the requirements of Ohta Pan 10,4.3.2.2 and the CNS Appendix J Program.

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COGPliR NUCLliAR STATION TillRD INTL!RVAL INSliRVICl! TliSTING PROGRAM Rlil:Ulil.ING OUTAGli JUSTIFICATION ROJ 14 VAINII: RF CV 14CV and RF CV-16CV Cl. ASS: 1 CATIIGORY: A/C l: UNCTION: Open to provide a flowpath for llPCI (RF-CV-14CV) or RCIC (RF-CV-16CV) to the reactor vessel.

Rl!QUIRiiD TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR Dlil liRRAl.: The feedwater injection check valves are nonnally open during plant operation due to feedwater flow. Ilowever, individual flow rate cannot be measured during nonnal operation due to system configuration. These valves are located inside the drywell and are not accessible during nonnal operation or during cold shutdowns unless the drywell is de-inerted.

Al.Tl!RNATl!

TliST: Although these valves are verified open by the nonnal operation of the feedwater system, these valves will be verified to open to pass the required ilPCI and RCIC flows during refueling outages by either a flow test or by valve disassembly and inspection.

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COOPliR NUCl.l!AR STATION TillRD INTliRVAI, INSliRVICl! TliSTING PROGRAM Rl!FUI!!.ING OUTAGli JUSTIFICATION ROJ 15 VAIN!!S: RWCU-CV-15CV Cl, ASS: 1 CATl! GORY: A/C FUNCTION: Normally open Reactor Water Cleanup (RWCU) return line check valve and containment isolation valve.

Rl!QUIRIiD Tl!ST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DliFl!RRAl.: This valve cannot be verified as being closed upon reversal or stopping of flow without opening and venting the line upstream of the check valve. Opening or venting the RWCU line during operations could cause a leak of high pressure reactor coolant and potentially lead to the release of radioactive material.

Stopping RWCU now during normal operations or cold shutdown for an extended period would lead to a degradation of reactor water purity. This would add to the radioactive contamination in the reactor coolant system and could lead to additional exposure of site personnel. It is essential that RWCU remain in operation as much as possible and RWCU-CV 15CV be exercised to the closed position only during refueling outages.

Al.TliRNATl!

TliST: The closure capability of RWCU-CV-15CV will be verified during refueling outages by performing a Type C local leak rate test per the requirements of OMa Part 10, 4.3.2.4 and the CNS Appendix J Program.

Revision 2.1 Section V Page 111 of 155

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COOPl!R NUCLilAR STATION  !

TillRD HTliRVAL l INSliRVICl! TliSTING PROGRAM l i

REFUlil.ING OUTAGli JUSTIFICATION ROJ 16 VALVis: SLC CV 12CV and SLC CV 13CV CLASS: 1 CATl! GORY: A/C FUNCTION: Inboard and outboard containtnent isolation valves which must open to allow injection of sodium pentaborate (neutron poison) for reactivity control. The injection of the neutron poison is not a safety function, but may be required in emergency situations. These valves must be capable of closure to provide containment isolation.

REQUIRiiD TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and ,

4.3.2.5.

IIASIS FOR DliFliRRAL: These valves are normally closed with reactor pressure on the downstream side, fixercising these valves to the closed position during power operation would require drywell entry for the inboard valve and breach of reactor coolant pressure boundary when testing either valve. This is not practicable due to inaccessibility created by the inerled environment and the potential for a reicase of radioactivity as a result compromising the two-valve RCS isolation barrier. Valve exercising during cold shutdown, when the drywell is deinerted, could delay plant restart due to the necessity of using portable test equipment inside the drywell. The additional test activity during cold shutdown represents an unusual burden without a compensating increase in the level of quality and safety.

ALTERNATli TliST: The closure capability of the SLC check valves will be verified during refueling outages by performing a Type C, local leak rate test per the requirements of OMa Part 10,4.3.2.4 and the CNS Appendix J Program.

Revision 2.1 Section V Page 112 of 155

COOPER NUCl.11AR STATION TillRD INTEkVAl.

INSliRVIC6 Tl! STING PROGRAM Rl!FUlil.ING OUTAGli JUSTIFICATION ROJ-17  :

VA!Nii: RCIC CV 20CV and RCIC-CV 21CV Cl. ASS: A. 2 CATliGORY: C FUNCTION: Reactor Core isolation Cooling (RCIC) condensate pump discharge check valves.

These valves open to provide a flow path for the RClc condensate pump discharge, and RCIC-CV-21CV closes to prevent diversion of RCIC pump suction flow.

RiiQUIRl!D Tl!ST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DliFliRRAl.: These valves are normally closed check valves (in series). They open to provide a flow path for the RCIC condensate pump discharge. There is no practical means to verify sulficient flow to full-stroke exercise these valves open. System configuration and absence of appropriate instrumentation prohibits full stroke open verification.

Should the RCIC condensate pump fail to start, RCIC-CV-21CV closes to prevent diversion of RCIC pump suction flow. The current system design does not allow testing to ensure the valve has closed.

Al.TIIRNATl!

TliST: The valves will be disassembled, inspected, and manually exercised during refueling outages. In addition, a partial stoke exercise test to the open position will be performed quarterly and after each disassembly and inspection.

Revision 2.1 Section V Page 113 of 155

COOPliR NUCl. liar STATION TillRD INTL!RVAl.

INS!!RVICl! TliSTING PROGRAM i

Rl!FUlILING OUTAGli JUSTIFICATION ROJ 18 l l

VAIN!!: RilR CV-10CV, RilR-CV-IICV. RilR CV 12CV, and RilR-CV.13CV CLASS: 2 CATliGORY: C l I; UNCTION: Open to provide a flow path for RilR pump minimum flow.

RiiQUIRl!D Tl!ST: OMa Part 10, 4.3 2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR DiiFliRRAL: There is no practical means of verifying suf ficient flow to full-stroke exercise the valves open. System configuration and absence of appropriate instrumentation prohibits full-stroke open verification.

All!'liRNAT!!

Tl!ST: A dif ferent valve will be disassembled, inspected and manually exercised during each refueling outage until the entire group has been tested, if the disassembled

, valve is not capable of being full-stroke exercised or there is binding or failure of valve internals, the remaining valves in that group will also be disassembled, inspected and manually exercised during the same outage. In addition, a partial stroke exercise test, with flow, will be performed quarterly, and after each disassembly / inspection.

Revision 2.1 Section V Page 114 of 155

COOPER NUCl.!!AR STATION TillRD INTliRVAL INSliRVICli TliSTING PROGRAM Rl!FUlit.ING OUTAGli JUSTIFICATION ROJ.19 VALVil: PC-CV 13CV and PC-CV-14CV Cl. ASS: 2 CATl! GORY: A/C FUNCTION: Open to provide vacuum reller for the suppression chamber.

Rl!QUIRl!D

'lliST: OM Part 1,1.3.4.3 requires primary containment vacuum relief valves to have individual operability tests nominally every 6 months.

IIASIS FOR Dlil:liRRAL: These check valves open to provide assurance that the suppression chamber is not operated at a significantly lower pressure than the reactor building. They are not equipped with external operators for testing. These valves are located on top of the suppression chamber and are part of the primary containment boundary.

Access to these valves is hazardous to personnel because there are no permanently installed walkways or handrails above the suppression chamber. These valve are not located in an environment that would degrade the valve seals. The valves are normally closed and are only opened for testing. A test frequency of every 6 months represents an unusual burden without a compensating increase in the level of quality and safety.

ALTl!RNATli TliST: The reactor building to suppression chamber vacuum relief valves will be operability tested each refueling outage in accordance with OM Part 1,3.3.2.3.

Revision 2.1 Section V Page 115 of 155 L

COOPI',R NUCLilAR STATION TillRD INTL!RVAl.

INSliliVICl! TI! STING PROGRAM RI!!:Ul! LING OUTAGl! JUSTil lCATION ROJ 20 VALVli: llPCI CV.17CV CLASS: 2 CATl! GORY: C FUNCTION: IIPCI CV-17CV - Opens to provide a flowpath for llPCI pump minimum flow; closes to prevent diversion of RilR suppression pool cooling.

RiiQUIRiiD TliST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

HASIS FOR Dl!FliRRAL: There is no practical means of verifying sufficient flow to full stroke exercise this valve open. System configuration and absence of appropriate instrumentation prohibits full stroke open verification.

AllfliRNATl!

Tl!ST: The valve will be disassembled, inspected and manually exercised during each refueling outage in addition, a partial stroke exercise test, with flow, will be performed quarterly, and after each disassembly /inslwetion.

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COOPl!R NUCl l!AR STATION -

TillRD INTliRVA1.  !

INSliRVICl! TliSTING PROGRAM i

i  !

Rl!FUl! LING OUTAGliJUSTIFICATION ROJ 21 l VAIN!!: ilPCI CV 24CV, llPCI CV 25CV. IIPCI CV 26CV, llPCI CV 27CV, RCIC. ~i CV-22CV, RCIC-CV 23CV, RCIC CV-24CV, and RCIC-CV 25CV  ;

CLASS: - 2' CATliGORY: C FUNCTION. IIPCI and RCIC Turbine lixhaust 1 ine Vacuum lireakers open to prevent siphoning suppression pool water into the exhaust line.  :

Rl!QUIRl!D TF.ST: OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally-every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and  !

4.3.2.5. ,

D/.SlS FOR  ;

L DliFliRRAI.: These valves are nonnally closed check valves with two in series cross connected [

RIILil!F: to two in parallel (11 pattern). The four RCIC valves are lift check valves, and the four ilPCI valves are swing check valves. The valves are located in the

. suppression pool free space in the closed position they prevent steam from the

exhaust line entering the free space of the suppression chamber. !!ither two inboard valves or two outboard valves must be closed to perfonn this function. .

Two valve:: in series provides added assurance that steam will not enter the suppression chamber.

The valves open to prevent siphoning suppression pool water into the exhaust line i due to steam condensing when the associated IIPCI or RCIC systems are isolated.

F.ach pair of valves is cross connected to the parallel pair of valv.cs (11 pattern) so that'a single failure will not prevent the vacuum relief function. These valves are j not required to be leak tight and are not equipped with position indication or i pressure sensing devices. During power operation the suppression chamber is 4

- inerted and inaccessible.

Due to the h> cation and configuration of these valves (located on the open ended 4

turbine exhaust lines) a closure test can not be performed.- ,

4 ALTl!RNATE TilST: IIach vaIve will be disassembled, inspected, and manually exercised open and closed during each refueling outage.

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COOPliR NUCLl!AR STATION TillRD INTI!RVAL  :

INSliRVICl! Tl! STING PROGRAM

11. Valve Relief Requests IUL&L .n s dpflun Noms RV 01 Ilot Shutdown Component Testing 1 RV-02 CRD AOV-CV126. CRD AOV-CV127, and CRD-CV- 2 114CV (typical of 137) lixercising !!y Scram Testing ,

RV-03 CRD CV 115CV (typical of 137) Testing to the Closed 2 Position RV 04 CRD CV 138CV (typical of 137) Test Metlux! 2 RV-05 CRD SOV-SO120 SO121. S0122, and SO123 (Typical 2 of 137) Test Mellux!

RV-06 CS CV-12CV, CS-CV-13CV, CS CV-14CV, and CS-CV-15CV Testing to the Closed Position RV 07 IIPCI CV-18CV and 19CV Testing to the Closed Position RV 08 IIPCI SOV-SSV64 and SSV87 Stroke Timing Alternative 3 RV-09 MS RV-71 ARV to 7111RV livercising Testing Frequency 3 RV-10 I!xcess Flow Check Valves Testing Per Technical 4 Specifications RV-I l RCIC-CV-18CV and 19CV Testing to the Closed Position HV-12 RilR CV 18CV,19CV,24CV, and 25CV Testing to the Closed Position RV-13 SW-MOV MO89A and MO8911 Testing Relief 3 RV-14 Withdrawn Noirs 1 NRC Approval not required (TAC NO. M94530) 2 Approved by NRC letter dated February 19,1997 (TAC NO. M94530)

Revision 2.1 Section V Page 118 of 155

COOPliR NUCl. EAR STATION TillRD INTI!RVAL INSI!RVICl! TliSTING PROGRAM 3 Revised to address NRC conunents.

4 Acceptable per OM 10. NRC approval not required (TAC No, M94530)

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Revision 2.1 - Section V Page 119 of 155

l COOPIIR NUCl.!!AR STATION l TillRD INTliRVAl, i INS!!RVICli TliSTING PFOGRAM Rlil.IliF RI!QUliST RV-01 VAINil: Non-component Specine I CLASS: All CATl! GORY: All FUNCTION: Various RiiQUIRiiD Tl!ST: OMa Part 10 provides the rules and requirements for inservice testing to verify operational readiness of certain valves (and their actuating and position indicating systems) in light water cooled nuclear plants, which are required to perfonn a specific function in shutting down a reactor to the cold shutdown condition, in maintaining the cold shutdown condition, or in mitigating the consequences of an accident.

IIASIS FOR Riii.Il!F: Cooper Nuclear Station's accident analyses do not carry the response to an accident (e.g. Design Ilasts 1.OCA) to a point beyond the hot shutdown condition (i.e., to a cold shutdown condition). The licensing basis does not require the plant to go to the cold shutdown condition in order to satisfy 10CFR100 radiological release guidelines.

Since Safe Shutdown is defined in the CNS licensing basis as the hot shutdown condition, inservice testing of components which are required to achieve cold shutdown is unwarranted, and does not provide any increase in the level of program quality or safety to the public.

Allfl!RNATli TliST: Cooper Nuclear Station's inservice Testing (IST) and Augmented Testing Programs will implement the rules and requirements for inservice testing to verify

- operational readiness of certain Class 1,2,3 and Non-Code Class valves (and their actuating and position indicating systems) which are required to perform a specific function in shutting down the reactor to the safe shutdown (hot shutdown) condition, in maintaining the hot shutdown condition, or in mitigating the consequences of an accident.- Components which support achievement of cold

- shutdown only, are not required to be included in the IST or Augmented Test Programs.

Revision 2.1 Section V Page 120 of 155

COOPl!R NUCLEAR STATION TillRD INTERVAL INSliRVICE TESTING PROGRAM RELIEF REQUEST RV-02 VAINE: CRD AOV CV126. CRD-AOV CV127, and CRD-CV-114CV (typical of 137)

CLASS: 1, 2 CATEGORY: II, C FUNCTION: CRD AOV CV126 - Open with a scram signal to pressurize the lower side of the CRDM pistons from the accumulator or from the charging water header.

CRD-AOV-CV127 - Open with scram signal to vent the top of the CRDM pistons to the scram discharge header.

CRD-CV 114CV (typical of 137)- Open to allow How from the top of the CRDM pistons to the scram discharge header.

Rl!QUIRl!D 1) OMa Part 10, 4.2.1.1 requires Category A and H power operated valves to be /

TEST: Individually full stroke exercised nominally every 3 months, except as provided by paragraphs 4.2.1.2. 4.2.1.5, and 4.2.1.7.,

2) OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3, 4.3.2.4, and 4.3.2.5. ,

HASIS FOR Rl! LIEF: These valves are required to operate for rapid insertion (scram) of control rods.

Each valve is tested by scram timing control rods in accordance with Technical Specification Sections 3,3 and 4.3. The Technical Specifications require testing 10 percent of the CRDs every 16 weeks and 100 percent of the drives each refueling.

The CRDs must fully insert within specified time limits. Should either the insert or exhaust valves fall, the CRDs would not be able to meet Technical Specification requirements.

The air-operated valves fail-open on loss of air or power. Normal opening removes power to the pilot solenoid valve, simulating a loss of power. On loss of power, the solenoid vents the air operator and CRD AOV-CV126 and CRD AOV-CV127 are spring-driven open. Thus, each time a scram signal is Revision 2.1 Section V Page 121 of 155

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i COOPlill NUCl.l!All STATION TillitD INTliitVAL INSliitVICli Tl! STING PitOGitAM lll!Lilil' lll!QUliST ltV 02 (Continued) given, the valves " experience" a loss of air / power to verify each valvc's fail safe open feature. In elfeet, scram testing meets or exceeds the functional testing requirements of Section XI to assess operational readiness. Individt"d stroke time measurements of CRD-AOV-CV126 and CitD-AOV-CV127 are impracticable due to their rapid acting operation.

One hundred percent of the valves cannot be tested more often than each refueling outage. Testing 1(X) percent of the valves simultaneously would result in a full reactor scram. An excess number of scrams performed routinely could cause thermal and reactivity transients, which could lead to fuel, vessel, CitD, or piping damage. The CitDs cannot be tested during cold shutdown because the control rods are inserted and must remain inserted. This testing method for the valves is consistent with GL 89 04, position 7.

Al!!'liltNATl!

TliST: Scram testing per Technical Specifications will be substituted for all Section XI requirements. The test frequency will be 10% each 16 weeks and 100% cach refueling cycle. Vaive stroke times will not be measured. This testing methm! is consistent with GL 89-04, position 7.

llevision 2.1 Section V Page 122 of 155

COOPliR NUCLliAR STATION TillRD INTL!RVAL INSliRVICl! TliSTING PROGRAM lilillliF Rl!QUliST RV-03 VAINii. CRD-CV-115CV (typical of 137)

CLASS: 2 CATliGORY: C FUNCTION: Prevent bypassing scram water (from the accumulator) to the charging water header (if depressurized).

RiiQUIRi!D OMa Part 10, 4.3.2.1 requires check valves to be individually exercised TliST: nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3, 4.3.2.4, and 4.3.2.5.

IIASIS FOR lixercising these valves requires the depressurization of the charging water RiiLil!F: header. The header is depressurized by either stopping the CRD pumps or by valving out and depressurizing the charging water header. Stopping the CRD pumps could result in seal damage to the control rod drive mechanisms (CRDM) from a loss of seal cooline water. Additionally, stopping the pumps would interrupt seal cooling water now to the reactor recirculation pumps resulting in shaft seal damage. This is impracticable during normal plant operation since valving out and depressurizing the charging water header would render the CRD accumulators inoperable and stopping th: CRD pumps could cause pressure variations in the CRD System during the test evolution.

lixercising these valves during cold shutdown is not possible due to the interruption of shaft seal cooling water flow as previously discussed. If the recirculation pump became idle stopping the CRD pumps or manually isolating the charging water header for reverse exercise testing could delay plant startup due to the necessity of depressurizing upstream of each individual valve (137 each) in order to accomplish an adequate test. This additional test activity during cold shutdown represents an unusual burden without a compensating increase in the level of quality and safety.

This testing method for the charging water header check valves is consistent with GL 89 04, position 7.

ALTliRNATl!

TliST: These valves will be tested during each reactor refueling ou: age. Proper closure shall be verified by isolating each of the CRD scram accumulators and venting pressure on the upstream side of the check valve, Accumulator pressure decay would be observed should the respective valve fail to close properly.

Revision 2.1 Section V Page 123 of 155 l

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COOPlill NUCl.liAll STATION TillllD INTlillVAl.

INSlil(VICl! TliSTING Pl(OGilAM 4

1(lil.lliF 1(liQUl!ST 1(V-04 VAINiiS: CilD CV 138CV (typical of 137)

ClA SS: 2 CATliGOl(Y: C 1: UNCTION: Close in the event of a scram to prevent diversion of pressurized llCU accumulator water to the cooling water header.

1(liQUll(lid Tl!ST: OMa Part 10, 4.3.2.1 requites check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS 1 Olt 1(lit.IliF: Normal control rod motion will verify that the associated cooling water check valve has moved to the safety function position industry experience has shown that rod motion may not occur if this check valve were to fail in the open position.

This testing method for the cooling water header check valves is consistent with Gl,894M, position 7.

4 Al!Ilil(NATli '

TliST: During normal plant operation above 30 percent power, each partially or fully withdrawn operable control rod is exercised one notch at least once each week (Technical Specification 4.3. A.2). A cooling water header check valve is verified closed when the associated control rod is successfully exercised, llevision 2.1 Section V Page 124 of 155

COOPER NUCI. EAR STATION TillRD INTI RVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV 05 VALVES: CRD-SOV-SO120, S0121, SO122, and SO123 (Typical of 137)

CLASS: 1 CATEGORY: 11 UUNCTION: Close to provide Class 1 to Non Code Class boundary isolation.

REQIllRED

, TliST: OMa Part 10, 4.2.1.1 requires Category A and Il power operated valves to be individually full stroke exercised nomit Ily eveiy 3 months, except as provided by

} part. graphs 4.2.1.2, 4.2.1.5, and 4.2.1. /.

n BASIS FOR 7 I RELIEF: During normal operation these valves are used for control rod insertion and withdrawal. They are normally closed and muct remain closed to prevent diverting  ?

water during a scram. They are exercised open and closed during normal L

operation of the associated CRD. They are not equipped with position indication.

t This testing method for the CRD insert and withdrawl solenoid valves is consistent with GL 89-04, position 7.

ALTERN A'l E TEST: During normal plant operation above 30 percent power, each partially or fully withdrawn operable cv.rol rod is exercised one notch at least once each week (Technical Specification 4.3 A.2). One pair of these solenoids is exercised when the associated CRD is withdrawn a notch, and the other pair is exercised when the CRD is inser'ed a notch. Proper operation of the CRD verifies the operation of the associated solenoid valves.

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h Revision 2.1 Section V Page 125 of 155

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COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV-06 VALVE: CS-CV-12CV, CS-CV-13CV, CS-CV-14CV, and CS-CV-15CV CLASS: 2, A (outboard) CATEGORY: C 9

FUNC flON: Core Spray (CS) Loop A and Loop B pressure maintenance check valves from the condensate supply system. These valves open to maintain the Core Spray system solid and close to prevent diversion of core spray How.

REQUIRED OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominaily TESTS: every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5. ,

BASIS FOR These valves are normally closed check valves (with two in series). The inboard RELIEF: valve is essential (safety related). The redundant outboard valve is non-essential.

The valves are the same make and model number and met the same quality assurance requirements at the time they were installed. They open as necessary to keep the CS system in a solid standby condition, which is not a safety function.

When the CS pumps start, these valves close to ensure maxin am Dow to the reactor. These valves do not have perform a function which requires leakage to be limited to a specified amount.

\

Only one valve is required to close to prevent diversion of How as determined and documented in accordance with CNS safety classification requirements. Ilowever, the current system design does not allow independent testing to ensure both valves have closed. Thus both valves will be tested together. When a CS Pump is started, should both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply s de of the valves.

i ALTERNATE TEST: The check valves in each loop will be tested closed simultaneously to assess the operational readiness of each pair of valves. Should the acceptance criteria be exceeded, both valves will be declared inoperable until they are repaired or replaced as necessa.

Revision 2.1 Section V Page 126 of 155

COOPER NUCLEAR S TATION TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV-07 VALVE: llPCI-CV-18CV and llPCI-CV-19CV CLASS: 2, A (outboard) CATEGORY: C FUNCTION: liigh Pressure Coolant injection (IIPCI) pressure maintenance check valves from the condensate supply system. T1.ese valves open to maintain the IIPCI system solid and close to prevent diversion of IIPCI injection now.

REQUIRED OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally TESTS: every 3 months, except as provided by paragraphs 4.3.2.2. 4.3.2.3,4.3.2.4, and 4.3.2.5.

BASIS FOR These valves are normally closed check valves (with two in series). The inboard ,

RELIEF: valv: is essential (safety related). The redundant outboard valve is non-essential.

The valves are the nme make and model number and met the same quality assurance requirements at the time they were installed. They open as necessary to keep the llPCI system in a solid standby condition, which is not a safety function.

When the llPCI starts, these valves close to ensure maximum now to the reactor.

These va!ves do not have perfonn a function v>hich requires leakap to be limited to a specified amount.

Only one valve is required to close to prevent diversion of How as detennined and documented in accordance with CNS safety classification requirements. Ilowever, the current system design does not allow independent testing to enture both valves have closed. Thus both valves will be tested together. When IIPCI is started, should both valves fail to close, a relief va!ve would lift or a prc=sure sensor would alarm on the condensare supply side of the valves.

ALTERNATL TEST: The check valves will be tested closed simultaneously to assess the operational readiness of the pair of valves. Should the acceptance criteria be exceeded, both valves will be declared inoperable until t'.iey are repaired or replaced as necessary.

5 Revision 2.1 Section V Page 127 of 155 1

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COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TliSTING PROGRAhi RELIEF REQUEST RV-08 VALVE: ilPCI SOV-SSV-64 and IIPCI-SOV-SSV87 CLASS: 2 CATEGORY: B FUNCTION: The IIPCI tu:bine end exhaust steam drip leg drain to gland condenser (IIPCI-SOV-SSV64) and ilPCI turbine and exhaust steam drip leg drain to equipment drain isolation valve (IIPCI-SOV-SSV87) have an active safety function in the closed position to maintain pressure boundary integrity of the llPCI turbine exhaust line. These valves serve as a Class 2 to Non-Code boundary barrier.

REQUIRED Ohta Part 10,4.2.1 requires Category A and B power operated valves to be TEST: individually full stroke exercised and stroked timed nominally every 3 months, except as provided by paragraphs 4.2.1.2,4.2.1.5, and 4.2.1.7.

Ohta Part 10,4.2.1.6 requires that valves with fail-safe actuators shall be tested by observing the operation of the ,,etuator upon loss of valve actuating power in mordance with the exercising frequency of paragraph 4.2.1.1.

BASIS FOR These valves are rapid acting, encapsulated, solenoid operated valves. Their RELIEF: control circuitry is provided with a remote manual switch for valve actuation to the Open position e'id an Auto function which allows the valves to actuate from signals  !

received from the associated level switches IIPCI-LS-98 and IIPCI-LS-680. Both valves receive a signal to change disc position during operability testing of drain pot level switches. Ilowever, remote position indication is not provided for positive verification of disc position Additionally, their encapsulated design prohibits the ability to visually verify the physical position of the operator, stem or internal components. hiodification of the system to verify valve closure capability ,

and stroke timing is not practicable nor cost beneficial since no commensurate l increase in safety would be derived.

{1 ALTERNATE TEST: Quarterly, each valve shall be exercised to the full closed position. Although valve stroke timing will not be performed, this test will verify that the valve moves to the safe position. Enhanced maintenance shall be perfemled each refueling outage by disassembling and inspecting each solenoid valve to monitor for degradation.

Revision 2.1 Fection V Page 128 of 155

COOPER NUCLEAR STATION TillRD INTERVAL INSliRVICE TESTING PROGRAM RELIEF REQUEST RV-09 VALVE: MS-RV-71 ARV, BRV, CRV, DRV, ERV, FRV, GRV, and IIRV CLASS: 1 CATEGORY: B/C FUNCTION: The main steam power operated safety valves have an active safety function in the open position to prevent over pressurization of the reactor vessel. These safety valves have an active safety function in tr.e closed position to maintain reactor vessel integrity.

REQUIRED TEST: OMa Part 10,4.2.1 requires Category A and B power operated valves to be individually full stroke exercised and stroked timed nominally every 3 months, except as provided by paragraphs 4.2.1.2, 4.2.1.5, and 4.2.1.7.

BASIS FOR RELIEF: These valves are power actuated safety relief valves for the main steam lines.

Each valve is exercised during startup following refueling outages. Exercising these valves during power operations can cause pressure, temperature, and reactivity transients.

Exercising during cold shutdown is impracticable since a minimum of 50 psig \

steam pressure is iequired to open the valves. The valse supplier does not recommend exercising these valves below 150 psig steam pressure because of the risk of valve seat damage and resultant leakage. Technical Specifications require testing once each refueling cycle at a reactor pressure > 100 psig, which is adequate to assess the operational readiness of these valves.

Relief valves are quick acting and their stroke-times cannot be measured by conventional means. They do not have position indication in the usual sense.

Pressure switches in the SRV discharge lines annunciate in the control room and indicate when the valve is open or closed. Should a relief valve fail to function as designed, corrective action is required.

Revision 2.1 Section V Page 129 of 155

COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV 09 (Continued)

ALTERNATE TEST: In addition to testing to the requirements of OM-1987, Part 1, Paragraph 3.3.1.1, full stroke exercise tests of these valves open and closed will be perfonned during each refueling outage. The opening stroke time will be measured from the time the switch is actuated until the pressure switch in the discharge line annunciates.

This testing method is consistent with GL 89-04, position 6.

I l

i N

Revision 2.1 Section V Page 130 of 155 i

COOPliR NUCLEAR STATION

- TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV-10 VALVES: Excess Flow Check Valves CLASS: 1 CATEGORY: A/C FUNCTION: The excess flow check valves are installed in instrument lines that provide signals for operation of safety related pnnps and valves. They prevent excess llow of reactor water should an instmment line break outside containment.

REQUIRED TEST: OMa i> art 10, 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

Testing in accordance with OMa Part 10, 4.3.2.4 requires demonstration that the valve disk travels to the seat on cessation of flow. Confirmation that the disk is on the seat may be by direct indication, such as position indicating devices, or by >

other indicators such as changes in system pressure, llowrate, level, temperature, seat leakage testing or other positive means.

IIASIS FOR RELIEF: Uninterrupted function of these valves is essential for safety. Routine testing in  !

accordance with Section XI would cause instrument line interruptions. This would disable instruments re tuired for safe plant operations, safety-system actuation, reactor shutdown, or sensing accident conditions. In addition, these valves cannot be exercised during cold shutdown because removal of multiple instruments from service could prevent or interrupt the operation of systems required for decay heat removal.

The excess flow check valves are tested using a modified leak-rate test to assess operability. Testing is performed at least once cach operating cycle in accordance with Technical Specification 4.7.D. I.c. Testing more frequently could jeopardize the safety of the reactor.

ALTERNATE TEST: In lieu of Section XI testing, a modified leak-rate test will be performed at least once each operating cycle.

Revision 2.1 Section V Page 131 of 155

l COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV-ll VALVE: RCIC-CV-18CV and RCIC-CV-19CV CLASS: 2. A (outboard) CATEGORY: C FUNCTION: Reactor Core isolation Cooling (RCIC) pressure maintenance check valves from the condensate supply system. These valves open to maintain the RCIC system solid and close to prevent diversion of RCIC injection flow.

REQUIRED OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally

'ITiSTS: every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

IIASIS FOR These valves are normally closed check valves (with two in seriest The inboard I

RELIEF: valve is essential (safety related). The redundant outboard valve is non-essential.

The valves are the same make and model number and met the same quality assurance requirements at the time they were installed. They open as necessary to keep the RCIC system in a solid standby condition, which is not a safety function.

When the RCIC starts, these valves close to ensure maximum flow to the reactor.

Tinse valves do not have perform a function which requires leakage to be limited to a specified amount.

Only one valve is required to close to prevent diversion of flow as determined and documented in accordance with CNS safety classification requirements, llowever, the current system design does not allow independent testing to ensure both valves have closed. Thus both valves will be tested together. When RCIC is started, should both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply side of the valves.

ALTERNATE

' TEST: The check valves will be tested closed simultaneously to assess theoperationai readiness of the valves. Should the acceptance criteria be exceeded, both valves will be declared inoperable until they are repaired or replaced as necessary.

Revision 2.1 Section V Page 132 of 155

COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST RV-12 VALVE: RilR-CV-18CV, R11R-CV-19CV, RilR-CV-24CV, and RHR-CV-25CV CLASS: 2. A (outboard) CATEGORY: C FUNCTION: Residual lleat Removal (RllR) Loop A and Loop B pressure maintenance check valves from the condensate supply system. These valves open to maintain the RllR system solid and close to prevent diversion of LPCI injection now.

REQUIRED OMa Part 10, 4.3.2.1 requires check valves to be individually exercised nominally TESTS: every 3 months, except as provided by paragraphs 4.3.2.2,4.3.2.3,4.3.2.4, and 4.3.2.5.

BASIS FOR These valves are normally closed check valves N'ith two in series). The inboard REl.lEF: valve is essential (safety related). The redundant outboard valve is non-essential.

Each pair of valves are the same design and met the same quality assurance requirements at the time they were installed. They open as necessary to keep the RilR system in a solid standby condition, which is not a safety function. When the RilR pumps start, these valves close to ensure maximum Dow to the reactor.

These valves do not have perform a function which requires leakage to be limited to a specified amount.

Only one valve is required to close to prevent diversion of Dow as determined and documented in accordance with CNS safety classification requirements. However, the current system design does not allow independent testing to ensure both valves have closed. Thus both valves will be tested together. When a RHR Pump is started, shnuld both valves fail to close, a relief valve would lift or a pressure sensor would alarm on the condensate supply side of the valves.

ALTERNATE TEST: The check valves in each loop will be tested closed simultaneously to assess the operational readiness of each pair of valves. Should the acceptance criteria be exceeded, both valves will be declared inoperable until they are repaired or replaced as necessary.

Revision 2.1 Section V Page 133 of 155

COOPER NUCLEAR STATION TillRD INTERVAL INSERVICE TESTING PROGRAh!

RELIEF REQUEST RV-13 VALVE: SW-h10V h1089A and SW-h10V-h1089B CLASS: 3 CATEGORY: B FUNCTION: loop A and loop B outlet isolation for the Service Water boester pump cooling water to the RilR beat exchangers. These normally closed valves have an active safety function in the throttled position to provide a flow path for cooling water flow through the RilR heat exchangers during transient and accident conditions.

REQUI'tED TEST: Ohta Part 10,4.2.1 requires Category A and B power operated valves to be individually full stroke exercised and stroked timed nominally every 3 months, except as provided by paragraphs 4.2.1.2, 4.2.1.5, and 4.2.1.7.

1 BASIS FOR RELIEF: These valves are exercised during quarterly Service Water Booster Pump flow testing to a throttled position required to satisfy Technical Specification flow requirements. Valve stroke timing to the fully opened position is impracticable.

Full opening will cause RilR Service Water Booster Pump run out. These valves cannot be accurately stroke timed because they are controlled with a thumb wheel type controller. After a pump associated with either valve has started, valve

(

movement is subject u considerable variation. This type of controller provides an output signal that is dependant upon the speed with which the c ' roller is operated. Stroke time measurements of these valves would be very difficult to repeat due to the absence of normal valve control switches and would not contribute meaningful data to utilize in monitoring valve degradation.

ALTERNATE TEST: These valves will be exercised to their safety-related throttled position quarterly, but stroke times will not be measured. At refueling outages, these valves will be tested under the CNS h10V Program in accordance with GL 89-10. Stroke times will be one of the parameters measured.

Revision 2.1 Section V Page 134 of 155 l

COOPER NUCLEAR STATION TillRD INTERVAL .

INSERVICE TESTING PROGRAM REl.lEF REQUESR RV-14 Withdrawn Revision 2.1 Section V Page 135 of 155

-l ATTACHM2NT 3 LIST OF NRC COMMITMENTS l Correspondence No: HLs970162 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None l

l PROCEDURE NUMBER 0.42 l REVISION NUMBER 5 l PAGE 9 OF 13 l r --- - - - - - - - - - _ - - _ - - - _ - - - - _ _ - - - - -