ML20217C283

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Forwards Rev 0 to Inservice Testing Program Plan Pumps & Valves Braidwood Nuclear Generating Station,Units 1 & 2. Summary of All Changes Attached to Facilitate NRC Review Also Encl
ML20217C283
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 04/16/1998
From: Tulon T
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217C289 List:
References
GL-89-04, GL-89-4, NUDOCS 9804230259
Download: ML20217C283 (32)
v • d • e


Text

Commonwealth Illison Company

,,, tiraidwomi Generating Mat'

    • Route al, Ika Hi Hraces ille. II. 60 W% 19 t Td HI4158-2801 April 16,1998 l

United States Nuclear Regulatory Commission 3 ATTN: Document Control Desk I Washington. D. C. 20555 - 0001 j

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Subject:

Braidwood Station Units I and 2 l Inservice Testing Program Plan for Pumps and Valves )

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1 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating License NPF -72 and NPF-77 {

1 NRC Docket Number: 50-456 and 50-457 i

Reference:

(1) Revision 7 of the first 10 year interval Braidwood Inservice Testing ,

Program Plan For Pumps and Valves (2) Revision 0 of the second 10 year interval Byron Inservice Testing Plan Pumps Aad Valves Attached is the Braidwood Station Units I and 2 second ten year intenal insenice Testing Program Plan Pumps and Vahes, Resision O. As required by 10CFR 50.5Yf)(ii), this l

Program Plan fbr Braidwood's second ten year interval has been prepared to the requirements  ;

of the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel Code, Subsections j IWP and IWV. The 1989 Edition of ASME Section XI subsequently references the ASME/ANEl OM Part 6 for pump testing and ASME/ ANSI OM Part 10 for Valve testing.

The Edition and Addenda of ASME/ ANSI OM Part 6 and OM Part 10 is the Oma-1988 Addenda to the OM-1987 Edition.

The Commercial Senice Date for Braidwood Unit I was July 29,1988. and October 17,1988 for Unit 2. As was done for the first intenal insenice Testing Program, Braidwood intends to keep both Units I and 2 on a common implementation date. This stan date for the second ten year interval for Braidwood Units I and 2 shall be July 29,1998. The second ten year interval will be from July 29,1998 through and including July 28. 2008.

Where the Code required tests were detennined to be impractical, relief requests hase been included in this Inservice Testing Program Plan submittal. There are no relief requests being submitted at this time pertaining to the pump portion of the Inservice Testing Program, however there are four relief requests VR-1, VR-2, VR-3 and VR-4, for the valve portion of the Inservice Testing Program.

[ VR-1 addresses the same subject as VR-31 of Reference (1). VR-1 was revised for fomiat and \I l clarifying infonnation, but has the same provisions as VR-31 of Reference (1), which was \

L approved per Generic letter 89-04 and is currently in use at Braidwood. VR-1 also contains the same provisions as VR 5 frontReference (2). .tv 0 9904230259 980416

.. v v u q t i V PDR ADOCK 05000456 P PDR

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i VR-2 pertains to disassembly and inspection in accordance with Generic Letter 89-04, except

[ the sample plan frequency for some of the valves is every 18 months, whereas Generic Letter l 89-04 provides for a refueling outage sample plan frequency. Braidwood used guidance provided in NUREG 1482 Appendix A, which addresses this subject, in preparing VR-2.

l VR-3 pertains to disassembly and inspection, per Generic Letter 89-04. VR-4 is the same relief request as VR-13 from Reference (1), except for fonnat revisions. VR-13 was approved and i is currently in use at Braidwood. Additionally, VR-4 is nearly identical to VR-8 of Reference l (2). I Based on the above discussion, Braidwood plans to implement VR-1, VR-2, VR-3, and VR-4 unless othenvise directed. Justification for these requests is in Section 3.5 " Valve Relief j

Request" of the attached testing program plan. Also a summary of all changes is attached to

facilitate your review.

Braidwood will begin implementation of the updated Insenice Testing Program upon this submittal date for the attached updated Inservice Testing Program Plan, as provided per NUREG 1482 Section 3.3.4. The schedule for completion of the implementation process in I

regard to procedure revisions is no later than 3 months after the start date of the new interval, which would be 3 months after July 29,1998 (October 29,1998).

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l Approval of the Braidwood Station Units 1 and 2 second ten year interval inservice Testing Program Plan Pumps and Valves, Revision 0, is requested by July 14,1998.

Please address any comments or questions regarding this matter to Donald W. l Zebrauskas, at (815) 458-2801 extension 2520.

Very truly yours, J

Timothy J. Tul 1

Site Vice Presid Braidwood Nuclear Generating Station TliTBhbum,fw 80Mn e doc

Attachment:

Inservice Testing Program Plan Pumps And Valves Braidwood Nuclear Generating Station Units #1 And #2 l

cc: A.B. Beach - Regional Administrator-Rill Stu Bailey - Braidwood Project Manager-NRR C.J. Phillips - Senior Resident Inspector-Braidwood J. A. Gavula - RIII Office of Nuclear Safety - IDNS l

r e,

Attachment A Summary of Changes for Revision O of the Second Interval Inservice Testing l Program Plan i

Pumps And Valves Braidwood Nuclear Generating Station Units #1 And #2 Backgrounds Currently, the Braidwood Inservice Testing Program Pumps and Valves is in accordance with ASME Section XI 1983 Edition. Beginning July 29,1998, Braidwood will be required to update its Inservice Testin- Program Pumps and Valves to the requirements of ASME Section XI, 1989 Editi n. For pump testing ASME Section XI 1989 Edition references OM-1987 1988 Addenda Part 6. For valve testing, ASME Section XI 1989 Edition references OM-1987 1988 Addenda Part 10. OM Part 10 then references OM Part 1 for relief valve testing.

Revision 0 Dated January 1998 is the revised Braidwood Inservice Testing Program Plan Pumps and Valves, which is in accordance with ASME Section XI 1989 Edition except for specific relief as identified in the Program Plan.

The following is a summary of the major changes of this Revision O of the Second Interval Inservice Testing Program Plan compared to tha current Inservice Testing Program Plan Rev 7. The Revision 0 Second Interval Inservice Testing Program Plan will become effective July 29, 1998.

A. General Changes:

1. The IST Program has been separated from the ISI Program and will be maintained as a stand alone document. NRC submittals will continue to be separate from the ISI Program.
2. A revision summary sheet has been incorporated as the first page of the document to easily illustrate any revisions that are made throughout the second interval.
3. A new Table of Contents Format has been utilized.
4. Code references were revised throughout to reflect the new code.
5. Summary sheets have been added at the beginning of major sections.
6. All justification sections and relief requests now include a Drawing Number and Drawing Coordinate for each component.

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Attactunent A l

7. OM-1987 1988 Addenda allows testing at refueling outages. As a result, many of the relief requests from the First Interval t

Inservice Testing Program Plan have been converted into refueling

( outage justifications in the second Interval Inservice Testing l

Program Plan. All such refueling outage justifications had some degree of revision when being converted to a refueling outage justification.

I l- 8. Many of the Notes were converted into Cold shutdown

{ Justifications. They had some degree of revision when converted to Cold shutdown Justifications.

B. Section 1.0 Information Common to Pumps and Valves:

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1. The introduction section has now been combined for Pumps and Valves, with specific information noted concerning common information (code information, interval dates, etc.) The Program Plan is no longer a pump plan and a valve plan, but is now one plan with a pump section and a valve section.

C. Section 2.0 IST Pump Plant

1. OM-6 does not require the observation of lubricant level or pressure, the measurement of bearing temperatures, or the measurement of inlet pressure (may still be required to obtain the

! required differential pressure). Discharge pressure, rather than differential pressure, is required for positive displacement l pumps.

Results:

i A. Inlet pressure, bearing temperature, and lubrication level l descriptions and columns have been removed from sections 2.1.1, Pump Table Descriptions, and section 2.1.2, Pump l Tables. The wording of the pressure column description was changed, to reflect OM-6.

B. Previous notes associated with lubricant level and inlet pressures were deleted. This eliminates the entire Notes l Section, and the Remarks Column from the pump table.

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! 2. Format of the Pump Table Description has changed, and the information is described in a difterent manner. The Pump Name column is described. Code Class is further described as to what each designation signifies. Deleted the N for non-Code and replaced it with G, which is defined as non Code or Codes other than Section XI. It further explains that G is used for the Diesel oil Transfer pumps and that it will be treated as ASME Section III Class 3 for IST purposes. This was done as the current Rev 7 2

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i Attaciunent A Program did not use the N in the pump table columns, and used 3 for the Code class of the Diesel Oil Transfer Pumps. Though Braidwood treats these pumps as Class 3 for IST purposes, the Braidwood Mechanical Department Valve List lists them as G. The change is to more accurately reflect the actual situation.

Deleted the descriptions as to the type of instruments and the references to calibration and accuracy requirements. This info was not needed as the Code contains these requirements. Changed the description of vibration, to include additional information from OM-6. Added that all vibration measurements are in velocity.

Changed the description of pump speed to mention constant speed pumps. Made several editorial changes to the descriptions to reflect how they are designated in the pump program tables.

3. The Program description for pumps has been deleted, some of the information is contained in the Introduction and Program Description. Much of the information has been deleted as it is not required for Program Plan submittal and does not appear to add value to the Program Plan submittal.
4. Pump Tables:
a. Eliminated the Boric Acid Transfer Pumps from the pump Table. The Boric Acid Transfer Pumps are not required to be in the IST Program and they were not part of the IST Program for Rev 7 of the First Interval Inservice Testing Program Plan. They were listed in the pump table in Rev 7 for tracking purposes. Pump Technical Position PA-01 of this Rev 0 submittal of the Second Interval Inservice Testing Program Plan mentions that they are tested outside the scope of the IST Program.
b. Corrected typographical error in the pump tables to show that pump speed is measured for pumps lAF0lPB and 2AF0lPB.
c. Changed the class designation of the diesel oil transfer pumps from 3 to G.

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d. Corrected the editorial error to now include the 2D00lPD pump along with the appropriate entries in the columns.
e. Corrected the editorial error to show the correct P&ID number for 1DOOlPD.
f. Corrected the editorial error to show the correct P&ID number for 2SI0lPA and 2SI0lPB.

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i Attaclunent A l 4. g. Provided the sheet number for several P&ID numbers.

h. Made editorial changes to the pump tables such as different designators to indicate if a test is performed.

l i. Changed the Test Interval designator from Quarterly to 3M.

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l 5. Revised the wording in Technical Position PA-02, concerning the i Boric Acid Transfer Pumps.

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6. Deleted relief request PR-01, regarding pump vibration measurements. Relief Request no longer needed when using OM Part 6 Code. Also deleted reference to this relief request in the pump tables.
7. Deleted previous Relief Request PR-02, which had asked for relief from measuring pump bearing temperatures.
8. PR-03, PR-04, and PR-05 were already previously deleted.

l 9. Deleted previous Relief Request PR-06, asking for relief to use discharge pressure rather than differential pressure for the

, Diesel 011 Transfer positive displacement pumps. This is allowed I

per OM-6. Deleted reference to this relief request in the pump

, tables. It should be noted that with the deletion of these relief I

requests from the Pumps Section of the Second Interval Inservice Testing Program Plan, there are no longer any pump relief requests.

10. Deleted the reference to BwVP 200-1.

l l 11. Added Note to pump reference list to show that Tech Spec 4.0.5 will become 5.5.8 when the Improved Technical Specifications are implemented.

D. Section 3.0 IST Valve Plant

1. SCOPE:

l One of the major areas of review for the ten year update, was scope. Braidwood/ Byron performed a joint scope review in 1994, per NTS item 456-100-93-01100A and OSR #94-131, and incorporated all valves, except relief valves, into previous First Interval Program revisions. It was felt that the relief valve additions would not be required until the new code was adopted.

Additionally, since the completion of the review in June, 1994, positions regarding " thermal" relief valves were in question, and another review of relief valves was completed in 1995. The following relief valves are being added to the IST Program.

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i Attachment A D 1. a. Per the Braidwood/ Byron Scope review in 1994, these 51 relief valves will be added to the program: l J

OCC9432 OGW9300A-F OWOO28A/B 1/2CV8117 1/2CS08KA,MB 1/2CV8118 1/2CV8121 1/2D0020A-D 1/2RYO30A/B 1/2VF01H 1/2SA148A-D 1/2SI8853A/B 1/2SI8856A,B 1/2SI8858

b. Per a follow-up review of relief valves, these additional 18 relief valves will be added to the program :

1/2CV8124 1/2SI8851 1/2SI8842 1/2SI8855A-D 1/2SI121A/B

c. Due to a Zion audit, the following 8 CC check valves were added for the closure direction. A procedure currently exists to test these valves, and they have been tested during AIR 06 and A2R06:

1 1/2CC9495A-D

d. The following fail safe testing will be added to the IST Program Tables, which is already being performed in stroke time procedures:

1/2VQOO3, 4A, 4B, SA-C 1/2CV8114, 1/2CV8116

e. Stroke time testing and indication testing were added for the following valves. (Braidwood is currently only performing fail-safe testing):

1/2SX147A/B

f. Closure testing was added for 1/2CV8546 and 1/2SI8926 per concerns raised at Zion Station. These check valves had previously only been tested in the open direction. The additional closure tests are currently included in a procedure, and were tested during AIR 06 and A2R06.
g. The following testing will be deleted from the IST Program.
1) 1/2CC9486 check valve full stroke test. Per the Braidwood/ Byron Scope review, it was determined that the valve does not have an IST open safety function.

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l Attactunent A

2) 1/2CV128 position indication test (stroke timed locally) remote position indication test is not required.

D. 2. Valve Table Descriptions:

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a. Revised references from particular paragraphs from ASME XI 1983 Summer 1983 to the appropriate paragraph from OM Part 10 1988 Addenda or OM Part 1 1987.
b. Revised the description of Class to better describe the designators. Eliminated the designator "T for tracking purposes only".

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j c. Described the Valve Categories in mors detail.

! d. Under Test Methods revised the description of the (Bt)

Backflow Test and the (Ct) Check Valve Full Stroke Test. j

e. Revised (Ft) Fall Safe Test to indicate more specifically (Fo) Fail Safe Test Open or (Fc) Fail Safe Test Closed. {

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t f. Revised the description of the seat Leakage Test (Lt), to l include that the tests will also be performed in accordance with 10CFR50.55a(b)(2)vii.

g. Revised the description of the partial stroke test (Xt), to i describe that it is done when plant conditions allow.
h. " Test Mode" column revised to indicate " Test Frequency" with j the following revised or new designations:

l j 1) Normal Operation (OP) revised to indicate Quarterly l (Q).

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2) Semi-annual (S) test frequency removed. This frequency was being used for some VQ Tech spec leak test requirements, but has been revised to fall under the Appendix J test frequency.
3) cold shutdown (CS) slightly revised wording to more closely match OM Part 10.
4) Two Year (2Y) frequency added mainly due to the requirement that indication tests be performed at least once every two years.

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Attaciunent A

, 5) Five Year (SY) and Ten Year (10Y) frequencies created I to encompass relief valve frequencies for class 1 valves, and class 2 or 3 valves, respectively.

6) Sample Disassembly (SD) designation was created for those check valves which are disassembled to satisfy f IST requirements.

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7) The Appendix J (AJ) designation was added for those valves which are tested at the frequency of the Appendix J leak test. Testing may go beyond a j refueling outage frequency for the good performers, in accordance with Appendix J Option B.
1. Deleted the " Remarks" column, and added " Cold Shutdown Justification" and " Refueling Outage Justification" columns.

OM- 10 allows the licensee to justify cold shutdown and refueling outage frequencies without NRC approval. Per the

! 1983 Edition, only cold shutdown frequencies (at Braidwood,

( indicated with a brief Note) could be justified without NRC approval.

3. Valve Tables:

Several changes were made to the Notes, the Valve Technical Positions, Cold shutdown Justifications, and the Relief Requests from the Revision 7 first interval IST Program. Additionally, the Rev 0 second interval Program contains additional Cold shutdown

, Justifications and Refueling Outage Justifications. These changes included items which would be reflected in a change to the Valve

( Tables, such as numbering changes, the Notes; Justifications; etc.

which are applicable to a valve, or a change in frequency. Many of these changes are addressed in subsequent sections of this Summary of Change. Where such description of the change are l

addressed in subsequent sections, the change will not additionally be explained in this Valve Tables Section. The changes described in the Section 3 Valve Tables are primarily changes which are not addressed in other sections.

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a. For 3 month (quarterly) test frequency, (OP) was changed to (Q).
b. All of the Position Indication tests (IT) now indicate (2Y) l for test frequency, previously it was (RR). All of these l tests receive a Note 4.

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c. For containment isolation valves (designated by Note 1) for which the leak test is not being used to satisfy other test requirements, such as a check valve backflow test (Bt), the 7

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Attackunent A l

l test frequency is now designated as %J. For containment isolation valves for which the leak test (Lt) is also used to satisfy other test requirements, sech as a check valve backflow test (Bt), the frequency remalas RR (as in the First Interval Rev.7 Program), because the leak test would  !

still have to be done on a refueling outage frequency to satisfy the backflow test (Bt) frequency requirements.

d. All valves for which the Test Method is identified as I

requiring a full stroke test (ST), except for manual valves, now have Tech Position VA-3 indicated in the Tech Position )

Column.

l e. The test frequency for all relief valves has been revised l from refueling outages RR to either 5Y or 10Y.

f. Valves OAB8473 and 1/2AB8487 were removed from the Valve Tables. As described in Valve Technical Position VA-5, I these val..s are outside the scope of the IST Program. This I

was the same position as the Revision 7 first interval IST

{

Program, and the testing performed outside of the IST I Prograni is the same. The difference from Revision 7 of the first interval IST Program is that the valves will no longer be listed in the Valve Tables.

g. The Valve size for 1/2cc685 was revised from 4 inches to 3 inches to reflect the correct valve size as identified on the P& ids. l
h. The valve size for 1/2MS019A-D was revised from 6 inches to 8 inches to reflect the correct valve size as identified on the P& ids.
1. The valve size for OSX007 was changed from 30 inches to 24 inches to reflect the size on the P& ids.

l j. For valves 1/2SX147A and 1/2SX147B, changed the Normal l Position from N/A to O (open).

k. For Valves 1/2PR002G, 1/2PR002H, 1/2SI8968, and 1/2WM191 the l Backflow (Bt) test was added. This was not an added test, as ;
the leak test (Lt) did perform the backflow test. The change ;

( is that the table now reflects the test. Additionally, the j term passive was deleted for these valves.  !

1. For valves 1/2RH8708A,B added the closed stroke direction.
m. Valves 1/2SX116A and 1/2SX116B were removed from the System and are now deleted from the tables.

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i Attaciunent A I

n. Changes were made to the valve tables to reflect the changes indicated in D.1 Scope.
4. Notes:

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a. Note 1 was created from previous Relief Request VR-1, which j allowed leak rate testing of containment isolation valves to {

be completed via the Appendix J Leak Test. OM-10 allows l this provision per paragraph 4.2.2.2. This note now just references which valves are affected and that 10CFR50.55 a(b)(vii) also applies.

b. Previous Note 1 has been made into Cold Shutdown i Justification VC-1. The partial stroke requirement every three months was deleted as explained in VC-1. Additional information was added to the Cold Shutdown Justification to l support the reasoning behind it.
c. Previous Notes 2,4, and 5 have been incorporated into new Cold Shutdown Justifications VC-2, VC-4, and VC-5. f Additional information was added to the cold shutdown j justifications to support the format and reasoning behind j them.

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d. Previous Note 6 is now Note 16, and still identifies the valves which are pressure isolation valves. The note has been revised slightly, basically deleting information already contained in other portions of the IST Program.
e. Previous Notes 7-10 have been incorporated into new Cold Shutdown Justifications VC-6 through VC-9. Additional information was added to the cold shutdown justifications to l support the format and reasoning behind them.

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f. Note 11 (the part associated with the stroking of the 1/2VQ001A,B and 1,2VQOO2A,B valves) has been incorporated into new Cold Shutdown Justification VC-24. Additional information was added to the new cold shutdown justification to support the format and reasoning behind it and now mentions that these valves are blocked closed. The rest of previous note 11 concerning leak testing frequencies of VQ valves are now covered under Note 1. i i

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g. Previous Notes 12 is now VC-11, except for the 1/2AF001A and 1/2AF001B valves. These valves are now included in Refueling Outage Justification ROJ-15, with additional information including information from VR-19.

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1 Attackunent A

h. Previous Notes 13 and 14 have been incorporated into new cold Shutdown Justifications VC-12 and VC-13. Additional information was added to the cold shutdown justifications to support the format and reasoning behind them.
i. Portions of previous Notes 16, 17, and 21 have been incorporated into Refueling Outage Justification ROJ-14.

I Additional information was added to the new refueling outage justification to support the format and reasoning behind it.

j. Previous Note 20 is now Note 5.
k. Previous Note 22, concerning the monitoring of check valves 1/2PS231A/B open quarterly, has been moved to Note 2.
1. Previous Note 23 is now Note 7, and has been revised to indicate the correct valve EPNs (SI8948A/B revised to SI8941A/B.
m. Previous Note 24 is now Note 8.
n. Previous Note 28 has been incorporated into Refueling ,

Outage Justification ROJ-22. Additional information was  !

added including explaining non-intrusive testing methods l and justification to change the test frequency from cold j shutdown to refueling.

o. Previous Note 30 has been incorporated into new cold Shutdown Justification VC-11. Additional information was added to the new cold shutdown justification to support the format and reasoning behind it. i
p. A portion of previous Note 31, involving 1/2SI8919A/B, has been incorporated into Note 9, with some wording revisions.

The remainder has been deleted.

q. Previous Note 34 has been revised and is now Note 11.
r. The subject of Previous Note 35 has been incorporated into ROJ-9. Additionally, previous Relief Request VR-15B has also been incorporated into ROJ-9, with revised wording.

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l s. Previous Note 36 is now Note 12, and is also addressed in VC-14.

1) Cold shutdown frequency for the stroke of 1/2RY455A l and 1/2RY456 placed in Cold Shutdown Justification VC-
14. Additional information was added to the new cold shutdown justification to support the format and i reasoning behind it.

l 2) Indication testing at Refueling was placed in Note 12.

t. Previous Note 37, involving the stroke time testing of l 1/2RH8716A/B, has been expanded and is now covered under new l cold Shutdown Justification VC-18.

l u. Previous Note 40 has been incorporated in Cold Shutdown l Justification VC-19.

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i v. Previous Note 38, involving the closure test of the 1/2FWO36A-D valves, has been expanded and is now covered under Cold Shutdown Justification VC-20.

t l l w. Previous Notes 15, 18, 19, 32, and 39 were previously i deleted.

! I l x. Previous Notes 25 is now included in ROJ-1. Previous Note k j 26 is included in ROJ-7. This was done as Braidwood now l includes the (Bt) backflow test for these valves in the IST

( Program. j i

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y. Notes 27 and 29 were deleted as the valve functions they j describe are more appropriate to address in the Scope Basis l Document.

l z. Note 3 is now VC-3 with additional wording.

aa. Note 33 was not used at Braidwood and has been deleted.

l bb. New Notes 3, 4, 6, 13, 14, and 15 were added in this revision.

5. Valve Technical Positions '
a. Previous Technical Position VA-01, Method of Stroke Timing Valves, has been revised accordingly for the new code and still remains as VA-1. The method of stroke timing valves locally was added.

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Attactunent A

b. Previous Technical Position VA-02, Method of Fail Safe Testing Valves, has been revised slightly, but still remains VA-2.
c. Previous Technical Position VA-03, Method of Full Stroke (Ct) and Backflow (Bt) Exercising valves, was deleted. No methods were discussed in which a position had to be taken.
d. Portions of previous Technical Position VA-04, Determining  ;

limiting values of full-stroke times for Power-Operated {

Valves, portions of Previous Relief Request VR-20, which j dealt with establishing Acceptance criteria, and previous j relief request VR-12, concerning fast-acting valves, have l been reviewed and incorporated into new Technical Position VA-3, method of Establishing Acceptance Criteria for Power-  :

Operated Valves. l I

e. Previous Technical Position VA-05 has been revised slightly, !

but remains VA-5. Previous Technical Position VA-06 was revised slightly to delete references to the previous Code test methods, but remains VA-6.

f. Previous Technical Position VA-07, concerning the exercising of CC manual valves at a U-2 Cold Shutdown Frequency, has been moved to ROJ-3 and has been revised considerably. The frequency has been changed to refueling outages instead of U-2 cold shutdowns. The revisions reflect the test methods used at Braidwood, and now establishes the exercising frequency at U-2 Refueling Outages.
g. New Technical Position VA-4, Method of Position Indicatisn Testing, has been added to discuss Braidwood's position on l the subject.
6. Cold Shutdown Justifications (not previously in Item 3):

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a. Previous Cold Shutdown Justification VC-4 has been revised ,

slightly and is now Cold shutdown Justification VC-10.

b. Previous Cold Shutdown Justification VC-1 has been moved to Cold Shutdown Justification VC-21 with some revision.
c. Previous Cold Shutdown Justification VC-2, containing the closure testing of the 1/2CV8355A-D and the 1/2CV8368A-D valves, has been split up. The 1/2CV8355A-D valves have been moved to Cold Shutdown Justification VC-22. The 12

Attactunent A l

1/2CV8368A-D valves have been moved to Refueling Outage Justification ROJ-12. ROJ-12 justifies the change from cold shutdown testing to a refueling outage frequency, based on using radiography to test these valves.

d. Previous Cold Shutdown Justification VC-3 has been moved to l Cold Shutdown Justification VC-23, with slight revisions.
7. Refueling Outage Justifications (not previously mentioned):

l l The following Refueling Outage Justifications were created and/or revised, as required, to further support the justification and format of the Refueling Outage Justifications. A refueling outage

! frequency previously required NRC prior approval, but will not per OM-10, Braidwood's second interval code. Wording changes were i made when in the process of converting relief requests to refuel

! outage justifications.

a. Previously approved Relief Request VR-16 has been

! incorporated into ROJ-4.

b. Previously approved Relief Request VR-10 has been

( incorporated into ROJ-5. The wording has been revised l considerably.

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c. Previously approved Relief Requests VR-3, VR-6, and VR-15C l

have been incorporated into ROJ-6.

t j d. Previously approved Relief Request VR-15A has been l incorporated into ROJ-7.

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e. Previously approved Relief Request VR-15D has been l

incorporated into ROJ-8. l

f. Previously approved Relief Request VR-29 has been l l incorporated into ROJ-10, with several wording changes. l l
g. Previously approved Relief Request VR-30 has been I incorporated into ROJ-11, with considerable wording changes.

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h. Previous Relief Request VR-5 has been incorporated into ROJ-2, with considerable wording changes. It now explains j the use of an option to acoustically test only one of four loops.
j. Previous Relief Request VR-8 and VR-9 are now ROJ-21 and ROJ-20.

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Attachment A l

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, k. Previously approved relief request VR-19,.has been revised

! moderately and is now covered under ROJ-15. It mentions l partial stroke during operating and discusses other possible test methods. Also deleted the discussion of RCM. J

l. Previous Relief Request VR-24 is now ROJ-16, VR-25 is now ROJ-17, VR-26 is now ROJ-18, VR-27 is now ROJ-19. All have l been moderately revised.
m. ROJ-23,ROJ-24,and ROJ-25 were added. This is due to the Backflow test (Bt), being added to valves 1/2PR002G, l 1/2PR002H, 1/2SI8968, and 1/2WM191.
8. Relief Requests (not previously mentioned).
a. Previous Relief Requests VR-2, 4, and 28 have been combined into VR-2, with considerable wording changes.

i l b. Previously approved relief request VR-31 is now contained in VR-1. It has been revised slightly to further address l difficulties in disassembly with the valve. +

c. Previously approved relief request VR-13 is now contained in VR-4.

l

! d. VR-3 is a new Relief Request for the 1/2CC9495 valves, which

were added to the IST Program,
j. e. Previous relief requests VR-7, VR-11, VR-14, VR-17, VR-18, l VR-21, VR-22, and VR-23 were previously deleted. l t -

l l

14

March 15,1998 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington. D. C. 20555 - 0001

Subject:

Braidwood Station Units 1 and 2 Inservice Testing Program Plan for Pumps and Valves Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating License NPF -72 and NPF-77 NRC Docket Number: 50-456 and 50-457

Reference:

- (1) Revision 7 of the first 10 year interval Imudwood Inservice Testing Program Plan For Pumps and Valves (2) Revision 0 of the second 10 year interval Byron Inservice Testing Plan Pumps And Valves Attached is the Braidwood Station Units I and 2 second ten year interval Inservice Testing Program Plan Pumps and Valves, Revision 0. - As required by 10CFR 50.55a(f)(ii), this Program Plan for Braidwood's second ten year interval has been prepared to the requirements of the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel Code, Subsections IWP and IWV.

The 1989 Edition of ASME Section XI subsequently references the ASMF/ ANSI OM Part 6 for pump testing and ASME/ ANSI OM Part 10 for Valve testing. The Edition and Addenda of ASME/ ANSI OM Part 6 and OM Part 10 is the Oma-1988 Addenda to the OM-1987 Edition.

The Commercial Senice Date for Braidwood Unit I was July 29,1988, and October 17,1988 for Unit 2. As was done for the first interval Inservice Testing Program, Braidwood intends to keep both Units 1 and 2 on a common implementation date. This start date for the second ten year interval for Braidwood Units I and 2 shall be July 29,1998. The second ten year intenal will be from July 29,1998 through and including July 28,2008.

' Where the Code required tests were determined to be impractical, relief requests have been included in this Inservice Testing Program Plan submittal. There are no relief requests being submitted at this time pertaining to the pump portion of the Insenice Testing Program, however there are four relief requests, VR-1, VR-2, VR-3 and VR-4, for the valve portion of the Insenice Testing Program.

VR-1 addresses the same subject as VR-31 of Reference (1). VR-1 was revised for format and clarifying information, but has the same provisions as VR-31 of Reference (1), which was approved per Generic Letter 89-04 and is currently in use at Braidwood. VR-1 also contains the same provisions as VR-5 from Reference (2).

I VR-2 pertains to disassembly and inspection in accordance with Generic Letter 89-04, except the sample plan frequency for some of the valves is every 18 months, whereas Generic Letter 89-04 provides for a refueling outage sample plan frequency. Braidwood used guidance provided in NUREG 1482 Appendix A, which addresses this subject, in preparing VR-2.

VR-3 pertain to disassembly and inspection, per Generic Letter 89-04. VR-4 is the same relief request as VR-13 from Reference (1), except for format revisions. VR-13 was approved and is currently in use at Braidwood. Additionally, VR-4 is nearly identical to VR-8 of Reference (2).

Based on the above discussion, Braidwood plans to implement VR-1, VR-2, VR-3, and VR-4 unless othenvise directed. Justification for these requests are in Section 3.5 " Valve Relief Request" of the attached testing program plan. Also a summary of all changes is attached to facilitate your review.

Braidwood will begin implementation of the updated Inservice Testing Program upon this submittal date for the attached updated Inservice Testing Program Plan, as provided per NUREG 1482 Section 3.3.4. The schedule for completion of the implementation process in regard to procedure revisions is no later than 3 months after the start date of the new interval, which would be 3 months after July 29,1998 (October 29,1998).

Approval of the Braidwood Station Units I and 2 second ten year interval Inservice Testing l Program Plan Pumps and Valves, Revision 0, is requested by July 14,1998.

Please address any comments or questions regarding this matter to Donald W.

Zebrauskas, at (815) 458-2801 extension 2520.

Very truly yours, Timothy J. Tulon SiteVice President Braidwood Nuclear Generating Station

Attachment:

Inservice Testing Program Plan Pumps And Valves Braidwood Nuclear Generating Station Units #1 And #2 l cc: A.B. Beach - Regional Administrator-Rill Stu Bailey - Braidwood Project Manager-NRR C.J. Phillips - Senior Resident Inspector-Braidwood J. A, Gavula - Rlli Oflice ofNuclear Safety - IDNS 1

L

I l

n .

e, i i

Attachment A l

l Summary of Changes for Revision O of the Second Interval Inservice Testing Program Plan Pueps And Valves Braidwood Nuclear Generating station Units #1 And #2 Backgrounds Currently, the Braidwood Inservice Testing Program Pumps and Valves is in accordance with ASME Section XI 1983 Edition. Beginning July 29,1998, Braidwood will be required to update its Inservice Testing Program Pumps and Valves to the requirements of ASME Section XI, 1989 Edition. For pump testing ASME Section XI 1989 Edition references OM-1987 1988 Addenda Part 6. For valve testing, ASME Section XI 1989 Edition references OM-1987 1988 Addenda Part 10. OM Part 10 then references OM Part 1 for relief valve testing.

Revision O Dated January 1998 is the revised Braidwood Inservice Testing

! Program Plan Pumps and Valves, which is in accordance with ASME Section XI 1989 Edition except for specific relief as identified in the Program Plan.

The following is a summary of the major changes of this Revision O of the l Second Interval Inservice Testing Program Plan compared to the current Inservice Testing Program Plan Rev 7. The Revision O Second Interval Inservice Testing Program Plan will become effective July 29, 1998.

I A. General Changes:

1. The IST Program has been separated from the ISI Program and will be maintained as a stand alone document. NRC submittals will ,

continue to be separate from the ISI Program. )

2. A revision summary sheet has been incorporated as the first page of the document to easily illustrate any revisions that are made throughout the second interval.
3. A new Table of Contents Format has been utilized.
4. Code references were revised throughout to reflect the new code.

S. Summary sheets have been added at the beginning of major sections.

1 l 6. All justification sections and relief requests now include a Drawir Number and Drawing Coordinate for each component.

I l

l l

l Attachment A  :

i l

7. OM-1987 1988 Addenda allows testing at refueling outages. As a result, many of the relief requests from the First Interval Inservice Testing Program Plan have been converted into refueling outage justifications in the second Interval Inservice Testing Program Plan. All such refueling outage justifications had some degree of revision when being converted to a refueling outage i justification.
8. Many of the Notes were converted into Cold Shutdown Justifications. They had some degree of revision when converted I to Cold Shutdown Justifications. I I

B. Section 1.0 Information Common to Pumps and Valves:

1

1. The introduction section has now been combined for Pumps and valves, with specific information noted concerning common information (code information, interval dates, etc.) The Program Plan is no longer a pump plan and a valve plan,.but is now one plan with a pump section and a valve section. I i

C. Section 2.0 IST Pump Plans l

1. OM-6 does not require the observation of lubricant level or pressure, the measurement of bearing temperatures, or the measurement of inlet pressure (may still be required to obtain the i required differential pressure). Discharge pressure, rather than differential pressure, is required fer positive displacement I pumps.

1 Results:

A. Inlet pressure, bearing temperature, and lubrication level descriptions and columns have been removed from sections 2.1.1, Pump Table Descriptions, and section 2.1.2, Pump Tables. The wording of the pressure column description was changed, to reflect OM-6.

B. Previous notes associated with lubricant level and inlet pressures were deleted. This eliminates the entire Notes l Section, and the Remarks Column from the pump table.

l 2. Format of the Pump Table Description has changed, and the information is described in a different manner. The Pump Name column is described. Code Class is further described as to what each designation signifies. Deleted the N for non-Code and I

replaced it with G, which is defined as non Code or Codes other than Section XI. It further explains that G is used for the Diesel Oil Transfer pumps and that it will be treated as ASME Section III Class 3 for IST purposes. This was done as the current Rev 7 2

i l

Attachment A l

Program did not use the N in the pump table columns, and used 3 for the Code Class of the Diesel 011 Transfer Pumps. Though Braidwood treats these pumps as class 3 for IST purposes, the j Braidwood Mechanical Department Valve List lists them as G. The j change is to more accurately reflect the actual situation.  !

Deleted the descriptions as to the type of instruments and the l references to calibration and accuracy requirements. This info l was not needed as the Code contains these requirements. Changed ,

the description of vibration, to include additional information l from OM-6. Added that all vibration measurements are in velocity. i Changed the description of pump speed to mention constant speed l pumps. Made several editorial changes to the descriptions to l reflect how they are designated in the pump program tables.

3. The Program description for pumps has been deleted, some of the information is contained in the Introduction and Program l Description. Much of the information has been deleted as it is not j required for Program Plan submittal and does not appear to add value to the Program Plan submittal.
4. Pump Tables:
a. Eliminated the Boric Acid Transfer Pumps from the pump Table. The Boric Acid Transfer Pumps are not required to be j in the IST Program and they were not part of the IST Program I for Rev 7 of the First Interval Inservice Testing Program l Plan. They were listed in the pump table in Rev 7 for l tracking purposes. Pump Technical Position PA-01 of this 1 Rev 0 submittal of the Second Interval Inservice Testing Program Plan mentions that they are tested outside the scope ;

of the IST Program.

b. Corrected typographical error in the pump tables to show that pump speed is measured for pumps lAF0lPB and 2AF0lPB. l
c. Changed the class designation of the diesel oil transfer )

pumps from 3 to G.

d. Corrected the editorial error to now include the 2D00lPD pump along with the appropriate entries in the columns.
e. Corrected the editorial error to show the correct P&ID number for IDOOlPD. 4
f. Corrected the editorial error to show the correct P&ID number for 2SI0lPA and 2SIOlPB.

3

I Attachment A

4. g. Provided the sheet number for several P&ID numbers.  ;
h. Made editorial changes to the pump tables such as different designators to indicate if a test is performed.
1. Changed the Test Interval designator from Quarterly to 3M.
5. Revised the wording in Technical Position PA-02, concerning the Boric Acid Transfer Pumps.
6. Deleted relief request PR-01, regarding pump vibration measurements. Relief Request no longer needed when using OM Part 6 Code. Also deleted reference to this relief request in the pump tables.
7. Deleted previous Relief Request PR-02, which had asked for relief from measuring pump bearing temperatures.
8. PR-03, PR-04, and PR-05 were already previously deleted.
9. Deleted previous Relief Request PR-06, asking for relief to use discharge pressure rather than differential pressure for the Diesel Oil Transfer positive displacement pumps. This is allowed per OM-6. Deleted reference to this relief request in the pump tables. It should be noted that with the deletion of these relief requests from the Pumps Section of the Second Interval Inservice Testing Program Plan, there are no longer any pump relief requests.

I

10. Deleted the reference to BwVP 200-1.

l 11. Added Note to pump reference list to show that Tech Spec 4.0.5 l will become 5.5.8 when the Improved Technical Specifications are i

! implemented.

D. Section 3.0 IST Valve Plant

1. SCOPE:

One of the major areas of review for the ten year update, was t scope. Braidwood/ Byron performed a joint scope review in 1994, per NTS item 456-100-93-01100A and OSR #94-131, and incorporated all valves, excep. relief valves, into previous First Interval Program revisions. It was felt that the relief valve additions would not be required until the new code was adopted.

Additionally, since the completion of the review in June, 1994, positions regarding " thermal" relief valves were in question, and another review of relief valves was completed in 1995. The following relief valves are being added to the IST Program.

4

l l

l Attaciunent A D 1. a. Per the Braidwood/ Byron Scope review in 1994, these 51 relief valves will be added to the program:

OCC9432 OGW9300A-F OWOO28A/B 1/2CV8117 1/2CS08MA,MB 1/2CV8118 1/2CV8121 1/2DOO20A-D l 1/2RYO30A/B 1/2VF01M 1/2SA148A-D 1/2SI8853A/B  ;

1/2SI8856A,B 1/2SI8858

b. Per a follow-up review of relief valves, these additional 18 relief valves will be added to the program :

1/2CV8124 1/2SI8851 1/2SI8842 1/2 SIB 855A-D 1/2SI121A/B

c. Due to a Zion audit, the following 8 CC check valves were added for the closure direction. A procedure currently exists to test these valves, and they have been tested during AIR 06 and A2R06:

1/2CC9495A-D

d. The following fail safe testing will be added to the IST Program Tables, which is already being performed in stroke time procedures:

1/2VQOO3, 4A, 4B, SA-C 1/2CV8114, 1/2CV8116

e. Stroke time testing and indication testing were added for the following valves. (Braidwood is currently only performing fail-safe testing):

1/2SX147A/B

f. Closure testing was added for 1/2CV8546 and 1/2SI8926 per concerns raised at Zion Station. These check valves had previously only been tested in the open direction. The additional closure tests are currently included in a procedure, and were tested during A1R06 and A2R06.
g. The following testing will be deleted from the IST Program.
1) 1/2CC9486 check valve full stroke test. Per the Braidwood/ Byron Scope review, it was determined that the valve does not have an IST open safety function.

5

Attactonent A

2) 1/2CV128 position indication test (stroke timed locally) remote position indication test is not required.

D. 2. Valve Table Descriptions:

a. Revised references from particular paragraphs from ASME XI l 1983 Summer 1983 to the appropriate paragraph from OM Part 10 1988 Addenda or OM Part 1 1987.

L b. Revised the description of Class to better describe the l designators. Eliminated the designator "T for tracking purposes only".

1 I

c. Described the valve Categories in more detail.
d. Under Test Methods revised the description of the (Bt)

Backflow Test and the (Ct) Check Valve Full Stroke Test.

e. Revised (Ft) Fall Safe Test to indicate more specifically (Fo) Fail Safe Test Open or (Fc) Fail Safe Test closed.
f. Revised the description of the seat Leakage Test (Lt), to include that the tests will also be performed in accordance with 10CFR50.55a(b)(2)vii.
g. Revised the description of the partial stroke test (Xt), to describe that it is done when plant conditions allow.
h. " Test Mode" column revised to indicate " Test Frequency" with the following revised or new designations:

I

1) Normal Operation (OP) revised to indicate Quarterly ]

(Q).  !

2) Semi-annual (S) test frequency removed. This frequency was being used for some VQ Tech Spec leak ,

test requirements, but has been revised to fall under l the Appendix J test frequency. )

3) Cold Shutdown (CS) slightly revised wording to more closely match OM Part 10.
4) Two Year (2Y) frequency added mainly due to the requirement that ind' cation tests be performed at least once every two years.

6

I I

Attactunent A

5) Five Year (5Y) and Ten Year (10Y) frequencies created to encompass relief valve frequencies for class 1 valves, and class 2 or 3 valves, respectively.
6) Sample Disassembly (SD) designation was created for-those check valves which are disassembled to satisfy IST requirements.
7) The Appendix J (AJ) designation was added for those valves which are tested at the frequency of the Appendix J leak test. Testing may go beyond a refueling outage frequency for the good performers, in accordance with Appendix J Option B.
1. Deleted the " Remarks" column, and added " Cold Shutdown Justification" and " Refueling Outage Justification" columns.

OM- 10 allows the licensee to justify cold shutdown and refueling outage frequencies without NRC approval. Per the 1983 Edition, only cold shutdown frequencies (at Braidwood, indicated with a brief Note) could be justified without NRC approval.

3. Valve Tables:

Several changes were made to the Notes, the Valve Technical Positions, Cold Shutdown Justifications, and the Relief Requests from the Revision 7 first interval IST Program. Additionally, the Rev 0 second interval Program contains additional Cold Shutdown Justifications and Refueling Outage Justifications. These changes included items which would be reflected in a change to the Valve Tables, such as numbering changes, the Notes; Justifications; etc.

which are applicable to a valve, or a change in frequency. Many of these changes are addressed in subsequent sections of this Summary of Change. Where such description of the change are addressed in subsequent sections, the change will not additionally ,

be explained in this Valve Tables Section. The changes described l in the Section 3 Valve Tables are primarily changes which are i not addressed in other sections.

I

a. For 3 month (quarterly) test frequency, (OP) was changed to (Q). >
b. All of the Position Indication tests (IT) now indicate (2Y) j

( for test frequency, previously it was (RR). All of these i tests receive a Note 4.

I i

c. For containment isolation valves (designated by Note 1) for which the leak test is not being used to satisfy other test requirements, such as a check valve backflow test (Bt), the 7

Attachment A test frequency is now designated as AJ. For containment isolation valves for which the leak test (Lt) is also used to satisfy other test requirements, such as a check valve backflow test (Bt), the frequency remains RR (as in the First Interval Rev.7 Program), because the leak test would still have to be done on a refueling outage frequency to satisfy the backflow test (Bt) frequency requirements.

d. All valves for which the Test Method is identified as requiring a full stroke test (ST), except for manual valves, I now have Toch Position VA-3 indicated in the Tech Position Column.
e. The test frequency for all relief valves has been revised from refueling outages RR to either SY or 10Y.

I

f. Valves OAB8473 and 1/2AB8487 were removed from the Valve Tables. As described in Valve Technical Position VA-5, these valves are outside the scope of the IST Program. This was the same position as the Revision 7 first interval IST Program, and the testing performed outside of the IST Program is the same. The difference from Re"ision 7 of the  !

first interval IST Program is that the valves will no longer l be listed in the Valve Tables. l l

g. The Valve size fcr 1/2Cc685 was revised from 4 inches to 3 inches to reflect the correct valve size as identified on the P& ids.
h. The valve size for 1/2MS019A-D was revised from 6 inches to 8 inches to reflect the correct valve size as identified on the PGIDs.
i. The valve size for OSXOO7 was changed from 30 inches to 24 inches to reflect the size on the P& ids.

i

j. For valves 1/2SX147A and 1/2SX147B, changed the Normal Position from N/A to O (open).
k. For Valves 1/2PR002G, 1/2PR002H, 1/2SI8968, and 1/2WM191 the Backflow (Bt) test was added. This was not an added test, as the leak test (Lt) did perform the backflow test. The change is that the table now reflects the test. Additionally, the term passive was deleted for these valves.
1. For valves 1/2RH8708A,B added the closed stroke direction.
m. Valves 1/2SX116A and 1/2SX116B were removed from the System and are now deleted from the tables.

8

I

}

I l

, Attachment A l

l i l l l l

n. Changes were made to the valve tables to reflect the changes '

indicated in D.1 Scope.

1

4. Notes
a. Note 1 was created from previous Relief Request VR-1, which allowed leak rate testing of containment isolation valves to be completed via the Appendix J Leak Test. OM-10 allows this provision per paragraph 4.2.2.2. This note now just references which valves are affected and that 10CFR50.55 a(b)(vii) also applies.

l

b. Previous Note 1 has been made into Cold Shutdown l Justification VC-1. The partial stroke requirement every three months was deleted as explained in VC-1. Additional information was added to the Cold Shutdown Justification to support the reasoning behind it.
c. Previous Notes 2,4, and 5 have been incorporated into new l Cold Shutdown Justifications VC-2, VC-4, and VC-5.

Additional information was added to the cold shutdown justifications to support the format and reasoning behind them,

d. Previous Note 6 is now Note 16, and still identifies the valves which are pressure isolation valves. The note has been revised slightly, basically deleting information already contained in other portions of the IST Program.
e. Previous Notes 7-10 have been incorporated into new Cold shutdown Justifications VC-6 through VC-9. Additional information was added to the cold shutdown justifications to support the format and reasoning behind them.
f. Note 11 (the part associated with the stroking of the 1/2VQOO1A,B and 1,2VQOO2A,B valves) has been incorporated into new cold Shutdown Justification VC-24. Additional information was added to the new cold shutdown justification to support the format and reasoning behind it and now mentions that these valves are blocked closed. The rest of previous note 11 concerning leak testing frequencies of VQ valves are now covered under Note 1.

I I

t

g. Previous Notes 12 is now VC-11, except for the 1/2AF001A and 1/2AF001B valves. These valves are onw included in Refueling Outage Justification ROJ-15, with additional information including information from VR-19.

9 i

r Attachauent A

h. Previous Notes 13 and 14 have been incorporated into new Cold Shutdown Justifications VC-12 and VC-13. Additional information was added to the cold shutdown justifications to support the format and reasoning behind them.
i. Portions of previous Notes 16, 17, and 21 have been incorporated into Refueling Outage Justification ROJ-14.

l Additional information was added to the new refueling outage l justification to support the format and reasoning behind it.

I

j. Previous Note 20 is now Note 5.
k. Previous Note 22, concerning the monitoring of check valves 1/2PS231A/B open quarterly, has been moved to Note 2.
1. Previous Note 23 is now Note 7, and has been revised to indicate the correct valve EPNs (SI8948A/B revised to SI8941A/B.
m. Previous Note 24 is now Note 8.

l n. Previous Note 28 has been incorporated into Refueling Outage Justification ROJ-22. Additional information was added including explaining non-intrusive testing methods and justification to change the test frequency from cold shutdown to refueling.

o. Previous Note 30 has been incorporated into new cold shutdown Justification VC-11. Additional information was added to the new cold shutdown justification to support the format and reasoning behind it.

I

p. A portion of previous Note 31, involving 1/2SI8919A/B, has l

l been incorporated into Note 9, with some wording revisions.

The remainder has been deleted,

q. Previous Note 34 has been revised and is noa Note 11.

l l

r. The subject of Previous Note 35 has been incorporated into l

ROJ-9. Additionally, previous Relief Request VR-15B has also been incorporated into ROJ-9, with revised wording.

10

I Attachment A

s. Previous Note 36 is now Note 12, and is also addressed in VC-14.
1) Cold Shutdown frequency for the stroke of 1/2RY455A and 1/2RY456 placed in Cold Shutdown Justification VC-
14. Additional information was added to the new cold shutdown justification to support the format and reasoning behind it.
2) Indication testing at Refueling was placed in Note 12.
t. Previous Note 37, involving the stroke time testing of 1/2RH8716A/B, has been expanded and is now covered under new cold Shutdown Justification VC-18.
u. Previous Note 40 has been incorporated in Cold Shutdown Justification VC-19.
v. Previous Note 38, involving the closure test of the 1/2FWO36A-D valves, has been expanded and is now covered under Cold Shutdown Justification VC-20.
w. Previous Notes 15, 18, 19, 32, and 39 were previously deleted.
x. Previous Notes 25 is now included in ROJ-1. Previous Note 26 is included in ROJ-7. This was done as Braidwood now includes the (Bt) backflow test for these valves in the IST Program.
y. Notes 27 and 29 were deleted as the valve functions they describe are more appropriate to address in the Scope Basis Document.
z. Note 3 is now VC-3 with additional wording, aa. Note 33 was not used at Braidwood and has been deleted.

bb. New Notes 3, 4, 6, 13, 14, and 15 were added in this revision.

5. Valve Technical Positions
a. Previous Technical Position VA-01, Method of Stroke Timing valves, has been revised accordingly for the new code and still remains as VA-1. The method of stroke timing valves locally was added.

11 1

1 o .. '.

Attachment A

b. Previous Technical Position VA-02, Method of Fall Safe Testing Valves, has been revised slightly, but still remains J VA-2.
c. Previous Technical Position VA-03, Method of Full Stroke (Ct) and Backflow (Bt) Exercising valves, was deleted. No methods were discussed in which a position had to be taken.
d. Portions of previous Technical Position VA-04, Determining limiting values of full-stroke times for Power-Operated Valves, portions of Previous Relief Request VR-20, which dealt with establishing Acceptance Criteria, and previous relief request VR-12, concerning fast-acting valves, have ,

been reviewed and incorporated into new Technical Position l VA-3, method of Establishing Acceptance Criteria for Power-Operated Valves.

e. Previous Technical Position VA-05 has been revised slightly, but remains VA-5. Previous Technical Position VA-06 was revised slightly to delete references to the previous Code test methods, but remains VA-6.
f. Previous Technical Position VA-07, concerning the exercising of CC manual valves at a U-2 Cold Shutdown Frequency, has been moved to ROJ-3 and has been revised considerably. The frequency has been changed to refueling outages instead of U-2 cold shutdowns. The revisions reflect the test methods used at Braidwood, and now establishes the exercising frequency at U-2 Refueling Outages.
g. New Technical Position VA-4, Method of Position Indication Testing, has been added to discuss Braidwood's position on the subject.
6. Cold Shutdown Justifications (not previously in Item 3):
a. Presious Cold Shutdown Justification VC-4 has been revised slightly and is now Cold Shutdown Justification VC-10.
b. Previous cold Shutdown Justification VC-1 has been moved to  ;

Cold Shutdown Justification VC-21 with some revision. l l

c. Previous Cold Shutdown Justification VC-2, containing the closure testing of the 1/2CV8355A-D and the 1/2CV8368A-D valves, has been split up. The 1/2CV8355A-D valves have been moved to cold Shutdown Justification VC-22. The j 12 I L

l c .. .

Attactunent A 1/2CV8368A-D valves have been moved to Refueling Outage Justification ROJ-12. ROJ-12 justifies the change from cold shutdown testing to a refueling outage frequency, based on using radiography to test these valves.

l

d. Previous Cold Shutdown Justification VC-3 has been moved to Cold Shutdown Justification VC-23, with slight revisions, t

l 7. Refueling Outage Justifications (not previously mentioned):

The following Refueling Outage Justifications were created and/or revised, as required, to further support the justification and format of the Refueling Outage Justifications. A refueling outage frequency previously required NRC prior approval, but will not per OM-10, Braidwood's second interval code. Wording changes were made when in the process of converting relief requests to refuel outage justifications.

l l a. Previously approved Relief Request VR-16 has been  !

incorporated into ROJ-4.

b. Previously approved Relief Request VR-10 has been incorporated into ROJ-5. The wording has been revised considerably.
c. Previously approved Relief Requests VR-3, VR-6, and VR-15C l have been incorporated into ROJ-6.
d. Previously approved Relief Request VR-15A has been incorporated into ROJ-7.
e. Previously approved Relief Request VR-15D has been incorporated into ROJ-8.
f. Previously approved Relief Request VR-29 has been incorporated into ROJ-10, with several wording changes.
g. Previously approved Relief Request VR-30 has been incorporated into ROJ-11, with considerable wording changes.
h. Previous Relief Request VR-5 has been incorporated into ROJ-2, with considerable wording changes. It now explains the use of an option to acoustically test only one of four loops,
j. Previous Relief Request VR-8 and VR-9 are now ROJ-21 and ROJ-20.

13

)

Attachment A ,

l l

k. Previously approved relief request VR-19, has been revised moderately and is now covered under ROJ-15. It mentions partial stroke during operating and discusses other possible )

test methods. Also deleted the discussion of RCM. ]

1. Previous Relief Request VR-24 is now ROJ-16, VR-25 is now ROJ-17, VR-26 is now ROJ-18, VR-27 is now ROJ-19. All have been moderately revised.
m. ROJ-23,ROJ-24,and ROJ-25 were added. This is due to the Backflow test (Bt), being added to valves 1/2PR002G, 1/2PR002H, 1/2SI8968, and 1/2WM191.
8. Relief Requests (not previously mentioned).
a. Previous Relief Requests VR-2, 4, and 28 have been combined into VR-2, with considerable wording changes.
b. Previously approved relief request VR-31 is now contained in ,

VR-1. It has been revised slightly to further address difficulties in disassembly with the valve.

I

c. Previously approved relief request VR-13 is now contained in VR-4.

l

d. VR-3 is a new Relief Request for the 1/2CC9495 valves, which were added to the IST Program,
e. Previous relief requests VR-7, VR-11, VR-14, VR-17, VR-18, VR-21, VR-22, and VR-23 were previously deleted.

14

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