RS-25-132, Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request
| ML25232A248 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/20/2025 |
| From: | Humphrey M Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-25-132 | |
| Download: ML25232A248 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-25-132 August 20, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket N0. 50-461
Subject:
Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request
References:
- 1.
Letter from M. D. Humphrey (Constellation Energy Generation, LLC) to U.S. NRC, "License Amendment Request for Proposed Change to the USAR to Approve Alternate Method of Verifying MSIV Closure Reactor Protection System Response Time," dated June 26, 2025 (ADAMS Accension No. ML25177C292)
- 2.
Email from B. Wetzel (U.S. NRC) to N. Lien (Constellation Energy Generation, LLC, " Final RAI - Clinton Power Station, Unit 1 - A Proposed Change to the USAR to Approve Alternate Method of Verifying MSIV Closure RPS Response Time (EPID No. L-2025-LLA-0099), " dated August 6, 2025
- 3.
Letter from M.D. Humphrey (Constellation Energy Generation, LLC) to U.S. NRC, "Response to Request for Additional Information Related to License Amendment Request for Clinton Power Station to Approve a Methodology for Testing MSIV Closure RPS Response Time, " dated August 13, 2025 (ADAMS Accession No. ML25225A226)
In Reference 1, in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, Constellation Energy Generation, LLC (CEG) requested an amendment to Facility Operating License No. NPF-62 for Clinton Power Station, Unit 1. The proposed amendment would permit a USAR change that will allow for an NRC-approved methodology for Main Steam Isolation Valve (MSIV) - Closure Reactor Protection System (RPS) response time testing.
August 20, 2025 U.S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC requested additional information that was needed to complete a review of that license amendment request. In Reference 3, CEG responded to that request for additional information.
On August 15, 2025, a phone call was held between the NRC and members of CEG. The NRC required additional detail on how the revision to procedure 9431.10 Reactor Protection System (RPS) Main Steam Line Isolation Valve (MSIV) Channel Calibration, given in Reference 3 would ensure that MSIV limit switch degradation would be identified. The Attachment to this letter addresses that request with additional technical details and the newly revised procedure (9431.10). The specific change is on page 14 in that procedure. Procedures 9431.10 A through G are for the other seven channels but will be revised the same way.
CEG has reviewed the information supporting the finding of No Significant Hazards Consideration, and the Environmental Consideration, which were previously provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Nick Lien at (779) 231-6283.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 20th day of August 2025.
Respectfully, Mark Humphrey Sr. Manager Licensing Constellation Energy Generation, LLC
Attachment:
Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request cc:
Regional Administrator-NRC Region III NRC Senior Resident Inspector - Clinton Power Station Illinois Emergency Management Agency - Department of Nuclear Safety and Homeland Security
- Humphrey, Mark D.
Digitally signed by Humphrey, Mark D.
Date: 2025.08.20 13:19:12
-05'00'
ATTACHMENT Clinton Power Station Docket No. 50-461 Facility Operating License No. NPF-62 Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request
ATTACHMENT Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request
- 1.
Scope The following Constellation Energy Generation, LLC (CEG) supplement response provides an enhancement to a procedure revision for Reactor Protection System (RPS) Main Steam Line Isolation Valve (MSIV) Channel Calibration (9431.10) that was provided as an attachment in the Clinton Power Station (CPS) Request for Additional Information response letter dated August 13, 2025 (ML25225A226). This enhancement is in support of discussion that occurred on August 15, 2025, between the NRC and CEG via teleconference. The NRC required additional detail on how the 9431.10 procedure revision would ensure that Main Steam Isolation Valve limit switch degradation would be identified.
- 2.
NRC Request The Definitions section 2.2 of 9431.10H Rev 2, provided the following definition: Sluggish Response of snap-acting limit switch - Switch operates with an indication of delay in switch response or erratic electrical indications. Explain how this definition provides adequate instruction to identify limit switch degradation and the acceptance criteria.
- 3.
CEG Response As part of the discussion, CEG explained that this is a spring-actuated limit switch, and its operation is observable at the switch during performance of this procedure. However, the NRC requested this be further explained in the procedure. Additional technical details are provided in the following paragraphs.
The limit switch utilized for the MSIV position input to the RPS system is a snap acting NAMCO model EA740-50100. The switch contacts are normally closed with the MSIV in the full-open position. As the MSIV moves in the closed direction, the limit switch arm is repositioned to open the electrical contacts. The contacts are spring loaded to ensure reliable, positive response of the switch during actuation. The most common degradation mechanism is hardening of the lubrication inside the switch resulting in a delay in actuation of the switch. This is readily observed while stroking the MSIV and observing the switch for proper operation. Any delay in switch response would result in the replacement of the limit switch.
In addition, the calibration procedure requires coordination between the Main Control Room (MCR) operator controlling the valve, an Instrumentation Technician in the MCR monitoring electrical response (observation of voltage change from nominal 125 VDC to 0 VDC), and an Instrumentation Technician locally at the MSIV observing operation of the valve and limit switch and marking valve position when the limit switch electrically changes state. Instrumentation Technicians that have experience performing this test report that switch actuation is normally rapid as soon as the setpoint is reached due to the spring-loaded operation of the switch. The
ATTACHMENT Supplement to Clinton Response to Request for Additional Information Related to Response Time Testing License Amendment Request Instrumentation Technician in the MCR can audibly hear the switch actuation over the headphones while observing the position indicating lights and digital voltmeter. In this way, any erratic electrical response can be observed.
Because the limit switches are bolted in place and the actuator arms are splined to the shaft, other than delayed response, there is no mechanism for drifting of the limit switch setpoint. Any delay in the response of the limit switch would be manifested as further valve travel when being monitored electrically. Changes in measured as-found limit switch setting can be trended to determine if any delay is occurring.
The attached revision of 9431.10H addresses this request. Key changes made are to step 8.1.15, which now states, Verify there is no sluggish or delayed response of the snap-acting limit switch. The or delayed was added in the new revision. Step 9.2.4 continues to provide the acceptance criteria to notify supervision if any step was unacceptable.
CPS 9431.10H Rev. 3 Page 1 of 25 RPS MAIN STEAMLINE ISOLATION VALVE B21-F028D CHANNEL CALIBRATION SCOPE OF REVISION:
Revison to add step 8.1.15 Bullet 1 to look for sluggish response during MSIV stroke. PCRA# 4878399-02 [Jim LoPresto]
CPS 9431.10H Rev. 3 Page 2 of 25 1.0 PURPOSE 1.1 To provide instructions for performance of a channel calibration of the Reactor Protection System (RPS) Main Steamline Isolation Valve (MSIV) Outboard B21-F028D as specified in CPS ITS SR 3.3.1.1.13 T6.
1.2 Performance of this procedure satisfies the functional test requirements of ITS SR 3.3.1.1.9 T6 1.3 This procedure also partially satisfies the Logic System Functional requirements of SR 3.3.1.1.15 T6 and SR 3.3.1.1.17 T6 for these MSIV channels.
1.4 ISI Program - Partial Exercise of MSIVs 2.0 DISCUSSION/DEFINITIONS 2.1 Discussion
2.1.1 Frequency
<<LBD-1, LBD-2>>
- 1. Normal Frequency in accordance with the Surveillance Frequency Control Program (SFCP).
- 2. Other Triggers - Any maintenance that may disturb limit switch setpoint.
2.1.2 This procedure includes steps necessary to perform the Channel Calibration of the instrument channel up to the point where this channel converges with other channels.
2.1.3 This procedure also checks the logic associated with the Main Steam Line (MSL) D BYPASS switch operation. This procedure is only performed during Operational Condition 4 or 5 due to the prerequisite that the REACTOR SYSTEM MODE switch is NOT in RUN position. This channel provides trip signals to the Reactor Protection System logic.
2.1.4 This procedure also includes steps necessary to perform the individual instrument calibrations needed to restore the channel to the loop specifications. The components in the loop are as follows:
Loop D Limit Switch on Valves B21-F028D V-112-781 Annunciator Window 3-C H13-P680-05A (5004)
Computer Point B21NC050
CPS 9431.10H Rev. 3 Page 3 of 25 2.1.5 Performance of this procedure satisfies the requirements of CPS 9031.10, RPS Main Steam Line Isolation Valve Channel Functional 2.2 Definitions Sluggish Response of snap-acting limit switch - switch operates with an indication of delay in switch response or erratic electrical indications.
3.0 RESPONSIBILITY The Manager - Instrument Maintenance Department (IMD) shall be responsible for the implementation and review of this procedure.
4.0 PRECAUTIONS 4.1 Close proximity to the moving parts on the MSIV is necessary to perform this procedure. Extreme care should be exercised to avoid personnel injury during valve movement.
4.2 Improper implementation of this procedure could result in a scram initiation signal to occur. Ensure that performance of this channel calibration does not satisfy any 2/4 logic functions which would cause unwanted responses (refer to step 5.11).
4.3 Do not reuse pipe plug. When removing or installing a pipe plug, care shall be taken to restrain the assembled operating lever so the applied torque is not transmitted to the switch shaft.
CPS 9431.10H INITIAL Rev. 3 Page 4 of 25 5.0 PREREQUISITES 5.1 Verify calibration due-date of test equipment to be used to ensure calibrations up-to-date.
5.2 Establish Communications between the Main Control Room (MCR) and the Turbine Building Main Steam Tunnel V-110-762 (jack G17) for performance of Sections 8.1, 8.2, 8.3 and 8.4.
5.3 In conjunction with Shift Management, review the following impact statements and referenced Operability Impacts to determine required plant status to perform this test:
OPERABILITY IMPACTS CPS ITS LCO 3.3.1.1, Reactor Protection System (RPS)Instrumentation, Table 3.3.1.1-1, item:
- 6. Main Steam Line Isolation Valve - Closure CPS ITS LCO 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation, Table 3.3.6.1-1, item:
- 1. Main Steam Line Isolation d) Condenser Vacuum - Low OTHER SYSTEMS AFFECTED - IF Condenser Vacuum NOT being simulated, THEN Condenser Low Vacuum Bypass Switches for all divisions will be placed in BYPASS to override Low Condenser Vacuum Trip Signal.
DIV 1 OR 4 MSIV CL TRIP [5004-3C]
DIV 2 OR 3 MSIV CL TRIP [5005-3C]
MAIN CONDENSER LOW VACUUM BYPASS (5067-4E)
MAIN CONDENSER LOW VACUUM BYPASS (5066-4E)
Computer Points:
B21NC050 RPS TRIP - Yes, Reactor Scram CRVICS ISOLATION - No Impact
CPS 9431.10H INITIAL Rev. 3 Page 5 of 25 5.3 (contd)
LOGIC TYPE - 2/4, One Inboard MSIV Switch or One Outboard MSIV Switch on the same steam line constitutes one input to the 2 out of 4 logic.
Any 2 inputs to the 2 out of 4 logic will cause a SCRAM.
COINCIDENT CHANNELS TO PREVENT ACTUATION None: MSIV closure scram is bypassed with the mode switch in SHUTDOWN position.
PLANT/SYSTEM CONDITIONS ASSUMED FOR TEST:
This procedure is only performed during operational condition 4 or 5.
Able to Open MSIVs
/
SMngt Performer 5.4 Obtain Shift Management permission (Initials, Date and Time) prior to performing this test.
/
DATE TIME SMngt
5.5 Operations
IF Condenser Vacuum NOT being simulated, THEN Verify MSL D BYPASS switch is in NORM [5067B].
IV /
5.6 Operations
Verify Reactor System Mode switch is NOT in RUN [H13-P680-11E2].
IV /
CPS 9431.10H INITIAL Rev. 3 Page 6 of 25
5.7 Operations
Verify occurrence of the following:
- 1. Annunciator DIV 1 MSL A CL SCRAM BYP/NOT IN RUN is alarming [5004-1G].
IV /
- 2. Annunciator DIV 2 MSL B CL SCRAM BYP/NOT IN RUN is alarming [5005-1G].
IV /
Annunciator DIV 3 MSL C CL SCRAM BYP/NOT IN RUN is alarming [5005-2G].
IV
/
- 4. Annunciator DIV 4 MSL D CL SCRAM BYP/NOT IN RUN is alarming [5004-2G].
IV /
OPS IMD 5.8 IF the following annunciators are in alarm OR Condenser Vacuum is being simulated, THEN proceed to step 5.14 and N/A steps not required.
If annunciators not in alarm, THEN proceed to step 5.9.
- 1. MAIN CONDENSER LOW VACUUM BYPASS (5067-4E)
- 2. MAIN CONDENSER LOW VACUUM BYPASS (5066-4E)
CPS 9431.10H INITIAL Rev. 3 Page 7 of 25 NOTE Valves out of service for maintenance may be N/Ad.
5.9 Operations
Place/verify the following switches in CLOSE:
5067C 1.
B21H-F028A MAIN STEAM LINE A OUTBD MSIV IV
/
- 2. B21H-F028B MAIN STEAM LINE B OUTBD MSIV IV /
- 3. B21H-F028C MAIN STEAM LINE C OUTBD MSIV IV /
- 4. B21H-F028D MAIN STEAM LINE D OUTBD MSIV IV /
- 1. B21H-F022A MAIN STEAM LINE A INBD MSIV IV /
- 2. B21H-F022B MAIN STEAM LINE B INBD MSIV IV /
- 3. B21H-F022C MAIN STEAM LINE C INBD MSIV IV /
- 4. B21H-F022D MAIN STEAM LINE D INBD MSIV IV /
OPS IMD 5.10 Notify CRS/RO the following annunciators will alarm in step 5.11:
- 1. MAIN CONDENSER LOW VACUUM BYPASS (5067-4E)
- 2. MAIN CONDENSER LOW VACUUM BYPASS (5066-4E)
CPS 9431.10H INITIAL Rev. 3 Page 8 of 25 5.11 Operations: Momentarily place following switches in BYPASS, then return switches to AUTO.
5067B
IV /
Div 4 CONDENSER LOW VACUUM (B21H-S24D)
IV
/
IV /
IV /
OPS IMD 5.12 Operations: Momentarily depress INBOARD ISOLATION SEAL IN RESET (5066B).
OPS 5.13 Operations: Momentarily depress OUTBOARD ISOLATION SEAL IN RESET (5067B).
OPS 5.14 IF plant conditions do not allow all MSIVs to be open, THEN jumpers may be installed below to provide a signal to logic by simulating the appropriate MSIV is open. IF a jumper(s) is not required, THEN this step may be N/Ad.
1B21F022A 1H13P706A TM015 Terminals 9 & 10 CV /
1B21F022B 1H13P707B TM008 Terminals 9 & 10 CV /
1B21F022C 1H13P708B TM004 Terminals 7 & 8 CV /
1B21F022D 1H13P709B TM004 Terminals 7 & 8 CV /
1B21F028A 1H13P706A TM015 Terminals 7 & 8 CV /
1B21F028B 1H13P707B TM008 Terminals 7 & 8 CV /
1B21F028C 1H13P708B TM004 Terminals 5 & 6 CV /
1B21F028D 1H13P709B TM004 Terminals 5 & 6 CV /
CPS 9431.10H INITIAL Rev. 3 Page 9 of 25 5.15 Operations: OPEN, verify OPEN or verify jumper installed per step 5.14 for OPEN inboard MSIV's 1B21-F022A, B, C, D at 5066C and outboard MSIV's 1B21-F028A, B, C, D at 5067C, per 3101.01.
IV /
OPS IMD 5.16 Operations: Verify none of the following alarms/trips are present; if any are present, refer to step 6.2.
- 1. DIV 1 OR 4 MSIV CL TRIP annunciator on panel 5004 window 3-C.
IV /
- 2. DIV 2 OR 3 MSIV CL TRIP annunciator on panel 5005 window 3-C.
IV /
OPS IMD 6.0 LIMITATIONS 6.1 If during the performance of this Procedure a SCRAM signal occurs, performance of this procedure shall be halted. Contact Operations for directions prior to restoring channel or recommencing test.
6.2 If any of the alarms/trips listed in step 5.16 are present, performance of this procedure will cause a scram initiation signal to occur.
Notify IMD Supervision and obtain Shift Management permission prior to continuing.
CPS 9431.10H INITIAL Rev. 3 Page 10 of 25 7.0 MATERIALS/TEST EQUIPMENT 7.1 The following is a list of the test equipment that is required for the performance of this procedure.
Equivalent test equipment may be used.
7.1.1 Multimeter (DMM) to monitor contact/relay operation Type:
Fluke 45 Range:
0 - 125 VDC Accuracy: N/A 7.1.2 12 inch metal rule or tape measure (capable of measuring 64ths of an inch).
7.1.3 Scribe 7.1.4 Pipe Plug - SZ4005 (set screw) 7.1.5 3/16" Hex Key (allen wrench) 7.1.6 Portable lighting <<CM-1>>
CPS 9431.10H INITIAL Rev. 3 Page 11 of 25 8.0 PROCEDURE 8.1 Loop Calibration of RPS MSIV Limit Switch NOTE Refer to Figure 1 for MSIV component layout.
8.1.1 Verify or scribe a mark, on limit switch bracket at lower surface of bottom spring seat assembly of valve B21-F028D.
8.1.2 Operations
Place MAIN STEAMLINE D OUTBD MSIV switch to CLOSE TEST [5067C].
IV /
OPS IMD NOTE The following step will stroke the MSIV, be ready to measure the stroke distance from full open to full shut.
The MSIV test switch is a momentary pushbutton type and is required to be held in until the desired valve travel is achieved. Releasing the switch will return the MSIV to OPEN.
WARNING Performance of the following step will cause valve movement.
8.1.3 Operations
Depress MAIN STEAMLINE D OUTBD MSIV TEST switch [5067C].
OPS 8.1.4 Verify or scribe a mark, on limit switch bracket at lower surface of bottom spring seat assembly of valve B21-F028D.
8.1.5 Operations
Release MAIN STEAMLINE D OUTBD MSIV test switch.
OPS 8.1.6 Measure stroke distance from full open to full close. Record stroke distance below.
Stroke Distance = _____________ inches
CPS 9431.10H INITIAL Rev. 3 Page 12 of 25 FIGURE 1 MSIV COMPONENT LAYOUT
CPS 9431.10H Initial Rev. 3 Page 13 of 25 8.1.7 Verify the following:
All Inbd (B21-F022A,B,C,D) and Outbd (B21-F028A,B,C,D) MSIV's are OPEN, or jumper installed per step 5.14.
Annunciator DIV 1 or 4 MSIV CL TRIP is reset
[5004-3C].
Computer Point B21NC050 is reset.
8.1.8 Calculate the acceptable and allowable values and tolerances in the following table.
An example is given in Appendix A.
Stroke Distance (8.1.6)
Multiply Multiply Round to nearest whole #
Calculated value (inches)
(inches)
Maximum AFT (13% closed) x 64=_____
x.13=_____
round=_____
down
_______/64 (A)
Minimum AFT (1% closed) x 64=_____
x.01=_____
round=_____
up
_______/64 (B)
Maximum ALT (9% closed) x 64=_____
x.09=_____
round=_____
down
_______/64 (C)
Minimum ALT (5% closed) x 64=_____
x.05=_____
round=_____
up
_______/64 (D)
Acceptable Limit TRIP SETPOINT (7% closed) x 64=_____
x.07=_____
round=______
down
_______/64 (E)
Allowable Limit Trip
( 13% closed) x 64=_____
x.13=_____
round=______
down
_______/64 (F) 8.1.9 Independent Verifier: Verify calculations in step 8.1.8 are correct.
Ind Ver 8.1.10 Enter the values from step 8.1.8 into the data table in step 8.1.14 AND 8.2.8.
CPS 9431.10H Initial Rev. 3 Page 14 of 25 CAUTION 125 VDC exists at terminals. Ensure all necessary safety precautions are taken while working on energized equipment.
8.1.11 In Main Control Room, connect a DMM, set to read 125vdc, to the terminals listed below for the channel under test.
B21-F028D: H13-P709B, TM004, Terms 5(+)
6(-)
WARNING Performance of the following step will cause valve movement.
8.1.12 Operations: Depress MAIN STEAMLINE D OUTBD MSIV TEST switch [5067C].
OPS 8.1.13 WHEN limit switch LS-5 opens, as indicated by DMM, THEN note position of lower surface of bottom spring seat assembly on limit switch bracket.
8.1.14 Record valve travel in AS FOUND column of data table. <<LBD-1>>
Desired Value (inches)
Tech Spec Allowable Limit (inches)
Minimum Acceptable (inches)
B21-F028D Valve Travel OPEN As Found (inches)
Maximum Acceptable (inches)
______/64 (E)
_____/64 (F) 13% closed
_____/64 (D)
_____/64 to _____/64 (B) (A)
_____/64 (C) 8.1.15 Verify the following:
Verify there is no sluggish response or delay of the snap-acting limit switch.
Annunciator DIV 1 OR 4 MSIV CL TRIP is alarming [5004 Window 3-C]. <<LBD-2>>
Computer Point B21NC050 is tripped.
Both red and green lights are ON for valve B21-F028D.
CPS 9431.10H Initial Rev. 3 Page 15 of 25 8.1.16 Operations: Verify correct BYPASS switch to be placed in BYPASS, then position the MSL D BYPASS switch to BYPASS [5067B].
OPS 8.1.17 Verify the following:
Annunciator DIV 1 OR 4 MSIV CL TRIP is reset
[5004 window 3-C].
Computer Point B21NC050 is reset.
8.1.18 Operations: Verify correct BYPASS switch to be placed in NORM, then position the MSL D BYPASS switch to NORM.
OPS 8.1.19 Verify the following:
Annunciator DIV 1 OR 4 MSIV CL TRIP is alarming [5004 window 3-C].
Computer Point B21NC050 is tripped.
8.1.20 Operations: Release MAIN STEAMLINE D OUTBD MSIV TEST switch.
OPS 8.1.21 WHEN limit switch LS-5 closes, as indicated by DMM, THEN note position of lower surface of bottom spring seat assembly on limit switch bracket.
8.1.22 Record valve travel in the AS FOUND column of the data table.
Desired Value (inches)
Minimum Acceptable (inches)
B21-F028D Valve Travel Close As Found (inches)
Maximum Acceptable (inches)
Record N/A N/A
CPS 9431.10H Initial Rev. 3 Page 16 of 25 8.1.23 Verify occurrence of the following:
Annunciator DIV 1 OR 4 MSIV CL TRIP is reset
[5004 window 3-C].
Computer Point B21NC050 is reset.
Red light ON and green light OFF for valve under test B21-F028D.
8.1.24 IF all AS FOUND data is acceptable, THEN;
- 2. Mark section 8.2 as not applicable.
- 3. proceed to step 8.3.
8.1.25 IF any AS FOUND data is not acceptable, THEN notify Shift Management and IMD Supervision.
8.2 Adjustment of RPS MSIV Limit Switch NOTE The limit switch actuation point is changed by moving the actuation arm of the limit switch.
8.2.1 At limit switch LS-5, perform following:
- 1. Remove limit switch actuation arm pipe plug from spline shaft and properly discard.
- 2. Remove actuation arm, noting number of splines moved and replace actuating arm.
NOTE There should be no relative motion between the limit switch shaft and operating lever.
8.2.2 Install a new pipe plug and lightly tighten, (do NOT torque to snug tight).
CPS 9431.10H Initial Rev. 3 Page 17 of 25 WARNING Performance of the following step will cause valve movement.
8.2.3 Operations
Depress MAIN STEAMLINE D OUTBD MSIV TEST switch.
IV
/
OPS IMD 8.2.4 WHEN limit switch LS-5 opens, as indicated by DMM, THEN note position of lower surface of bottom spring seat assembly on limit switch bracket.
8.2.5 Operations
Release MAIN STEAMLINE D OUTBD MSIV TEST switch.
IV /
OPS IMD 8.2.6 WHEN limit switch LS-5 closes, as indicated by DMM, THEN note position of lower surface of bottom spring seat assembly on limit switch bracket.
8.2.7 Repeat steps 8.2.1 through 8.2.6 until the values are within the acceptable limits. Torque pipe plug(s) snug tight.
8.2.8 Record final valve travel in the AS LEFT column of data table. <<LBD-1>>
Desired Value (inches)
Tech Spec Allowable Limit (inches)
Minimum Acceptable (inches)
B21-F028D Valve Travel OPEN As Left (inches)
Maximum Acceptable (inches)
______/64 (E)
_____/64 (F) 13% closed
_____/64 (D)
_____/64 (C)
Desired Value (inches)
Minimum Acceptable (inches)
B21-F028D Valve Travel CLOSE As Left (inches)
Maximum Acceptable (inches)
Record N/A N/A 8.2.9 IF any AS LEFT readings are not acceptable, THEN notify IMD Supervision.
CPS 9431.10H Initial Rev. 3 Page 18 of 25 8.3 System Restoration 8.3.1 Remove the DMM.
8.3.2 Operations
Verify correct MSIV switch to be placed in AUTO then, place MAIN STEAMLINE D OUTBD MSIV switch to AUTO.
IV /
OPS IMD NOTE If there are remaining valves to be tested, the MSIVs may be left OPEN and step 8.3.3 should be N/A'd.
8.3.3 Operations
Verify correct MSIV to be closed then, CLOSE all Inbd (B21-F022A,B,C,D) and Outbd (B21-F028A,B,C,D) MSIVs (if plant conditions permit).
IV /
OPS IMD 8.3.4 IF a jumper was installed in step 5.14 THEN remove jumper: N/A if not installed.
1B21F022A 1H13P706A TM015 Terminals 9 & 10 IV /
1B21F022B 1H13P707B TM008 Terminals 9 & 10 IV /
1B21F022C 1H13P708B TM004 Terminals 7 & 8 IV /
1B21F022D 1H13P709B TM004 Terminals 7 & 8 IV /
1B21F028A 1H13P706A TM015 Terminals 7 & 8 IV /
1B21F028B 1H13P707B TM008 Terminals 7 & 8 IV /
1B21F028C 1H13P708B TM004 Terminals 5 & 6 IV /
1B21F028D 1H13P709B TM004 Terminals 5 & 6 IV /
8.3.5 RPS MSIV Channel D is restored to service and operating properly.
CPS 9431.10H Initial Rev. 3 Page 19 of 25 CAUTION If Low Condenser Vacuum Bypass is reset with a Low Condenser Vacuum condition present a group #1 Main Steam Line Isolation Trip signal will be generated.
8.3.6 Operations
IF directed by Shift Management, THEN reset Low Condenser Vacuum Bypass by momentarily placing the following switches in RESET, then return switches to AUTO.
5067B
OPS 5066B
OPS 8.3.7 List test equipment used for quantitative data in work order.
8.3.8 Verify all information contained on the procedure and data tables is complete and accurate.
8.3.9 Notify the Shift Management of procedure completion.
/
Date Time Tech 8.3.10 Perform review of AS FOUND data for previous 2 performances of this procedure. If a negative trend is identified notify management and generate an IR. _______
CPS 9431.10H Rev. 3 Page 20 of 25 9.0 ACCEPTANCE CRITERIA 9.1 OPERABILITY Requirements Failure to meet the Acceptance Criteria given below shall constitute a failure to comply with the applicable LCO.
Refer to Supplemental Review Sheet for applicable LCOs.
9.1.1 The AS LEFT Valve Travel values are within the Allowable Limits specified on the data table.
9.1.2 The annunciator for the valve being tested actuated to satisfy the MSIV Functional Test.
9.2 OTHER DATA Requirements 9.2.1 The AS LEFT data taken for the Loop Specifications, are within the Acceptable Limits specified on the data table.
9.2.2 The alarms/trip actuations occur as specified.
9.2.3 All other alarms and indications responded correctly.
9.2.4 If any step was unacceptable notify IMD Supervision.
10.0 FINAL CONDITIONS All Inbd (B21-F022A,B,C,D) and Outbd (B21-F028A,B,C,D)
MSIVs are operating properly.
11.0 REFERENCES
11.1 Licensing Basis Documents 11.1.1 LBD-1 CPS ITS SR 3.3.1.1.13 T6 11.1.2 LBD-2 CPS ITS SR 3.3.1.1.15 T6, SR 3.3.1.1.17 T6 11.1.3 CPS ITS LCO 3.3.6.1, 3.3.1.1 11.1.4 USAR - 3.1.2.3.10.1, 5.4.5, 7.2.1.1.4.2(item 6),
7.2.1.1.4.8, 7.2.2.1.2.3.1 11.1.5 ORM Attachment 2-3 (Table 1)
CPS 9431.10H Rev. 3 Page 21 of 25 11.2 Procedures 11.2.1 CPS 9031.10, RPS Main Steamline Isolation Valve Channel Functional 11.2.2 CPS 8492.02, Electric Conductor Seal Assembly 11.2.3 CPS 1887.00, Administration Of ISI Program Activities 11.3 Design/Vendor/Print/Other 11.3.1 E02-1RP99, Sh. 6, 7, 9, 25, 26, 27, 28, 30, 11.3.2 G.E. Design Specification Data Sheet 22A4622AV, Sh. 11 11.3.3 K2801-0002, ATWOOD AND MORRILL VENDOR MANUAL 11.3.4 MAINTENANCE OF EQUIPMENT QUALIFICATION PROGRAM MANUAL, MS-02.00, EQ-CL013B-02 11.3.5 IP-C-0075, Rev. 1, Setpoint Calculation for Main Steam Isolation Valve Position for RPS MSIV Closure Trip.
11.4 Commitments CM-1 OSHA Reportable Injury 2/1/94, CCT 061412 (7.1.6) 12.0 APPENDICES A. Example data sheet 13.0 DOCUMENTS 13.1 Surveillance Frequency Control Program (SFCP)
CPS 9431.10H Rev. 3 Page 22 of 25 APPENDIX A Example Data Sheet STEP 8.1.6 Stroke distance = 11.125 inches.
8.1.8 STROKE DISTANCE MULTIPLY MULTIPLY ROUND TO NEAREST WHOLE NUMBER CALCULATED VALUE (INCHES)
DESIGNATOR MAXIMUM AFT (13% CLOSED) 11.125 X64
= 712.0 X 0.13
= 92.56 ROUND DOWN
= 92
= 92/64 (A)
MINIMUM AFT (1% CLOSED) 11.125 X64
= 712.0 X 0.01
= 7.12 ROUND UP
= 8
= 8/64 (B)
MAXIMUM ALT (9% CLOSED) 11.125 X64
= 712.0 X 0.09
= 64.08 ROUND DOWN
= 64
= 64/64 (C)
MINIMUM ALT (5% CLOSED) 11.125 X64
= 712.0 X 0.05
= 35.60 ROUND UP
= 36
= 36/64 (D)
TRIP SETPOINT (7% CLOSED) 11.125 X64
= 712.0 X 0.07
= 49.84 ROUND DOWN
= 49
= 49/64 (E)
ALLOWABLE LIMIT
(< 13%
CLOSED) 11.125 X64
= 712.0 X 0.13
= 92.56 ROUND DOWN
= 92
= 92/64 (F)
CPS 9431.10H Rev. 3 Page 23 of 25 CALIBRATION SPECIFICATIONS (EXAMPLE)
DESIRED AS FOUND TOLERANCES Trip (open) 49/64 inches (7% closed) 92/64 to 7/64 inches (13% to 1% closed)
Designator (E)
(A) (B)
Reset (closed)
N/A DESIRED AS LEFT TOLERANCES Trip (open) 49/64 inches (7% closed) 64/64 to 35/64 inches (9% to 5% closed)
Designator (E)
(C) (D)
Reset (closed)
N/A DESIRED ALLOWABLE LIMIT Trip (open) 49/64 inches (7% closed)
<92/64 inches (<13% closed)
Designator (E)
(F)
Reset (closed)
N/A
CPS 9431.10H Rev. 3 Page 24 of 25 SUPPLEMENTAL REVIEW SHEET Corrective Action Taken Operability Requirements:
ITS LCOs:
3.3.1.1 3.3.6.1 As applicable:
Initiated Issue Report No. ____________________
Comments/Deficiencies
CPS 9431.10H Rev. 3 Page 25 of 25 Initial Sheet 1.
All test performers that initialed steps Print name and write initials below.
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
Performed by:
(Print Name)
(Initial)
- 2.
Circle as applicable the As Found out of tolerance results below IF CAT A per CPS No. 1401.09, Appendix E, AND As Found data out of tolerance, THEN initiate CPS No. 1401.09F002, CAT A INST FAILURE CHECKLIST.
IF any As Found data is NOT acceptable, THEN review ER-AA-520 to determine if an Issue Report is required.
AS FOUND Data out of tolerance? (Circle as applicable) a)
Tech Spec Data YES NO N/A b)
Non-Tech Spec Data YES NO N/A c)
CAT A YES NO N/A