PLA-5806, Proposed Revision to Relief Requests Irroi and 2RR01 for Proposed Third Ten-year Interval Inservice Testing Program Plans

Proposed Revision to Relief Requests Irroi and 2RR01 for Proposed Third Ten-year Interval Inservice Testing Program Plans

ML042650105
Person / Time
Site:	Susquehanna
Issue date:	09/10/2004
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-5806
Download: ML042650105 (24)

Text

Britt T. McKinney PPL Susquehanna, LLC  % II Vice President-Nuclear Site Operations 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 SEP 1 0 2004 btmckinney@pplweb.com pp I ,,.

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• 1,* N U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station P1-137 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED REVISION TO RELIEF REQUESTS IRROI AND 2RR01 FOR PROPOSED THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM PLANS FOR SUSQUEHANNA SES UNITS 1&2 Docket Nos. 50-387 PLA-5806 and 50-388

Reference:

Letter (PLA-5746) from Mr. B. L. Shriver (PPL) to NRC Document ControlDesk titled "ProposedThird Ten-Year Inservice Testing ProgramPlansfor SlisqzlehannaSES Units 1 & 2, " datedMay 5, 2004.

Attached for NRC staff's review and approval are revisions to proposed Relief Requests IRROI and 2RR01 for the Third Ten-Year Interval Inservice Testing Program Plans for Susquehanna SES Units I & 2. These revisions include additional check valves in the HPCI, RCIC, RHRSW and ESW systems to be disassembled during system outages instead of refueling outages. The attached Relief Requests supercede those Relief Requests provided in the reference.

We request that Relief Requests IRROI and 2RR01 to the Third Ten-Year Interval IST Program Plans for Susquehanna SES Units 1 and 2 be approved by January 1, 2005.

Should you have any questions, please contact C. T. Coddington at (610) 774-4019.

Sincerely, B. T. McKinney cook

Document Control Desk PLA-5806 Attachments:

Attachment 1 - Proposed Revision 1 to Relief Request IRROI to the Susquehanna Steam Electric Station Unit 1 Third Ten-Year Interval Inservice Testing Program Plan Attachment 2 - Proposed Revision 1 to Relief Request 2RRO1 to the Susquehanna Steam Electric Station Unit 2 Proposed Third Ten-Year Interval Inservice Testing Program Plan Copy: Regional Administrator - Region I Mr. A. J. Blamey, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP

Attachment No. 1 to PLA-5806 Proposed Revision to Relief Request IRR01 to Proposed Third Ten-Year Interval Inservice Testing Program Plan Susquehanna SES Unit 1

Attachment I to PLA-5806 Page 1 of 11 RELIEF REQUEST IRROI Relief in accordance with 10 CFR 50.55a (a)(3)(i)

Alternative Provides Acceptable Level of Quality and Safety I1. ASME Code Component(s) Affected Valve System Cat Safety Number I I I Class Check Valve Group CV02___

011033 Emergency Service Water C 3 011034 Emergency Service Water C 3 011035 Emergency Service Water C 3 011036 Emergency Service Water C 3 011037 Emergency Service Water C 3 011038 Emergency Service Water C 3 011039 Emergency Service Water C 3 011040 Emergency Service Water C 3 Check Valve Group CV03 011513 lEmergency Service Water C 3 011514 l Emergency Service Water j C 3 Function These check valves are in the cooling water lines to the Emergency Diesel Generators. They have an open safety function to provide Emergency Service Water to the Emergency Diesel Generators jacket water coolers, lube oil coolers and intercoolers. They have a closed safety function to prevent backflow when the cooling is being supplied by the opposite loop of Emergency Service Water.

These valves have no containment isolation function. The open and close safety functions of these valves are currently verified by valve disassembly. These valves are part stroked open during quarterly Emergency Service Water flow verification (inservice pump test).

Attachment 1 to PLA-5806 Page 2 of 1I Valve Number I System II_Cat. I_ Safety Class Check Valve Group CV5X 149F01 1 Reactor Core Isolation C 2 Cooling 149F030 Reactor Core Isolation C 2

__ __ _ Cooling I Function These check valves are in the Reactor Core Isolation Cooling (RCIC) pump suction lines. They have an open safety function to provide a flow path for the RCIC pump while taking suction from the condensate storage tank (149F01 1) or the suppression pool (149F030). They have a closed safety to prevent diversion of RCIC flow when the alternate suction path is being used. These valves have no containment isolation function. The open and close safety functions of these valves are currently verified by valve disassembly.

Valve Number System System Check Valve Group CV09 Cat.

Safety Class 149F021 Reactor Core Isolation C 2 CoolingF Function This check valve is in the Reactor Core Isolation Cooling (RCIC) pump minimum flow line. It has an open safety function to provide a minimum flow path for protection of the pump. This valve has a containment isolation function although it is not Appendix J tested. This line terminates below the minimum suppression pool level, which provides a water seal. The open and close safety function of these valves is currently verified by valve disassembly. This valve is part stroked open during the quarterly Reactor Core Isolation Cooling flow verification (inservice pump test).

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I~~~~~ ~~ , . J Attachment 1 to PLA-5806 Page 3 of 11

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Valve System Cat. l Sfet C Number V I ICV24 Check Valve Group CV24

- Function These check valves are located in the discharge of the Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) vacuum condenser pumps and provide the ASME Code boundary between the RCIC/HPCI pump suction and the discharge of the vacuum tank condenser pump. They have a closed safety function to maintain RCIC/HPCI water inventory in the event of a line break of the non-Code piping. Under ISTC-5221(a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function. The close safety function of these valves is currently verified by valve disassembly.

Valve 1t1 Safety Number I System Cat. Class Check Valve Group CVO8 _

151F046A Residual Heat Removal C 2 151F046B Residual Heat Removal l C 2 151F046C Residual Heat Removal C 2 151F046D Residual Heat Removal C 2 Function These check valves are in the Residual Heat Removal pump minimum flow lines.

They have an open safety function to provide a minimum flow path for pump protection. Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly.

These valves are part stroked open during the quarterly Residual Heat Removal flow verification (inservice pump test).

Attachment 1 to PLA-5806 Page 4 of II Valve System Cat. Safety Number S I I Class Check Valve Group CVIO 152005 l Core Spray I C l 2 Function This check valve is located in the suppression pool fill line. It has a safety function to close if the line is being used for filling the suppression pool (manual upstream valve 152028 open) to maintain Core Spray water inventory. This valve has no containment isolation function. The close safety function of this valve is currently verified by valve disassembly.

Valve System Cat. Safety Number _ __e Class Check Valve Group CV22 152F029A Core Spray C 2 152F029B Core Spray C 2 152F030A Core Spray C 2 152F030B Core Spray C 2 Function These check valves are in the keep fill lines for the Core Spray system. They have a closed safety function to prevent loss of inventory during Core Spray system operation. Under ISTC-5221(a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function.

The close safety function of these valves is currently verified by valve disassembly. The open function of these valves is continually verified during plant operation by proper operation of the keep fill system.

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Attachment 1 to PLA-5806 Page 5 of II Valve I Safety Number __ lass ClSystem Check Valve Group CV1 1 152F036A Core Spray C 2 152F036B Core Spray C 2 152F036C Core Spray C 2 152F036D Core Spray C 2 Function These check valves are in the Core Spray pump minimum flow lines. They have an open safety function to provide a minimum flow path for pump protection.

Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly. These valves are part stroked open during the quarterly Core Spray flow verification (inservice pump test).

Valve System Cat Safety Number I I I Class Check Valve Group CV14 153071A J Fuel Pool Cooling & Cleanup l C[ 3 153071B j Fuel Pool Cooling & Cleanup lC 3 Function These check valves are in the alternate flow path to the fuel storage pool. They have an open safety function to provide fuel storage pool cooling. Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure.

These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly. These valves are part stroked open during periodic pressure testing required by ASME Boiler &

Pressure Vessel Code,Section XI.

Attachment 1 to PLA-5806 Page 6 of 11 I, .

Function These check valves are in the High Pressure Coolant Injection (HPCI) pump suction lines. They have an open safety function to provide a flow path for the HPCI pump while taking suction from the condensate storage tank (155FO 19) or the suppression pool (551F045). They have a closed safety to prevent diversion of HPCI flow when the alternate suction path is being used. These valves have no containment isolation function. The open and close safety functions of these valves are currently verified by valve disassembly.

Valve System OM Safety Number _ Sy____ __ Cat. Class 155F046 Check Valve Group CV13 lHigh Pressure cCoolantInjection I C 2 Function This check valve is in the High Pressure Coolant Injection (HPCI) pump minimum flow line. It has an open safety function to provide a minimum flow path for protection of the pump. This valve has a containment isolation function although it is not Appendix J tested. This line terminates below the minimum suppression pool level, which provides a water seal. The open and close safety function of this valve is currently verified by valve disassembly. This valve is part stroked open during the quarterly High Pressure Coolant Injection flow verification (inservice pump test).

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Attachment I to PLA-5806 Page 7 of II Valve System Cat. Safety Number I I I Class Check Valve Group CV25 01 1193A Emergency Service Water C 2 011193B EmerRency Service Water C 2 012807A RHR Service Water C 2 012807B RHR Service Water C 2 Function These check valves are in the Emergency Service Water and RHR Service Water biocide injection lines and provide the ASME Code boundary between Emergency Service Water and RHR Service Water and the biocide injection line. They have a close safety function to provide and maintain Emergency Service Water and RHR Service Water inventory in the event of a line break in the non-Code piping.

Under ISTC-5221 (a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function. The closed safety function of these valves had been verified by checking a telltale drain valve upstream of the check valves.

Valve Number. II_______ System I Cat.

I__Safety Class Check Valve Group C 12 149F063 Reactor Core Isolation C 2 Cooling 149F064 Reactor Core Isolation C 2 Cooling 155F076 High Pressure Coolant C 2 Injection 155F077 High Pressure Coolant C 2 Injection Function These check valves are in the Reactor Core Isolation Cooling and High Pressure Coolant Injection turbine exhaust lines. They have an open safety function to prevent a vacuum relief path for the turbine exhaust line. They have a close safety function to prevent steam flow into the suppression chamber. These valves have no containment isolation function. The open and closed safety functions of these valves are currently verified by valve disassembly.

Attachment I to PLA-5806 Page 8 of II Function These check valves are located in the keep fill lines for the Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) systems. They have a closed safety function to prevent loss of inventory during Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) system operation.

Under ISTC-5221 (a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function. The close safety function of these valves is currently verified by valve disassembly. The open function of the valves is continually verified during plant operation by proper operation of the keep fill system.

Number System l_Cat._ SaCaty Check Valve Group CV07 High Pressure C 2 Coolant Injection High Pressure C 2 Coolant Injection Function These check valves are located on the outlet of the High Pressure Coolant Injection (HPCI) Lube Oil Cooler and in the HPCI Lube Oil Cooler return line to the HPCI Booster pump. They have an open safety function to provide a flow path for cooling water from the turbine lube oil cooler. Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly.

Attachment 1 to PLA-5806 Page 9 of II

2. Applicable Code Requirement

ASME OM Code 1998 Edition through OMb-2000 Addenda ISTC-522 I (c)(3), "Valve Obturator Movement" "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in each group shall be disassembled and examined at least once every 8 years."

3. Basis for Relief Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3), relief is requested from the requirements of ASME OM Code ISTC-5221(c)(3). The basis of the relief request is that the proposed alternative would provide an acceptable level of quality and safety.

The components listed above are check valves with no external means for exercising and no external position indication. Due to a lack of installed flow or pressure indication and a lack of test connections, it is not possible to use other means to verify the open and/or close exercising of these check valves.

Disassembly of the valves is the most feasible method to verify operability and can be accomplished during system outages, which may be conducted on line.

The check valves have been grouped by valve manufacturer, design, service, size, materials of construction, and orientation as required by ASME OM Code 1998 thorough 2000 Addenda, Section ISTC-5221(c)(1).

Prior to performing a system outage on-line, its effect on risk is evaluated in accordance with requirements of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear power Plants." This requirement states in part that: "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities."

SSES complies with the requirements of 10 CFR 50.65(a)(4) via application of a program governing maintenance scheduling. The program dictates the requirements for risk evaluations as well as the necessary levels of action required for risk management in each case. The program also controls operation of the on-line risk monitoring system, which is based on probabilistic risk assessment (PRA).

With the use of risk evaluation for various aspects of plant operations, SSES has

Attachment 1 to PLA-5806 Page 10 of II initiated efforts to perform additional maintenance, surveillance, and testing activities during normal operation. Planned activities are evaluated utilizing risk insights to determine the impact on safe operation of the plant and the ability to maintain associated safety margins. Individual system components, a system train, or a complete system may be planned to be out of service to allow maintenance, or other activities, during normal operation.

Disassembly and inspection may involve a system breach. However, the valves are isolated and the associated section of piping drained during disassembly.

Thus, the system breach does not increase the risk due to internal flooding or internal system loss-of-coolant accident. The risk associated with these activities would be bounded by the risk experienced due to the system outage. Therefore, disassembly and testing of these valves during scheduled system outages while on-line would have no additional impact on core damage frequency.

As more system outages are performed on-line, it is evident that selected refueling outage inservice testing activities, (e.g., valve exercising and disassembly) could be performed during these system outage windows without sacrificing the level of quality or safety. Inservice testing performed on a refueling outage frequency is currently acceptable in accordance with ASME OM Code, 1998 Edition through 2000 Addenda. By specifying testing activities on a frequency commensurate with each refueling outage, ASME OM Code, 1998 Edition through 2000 Addenda, establishes an acceptable time period between testing. Historically, the refueling outage has provided a convenient and defined time period in which testing activities could be safely and efficiently performed. However, an acceptable testing frequency can be maintained separately without being tied directly to a refueling outage. Inservice testing performed on a frequency that maintains the acceptable time period between testing activities during the operating cycle is consistent with the intent of ASME OM Code, 1998 Edition through 2000 Addenda.

Over time, approximately the same number of tests will be performed using the proposed operating cycle frequency as would be performed using the current refueling outage frequency. Thus, inservice testing activities performed during the proposed operating cycle test frequency provide an equivalent level of quality and safety.

Attachment 1 to PLA-5806 Page 11 of 11

4. Proposed Alternate Testing Pursuant to 10 CFR 50.55a(a)(3)(i), SSES proposes an alternative testing frequency for performing inservice testing of the valves identified above. At least one valve from each group wvill be tested on a frequency of once each operating cycle in lieu of once each refueling outage as currently allowed by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-5221(c)(3), "Valve Obturator Movement." All valves in each group will be tested at least once every 8 years as required by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-522 I (c)(3).

Check valve groups CV04, CV07, CV09, CV10, CV 13, CV14, and CV24 include identical Unit 2 valves. For these check valve groups, one valve from each group xvill be tested each outage cycle combination. An outage cycle combination is defined as the start of Unit 1 operating cycle to the completion of Unit 2 operating cycle.

Similar relief has been approved for Entergy's Grand Gulf Nuclear Station, Unit I (TAC No. MB6900).

5. Duration of Relief Request This proposed alternative is requested for the duration of the Third Ten-Year Interval Susquehanna Steam Electric Station Unit 1 IST program (June 1, 2004 through May 31, 2014).

Attachment No. 2 to PLA-5806 Proposed Revision to Relief Request 2RR01 to Proposed Third Ten-Year Interval Inservice Testing Program Plan Susquehanna SES Unit 2

Attachment 2 to PLA-5806 Page 1 of 9 RELIEF REQUEST 2RRO1 Relief in accordance with 10 CFR 50.55a (a)(3)(i)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Valve System Cat. Safety Number Vasem __ I Class Check Valve Group CV17 Reactor Core C 2 Isolation Cooling Reactor Core C 2 Isolation Cooling Function These check valves are in the Reactor Core Isolation Cooling (RCIC) pump suction lines. They have an open safety-function to provide a flow path for the RCIC pump while taking suction from the condensate storage tank (249F01 1) or the suppression pool (249F030). They have a closed safety to prevent diversion of RCIC flow when the alternate suction path is being used. These valves have no containment isolation function. The open and close safety functions of these valves are currently verified by valve disassembly.

Valve N um ber J

I _ __ _

System

__ __ _ __I_ _

l Cat.

_ I__

Safety C lass Check Valve Group CV09 249F02 1 Reactor Core C 2 Isolation Cooling Function This check valve is in the Reactor Core Isolation Cooling (RCIC) pump minimum flow line. It has an open safety function to provide a minimum flow path for protection of the pump. This valve has a containment isolation function although it is not Appendix J tested. This line terminates below the minimum suppression pool level, which provides a water seal. The open and close safety function of these valves is currently verified by valve disassembly. This valve is part stroked

Attachment 2 to PLA-5806 Page 2 of 9 open during the quarterly Reactor Core Isolation Cooling flow verification (inservice pump testyj)

Valve System Cat. Safety Number Syste i I_ lass Check Valve Group CV24 250F047 Reactor Core C 2 Isolation Cooling 256F052 High Pressure C 2 Coolant Injection Function These check valves are located in the discharge of the Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) vacuum condenser pumps and provide the ASME Code boundary between the RCIC/HPCI pump suction and the discharge of the vacuum tank condenser pump. They have a closed safety function to maintain RCIC/HPCI water inventory in the event of a line break of the non-Code piping. Under ISTC-5221(a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function. The close safety function of these valves is currently verified by valve disassembly.

Valve Number 1yse1System a Cat 1 Safety Class Check Valve Group CV08 251F046A Residual Heat Removal C 2 251F046B Residual Heat Removal C 2 251F046C Residual Heat Removal C 2 251F046D Residual Heat Removal C 2 Function These check valves are in the Residual Heat Removal pump minimum flow lines.

They have an open safety function to provide a minimum flow path for pump protection. Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly.

These valves are part stroked open during the quarterly Residual Heat Removal flow verification (inservice pump test).

Attachment 2 to PLA-5806 Page 3 of 9 Valve SseCa. Safety Number System Cat. Class

' .Check Valve Group CV10 'l 252005 CoreSpray T C 1 2 l Function This check valve is located in the suppression pool fill line. It has a safety function to close if the line is being used for filling the suppression pool (manual upstream valve 252028 open) to maintain Core Spray water inventory. This valve has no containment isolation function. The close safety function of this valve is currently verified by valve disassembly.

Valve Ca.ISafety Number System l Cat Cass Check Valve Group CV23 252F029A Core Spray C 2 252F029B Core Spray C 2 252F030A Core Spray C 2 252F030B Core Spray C 2 Function 0 These check valves are in the keep fill lines for the Core Spray system. They have a closed safety function to prevent loss of inventory during Core Spray system operation. Under ISTC-5221(a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function.

The close safety function of these valves is currently verified by valve disassembly. The open function of these valves is continually verified during plant operation by proper operation of the keep fill system.

Number System ICat. I Class Check Valve Group CV16 252F036A Core Spray C 2 252F036B Core Spray C 2 252F036C Core Spray C 2 252F036D Core Spray Cl 2

Attachment 2 to PLA-5806 Page 4 of 9 Function These check valves are in the Core Spray pump miniimum flow lines. They have an open safety function to provide a minimum flow path for pump protection.

Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly. These valves are part stroked open during the quarterly Core Spray flow verification (inservice pump test).

Function These check valves are in the alternate flow path to the fuel storage pool. They have an open safety function to provide fuel storage pool cooling. Under ISTC-5221(a)(2), it is required that these check valves also be verified for closure.

These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly. These valves are part stroked open during periodic pressure testing required by ASME Boiler &

Pressure Vessel Code,Section XI.

Valve tCat. Safety Number St_ Class Check Valve Group C 19 _

255F019 High Pressure C 2 Coolant Injection 255F045 High Pressure C 2 Coolant Injection Function These check valves are in the High Pressure Coolant Injection (HPCI) pump suction lines. They have an open safety function to provide a flow path for the HPCI pump while taking suction from the condensate storage tank (255F019) or the suppression pool (255F045). They have a closed safety to prevent diversion of HPCI flow when the alternate suction path is being used. These valves have no

Attachment 2 to PLA-5806 Page 5 of 9 containment isolation function. The open and close safety functions of these valves are currently verified by valve disassembly.

Valve System 1 OM l Safety Number I Cat. Class Check Valve Group CV13 255F46 lHigh Pressure C l Coolant Injection l 2 Function This check valve is in the High Pressure Coolant Injection (HPCI) pump minimum flow line. It has an open safety function to provide a minimum flow path for protection of the pump. This valve has a containment isolation function although it is not Appendix J tested. This line terminates below the minimum suppression pool level, which provides a water seal. The open and close safety function of this valve is currently verified by valve disassembly. This valve is part stroked open during the quarterly High Pressure Coolant Injection flow verification (inservice pump test).

Valve System Cat. Safety Number S I I Class Check Valve Group CV20 211132 l Emergency Service Water l C l_3 211134 l Emergency Service Water C 3 Function Check valve 211132 is in the Emergency Service Water (ESW) supply line to the Emergency Switchgear and Load Center Room "A" Cooler. Check valve 211134 is in the Emergency Service Water (ESW) supply line to Emergency Switchgear and Load Center Room "B" Cooler. The open safety function of these valves is currently verified by disassembly.

Valve Sysem at Safety Number System Cat I Class Check Valve Group CV21 211133 lEmergency Service Water lC 13 211135 rEmergency Service Water C 1 3

Attachment 2 to PLA-5806 Page 6 of 9 Function Check valve 211133 is in the Emergency Service Water (ESW) return line from the Emergency Switchgear and Load Center Room "A" Cooler. Check valve 211135 is in the Emergency Service Water (ESW) return line from the Emergency Switchgear and Load Center Room "B" Cooler. The open safety function of these valves is currently verified by disassembly.

Valve Sysem aI Safety Number System Cat Class Check Valve Group CV18 l 249F063 J Reactor Core Isolation Cooling J C l 2 249F064 l Reactor Core Isolation Cooling l C 2 255F076 _ High Pressure Coolant Injection C 2 255F077 l High Pressure Coolant Injection C 2 Function These check valves are in the Reactor Core Isolation Cooling and High Pressure Coolant Injection turbine exhaust lines. They have an open safety function to prevent a vacuum relief path for the turbine exhaust line. They have a close safety function to prevent steam flow into the suppression chamber. These valves have no containment isolation function. The open and closed safety functions of these valves are currently verified by valve disassembly.

Valve SysemCat.' Safety Number ISystemI Class Check Valve Group CV04 249016 Reactor Core Isolation Cooling C 2 255013 High Pressure Coolant Injection Cl 2 Function These check valves are located in the keep fill lines for the Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) systems. They have a closed safety function to prevent loss of inventory during Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) system operation.

Under ISTC-5221 (a)(3), it is required that these check valves also be verified to partially open. These valves have no containment isolation function. The close safety function of these valves is currently verified by valve disassembly. The open function of the valves is continually verified during plant operation by proper operation of the keep fill system.

Attachment 2 to PLA-5806 Page 7 of 9 Valve System Cat. Safety Number _ _ _ _ __JC lass Check Valve Group CVO7 07 256F048 High Pressure C 2 Coolant Injection I 256F057 High Pressure C 2 Coolant Injection Function These check valves are located on the outlet of the High Pressure Coolant Injection (HPCI) Lube Oil Cooler and in the HPCI Lube Oil Cooler return line to the HPCI Booster pump. They have an open safety function to provide a flow path for cooling water from the turbine lube oil cooler. Under ISTC-522 1(a)(2), it is required that these check valves also be verified for closure. These valves have no containment isolation function. The open safety function of these valves is currently verified by valve disassembly.

2. Applicable Code Requirement

ASME OM Code 1998 Edition through OMb-2000 Addenda ISTC-522 1 (c)(3), "Valve Obturator Movement" "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in each group shall be disassembled and examined at least once every 8 years."

3. Basis for Relief Pursuant to 10CFR50.55a, "Codes and Standards," paragraph (a)(3), relief is requested from the requirements of ASME OM Code ISTC-5221(c)(3). The basis of the relief request is that the proposed alternative would provide an acceptable level of quality and safety.

The components listed above are check valves with no external means for exercising and no external position indication. Due to a lack of installed flow or pressure indication and a lack of test connections, it is not possible to use other means to verify the open and/or close exercising of these check valves.

Disassembly of the valves is the most feasible method to verify operability and can be accomplished during system outages, which may be conducted on line.

The check valves have been grouped by valve manufacturer, design, service, size, materials of construction, and orientation as required by ASME OM Code 1998 thorough 2000 Addenda, Section ISTC-5221(c)(1).

Attachment 2 to PLA-5806 Page 8 of 9 Prior to performing a system outage on-line, its effect on risk is evaluated in accordance with requirements of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This requirement states in part that: "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities."

SSES complies with the requirements of 10 CFR 50.65(a)(4) via application of a program governing maintenance scheduling. The program dictates the requirements for risk evaluations as well as the necessary levels of action required for risk management in each case. The program also controls operation of the on-line risk monitoring system, which is based on probabilistic risk assessment (PRA). With the use of risk evaluation for various aspects of plant operations, SSES has initiated efforts to perform additional maintenance, surveillance, and testing activities during normal operation. Planned activities are evaluated utilizing risk insights to determine the impact on safe operation of the plant and the ability to maintain associated safety margins. Individual system components, a system train, or a complete system may be planned to be out of service to allow maintenance, or other activities, during normal operation.

Disassembly and inspection may involve a system breach. However, the valves are isolated and the associated section of piping drained during disassembly.

Thus, the system breach does not increase the risk due to internal flooding or internal system loss-of-coolant accident. The risk associated with these activities would be bounded by the risk experienced due to the system outage. Therefore, disassembly and testing of these valves during scheduled system outages while on-line would have no additional impact on core damage frequency.

As more system outages are performed on-line, it is evident that selected refueling outage inservice testing activities, (e.g., valve exercising and disassembly) could be performed during these system outage windows without sacrificing the level of quality or safety. Inservice testing performed on a refueling outage frequency is currently acceptable in accordance with ASME OM Code, 1998 Edition through 2000 Addenda. By specifying testing activities on a frequency commensurate with each refueling outage, ASME OM Code, 1998 Edition through 2000 Addenda, establishes an acceptable time period between testing. Historically, the refueling outage has provided a convenient and defined time period in which testing activities could be safely and efficiently performed. However, an acceptable testing frequency can be maintained separately without being tied directly to a refueling outage. Inservice testing performed on a frequency that maintains the acceptable time period between testing activities

Attachment 2 to PLA-5806 Page 9 of 9 during the operating cycle is consistent with the intent of ASME OM Code, 1998 Edition through 2000 Addenda.

Over time, approximately the same number of tests will be performed using the proposed operating cycle frequency as would be performed using the current refueling outage frequency. Thus, inservice testing activities performed during the proposed operating cycle test frequency provide an equivalent level of quality and safety.

4. Proposed Alternate Testing Pursuant to 10 CFR 50.55a(a)(3)(i), SSES proposes an alternative testing frequency for performing inservice testing of the valves identified above. At least one valve from each group will be tested on a frequency of once each operating cycle in lieu of once each refueling outage as currently allowed by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-5221(c)(3), "Valve Obturator Movement." All valves in each group will be tested at least once every 8 years as required by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-5221 (c)(3).

Check valve groups CV04, CV07, CV09, CV10, CV13, CV14, and CV24 include identical Unit 2 valves. For these check valve groups, one valve from each group will be tested each outage cycle combination. An outage cycle combination is defined as the start of Unit 1 operating cycle to the completion of Unit 2 operating cycle.

Similar relief has been approved for Entergy's Grand Gulf Nuclear Station, Unit 1 (TAC No. MB6900).

5. Duration of Relief Request This proposed alternative is requested for the duration of the Third Ten-Year Interval Susquehanna Steam Electric Station Unit 2 IST program (June 1, 2004 through May 31, 2014).