PY-CEI-NRR-0445, Forwards Seven Addl Relief Requests to Util Inservice Testing Program for Pumps & Valves.Requests Needed in Order to Maintain Sys/Component Operability.Minor Changes Summarized on Encl Index

Forwards Seven Addl Relief Requests to Util Inservice Testing Program for Pumps & Valves.Requests Needed in Order to Maintain Sys/Component Operability.Minor Changes Summarized on Encl Index

ML20205M568
Person / Time
Site:	Perry
Issue date:	04/08/1986
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Butler W Office of Nuclear Reactor Regulation
References
PY-CEI-NRR-0445, PY-CEI-NRR-445, NUDOCS 8604150314
Download: ML20205M568 (33)

Text

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o e f THE CLEVELAND ELECTR P.o. Box 5000 - CLEVELAND, ohio 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLOG.

Serving The Best Location in the Nation

- 55 PUBLICSoVARE MURRAY R. EDELMAN VICE PRESIDENT April 8, 1986 NUCLE A R PY-CEI/NRR-0445 L Dr. W. R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Pump & Valve Inservice Testing Program License Condition 26

Dear Dr. Butler:

The purpose of this letter is to submit seven additional relief requests to the Perry Nuclear Power Plant Unit 1 Inservice Testing Program (IST) for Pumps and Valves (document No. 80A5237 Rev. I submitted on August 21 1985, PY-CEI/NRR-0318L). Initial surveillance testing identified the need for the additional relief requests in order to maintain system / component operability.

The basis for relief is identified within each relief request, (see attached PR-10 to PR-12 and VR 45 to VR 48).

Other minor changes to our previous submittal summarized on the attached index were clerical in nature, correcting component's I.D. numbers and typographical errors. The index identifies these relief request.

Please feel free to contact me if you have any questions or comments.

Very truly yours itA 'h Murray R. Edelman Vice President Nuclear Group MRE:njc cc: Jay Silberg, Esq.

John Stefano (2)

J. Grobe g I I 8604150314 860408 i PDR ADOCK 05000440 P PDR

, ATTACHMENT t,

- PY-CEI/NRR-0445 L INDEX The following listing identifies the revisions made to'the Pump and Valve Inservice Testing Program Revision 1 (Document No. PY-CEI/NRR-0318L) Relief Requests by Revision 2.

Revision 2 Relief Request No. Comment (Changes, Addition, and Deletions)

PR-1 Changed - Revised listing of pumps PR-3 Changed - Typo PR-4 Changed - Typo PR-5 Changed - Incorporated Combustible Gas Control Blowers PR-6 Changed - Typo PR-7 Changed - Typo PR-8 Changed - Typo PR-9 Changed - Wofding clarification '

PR-10 Addition PR-Il Addition PR-12 Addition VR-3 Changed - Consistent with Technical Specification VR- 4 Changed - Revised listing of valves VR-22 Changed - Typo VR-23 Changed - Typo VR-24 Changed - Typo VR-27 Changed - Revised listing of valves VR-29 Changed - Typo VR-33 Changed - Wording clarification VR-35 Changed - Typo VR-36 Changed - Typo VR-37 Changed - Wording clarification VR-38 Changed - Typo VR-39 Changed - Typo VR-40 Changed - Deletion of fail safe test requirement VR-41 Changed - Wording clarification I VR-44 Changed - Deleted Rev. No. I and incorporated within I VR-45, Rev. No. I VR-4 5 Addition VR-46 Addition i VR-47 Addition {

VR-48 Addition  !

Typo - changes such as: correcting component's I.D. number,'t' rev ising component listings to an alphanumeric order, correcting punctuation I or spelling errors. j

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t Pump Relief Request #

PR-1 System: As applicable Pumps: IC41-C001A 1E22-C003 1P42-C001B 1R45-C002A l 1C41-C001B IE32-C001 1P45-C001A 1R45-C002B C41-C002A 1E32-C002B 1P45-C001B 1R45-C002C C41-C002B IE32-C002F 1P45-C002 1E12-C002A 1E51-C001 P47-C001A 1E12-C002B IE51-C003 P47-C001B 1E12-C002C G41-C003A P49-C002A l 1E12-C003 G41-C0038 P49-C002B IE21-C001 IM51-C001A 1R45-C001A 1E21-C002 1M51-C001P 1R45-C001B IE22-C001 1P42-C001A 1R45-C001C Function: As applicable

! Class: ASME Class 2 and 3 Test Requirement: ASME (IWP-4310) requires the temperature of all centri-

! fugal pump bearing, outside the main flow path, shall be measured at points selected to be responsive to changes in the temperature of the bearing.

l Basis for Relief:

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(a) Some of the purps addressed in this relief request are cooled l by their respective process fluid, " Main Flow Path." Thus,_

bearing temperature measurements would be highly dependent on the temperature'of the cooling medium.

s 1 (b) Pump bearing temperature is taken at (1) one-year intervals, A

only, which provides very little data toward determining the incremental degradation of a bearing, or provide any meaningful trend data.

(c) Except for the Emergency Service Water Pumps 1P45-C001A, B and C002, which are submerged under water, all pumps addressed in

, this relief request will be subject to vibration measurements  !

per subsection IWP-4500. Vibration measurements are a signifi-i cantly more reliable indication of pump bearing degradation

than that of temperature measurements, in summary other measur-

able parameters are more indicative of pump performance, and in i some instances the measured temperature does not represent the actual bearing temperature. Therefore, pump bearing tempera-ture will not be measured.

Alternate Testing:

Vibration measurements will be taken on all pumps identified j

-above as required by ASME Section XI Subsection IWP-4500, '

l except as noted in paragraph "c", above.

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f f Pump Relief Request #

PR-3 System: Standby Liquid Control System Pumps: IC41-C001A and 1C41-C001B Class: 2 Function: Provides a method of shutting down the reactor without use of the control rods.

Test Requirements: IWP-3300; Scope of Test - measurement and observation of inlet pressure (Pi) and differential pressure (Pd) across the pumps.

Basis for Relief: The standby liquid control pumps are required to supply the necessary flow rate at a given system pressure. The inlet pressure (no installed test equipment) will be equivalent to the static head provided by the test tank.

Test tank level is established within the inservice test procedures. Also, the measurement of inlet pressure on a positive displacement pump is not a significant test parameter. The system resistance is varied to establish the measured and observed discharge pressure as the reference value. Flow rate is measured, observed and monitored to verify pump operability and degradation.

Alternate Testing: Utilize pump discharge pressure reading in lieu of pump differential pressure reading.

, t Pump Relief Request #

PR-4 System: Waterleg Fill Pumps (RHR, LPCS, HPCS, and RCIC)

Pumps: 1E12-C003, IE21-C002,1E22-C003, and 1E51-C003 Class: 2 Function: Waterleg pumps maintain the discharge piping of safety-related systems full to expedite flow during initiation, and to minimize the likelihood of system damage due to water hammer.

Test Requirements: IWP-4600 Flow measurement (Accuracy), IWP-3230 (a) correc-tive action (alert range), and IWP-3230(b) corrective action (action range).

Basis for Relief: The waterleg pumps were designed to be in service to keep functional systems full. The waterleg pumps have a i capacity of 40 gpm and a minimum flow design requirement '

of 10 gpm. Testing will establish a flow path with a minimum system resistance. Hydraulic parameters shall be l measured, with flow rate being measured by using a survey flowmeter. The accuracy of the survey flowmeter is approximately 5%. The pump can meet the design function j with as much as 75% degradation. Therefore, relief from -

accuracy requirements and alert / action ranges adequately i allows assessment of pump operability. i Alternate Testing: Measurement of flow by survey flowmeter (approximately 15%

accuracy) and corrective action ranges for flow shall be:

50% degradation alerf* range and 75% degradation action range.

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9 8 Pump Relief Request #

4 PR-5 System: MSIV Leakage Control (E32), Combustible Gas Control (M51)

Pumps: 1E32-C001, 1E32-C002B, 1E32-C002F, IM51-C001A, IM51-C001B Class: 2 Function: The blowers provide: 1) MSIV Leakage Control (E32) - a means to control and minimize the release of fission products which may leak through the closed MSIVs after a Loss-of-Coolant Accident (LOCA) and

2) Combustible Gas Control (M51) - prevent flammable hydrogen concentrations from forming in the containment vessel or drywell following a Loss-of-Coolant Accident (LOCA).

i Test Requirements: IWP-3300, Scope of Test - measurement and observation of flow (Qf), inlet pressurc (Pi), and differential pressure (Pd).

Basis for Relief: Although the blowers may fall within the definition of pumps, they do not have hydraulic characteristics that will show blower degradation; therefore, only the mechan-ical characteristics will be monitored.

Alternate Testing: Perform testing of the mechanical characteristics in conjunction with PNPP Unit 1 Technical Specification.

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O t Pump Relief Request #

PR-6 System: Emergency Service Water System (P45)

ESW Screen Wash (P49)

Pumps: 1P45-C001A, IP45-C001B, 1P45-C002, P49-C002A, P49-C002B Class: 3 Function: The emergency service water pumps provide the cooling water to support the safety-related shutdown systems.

The ESW Screen Wash Pumps provide clean water to the spray nozzles for cleaning debris from the ESW traveling screens. The pumps also supply flushing water to the ESW screen tray.

Test Requirements: ASME Section XI, IWP-4500 requires vibration measurements to be taken at a location on a bearing housing or its structural support, provided it is not separated from the pump by any resilient mounting.

Basis for Relief: The service water and screen wash pumps are totally submerged under water making the required vibration testing impractical, however, the motor drivers are shaft connected to the pumps and are accessible.

Alternate Testing: The vibration measurements will be taken, as scheduled on a quarterly basis, on the lower bearing, closest to the pump driver motor.

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l Pump Relief Reques"t?#

PR-7

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System: Emergency Service Water (P45)

Emergency Service Water Screen Wash (P49)

Pumps: 1P45-C001A, 1P45-C001B, IP45-C002,P49-C002A, P49-C002B  !

l Class: 3 Function: The emergency service water pumps provide the cooling water to support the safety-related shutdown systems.  !

The ESW Screen Wash Pumps provide clean water to the spray nozzles for cleaning debris from the ESW traveling screens. The pumps also supply flushing water to the ESW screen tray. l l

Test Requirements: Measure, record, and compare inlet (suction) pressure Pi i Per IWP-3100. I Basis for Relief: An inlet (suction) pressure gauge is not provided for the emergency service water pumps. The pumps have an inlet i

pressure dependent upon Lake Erie water level. Cal-culation of this static head between Lake level and pump inlet should adequately provide the necessary inlet pressure.

Alternate Testing: Calculate the static head between Lake Erie water level and the pump suction for inlet suction pressure.

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4 Pump Relief Request #

PR-8 System: Emergency Service Water Screen Wash

> Pumps: P49-C002A and P49-C002B Class: 3 Function: The ESW Screen Wash Pumps provide clean water to the spray nozzles for cleaning debris from the ESW traveling screens. The pumps, also, supply flushing water to the ESW screen tray.

Test Requirements: IWP-4600 Flow Measurement (accuracy), IWP-3230(a) correc-tive action (alert range), and IWP-3230(b) corrective action (action range).

Basis for Relief: Flow rate will be measured and observed with a survey flowmeter which has an accuracy of 15%. A low pressure I apray header alarm is provided to warn operators of insuf ficient screen cleaning pressure and to start the traveling screens. The low pressure alarm setpoint is at 72 psid.

Alternate Testing: Measurement of flow by survey flowmeter (approximately 15%) and corrective action ranges for flow shall be: 15%

degradation alert range and 25% degradation action range.

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Pump Relief Request #

PR-9 System: Standby Diesel Generator Fuel Oil (A and B), HPCS Diesel Generator Fuel Oil (C)

Pumps: 1R45-C001A/1R45-C002A, 1R45-C001B/1R45-C002B, 1R45-C001C/1R45-C002C

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Class: 3 Function: The fuel oil transfer pumps maintain a sufficient operating level in the fuel oil day tank by transferring fuel oil from the fuel oil storage tank to the fuel oil day tank.

Test Requirements: IWP-4600 Flow measurement (accuracy), IWP-3230(a) correc-tive action (alert range), and IWP-3230(b) corrective action (action range).

Basis for Relief: TWo fuel oil transfer pumps supply one day tank; one pump is designated as inservice and the other pump is desig-nated as backup. The capacity of a fuel transfer pump is90-140 gpm with the required design capacity of the Diesel Engine being 35 gpe. Flow rate will be measured with a survey flowmeter which has an accuracy of approximately 15%. The pump can meet the design function with as much as 50% degradation; therefore, relief from accuracy requirements and alert / action ranges adequately allows assessment of pump operability.

Alternate Testing: Measurement of flow by survey flowmeter (approximately 15%) with corrective action ranges for flow shall bat 25%

degradation alert range and 50% degradation action range.

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Pump Relief Request #

PR-10  %

System: Waterleg Fill Pumps (RHR, LPCS, and HPCS)

> Pumps: 1E12-C003, 1E21-C002, and 1E22-C003 Class: 2 l

Function: Waterleg pumps maintain the discharge piping of safety-related systems full to expedite flow during initiation, and to minimize the likelihood of system damage due to waterhammer. ,

Test Requirements: IWP-3400; Test Frequency - Test pumps at least every three -

months, quarterly.

Basis for Relief: The waterleg pumps were designed to be inservice to maintain functional systems (discharge / suction piping) pressurized. The waterleg pump normal discharge path must I be redirected to perform safety-related pump testing.  !

This would require racking out of safety-related pump breakers (RHR, LPCS, and HPCS) as to prevent system damage i due to waterhammer or cavitation upon receipt of an l actuation signal. Racking out of safety-related pump l breakers will place the plant in a Limiting Condition of Operation for testing. The intent of ASME Code,Section XI is not to reduce the reliability of safety-related systems. Therefore, the listed  ;

safety-related waterleg pumps shall be tested during cold shutdown.

Alternate Testing: Test during cold shutdown.

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l Pump Relief Request #

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PR-11 System: Reactor Core Isolation Cooling Pump and Waterleg Fill Pump Pumps: 1E51-C001 and 1E51-C003 Class: 2 Function: The RCIC Pump ensures sufficient reactor water inventory during a vessel isolation condition and prevents reactor fuel overheating.

The RCIC Waterleg Pump maintains the suction / discharge piping of the reactor core isolation cooling system full to expedite flow during l initiation, and to minimize the likelihood of system damage due to waterhammer.

Test Frequency: IWP-3400; Test Frequency - Test pumps at least every three months, quarterly.

Basis for Relief: The Reactor Core Isolation Cooling (E51) System is required to be operable during power operation, start-up and hot shutdown with reactor steam dome pressure greater than 150 psig. The RCIC System pumps shall be tested within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is being supplied to the turbine at 1020+25-100 psig. The system operability shall be verified in accordance with IWP-3400 after performance of initial test when reactor steam pressure is adequate (1020+25-100 psig).

Alternate Testing: Test in accordance with PNPP Unit 1 Technical Specification.

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Pump Relief Request #

PR-12 System: Standby Liquid Control Transfer Pumps: C41-C002A and C41-C002B Class: 3 Function: The SLC Transfer Pumps provide makeup solution to the Standby Liquid Control Systems (Unit 1/ Unit 2) for long tett operation.

Test Requirements: IWP-4600 Flow Measurement (accuracy), IWP-3230(a) correc-tive action (alert range), and IVP-3230(b) corrective action (action range).

Basis for Relief: Flow rate will be measured and observed with a survey flowmeter which has an accuracy of 15%. The flow path shall be established using the test return line to the ,

transfer tank. Differential pressure shall be adjusted to a predetermine value and degradation of the pump hydraulic characteristics shall be trended / monitored using flowrate.

Alternate Testing: Measurement of flow by survey flowmeter (approximately iS%) and corrective action ranges for flow shall be:

15%

degradation alert range and 25% degradation action range.

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Valve Relief Request #

6 1 VR-3 System: As applicable Valves: Valve Test Tables 4

. Category: A and AC Class: As applicable Function: As applicable Test Requirements: IWV-3427(b); corrective action For valves 6 in. nominal pipe size and larger, if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate by 50% or greater, the test frequency shall be double. 1 (IWV-3427(b)). I Basis for Relief: These valves are located inside containment and testing on j

an increased frequency would increase exposure for testing personnel. Testing is now being performed during refuel-j ing to minimize exposure. With increased frequency, '

operational constraints would be placed upon the plant ,

requiring possible shut down for testing. Therefore, l corrective action per IWV-3427(b) will not be used due to 1 ALARA considerations and operational constraints on the l plant. I Alternate Testing: Valves will be replaced or repaired as required when the leakage rate exceeds that as stated in Perry Nuclear Power Plant Technical Specifications.

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Valve Relief Request #

VR-4 l

System: As applicable

, Valves: All Fest-acting solenoid operated valves with short-stroke time less than or equal to 3 seconds.

Category: A, B Class: As applicable Test Requirements: Section XI, IWV-3300 Valve Position Indicator Verifica-tion. Valves with remote position indicators, shall be visually observed during a plant shutdown, at least once every two years to verify that remote valve indications accurately reflect valve operation.

Basis for Relief: These valves require disassembly of the actuator compo-nents to verify operation. Additionally, each valve has minimal stroke time (less than 1 second) and stem travel (approximately 0.075 inch). The accurate visual verifica-tion of valve operation is not possible due to the minimal stem travel and short stroke period. This visual observa-tion would not contribute significantly to the assurance of safe and proper valve operation.

Alternate Testing: The valve open indication /open position (evergized) is var'fied by normal system parameters during operation.

The valve shut indication / shut position (de-energized) is verified by 10CFR50 Appendix J testing, and ASME Code Section XI Seat Leakage Testing during refueling outages or oy normal system operating parameters.

Valves affected by this general exception, see following listing:

1D17-F071A 1D23-F050 1M51-F240A 1P53-F040 1P87-F077 1D17-F071B IE12-F060A 1M51-F2408 IP53-F045 1P87-F083 1D17-F079A 1E12-F060B 1M51-F250A 1P53-F070 1P87-F264 1D17-F079B 1E12-F075A iM51-F250B 1P53-F075 1D17-F081A 1E12-F075B 1M51-F260A 1P87-F001 1D17-F081B 1G43-F050A iM51-F260B 1P87-F007 1D17-F089A 1G43-F050B IM51-F270A 1P87-F025 1D17-F089B 1G43-F060 1M51-F270B 1P87-F028 1D23-F010A 1M17-F055 1PS2-F160 1P87-F037 1D23-F010B 1M17-F065 1PS2-F170 1P87-F046 1D23-F020A 1M51-F210A 1P53-F010 1P87-F049 1D23-F020B 1M51-F210B IP53-F015 1P87-F052 1D23-F030A iM51-F220A 1PS3-F020 1P87-F055 i 1D23-F030B 1M51-F2208 1P53-F025 1P87-F065 1D23-F040A iM51-F230A 1PS3-F030 1P87-F071 j 1D23-F040B 1M51-F230B 1PS3-F035 1P87-F074 1

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Valve Relief Request # )

VR-22 System: Residual Heat Removal Shi -down Cooling (E12)

Valves: 1E12-F050A, 1E12-F0508 ,

Category: C Class: 2 Function: Provide a flowpath for RHR water for shutdown cooling (e.g. , using the feedwater nozzles).

Test Requirements: IW-3521; Test Frequency - Exercise at least once every three months, quarterly.  ;

Basis for Relief: These simple check valves are within the normal flowpath for shutdown cooling (e.g. , using the feedwater nozzles), i The valves are normally closed during plant operation and require forward flow exercising. Initiation of shutdown I

cooling shall be used to verify the simple check valve l forward flow exercising. Both loops of shutdown cooling should not be required during cold shutdown. Therefore, verification of both shutdown cooling loops (e.g.,

1E12-F050A and 1E12-F050B) operability shall be performed during refueling.

Alternate Testing: Exercise valve during refueling.

Valve Relief Request #

VR-23 System

Reactor Coolant Pressure Isolation Check Valves (RHR, LPCS, HPCS, i

and RCIC) of a testable nature.

Valves: 1E12-F041A, 1E12-F041B, IE12-F041C, 1E21-F006, 1E22-F005, 3 1E51-F065,1E51-F066 3

Category: AC Class: 1 Function: Provide pressure isolation of the reactor coolant pressure boundary between the high pressure reactor coolant system and other safe-

ty-related systems containing low pressure designed components.

Test Requirements

IWV-3521; Test Frequency - Exercise at least once every three months, quarterly, i Basis for Relief: These pressure isolation valves maintain one of the two

high to low pressure barriers during plant operation. To j exercise these valves during plant operation would involve i a loss of one isolation barrier. There is a significant ,

increase in the probability of an internal loss of coolant accident to exercise these valves quarterly.

Alternate Testing: Exercise valve during cold shutdown.

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Valve Relief Request #

VR-24 System: Residual Heat Removal Head Spray Line (E12)

, Valves: IE12-F019 i

Category: C Class: 1

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Function: Provide a flowpath for RHR water for head spray collapsing of the steam in the reactor vessel head.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: The simple check valve is within the normal flowpath for RHR head spray to the reactor vessel head. This valve is l

normally closed during plant operation and requires 1 forward flow exercising. The initiation of head spray 1 when shutting down for refueling shall verify forward flow exercising.

Alternate Testing: Exercise valve during refueling.

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Valve Relief Request #

VR-27 l

System: Safety Relief Valve (SRV) Reactor Head Vent and RHR Relief Line to Suppression Pool Discharge Lines Valves: IB21-F037A, B, C, D, E, F, G, H J, K, L, M, N, P, R, S, T, U, V 1B21-F078A, B, C, D, E, F, G, H J, K, L, M, N, P, R, S, T, U, V i 1B21-F040, IE12-F605A and F605B I

Category: C Class: 2, 3 Function: Vacuum breakers ensure that the steam exhaust discharge lines pressure remains equalized.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

l l Basis for Relief: The SRV, reactor head vent, and RHR relief line to suppression pool discharge vacuum breakers are to provide a means for releasing a vacuum developed in the discharge line from condensing steam. The vacuum breakers are normally closed during plant operation. The forward flow exercising of these valves can be verified manually. This method of exercising would have adverse safety or ALARA concerns during power operations. Exercising to be performed during cold shutdown.

Alternate Testing: Exercise valve during cold shutdown.

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Va1ve Relief Request #

VR-29 System: Drywell Containment Isolation Check Valves Valves: IP22-F593, 1P43-F722, 1PS2-F639 Category: C Class: 2 Function: System check valves for systems penetrating drywell containment.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: These check valves are the inboard drywell containment isolation valves for systems considered inservice during plant operation. The normally open check valves required an exercise in the reverse flow direction. Leak testing ,

of check valves ensure valve exercising in the close direction. Drywell containment leak integrity leakage testing (i.e., Technical Specification 4.6.2.2) and individual leak test each refueling verifies proper valve ,

exercising.

l Alternate Testing: Exercise valve during refueling. 1 l

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Valve Relief Request #

VR-33 System: Nuclear' Boiler (B21)

Valves: IB21-F460, 1B21-F461, 1B21-F462, 1821-F463, 1B21-F480, 1B21-F481, 1B21-F482, 1B21-F483 Category: B Class: 3 Function: Provide air to air operators of the main steam isolation valves.

Test Requirenants: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power operated valvas - Full stroke time i~

IWV-3415; Fail Safe - at least once every 3 months.

Basis for Relief: These solenoid operated valves are proven operable by testing performed on the main steam isolation valves.

Full stroke exercising of the Main Steam Isolation Valves shall result in a loss of steam flow from one main steam line to the turbine. Recent industry information indicates that closing MSIVs with high steam flow in the line may be a large factor in observed seat degradation.

The MSIVs are designed for partial stroke exercising with full steam tiow during plant operation. The partial stroke test will verify operability of the valve and operator.

Alternate Testing: Exercising, full stroke timing, and fail safe timing will be accredited by the testing of the main steam isolation valves during cold shutdown. Position indication of each solenoid operated valve will be verified during this testing at least once every two years.

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Valve Relief Request #

VR-35 System: Nuclear Boiler Head Vent Lines Valves: IB21-F001, 1821-F002, 1821-F005 Category: B Class: 1 Function: Provide a path for venting non-condensible gases from the reactor head region.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valve - Full stroke time Basis for Relief: Exercising of the 1821-F001, 1B21-F002 and 1B21-F005 shall be performed during cold shutdown. Opening of the 1B21-F001 and 1B21-F002 during operation will allow steam to be released into the suppression pool causing a temperature rise and release of non-condensible gas into the primary containment. Testing 1B21-F005 during operation would potentially cause isolation of the head vent path to the main steam lines. Also, the 1B21-F005 valve is not required to operate (i.e., normally open passive) during plant operation.

Alternate TestinT: Exercise valves during cold shutdown.

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e a Valve Relief Request #

VR-36 System: Nuclear Boiler Safety Relief Valves (SRVs)

Valves: IB21-F041 A, B, C, D, E, F, G K IB21-F047 B, C, D, F, G, H 1B21-F051 A, B, C, D G Category: BC Class: 1 Function: To provide a flow path for steam to reduce reactor vessel pressure and heat removal during abnormal plant conditions.

Test Requirements: IWV-3511; Test Frequency - Tested at the end of each time period as defined in Table IWV-3510-1 and IWV-3513 Addi-tional Tests Requirement.

Basis for Relief: The safety relief valves shall be tested in accordance with PPNP Unit 1 Final Safety Analysis Report which requires a 50% sample of SRVs to be set pressure tested each refueling and 100% visual inspection every 5 years.

The FSAR sampling requirements are in excess of ASME code,Section XI requirements.

Alternate Testing: Safety relief valves - relief function - shall be in accordance with PPNP Unit 1 Final Safety Analysis Report test requirements.

Valve Relief Request #

VR-37 System: Reactor Water Cleanup (G33)

Valves: 1G33-F052A, 1G33-F052B Category: C Class: 2 Function: Normal return flow path for Reactor Water Cleanup (RWCU) water to the reactor vessel via feedwater.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly.

Basis for Relief: The reactor water cleanup system is inservice during plant operation maintaining the above check valves open. The function of the RWCU system is to maintain reactor coolant clarity and conductivity. Testing requires the RWCU system to be in an inoperative status. Reverse flow exercising shall be performed during refueling as plant conditions allow.

Alternate Testing: Exercise valves during refueling.

f Valve Relief Request #

VR-38 System: Control Rod Drive Hydraulics (C11)

Valves: IC11-120, IC11-121, 1C11-122, IC11-123 (Typical of 177)

Category: B Class: 2 Function: Direct Control Rod Drive (CRD) for the insertion and withdrawal of control rods.

Test Requirements: IWV-3413; Power operated valves - Full stroke time.

Basis for Relief: The insertion and withdrawal of control rods is accom-plished by the positioning of these valves and IC11-138 (i.e., CRD cooling water check valve). The CRD Units are integrally attached components and notching of control i rods causes rapid positioning of these components. The recording of stroke time (e.g. , less than tenth of a second) would only be indication of electrical circuitry delay and human response errors. Proper in-sertion/ withdrawal by notching shall verify proper valve operability.

Alternate Testing: Verify control rod movement by notching weekly.

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Valve Relief Request #

VR-39 System: Standby Liquid Control Transfer System (C41)

Valves: C41-FS20 Category: AC Class: 2 Function: To provide inboard containment isolation.

Test Requirements: IWV-3251; Test Frequency - Exercise at least once every three (3) months, quarterly.

Basis for Relief: This check valve provides containment isolation and allows a flow path from the SBLC transfer tank to the SBLC tank.

The SBLC tank is maintained in a constant state of readi-ness during plant operations. Testing the check valve requires draining borated solution from the SBLC tank while providing demineralized makeup water, thus reducing the system readiness condition. Transferring water during refueling shall verify forward flow exercising when plant operational mode allows the SBLC system to be inoperable.

Alternate Testing: Exercise during refueling.

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Valve Relief Request #

VR-40 i

System: Reactor Water Cleanup System (G33)  !

Valves: 1G33-F001, IG33-F004, 1G33-F053, IG33-F054 Category: A Class: 1 Function: To provide containment isolation of the Reactor Water Cleanup System.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valves - Full stroke time.

Basis for Relief: The Reactor Water Cleanup System is inservice during ,

normal plant operation and provides a backup in post '

accident analysis. This system ensures that reactor coolant chemistry parameters of pH, chlorides, and acti-vity are maintained within specified limits. These limits are to prevent the likelihood of exceeding 10CFR100 guidelines or allowing stress corrosion cracking of the stainless steel systems. A closure of any valve during surveillance testing would cause a loss of the plant's ability to control chemistry. The operational readiness of these valves shall be verified during cold shutdown.

Alternate Testing: Exercise valve during cold shutdown.

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Valve Relief Request #

VR-41 System: Control Rod Drive Hydraulic System (C11) e Valves: IC11-115 (typical of 177)

Category: C Class: 2 Function: Control Rod Drive Accumulator Supply Check Valve.

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months Basis for Relief: This valve operates as an integral part of the hydraulic control unit to rapidly insert control rods. The valve will be tested in accordance with Technical Specifica-tion 4.1.3.3.b.2 (Scram Accumulator Pressure Drop Test). l The Technical Specification requires verifying that each l individual accumulator check valve maintains the associ-ated accumulator pressure above the alarm setpoint for '

greater than or equal to 10 minutes at least once every ,

18 months.

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The reverse flow exercising of the check valve shall be satisfied by performance of the Accumulator Pressure Drop l Test. l I

Alternate) Testing: Accumulator Pressure Drop Test shall be substituted for the check valve exercising each refueling.

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VR-44 System: Containment Vessel & Drywell Purge (M14)

Valves: 1M14-F045, IM14-F055A, IM14-F055B, 1M14-F060A, 1M14-F060B, IM14-F065, IM14-F070, IM14-F085 Category: A, B Class: 1, 2 Function: To provide drywell isolation for the Drywell Purge Supply System and containment isolation for the Drywell and Containment Purge Systems.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valves - Full Stroke Time.

IWV-3415; Fail Safe - At least once every three months. l Basis for Relief: These valves are placed under " sealed closed" administra-tive controls during normal plant operations. The drywell purge supply train isolation valves are maintained closed per Technical Specification 3.6.1.8.c and seal water is injected between these isolation valves. The seal water i is used to minimize the affects of radiation streaming. i The term " sealed closed" as used in this context means l that the valves are secured in its close position by deactivating the motor operators. The maintaining of drywell integrity and required draining / filling of these lines to perform routine testing would involve extensive maintenance periods. Exercising of these valves shall be deferred to refueling outages and prior to declaring the l valves operable.

Alternate Testing: Exercise valve during refueling and/or prior to declaring valves operable.

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Valve Relief Request #

VR-45 System: Fuel Pool Cooling and Cleanup (G41)

Valves: G41-F597A and G41-F597B l

Category: C Class: 3 Function: The check valves prevent backflow from the Fuel Pool Cooling and i Cleanup Surge Tanks (G41-A002A and G41-A002B) to the Fuel Transfer Tube Drain Tank (G41-A003).

Test Requirements: IWV-3521; Test Frequency - Exercise at least once every three months, quarterly, i

l Basis of Relief: These check valves remain closed during reactor operation with the Fuel Transfer Tube Drain Tank secured. The l functional operability of each check valve (i.e., forward I flow exercising) shall be required during refueling I outages for the purpose of pumping the Fuel Transfer Tube Drain Tank to the Surge Tanks. In addition, the Fuel Transfer Tube Drain Tank is isolated by a blank flange l (10CFR50, Appendix J, Type C Test) making the system inoperable during reactor operation. Action required prior to placing the Fuel Transfer Tube Drain Tank in an operable status shall be forward flow exercising of the check valves.

Alternate Testing: Exercising valves during refueling. l I

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Valve Relief Request #

I VR-46 I

.l System: Reactor Coolant Pressure Isolation Testable Check Valves (RHR, LPCS, 7 RCIC and HPCS).

Valves: 1E12-F041A, 1E12-F041B, 1E12-F041C, 1E21-F006, 1E22-F005, IE51-F066 Category: AC Class: 1 i

Function: Provide pressure isolation of the reactor coolant pressure boundary I between the high pressure reactor coolant system and other safe-ty-related systems containing low pressure designed components.

Test Requirements: IWV-3300 Valve Position Indicator Verification. Valves with remote position indicators shall be observed at least i once every two (2) years to verify that valve operation is I accurately indicated. )

Basis of Relief: These check valves have no external means of visually verifying actual valve position. Valve position shall be verified by magnetic means and compared to indicator lights at least every two years. )

Alternate Testing: Verify actual valve position by magnetic means.

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Valve Relief Request #

VR-47 l System: Residual Heat Removal System (1E12)

Valves: 1E12-F026A, IE12-F026B, 1E12-F052A, IE12-F052B, IE12-F087A, j 1E12-F087B.  ;

Category: B J

Class: 2 Function: Residual Heat Removal Valves used during steam condensing mode of operation. With the RHR system in standby readiness these valves l are normally closed isolating the RHR from Main Steam system I pressure.

Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valves - full stroke time l Basis for Relief: These valves are closed for all modes of system operation except steam condensing mode. The Residual Heat Removal l System is designed as low pressure and requires isolation from the reactor coolant pressure boundary. These valves provide system pressure isolation from Reactor Core Isolation Cooling supply steam and RCIC pump supply. To maintain the system pressure isolation these valves shall i be tested during cold shutdown.

Alternate Testing: Exercise valves during cold shutdown.

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VR-48 System: Residual Hast Removal (Loop C), Low Pressure Core Spray, High Pressure Core Spray Valves: 1E12-F105, 1E21-F001, 1E22-F001, IE22-F015.

Category: A, B Class: 2 Function: These valves provide the suction supply for the safety-related pumps. The two (2) sources of water supply are the condensate storage tank and suppression pool.

, Test Requirements: IWV-3411; Test Frequency - Exercise at least once every three months and IWV-3413; Power Operated Valves - full stroke time Basis for Relief: These valves have stroke time durations, such that, should ,

the pumps receive a signal to start during the exercising, pump damage could occur due to loss of suction supply. To prevent pump starts would require making the safety system inoperable which would place the plant in a Limiting Condition of Operation. These valves shall be tested during cold shutdown as not to place the plant in a Limiting Condition of Operation.

Alternate Testing: Exercise valves during cold shutdown.

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