U-601949, Forwards Info to Resolve Issues Re NRC Review of Util Inservice Testing Program for Initial 120-month Insp Interval & Relief Requests

Forwards Info to Resolve Issues Re NRC Review of Util Inservice Testing Program for Initial 120-month Insp Interval & Relief Requests

ML20091D897
Person / Time
Site:	Clinton
Issue date:	04/03/1992
From:	Spangenberg F ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
U-601949, NUDOCS 9204130169
Download: ML20091D897 (46)

Text

{{#Wiki_filter:__._ I t iwn.au.m comne C\\mtm Wset %fm v o to, un l rimLut k ( 11/7 1101217 OE fEP1 ILLINF)lS POWER $$$$4n)u> BE.100c April 3, 1997 10CrR50.55a Docket No. 50 461 Docuroent Cont rol Desk Noelwr Regulatory Commission Washington, D.C. 20555

Subject:

Clintori Power Station Proposed Resolution of Issues Related to NRC Review of Innervice Testinn Pror.rnm

Dear Sir:

lay NRC letter dated September 30, 1991, Illinois Power (IP) received the results of the NRC's review of the Clinton Power Station (CPS) Inservice Tasting (IST) prograrn for the initial 120 ronth inspection interval. The NRC's September 30, 1991 Safety Evaluation Report (SER) concluded that the CPS IST prograin is acceptabic f or 1rnplernentation (except for those relief requests which were denied) provided the iteins identified in the SER are addressed within 8 months of receipt. Resolution of the items identified in the SER was the subject of a meeting between IP and NRC staff personnel held at the NRC's White Flint offices on January 23 and 24, 1992.* This letter is being provided an a follow.up to that rueeting and to provide a summary of IP's proposed course of action to resolve the items identified in the SER. Detailed informat. ion and discussion regarding IP's proposed disposition of euch of the relief requests associated with the iterns identified in the SER is provided in the attachments to this letter, Attachment 1 to this letter provides a_ discussion of the proposed resolution for each of the subject relief requests. Attachment 2 to this letter provides a re-creation of the flow chart developed during the January rnecting for . categorizing each of the relief requests, and Attachment 3 provides a more detailed matrix which serves to crosn-reference the relief request numbers with the items identified in the SER. to this lotter contains those reli.cf requests which have been revised as a result of the January meeting. In addition, it should be noted that several relief requests (ani discussed in Attachment 1) are being withdrawn by this letter. I j (. [)( $ A roeoting summary, including a list of attendees, was issued by NRC letter dated March 3,1992. ( 9204130169 920403 l PDR ADOCK 05000461' t p. PDR

U-601949 Pare 2 of 2 l g As discussed at the January meeting and in accordance with the NRC's September 30, 1991 SER which was received on October 25, 1991, IP will provide a final response to the items identified in the SER by June 25, 1992. Sincerely yours, .U Os 0% F. A, Spang,nberg 111 Manager, Li ensin and Saf DAS/alh TBE2:DAS12 Attachments cc: NRC Clinton Licensing Project Manager NRC Resident Office NRC Region III Regional Administrator 1111noia Departnent of bucicar safety _

Attachment. 1 i to U.601949 t Pagt 1 of 6 Dackr.round by letter dated September 30, 1991, Illinois Power (1P) received the results of the NRC's review of the Clinton Power Station (CPS) Inservice Testing (IST) program for the initial 120 month inspection interval. As identified in the NRC's letter, each of the relief requesta contained in the IST program was i ther granted, granted with provisions, granted on an intering basis, or denied. Those relief requests which were not granted have been further categorized below into seven " cases" in order to facilitate identification of further actions required on the part of IP or the NRC. This attachment provides a aiccussion of the proposed resolution l of each of the relief requests discussed in the NRC's September 30, 1991 safety evaluation report ( S ER). Additional description and details for each relief request discussed in this attachment are provided in Attachments 2 and 3. I came 1 r The following relief requests were denied by the NRC and are being withdrawn by this letter. These requests are identified in Attachment 2 as - Case 1: 1002 - Deferring testing if back up subsystem / loop / train is out of servico. i 2017 - Testing frequency for reactor water cleanup syrtem valves 1C33-F001, F004, F039, F040, F053, and F054, 2030 - Exercise requirements for standby liquid control system check valve IC41-F006 and closure verification for valves 1E21-F050A/B and 1ES1-

F040, f

2031 - Alternato method for determining test samplo size for Main Steam Safety / Relief Valves. %.1.1 The following relief requests were denied by the NRC, but based on discussions at the January meeting, they have been revised for resubmittal and reconsideration. The revised relief requests contain more detail with respect to justification for the requested relief. IP believes that the additional justification provided will facilitate NRC approval. These - revised relief requests are contained in Attachment 4 for NRC review, Please note that IP is requesting priority review of these revised relief requests. These requests are identified in Attachment 2 as Case 2; 2014 - Full stroke exercise requireuents for testable check valves 1E12-F041 A/B/C, 1E21-F006, and 1E22 F005. 3002 Flow rate measurement method and acceptance criteria for diesel generator fuel oil transfer pumps 1D001PA, PB, and PC. r 'm se - - m. . e _.4---,,, ,.r. - ....-..-....a..-

to U 601949 s Page 2 of 6 3006 - Allowable ranges for flow rates and differential pressures associated w!:h pumps in the IST program. (It should be noted that the scope of this request has been significantly reduced. This request was previously submitted as a generic request for all pumps in the IST program except those covered in relief request 3002. This relief request is now liidted to the four water leg pumps.) Cane 3 Approval of the following relief tequests was granted with provisions or on an interim basin, _ These requests require no further NRC review as the provisions are curren;1y being implemented, will be implemented via a revision to the CPS IST program (which will be submitted by June 25, 1992) s or the requests are being withdrawn. P'tatis-for each of these requests are identified below. These requests are identified in Attachment 2 as -Case 3: 2007 Stroke time testing for valve 1E12 F095. (This relief request will be resolved prior to June 25, 1992. See Attachment 3 for additional details.) 2020 This relief request was previously withdtawn as acknowledged in the NRC's September 30, 1991 SER, 2021 Stroke time testing following packing adjustment. (This request is being withdrawn via this submitts1.) 2027 - Drywell isolation valves. (This request will be resolved prior to June 25, 1992. Jee Attachment 3 for additional details.) 2029 - Verification of air accumulator check valve closure by pressure drop tosta. (The provisions have already been implemented. No program revision is required.) Case 4 Approval of the following relief requests "as granted with provisions or on an interim basis. These requests have been revised to indicate that they are associated with augmented testing _ requirements which are beyond tha scope of 10CFR50.55a as these components are not ASME Class 1, 2, or 3. No further NRC review of those requests is necessary. These revised relief . requests have been provided in Attachment 4 for informational purposes and are identified in Attachment 2 as Case 4: 2024 - Control rod drive hydraulic control unit valvos 1C11 126, 127, 139, and 114. 2026 - Diesel generator air start system solenoid valves IDC008A.K.

..., -. ~ ~. _ _ _ - Y -Attachment 1 to U-601949 b Page 3 of-6 - Case 5 Approval of relief request 2008 was partially granted with provisions and partially on an interim basis. This request has been revised to agree with the results of discussions with the NRC staff and been divided into two relief requests for clarity. -These requests are provided-in Attachment 4 z for NRC review and are identified in Attachment 2 as Case 5: 2008 Testing method for water-leg keep fill stop-check valves IE22 F006, 1E12 F085A, B, C and IE21 F034 and check valves 1033 F051 and F052 A/B, Approval of the portion of this relief request associated with the water-leg keep fill stop check valves was granted on an interim basis untti June 25, 1992. IP is requencing an extension of the interim relief period until ND.C review of revised relief request 2008'is complete. For clarity, the requast pertaining to valves 1033-F051 and F052A/B has been daleted from relief request 2008 and is now addressed separately in new relief request 2033 below. IP is further requesting priority review of revised relief request 2008, With respect to interim approval of relief request 2008, the NRC's SER stated that inspecting a sample of the water-leg keep-fill stop-check valves, as CPS ptoposed, was unacceptable. The SER states that IP must inspect all of the subject valses during the interim period, As stated in Section 3.1.8.1 of the Technical Evaluation Report attached to the NRC's SER, check valve disassembly and inspection is a valuable maintenence tool that provides a great deal of information about valve condition and as such, should provide reasonable assurance of valve operational readiness during the interim period. In addition, sample disassembly programs are consistent with NRC Ceneric Letter 89 04, Attachment 1 Position 2. As a result, IP has determined that the current sample disassembly program will provide adequate assurance of the aparational readiness of.these valves until NRC review of revised relief request 2008 is complete. 2033 - This is a new celief request addressing the testing frequency and method for exercising check valves IC33-F051 and F052 A/B. Approval of this portion of e.. ,ci ' request 2008 was granted with provisions. However, based on :U: -.lons at the January meeting,'IP has revised the alternate test;nt.ethod for these valves. As stated in the SER, progra.a/ procedure changes covered by this item must-be made prior to June 25, 1992, le is requesting that1the required implementation date for the provisions identified in the SER for the portion of relief request 2008 associated with these valves be extended until NRC review of new relief request 2033 is complete. IP is also requesting priority review of this new relief request. t P d

f to U-601949 Page 4 of 6 4 Case 6 Approval of the following rellei request was granted with provisions. This request has-been revised to comply with the provisions identified in the a SER. This revised relief request has been provided in Attachment 4 for informational purposes. No further NRC review of this relief request is necessary. This request is identified in Attachment 2 as case 6: 1001 - Allowable extension for test frequency of valves and pumps in the IST program. Casql - Approval of the following relief requests was granted with provisions. As IP plans to impicment tho' provisions identified in the SER, no further NRC review of these relief requests is required. Ilowever, an extension to the required implementation date for the provisions is being requested until the next test.following August 26, 1992 to allow time to complete the required procedure changes. These requests are identified in Attachment 2 as Case 7: 2011 - Leak rate testing, excess _ flow check valve differential pressure testing, analysis of leakage rate, and co rective action for containment isolation valves. 2012 - Test frequency and stroke time evaluation for automatic depressurization' system (ADS) valves IB21-F041 B/C/D/F, F047 A/C and Tr$1C. This rclief request has been revised to address the ovisions identified in the SER and to be in conformance with NRC Gi 7eric Letter 89-04. This revised relief request has been provided for informational purposes, & %Jyn< 3 Relief Reauest IP had previously submitted relief request 2032 for NRC review prior to receipt of the NRC's SER on the CPS IST program. However relief request 2032 was not included in the NRC's review of the CPS IST program as documented in the SER. Relief request 2032 requested relief from the requirements of IWV-3417 for stroke. time testing of power (air) operated valves with stroke times of ten seconds or less. After further discussion with the NRC staff, IP has - determined that this request should be revised to comply with NRC Ceneric Letter 89-04, Attachment 1 Positions S and 6. These NRC positions address establishing limiting stroke time. for power operated valves and measuring g the changes in valve stroke times (for. valves with stroke-timos less than ten seconds) from a reference value rather than from the previous test. JThis relief-request has been revised and is included in Attachment 4 for informational purposes. As this alternate testing criteria is in conformance with NRC Ceneric Letter 89-04, no further NRC review of relief request 2032 is required. l l

to U 601949 Page 5 of 6 Summary-Based-on the above discussion, IP is requesting further NRC action as follows: 1, Grant an exten< ion to the required impicmentation date until the next test following August 26, 1992 for those relief requests which were granted with provisions and for which additional time is necessary to maks required procedure changes tr implement the provisions of the NRC's SER. This request applies to Case 7 relief requests 2011 and j 2012. 4 2. Grant an extension to the interim relief period for Case 5 relief request 2008 from June 25, 1992 until NRC review of revised relief request 2008 and new relief request 2033 is complete. In addition, IP is requesting that the requirement to disassemble all water-leg keep fill stop check valves during this interim period be waived. 3. Priority review-is being requested for those relief requests which have been revised to address those concerns identified in-the NRC's SER. This request applies to revised relief requests 2014, 3002, 3006, and 2008 and new relief request 2033. (Cases 2 and 5). No further action is being requested of the NRC for relief requests 1002, 2017, 2030, 2031, 2007, 2020, 2021, 2027, 2029, 2024, 2026, 1001, and 2032. (Cases 1,.3, 4, and 6). As indicated previously, Attachment 4 to this letter contains those relief requests which have been revised. The relief requests contained in are arranged in order by relief request number, first for those which require NRC review (relief requests 2008, 2014, '033, 3002, and 3006), and second for those which do not' require NRC review (relief requests 1001, 2012, 2024, 2026, and 2032). Finally, it should again be noted that relief requests 1002, 2017, 2020, 2021, 2030, and 2031 have been-withdrawn. ASME Code' Edition During the. January. 23, 1992 meeting with the NRC, the ASME Code edition on-which the-CPS _IST program is based was questioned. The regulations [10CFR50.55a(g)(4)(1)] require the IST program for the initial 120 month inspection interval to comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of 10CFR50,55a on the date 12 months prior to the date of issuance of the operating license. NRC approval of the 1983 Edition with addenda through - Summer.1983 Addenda was identified in the September 26, 1985 Federal Register (page 38970). liowever, the identified effective date for this change was October 28, 1985. Therefore per 10CFR50.55a(g)(4)(1), the initial '120-month inspection interval IST programs for those plants whose opersting license was issued after October 28. 1986 are required to be based on thn 1983 Edition with addenda through the Swnmer 1983 Addenda.

.. - -= to U-601949. Page 6 of_6 ~ ~ - The low-power operating license for CPS ~(NPF-55) was issued on September-29, 1986,- As-a' result, the abovel change did not alter the requirements for CPS. The requirements in effect prior to_ issuance of.the September 26,- 1985 Federal Register required the initial-120 month inspection interval IST program to be based on the 1980 Edition with addenda through the Winter 1981 Addenda. -Therefore, the Code edition on which the initial 120-month ' inspection interval CPS IST program is based is in conformance with 1 10CFR50.55a(g), i s ? + 6 sry- + c ,.y--in, ..v# .-,r-- ,,. r .,_ --->-i .e ,1-- a.

ATTACHMENT 2 CASE 1 CASE 2 CASE 3 CASE 4 CASE 5 CASE 6 CASE 7 RELIEF RELIEF INTERIM INTERIM INTERIM RELIEF RELIEF DENIED DENIED RELIEF RELIEF RELIEF GRANTED GRANTED GRANTED OR GRANTED OR GRANTED OR WITH WITH GRANTED GRANTED GRANTED FROVISIONS PROVISIONS WITH WITH WITH PROVISIONS PROVISIONS PROVISIONS MEET CODE RESUBMIT MEET RESUBMIT RESUDMIT REVISE RELIEF PROVISIONS RELIEF TO COMPLY PROGRAM TO REQUEST OR REQUEST WITH COMPLY WITH MEET CODE PROVISIONS PROVISIONS ITEMS NO NRC NRC NO NRC NO NRC NRC REVIEW NO NRC NRC EXTEND ACTION REVIEW ACTION ACTION AND EXTEND ACTION REQUIRED REQUESTED REQUESTED REQUESTED REQUESTED INTERIM REQUESTED IMPLEMENTATION RELIEF DATE 1002, 2017

2014, 3002

2007, 2020 2024, 2026 2008, 2033 1001 2011, 2012 2030, 2031 3006*

2021, 2027 2029 REPLACE GENERIC RELIEF REQUEST WITH SPECIFIC OR MEET THE CODE

ATTACHMENT 3 L IP REllEF REGUEST SER PROPOSED SESOLUTION ANCMALY NUMBER (S) RELIEF SER REFERENCE SER REQUIREMENT PROPOSED SOLUTION ACTIONS. REQUEST AND SUBJECT CESCRIPfl0N AND FLOW CHART PETERENCE i 1 3006 2.1.2.1 Relief Denied. Each ptanp in the ISI program CPS-The fctiowing purps s*et [ (22) has been evaluated, and section XI acceptance less restrictive flow and DP CPS eust follow IWP CPS is revising the IST criteria, therefore, CPS dets allowabla range requirements guidelines. Program to meet the Code, or not need any re11ef from for att pu m s in the CPS ISI where applicable the relief Section X1 acceptarwe program. request has been revised via criteria. this stinittal on an individust cocponent basis. 1C41-C00'A,8; 1E12-C002A,8,C; 1E21-C001; 1E22-LD01; Case 2 1E51-CO'J1; 1FCO2PA,8; ISx01PA.8,C; OVCOBA,8. CPS is revising the applicable procedures fer these puros to revise the acceptance criteria to comply with Section x! on a l priority basis ard will be co mtete before 6-25-92: o CPS-This Relief Request has been revised and resubmitted with this letter for water-teg pa ys 1E12-C003, 1E21-C002, i 1E22-C002 and 1E51-C002 to } justify the need for relief i-from Section XI accepta*ce criteria based on CPS operating e merience of these ptrps. Diesel fuel oil trarafer punes 10001PA,0,C are address *d in the revised relief request 3002. 2 3002. 2.3.1.1 Relief Denied. CPS will provide further CPS has revised the relief continued on next page Page 1 of 7 i r i 4 v s -

l IP RELIEF REQlfB7 tER PROPOSED RESOLtiTION ANOMALY tPJMBER S) RELIEF SER REFERENCE SER REQUIREMENT PROPOSED SOLUTION ACTIONS REQUEST AND SUBJECT DESCRIPfl0N AND FLOW CHART REFERENCE 2 3002 Justification for e panded l request and restmitted it ' Diesel fuel oft transfer purps The attowable ranges should be acceptence criteria. with this letter for the DC (DO) attewable range based on deviation frors ptrps, justifying the reed for specifications for flow. reference values as per Code Case 2 expanding attowable and alert Atsc, flow measurement methxi requirements. The proposed ranges based upon each p.ro's and accuracy. method of flou rate reference or baseline flew measurement is acceptebte rate and performance history. p-ovided the instrument accuracy meets the The calculated flow rates r= quire *nts od IWP-4110 end provide an accuracy which itP-C20. meets the Code recu1re-erts. 3 1002 3.1.2.1 Relief denied. CPS is withdrawing this petief Mone-Actions comotete via Request. this submittat. Testing of a cmponent when a specific relief requests redundant train is should be submitted for Case 1 out-of-service. affected comyanents. 4 and 7 2011 3.1.3.1 Retief granted with provision. Procedures will be reviewed to hRC - Estension of required 3.1.7.1 ensure that valves which can inptementation date regeested. Testing and evaluating those be individually tested are net Individual teak rate testing containment isetation valves tested in groups. CPS will review'and determine of contaireent itolation that cannot practically be the need to change procedures vatwes using maximum irdividually leak rate tested, CPS will verify that the by 6-25-92. Procedures will permissible leakage of an provided that these valves are assigned maxietn group tenkage then be revised by the next individual valve, teak rate tested in a grote rate limits are conservative test after B-26-72. and uximurn grotp teskage rate based on CPS experience with Leak rate testing of excess limits are assigned that are each penetration. Action cerclete via this flow check valves. conservative based on the stirsittat for excess ficu smallest valve in the grosp. Current IST Program and check valves. procedures verify that each Each excess flow check valve excess flow check valve actuates to restrict flow. hen actuates to restrict flow at subjected to the required the required differential differential pressure. pressure. continued on next page Page 2 of 7 t

IP RELIEF REQUEST SE2 PROPOSED KESOLUTION ANOMLY NUMBER (S) ~ RELIEF .SER REFERENCE SER REQUIREMENT PROPOSED SOLUTION ACTIONS REQUEST AND SUBJECT DESCRIPTION AND FLOW CMART REFERENCE 4 and 7 2011 Case 7 5 2021 3.1.4.1 Relief granted with provision. CPS is withdrawing this Relief CPS - Revise the applicable ReQJest. CPS procedure by 6-25-92. Deferment of PMT for minor Due to the sensitive nature of packing adjustments. this maintenance work and the case 3 possibility of comon mode falture, relief frorn the Code requirements is contingent upon meeting several conditions. 6 2027 3.1.6.1 Interim relief granted. CPS witt reevatunte these CPS-Based soon its watwes to determine whether evaluation, CPS will revise Itdividual teak rate testing Proposed alternate testing these valves should be the IST program and preceduees of drywell isolation valves. does not provide infermation Category A cr 8. If this by 6-25-92. that assures that these valves evaluation determines that are capable of performing a these valves could be Category Category A teak tight closu*e B, then CPS will ensure that function. the drywett bypass teakage test procedure has criteria for actico to identify problem valves. t case 3 4 8 20C8 3.1.8.1, 3.10.2.1 Interim relief granted. Per NRC discussion en 1-23-92, CPS has revised the relief CPS considers the ser!es check request arti resubmitted it verification of water-leg CPS Fust devetCp and implement valves to be a single entity with this tetter to only keep-fill check valve and procedures to test check valve which is to be tested as a address the water-tes reactor water cleanup check closure by manually opening unit. keep-fiti check valves. Fer valve closure. the check valves in series clarity, CPS has generated with the check valves listed Case 5 actief peesest 2033 to in this relief req.Jesi. In separately address the reacter addition, exercise testim water cleanup check 'alves. v continued on next Inge Page 3 of 7 + + -w--r

IP QEllEF REQUES7 SER KX) POSED QESCLUT!0er AMOMALY WUMBER(S) RELIEF SER REFERENCE' SER REQUIREMENT .tR0 POSED SOLUTION ACTIONS REQUEST AND SUBJECT DESCRIPTION AND FLOW CHART REFERENCE t 8 2008 with flow is expected to be This request is also being performed after, valve stknitted via this letter. 'l disassenbly and inspection is eceptete but before returning NRC - Extensio1 of interim I the valve to service. ~ relief period until NRC. approval of. revised relief' i request 2008 and new relief [ request 2033 is requested.' ( CPS - Revise the IST Program and procedures to reflect the proposed testing method [ feitowing WRC approval. 9 2012 3.2.1.i Relief granted wiin provision. These valves will be treated NRC-Exte% ion of required as rapid-acting in accordance inplementation date until I i Testing of ADS valves to CPS should develop som means witn Generic Letter 89-04 8-26-92 is req;ested. detect degradation. of testing these valves that Relief Request has been will allow the detection of revised and resubmitted with CPS - IST Program and salve degradation so this letter. procedures will be revised to corrective actions can be reflect the changet by taken when a valve's continued Case 7 8-26-92. -t operability is in question. i CPS has revised the relief request and resubsitted it with this letter. 10 2031 3.2.2.1 Relief denied. CPS is withdrawing this relief None-Actions corptete via request. this submittat. M?RV replacement and The proposal to not require additional testing. edditional valve testing based Case 1 on failure rates is net supported by plant and industry feiture rates for { continued on next page Page 4 of 7 4 I

IP REtlEF REQUESV SER PROPOSED RESOLU7tDN i ANOMALY NUMBER (S) RELIEF SER REFERENCE ' SER REQUIREMENT - PROPOSED $0 TUT 10N ACT10NS i REQUEST AND SUBJECT DESCRIPTION AND FLCW CHART REFEAENCE 1 10 2031 these valves. 11 2014 3.4.1.T, 3.S.1.1, I.6.1.1 Relief denied. CPS resubmit the retief CPS has revised the relie*' request to provide further request and resubmitted it Futt stroke testing of CPS ISI pecgrara nust incbJde justification. with this letter, providin? testable check valves. full stroke exercise of mere specific technical applicable testable check Case 2 Justification for not I walves on a cold shutdown performing fuit streke sched;te, enrcise of these testable check valves during cold shutdowns. i 12 2029 3.3.1.2 Relief granted with provision. No fur *ber action is reqJired. None-Action Complete. i The CPS IST Prograre and verification of air CPS IST program to identify procedures provide acceptance acetrutator check valve acceptance criteria fer these criteria for pressure drop closure. pressure drop tests. tests. Case 3 .l t 13 and 16,17 2030 3.4.1.3, 3.7.1.2, 3.8.1.2 Retlef danled. CPS is withdrawing this relief The CPS IST Program has been request. revised to incorporate a i verification of ct.erk valve CPS must revise the IST mechanical closure exercise L closure (1ES1-F040, Program and procedures to Case 1 fcr these valves on a 1E12-F050A, 1E12-F0509). perform testire to verify quarterly or cold shutdewn Exercise recuir*ments for closure of the affected check freqJenCY. 1C41-F006. valves quarterly during power i operation or durirl cold shutdowns. IInterim relief granted fcr 1C41-F006 exercise requirement. i I. continued on next page i Page 5 of 7

IP RELIEF REQUEST SER PROPOSED RESOLUTICW A OdAl,Y VJMSER(S) RELIEF SER REFERENCE SER REQUIREMENT PROPOSED SQLtJTION ACTIONS AND FLOW CHART REFERENCE RE7 JEST A C SU3 JECT DESCRIPTION I 13 and 16,17 2030 14 2037 3.4.2.1 Interim relief granted. CPS is evaluatirg this valve Based upon its evaluation, CPS to determine if it has en allt revise the IST Progra* Stroke time testing of CPS must develop a means to ac'ive safety function in i@tementing procedsres and . 1E12-F095. monitor valve condition and shutting down the reactcc to a itsAR by 6-23-92. detect degradation, incitxfing cold shutdown condition or in developing a method to measure mitigating the consevsences of stroke time ard verif y that an accident. this time remains under a reasonable maxle m strcke time case 3 timit. 15 2020 3.7.t.1 Interim relief granted. CPS has previously withdra e None-Action Co@ tete. This request, as noted in Fult stroke exercising of CFS should full-stroke US1GC Safety Evaluation, testable ched valve 1E51-F066 exercise this vatve as section 2.0 Evaluatf rn, page during cold shutdown. req; ired by the Code. 2, paragraph 5. Case 3 13 2017 3.10.1.1 Relief Denied. cps is withdrawing this retief The C IST program erwt i@lTmenting procedure % have reqJest. been revised to comply with Testing of RT system CPS must revise affected contaireent isolation valves procedres to exerefse va!ves case 1 the Code regairements, during cold shutdown. daring ;old shutdown. 19 2026 3.12.1.1 Interim retief granted. cps restbnit the relief cps has revised the retief request providirs f urther ree;est and resubmitted it Strcke time testing of Og CPS to perf o-m strcke time justification. with this letter to identify that these ceriponents are air-start system solenoid trending of dieset gererator non-Code and are not within air-start solenoid valves. Case 4 'vatves. the scope of Section XI. CPS will continue its current 151 testing as augnented testing. Page 6 of 7 l

-,....~m..-.- .~.... -.. -. m -... ~. _ ~. ~ Iy : 'IP RELIEF RECUEST SER PQCPOSED RESOLUTION ANOMALY NUMBER (5) RELIEF: SER REFERENC1 SER REQUIREMENT PROPOSED SOLUTION ACTICNS REQUEST AND SUBJECT DESCRIPTION AND TLOW CHART REFERENCE 19 - 2026 20 2024 3.9.3.1 Relief granted with provision. CPS resutrait the relief CPS has revised the retlef reg;est r oviding further request ard restkxnitted it Testing of Control-Rod Drive A more specific technical justification.' with this letter, to provide (HCU).1C11-114 valves. This justification'should be specific technicat relief request also includes provided for valve 1C11-114 Case 4 justification for velve valves 1C11-126, 1C11-127, and 1C11-114 and to identify that 1C11-130 att four (4) valves ilsted in this relief request are non-Code and are not within the scope of Section XI.. CPS witI coMinue te test 10% ef these valves every 120 days as required by the CPS Technical Specifications. 21 1001 3.1.$.1 Relief granted with CPS to resubmit relief regast CPS has revised the retlef provisions. Specifying testing fre7JenCY. request and resubmitted it IST frequancy extensicrt. jwith this letter. This Relief not applicable to Case 6 revised request identifies safety and relief valves and that this relief request is valves not tested at Code only a @ ticable to those tests specified Intervals. required on a quarterly (3 eer.th) or shorter testing frequency. No changes to irplementing procedures are required. Page 7 cf 7 t

f ATTACllMENT 4 Revised Relief Requesta 3 s 9 i i [ [ l l: I i i 4 w

Revised Relief Roquests Wh'ch Require NRC Review ~ N I

-. - ~ ) i 1 ILLINOIS POWER COMPANY Clinton Power Station ASME Section XI Relief Request RELIEP REQUEST 2008 (Revision 3) l Valve 1E22-F006 is located COMPONENT INFORMATION between liigh Pressure Core Spray (HP) water-leg pump and the main HP injuction line. It is a 2-inch stop-check valve, ASME Section III class 2, Section XI Category C. It is circled on the attached drawing "A". Valves 1E12-F085A,B,C and 1E21-F034 are located between the water-leg pumps and their respective injection lines (Residual Heat Removal (RHR) and Low Pressure Core Spray (LP)). They are ASME Section III Class 2, Section XI Category C valves. They are 2-inch stop-check valves of identical design. As their piping configuration is similar, only 1E21-F034 is circled on the attached drawing "B". The ASME

Code, Section XI,

-CODE REQUIREMENTS Subarticle IWV-2520 requires that these valves be full-stroke " exercised individually every three (3) months. Illinois Power Company requests -RELIEF REQUEST / JUSTIFICATION re1ief from the Code requirements for the tollowing reasons: The above_ groups of valves, although located in separate systems, have similar configurations; -they are check valves located in series with other check valves and no test connections provided between them to permit individual valve testing. Each of these valves has a separate check valve in series. The two check valves in series, although not required by design or safety

analysis, provide an added assurance that the high pressure Emergency Core Cooling System (ECCS) line will not damage the lower

_ pressure water-leg piping. Illinois Power Company considers these two check valves in series as a single entity and will test them as such.

~ -.. Illinois Power company considern -ALTERNATE TESTIllG PROPOSED these two check valves in series a single entity and will perform 1 the closure test every three (3) months as a single unit. Acceptance criteria vill-be established-and'in the.cVent of not meeting this criteria, appropriate action Will be initiated for the entity and the deficiency will be corrected. The open exercise of these valves will also be performed every three (3) months. e t l-l i l s.___,..-.-._._..- , ~.. -.

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ILLINOIS POWER COMPANY Clinton Power Station ASME Section XI Relief Request RELIEF REQUEST 2014 (Revision 2) These testable check valves COMPONENT INFORMATION (1E12-F041 A/B/C, 1E21-F006, and L 1E22-F005) provide isolation i trom the reactor coolant system and the emergency core cooling systems (Residual }{ cat Removal, Low Pressure Core Spray, High Pressure Core Spray). These valves are ASME Section III Code Class 1, Section XI Category A/C valves. Valves 1F12-F041 A,B, and C are 12" diameter and valves 1E21-F006 and 1E22-F'05 are 10" diameter. All of these valves are non-slam check vc.1ve, One of these valves (1E12-F041A), which is typical of the group, is circled on the attached drawing. The ASME

Code, Section XI, CODE REQUIREMENTS Subsection IWV-3520 requires that these valves be exercised every three (3) months unless such operation is not practical during plant operation.

In this situation, the valves may be part-stroke exercised during plant operation and full-stroke exercised during cold shutdown. Exercising these valves on a RELIEF REQUEST / JUSTIFICATION three month frequency using the emergency core cooling system pumps to 11_ect water into the reactor is not in the interest of plant safety, because this cooler water would create an undesirable power transient. In addition, neither the Low Pressure Core Spray nor Residual Heat Removal pumps are capable of opening their injection valves against full reactor pressure. Mechanically exercising these valves during reactor operation is not practical because they are located inside the drywell and access is restricted due to radiation conditions. Mechanically exercising these valves on a cold shutdown frequency as allowed by the ASME Code is not practical because the air operator is not designed to perform a full stroke test. Although the air operator can be removed to perform the full stroke test, this is a significant maintenance activity and could interfere with work which is necessary to restore the plant to service. This would create an unreasonable hardship for Illinois Power Company which is not consistent with the guidelines for cold shutdown testing which were provided in Generic Letter 89-04. I

'Using pump pressure to exercise these valves during cold shutdown is also not in the interest of plant safety.. Although temperature could be ' matched - f airly closely be. tween the injection source (emergency core cooling systems) and the reactor, a minor _ thermal mismatch between these temperatures creates an undesirable effect on the-fatigue life of the reactor nozzles. In addition, the injection lines associated with the residual heat removal system nozzles are not equipped with internal spargers. General Electric Sarvice Tnformation Letter 401 identifies problems in injecting water through thi.' flow-path and the potential damage to nuclear instrumentation or fuu) assemblies which could occur if this flow path were used for other titan emergency conditions, Illinois Power company will ALTERNATE TESTING PROPOSED: partial-stroke exercise these valves using the air operators-durang cold shutdown and full e-stroke ' exercise the valves by removing the air actuator during refueling' outages and measuring the torque required to lift the disc and then move the disc through a full stroke.

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9 ) i ILLINOIS POWER COMPANY Clinton Power Station ASME Saction XI Relief Request RELIEF REQUEST 2033 Valves 1G33-F051 and 1G33-COMPONENT INFORMATION. F052A/B are the injection check valves which complete the flow path between the Reactor Water Cleanup (RT) System and the Reactor Pressure Vessel. These valves are ASME Section III code Class 2, Section XI Category B valves. They are 4-inch check valves of identical design i .I are circled on the attached drawing. The ASME

Code, Section II, CODE REQUIREMENTS Subarticle IWV-3520 requires l

that these valves be full-stroke exercised individually every three (3) months. 1G33-F052A/D are parallel valves REL;EP REQUEST / JUSTIFICATION in the piping system and both of these valvoc are in series with 1G33-F051. These valves are located in series with no test connections provided between them to permit individual valve testing. Illinois Power Company considers valves 1G33-F052A and 1G33-F051 (both are in series) as a single entity and will test the valves as such. Valves 1G33-F052B and 1G33-F051 (both are in series) are also considered as a single entity for testing purposes and will be' tested as such. These units (valves) cannot be tested every three (3) months, since they are located in the Steam Tunnel and physical access is restricted during normal plant operation due to the high radiation field in this area. Testing these valves during cold shutdown will either require the Reactor Water Cleanup (RT) System to be out of service or will require flow to be bypassed to the condenser. Testing these valves with RT system flow bypassed to the condenser .may create spurious differential flow signals and may cause containment isolation valves in this system to isolate and subsequently trip the RT pumps, which will likely require filing a Licensee Event Report (LER). Either method will cause the RT system to be out of service and create potential delay for plant startup. This will cause unnecessary hardship for Illinois Power Company without any significant gain in salety.

_ _ ~ l t -] I Illinois Power company considers-ALTERNATE--TESTING PROPOSED' these check valves in series as a single entity and will perform the closure test every' refueling outage as a single unit. Acceptance criteria will be established I and in the event'of_not meeting this criteria, appropria to action will he initiated -for the entity and the deficiency will be - corrected.

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ILLINOIS POWER COMPANY Clinton Power Station ASME Section XI Relief Request RELIEF REQUEST 3002 (Revision 2) This relief request refers to COMPONENT-INFORMATION three (3) Diesel Fuel Oil (DO) transfer pumps (1DOO3PA, 1DOO1PD, and 1DOO1PC). These pumps are used to transfer diesel fuel from the diesel storage tanks to the diesel fuel day tanks. The pumps are ASME Section III, Code Class 3. All of the pumps are-Delaval 1MO type N3DBS-137. CPS tests the pumps at a fixed differential pressure (DP) of 13 psid, with baseline flowrates ranging from 16.424 to 18.13 gpm. The ASME

Code, Section XI,

~ CODE REQUIREMENTS Subsection IWP-3210 tabulates the allowable ranges of inservice test quantities (flowrate) in relation to the reference or baseline values. Table IWP-3100-2 requires an acceptable flowrate range of 0.94 to 1.02. of baseline flowrate, and an Alert range of 0.9 to 1.03 of baseline flowrate. Because the DO pumps operate at RELIEF REQUEST / JUSTIFICATION a low flow and the Code specified acceptable ranges are based upon a percentage of the baseline, an increase in flow of less than 0.5 gpm (1.02 x baseline flowrate) is sufficient to force any of the pumps into the Required Action range. (SEE GRAPH 1) The design required fuel delivery rates for each of the diesel generators (supplied by the day tanks which the DO pumps maintain) is considerably less than the rated fuel delivery of any of the three DO pumps. The diesel engines are equipped with skid mounted pumps which supply fuel oil at a rate of 4 gpm per engine. The engines consume less than 3 gpm per engine with the excess routed back to the day tank, pumps 1DOO1PA and 1DOO1PB supply 2 engines each and therefore 8-gpm has beer determined to be -the limiting flow rate required for these pumps to. ensure adequate fuel l delivery. Pump 1DOO1PC supplies only 1 engine and therefore has a l limiting flow rate of 4 gpm. i CPS believes that due to the low flow characteristics of the DO pumps and the significant margin of safety between the flow l requirements of the diesel generator and the baseline flowrate provided by the DO pumps, compliance with the Code requirements constitute a hardship with no appreciable gain in safety. l 1 I

_.. _ _ ~ Illinois Power will utilize-the ' ALTERNATE. TESTING PROPOSED following Allowable, Alert, and Action ranges for Diesel Oil pump flowrates. ^ Acceptable Range 2 14 gpm and $ 19 gpm Alert Range' 2 13 and <14 gpm or 2 19 and < 20 gpm Action Range .< 13 gpm > 20 gpm - Based-upon CPS's operating-experience, CPS feels that the revised upper ranges will provide good indications of pump degradation without the unnecessary burden of requiring the pumps to be tested - on an increased frequency or declared inoperable for minor ( < 0.5 gpm') variations in flowrates. (SEE GRAPH 2) u

4 JUV3 '. J 0 013 A (GRAPH 1) BASED UPON A DIFFERENTIAL PRESSURE (DP) OF 13 psid 22 21-20 - 19 18 - s FLOW (gem; y-s--v-d _ :. g-x y y 'y y v v y y y y y .c y y $N

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JUV3 f.J0013A (GRAPH 2) BASED UPON A DIFFERENTIAL PRESSURE (DP) OF 13 psid 2:: 21-CPS RELIEF REQUEST 3002 ALERT RANGE UPPER BOUND x act x x x x x x x x x x x x x x x x x x x x x Y x CPS RELIEF REQUEST 3002 ACCEPTABLE RANGE UPPER BOUND + c l 10 FLOW (gpm, 17 - 3 = = = = = = a- = = = = = = = = = = = = = ~ BASELINE = 15-u- CPS RELIEF REQUEST 3002 ACCEPTABLE RANGE LOWER BOUND + c: Y x x xm x x r. x x x r. x x x x x x x x x y x CPS RELIEF REQUEST 3002 ALERT RANGE LOWER BOUND x b

j ILLINOIS POWER COMPANY Clinton Power Station ASME Section XI Roliof Request RELIEF REQUEST 3000 (Revision 1) This relief request portains to COMPONENT INFORMATION the four (4) water-log pumps (1E12-C003, IE21-C002, IE22-C003, and 1E51-C003) in the CPS ~ IST program. These pumps are required to maintain the water levol in the associated ECCS systems to ensure the provention of a water-hammer transient in the event of an ECCS initiation.. In addition, these pumps have similar characteristics. All four are Gould model 3196 ST, with the primary dif ference being impollor diameter. They are testod at flows m ging from 50 to G4.5 gpm with basolino differential pressurec 'DP) ranging from 44.4 to 48.3 paid for the 1E12-C003, 1E21-C002, and 1022-C003 pumps and 29.4 pond for 1E51-L C003. All pumps are ASME Code Class 2. The ASME Codo Section XI, i CODE' REQUIREMENTS Subsection IWP-3210 tabulatop the allowable and alort ranges of inservice toat quantities (differential pressure (DP)) in relation to the reference, or basolino, values. Tablo J WP-3100-2 requires an acceptable DP range i of 0.93 baseline DP to 1.02 baseline DP and an alert range of 0.9 baseline DP to 1.03 baseline DP. Because the water-leg pumps RELIEF REQUEST / JUSTIFICATION operate at a low DP and the Code specifled acceptable ranges.are i based on a porcentags of the ~ basolino, a small increase in DP can result in the pump reaching the alert or action rango when the pump is operating within design parameters. Using data for the HPCS water-leg pump (IE22-C003) as a representativo example, which has a baseline DP of 48.5 psid, the Code-required acceptable range varies from 45.1 to 49.5 psid, or less than 4.4 psid (SEE GRAPH 1). Likewiso the Code required alert - range for 1E22-C003 varies from 43.7 to 50 psid, for a rango of -6.3 psid. CPS believes the lower acceptable and alert range boundaries (0.93 and 0.9 of baseline DP) are achievable without undue hardship. However, based upon the Code required upper acceptable and alert range boundarios of 1.02 and 1.03 baseline DP) a deviation of only 1.0 paid aboso baceline DP is sufficient to force any of the CPS waterleg pumps onto increased treguency, and an increase greater

l than 1.5 psid above tho-baselino DP will place the pumps in the j action-range. 4 Illinois power will utilize the ALTERNATE TESTING PROPOSED following allowable, alert, and action rangos for water-leg pump difforontial pressure. j neceptabio Rango (0.93 to 1.05) x (basolino dp value) i Alert Rango (0.90 to 1.10) x (baselino dp value) l (0.90) x (basolino dp valuo) Action Rango ~ < l > (1.10) x _(baselino dp valuo) Based upon CPS's operaPing oxporlonco, CPS fools that the rovisod upper rangos - Will provide good indications of pump degradation without the unnecessary burden of requiring the pumps to be tested on increased frequency or declaring them inoperable for minor (1 to 2 psid) v.. ?ntions in DP (SEE GRAPil 2). ' CPS has ovaluated minor fluctuations of this type and has datormined that this performance L is not an indication of pump degradation, and the pumps are operating within design allowable limits. In addition, as those pumps are normally running, line pressure is continually monitored via pressuro transmittors by the Main control i Room snd any failure will be immediately observed by Control Room personnel. t. t t' ,w.-.n,+ w y

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Revised Relief Requests k'hich Do tiot Require 101C Review

ILLIllOIS POWER COMPA!1Y Clinton Power Station ASME Section XI Relief Request RELIEF REQUEST 1001 (Revision 1) 4 All pumps and valves that are COMPO!1E11T I!1 FORMATIO 11 required to perform a specific function in shutting down the reactor or in mitigating the consequences of an accident and " ~ listed in Table I and Table II of the IST Program except safet< ass ~;ter valves and valveu not tested at three (3) month or sh rter "vt-t%, MMe Code Sectico X1, CODE REQUIREME11TS Suom.1ction iWP-3400 requires perfirming an inservice test on each p; imp nominally every three (3) months. Subsection IWV-3411 requires that valves be exercised and stroke timed at least once every three (3) months. Subsuction IWV-3521 requires that check valves be exercised at least once every three (3) months. The ASME Code Section XI, RELIEF REQUEST /JUSTIFICATIOli various subsections mentioned

above, specify the test frequency interval but do not specify any allowable extension.

Often there are operational constraints or other valid concerns that make it impractical to perform testing within the Code specified interval. It would be imp'actical and burdensome for CPS to strictly follow the Code c testing intervals without extensions to cover neconcary deviations. Clinton Power Station Technical Specification 4.0.2 specifies a maximum allowabic extension not to exceed 25% of the surveillance interval. CPS propocos to have a 25% extension which is reasonable for most Code specified testing and provides an acceptable level of quality = and safety. This is consistent with Technical Specification 4.0.S.c. Illinois Power company will ALTER 11 ATE TESTING PROPOSED uti1i2e CPS Technica1 Specification 4.0.2 allowable extension with the specified interval for all pumps and valves except se.foty and relief valves and valves not tected at three (3) month or shorter intervals.

._ m- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _. _.. ~ -. - _ _. _ _ _.... _ _ _. _ ILLINOIS POWER COMPANY Clinton Power Statlon ASME Section XI Relief Request RELIEF REQUEST 2012 (Revision 1) These Automatic Depressurization COMPONENT INFORMATION System valves (IB21-F041B/C/D/F, 1B21-F047A/C, 1821-F051G) depressurize the Reactor Pressure vessel to allow Low Pressure Core Spray and Low Pressure Coolant Injection Systems to inject water into the reactor. They are ASME Section III Code Class 1, Section XI Category B/C valves. They are a in. x 10 in, safety / relief valves. The ASME Code Section XI, CODE REQUIREMENTS Subsection IWV-3411 requires that these valves be exercised and stroke timed every three (3) ~~ months. Section XI, Subsection IWV-3417(a) requires trending the stroke time test results and taking appropriate corrective action. Illinois Power Company requests RELIEF REQUEST / JUSTIFICATION relief from the Code requirements for the following reasons: These valves cannot be exercised quarterly during power cperations because failure of a valve in the open position would place the plant in a LOCA condition. These valves should not he exercised during cold shutdowns in order to reduce the number of challenges to safety / relief valves as recommended by HUREG-0737 and a recent study on the subject (BWR Owner's Group Evaluation of NUREG-0737 Item II.K.3.16, Reduction of Challenges and Failures of Relief Valves). ' The reactor pressure is not utilized when testing these valves. A handswitch is utilized with a special tool which reduces the valve speed to avoid damaging the seating surfaces and the disk. Based upon CPS operating experience, Illinois Power Company will consider these valves as rapid acting valves. As these valves stroke rapidly, measurement of the stroke time of these valves to the nearest second por IWV-3413(b) means that a very small increase in stroke time could result in an extremely large percentage of change. The verification that these valveu meet a specified maximum stroke time of a relatively short duration provides adequate assurance of operability of these valves.

4 s Illinois Power company will ALTERNATE-TESTI!1G PROPOSED exerciso and stro):o timo those valves during refueling outages. Illinois Power Company will assign a maximum stroke timo of two (2) seconds for these valves. If this limiting stroko time is exceeded, the valvo will bo declared inoperable and correctivo action will be taken. This is in conformance with !JRC Generic Letter 89-04, Attachment 1 Position 6. l l l L 6 0 d -,m.-,-#mp,..p.,,.,_.A .,e -wm .v_,. ,4,..,v4- .w., ..r.,,........-+,,w y ...#._,..,w..,-, .-...,,,.,_..,,,y.,,-,.,,_....,_m,,,,.

ILLINDIS POWER COMPANY Clinton Power Station ASME Section XI Re1lof Request RELIEF REQUEST 2024 (Revision 1) Valves 3C11-126, 127 and 139 COMPONENT INF0101ATION-(typical of 145 each) are power operated valves which actuate (open) to scram the control rod drives. Valve IC11-114 (typical of 145 each) is the scrum dischargo check valve. Refer to the attached schematic drawing for the system. Valve 126 is a power operated, Category B, 1" diaphragm operated control valve. This valve opens to allow -flow to scram the control rod drive. Valve 127 is a power operated, Category B, 3/4" diaphragm operated control valve. This valve opens to allow flow to exhaust from the control rod drive to the scram discharge volume. Valve 139 is a power operated, Category B, pilot air valvo. This valve opens to relieve pressure to valves 126 and 127 which causes them to open. Valve 114 is a 3/4" check valve, Category C. This valve opens to allow flow to tht' scram discharge volume. ASME Section XI, Subarticles . CODE REQUIREMENTS IWV-3411 and IWV-3411 require power operated valves to be exercised and stroke time tested every 3 months. IWV-3521 requires check valves to be exercised on a 3 month frequency, as well. These valves are not ASME Class 1, 2, or 3, but are included in the CPS Inservice Testing Program since the system performs a safety function. This relief request does not require NRC approval. These valves operate f.5LIEP. REQUEST / JUSTIFICATION simultaneously when a scram signal is prosent. As these valves are ok id mounted with no prc, visions for testing, it is not practical to individually test each valve without extensive modifications, which would create a financial hardship to Illinois Power Company. The current testing, per Technical Specification 4.1.3.2, monitors individual rod scram time. This tecting does not measure stroke time for the power operated valves or provide specific exercising verification for either the power operated or check valves, liowever, it does assure that each valve functions properly to allow the rod to move to its safety position in the required time.

4 Testing of the control rod drivo AI/fERNATE TESTI!1G PROPOSED hydraulic control unita por Technical Specification 4.1.3.2 will be performed in lieu of the Codo requiremonta. The Technical Specifications require all rods to be tested following any coro alterations and any prolonged outages (120 days). Ton porcent of the rods are testod on a rotating basis every 120 days and any rod requiring maintenance is touted upon complation of the work. This is in accordance with 11RC Generic Letter 09-04,, Item 7. i

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l ILLIllOIS POWER CO:4PA11Y Clinton Power Station AS!4E Section XI Holief Request RELIEF REQUEST 2026 (Revision 1) Diesel generator (DG) air start . COMPollEliT t I!4FOR14ATIO!i-valves,1DG000A-K are 1.5" power

operated, Category D

valves + o required to open to allow air to flow to the air motors which start the emergency Diocol Gonorators to supply.back-up power for the plant. ASME Section XI, Subarticles 4 + IW-3 411 and IW-3 413 require -CODW REQUIREME!1TS-- d "/ power operated valves to be exercised and have their stroke time measured every three (3) months. These valves, however, are not ASME Class 1, 2, or 3, but are included in the CPS Inservice Testing Program since the system performs a safoty function. Therefore, this relief request does not requiro HRC approval. Those valvos are totally ~ ' RELT EP' REQUEST /JUSTIFICAT1011 = enclosed solenoid valvon with no positive means of datormining valvo position. It is not practical to record individual stroke timo for theaa valves without extensive modifications, which would create a financial hardship to Illinois Power Company. Technical Specif ication 4.8.1.1.2 requires each diesel generator to be Nsted at 1 cast overy 31 days. Those tests are designed to test the diesel generator as a' unit, but do not specifically verify actuation of each individual valvo. 11 0 stroke timo testing of those c ALTER 11 ATE 1TESTIliG PROPOSED air start valves will be ~ performed. The air gauge upstream of each valve will be monitored to verify that a pressure drop has occurred which indicates that the valves have opened. In addition, diosol generator start times are monitored closely. This test will be performed on a monthly frequency.

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ILL11101S POWER COMPA11Y Cljnton Power Station ASME Section XI Relief Request RELIEF REQUEST 2032 (Revinion 1) This Relief Roquest refers to COMPot1E!1T I!1 FORMAT 10!i Power (Air) Operated valves with a stroke time of 10 seconds or leno (see Table 2032-1). The ASME Code Section XI, CODE REQUIREMEt4TS Subarticle IWV-3417 (a) requirco j ncreasing the testing f requency to monthly - for a 50% -increase - ~~ from the previous stroke time tent. Per Generic Letter 89-04 those RELIEF REQUEST /JUSTIFICATIO!I-valves are detined no rapid acting (with a normal stroke time of less than 10 seconds), where a 2 second increase can cause the testing frequency for the valves to be increased Irom quarterly to monthly. CPS's operating experience has shown that when pinced on increased frequency for minor increason in otroke time (1 2 secondo), none of those valves were found to have a phyoical problem and all wel e subsequently returned to normal frequency. Illinois Power Company propocos ALTERNATE TESTING PROPOSED to evaluate the test results for the air-operated valves on Table 2032-1 in accordance with Generic Letter 89-04, Positions 5 and 6, and the Minutes of the Public Meetingo on Generic Letter 89-04, page 26, Response to Question 40. Specifically, CPS will establish a reference value for each valve in Table 2032-1 based upon each valvo's average stroke time when it la in good condition and operating properly. Should any valve's stroke time increase by more than 501, f rom the valvo's reference value, CPS will consider this to oc an indication of potential valve degradation and _ increase the valve's testing frequency. Should any valvo's otroke time increase beyond the valve's limiting stroke time value, the valve will be declared inoperable. As this position is in accordance with the pooitions stated in 11RC Generic Letter 89-04, no further NRC approval in required.

4 88 ILLINOIC POWER COMPANY CLINTON POWER UTATION 01'CTION XI RELIEF REQUEST Table 2032-1 (Rev. 1) Baseline Stroke Time (r.) for 1.ast 4 Years Valve No. Stroke Tine (sec ) MLuimum (sec.) Haximum (r,ce.) ORA 026 1.44 1 2 ORA 027 1.38 1 2 ORA 028 1.10 1 2 ORA 029 1.16 1 2 OVC010A 4.31 3 6 OVC010B 1.91 2 4 OVC022A 4.25 3 6 OVC022B 4.44 3 6 1833 P019 1.09 1 2 1B33 1V20 2,11 2 3 1C11 1910 3.80 3 6 1C11 0011 1.91 1 3 1E51-r004 2.02 1 3 1E51.P005 2.65 2 3 1E51-r025 2.12 2 5 IE51 0026 1.56 1 3 1rCO23 4.62 4 6 1RE019 3.74 4 6 1RE020 3.61 4 5 1RE021 4.68 5 6 1RE022 2.43 3 5 1Rr019 3.74 4 6 1Rr020 3.81 3 5 1Rr021 4,69 4 6 1Rr022 3.41 3 5 ISA030 4.93 5 6 ISA031 5.11 5 6 ISX010A 1.02 2 3 ISX010B 0.98 1 2 ISX010C 1.68 2, 4 ISX023A 3.59 3 5 ISX023B' 2.74 2 4 ISX027A 3.05 2 8 ISX027B

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5 ISX027C 2.55 2 4 ISX029A 3.16 2 4 ISX029B 4.04 3 6 ISX029C 1.80 2 3 ISX033 2.16 2 6 ISX037 1.23 1 4 ISX041A 2.12 1 3 ISXO41B 2.46 2 4 ISX181A 1.53 2 3 .1SX181B 1.86 2 3 ISX185A 3.27 2 5 ISX185B 1.41 2 2 ISX189 1,40 2 3 M1757/M89/3

ILLINOID POWER COMPANY CLINTON POWEll DTATION DECTION XI RELIUP REQUEDT Tablo 2032-1 (1 tov. 1) Baseline Stroke T1:se(s) for 1.ast 4 Years Valve No. S*.Jrte_ Time (sec.) Hintrowp (sec. ) Hnxituurn (sec.) ISX193A 2.15 2 3 ISX1938 1.52 2 3 ISX197 1.57 2 3 ISX209 2.05 1 3 } IVQOO2 2.51 1 3 IVQOO3 4.11 2 5 ( IVQOO4A 3.92 2 4 IVQOO4B 3.28 2 4 IVQ005 0.93 1 2 IVR001A 1.70 1 3 IVR001B 1.35 -2 4 IVR006A 3.23 2 4 IVR006B 3.01 2 4 IVA007A 2.68 2 4 IVR007B 3.77 2 4 IVX019 1.19 1 2 IVX020 1.34 1 2 4 M1757/H89/4 1 .......}}