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==References:==
==References:==
This section will identify references applicable to Technical Specifications and other necessary material as drawings.
This section will identify references applicable to Technical Specifications and other necessary material as drawings.
: 2) Purpose: This section will identify test objectives.
2)
 
==Purpose:==
This section will identify test objectives.
: 3)  Initial Conditions: Each procedure should identify those independent actions or procedures which shall be completed and station conditions which shall exist prior to use.
: 3)  Initial Conditions: Each procedure should identify those independent actions or procedures which shall be completed and station conditions which shall exist prior to use.
* 4)  Precautions: Precautions should be established to alert the individual performing the task to those situations in which important measures should be taken early or where extreme care should be used to protect equipment and personnel. Cautionary notes applicable to specific steps in the procedure should be included in the main body of the procedure as appropriate and should be identified as such.
* 4)  Precautions: Precautions should be established to alert the individual performing the task to those situations in which important measures should be taken early or where extreme care should be used to protect equipment and personnel. Cautionary notes applicable to specific steps in the procedure should be included in the main body of the procedure as appropriate and should be identified as such.

Revision as of 13:03, 30 November 2019

Forwards Rev 3 to, Surry Power Station,Unit 2 Inservice Testing Program Plan for Pumps & Valves,Second Insp Interval 821222-921222 & Rev 5 to Surry Power Station Unit 1, Inservice Testing Program Plan for Pumps & Valves....
ML18151A308
Person / Time
Site: Surry  Dominion icon.png
Issue date: 07/24/1992
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18151A309 List:
References
92-286, NUDOCS 9208040063
Download: ML18151A308 (212)
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Text

. :,,"'-- -

e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 24, 1992 United States Nuclear Regulatory Commission Serial No.92-286 Attention: Document Control Desk NO/ETS Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REVISIONS TO THE ASME SECTION XI INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES The ASME Section XI lnservice Testing (1ST) Program Plans for Pumps and Valves have been revised for Surry Power Station Units 1 and 2. Revision 5 for Unit 1 and Revision 3 for Unit 2 are included as Attachments 2 and 3 to this letter, respectively.

These program revisions are necessary due to plant configuration changes and scope changes which resulted from a detailed internal review of the programs. Program changes submitted to the NRC since the last program submittal have also been incorporated into these revisions.

Attachment 1 to this letter describes the changes between Revision 4 and Revision 5 of the program for Surry Power Station Unit 1. This description of the changes also applies to the like components in the Unit 2 program revision. Changes which only apply to the Unit 2 program are provided at the end of the summary for each section in Attachment 1. The program changes are highlighted by a bar in the right margin of Attachments 2 and 3. The six pump and five valve relief requests, which require NRC approval prior to use, are identified in Attachment 1. In order to facilitate implementation of the applicable items during the upcoming Unit 2 refueling outage, Virginia Electric and Power Company requests NRC review of these relief requests by November 1992.

Surry Power Station plans to* implement the new test requirements, described in Revisions 5 and 3 of the 1ST Program, in accordance with the following schedule.

Quarterly Testing for Units 1 and 2 This testing will be performed as soon as practicable for both Units 1 and 2. However, the testing will start no later than the first quarter following the next Unit 2 refueling outage, currently scheduled for February 1993.

,!."'.':':...C...'"'1 ..*LI'.\_,, _ __ _ __ _

I ** *. 9208040063 920724 . ~\

PDR ADOCK -05000280.. . 1.

G PDR

e Cold Shutdown Testing For Unit 1 This testing will be performed for Unit 1 during the first cold shutdown following the next Unit 2 refueling outage.

Cold Shutdown Testing For Unit 2 This testing will be performed during the next Unit 2 refueling outage.

Reactor Refueling Testing For Units 1 and 2 This testing will be performed during the next refueling outages for both Units 1 and 2, currently scheduled for February 1994 and February 1993, respectively.

If you have any questions, please contact us.

Very truly yours,

"~~l~

W. L. Stewart Senior Vice President - Nuclear Attachments:

i. Summary of Program Changes
2. Revision 5 to the Unit 1 1ST Program
3. Revision 3 to the Unit 2 1ST Program cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 INSERVICE TESTING PROGRAM PLAN FOR PUMPS AND VALVES SECOND INSPECTION INTERVAL DECEMBER 22-1982 - DECEM.BER 22-1992 REVISION 5

-NOTICE-THE ATIACHED FILES ARE OFFICIAL RECORDS . OF THE INFORMATION

.

&

REPORTS MANAGEMENT BRANCH.

THEY.HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERiOD AND MUST BE RETURNED TO THE RE-CORDS

, & ARCHIVES SERVICES SEC-TION P1-22 WHITE FLINT. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL.

OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE RE-FERRED TO FILE PERSONNEL.

_,_NOTICE-

  • VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 INSERVICE TESTING PROGRAM PLAN FOR PUMPS AND VALVES SECOND INSPECTION INTERVAL DECEMBER 22, 1982 - DECEMBER 22, 1992 REVISION 5 ADDRESSES:
  • VIRGINIA ELECTRIC AND POWER COMPANY P. 0. BOX 26666 RICHMOND, VIRGINIA 23261 SURRY POWER STATION P. 0. BOX 315 SURRY, VIRGINIA 23883
  • TABLE OF CONTENTS INSERVICE TESTING PROGRAM PLAN FOR PUMPS AND VALVES

1.0 INTRODUCTION

2.0 PROGRAM DESCRIPTION 3.0 PUMP INSERVICE TEST PROGRAM DESCRIPTION 3.1 Program Development Philosophy 3.2 Program Implementation 3.3 Program ~dministration 3.4 Pump Reference List 3.5 Pump Inservice Test Tables 3.6 Pump Test Program Relief Request 3.7 Alternative Testing for Non-Code Pumps 4.0 VALVE INSERVICE TEST PROGRAM DESCRIPTION 4.1 Program Development Philosophy

  • -

4.2 Program Implementation 4.3 Program Administration 4.4 Valve Inservice Test Table 4.5 Valve Test Program Relief Request 4.6 Valve Test Program Cold Shutdown Justification 4.7 Alternative Testing for Non-Code Valves 5.0 REPORTING OF INSERVICE TEST RESULTS 5.1 Pump Inservice Program 5.2 Valve Inservice Program 6.0 QUALITY ASSURANCE PROGRAM

  • SiPV-1R5 ii Rev. 5 March 19, 1992
  • INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

1.0 INTRODUCTION

This Pump and Valve Inservice Test (IST) Program Plan is applicable to the Surry Power Station Unit 1 which began commercial operation on December 22, 1972. This program plan is comprised-of two independent subprograms - the Pump Inservice Test Program and the Valve Inservice Test Program.

The development, implementation and administration of these two programs are detailed in subsequent sections.

Surry Power Station received a Safety Evaluation Report (SER) for the IST Program in August of 1990. Certain program anomalies were identified in_the SER. Surry Power Station submitted updates to Revision 4 of the IST Program

  • on November 28 and 30, 1990 in part to correct these anomalies. The updates are included in this program revision .
  • SlPV-lRS 1-1 Rev. 5 March 19, 1992
  • 2.0 PROGRAM DESCRIPTION This Inservice Testing Program for ISI Class 1, 2, 3 and NC pumps and valves meets the requirements of Subsections IWP and IWV of Section XI of the ASME Boiler and Pressure Vessel Code, 1980 Edition through the Winter 1980 Addendum. Where these requirements are determined to be impractical, specific requests for relief have been written and included in the program plan attached *
  • 3.0 PUMP INSERVICE TEST PROGRAM DESCRIPTION 3.1 PROGRAM DEVELOPMENT PHILOSOPHY Highly reliable safety-grade equipment is a vital consideration in the operation of a nuclear generating station. To help assure operability, the Surry Power Station Unit 1 Pump Inservice Test Program has been developed.

The Program is designed to detect and evaluate significant hydraulic or mechanical changes in the operating parameters of vital pumps.and to initiate corrective action when necessary. The Program is based on the requirements of the ASME Boiler and Pressure Vessel Code (B&PV),Section XI, Subsection !WP~ To the maximum extent pr~ctical, the Program complies with the specifications of ASME B&PV Code,Section XI, Subsection !WP, 1980 Edition with Addendum through Winter of 1980; 10CFR50.55a(g); and NRC Staff guidelines for complying with certain provisions of 10CFR50.55a(g) "Inservice Inspection Requirements."

The Nuclear Regulatory Commission and Code Committee recognized that design differences among plants may

  • render impractical certain Code requirements. Where such impracticalities exist, they have been substantiated as exceptions as allowed by the Code.

Alternate testing requirements have been proposed when warranted.

3.2 PROGRAM IMPLEMENTATION surveillance*testing is performed to detect equipment malfunction or degradation and to initiate corrective action. Since the safeguards pumps are normally in standby mode, periodic testtng of this equipment is especially important. The Surry Power station Unit 1 Inservice Test Program provides a schedule for testing safety-grade pumps and will be implemented as part of normal periodic surveillance testing.

Reference data will be gathered during initial surveillance tests. In most cases, test parameters will be measured with normal plant instrumentation.

This approach will simplify the test program and will promote timely completion of periodic surveillance testing. When permanently installed instrumentation is not available, portable instrumentation will be used to record the required parameters .

.March 19, 1992

  • During subsequent surveillance tests, flow rate will normally be selected as the independent test parameter and will be set up to match the reference flow rate.

Other hydraulic and mechanical performance parameters will be measured and evaluated against the appropriate reference values. The results of such evaluations will determine whether or not corrective action is warranted.

Each pump in the Pump Inservice Test Program will be tested according to a detailed test procedure. The procedure will include, as minimum:

1)

References:

This section will identify references applicable to Technical Specifications and other necessary material as drawings.

2)

Purpose:

This section will identify test objectives.

3) Initial Conditions: Each procedure should identify those independent actions or procedures which shall be completed and station conditions which shall exist prior to use.
  • 4) Precautions: Precautions should be established to alert the individual performing the task to those situations in which important measures should be taken early or where extreme care should be used to protect equipment and personnel. Cautionary notes applicable to specific steps in the procedure should be included in the main body of the procedure as appropriate and should be identified as such.
5) Instructions: The main body of a procedure should contain step by step instructions in the degree of detail necessary for performing a required test.
6) Acceptance Criteria: The ranges within which test data will be considered acceptable will be established and included in the test procedure. In the event that data fall outside the acceptable range, operator action will.be governed by approved station procedures~

Finally, it is recognized that the Pump Inservice Test Program sets forth minimum testing requirements.

Additional testing will be performed, as required, after pump maintenance or as determined necessary by

  • personnel at Surry Power Station .

3-2 S1PV-1R5 Rev. 5 March 19, 1992

'

I .

  • 3.3 PROGRAM ADMINISTRATION The operations and engineering staffs at Surry Power Station are responsible for administration and execution of the*Pump Inservice Test Program . . The Program was officially implemented on December 22, 1982 and will govern pump testing for a 120 month period.

Prior to the end of the 120 month period, the Program will be reviewed and upgraded to assure continued compliance with 10CFR50.55a(g) (4). The Program will be updated a minimum of at least once every 40 months for new systems, relief request, etc.

3.4 PUMP REFERENCE LIST This list gives a brief description of each pump identified in the Pump Inservice Test Program. The pump's ASME Code Classifications are* specified in "PUMP INSERVICE TEST TABLES".

1-CH;...P-lA 1-CH-P-lB 1-CH-P-lC High Head Safety Injection or Charging Pumps provide

  • high pressure flow for the Safety Injection System and during,normal operation, maintain pressurizer level and seal water injection to the Reactor Coolant Pumps.

drawing 11448-CBM-88B, Sheet 2.

1-SI-P-lA See 1-SI-P-lB Low Head Safety Injection Pumps provides low pressure safety injection to the core for long term cooling and as a backup to accumulators. See drawing 11448-CBM-89~, Sheet 1.

  • 1-CS-P-lA 1-CS-P-lB Containment Spray Pumps provide a cooled, chemically treated, borated spray to reduce containment pressure following a loss of coolant accident. See drawing 11448-CBM-84A, Sheet 2~
  • 1-RS-P-2A 1-RS-P-2B Outside Recirculation Spray Pumps aid the Containment Spray System in reducing containment pressure rapidly following a loss of coolant accident. See drawing 11448-CBM-8¢B, Sheet 2.

1-RS-P-lA 1-RS-P-lB Inside Recirculation* Spray Pumps aid the containment spray system in reducing containment pressure rapidly following a loss of coolant accident. See drawing 11448-CBM-84B, Sheet 1.

1-FW-P-3A 1-FW-P-3B 1-FW-P-2 Auxiliary Feedwater Pumps supply the steam generator with feedwater in the event of a complete loss of normal feedwater. See drawing 11448-CBM-GSA, Sheet 3.

  • 1-CC-P-lA 1-CC-P-lB Component Cooling Water Pumps are used to supply water to remove heat from the Residual Heat Removal System.

See drawing 11448-CBM-72D, Sheet 1.

l-CH-P-2A l-CH-P-2B Boric Acid Transfer Pumps supply boric acid to suction of charging pumps via normal coolant boron concentration and emergency makeup. See drawing 11448-CBM-BBA, Sheet 1 .

  • 1-CC-P-2A 1-CC-P-2B Charging Pump Cooling Water Pumps provide water to transfer.heat from the charging pump mechanical seals.

See drawing 11448-CBM~?lB, Sheet 2.

1-SW-P-lOA 1-SW-P-lOB Charging Pump Service Water Pumps provide cooling water for Charging Pump Cooling Water Systems. See drawing 11448-CBM-?lB, Sheet 1.

1-SW-P-lA 1-SW-P-lB 1-SW-P-lC Emergency Service Water Pumps supply the required service water to the canal to* provide for minimum safeguards operation in the unlikely event of a loss of site power coincident with a OBA. See drawing 11448-CBM-?lA, Sheet 1.

1-EE-P-lA

38A, Sheet 2.

See drawing 11448-CBB-

  • 1-vs-P-1A 1-VS-P-lB 1-VS-P-lC Main Control Room Air Conditioning System condenser side pumps provide service water to the main control room air conditioning system chillers. See drawing 11448-CBM-71D, Sheet 1.

1-VS-P-2A 1-VS-P-2B 1-VS-P-2C Main Control Room Air Conditioning System chiller side pumps circulated chilled water to the main control room and switch gear room air handling units. See drawing 11448-FB-41A, Sheet 2 *

  • 3.5 PUMP INSERVICE TEST TABLES This tabulation identifies the pumps to be tested, code classes, required test quantities and frequencies.

Relief from test requirements is requested in cases where test requirements have been determined to be impractical. Where relief is requested, technical justification is provided along with alternative test methods when applicable.

For non-Code pumps, a request for relief is not necessary when provisions of the Code cannot be met.

Section 3.7 contains a discussion of the testing requirements for non-Code pumps and descriptions of*

alternative testing in cases where the provisions of the Code cannot be met.

To aid the reader in interpreting the Pump Inservice Test Table, brief explanations of the table headings and abbreviations are provided below.

1) Pump Number - Each pump in the plant has a unique "tag" number which identifies the system to which the pump belongs.

Note: NC is for non-Code pumps. These pumps are important to safety but are not in systems that are classified ASME Class 1, 2 or 3.

3) System Resist - Either FIX for a test loop with a fixed system resistance or VAR for a test loop with a system resistance that can be varied.
4) The required Section XI test quantities of Inlet Pressure, Differential Pressure (Discharge Pressure is not a required test quantity but is listed for clarity), Flow Rate, Vibration, Bearing Temperature, Pump Speed and Lubrication Level/Pressure are given as column headings. The following abbreviations are used to describe the test status:

Q - the test will be performed on a quarterly basis CSD - the test will be performed every cold shutdown. A relief request explains the need for deviating from Section XI test frequency requirements

  • NA - the test is not applicable, see corresponding relief request RR - the test will be performed every reactor refueling. A relief request explains the need for deviating from Section XI test frequency requirements.

2Y - the test will be performed every 24 months Under pump speed, NA applies to constant speed pumps which do not require the measurement of speed. Therefore, no relief is necessary.

Under Lubrication Level/Pressure, NA applies to pumps that have a lubrication system with no level or pressure indication. No relief is necessary .

Pump Ident.

  • ASME System Class Resist Inlet Disch Press Press Diff Press
  • PUMP INSERVICE TEST TABLE Flow Bearing Pump Rate Vibration Temperature Speed Lubrication
  • Relief Level/Pressure Request 1-CH-P-lA 2 VAR Q Q Q Q Q NA NA Q 1 1-CH-P-lB 2 VAR Q Q Q Q Q NA NA Q 1 1-CH-P-lC 2 VAR Q Q Q Q Q NA NA Q 1 1-SI-P-lA 2 FIX Q Q Q Q Q NA NA NA 1 1-SI-P-lB 2 FIX Q Q Q Q Q NA NA NA 1 1-CS-P-lA 2 FIX Q Q Q Q Q NA NA Q 1 1-CS-P-lB 2 FIX Q Q Q Q Q NA NA Q 1 1-RS-P-2A 2 FIX 2Y 2Y 2Y 2Y 2Y NA NA NA 1.4 1-RS-P-2B 2 FIX 2Y 2Y 2Y 2Y 2Y NA NA NA 1.4 1-RS-P-lA 2 VAR RR RR RR RR RR NA NA NA 1.5 1-RS-P-lB 2 VAR RR RR RR RR RR NA NA NA 1. 5 1-FW-P-JA 3 VAR Q Q Q Q Q NA NA Q 1 1-FW-P-3B 3 VAR Q Q Q Q Q NA NA Q 1 1-FW-P-2 3 VAR Q Q Q Q Q NA Q Q 1 1-RH-P-lA 2 VAR CSD CSD CSD CSD CSD NA NA NA 1. 7 1-RH-P-lB 2 VAR CSD CSD CSD CSD CSD NA NA NA 1. 7 1-CC-P-lA 3 VAR Q Q Q Q Q NA NA Q 1.19 1-CC-P-lB 3 VAR Q Q Q Q Q NA NA Q 1.19 3-8 S1PV-2R5 Rev. 5 May 18, 1992

Pump

!dent.

  • ASME System Class Resist Inlet Disch Press Press Diff Press
  • PUMP IN SERVICE TEST TABLE Flow Bearing Pump Rate Vibration Temperature Speed Lubrication
  • Relief Level/Pressure Request 1-CH-P-2A 2 VAR Q Q Q Q Q NA NA NA 1.21 1-CH-P-2B 2 - VAR Q Q Q Q Q NA NA NA 1.21 1-CC-P-2A 3 VAR 0 Q 0 Q Q NA NA NA 1 l-CC-P-2B 3 VAR 0 0 Q Q Q NA NA NA 1 1-SW-P-10A 3 VAR 0 Q 0 Q 0 NA NA NA 1 l-SW-P-10B 3 VAR 0 Q 0 Q Q NA NA NA 1 1-SW-P-1A 3 . FIX Q 0 Q Q Q NA 0 0 1.11 1-SW-P-lB 3 FIX 0 0 0 0 0 NA Q 0 1.11 1-SW-P-1C 3 FIX Q Q Q Q Q NA Q 0 1.11 1-EE-P-lA NC FIX NA Q NA Q 0 NA NA NA 1.PNC-1 1-EE-P-lD NC FIX NA Q NA* Q Q NA NA NA 1.PNC-1 1-EE-P-lF NC FIX NA 0 NA Q Q NA NA NA 1.PNC-1 1-VS-P-lA 3 VAR NA 0 NA NA Q NA NA NA 1.16 1-VS-P-lB 3 VAR NA 0 NA NA 0 NA NA NA 1.16 1-VS-P-lC 3 VAR NA Q NA NA Q NA NA NA 1.16 Note: PNC-1 is not a request for relief but a description of alternative testing for non-Code pumps. Refer to Section 3.7.

3-9 S1PV-2R5 Rev. 5 May 18, 1992

Pump Ident.

  • ASME System Class Resist Inlet Disch Press Press Diff Press
  • PUMP INSERVICE TEST TABLE Flow Bearing Pump Rate Vibration Temperature Speed Lubrication
  • Relief Level/Pressure* Request 1-VS-P-2A 3 VAR 0 0 0 0 0 NA NA NA 1.17 1-VS-P-2B 3 VAR 0 0 0 0 0 NA NA NA 1,17 1-VS-P-2C 3 VAR 0 0 0 Q Q NA NA NA 1,17 3-10 S1PV-2R5 Rev. 5 March 19, 1992
  • 3.6 PUMP TEST PROGRAM RELIEF REQUEST Relief Requests identify code requirements which are impractical for Surry Unit 1 and provide justification for the requested exception.* Where appropriate, alternate testing to be performed in lieu of the code requirements is proposed *
  • RELIEF REQUEST P-0 Relief Request Withdrawn

~ump(s): IWP Program Pumps. See.PUMP INSERVICE TEST TABLE.

ClassSection XI Code Requirements For Which Relief Is Requested Measure pump bearing temperatures and vibration in mils.

Basis For Request Pump vibration and bearing temperature measurements are used to detect changes in the mechanical characteristics of a pump.

Regular testing should detect developing problems, thus repairs can be initiated prior to a pump becoming inoperable. The ASME Section XI minimum standards require measurements of the

  • vibration amplitude displacement in mils every three months and bearing temperatures once ~er year.

Our proposed program is based on vibration readings in velocity

  • units ra_ther than vibration amplitude in mils displacement. This technique is an industry accepted method which is more sensitive to small changes that are indicative of developing mechanical problems and hence m.ore meaningful. Velocity measurements detect not only high amplitude vibrations that indicate a major mechanical problem, but also the equally harmful low amplitude high frequency vibrations due to misalignment in balance, or bearing wear that usually go undetected by simple displacement measurements.

In addition, these readings go far beyond the capabilities of a bearing temperature monitoring program. A bearing will be seriously degraded prior to the detection of increased heat at the bearing housing. Quarterly vibration velocity readings should achieve a much higher probability of detecting developing problems than the once per year reading of bearing temperatures.

Bearing temperature tests present problems which include the following:

1. Certain systems have n6 recircul~tion test loops and a limited source of water. An enforced thirty minute run time would deplete the source .
  • SlPV-4R5 3-13 Rev. 5 Marc;:h _19, 1992
  • . 2.

RELIEF REQUEST P-1 (Cont.)

The lubrication fluid for some pumps is taken from the--

process water, which can change temperature depending on ambient conditions. *oata trending for these cases is not meaningful.

Therefore, the detection of possible bearing failure by a yearly temperature measurement is extremely unlikely. The small probability of detection of a bearing failure by temperature measurement does not justify the additional pump operating time required to obtain the measurements. In addition, it is impractical to measure bearing temperatures on many pumps.

Alternate Testing Proposed Pump vibration measurements will be taken in vibration velocity (in/sec). The evaluation of the readings will be per the attached table. The ranges of Test parameters given in the attached table were taken from ANSI/ASME OM (Part 6), An American National Standard In-Service Testing of Pumps .

  • RELIEF REQUEST P-1 (cont.)

RANGES OF TEST PARAMETERS (1)

  • PUMP PUMP TEST ACCEPTABLE ALERT REQUIRED TYPE SPEED PARAMETER RANGE RANGE ACTION.RANGE Centrifugal <600 rpm Va S2.5 Vr >2.5Vr to 6Vr >6 Vr And Vertical Line Shaft but not >10.5 mils but not >22 mils

~600 rpm Vv s2.5 Vr (2) >2.5 Vr to 6Vr >6 Vr but not >0.325 in/sec but not >0.70 in/sec Reciprocating Va or Vv S2.5 Vr >2.5 Vr to 6Vr >6 Vr Note: (1) Vr is the vibration reference value in the selected units Va is vibration displacement measured peak-to-peak, unfiltered Vv is vibration velocity measured peak, unfiltered (2) Small values for Vr will produce small acceptable ranges *for pump operation. Based on a small acceptable range, an adequately and smoothly running pump could be subject to corrective action. To avoid this situation, a minimum value for Vr of 0.05 in/sec has been established for velocity measurements. Pumps with a measured reference value below 0.05 in/sec shall have subsequent test results compared to an acceptable range based on 0.05 in/sec. Use of a minimum value for Vr is allowed for a three year period which ends in August, 1993. This interim period is discussed in the Surry Safety Evaluation Report received in August of 1990 (Serial No.90-546).

3-15 S1PV-3R5 Rev. 5 March 19, 1992

  • INTERIM RELIEF REQUEST P-2 Relief Request Withdrawn
  • RELIEF REQUEST P-3 Relief Request 'Withdrawn

-*

  • System:

Pump(s): l-RS-P-2A RELIEF REQUEST P-4 Recirculation Spray l-RS-P-2B Class 2 Section XI Code Requirements For Which Relief Is Requested

1. An. inservice test shall be run on each pump nominally every 3 months during normal plant operation.
2. Each pump shall be run at least five minutes under conditions as stable as the system permits prior to measuring the test quantities.
3. Measure inlet pressure and differential pressure.

Basis For Request

1. The outside recirculation pumps take suction from the
  • containment sump and discharge to the containment spray arrays. To test these deep draft pumps, the pump pit and the recirculation test loop must be filled with primary grade water and vented. The filling and venting process takes approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. After the test is completed, the pump pit and recirculation piping must be slowly drained to avoid flooding the basement.

Testing is the only source of operational based degradation 0 for the pumps. During normal operation, the outside recirculation spray system lacks fluid inventory except for some primary grade water trapped in the bottom of the pump pit. The portions of the pump exposed to this standing water are made of stainless steel and not subject to corrosion.

Considering the complexity of testing these pumps described above, the exposure to degradation caused by frequent testing and the lack fluid inventory during normal operation, there is no compensating increase in safety achieved by testing these pumps every three months.

This position is supported by ANSI/ASME OM {Part 6), An American Standard In-Service Testing of Pumps, Paragraph 5.5, which states, "Pumps lacking required fluid inventory, (e.g.,

pumps in dry sumps) need not be tested in accordance with this Part every 3 months. These pumps shall be tested at least

  • once every 2 years except as provided in para. 5.4. The required fluid inventory shall be provided during this test."

3-18 S1PV-4R5 Rev. 5 March 19, 1992

  • RELIEF REQUEST P-4 (Cont.)

Paragraph 5.4 discribes the testing frequency of pumps in systems which are declared inoperable or not required for service.

2. The test loop for these pumps contains a small volume of water. A four inch test recirculation line branches off the ten inch pump discharge line a short distance from the pump.

The recirculation line discharges into the pump pit which is a cylinder approximately 50 feet deep and two feet in diameter.

Because of the small volume in the test loop, the hydraulic parameters stabilize quickly. Therefore, a five minute stabilization period is not necessary to achieve repeatable test results.

In addition, if the pump is run for too long of a period,- the water will heatup due to the limited water volume. This heatup can lead to excessive pressures in the test loop.

3. Inlet pressure instrumentation is not installed. However, the outside recirculation spray pumps obtain flow through a suction bell immersed in the pump casing. During testing, a casing level is established by filling the casing with PG
  • water to provide NPSH to the pump. Flow is recirculated through the pump, recirculation line, and back to the casing.

By establishing a casing level and maintaining it constant for the tests, any variation in pump differential pressure would be directly indicated by monitoring pump discharge pressure.

The static inlet pressure will be calculated and subtracted from the discharge pressure to yield a differential pressure.

Alternate Testing Proposed These pumps will be flow tested on their recirculation paths at least once every two years. Maintaining a constant pump casing water level from test to test by filling the casing with PG water will yield the same suction pressure for each test. The static inlet pressure will be calculated and subtracted from the discharge pressure to yield a differential pressure. After a two minute stabilization period, static inlet pressure, differential pressure as determined from the calculated static inlet pressure and measured discharge pressure, flow rate and vibration measurements will be taken .

  • $ystem:

Pump (s) : 1-RS-P-1A RELIEF REQUEST P-5 Recirculation Spray 1-RS-P-1B Class  : 2 Section XI Code Requirements For Which Relief Is Requested Measure test quantities every quarter.

Measure inlet pressure and differential pressure.

Basis For Request These pumps are located inside containment, therefore, flow testing cannot be performed during plant operation*.

Flow testing of these pumps requires the installation of a temporary recirculation line and the erection of a temporary dike to contain the recirculated water. Approximately five to six

  • days are needed to set up, perform the test, and return the system to its normal configuration. Testing on a cold shutdown frequency would not allow enough time to plan for and perform a five to six day flow test.

Because these pumps are designed to take suction from a sump, measurement of inlet pressure is not practical. Also, the sump level cannot vary more than one foot during testing because of the limitations in the test dike design and the requirements for NPSH. Therefore, inlet pressure will be calculated from sump level.

Alternate Testing Proposed These pumps will be bump tested to verify operability every quarter. Each pump is equipped with a sensor to detect pump rotation which alarms in the control room. This alarm will be observed during each pump test. A flow test which includes vibration measurement will be performed every reactor refueling.

Differential pressure will be determined from the measured discharged pressure and the calculated inlet pressure .

  • RELIEF REQUEST P-6 Relief Request Withdrawn
  • System:

Pump(s): 1-RH-P-lA RELIEF REQUEST P-7 Residual Heat Removal 1-RH-P-lB Class 2 Section XI Code Requirements For Which Relief Is Requested Frequency of Pump Test.

Measure inlet pressure.

Basis For Request The low pressure RHR pumps take suction from and discharge to the reactor coolant system which operates at 2235 psig. This is well above the-operating pressure for the RHR pumps. Therefore, testing during normal operation is not possible.

The use of permanent inlet and discharge pressure instrumentation

  • for determining differential pressure is not feasible because the inlet pressure can vary between 20 and 200 psig depending upon*

plant conditions. Therefore, ranges for the inlet and discharge pressure gauges must vary from test to test. The current method is to install temporary inlet and discharge gauges. Properly matching the ranges of the temporary instrumentation to existing plant conditions has proved to be difficult.

To eliminate this difficulty, differential pressure gauges have been installed. With the installation of the differential pressure gauges, the measurement of inlet pressure is no longer necessary to trend pump performance. The new ASME Code for pump testing, Section IST, Subsection ISTB, Inservice Testing of Pumps in Light-Water Reactor Power Plants, does not require the measurement of inlet pressure if differential pressure gauges are used .

  • SlPV-4R5 3-22 Rev. 5 May 18, 1992
  • RELIEF REQUEST P-7 (Cont.)

Also, the installation of the temporary gauges results in a high dose (approximately 70 to 100 mrem per gauge). Because measurement of inlet pressure presents a hardship in terms of dose and does not add meaningful information for trending pump performance if differential pressure is measured directly, inlet pressure will not be measured.

  • Alternate Testing Proposed Pumps will be tested each cold shutdown (but not more frequently than every three months). Differential pressure will be measured directly with a differential pressure gauge. Inlet pressure will no longer be measured *
  • RELIEF REQUEST P-8.

Relief Request Withdrawn

  • 0
  • INTERIM RELIEF REQUEST P-9 Relief Request Withdrawn
  • RELIEF REQUEST P-10 Relief Request Withdrawn
  • System:

Pump(s):

Service Water 1-sw-P-lA RELIEF REQUEST P-11 1-SW-P-lB 1-SW-P-lC.

Class 3 Section XI Code Requirements For Which Relief Is Requested Measure inlet pressure and differential pressure.

ASME Section XI, Subarticle IWP-3110 requires reference values to be one or more fixed set of measured values. All subsequent test results shall be compared to these reference values.

Basis For Request No installed inlet pressure instrumentation exists. Inlet pressure will be calculated from the tide level and subtracted from the discharge pressure to yield differential pressure *

  • The emergency service water pumps take suction from the James river and discharge into the intake cannel. The James river near the plant is subject to a tide level variation of approximately five feet. Therefore, the total static head for the system can vary from test to test. There are no valves in the lines to throttle flow and to compensate for the change in system static head. The only way to duplicate flow and differential pressure from test to test is to perform the test at the same tide level each time. Trying to perform this test within a small enough tide level range to produce repeatable results has proven impractical. To compensate for the change in total system head, a pump reference curve will be prepared based on test results taken at different tide levels. Tests will be conducted within the tide level limits of the curve, and results will be compared to acceptance criteria based on the reference curve and the ranges given in Table IWP-3100-2.

Alternate Testing Proposed Inlet pressure will be calculated from the tide level and subtracted from the discharge pressure to yield differential pressure. Tests will be conducted within the tide level limits of the pump reference curve, and results will be compared to acceptance criteria based on the reference curve and the ranges

  • given in Table IWP-3100-2 .

3-27 S1PV-4R5 Rev. 5 March 19, 1992

  • RELIEF REQUEST P-12 Relief Request Withdrawn RELIEF REQUEST P-13 Relief Request Withdrawn RELIEF REQUEST P-14 Relief Request Withdrawn RELIEF REQUEST P-15
  • Relief Request Withdrawn
  • '

system:

Pwnp(s):

INTERIM RELIEF REQUEST P-16 Main Control Room Air Conditioning 1-VS-P-lA 1-VS-P-lB 1-VS-P-lC Class 3 Section XI Code Requirements For Which Interim Relief Is Requested Measure flow, inlet pressure and differential pressure.

Basis For Interim Request No flow or inlet pressure instrwnentation is installed.

According to Technical Specification paragraph 3.23.C.1.b, "If .

one chiller becomes inoperable, return the inoperable chiller to operable status within seven (7) days or bring both units to Hot Shutdown within the next six {6) hours and be in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." Because the main control and emergency switchgear room emergency ventilation system is common

  • for both units, the above action statement applies whenever Unit 1 or Unit 2 is operating.

Given the scope of the required instrumentation modifications and the existing system configuration, it is estimated that installation of the appropriate flow and pressure instrumentation cannot be completed within the Technical Specification 7 day action statement. Two additional Main Control Room and Emergency Switchgear Room Air Conditioning System chillers are scheduled for installation by the end of 1992. The additional chillers will eliminate the need for entry into the Technical Specification action statement to install the instrumentation.

Also, the flow elements for the chiller service water pumps cannot be installed at power. Therefore, installation of the additional instrumentation is scheduled to be completed by the end of the Unit 1 Cycle 12 refueling outage currently- scheduled for second quarter of 1994.

Interim Alternate Testing Proposed The control room chillers are monitored at least once every quarter for adequate performance. Part of this surveillance verifies that minimum service water flow requirements are being met by the pumps. A flow rate of 240 gpm is*the minimum required service water flow for condenser operability. The minimum flow

  • is verified by measuring the differential pressure across the chiller condensers. The normal operating range is 4 to 7 psid 3-29 SlPV-4R5 Rev. 5 March 19, 1992
  • INTERIM RELIEF REQUEST P-16 (Cont.)

across the chiller condensers. An alert value has been established at 10% above the minimum flow or 264 gpm. This flow equates to a differential pressure of 4 psid. If a differential pressure of at least 3.5 psid (240 gpm) cannot be achieved after any adjustments (i.e., adjusting the backwash valve*and cleaning the service water pump Y-strainer) then the pump is declared inoperable.

When differential pressure exceeds 7 psid, the condenser tubes require cl~aning. Also, if a pump discharge pressure of 30 psig cannot be achieved with a fully shut backwash isolation valve, then an investigation is initiated to check for possible upstream restriction or a degraded pump. Vibration monitoring has been added to the surveillance and will be performed at least once every quarter. The acceptance criteria for vibration are based upon the Section XI program.

The correlation between condenser differential pressure and flow was established during special tests that were conducted in June of 1989. The special tests consisted of fabricating a temporary instrumented loop of pipe with a straight run long enough to produce stable flow. The permanent piping has no straight runs

  • that are long* enough to measure flow. A section of permanent pipe was removed and the temporary section installed. The results of the tests are given in Figure 1 and Table 1.

Inlet pressure and flow instrumentation installation will be completed by the end of the Surry Unit 1 Cycle 12 refueling outage, currently scheduled for the second quarter of 1994. As the instrumentation is installed, inlet pressure, differential pressure, flow and vibration will be measured at least once every

~hree months in accordance with ASME Section XI requirements .

...to Cll

  • * *

R TYPE SIZE , CLASS CAT POS TYPE TYPE v- csv- VNC-1-SS-TV-103B 11448-CBM*082B 2 OF 2 F-6 SO GATE 0.375 2 AE C CIV LT VP RHR SAMPLE HEADER, OUTSIDE CONTAINMENT ISOLA-TION VALVE 1-SS*TV-104A 11448-CBM-082B 2 OF 2 D-7 SO GATE 0.375 2 A C CIV EV FS LT ST 34 VP PRESSURIZER RELIEF TANK GAS SPACE.SAMPLE LINE, INSIDE CONTAINMENT ISOLATION VALVE

. '

A. C 1-SS*TV-104B 11448-CBM-082B 2 OF 2 C-6 SO GATE 0.375 2 CIV EV FS LT ST 34 VP PRESSURIZER RELIEF TANK GAS SPACE SAMPLE LINE, OUTSIDE CONTAINMENT ISOLATION VALVE 1*SS*TV-106A 11448-CBM-082B 2 OF*2 E-7 SO GATE 0.375 A C CIV EV FS

-- ----------------------- .------------------------------------------------------------------------------------------------

1-SS-TV-106B 11448-CBM-082B 2 OF 2 E-6 SO GATE 0.375 A C CIV EV FS LT ST 34

. VP 1 REACTOR COOLANT HOT LEGS SAMPLE HEADER, OUT-SIDE CONTAINMENT ISOLATION VALVE

  • VIRGINIA POWER COMPANY PAGE: 56 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM* VALVE TABLE NC ISO REL COLD ALT VALVE DRAIJING SHEET DRIJG VALVE VALVE ASME TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT PCS TYPE TYPE V* csv- VNC-1-SV*TV-102A 11448*CBM-066A 2 Of 3 E-4 AO GATE 6.00 2 A C CIV EV FS LT ST VP CONDENSER AIR REMOVAL DISCHARGE TO CONTAIN-MENT, OUTSIDE CONTAINMENT ISOLATION VALVE
  • VIRGINIA POWER COMPANY PAGE: 57 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM* VALVE TABLE NC ISO REL COLD ALT VALVE DRAWING SHEET DRWG VALVE VALVE . ASME TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE v- csv- VNC-1-SW-108 11448-CBM*071B 1 OF 2 B-4 CHECK VALVE 2.00 3 C oc CV

CHARGING PUMP SERVICE WATER PUMP CHECK VALVE 1-SW-113 11448-CBM-071B 1 OF 2 B-7 CHECK VALVE 2.00 3* C QC CV CHARGING PUMP. SERVICE WATER PUMP CHECK VALVE 1-SW-130 11448-CBM-071B 1 OF 2 D-7 CHECK VALVE 2.00 3 C 0 CV CIRCULATING WATER TO DISCHARGE TUNNEL CHECK VALVE

1-SW-206 11448-CBM-071A 3 OF 3 E-8 MAN GATE 2.00 2 AE C CIV LT

*--~--------

CONTAINMENT ~SOLATION VALVE .FOR SERVICE WATER DRAINS TO HEAT EXCHANGER

*--------------------------------------------------------------

1-SW-208 11448-CBM-071A 3 OF 3 E-8 MAN GATE 2.00 . 2 AE C CIV LT CONTAINMENT ISOLATION VALVE FOR SERVICE WATER DRAINS TO HEAT EXCHANGER 1-SW-246 11448-CBM-071A 3 OF 4 C-8 CHECK VALVE 3.00 NC C 0 CV

  • 1-SW-247

. RECIRCULATION SPRAY HEAT EXCHANGER SERVICE

~ATER RETURN VENT VALVE 11448-CBM-071A 3 OF 4 D-7 CHECK VALVE RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER SUPPLY VENT VALVE 3.00 3 C 0 CV 1-S'w-248 1144a-CBM-071A 3 OF 4 C-7 CHECK VALVE 3.00 NC C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER RETURN VENT VALVE

,*-sw-249 11448-CBM-071A 3 OF 4 D-6 CHECK VALVE 3.00 3 C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER.SUPPLY VENT VALVE 1-SW-250 11448*CBM-071A 3 OF 4 C-6 CHECK VALVE 3.00 NC C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER RETURN VENT VALVE

. ---------------------------------------

1-SW-251 11448-CBM-071A 3 OF 4 D-5 CHECK VALVE 3.00 3 C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER SUPPLY VENT VALVE 1-SW-252 11448-CBM-071A 3 OF 4 C-5 CHECK VALVE 3.00 NC C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER RETURN VENT VALVE

***--------------------***-------------------***------------------------------ *------

  • VIRGINIA POWER COMPANY PAGE: 58 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL COLD ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE V- CSV- VNC-1-SW-253 11448-CBM-071A 3 OF 4 D-4 CHECK VALVE 3_00 3 C 0 CV RECIRCULATION SPRAY HEAT EXCHANGER SERVICE WATER SUPPLY VENT VALVE 1-SW-262 11448-CBM-071B
  • 1 OF 2 B-4 CHECK VALVE 2.00 3 C 0 CV CHARGING PUMP SERVICE WATER PUMP DISCHARGE CHECK VALVE 1-SW-263 11448-CBM-071D 1 OF 1 C-7 AO GATE 6.0 3 E 0 VP CONTROL ROOM CONDENSER WATER SELF CLEANING STRAINER ISOLATION VALVE 1-sw-264 11448-CBM-071D 1 OF 1 C-5 MANUAL BFLY 6.0 3 B 0 EV CONTROL ROOM CONDENSER WATER TO BACKUP*

STRAINER BYPASS LINE ISOLATION VALVE 1-SW-265 11448-CBM-071D 1 OF 1 C-7 MANUAL BFLY 6.0 3 B 0 EV CONTROL* ROOM CONDENSER WATER TO BACKUP STRAINER BYPASS LIME ISOLATION VALVE

*----------------------------------

1-SW*268 11448-CBM*071B 1 OF 2 B-6 CHECK VALVE 2.00 3 C 0 CV

  • 1-SW*313 CHARGING PUMP SERVICE WATER PUMP DISCHARGE CHECK VALVE 11448*CBM-071D 1 OF 1 F-7 CHECK VALVE CONTROL ROOM CONDENSER WATER SYSTEM PUMP DISCHARGE CHECK VALVE 3.0 3 C 0 CV 46 1-SW-323 1144a-CBM*071D 1 OF 1 F-5 CHECK VALVE 3.0 3 C 0 CV 46 CONTROL ROOM CONDENSER WATER SYSTEM PUMP DISCHARGE CHECK VALVE 1-SW-MOV-101A 11448-CBM-071A 3 OF 3 B-4 MO BFLY 36.00 3 B C .EV ST VP BEARING COOLING WATER HEAT EXCHANGER ISOLATION VALVE 1-SW-MOV-101B 11448-CBM-071A 3 OF 3 B-4 MO BFLY 36.00 3 B C EV ST VP BEARING COOLING WATER HEAT EXCHANGER ISOLATION VALVE

*---------------------------------------------------

1-SIJ*MOV*102A 11448-CBM-071A 2 OF 3 D-6 MO BFLY 42.00 3 B oc EV ST VP SERVICE WATER HEADER SUPPLY ISOLATION TO COMPONENT COOLING HEAT EXCHANGERS

  • VIRGINIA POWER COMPANY PAGE: 59 OF 65 SURRY UNIT 1 , REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL COLD ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASHE TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT PCS TYPE TYPE v- csv- VNC-1-SW-MOV-102B 11448-CBM-071A 2 OF 3 D-5 MO BFLY 42.00 3 B OC EV ST VP SERVICE WATER HEADER SUPPLY ISOLATION TO COMPONENT COOLING HEAT EXCHANGERS

-------------------------------------------------------------------------------------------------

1-SW-MOV-103A 11448-CBM-071A 3 OF 3 B-8 MO BFLY 30.00 3 B 0 EV ST VP SERVICE WATER HEADER SUPPLY ISOLATION TO RECIRC SPRAY HEAT EXCHANGERS 1-SW-MOV-103B 11448-CBM-071A 3 OF 3 B-8 MO. BFLY 30.00 ' 3 B 0 EV ST VP SERVICE WATER HEADER SUPPLY ISOLATION TO RECIRC $PRAY HEAT EXCHANGERS 1-Si.i-MOV-103C r 11448-CBM-071A 3 OF 3 B-3 MO BFLY 30.00 3 B 0 EV ST VP SERVICE WATER HEADER SUPPLY _ISOLATION TO

  • RECIRC SPRAY HEAT EXCHANGERS 1-SW-MOV-103D 11448-CBM-071A 3 OF 3 B-2 MO BFLY 30.00 3 B 0 EV ST VP SERVICE WATER HEADER SUPPLY ISOLATION TO RECIRC SPRAY HEAT EXCHANGERS

*---

1-SW-MOV-104A 11448-CBM-071A 3 OF 3 D-7 MO BFLY 24.00 3 B OC EV ST VP SERVICE WATER SUPPLY TO "A" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE

~:;~:~~~:~~4;----;;44~:~;~:~~;~---;-~;-;--~:~---;~-;;~;----------i4:~~---;------;----~~-----------;~---------------------- -I ST VP SERVICE WATER SUPPLY TO "B" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE

1-SW-MOV-104C 11448-CBM-071A 3 OF 3 D-5 MO BFLY 24.00 3 B oc EV ST I

VP SERVICE WATER SUPPLY TO "C" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE

  • VIRGINIA POIJER COMPANY PAGE: 60 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE T~BLE NC ISO REL C!)LD ALT VALVE DRAYING SHEET DRYG VALVE VALVE ASME TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE v- csv- VNC*

1-SY*MOV-104D 11448-CBM-071A 3,0F 3 D-4 MO BFLY 24.00 3 B oc EV ST VP SERVICE YATER SUPPLY TO 11 D11 RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE 1*SY-MOV-105A 11448-CBM-071A 3 OF 3 D-8 MO BFLY 24.00 3 B oc EV ST VP SERVICE YATER RETURN FROM "A" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE 1*SY-MOV-105B 11448-CBM-071A 3 OF 3 D-7 MO BFLY 24.00 3 B oc. EV ST VP SERVICE YATER RETURN FROM 11 B" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE 1*SY*MOV* 105C 11448-CBM-071A 3 OF 3 D-6 MO BFLY 24.QO 3 B o.c EV ST VP.

SERV.1 CE YATER RETURN FROM "C" REC I RC SPRAY

  • HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE 1-SY*MOV-105D 11448-CBM-071A 3 OF 3 D-5 MO BFLY 24.00 3 B oc EV ST VP SERVICE YATER RETURN FROM "D" RECIRC SPRAY HEAT EXCHANGER, OUTSIDE CONT ISOLATION VALVE 1-SY*PCV*100A 11448*CBM-071D 1 OF 1 F-7 AO GATE 3.0 3 B 0 EV FS ST 47 CONTROL ROOM CONDENSER YATER SYSTEM PRESSURE CONTROL VALVE 1-SY*PCV-1008 11448-CBM-071D 1 OF 1 F-5 AO GATE 3.0 3 B 0 EV FS ST 47 CONTROL ROOM CONDENSER YATER SYSTEM PRESSURE CONTROL VALVE
  • ---------------------------------------------*-----------------------------------------------------------------------------

1-SY*PCV-100C 11448-CBM-071D 1 OF 1 F-3 AO GATE 3.0 3 B 0 EV FS ST 47 CONTROL ROOM COIJDENSER YATER SYSTEM PRESSURE CONTROL VALVE

*---------------* --------------

  • VIRGINIA POWER COMPANY PAGE: 61 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL COLD ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME TEST VALVE TEST REQ SHUT TEST NUMBER NUMBER
  • NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE v- csv- VNC-1-SW-PCV-101A 11448*CBM-071D 1 OF 1 E-8 AO GATE 3.0 3 B C EV FS ST 47 CONTROL ROOM CONDENSER WATER SYSTEM PRESSURE CONTROL VALVE

*-------------------------------------------------------

1-SW-PCV-101B 11448*CBM-071D 1 OF 1 E-6 AO GATE 3 B C EV FS ST 47 CONTROL ROOM CONDENSER-WATER SYSTEM PRESSURE CONTROL* VALVE 1-SW*PCV-101C 11448*CBM-071D 1 OF 1 E-4 AO GATE 3.0 3 B C EV FS ST 47

* ---------------

CONTROL ROOM CONDENSER WATER SYSTEM PRESSURE CONTROL VALVE

*-------

1-SW-TCV*108A 11448-CBM-071B 1 OF 2 E-7 AO GATE 1.5 3 B 0 EV FS ST 47 SERVICE WATER TO CHARGING PUMP LUBE Oil

  • COOLER TEMPERATURE CONTROL VALVE

-------------------------------

1-SW*TCV-108B 11448*CBM-071B 1 OF 2 E-5 AO GATE 1.5 3 B 0 EV FS ST 47 SERVICE WATER TO CHARGING PUMP LUBE OIL COOLER TEMPERATURE CONTROL VALVE 1*SW*TCV*108C 1144"8-CBM-071B 1 OF 2 E-4 AO GATE . 1.5 3 B 0 EV FS ST 47

* ---------------------------

SERVICE WATER TO CHARGING PUMP LUBE OIL COOLER TEMPERATURE CONTROL VALVE 2-SW-333 11448-CBM*071D 1 OF 1 F-3. CHECK VALVE 3.0 3 C 0 CV - 46 CONTROL ROOM CONDENSER WATER SYSTEM PUMP DISCHARGE CHECK VALVE

  • VIRGINIA PO\IER COMPANY PAGE: 62 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL COLD ALT VALVE DRAWING SHEET DR\JG VALVE VALVE ASHE TEST VALVE TEST REC SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE V- CSV- VNC-1-VA-001 11448-CBH-083A 1 OF 3 B-7 MAN GATE 2.00 2 AE C CIV LT VENT LINE FROM PRIMARY VENT POT, OUTSIDE CONTAINMENT ISOLATION VALVE 1-VA-006 11448-CBM-083B 3 OF 3 F-2 MAN GATE 2.00 2 AE C CIV LT VENT LINE FROM PRIMARY VENT POT, INSIDE CONTAINMENT ISOLATION VALVE

*------------------------------------------------------------------------------------------------------------------

  • VIRGINIA POWER COMPANY PAGE: 63 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL COLD ALT VALVE DRAI.IING Sl!EET DRI.IG VALVE VALVE . ASME TEST VALVE TEST REC SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE v- csv- VNC-1*VG-TV-109A 11448-CBM-083B 1 OF 3 F-7 AO GATE 2.00 2 A C CIV EV FS LT ST 34 VP VENT LINE !SOL FROM PRIMARY DRAINS TRANSFER TANK TO GAS STRIPPERS, INSIDE CONT !SOL VLV 1-VG*TV-1098 11448-CBM-083A 1 OF 3 F-7 AO GATE 2.00 2 A C CIV EV FS LT ST 34 VP VENT LINE !SOL FROM PRIMARY DRAINS TRANSFER TANK TO GAS STRIPPERS, OUTSIDE CONT !SOL VLV
  • VIRGINIA POIJER COMPANY PAGE: 64 OF 65 SURRY UNIT 1 REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM *- VALVE TABLE NC ISO REL COLO ALT VALVE DRAWING SHEET ORIJG VALVE VALVE ASHE TEST VALVE TEST REC SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT PCS TYPE TYPE V- CSV- VNC-1-VP-012 11448-CBM-066A 2 OF 3 F-4 CHECK VALVE 6.00 2 AC C CIV CV 44 LT CONDENSER AIR REMOVAL OISCHARG TO CONTAINMENT INSIDE CONTAIN ISOLATION CHECK VALVE

~------------------------------------------------------------------------------------------

  • VIRGINIA POWER COMPANY PAGE: 65 OF 65 SURRY UN IT 1
  • REVISION: 05
  • SECOND INSPECTION INTERVAL DATE: 3/19/92 INSERVICE TESTING PROGRAM* VALVE TABLE NC ISO REL COLD ALT VALVE ORAi.JING SHEET ORI.JG VALVE . VALVE ASHE TEST VALVE TEST REC SHUT TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT POS TYPE TYPE v- csv- VNC-1-VS-285 11448-FB -041A 2 OF 2 C-6 MANUAL GATE 3.0 3 B oc EV CONTROL ROOM CHILLED IJATER CROSS TIE ISOLATION VALVE 1-VS-286 11448-FB *D41A 2 OF 2 C-5 MANUAL GATE 3.0 3 B oc EV CONTROL ROOM CHILLED IJATER CROSS TIE ISOLATION VALVE 1-VS-288 11448-FB -041A 2 OF 2 B-7 CHECK VALVE 2.0 3 C oc CV CONTROL ROOM CHILLED IJATER PUMP DISCHARGE CHECK VALVE 1-VS-292 11448-FB -041A 2 OF 2 B-5 CHECK VALVE 2.0 3 C oc CV CONTROL ROOM CHILLED IJATER PUMP DISCHARGE CHECK VALVE . .

*--------------------------------------------------

1-VS-296

  • 11448-FB -041A 2 OF 2 B-4 CHECK VALVE 2.0 3 C oc CV CONTROL ROOM CHILLED IJATER PUMP DISCHARGE CHECK VALVE 1*VS*MOV-100A 11448-CBB-006A 1 OF 2 C-4 MO BFLY 36.00 2 AE C CIV LT 39
  • VP CONTAINMENT PURGE SUPPLY, INSIDE CONTAINMENT ISOLATION VALVE 1-VS*MOV-100B 11448-CBB-006A 1 OF 2 C-3 MO BFLY 36.00 2 AE C CIV LT 39 VP CONTAINMENT PURGE SUPPLY, OUTSIDE CONTAINMENT ISO[ATION VALVE .

1-VS*MOV-100C 11448-CBB-006A 1 OF 2 D-4 MO SFLY 36.00 2 AE C CIV LT 39 VP CONTAINMENT PURGE EXHAUST, INSIDE CONTAINMENT ISOLATION VALVE 1-VS*MOV-100D 11448-CBB-006A 1 OF 2 D-3 MO BFLY 36.00 2 AE C CIV LT 39 VP CONTAINMENT PURGE EXHAUST, OUTSIDE CONTAIN-MENT ISOLATION VALVE . .

*-------------------------------------------------------------------------------------------------------------

1-VS*MOV-101 11448-CBB-006A 1 OF 2 D-3. MO BFLY 8.00 2 AE C CIV LT 39 VP CONTAINMENT PURGE BYPASS, OUTSIDE CONTAINMENT ISOLATION VALVE

*--------------------------~----------

1-VS*MOV-102 11448-CBB*006A 1 OF 2, C-3 MO BFLY

.-------------------------------------------------------------------------

18.00 2 AE C CIV LT 39 VP CONTAINMENT VACUUM BREAKER

  • 4.5 VALVE TEST PROGRAM RELIEF REQUEST Relief Requests identify code requirements which are impractical for Surry Unit 1 and provide justification for the requested exception. Where appropriate, alternate testing to be performed in lieu of code requirements is proposed .
  • System Valve(s):

Various RELIEF REQUEST V-1 All safety and relief valves Category:

Class Function:

Section XI Code Requirement For Which Relief Is Requested Safety and relief valve setpoints are tested in accordance with PTC-25.3-1976 as directed by IWV-3512.

Basis For Request The American National Standard, ANSI/ASME OM 1981, Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices, is approved for use in the 1986 Edition of ASME Section XI, Subsection IWV. OM-1 represents

  • current industry practices for testing relief valves and is a better standard for setpoint testing than PTC-25.3-1976.

Alternate Testing Proposed Safety and relief valves will be tested .in accordance with ANSI/ASME_OM 1981 .

  • System Valve(s):

Feedwater 1-FW-10 1-FW-41 RELIEF REQUEST V-5 1-FW-72 Category: C Class 2 Function: Main Feedwater check valves at Containment Penetrations.

Sectio~ XI Code Requirement For Which Relief Is Requested

.Exercise valve every three months.

Basis For Request Closure of these valves during power operation would require securing feedwater which would result in reactor trip. Cold

  • shutdown testing of valves using flow to verify closure is inconclusive due to the inability to establish adequate differential pressure across the valve disc.

A test was conducted in an effort to verify whether closure of these valves can be determined using flow. Because there is no isolation boundary between the steam generators and the valves, the test.volume must include the steam generators. A steam generator was pressurized with a nitrogeri blanket to approximately 5 psig. The 0.75 inch drain valve just upstream of the check valve was opened and flow was observed. The 14 inch check valve did not stop the back flow through the vent. It was concluded that the flow was inadequate to seat the check valve completely. Just a small gap between the disc and the seat was sufficient to create a flow area equal to or greater than the flow area through the drain. Therefore, the pressure differential associ~ted with the back flow is being created across the drain valve and not the disc of the check valve.

The above test proved to be inconclusive because of the inability to establish a sufficient differential pressure across the disc.

The only way to increase the differential.pressure is to increase the flow area from the test volume. However, this is not achievable for the existing configuration. Immediately upstream of the drain valve is another 14 inch check valve, so the only available flow area from the test volume is the drain valve .

  • RELIEF REQUEST V-5 (Cont.)

Alternate Testing Proposed These valves will be grouped together and one valve from this group will be disassembled every reactor refueling. A different valve will be disassembled every reactor refueling-.

  • RELIEF REQUEST V-6 Relief Request Withdrawn RELIEF REQUEST V-7 Replaced by Cold Shutdown CSV-5 RELIEF REQUEST v~s Replaced by Cold Shutdown Justification CSV-6 RELIEF REQUEST V-9

' -

RELIEF REQUEST V-11 Replaced by Cold Shutdown Justification CSV-8

  • System Valve(s): 1-CH-258 RELIEF REQUEST V-14 Chemical and Volume Control 1-CH-267 1-CH-276 Category: C Class  : 2 Function: Charging Pump Discharge Check Valve Section XI Code Requirement For Which Relief Is Requested Exercise valves every three months.

Basis For Request With present plant design, these valves can only be partial stroke exercised during power operation because the charging pumps cannot achieve design accident flow when pumping into the

Alternate Testing Proposed These valves will be partially stroked every three months and full flow tested each refueling .

  • SlPV-SRS 4-14 Rev. 5 March 19, 1992
  • RELIEF REQUEST V-20 System Safety Injection Valve(s): l-SI-56 l-SI-47 Category: C Class  : 2 Function: Low Head Safety Injection Pump Suction from Containment sump Check Valve Section XI Code Requirement For Which Relief Is Requested Exercise valves every three months.

Basis For* Request To partial or full flow test these valves requires taking suction from the reactor containment sump which contains untreated water.

This water should not be introduced into the system .

  • Alternate Testing Proposed These valves will be grouped together and one valve from this group will be disassembled and inspected every reactor refueling.

A different valve will be disassembled every reactor refueling .

  • .SlPV-5R5 4-16 Rev. 5 March 19, 1992
  • system Valve(s):

RELIEF REQUEST V-21 Safety Injection Valves affected by this request are identified in Table F.

Category:

.Class Function:

Section XI Code Requirement For Which Relief I~ Requested Exercise valves every three months.

Basis For Request These valves cannot be full stroke exercised during plant power operation. The only full flow path is into the Reactor Coolant System and Low Head Safety Injection pumps cannot overcome Reactor Coolant system operating pressure. These.valves will be

  • partially stroked every three months through the pump recirculation line. During cold shutdown, the Reactor Coolant system pressure still prevents full flow testing of the check valve. During cold shutdown, the charging flow could cause an overpressurization condition.

Testing valves 1-SI-50 and 58 to the closed position requires isolating.the suction lines to the low head safety injection.

pumps, venting on the upstream side of the valve being tested, starting the pump on the other path, checking for leakage and then repeating the process for the *other valve. This test can take up to a hour to complete and places the*unit into a LCO per Technical Specification 3.3 if performed during normal operation.

Alternate Testing P~oposed These valves will be partially stroked every three months and full stroked every refueling.

Valves 1-SI-50 and 58 will be tested to the closed position every cold shutdown .

  • Valve RELIEF REQUEST V-21 (Cont.)

category TABLE F Class Function l-SI-46A,B C 2 Low Head Safety Injection Pump Suction from Refueling Water Storage Tank Check l-SI-58 C 2 Low Head Safety Injection l-SI-50 Pump Discharge Check

  • Relief Request Withdrawn
  • RELIEF REQUEST V-26 System Safety Injection Valve(s): 1-SI-107 1-SI-109 1-SI-128 1-SI-130 1-SI-145 1-SI~147 Category: C Class  : 1 Function: Accumulator Discharge Check Section XI Code Requirement For Which Relief Is Requested Exercise valves every three months.

Basis For Request These valves cannot be partial or full flow tested during normal operation because the accumulator pressure (600 to 650 psig) is below Reactor Coolant System pressure and the injection of

  • borated water would upset the reactor coolant chemistry. During cold shutdown, the RCS pressure still prevents full flow testing .

To achieve full flow through the valves during reactor refueling, the accumulator would have to be discharged from an initial pressure of 600 psig. Discharging the accumulator from this pressure would stress the piping system and inject nitrogen into the RCS. 'Nitrogen in the RCS has been linked to gas binding of the RHR pumps.

Alternate Testing Proposed To verify that these valves will stroke to the open position, they will be placed into two groups. Valves 1-S.I-130 and 147 are in one group and valves 1-SI-107, 109, 128 anQ 145 are in. the other group. Because 1-SI-130 and 147 are downstream from where RHR connects to the SI line, they experience different service conditions than the other valves.

One valve from the group of four valves (1-SI-107, 109, 128 and 145) will be disassembled and inspected every refueling outage.

These valves will be partial flow tested every reactor refueling .

  • RELIEF REQUEST V-26 (Cont.)

Partial flow can be established through valves 1-SI-130 and 147 using RHR pump flow since these valves are downstream of where the two RHR lines discharge into the cold leg safety injection lines. Testing experience has shown that the flow from both RHR pumps can drive the disk of valves 1-SI-130 and 147 to the back seat. This impact event will be recorded using acoustic monitoring instrumentation for both valves each reactor refueling. The data will be analyzed to show that the disk struck the back seat, thus verifying that the disk stroked to the full open position .

  • system Valve(s):

RELIEF REQUEST V-27 Safety Injection Valves affected by this request are identified in Table G.

category:

Class Function:

Section XI ~ode Requirement For Which Relief Is Requested Exercise valves every three months.

Basis For Request The valves on the high head injection lines cannot be partial or full stroke exercised during power operation because flow through these valves would thermal shock the injection system and cause unnecessary plant transients. Flow cannot be established in the

  • low head injection lines during power operation. During cold shutdown, the Reactor Coolant System pressure still prevents full design flow.
  • Also, a partial or full stroke test could cause an overpressurization of the Reactor Coolant System and force a safety system to function.

To verify closure, valves 1-SI-79, 82, 85, 241, 242 and 243 must be vented*upstream and a leakage test performed. Per* Technical Specification Table 4.1-2A, periodic leakage testing on each valve shall be accomplished prior to entering power operation condition after each time the plant is placed in the cold shutdown condition for refueling and after each time the plant is placed in cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the proceeding 9 months. No significant increase in safety will be realized by performing the le~kage tests every cold shutdown.

Alternate Testing Proposed There is no installed instrumentation that can measure individual flow rates for valves 1-SI-79, 82, 85, 88, 91, 94, 238, 239, 240, 241, 242 and 243. Full flow through the hot leg safety injection valves {l-SI-88, 91, 94, 238, 239 and 240) will be verified using clamp on ultrasonic flow instrumentation .

  • RELIEF REQUEST V-27 {Cont.)

Using low head pump flow, the cold leg injection valves {l-SI-79, 82, 85, 241, 242 and 243) will be acoustically monitored for the disk striking the back seat every reactor refueling. The data*

will be analyzed to show that the disk struck the back seat, thus verifying that the disk stroked to the full open position.

Valves 1-SI-224, 225, 226, 227, 228, 229, 235, 236 and 237 will be full stroke exerc_ised with flow every reactor refueling.

Valves 1-SI-79, 82, 85, 241, 242and 243 will be tested to the closed position every reactor refueling per Technical Specification Table 4.1-2A.

Valves l-SI-88, 91, 94, 238, 239 and 240 are confirmed closed by monitoring leakage from the Reactor Coolant System per Technical Specifications 3.1.C and 4.3. Individual valve verification to the closed position is not possible with the current line configurations.

The remaining valves need only*to open .

.TABLE G Valve category Class Function 1-SI-88, 91 C 1 Safety Injection to RCS 1-SI-94, 238 Hot Legs 1-SI-23_9, 240 1-SI-235 C 1 High Head Safety Injection 1-SI-236 to RCS Cold Legs 1-SI-237 l-SI-241 AC 1 Low Head Safety Injection l-SI-242 to RCS Cold Legs 1-SI-243 1-SI-224, 225 C 2 High Head Safety Injection 1-SI-226, 227 Check Valve at Containment Penetrations 1-SI-228, 229 C 2 -- Low Head Safety Injection Check Valves at containment Penetrations SI-79, 82, 85 AC 1 Safety Injection to RCS Cold Legs

  • system Valve{s):

RELIEF REQUEST V-28 .

RWST Cross Tie 1-SI-25 1-SI-410 Category: C Class 2 Function: Charging Pump Suction from RWST Cross Tie Section XI Code Requirement For Which Relief Is Reguested Exercise valves for operability every three months.

Basis For Relief Exercising these valves during power operation would require the charging pump suctions to be aligned with the refueling water storage tank. This would cause a sudden increase in reactor coolant boron inventory .

  • Full flow for the charging system can only be established during reactor refueling when the RCS is depressurized.

Valve 1-SI-25 must close to preserve inventory from the Unit 2 RWST when the cross tie lines are opened. There are no vents or pressure instrumentation upstream of the valve; therefore, the valve cannot be backseat tested with flow.

  • Alternate Testing Proposed These valves will partial flow tested during every cold shutdown and full flow tested during every reactor r~fueling.

Valve 1-SI-25 will be disassembled and inspected every other refueling outage to .verify valve closure.. P.er the guidelines of Generic Letter 89-04, this valve is the only one in the .sample group and is therefore subject to disassembly every outage.

However, disassembling this valve every outage represents excessive intrusive maintenance. If inspection results indicate degradation, the disassembly interval will be increased to once every refu~ling outage .

4-24 Rev. 5 March 19, 1992

  • System Valve(s):

RELIEF REQUEST V-31 Reactor Coolant 1-RC-SOV-lOOA-1 1-RC-SOV-lOOA-2 1-RC-SOV-lOOB-1 1-RC-SOV-lOOB-2 Category: B Class 1 Function: Head Vent for Reactor Vessel Section XI Code Requirements For Which Relief Is Requested Exercise valves and perform fail-safe testing every three months.

Basis For Request These valves isolate the reactor vessel from containment atmosphere. Partial or full stroke exercising the valves during

  • normal operation or during cold shutdowns where the reactor coolant system is pressurized could result in the release of uncontrolled contamination to containment.

Alternate Testing Proposed Exercise for operability during cold shutdowns when the reactor coolant system is not pressurized (but not more frequently than once per three months) .

  • System Valve(s):

Various RELIEF REQUEST V-34 Valves affected by this request are identified in Table J.

Category:

Class Function:

Section XI Code Requirement For Which Relief Is Requested Section XI, IWV-3417(a) "Corrective Action" Basis For Request These valves have a normal stroke time of 2 seconds or less.;

therefore, they could be considered rapid acting valves.

Alternate Testing Proposed

  • Whenever *the stroke time of these valves exceeds 2 seconds, IWV~

3417(b) will be applied.

Note: The list of valves in Table J may change due to maintenance activities- which affect valve performance. An updated list of rapid acting valves will be maintained by ISI site personnel .

  • Valve RELIEF REQUEST V-34 (Cont.)

Category TABLE J Class Function 1-SS-TV-lOOA,B A 1 Pressurizer Liquid Space Sample 1-SS-TV-lOlA,B A 1 Pressurizer Vapor Space sample 1-SS-TV-106A,B A 1 Primary Coolant Hot Leg Sample 1-SS-TV-102A,B A 1 Primary Coolant Cold Leg Sample 1-SS-TV-104A,B A 2 Pressurizer Relief Tank Gas Space Sample 1-DA-TV-lOOA

. 'B A 2 Reactor Containment Sump Pump Discharge Isolation 1-DA-TV-103A,B A 2 Post Accident Sample Return

  • 1-VG-TV-109A,B 1-LM-TV-lOOA-H A

A 2

2 Line Gas Vent Header Isolation Leakage Monitoring System Isolation 1-CV-TV-150B A 2 Containment Vacuum. Pump Suction Isolation 1-RC-PCV-1456 BC 1 Pressurizer Power Operated Relief Valve (max. time is 1.7 sec) 1-RC-PCV-1455C BC 1 Pressurizer Power Operated Relief Valve (max. time is 1.7 sec) 1-Rc~sov-100A-1,-2 B 1 Reactor Vessel Head Vent 1-RC-SOV-lOOB-1,-2

  • Valve RELIEF REQUEST V-34 (Cont.)

Category TABLE J Class Function 1-CH-TV-1204B A 2 RCS Letdown Isolation Trip Valve 1-GW-TV-100-107 A 2 Suction/Discharge Line to Hydrogen Analyzer 1-GW-TV-lllA,B A 2 Containment Grab Sample 1-BD-TV-100 A-F B 2 Steam Generator Blowdown Isolation 1-RM-TV-lOOA,B,C A 2 Isolation oh Monitor Return Line 1-DG-TV-108A,B A 2 Primary Drain Transfer Pump Discharge Isolation 1-IA-TV-100 Instrument Air Supply to

  • A 2 Containment Isolation 1-SI-TV-lOlB A 2 Accumulators to Waste Gas Charcoal Filters Containment Isolation
  • System Valve(s):

EE 1-EE-SOV-100 RELIEF REQUEST V-36 1-EE-SOV-101 1-EE-SOV-105 Category: 13 Class NC Function: Diesel Fuel Oil Pump Discharge ValvesSection XI Code Requirement For Which Relief Is Requested Exercise valves for operability every three months.

Basis For Request These valves are small (1"), fast acting solenoid operated gate valves with no position indication lights and no local visual means of determining stroke time. Valve operability can only be

  • indirectly observed by verifying system operability .

Also, these valves are interlocked with the pumps to open and close upon pump startup and shutdown.

Alternate Testing Proposed These solenoid valves will be stroke tested quarterly by observing that the solenoid.valves perform their intended function. (fuel oil is flowing to the day. tank after the solenoid valve has been opened) .

_. RELIEF REQUEST V-37 System EG Valve(s) 1-EG-SOV-lOOA 1-EG-SOV-lOOB 3-EG-SOV-300A 3-EG-SOV-300B Category: B Class NC Function: Diesel Air Start system Solenoid ValvesSection XI Code Requirement For Which Relief Is Requested Section XI, IWV-3413 "Power Operated Valves" Basis For Request These valves have actuation times considerably under a second and there is no visual reference on the solenoid valve when it has

  • stroked; therefore, the stroke time cannot be measured .

Alt'ernate Testing Proposed These solenoid valves will be stroke tested quarterly_by observing that the solenoid valves perform their intended function, which is to start the diesel engines. Adequate performance of the valves will be verified by recording the time it takes for the diesel engines to reach a predetermined RPM and comparing the time to an acceptance criterion.

Also, the failure of these valves to open or close properly will promptly give a diesel engine trouble alarm. Further investigation would identify problems with the operability of these valves .

  • RELIEF REQUEST V-38 Relief Request Withdrawn l
  • System Valve(s):

Various RELIEF REQUEST V-39 Valves affected by this request are identified by Table K Category:

Class Function:

Section XI Code Requirement For Which Relief Is Requested Leakage rate measurements shall be compared with.the permissible leakage rates specified by the plant owner for a specific valve.

Ba~is For Request The piping configurations for some containment penetrations do not allow for the individual leakage testing of the containment isolation valves which isolate the penetrations.

  • Alternate Testing Proposed In cases where containment isolation valves cannot be individually leakage tested, the containment isolation valves are grouped based on the configuration restraints and the groups are assigned permissible leakages. The valve groups are subject to the acceptance criteria described in IWV-3426 and 3427 .
  • Valve RELIEF REQUEST V-39 (Cont.)

Category Table K Class Function 1-SI-150 AE 2 Boron Injection Tank 1-SI-MOV-1867C A Isolation 1-SI-MOV--1867D A 1-SI-174 AE .2 High Head Safety Injection 1-SI-MOV-1869A A to Reactor Coolant System 1-SI-MOV-1860A A 2 Low Head Safety Injection 1-SI-MOV-1860B Pump Suction from

.1-SI-301, 311 AE Containment Sump 1-IA-446 -AE 2 Instrument Air to 1-IA-TV-100 A c*ontainment 1-LM-TV-lOOA A 2 Leakage Monitoring System 1-LM-TV-lOOC Isolation

  • 1-LM-TV-lOOE 1-LM-TV-lOOG
  • 1-LM-TV-lOOB 1-LM-TV-lOOD 1-LM-TV-lOOF 1-LM-TV-lOOH A 2 Leakage Monitoring System Isolation 1-CS-MOV-lOlA A 2 Containment Spray Pump 1-CS-MOV-lOlB Discharge 1-CS-MOV-lOlC A 2 Containment Spray Pump 1-CS-MOV-101D Discharge 1...,RS-MOV-155A A 2 Recirculation Spray Pump 1-RS-MOV-155B Suction from Containment 1-RS--46, 52 AE sump 1-VS-MOV-lOOC AE 2 Containment Purge Exhaust 1-VS-MOV-lOOD Isolation 1-VS-MOV-101
  • Valve RELIEF REQUEST V-39 (Cont.)

Category TABLE K.

Class Function 1-VS-MOV-lOOA AE 2 Containment Purge Supply 1-VS-MOV-lOOB Isolation 1-VS-MOV-102 1-RL-3 AE 2 Reactor Cavity 1-RL-5 Purification Return Line

  • INTERIM RELIEF REQUEST V-40 Relief Request Withdrawn
  • System Valve(s)

FW 1-FW-144 RELIEF REQUEST V-41 1-FW-159 1.-FW-174 1-FW-148 1-FW-163 1-FW-178 Category C Class 3 Function Auxiliary Feedwater Pump Recirc Line and Pump Oil Cooler Check ValvesSection XI Code Requirement For Which Relief Is Requested Exercise valves for operability every three months.

Basis For Relief These check valves cannot be partial or full flow tested because instrumentation is not installed to measure flow or differential pressure. There is no other indirect means to verify full flow

  • for these valves with the current configuration .

Alternate Testing Proposed Valves 1-FW-144, 159, and 174 will be grouped together; valves 1-FW-148, 163, and 178 will be grouped together and one valv~ from each group will be disassembled and inspected every reactor refueling. A different valve from each group will be disassembled every reactor refueling. These valves will be part stroke exercised every three months .

  • system Valve(s) :

MS 1-MS-176 RELIEF REQUEST V-42 1-MS-178 1-MS-182 Category: C Class 2 Function: Main Steam Header supply Check Valves To Turbine Driven Auxiliary Feedwater Pump Section XI Code Requirement For Which Relief Is Requested*

Exercise valves for operability to the closed position every three months.

Basis For Relief These check valves cannot be exercised to the closed position

  • during normal operation because this test would require th~

venting of process steam while verifying the closed position.

Venting of process steam would endanger the test personnel.

Alternate Testing Proposed These valves will be grouped together and one valve from this group will be disassembled and inspected every reactor refueling.

A different valve will be disassembled every reactor refueling.

The valves will be full flow tested every three months .

  • System Valve(s): 1-CS-105 RELIEF REQUEST V-43 Containment Spray 1-CS-13 l-Rs~11 1-CS-127 1-CS-24 1-RS-17 Category: AC (1-CS-13,24 and 1-RS-11,17) and C(l-CS-105,127)

Class  : 2 Function: Containment Spray Pump Discharge Check ValvesSection XI Code Requirement For Which Relief Is Requested.

Exercise valv.es for. operability every three months.

Basis For Relief These check .valves cannot.be partial or full flow exercised during normal operation because this test would introduce containment spray to containment. These valves cannot be locally

  • exercised during normal operation because they are located inside containment .

These valves are located upstream of the spray nozzles. For valves 1-CS-13 and 24, and 1-RS-11 and 17, the only way to perform a test (partial open or closed) is to install a blank flange downstream and locally perform an partial open and close test using air. The small in.crease in safety gained by performing this test every cold shutdown does not justify the burden of installing the blank flange and locally back seat testing the valves at the increased cold shutdown test frequency.

There are no blank flanges installed downstream for valves l-CS-105 and 127. Therefore, a back seat test or a partial open test cannot be performed on these valves with the current piping configuration. These valves have no external lever arms. The only means to exercise valves 1-CS-105 and 127 to the open and closed positions is by disassembly.

Valves 1-CS-13 and 24, and 1-RS-11 and 17 do have weight-loaded lever arms, however, the weight position and lever arm angle are subject to adjustment to ensure that the valves open when a pressure differential using air is applied every 18 months as required by T~ s. 4.5.C. Therefore, torque measurements would not be repeatable .

  • RELIEF REQUEST V-43 {Cont.)

Alternate Testing Proposed For testing to the open and closed positions, valves 1-CS-105 and 127 will be grouped together and one valve from the group will be disassembled and inspected every reactor refueling. A different valve will be disassembled every reactor refueling. A partial open test cannot be performed on valves l-CS-105 and 127 with the current piping configuration.

For testing to the full open position; valves l-CS-13 and 24 will be grouped together; and valves 1-RS-11 and 17 wili be grouped together and one valve from each group will be disassembled and inspected every reactor refueling. A different valve from each group will be *disassembled every reactor refueling.

Technical Specifications Paragraph 4.5.C. requires verification that valves 1-CS-13 and 24, and l-Rs-11*and 17 open when the discharge line of the pump is pressurized with air and seat when a vacuum is applied. This test partially strokes the valves open. Valves 1-CS-13 and 24, and 1-RS-11 and 17 are containment isolation valves and are tested to the closed position each refueling outage as part of the Appendix J leak testing program .

  • System Valve.(s):

.. Various RELIEF REQUEST V-44 Valves affected by this justification are identified by Table L.

category:

.Class Function:

Section XI Code Requirement For Which Relief Is Requested Exercise valves for operability-to the cl6sed p6sition every three months.

Basis For Relief These check valves must seat upon reversal of flow in order to fulfi*ll their safety functions. The only way to yerify closure is to perform a local.leak rate/back pressure test. Since the

  • valves are located inside containment, they.cannot be tested quarterly.

These valves are containm~nt isolation valves and are subject to leak testing every reactor refueling outage per the requirements of .the Appendix J leak testing program and Section XI IWV-3426 and 3427. The leak tests not only verify that the valves close adequately as does a normal back pressure test, but the tests also reveal the condition of the valve seating surfaces. As

  • required by IWV-3426 and IWV-3427, the le~k tests include acceptance criteria for the maximum allowed leakage.

Performing a back seat test every cold shutdown does not provide enough increase in safety to justify the burden of back seat testing on a more frequent basis.

Alternate Testing Proposed Exercise to the closed position every reactor refueling .

  • SlPV-6R5 4-43 Rev. 5 March 19, 1992
  • Valve RELIEF REQUEST V-44 (Cont.)

Category TABLE L Class Function 1-IA-938 AC 2 Instrument Air Containment 1-IA-939 Isolation 1-RC-160 AC 2 Primary Grade Water to Pressurizer Relief Tank 1-RM-3 AC 2 Isolation on Monitor Return Line 1-SI-234 AC 2 Nitrogen Accumulators N2 Supply 1-VP-12 AC 2 Condenser Air Removal Discharge to Containment

l

  • System Valve(s): 1-CC-1105 RELIEF REQUEST V-45 Component Cooling 1~cc-11ss 1-CC-1106 1-CC-1189 1-CC-1107 1-CC-1190 Category: C Class 3 Function: Component Cooling Supply to RCP Thermal Barrier Isolation Section XI Code Requirement For Which Relief Is Requested Exercise valves for operability to the closed position every three months.

Basis For Relief These check valves must seat upon reversal of flow in order to

  • fulfill their safety function to prevent gross leakage. For the following reasons, it is not practical to test the thermal barrier check valves quarterly or at cold shutdown:

1.) the valves are inside a locked radiation area located inside containment; therefore, they are not accessible during normal operation, 2.) the valves are inaccessible for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after cold shutdown due to decontamination activities which must be performed before entry into the area, 3*) the reactor cooling pump(s) may be running with the reactor cooling system temperature less than 200 OF if an RHR loop is unavailable (in this case the valves and thus cooling to the thermal barriers would normally not be isolated) and

  • 4.) the valves.have soft seats that are replaced every five years and using pressure to back seat these valves on the more frequent cold shutdown frequency may accelerate the degradation of the soft seats.

These valves will be exercised only during refueling outages

because the small increase in safety gained by performing this test every cold shutdown does not justify the burden of

  • performing a local pack pressure test.

4-45 S1PV-6R5 Rev. 5 March 19, 1992

  • RELIEF REQUEST V-45 (Cont.)

Alternate Testing Proposed Exercise to the closed position every reactor refueling .

  • System Valve(s):

INTERIM RELIEF REQUEST V-46 Service Water 1-SW-313 1-SW-323 2-SW-333 category: C Class 3 Function: Ser~ice Water Supply to Main Control Room Air Conditioning System ChillersSection XI Code Requirement For Which Interim Relief Is Requested Exercise valves for operability to the open position every three months.

Basis For Interim Relief These check valves cannot be full flow tested because

  • instrumentation is not installed to directly measure flow or differential pressure across the valve.

According to Technical Specification paragraph 3.23.C.1.b, "If one chiller becomes inoperable, return the inoperable chiller to operable status within seven (7) days or bring both units to Hot Shutdown within the next six (6) hours and be in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." Because the main control and emergency switchgear room emergency ventilation system is common for both units, the above action statement applies whenever Unit 1 or Unit 2 is operating.

Given the scope of the required instrumentation modifications and the existing system configuration, it is estimated that installation of the appropriate flow and pressure instrumentation cannot be completed within the Technical Specification 7 day action statement. Two additional Main Control Room and Emergency Switchgear Room Air Conditioning System chillers are scheduled for installation by the end of 1992. The additional chillers will eliminate the need for entry into the Technical Specification action statement to install the instrumentation.

Also, the flow elements for the chiller service water pumps cannot be installed at power. Therefore, installation of the additional instrumentation is scheduled to be completed by the end of the Unit 1 Cycle 12 refueling outage currently scheduled

  • for second quarter of 1994 .

4-47 S1PV-6R5 Rev. 5 March 19, 1992

  • INTERIM RELIEF REQUEST V-46 (Cont.)

Interim Alternate Testing Proposed These valves will be grouped together and one valve from this group will be disassembled and inspected every reactor refueling.

A different valve will be disassembled every reactor refueling.

They will be part stroked open once every three months with flow.

When flow instrumentation is installed in the second quarter of 1994, flow will be measured directly and the valves will be full flow tested once every three months .

  • System Valve(s):
Various RELIEF REQUEST V-47 Valves affected by tbis relief request are identified by Table M.

category:

  • class Function:

section XI Code Requirement For Which Relief Is Requested IWV-3417(a) - If, for power operated valves, an increase in stroke time of 25% or more from the previous test for .valves with full stroke time greater than 10 sec or 50% or more for valves with full stroke time less than or equal to io sec is observed, test frequency shall be increased to once each month until corrective action is taken.

Basis For Relief

  • The valves listed in Table M typically exhibit stroke time data scatter from test to test that exceeds the 25% and 50% required by IWV-3417(a). These valves either hqve no remote indication and/or no remote control, or no remote open/close control, or the test requires that the power source be interrupted at the valve and not at the switch. Therefore, applying the requirements of IWV-3417(a) in these cases is not practical.

Valve 1-CC-LCV-101 maintains the water level in the seal cooling water tank for component cooling to charging pump cooling system.

Because this valve is being added to the IST Program, there is currently no stroke time data. However, this valve has no remote indication or manual position switch. The valve can be exercised by manipulating the tank level signal and timed by locally observing* stem movement. Differences* in interpreting when the valve stem starts and stops will affect the repeatability of the stroke time measurements.

The position of valves 1-MS-RV-lOlA, Band C is controlled by a potentiometer. Although the valves have remote position indication, there is no open/closed switch. The speed at which the valve goes open or closed depends upon the speed at which the operator turns the potentiometer knob, which in turn affects the repeatability of the stroke time measurements .

  • RELIEF REQUEST V-47 (Cont.)

Valves 1-RH-FCV-1605 and 1-RH-HCV-1758 have no remote indication.

The stroke time is measured by locally observing stem movement.

Differences in interpreting when the valve stem starts and stops affect the repeatability of the stroke time measurements.

Valves 1-SW-PCV-lOOA, Band C, and 1-SW-PCV-101A, B ~nd.C have no remote indication or manual remote control. The valve position is manipulated by venting the actuator diaphragm and the stroke time is measured by observing the movement of the local position indicator. Differences in the speed at which the petcock is opened to vent the diaphragm and in interpreting when the position indicator.starts and stops affect the repeatability of the -stroke time measurements.

Valves 1-SW-TCV-108A, Band C control the flow of service water to the charging pump lube oil coolers. Because these valves are being added to the IST Program, there is currently no stroke time data. However, there is no remote indication or manual position switch. Valve position is controlled by lube oil temperature.

  • The valves can be locally manipulated and timed by observing stem movement. Differences in interpreting when the valve stem starts and stops will affect the repeatability of the stroke time
  • measurements .

Alternate Testing Proposed Maximum stroke times will be established in accordance with ~WV-3417(b). However, the ranges described in IWV-3417(a) will not be applied .

  • Valve RELIEF REQUEST V-47 (Cont.)

category TABLE M Class Function 1-CC-LCV-101 B 3 Charging Pump Seal Cooling Surge Tank Level Control 1-MS-RV-lOlA,B,C B 2 Main Steam Header Discharge to Atmosphere PORV 1-RH-FCV-1605 B 2 RHR Heat Exchanger Bypass Flow Control Valve 1-RH-HCV-1758 B 2 RHR Heat Exchanger Discharge Flow Control Valve 1-SW-PCV-lOOA,B,C B 3 Control Room Condense~

1-SW-PCV-lOlA,B,C B 3 Water system Pressure Control Valves

  • system Valve(s):

INTERIM RELIEF REQUEST V-48 Main Steam 1-MS-NRV-lOlA 1-MS-NRV-lOlB 1-MS-NRV-lOlC category: C Class 2 Function: Main Steam Non-Return ValvesSection XI Code Requirement For Which Interim Relief Is Requested Exercise valve ,for operability to the closed position every three months.

Basis For Interim Relief These stop check valves are currently verified closed by driving the stem down onto the disk using the motor operator *after the

  • main steam system has been isolated during plant shutdown. Full stroke or part stroke exercising of these valves during power operation could result in a turbine and reactor trip.

Closure testing of stop. check valves was initially addressed in response to Question 25 in the original meeting minutes to Generic Letter 89-04. The question and response are as follows:

Question 25:

Previous to this, it was permissible to verify closure of stop check valves simply by operation of the stem (shaft). Is this acceptable instead of reverse flow testing?

Response

Verification of closure capability of stop check valves by using the handwheel meets the ASME Code requirements. This, however, is not the pref erred method of test. The NRC st?1,ff considers reverse flow testing to be a more reliable indication of valve operability .

  • INTERIM RELIEF REQUEST V-48 (Cont.)

However, Item c in the NRC letter dated September 26, 1991 entitled, "Supplement to Minutes of the Public Meetings on Generic Letter 89-04," provided the following revision to-the Question 25 response:

If a prompt closure of these valves on cessation or reversal of flow is required to accomplis*h a safety-.

related function, closure must be verified by reverse flow testing or such other positive means as acoustic monitoring or radiography.

Surry Power Station interpreted the original Question 25 response to mean that driving the stem down onto the disk is a valid ASME Code closure test for stop check valves. However, Item C in the

  • revision* to the Question 25 response indicates that this test method is not adequate and that reverse flow testing or some other positive means as described above be used.

It is not practical to perfoim a reverse flow test at po~er for the reason previously stated. It is not practical to perform a reverse flow test during shutdown because it would.require that the valve stems remain in the open position during plant

  • shutdown. To ensure double valve isolation during a normal shutdown, the secondary plant piping is isolated from the steam source by driving the stern of the stop check valves onto the disk.

After the plant is shutdown, back seat testing these valves with air would require pressurizing over the disk to verify closure.

Given the mass of the 30" diameter disk and the large volume of pipe involved, lifting the disk off the seat to show free movement is not practicable. Disassembly and inspection or other visual inspection techniques would be meaningless because the disk could have been driven to the seat during normal shutdown; therefore, the inspection would not prove verificatio~ that the disk went freely to its seat after cessation of flow.

Another test method identified in Item C is radiography. This inspection technique suffers the same*limitations as the visual inspection techniques discussed above.* Also, given the size of these valves (30 11 nominal pipe size diameter) and internal surface irregularities, radiograph resolution would be poor~

The other test method identified in Item C is acoustic monitoring. Virginia and Electric Power_ Company is reviewing in-house and vendor capabilities to acoustically monitor the valves.

during shutdown .

  • INTERIM RELIEF REQUEST V-48 (Cont.)

Interim Alternate Testing Proposed During the Surry Unit 2, 1993 refueling outage, one or more test methods will be evaluated in the field to determine their practicality. If a test method, as described in Item c, can be developed, it will be implemented at Surry Power station Unit 1 during the next refueling outage following_ the Unit 1 1992 refueling outage.

Until the new test methods are implemented, Surry Power Station will continue to test these stop check valves to the closed position by driving the _stem to the disk every cold shutdown.

This test will be adequate to demonstrate that the disk can be properly positioned on the seat. Also, free movement of the disk from the seat to the full open position is demonstrated when steam flow is established in the mainsteam lines and 100% power is achieved .

4-54 Rev. 5 March 19, 1992

  • System Valve(s):

Various RELIEF REQUEST V-49 All Valves Subject to Appendix J Leakage Testing (Category A CIV Valves) category: A and AC Class Various Function: Limit Leakage to a Specific Maximum Amount Section XI Code Requirement For Which Relief Is Requested IWV-3427(b) - Specifies corrective actions in addition to IWV-3427(a) for valve sizes of six inches 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% .. Also, corrective actions are required if a projection based on three or more tests indicates that the leakage rate of the next sched~led test will exceed the maximum permissible leakage rate by greater than 10% .

  • Basis For Relief Most valves that are leak rate tested are tested in the "as found" condition, subject to maintenance and retested in the "as left" condition. The valve maintenance is performed on a routine basis and it effectively resets the leakage to a small amount.

Therefore, basing corrective actions on previous test results or projections serves no useful function.

Alternate Testing Proposed The requirements of IWV-3427(a) will be applied; however, the requirements of IWV-3427(b) will not be implemented. The alternate testing presented in this Relief Request conforms to NRC Generic Letter 89-04, Attachment 1, Item 10 .

    • 4.6 VALVE TEST PROGRAM COLD SHUTDOWN JUSTIFICATION Section XI, Paragraphs IWV-3412 and IWV-3522 allow for the full stroke exercising of valves during Cold Shutdown (but not more frequently than every three months) if the valves cannot be exercised during normal operation. Therefore, no request for relief from testing every three months is necessary.

However, the code does require that these valves be specifically identified by the owner. The cold shutdown justifications identify and provide the technical basis for valves exercised during cold shutdown but not during normal operation *

  • System Valve(s):

..

COLD SHUTDOWN JUSTIFICATION CSV-1 Main Steam 1-MS-TV-lOlA 1-MS-TV-lOlB 1-MS-TV-lOlC Category: B Class  : 2 Function: Main Steam Line Trip Valves Cold Shutdown Justification Full stroke or part stroke exercising of these valves during power operation could result in a turbine and reactor trip ..

Note: The technical specification acceptance criteria are more limiting than the standard Section XI test criteria because the technical specification requires the measurement of elapsed time from the manual initiation of steam line isolation to initiation of main trip valve

  • motion (must be less than or equal to 4.0 seconds) and the measurement of elapsed time from full open to full closed (must be less than or equal to 5.0 seconds). If either of the limiting times are exceeded, the valve fails the test.

Section XI requires the measurement of elapsed time: from initiation of steam line isolation to full valve closure, which is a less conservative test .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-4 Auxiliary Feedwater Valves affected by this justification are identified by Table A.

Category:

Class Function:

Cold Shutdown Justification Partial or full opening these valves during power operation would introduce cold auxiliary feedwater to the steam generators resulting in thermal stress and possible steam generator tube degradation.

To test valves 1-FW-142, 157 and 172 to the closed position, flow must be established to the steam generators in order to back seat the valves on the discharge side of the non-running pumps. This test would also introduce cold auxiliary feedwater to the steam

  • generators if performed during normal operation .

Category TABLE A Class Function 1-FW-27 C 2 Auxiliary Feedwater Header 1-FW-58 Check at Main Feedwater 1-FW-89 Heacier Valves 1-FW-131 C 2 Auxiliary Feedwater Header 1-FW-133 Check Valves at 1-FW-136 Containment Penetration 1-FW-138 1-FW-142 C 3 Auxiliary Feedwater Pump 1-FW-157 Discharge Check Valves 1-FW-172 1-FW-272 C 2 Check Valves at 1-FW-273 Containment Penetration (Cross-Connect for Unit 1 Aux. Feed. from Unit 2)

  • 1-FW-309 C 2 Check Valves at 1-FW-310 Containment Penetration (Cross-Connect for Unit 1 Aux. Feed. from Unit 2)
  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-5 Component Cooling Valves affected by this justification are identified by Table B Category:

.Class Function:

Cold Shutdown Justification These valves are located in the containment and may be normally open or closed depending on system lineup. A containment entry and manipulation of other system valves are necessary to test these valves to either the open or closed position. This is considered impractical during. power operation*.

  • Valve 1-CC-176 Category C

TABLE B Class 3

Function Component Cooling to RHR 1-CC-177 Heat Exchanger Check Valves 1-CC-242 C 3 Component Cooling to 1-CC-233 Reactor Containment Air 1-CC-224 Recirculation Coolers

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-6 Component Cooling Valves affected by this justification are identified by Table C.

Category:

Class -

.

Function:,

Cold Shutdown Justification*

To perform an operability or a fail-safe test, the component cooling lines must be isolated, thereby stopping the flow of cooling water to the Reactor Coolant Pumps. Loss of cooling water to these pumps can be damaging, even for short periods of time.

  • Valve 1-cc-1 Category C

TABLE C Class 3

Function Component Cooling to 1-CC-58 Reactor Coolant Pumps 1-CC-59 1-CC-TV-105A B 3 Component Cooling from 1-CC-TV-105B Reactor Coolant Pumps 1-CC-TV-105C

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-7 Reactor Coolant 1-RC-PCV-1456 1-RC-PCV-1455C Category: BC Class 1 Function: Pressurizer Power Operated Relief Valves Cold Shutdown Justification These pressurizer power operated relief valves have shown a high probability .of sticking open while being exercised during power operation. Also, these valves are not required for overpressure protection unless the primary system temperature is under 350 degrees F per Technical Sp~cification Paragraph 3.l.G.1.b(3).

These valves will be tested on approach to Cold Shutdown and testing shall not be deferred .

  • System Valve(s):

COLD *SHUTDOWN JUSTIFICATION CSV-8 Residual Heat Removal 1-RH-5 1-RH-11 category:_ C Class  : 2 Function: RHR Pump Discharge Check Valve Cold Shutdown Justification These valves can only be partial or full strok~ exercised to the open position and verified closed during the testing of RHR pumps 1-RH-P-lA and iB (refer to Relief Request P-7). The low pressure pumps take suction from and discharge to the reactor coolant system which operates at 2235 psig. *This *pressure is well above the operating pressure of the pumps; therefore, testing- during normal operation is not possible .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-9 Residual Heat Removal 1-RH-MOV-1700 1-RH-MOV-1701 Category: B Class 1 Function: RHR Suction form Reactor Coolant system Cold Shutdown Justification These valves are interlocked with Reactor Coolant System pressure such that the valves cannot be opened at.elevated reactor coolant system pressure~ Overpressurization of the suction line may cause a LOCA. The interlocks cannot be bypassed with normal control circuits .

  • System Valve(s):

..

COLD SHUTDOWN JUSTIFICATION CSV-10 Residual Heat Removal 1-RH-MOV-1720A 1-RH-MOV-1720B category: B Class  : 1 Function: RHR Discharge to Reactor Coolant System Cold Shutdown Justification With the MOV shut and if its respective check valve is leaking, there is no way to determine whether or not an overpressure condition exists before opening the MOV.

If the MOV was opened and an overpressure condition did exist between the MOV and the RCS, the primary pressure of 2235 psig will be released on the Residual Heat Removal System with a relief valve setting of 700 psig. This would be an unnecessary challenge to the Residual Heat Removal System *

  • system Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-11 Chemical and Volume Control l-CH-LCV-1115C l-CH-LCV-1115E Category: B Class ... 2 Function: Charging Pump suction from Volume Control Tanks Cold Shutdown Justification Partial or full strok~ exercising these valves during power operation would require the charging pump suctions to be aligned with the refueling water storage tank. Th°is would cause a sudden increase in Reactor Coolant System boron inventory, which would cause a plant transient. *

  • SlPV-6R5 4-67 Rev. 5 March 19, 1992
  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-13 Chemical and Volume Control 1-CH-MOV-1381 category: A Class 2 Function: Reactor Coolant Pump Seal Water Return Cold Shutdown Justification:

Closure of this valve with Reactor Coolant Pumps in operation will cause a loss of seal flow resulting in possible pump seal damage .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-14 Residual Heat Removal 1-RH-FCV-1605 1-RH-HCV-1758 Category: B Class 2 Function: Residual Heat Removal Exchanger flow control Cold Shutdown Justification These valves have no remote position indication and are located inside containment. The valves can only be exercised (partial or full stroke) and timed by locally observing stem movement~

Because a containment entry is required to perform the exercise and fail-safe tests, it will be conducted every cold shutdown .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-15 Chemical and Volume Control 1-CH-TV-1204A 1-CH-LCV-1460A 1-CH-TV-1204B 1-CH-LCV-1460B Category: A (1-CH-TV-1204A, B) and B (1-CH-LCV-1460A, B)

Class 1 (l~CH-LCV-1460A, B) and 2 (l-CH-TV-1204A, B)

Function: Reactor Coolant System Letdown Isolation Trip and Level Control Valves Cold Shutdown Justification Exercising these valves during power operation interrupts letdown flow from the reactor coolant system (RCS) to the volume control tank. If the valves should fail closed, reactor coolant inventory control would be lost.

The pressurizer level control program controls reactor coolant inventory by regulating the operation of the charging flow control valve so that the charging input flow to the RCS and

Also, exercising these valves during normal operation will interrupt letdown flow through the regenerative heat exchanger.

This flow interruption would allow a slug of relatively.cool charging water to thermal shock the nozzle connecting the 3 11 charging line to the 27" loop 2 cold leg injection line.

The valve controllers do not allow for a part stroke exercise test .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-16 Chemical ~nd Volume Control l~CH-MOV-1289A 1-CH-MOV-1289B Category: A (l-CH-MOV-1289A) and B (1-CH-MOV-1289B)

Class . 2 Function: Normal Charging Header Isolation Cold Shutdown Justification Failure of these valves in the closed position during exercising would cause a loss of charging flow and could result in an inability to maintain reactor coolant inventory .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-17 Safety Injection l-SI-MOV-1890C Category:* A Class  : 2 Function: Low Head Safety Injection to Reactor Coolant system Cold Legs, Cold Shutdown Justification In accordance with Technical Specification 3.3.A.8, during power operation, the A.C. power shall be removed from 1-SI-MOV-1890C with the valve in the open position. If this valve was stroked during power operation and failed in the closed position, the Low Head Safety Injection System would be rendered inoperable *

  • SlPV-6R5 4-73 Rev. 5 March 19, 1992
  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-18 Safety Injection 1-SI-MOV-1867C 1-SI-MOV-1867D Category: A Class 2 Function: High Head Safety Injection Isolation Cold Shutdown Justification These valves cannot be part_ial or full stroke exercised during power operation. Opening these valves would allow excess charging flow into the Reactor Coolant System causing a reactivity transient .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-19 Chemical and Volume Control 1-CH-225 1-CH-228 1-CH-227 1-CH-229 1-CH-MOV-1350 Category: B (1-CH-MOV-1350, 1-CH-228) and C (1-CH-225,227,229)

Class  : 2 Function: Emergency and Manual Emergency Boration Line Isolation Valves Cold Shutdown Justification To achieve full flow through Check valves 1-CH-225, 227 and 229, the boric acid transfer pumps must be set at high speed, which could inject enough boric acid into the reactor coolant system to cause a reactor power transient. Under normal plant operating conditions or when the plant is shutdown, valve 1-CH-MOV-1350 can be full stroke exercised and valves 1-CH-225, 227 and 229 can be

Manual valve 1-CH-228 will be stroked open when the alternate boration path is established every cold shutdown. The increased level of safety gained be exercising this valve every quarter does not justify the added burden of performing a separate test just for the manual valve.

Valve 1-CH-MOV-1350 will be full stroke exercised and check valves 1-CH-225, 227 and 229 will be part stroked exercised every quarter during normal operation when the reactor coolant boric acid concentration is above 100 ppm. Check valves 1-CH-225, 227 and 229, and manual valve 1-CH-228 will be full stroked exercised every cold shutdown .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-20 Chemical and Volume Control 1-CH-309 Category: AC Class 2 Function: Normal Charging Isolation Check Valve Cold Shutdown Justification Closure testing of 1-CH-309 cannot be performed during power operation because the test would interrupt the normal charging flow path .

  • system Valve(s}:

COLD SHUTDOWN JUSTIFICATION CSV-21 steam Generator Blowdown 1-BD-TV-lOOA 1-BD-TV-lOOD 1-BD-TV-lOOB 1-BD-TV-lOOE 1-BD-TV-lOOC 1*-BD-TV-lOOF Category: B Class 2 Function: Steam Generator Blowdown Isolation Cold Shutdown Justification Closing these valves during power 6peration causes the *downstream piping to become empty due to drainage and water flashing to steam. When the valves reopen, a flow surge could occur which automatically isolates the inner val_ves due to high flow. Then a containment entry is necessary to reset these valves and upon reopening the process may occur again .

  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-25 Safety Injection 1-SI-MOV-1842 1-SI-MOV-1869A 1-SI-MOV-1869B Category: A Class 2 Function: High Head Safety Injection to reactor Coolant System Cold Shutdown Justification These valves cannot be partial or full stroke exercised during power operation. Opening these valves would allow excess charging flow into the Reactor Coolant System causing a reactivity transient and possible thermal shock to the High Head Safety Injection System.

Also, according to Technical Specification 3.3.A.~, A. C. power shall be removed with the valves in the closed position during

  • power operation .
  • system Valve(s):

.

COLD SHUTDOWN JUSTIFICATION CSV-26 Component Cooling l-CC-181 l-CC-185 Category: B (manual)

Class . 3 Function: Component Cooling Supply/Return to/from RHR Heat Exchanger Isolation Valves Cold. Shutdown Justification A containment entry is required to exercise these manual butterfly valves. Therefore*, they will be exercised every cold shutdown .

  • March 19, 1992
  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-27 Component Cooling 1-CC-TV-107 1-CC-TV-120A 1-CC-TV-120B 1-CC-TV-120C Category: B Class 3 Function: Component Cooling Return from Reactor Coolant Pump Thermal Barrier Isolation Valves Cold Shutdown Justification Exercising these valves during normal operation would isolate component cooling water to the reactor coolant pump thermal barriers. Cooling water must be available to the reactor coolant pump thermal barriers when the reactor coolant system temperature is above 200 °F. Cold shutdown is entered when the reactor

  • coolant system temperature drops below 200 °F. The valve controllers do not allow for a part stroke exercise test.

These valves will be full stroke tested every cold shutdown .

  • SlPV-6R5 4-81 Rev. 5 March 19, 1992
  • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-28 Feedwater 1-FW-FCV-1478 1-FW-FCV-155A 1-FW-FCV-1488 1-FW-FCV-155B 1-FW-FCV-1498 1-FW-FCV-155C category: B Class NC Function: Main Feedwater Regulating and Regulating Bypass Isolation Valves Cold Shutdown Justification These valves are in positions required to sustain power operation. Full stroke exercising the valves would result in a reactor trip. The main feedwater regulating valves 1-FW-FCV-14 78, 1488 and 1498 move during no.rmal operation as they perform their regulating function. The bypass valves 1-FW-FCV-155A, B and C remain closed during power operation.

  • These valves will be part stroke exercised every three months and full stroke exercised every cold shutdown *
    • System Valve(s):

COLD SHUTDOWN JUSTIFICATION CSV-29 Safety Injectiqn 1-SI-109 1-SI-130 1-SI-147 Category: C Class 1 Function: SI Accumulator Discharge Isolation Check Valve Cold Shutdown Justification These check valves are located inside containment and are back seat tested using the installed sampling system. To ensure that all of the leakage that could pass by the check valves is collected, the accumulator discharge motor operated valves (1-SI-MOV-1865A, Band C) must be closed. However, these motor operated valves must be open and de-energized when the reactor coolant system pressure is above 1000 psig according to Technical Specification Paragraph 3.3.A.10. Therefore, the accumulator

  • check valves will be tested to the closed position every cold
  • shutdown .
  • System Valve(s):

..

COLD SHUTDOWN JUSTIFICATION CSV-30 Component Cooling l-CC-805 Category: C Class 3 Function: Charging Pump seal Cooling Surge Tank Makeup Valve Cold Shutdown Justification This valve must open to provide a flow path from the component cooling water system to the charging pump seal water surge tank as a supply of makeup water to the surge tank. There is no flow instrumentation to verify partial or full flow for the check valve. *

  • There is level instrumentation on the surge tank. The surge tank can be isolated, drained down and refill~d. However, the surge tank provides the NPSH for the charging pump cooling water pumps and it should not be isolated from the system during normal
  • operation when component cooling water for the charging pumps is required.

This valve will be tested to the full open position every cold shutdown .

  • SlPV-6R5 4-84 Rev. 5 March 19, 1992
  • System Valve(s):

..

COLD SHUTDOWN JUSTIFICATION CSV-31 Component Cooling l-CC-LCV-101 Category: B Class  : 3 Function: Charging Pump Seal Cooling Surge Tank Level Control Valve Cold Shutdown Justification This valve must open to maintain the level in the charging pump seal water surge tank and must close to prevent overflowing the surge tank and potentially draining the surge tank through the over flow line. The valve fails closed on lose of operating air.

Valve position is determine solely from tank level. In order to manipulate the valve for testing, the surge tank must be isolated. However, the surge tank provides the NPSH for the charging pump cooling water pumps and it should not be isolated

  • from the system during normal operation when component cooling water for the charging pumps is required.

This valve will be exercise to the open and closed positions every cold shutdown .

  • 4.7 ALTERNATIVE TESTING FOR NON-CODE VALVES According to the minutes of public meeting on Generic Letter 89-04, "Paragraph (g) of 10CFR 50.55a requires the use of Section XI of the ASME Code for inservice testing of components covered by the Code. For other components important to safety, the licensee also has the burden of demonstrating their continued operability." The minutes go on to state that, "The Code-required IST program is a reasonable vehicle to provide a periodic demonstration of the operability of pumps and valves not covered by the Code. If non-Code components are included in the ASME Code IST program (or some other licensee-developed inservice testing program) and certain Code provisions cannot be met, the Commission regulations (10 CFR 50.55a) do not require a

'request for relief' to be submitted to the staff.

Nevertheless, documentation that provides assurance of the continued operability of the non-Code components through the performed tests should be available at the plant site." Non-Code components are components that are important to safety but are not in systems or portions of systems that are classified ASME Class 1, 2 or 3.

  • Surry Power Station has elected to include certain non-Code components in the ASME IST program. Where the Code provisions cannot be met for non-Code components, alternative testing is performed that is adequate to ensure continued operability. The alternate testing is qescribed in this section. There may be other deviations from Code provisions that are not described in thip section. For these cases, documentation is available at the plant site.

As indicated in the minutes of public meeting on Generic Letter 89~04, a 'r~quest for relief' need not be *submitted for non-Code components. Therefore, the alternative tests described in this section are not

'requests for relief' but are provided for information.

The procedure of providing alternative testing descriptions instead of requests for relief for non-Code components begins with Revision 5. Requests for relief that were approved by the NRC in Revision 4 for non-Code components will remain in place .

  • System Valve(s):

NON-CODE ALTERNATIVE TESTING VNC-1 Instrument Air 1-IA-928 1-IA-949 1-IA-947 1-IA-952 1-IA-948 1-IA-953 Category: C Class  : NC Function: Bottled Air System Supply/Isolation Section XI Code Requirements Which cannot Be Met Measure flow to verify full stroke.

Exercise valves every three months.

Basis For Alternate Testing Valves 1-IA-928, 947 and 952 must close to ensure that bottled

  • air is available to actuate the main valves (l-RC-PCV-1455C, 1-RC-PCV-1456, and 1-MS-SOV-102A and B). Valves 1-IA-948, 949 and 953 must open to allow bottled air to reach the main valves.

There is no direct means to measure the flow of air through the check valves.

However, after the instrument air system is isolated and the lines vented, the stroke times of the main valves are measured and compared to acceptance criteria. Measuring the stroke times provides indirect evidence that valves 1-IA-948, 949 and 953 open properly and that valves 1-IA-928, 947 and 952 close properly.

The performance of this test renders the main valves inoperable; therefore, the tests cannot be performed during normal operation.

After stroking the main valves with the air bottles, the air bottles must be replaced. The safety gained in testing the valves every cold shutdown versus every reactor refueling does not justify the burden of replacing the air bottles on the more frequent basis .

  • NON-CODE ALTERNATIVE TESTING VNC-1 (Cont.)

Alternative Testing Valves 1-IA-928, 947 and 952 will be tested closed and valves 1-IA-948, 949 and 953 will be tested open by isolating and venting the instrument air lines, and then stroking the main valves with the bottled air. The stroke times of the main valves will be measured and compared to acceptance* criteria. This test will be performed every reactor refueling .

  • System Valve(s):

NON-CODE ALTERNATIVE TESTING VNC-2 Circulating Water 1-cw~111 Category: B (manual)

Class . NC

-*

Function: Discharge-Tunnel Vent Valve Section XI Code Requirements Which Cannot Be Met Exercise valve every three months~

Basis For Alternate Testing This valve i~ located on a line from the discharge tunnel to the discharge canal. The valve is opened following the initiation of an event to reduce the vacuum in the discharge tunnel which reduces the flow rate through the essential heat exchangers. By

  • reducing the flow rate, cooling water inventory is conserved in the intake canal. Full or partial opening o_f this valve during normal operation or during cold shutdown will reduce cooling to the component cooling system and the bearing cooling system which will disrupt plant operations.

Alternative Testing This valve will be exercised every reactor refueling .

  • SlPV-6R5 4-89 Rev. 5 March 19, 1992
  • system Valve{s):

..

NON-CODE ALTERNATIVE TESTING VNC-3 Emergency Generator 1-EG-43 3-EG-43 1-EG-44 3-EG-44 1-EG-45 3-EG-45 1-EG-46 3-EG-46 Category: B {l/3-EG-43,44)

C (1/3-EG-45,46)

Class  : NC Function: 1/3-EG-43,44 EDG starting Air/Drive Air Control/Relay Valves 1/3-EG-45,46 EDG Air Start Pressure Equalizing Check ValvesSection XI Code Requirements Which Cannot Be Met For valves l/3-EG-43,44, measure stroke time .

  • For valves 1/3-EG-45,46, measure flow to verify full open Basis For Alternate Testing Valves 1/3-EG-43 and 44 are air pilot valves that open to supply drive air to the EDG air starting motors. These valves have actuation times considerably under a second and there is no visual reference on the valve to observe the stroke; therefore, the stroke time cannot be measured.

Valves 1/3-EG-45 and 46 are check valves that close to prevent opening the air start valves before the air motor pinion gears are fully engaged. They open to ensure that the air motor pinions remain engaged (hold-in feature) when the air motors are operating. The only indication of the proper operation of the check valves is the proper operation of the pinion gears. The air pilot valves and the check valves work in concert with the air start solenoid valves to start the emergency diesels upon demand within the required time .

  • 4-90 Rev. 5 March 19, 1992
  • NON-CODE ALTERNATIVE TESTING VNC-3 {Cont.)

Alternative Testing These valves will be stroke tested quarterly by observing that the valves perform their intended function, which is to start the diesel engines. Adequate performance of the valves will be verified by recording the time it takes for the diesel engines to reach a predetermined RPM and comparing the time to an acceptance criterion.

Also, the failure of these valves to perform will promptly give a diesel engine trouble alarm. Further investigation would identify problems with the operability of these valves .

  • 5.0 REPORTING OF INSERVICE TEST RESULTS 5.1 PUMP INSERVICE PROGRAM Records of Pump Inservice Test Results will be in accordance with the intent of Article IWP~6000. Files will be established for each pump and will include:
1) Pump identification by equipment number, manufacturer and serial number.
2) The record of test shall include:

a) date of test, b) measured and observed quantities, c) identification of instruments used, d) comparison with allowable ranges of test valves and analysis of deviations, e) requirements for corrective actions, and f) conducting and analyzing the test

3) Inservice test plans. This may be by surveillance test procedure by which the pump is tested with reference drawing.
  • 4) summaries of corrective action some by maintenance report number, etc.

The Pump Inservice Test Program, associated surveillance test procedures and results will be kept at Surry Power Station. They will be available for audit by the Authorized Nuclear Inservice Inspector and the NRC.

5.2 VALVE INSERVICE PROGRAM Records of Valve Inservice Test Results will be in accordance with the intent of Article IWV-6000, files will be established for each valve and will include:

1) Valve identification by equipment number,*

manufacturer, size, valve type, actuator type.

2) The record of test.shall include:

a) date of test, b) measured and observes quantities where applicable, c) identification of instruments used where

  • applicable, 4-92 S1PV-6R5 Rev. 5 March 19, 1992
  • d) e)

f) comparisons with allowable ranges of test valves and analysis of deviations, maintenance history, and signature *of the person or persons responsible for conducting and analyzing the test.

3) summaries of maintenance history may be maintenance report numbers, etc.

The Valve Inservice Test Program, associated surveillance test procedures and results will be kept at Surry Power Station. They will be available for audit by the Authorized Nuclear Inservice Inspector and the NRC .

  • 6.0 QUALITY ASSURANCE PROGRAM The Pump and Valve Inservice Test Program activities will be conducted in accordance with the Nuclear Operations Department Standards Manual and Technical Specifications for Surry Power Station .
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