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| issue date = 05/23/1989
| issue date = 05/23/1989
| title = Forwards Rev 0 to App C Inservice Pump & Valve Testing Program for 1990-1999 Interval, QA Manual for Review & Approval.Program Reviewed to Positions Delineated in Generic Ltr 89-04
| title = Forwards Rev 0 to App C Inservice Pump & Valve Testing Program for 1990-1999 Interval, QA Manual for Review & Approval.Program Reviewed to Positions Delineated in Generic Ltr 89-04
| author name = MECREDY R C
| author name = Mecredy R
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| addressee name = JOHNSON A
| addressee name = Johnson A
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000244
| docket = 05000244
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:'.A.C:CELE RATED Dl gP BUTl ON DEM ONSTf+10N SYSTEM ,E,'-'-t REGULATORY IANFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:8906050144'OC.DATE:
{{#Wiki_filter:'.A.C:CELE RATED         Dl gP BUTl ON         DEM ONSTf+10N             SYSTEM
89/05/23 NOTARIZED:
                                    ,E,
NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
                                        '-'-t REGULATORY IANFORMATION DISTRIBUTION SYSTEM (RIDS)
Rochester Gas&Electric Corp.RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.
ACCESSION   NBR:8906050144'OC.DATE: 89/05/23 NOTARIZED: NO                           DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester                 G   05000244 AUTH. NAME           AUTHOR AFFILIATION MECREDY,R.C.           Rochester Gas & Electric Corp.
Project Directorate I-3  
RECIP.NAME           RECIPIENT AFFILIATION JOHNSON,A.               Project Directorate I-3 R


==SUBJECT:==
==SUBJECT:==
Forwards"QA Manual Ginna Station RGE App C Inservice Pump&R Valve Testing Program for 1990-99 Interval."+/g 7 DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR I ENCL g SIZE: 8 TITLE: OR Submittal:
Forwards "QA Manual Ginna Station RGE App C Inservice           Pump   &
Inservice Inspection/Testing/Relief from ASME Code D NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
Valve Testing Program for 1990-99 Interval."
05000244 8 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNAL: AEOD/DSP/TPAB NRR/DEST/MTB 9H OC/LQMB EG FZX'1 EXTERNAL: EG&G BROWN,B LPDR NRC PDR COPIES LTTR ENCL 1 0 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD1-3 PD NRR/DEST/MEB 9H NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EG&G ROCKHOLD,H NL 007 HEMMING NSIC COPIES LTTR ENCL 1 1 1 1 1 0 1 1 N 1 1 1 R I S NOTE'IO ALL"RIDS" RECIPIEMIS:
8    + /g 7 DISTRIBUTION CODE: A047D TITLE:    OR  Submittal: Inservice COPIES RECEIVED:LTR     I ENCL g   SIZE:
PLEASE HELP US IO REDUCE HASTE CGNZACT THE DXX3MEÃZ CONTROL DESK I RXM Pl-37 (EZZ.20079)KO ELIKBQQE YOUR NAME FRY DISTRIBUTION LISTS FOR DOCUMENZS YOU DONiT NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL SZZZrZZP IIIIIIII L4il Owl~''IJII Z ZSZruZ 8K.:::: I S ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y.14649.0001 May 23, 1989 TELEPHONC AscA coom 7ia 546.2700 U.S.Nuclear Regulatory Commission Document Control Desk Attn: Mr.Allen Johnson PWR Pro j ect Directorate I-3 Division of Reactor Projects I/II Washington, D.C.20555  
Inspection/Testing/Relief from ASME Code               D NOTES:License Exp date       in accordance with 10CFR2,2.109(9/19/72).               05000244 8 RECIPIENT           COPIES            RECIPIENT          COPIES ID  CODE/NAME        LTTR ENCL        ID CODE/NAME       LTTR ENCL PD1-3 LA                   1    0    PD1-3 PD JOHNSON,A                 1    1 INTERNAL: AEOD/DSP/TPAB                 1    1    NRR/DEST/MEB 9H         1     1 NRR/DEST/MTB 9H            1   1     NUDOCS-ABSTRACT        1     1 FZX'1 OC/LQMB EG 1
1 0
1 OGC/HDS2 RES/DSIR/EIB 1
1 0
1 EXTERNAL: EG&G BROWN,B                  1    1    EG&G ROCKHOLD,H               N LPDR                      1    1    NL 007 HEMMING         1 NRC PDR                    1   1     NSIC                    1     1 R
I S
NOTE 'IO ALL "RIDS" RECIPIEMIS:
PLEASE HELP US IO REDUCE HASTE   CGNZACT THE DXX3MEÃZ CONTROL DESK I RXM Pl-37 (EZZ. 20079) KO ELIKBQQE YOUR NAME FRY DISTRIBUTION LISTS FOR DOCUMENZS YOU DONiT NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR             21   ENCL
 
SZZZrZZP IIIIIIII                                                           L4il Owl ~
8K.::::
IJII  Z  ZSZruZ I   S ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 TELEPHONC AscA coom 7ia 546.2700 May 23, 1989 U.S. Nuclear Regulatory Commission Document               Control Desk Attn: Mr. Allen Johnson PWR Pro j ect Directorate I-3 Division of Reactor Projects Washington, D.C.       20555 I/II


==SUBJECT:==
==SUBJECT:==
Inservice Pump and Valve Testing Program R.E.Ginna Nuclear Power Plant Docket No.50-244  
Inservice Pump and Valve Testing Program R. E. Ginna Nuclear Power Plant Docket No. 50-244
 
==Dear Mr. Johnson:==
 
In accordance with requirements of 10 CFR Part 50, Section 50.55a, paragraph (g), we have enclosed the Ginna Station Inservice Pump and Valve Testing (IST) Program for the January 1, 1990 through December 31, 1999 interval for your review and approval. This program will direct surveillance requirements delineated in Technical Specifications Section 4.2 for the Inservice Pump and. Valve Testing Program. The enclosure is entitled "Appendix C Inservice Pump and Valve Testing Program for the 1990-1999 Interval." This program closely parallels the recently revised RGGE IST program for 1989 endorsed by your letter dated May 3, 1989. In accordance with 10 CFR 50.55a paragraph (g)(4)(ii), this program is based on the 1986 Edition of      ASME        Section XI".
The enclosed 10 year submittal was reviewed to positions delineated in Attachment 1 bf USNRC Generic Letter 89-04 issued.
on April 3, 1989'. The program complies with positions of Attachment 1 with one possible exception. Position 4 of Attachment 1 would. require two series check valves in Event V configurations to be individually tested. The Ginna. configura-tion for Safety Injection to each Reactor Coolant System Hot Leg contains two series check valves in series with a locked closed, deenergized motor operated. valve. The motor operated valve is leak tested along with a leak test conducted on the check valves in series. An evaluation. has been initiated. to determine is a discrepancy. The resolution, to be provided. prior to August.
if      this 1, 1989, will either involve further clarification to Technical Specifications, further clarification of this submittal or a commitment                  to a future modification.
3906050144 8'F0523 PDR          AGOCK 05000244 P                            PDC
 
Generic Letter 89-04, Attachment  1  Position  11 identifies examples of valves and pumps or valve groups that have generally and erroneously been omitted from IST programs.      Such items are included in the program as Management directed upgrades or from a good Engineering practice standpoint, when they are applicable to RGGE's System Selection Criteria. The following EGGG response numbers documented in our submittal dated December 20, 1988 substantiate the exclusion of some of these examples from the IST Program.
Position 11 reference                EG&G  Response  Number Control Room Chilled Water          H-2 Accumulator MOVs/Vents              E-10 Auxiliary Przr Spray                B-1 Boric Acid Transfer Pumps            B-7; 2-7 Valves in Emergency Borate          B-7; 2-7 Flowpath Since our December 20, 1988 response to the 99 EGGG questions provided in your June 21, 1988 letter to Mr. R.W.
Kober, a change in our response to Questions B-2, B-5, D-4, E-3, E-5, F-4, L-1, P-6 and P-9 has occurred. as follows:
The B-2 and B-5 responses indicated that valves 204A, 427 and 820 were to be tested as either pressure or containment isolation valves. With the reclassification of letdown isolation valves 200A, 200B, 202 to serve as both pressure and containment isolation functions, valves 204A, 427 and 820 are not required to be included. in the IST program.
The D-4 response indicated that full stroke. exercising flow rates for CCW valves 723A and B was 2500 GPM. Subsequent evaluation indicates that these valves will be partial stroke tested. to 2500 GPM quarterly and. full stroke tested.
to 2980 GPM at cold shutdown. This is due to system configuration and test methods available at power.
The E-3 response indicated full stroke exercise for SI pump discharge check valves 870A, 870B, 889A 6 889B would occur during cold shutdowns. Due to low temperature overpres-surization concerns for the reactor coolant system, a refueling frequency is now proposed consistent with relief request VR-11.
The E-5 response  indicated full stroke  exercise for safety injection  system pressure isolation valves 878G and 878J would occur during cold shutdowns. Due to low temperature overpressurization concerns for the reactor coolant system a refueling frequency is now proposed consistent with relief request VR-10.
 
The F-4 response    indicated. that safety injection recir-culation  and,  test  line return valves 897 and 898 would be exercised  at  cold  shutdown  as they were blocked open during normal operation. During      the 1989 outage the air operated valves were replaced with motor operated valves permitting quarterly testing in accordance with the Code.
~    The L-1 response provided a test method for closure verification of Main Feedwater check valves 3992 and 3993.
An alternate method, has been developed to test the valves during routine cold or refueling shutdowns involving a pressure drop verification. This will be used in lieu of the method previously described. For unscheduled shutdowns resulting from a plant trip, a relief request is provided. to allow deferral of testing to the next planned cold shutdown or refueling.
~    The P-6 response indicated that valve 857C was a passive valve which is kept locked open with power removed. During the 1989 outage the RHR to SI system cross-connect valves were upgraded. Valve 857C is now maintained closed and is required  to  open for high head safety injection re-circulation. This valve has been included in the program and will be exercised. in accordance with the Code.
~    The P-9 response indicated that valve 822A had a safety function and would be added, to the revised IST program as a Category A Class boundary valve. Subsequent review has determined. that valve 822A is not a containment isolation valve, therefore negating,its need to be included in the      IST'rogram.
Consideration was given to evaluating time and resources needed for an adequate pump and. valve review to current criteria and guidelines established in Generic Letter 89-04.        It estimated that one year and, approximately 2500 man-hours, as a was minimum, would be required. for existing programs.
Very truly yours, Robert C. Me dy General Manager, Nuclear Production RCMhcemh114


==Dear Mr.Johnson:==
0 C
In accordance with requirements of 10 CFR Part 50, Section 50.55a, paragraph (g), we have enclosed the Ginna Station Inservice Pump and Valve Testing (IST)Program for the January 1, 1990 through December 31, 1999 interval for your review and approval.This program will direct surveillance requirements delineated in Technical Specifications Section 4.2 for the Inservice Pump and.Valve Testing Program.The enclosure is entitled"Appendix C Inservice Pump and Valve Testing Program for the 1990-1999 Interval." This program closely parallels the recently revised RGGE IST program for 1989 endorsed by your letter dated May 3, 1989.In accordance with 10 CFR 50.55a paragraph (g)(4)(ii), this program is based on the 1986 Edition of ASME Section XI".The enclosed 10 year submittal was reviewed to positions delineated in Attachment 1 bf USNRC Generic Letter 89-04 issued.on April 3, 1989'.The program complies with positions of Attachment 1 with one possible exception.
II'}}
Position 4 of Attachment 1 would.require two series check valves in Event V configurations to be individually tested.The Ginna.configura-tion for Safety Injection to each Reactor Coolant System Hot Leg contains two series check valves in series with a locked closed, deenergized motor operated.valve.The motor operated valve is leak tested along with a leak test conducted on the check valves in series.An evaluation.
has been initiated.
to determine if this is a discrepancy.
The resolution, to be provided.prior to August.1, 1989, will either involve further clarification to Technical Specifications, further clarification of this submittal or a commitment to a future modification.
3906050144 8'F0523 PDR AGOCK 05000244 P PDC Generic Letter 89-04, Attachment 1-Position 11 identifies examples of valves and pumps or valve groups that have generally and erroneously been omitted from IST programs.Such items are included in the program as Management directed upgrades or from a good Engineering practice standpoint, when they are applicable to RGGE's System Selection Criteria.The following EGGG response numbers documented in our submittal dated December 20, 1988 substantiate the exclusion of some of these examples from the IST Program.Position 11 reference EG&G Response Number Control Room Chilled Water Accumulator MOVs/Vents Auxiliary Przr Spray Boric Acid Transfer Pumps Valves in Emergency Borate Flowpath H-2 E-10 B-1 B-7;2-7 B-7;2-7 Since our December 20, 1988 response to the 99 EGGG questions provided in your June 21, 1988 letter to Mr.R.W.Kober, a change in our response to Questions B-2, B-5, D-4, E-3, E-5, F-4, L-1, P-6 and P-9 has occurred.as follows: The B-2 and B-5 responses indicated that valves 204A, 427 and 820 were to be tested as either pressure or containment isolation valves.With the reclassification of letdown isolation valves 200A, 200B, 202 to serve as both pressure and containment isolation functions, valves 204A, 427 and 820 are not required to be included.in the IST program.The D-4 response indicated that full stroke.exercising flow rates for CCW valves 723A and B was 2500 GPM.Subsequent evaluation indicates that these valves will be partial stroke tested.to 2500 GPM quarterly and.full stroke tested.to 2980 GPM at cold shutdown.This is due to system configuration and test methods available at power.The E-3 response indicated full stroke exercise for SI pump discharge check valves 870A, 870B, 889A 6 889B would occur during cold shutdowns.
Due to low temperature overpres-surization concerns for the reactor coolant system, a refueling frequency is now proposed consistent with relief request VR-11.The E-5 response indicated full stroke exercise for safety injection system pressure isolation valves 878G and 878J would occur during cold shutdowns.
Due to low temperature overpressurization concerns for the reactor coolant system a refueling frequency is now proposed consistent with relief request VR-10.
The F-4 response indicated.
that safety injection recir-culation and, test line return valves 897 and 898 would be exercised at cold shutdown as they were blocked open during normal operation.
During the 1989 outage the air operated valves were replaced with motor operated valves permitting quarterly testing in accordance with the Code.~The L-1 response provided a test method for closure verification of Main Feedwater check valves 3992 and 3993.An alternate method, has been developed to test the valves during routine cold or refueling shutdowns involving a pressure drop verification.
This will be used in lieu of the method previously described.
For unscheduled shutdowns resulting from a plant trip, a relief request is provided.to allow deferral of testing to the next planned cold shutdown or refueling.
~The P-6 response indicated that valve 857C was a passive valve which is kept locked open with power removed.During the 1989 outage the RHR to SI system cross-connect valves were upgraded.Valve 857C is now maintained closed and is required to open for high head safety injection re-circulation.
This valve has been included in the program and will be exercised.
in accordance with the Code.~The P-9 response indicated that valve 822A had a safety function and would be added, to the revised IST program as a Category A Class boundary valve.Subsequent review has determined.
that valve 822A is not a containment isolation valve, therefore negating,its need to be included in the IST'rogram.
Consideration was given to evaluating time and resources needed for an adequate pump and.valve review to current criteria and guidelines established in Generic Letter 89-04.It was estimated that one year and, approximately 2500 man-hours, as a minimum, would be required.for existing programs.Very truly yours, Robert C.Me dy General Manager, Nuclear Production RCMhcemh114 0 C II'}}

Latest revision as of 11:25, 4 February 2020

Forwards Rev 0 to App C Inservice Pump & Valve Testing Program for 1990-1999 Interval, QA Manual for Review & Approval.Program Reviewed to Positions Delineated in Generic Ltr 89-04
ML17251A521
Person / Time
Site: Ginna Constellation icon.png
Issue date: 05/23/1989
From: Mecredy R
ROCHESTER GAS & ELECTRIC CORP.
To: Andrea Johnson
Office of Nuclear Reactor Regulation
Shared Package
ML17251A522 List:
References
GL-89-04, GL-89-4, NUDOCS 8906050144
Download: ML17251A521 (5)


Text

'.A.C:CELE RATED Dl gP BUTl ON DEM ONSTf+10N SYSTEM

,E,

'-'-t REGULATORY IANFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8906050144'OC.DATE: 89/05/23 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A. Project Directorate I-3 R

SUBJECT:

Forwards "QA Manual Ginna Station RGE App C Inservice Pump &

Valve Testing Program for 1990-99 Interval."

8 + /g 7 DISTRIBUTION CODE: A047D TITLE: OR Submittal: Inservice COPIES RECEIVED:LTR I ENCL g SIZE:

Inspection/Testing/Relief from ASME Code D NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 8 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 LA 1 0 PD1-3 PD JOHNSON,A 1 1 INTERNAL: AEOD/DSP/TPAB 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NUDOCS-ABSTRACT 1 1 FZX'1 OC/LQMB EG 1

1 0

1 OGC/HDS2 RES/DSIR/EIB 1

1 0

1 EXTERNAL: EG&G BROWN,B 1 1 EG&G ROCKHOLD,H N LPDR 1 1 NL 007 HEMMING 1 NRC PDR 1 1 NSIC 1 1 R

I S

NOTE 'IO ALL "RIDS" RECIPIEMIS:

PLEASE HELP US IO REDUCE HASTE CGNZACT THE DXX3MEÃZ CONTROL DESK I RXM Pl-37 (EZZ. 20079) KO ELIKBQQE YOUR NAME FRY DISTRIBUTION LISTS FOR DOCUMENZS YOU DONiT NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL

SZZZrZZP IIIIIIII L4il Owl ~

8K.::::

IJII Z ZSZruZ I S ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 TELEPHONC AscA coom 7ia 546.2700 May 23, 1989 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Mr. Allen Johnson PWR Pro j ect Directorate I-3 Division of Reactor Projects Washington, D.C. 20555 I/II

SUBJECT:

Inservice Pump and Valve Testing Program R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Johnson:

In accordance with requirements of 10 CFR Part 50, Section 50.55a, paragraph (g), we have enclosed the Ginna Station Inservice Pump and Valve Testing (IST) Program for the January 1, 1990 through December 31, 1999 interval for your review and approval. This program will direct surveillance requirements delineated in Technical Specifications Section 4.2 for the Inservice Pump and. Valve Testing Program. The enclosure is entitled "Appendix C Inservice Pump and Valve Testing Program for the 1990-1999 Interval." This program closely parallels the recently revised RGGE IST program for 1989 endorsed by your letter dated May 3, 1989. In accordance with 10 CFR 50.55a paragraph (g)(4)(ii), this program is based on the 1986 Edition of ASME Section XI".

The enclosed 10 year submittal was reviewed to positions delineated in Attachment 1 bf USNRC Generic Letter 89-04 issued.

on April 3, 1989'. The program complies with positions of Attachment 1 with one possible exception. Position 4 of Attachment 1 would. require two series check valves in Event V configurations to be individually tested. The Ginna. configura-tion for Safety Injection to each Reactor Coolant System Hot Leg contains two series check valves in series with a locked closed, deenergized motor operated. valve. The motor operated valve is leak tested along with a leak test conducted on the check valves in series. An evaluation. has been initiated. to determine is a discrepancy. The resolution, to be provided. prior to August.

if this 1, 1989, will either involve further clarification to Technical Specifications, further clarification of this submittal or a commitment to a future modification.

3906050144 8'F0523 PDR AGOCK 05000244 P PDC

Generic Letter 89-04, Attachment 1 Position 11 identifies examples of valves and pumps or valve groups that have generally and erroneously been omitted from IST programs. Such items are included in the program as Management directed upgrades or from a good Engineering practice standpoint, when they are applicable to RGGE's System Selection Criteria. The following EGGG response numbers documented in our submittal dated December 20, 1988 substantiate the exclusion of some of these examples from the IST Program.

Position 11 reference EG&G Response Number Control Room Chilled Water H-2 Accumulator MOVs/Vents E-10 Auxiliary Przr Spray B-1 Boric Acid Transfer Pumps B-7; 2-7 Valves in Emergency Borate B-7; 2-7 Flowpath Since our December 20, 1988 response to the 99 EGGG questions provided in your June 21, 1988 letter to Mr. R.W.

Kober, a change in our response to Questions B-2, B-5, D-4, E-3, E-5, F-4, L-1, P-6 and P-9 has occurred. as follows:

The B-2 and B-5 responses indicated that valves 204A, 427 and 820 were to be tested as either pressure or containment isolation valves. With the reclassification of letdown isolation valves 200A, 200B, 202 to serve as both pressure and containment isolation functions, valves 204A, 427 and 820 are not required to be included. in the IST program.

The D-4 response indicated that full stroke. exercising flow rates for CCW valves 723A and B was 2500 GPM. Subsequent evaluation indicates that these valves will be partial stroke tested. to 2500 GPM quarterly and. full stroke tested.

to 2980 GPM at cold shutdown. This is due to system configuration and test methods available at power.

The E-3 response indicated full stroke exercise for SI pump discharge check valves 870A, 870B, 889A 6 889B would occur during cold shutdowns. Due to low temperature overpres-surization concerns for the reactor coolant system, a refueling frequency is now proposed consistent with relief request VR-11.

The E-5 response indicated full stroke exercise for safety injection system pressure isolation valves 878G and 878J would occur during cold shutdowns. Due to low temperature overpressurization concerns for the reactor coolant system a refueling frequency is now proposed consistent with relief request VR-10.

The F-4 response indicated. that safety injection recir-culation and, test line return valves 897 and 898 would be exercised at cold shutdown as they were blocked open during normal operation. During the 1989 outage the air operated valves were replaced with motor operated valves permitting quarterly testing in accordance with the Code.

~ The L-1 response provided a test method for closure verification of Main Feedwater check valves 3992 and 3993.

An alternate method, has been developed to test the valves during routine cold or refueling shutdowns involving a pressure drop verification. This will be used in lieu of the method previously described. For unscheduled shutdowns resulting from a plant trip, a relief request is provided. to allow deferral of testing to the next planned cold shutdown or refueling.

~ The P-6 response indicated that valve 857C was a passive valve which is kept locked open with power removed. During the 1989 outage the RHR to SI system cross-connect valves were upgraded. Valve 857C is now maintained closed and is required to open for high head safety injection re-circulation. This valve has been included in the program and will be exercised. in accordance with the Code.

~ The P-9 response indicated that valve 822A had a safety function and would be added, to the revised IST program as a Category A Class boundary valve. Subsequent review has determined. that valve 822A is not a containment isolation valve, therefore negating,its need to be included in the IST'rogram.

Consideration was given to evaluating time and resources needed for an adequate pump and. valve review to current criteria and guidelines established in Generic Letter 89-04. It estimated that one year and, approximately 2500 man-hours, as a was minimum, would be required. for existing programs.

Very truly yours, Robert C. Me dy General Manager, Nuclear Production RCMhcemh114

0 C

II'