ML20195C018

Second Ten-Yr Resubmittal Pump & Valve Inservice Testing Program

ML20195C018
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/20/1988
From:	ARKANSAS POWER & LIGHT CO.
To:
Shared Package
ML20195C007	List: 1CAN108809, Forwards Updated,Second 10-yr Resubmittal Pump & Valve Inservice Testing Program, for Review ML20195C018
References
EWP880116, NUDOCS 8811020293
Download: ML20195C018 (79)

Text

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ARKANSAS P0k'ER & LIGHT COMPANY ARKANSAS NUCLEAR ONE LHIT ONE SECOND TEN YEAR RESUBMITTAL PUMP AND VALVE INSERVICE TESTING PROGRAM EkT880116 8811020293 881020 PDR ADOCK 05000313 P PDC

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. . EWP880116 TABLE OF CONTENTS SECTION PAGE I. Philosophy............................................. 1 II. Valve Testing.......................................... 2 A. Table A - Unit 1 Valves Requiring Inservice Testing 5 III. Pump Testing........................................... 25 A. Table B - Unit 1 Pumps Requiring Inservice Testing. 26 IV. Relief Requests........................................ 27 A. Generic Relief Requests........................... 28 B. Valves Requiring Relief Requests.................. 33 C. Pumps Requiring Relief Requests................... 54 V. Cold Shutdown Justifications........................... 57 A. Valves Requiring Cold Shutdown Justifications..... 58

vI. Attachments............................................ 76 A. List of P&ID's of ANO Safety-Related Systems...... 76 B. Description of Significant Changes to the Ten Year l

Submitta1......................................... 77

EWP880116 I. PHILOSOPHY l The Arkansas Nuclear One Unit 1 (ANO-1) Pump and Valve Inservice i Testing (IST) Program has been developed to meet the requirements of 10 CFR 50 Section XI of the ASME Boiler and Pressure Vessel Code (the Code), and the ANO-1 Technical Specifications. The purpose of the IST Program is to detect a change in the operating status of equipwent based upon a comparison of ba seline data (obtained during initial t testing or after equipment ovithaul) and the data obtained during the performance of periodic testit g, and to initiate corrective action when necessary.

ANO-1 Technical Specification 4.0 requires that "inservice inspection

of ASME Code Class 1, 2, 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to j 10 CFR 50, Section 50.55a(g)(6)(i)."

10 CFR Part 50, Section 50.55a(g)(4)(iv) states that "... tests of pump and valves ... may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) (Section 59.55a(b)) of this section, subject to the limitations and modifications listed in paragraph (b) of this section, and subject to Commission approval." The ANO-1 Section XI program is in accordance with tne 1980 edition and addenda through the Winter 1981 Addenda. In accordance with these requirements,' Arkansas Power & Light Company will perform inservice testing of the ANO-1 pumps and valves identified herein using IWP and IWV sections of the referenced edition and addenda of the Code.

A review of ANO-1 safety documents (e.g., the FSAR and Technical Specifications) and plant drawings (see Attachment VI), was conducted to identify those pumps and valves which are subject to the Code requirements (i.e., perform a specific function in shutting down the reactor o.e mitigat. the consequences of an accident). Where practical, the components are incorporated into the ANO-1 IST program and will be tested in accordance with the 1980 Edition of the Code (through Winter 1981 Addenda). If testing is impractical due to design or operating limitations, cold shutdown testing or relief from Code requirements is requested and alternate testing methods are proposed. (See Sections IV and V).

Operational and Surveillance Test Procedures have been established to govern the IST Program an ANO. The Engineering Services Group at ANO is responsible for monitoring the IST Progran and the ANO-1 Operations staff is responsible for performing the periodic surveillance tests prescribed by the IST Program.

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EWP880116 II. VALVE TESTING Subsection IWV of ASHE Section XI provides the rules and requirements for inservice testing to verify operational readiness of csrtain Class 1, 2 and 3 valves (i.e. , those valves which are required f.o perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident). The purpose of the IST valve program is to identify those valves subject to Code requirements and, subsequently, to test them according to the applicable Code requirements. The valves which are covered by the IST Program are listed in Table A.

Relief requests for valves subject to Code testing are detailed in Section IV. Cold Shutdown Justifications for Inservice Tests Valves are detailed in Section V.

The following is a brief explanation of the table headings:

Valve Number - Identification number of each valve.

System - The system to which the valve belongs.

Description - A brief description of the function of the valve.

Type - The type of valve (e.g., gate. globe, etc.)

IWV Category - Valve category classificatior. according to subsection IWV of ASME Section XI.

P&ID/ Sheet # - The P&ID and sheet # that shows the valve.

Coordinates - The coordinates show the position of the valve on the P&ID.

Passive or Active - This shows if the valve is active or passive as defined in IWV-2100. The "A" in this column designates an active valve while "P" designates a passive valve.

Normal Position - The normal position defines the position the valve is in during normal power operations. The "C" in this column refers to a normally closed valve while an "0" designates a normally open valve.

Testing Performed - The testing that is performed on the valve.

Testing Frequency - The frequency that testing is performed on the valve.

Comments - Any relief request or cold shutdown justification are noted in this column.

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EWP880116 The following is a brief explanation of abbreviations:

Aux C1g - Auxiliary Cooling BS - Building Spray Btfly - B'!tterfly BW - Borated Water BVST - Borated Water Storage Tank CF - Core Flood CK - Check Valve Clr. - Cooler CS - Condensate System CSD - Cold Shutdown CSJ - Cold Shutdown Justification CV - Control Valve CV - Chilled Water CZ - Clean Liquid Radwa,.it l DH - Decay Heat Disc - Discharge l

DVD - Dirty Waste Drain EDG - Emergency Diesel Generator EFW - Emergency Feedwater Emerg. - Emergency FO fuel Oil FW - Feedwater

• GZ - Waste Gas Radwaste HP - High Pressure HSD - Hot Shutdown HVAC - Heating, Ventilation and Air Conditioning 3

E

EWP880116 IA - Instrument Air I/C - Inside Containment.

ICW - Intermediate Cooling Water Iso - Isolation LO - Lube Oil LP - Low Pressure MOV - Motor Operated Valve MS - Main Steam MU - Make Up N/A - Not Applicable NaOH - Sodium Hydroxide Na - Nitrogen 0/C - Outside Containment PSV - Pressure Safety Valve PZR - Pressurizer Q - Quarterly RB - Reactor Building RCP - Reactor Coolant Pump RCS - Reactor System Rm - Room RR - Relief Request SF - Spent Fuel SG - Sluice Gate SS - Sampling System SV - Service Water SV - Solonoid Valve TK - Tank VSF - Ventilation Supply Fan 4

._ _- _ _ - - - _ . - . . - . - _ . - ... -- . . - _ _ _ _ -= __ -_ _ _ - . .

EWP880115 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pcge 1 of 20 PASSIVE IWV P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS M236 BS-4A BS Pump Discharge Check C SH1 F6 A C Stroked Refueling RR-17 M236 BS-4B BS Pump Discharge Check C SH1 F6 A C Stroked Refueling RR-17 Stop M231 BW-2 BW MU Pump Suction Check C SH1 B3 A O/C Stroked Refueling RR-14 Stop M2.s1 BW-3 Bk' MU Pump Suction Check C SH1 E3 A O/C Stroked Refueling RR-14 M232 BV-4A BW BWST Outlet Check C SH1 D2 A C Stroked Refueling RR-16 .

M232 BW-4B BW BWST Outlet Check C SHI D2 A C Stroked Refueling RR-1(

M236 BV-6A BS Pump Suction Check C SH1 F2 A C Stroked Q M236 rl-6B BS Pump Suction Check C SHI F2 A C Stroked Q Stop M232 t'A-61 CA NaOH Discharge Check C SH1 DI A C Stroked Refueling RR-25 Stop M232 CA-62 CA NaGil Discharge Check C SH1 D2 A C Stroked Refueling RR-25 Core Flood M230 Stroked Refueling RR-6 CF-1A RCS Discharge Check C SH1 F5 A C Leak Test CSD Core Flood M230 Stroked Refueling RR-6 CF-1B RCS Discharge Check C SH1 F4 A C Leak Test CSD EFW M204 CS-98 EFW from CST Check C SH3 11 6 P C Leak Test Q RR-29 EFW M204 CS-99 EW from CST Check C SH3 D6 P C Leak Test Q RR-29 l

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J EWP880116 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTfNG Page 2 of 20 PASSIVE IW P&ID OR NORMAL TESTING TEST -

VALUE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINA'ES ACTIVE FOSITION PERFORM FREQUENCY C0tefENTS EFW M204 CS-261 EW from CST . Check C SH3 D6 P C Leak Test Q RR-29 EFW M204 CS-262 EW from CST Check C SH3 D6 P C Leak Test Q RR-29 EW M204 CS-293 UV from CST Check C SHS D8 A C Stroked Q RR-23 EFW M204 CS-294 EW from CST Check C SHS D8 A C Stroked Q RR-23 ERV Block M230 Leak Test HSD CV-1000 RCS Velve Gate A SH1 G5 A O/C Stroked Q DH Removal M230 Leak Test CSD CV-1050 DH from RCS Cate A/B SHI E5 A C Stroked CSD CSJ-9 Quench M230 Leak Test Refueling CV-1052 CZ Tank Drain Gate A SH2 A6 A C Stroked Q Quench M230 Leak Test Refueling CV-1053 CZ Tank Drain Gate A SH2 A6 A C Stroked Q Quench M230 Leak Test Refueling CV-1054 SS Tank Sample Gate A SH2 B6 A C Stroked Q Quench M230 Leak Test Refueling CV-1065 CS Tank Iso Gate A SH2 C4 A C Stroked Q M231 Leak Test Eefueling CV-1214 MU RCS Letdown Gate A SH1 G7 A O Stroked Q M231 Leak Test Refueling CV-1216 MU RCS Letdown Gate A SH1 G7 A O Stroked Q M231 CV-1219 MU HP Jnjection Gate B SHI E7 A C Stroked Q M231 CV-1220 MU HP Injection Gate B SHI D7 A C Stroked Q 6

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EWP880116 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pege 3 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIP. ION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM ~ FREQUENCY COMMENTS M231 Leak Test Refueling CV-1221 MU RCS Letdown Gate A SH1 G6 A O Stroked Q M231 CV-1227 MU HP Injection Gate B SH1 B6 A C Stroked Q M231 CV-1228 MU HP Injection Gate B SH1 A6 A C Stroked Q M231 CV-1234 MU RCS Makeup Gate B SH1 D6 A O Stroked Q RCP Seal M231 Leak T?st Refueling CV-1270 MU Bleed Off Gate A SH2 E6 A O Stroked CSD CSJ-7 RCP Seal M231 Leak Test Refueling CV-1271 MU Biced Off Gate A SH2 F6 A O Stroked CSD CSJ-7 RCP Seal M231 Leak Test Refueling CV-1272 MU Bleed Off Gate A SH2 C6 A O Stroked CSD CSJ-7 RCP Seal M231 Leak Test Refueling CV-1273 MU Bleed Off Gate A SH2 H6 A O Stroked CSD CSJ-7 RCP Seal M231 Leak Test Refueling CV-1274 MU Bleed Off Gate A SH1 F6 A O Stroked CSD CSJ-7 M231 CV-1300 MU MU Pump Recirc Gate B SH1 F5 A O Stroked CSD CSJ-8 M231 CV-1301 MU MU Pump Recirc Cate B SH1 ES A O Stroked CSD CSJ-8 M232 CV-1400 DH Pump Isolation Gate B SH1 G6 A C Stroked Q M232 CV-1401 DH Pump Isolation Gate B SH1 F6 A C Stroked Q Dli Remova1 M232 CV-1404 DH from RCS Gate B SH1 B6 A C Stroked Q 7

. EWP880116 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Page 4 of 20 PASSIVE IWV P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRII'IION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS M232 CV-1405 DH Sump Suction Gate B SH1 C6 A C Stroked Q M232 CU-1406 Dil Sump Suction Gate B SHI B6 A C Stroked Q M232 CV-1407 Dit ifWST Outlet Gate B SHI F2 A C Stroked Q M232 CV-1408 DH EWST Outlet Gate B SHI F2 A C Stroked Q DH Removal .M232 Leak Test CSD CV-1410 DH from RCS Gate A/B SHI D7 A C Stroked CSD CSJ-9 "A" Dil Pump RB M232 CV-1414 DH Sump Suction Gate B SH1 C7 A O Stroked Q "B" DH Pump RB M232 CV-1415 DH Sump Suction Gate B SH1 B8 A O Stroked Q NaOH Tank M233 CV-1616 CA Outlet Gate B SH1 E2 A C Stroked Q NaOH Tank M233 CV-1617 CA Outlet Gate B SH1 El A C Stroked Q L.P. M233 Leak Test Refueling CV-1667 N2 N2 Supply Gate A SHI D4 A C Stroked Q PZR M237 CV-1814 SS Steam Sampic Gate B SHI G7 A C Stroked Q PZR M237 CU-1816 SS Water Sample Gate B SHI F7 A C Stroked Q Quench M237 Leak Test Refueling CV-1845 SS Tank Sample Gate A SH1 A7 A C Stroked Q Letdown M234 Leak Test Refueling CV-2214 ICV Cooler Iso Cate A S 11 2 A6 A O Stroked CSD CSJ-13 8

1 EWP880116 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING P ge 5 ef 23 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQLINCY COMMENTS Letdown M234 Leak Test Refueling CV-2215 ICW Cooler Iso Cate A SH2 F6 A O Stroked CSD CSJ-13 CRD/RCP M234 Leak Test Refueling CV-2220 ICV Cooling Iso Gate A SHI H4 A O Stroked CSD CSJ-14 l CRD/RCP M234 Leak Test Refueling CV-2221 ICW Cooling Iso Cate A FH1 H5 A O Stroked CSD CSJ-14 Irtdown M234 Leak Test Refueling CV-2233 ICW Cooler Iso Cate A SH2 C4 A O Stroked CSD CSJ-13 RCP M234 Leak Test Refueling CV-2234 1CW Motor Iso Gate A SHI E6 A O Stroked CSD CSJ-14 M234 Leak Test Refueling CV-2235 ICW CRD Iso Gate A SHI ES A O Stroked CSD CSJ-14 M236 CV-2400 BS RB Spray MOV Globe B SH1 F5 A C Stroked Q M236 CV-2401 ES RB Spray MOV Globe B SHI F5 A C Stroked Q P-7A Steam M202 CV-?613 EFW Admission Gate B SHI G7 A C Stroked Q Main Steam to M206 CV-2617 MS EFW Turbine Gate B SHI H3 A O Stroked Q P-7A Isolation M204 CV-2620 EFW to "B" SG Gate B SH3 C2 A O Stroked Q P-7B Isolation M204 CV-2626 EFW to "B" SG Gate B SH3 D2 A O Stroked Q P-7A Isolation M204 CV-2627 EFW to "A" SG Gate B SH3 F2 A O Stroked Q M206 CV-2630 FW "B" MFW Isol. Gate B SHI D2 A O Stroked CSD CSJ-17 9

EWP880116 i

TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING P.cge 6 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTIOs TYPE CAT SHEET # COORDINATES ACTIVE PCSITION PERFORM FREQUENCY COM'fENTS P-7A to "A" CV-2645 EIV Steam Gen. M204 l Control Viv Globe B SH3 F3 A O Stroked Q RR-10 P-7B to "A" CV-2646 EW Steam Gen. M204 Control Vlv Globe B SH3 G3 A O Stroked Q RR-10 P-7A to "B" CV-2647 EW Steam Gen. M204 Control Viv Globe B SH3 C3 A O Stroked Q RR-10 P-7B to "B" CV-2648 EW Steam Gen. M204 Control Viv Globe B SH3 D3 A O Stroked Q RR-10 P-7A Steam M202 CV-2663 EW Admission Cate B SH1 G7 A C Stroked Q Main Steam to M206 CV-2667 MS EIV Turbine Gate B SH1 H6 A O Stroked Q P-7B Isolation M204 CV-2670 EW to "A" SC Gate B SH3 G2 A O Stroked Q M206 CV-2680 IV "A" MW Isol . Cate B SH1 D7 A O Stroked CSD CSJ-17 Main Steam M206 CV-2691 MS Isolation Gate B SHI H5 A O Stroked CSD CSJ-5 Main Steam M206 CV-2692 MS Isolation Gate B SHI H4 A O Stroked CSD CSJ-5 P-7B Suction M204 CV-2800 EW from CST Cate E SH3 F7 A O Stroked Q P-7A Suction M204 CV-2802 EW from CST Cate B SH3 C7 A O Stroked Q P-7B Suction M204 CV-2803 EW from SV Gate B SH3 H7 A C Stroked Q 10

EWP880113 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pcge 7 cf 23 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS P-7A Suction M204 CV-2806 EFW from SW Gate B SH3 B7 A C Stroked Q P-7B Test  !!204 CV-2869 EFW Recire Iso Cate B SH3 F3 A C Stroked Q P-7B Test M204 CV-2870 EW Recirc Iso Cate B SH3 E3 A C Stroked Q Cross-tie SW M209 CV-3640 SW B to C Disc. Btily B SH1 E7 A O Stroked Q M239 CV-3641 SW Loop II Iso. Btily B SH1 F7 P O Stroked CSD CSJ-11 Cross-tie Sw M209 CV-3642 SW B to C Disc. Btfly B SHI E7 A O Stroked Q Aux CIg M209 CV-3643 SV Loop Iso Btfly B SH1 E7 A O Stroked CSD CSJ-10 Cross-tie Sw M209 CV-3644 SW A to F Disc. Btily B SH1 E7 A O Stroked Q M209 CV-3645 SW Loop I Iso Btfly B SHI D7 P O Stroked CSD CSJ-11 Cross-tic SW M209 CV-3646 SW A to B Disc Btily B SHI D7 A O Stroked Q E47A i CV-3804 SW Spray Pump Gate B M210 Inlet Valve SH1 F8 A C Stroked Q E47B CV-3805 SW Spray Pump Gate B M210 l Inlet Valve SHI E8 A C Stroked Q 1

i Emerg. Diesel M210 CV-3806 SW "A" Clr. Inlet Gate B SH1 F5 A C Stroked Q 11 i

_ _ . _ . _ . _ _ . - ~ _ . - . . . _ . , . . _ . _ - . _ _ _ _ - _- , _ .

EWP880116 TABLE A IJNIT I VALVES REQUIRING INSERVICE TESTING Page 8 of 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS Emerg. Diesel M210 CV-3807 SW "B" Clr. Inlet Gate B SHI ES A C Stroked Q SW Loop II M210 CV-3811 SW Iso to ICW Btfly B SHI 11 4 A 0 Stroked Q RB Cooler M210 CV-3812 SW SW Inlet Btfly B SHI C4 A C Stroked Q RB Cooler M210 CV-3813 SW SW Inlet Btfly B SHI B4 A C Stroked Q RB Cooler M210 CV-3814 SW SW Outlet Btfly B SHI D3 A C Stroked Q l RB Cooler F.210 l CV-3815 SW SW Outlet Btfly B SHI B2 A C Stroked Q SV Loop I M210 CV-3820 SW Iso to ICW Btfly B SHI 11 3 A O Stroked Q l

"B" DH Clr M210 CV-3821 SW Inlet Btfly B SHI  !!8 A C Stroked Q l "A" DH Clr M210 l CV-3822 SW Inlet Btfly B SHI 11 8 A C Stroked Q Combined SW Discharge M210 CV-3823 SW SW to Pond Btfly B SHI A5 A C Stroked 0 Combined SW Loop Disch. M210 CV-3824 SW to Flume Btfly B SHI E2 A 0 Stroked Q "A" Dil Lube Oil M210 CV-3840 SW Cooler Inlet Gate B SHI C8 A C Stroked Q "B" Dil Lube Oil P210 CV-3841 SW Cooler Inlet Gate B SHI D8 A C Stroked Q 12

- _ _ - _ _ . - -- - _ -- - _-_ _ ._.___ . _. - . . - - = _

l EWP880116 TABLE A 1

UNIT I VALVES REQUIRING IJSERVICE TESTING Page 9 of 23

PASSIVE

IW P&lD OR NORMAL TESTING TEST j VALVE NO. SYSTEM DESCRIITION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS EFW Suction M204

. CV-3850 EFV from SW Ioop I Cate B SH3 H8 A C Stroked Q EFW Suction from 11204

CV-3851 EFW SV Loop II Cate B SH3 A8 A C Stroked Q j O/C RB M213 Leak Test Refueling j CV-4400 DVD Sump Drain Gate A SH1 HS A C Stroked Q I/C RB M213 Leak Test Refueling CV-4446 DWD Sump Drain Gate A SHI H5 A C Stroked Q q RB Vent to M215 Leak Test Refueling i CV-4803 GZ Gaseove Waste Gate A SHI H7 A C Stroked Q RB Vent to M215 Leak Test Refueling

]' CV-4804 GZ Casecus Vaste Gate A SHI G6 A C Stroked Q Air Start M217

CV-5218 EDG Iso. Valve Plug B SH1 D3 A C Stroked Q j Air Start M217

! CV-5233 EDG Iso. Valve Plug B SH1 D3 A C Stroked Q 1

Air Start M217 CV-5237 EDG Iso. Valve Plug B SHI D1 A C Stroked Q Air Start M217 CV-5?19 EDG Iso. Valve I' lug B SHI D1 A C Stroked Q

' ~ ~

M219 Leak Test Refueling CV-5611 Fire RB Iso Cate A SHi E5 A C Stroked Q M219 Leak Test Refueling CV-56?" Fire RB Iso Cate A SH1 D6 A C Stroked Q M222 Leak fest Refueling CV-6202 CW Inlet Iso Gate A SH1 F5 A 0 Stroked CSD CSJ-15 M222 Leak Test Refueling CV-6203 CW Outlet Iso Gate A SH1 F5 A O Stroked CSL CSJ-15 13

_ . = _ . . - .

EWP880115 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pmge 10 of 23

~

PASSIVE IW P&ID OR NOPMAL TESTINC TELT VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITICN PERFORM FREQUENCE COMMFSTS

~

M222 Leak Test. Refueling CV-6205 CW Outlet Iso Gate A SHI F5 A O Stroked CSD CSJ-15 RB Purge M261 Leak Tert Refueling CV-7401 IIVAC Air O/C Btfly A SH1 D6 A C Stroked CSD CSJ-16 RD t rge M261 Leak Test Fafueling CV-7402 IIVAC Air */C Btily A SHI D6 A C Stroked CSD CSJ-16 RB Purge M261 Leak Test Refueling CV-7403 IIVAC Air I/C Btfly A SHI D6 A C Stroked CSD CSJ-16 RB Parge M261 Leak Test Refueling CV-7404 ffVAC Air I/C Btfly A Sill D6 A C Stroked CSD CSJ-16 O/C cydrogen M261 Leak Test Refueling CV-7443 IIVAC Purge Gate A SH1 D6 P C I/C llydrogen M261 Leak Test Refueling CV-7444 IIVAC Purge Cate A Sill F6 A O Stroked Q 0/C !!ydrogen M261 Leak Test Refueling CV-7445 HVAC Purge Gate A SH1 F6 P C I/C llydrogen M261 Leak Test Refueling CV-7446  !!VAC Purge Gate A SH1 F6 A O Stroked Q 0/C !!ydrogen M261 Leak Test Refueling CV-7447 IIVAC Purge Gate A SH1 F6 P C I/C Ilydrogen M261 Leak Test Refueling CV-7448 HVAC Purge Gate A SH1 F6 A O Stroked Q O/C Hydrogen M261 Leak Test Hefueling CV-7449 INAC Purge Gate A S!Il F6 P C 1/C !!ydrogen M261 Leak Test Refueling CV-7450 IIVAC Purge Gate A SH1 F6 A O Stroked Q Air Particulate M261 Leak Test Refueling CV-7453 KVAC I/C Monitor Gate A Sill G4 A O Stroked Q 14 l

EWP880115  ;

TABLE A

UNIT I VALVES REQUIRING INSERVICE TESTING Pcge 11 of 20 PASSIVE IW P&ID OR NORMAL TESTI!;G TEST VALVE NO. SYSTEM DESCRIPTION TTPE CAT SHEZT # COORDINATES ACTIVE POSITION PERFORM FREQUENCT COMMENTS R.B. Backdraft M261 CV-7470 IIVAC Damper Btfly B SH1 C5 A 0 Stroked Q i

R.B. Backdraft M261 CV 7471 HVAC Damper Btily B SH1 C5 A 0 Stroked Q R.B. Backdraft M461 CV-7472 HVAC Damper Btfly B SHI C4 A O Stroked Q R.B. Backdratt M261 CV-7473 HVAC Damper Btily B SHI C4 A O Stroked Q M232 D!l-2A DH Pump Discharge theck C SH1 C5 A C Stroked Q M232 DH-2B DH Pump Discharge Check C SH1 C3 A C Stroked Q M230 Leak Test CSD RR-8 DH-13A RCS LP Injection Check A/C SH1 F5 A C Stroked Refueling RR-8 M230 Leak Test CSD RR-8 DH-13B RCS LP Injection Check A/C SH1 F4 A C Stroked Refueling P.R-8 M230 Leak Test CSD DH-14A RCS LP Injection Check A/C SH1 E5 A C Stroked Refueling RR-7 M230 Leak Test CSD DH-14B RCS LP Injection Check A/C 5311 E4 A C Stroked Refueling RR-7 M230 Leak Test CSD RR-8 DH-17 RCS LP Injection Cineck A/C SHI F4 A C Stroked Refueling RR-8 l

l M230 Leak Test CSD RR-8 l DH-18 RCS LP Injection Check A/C SH1 F4 A C Stroked Refueling RR-8 Air Start Comp. M217 I FO-54A1 EDG C4A1 Disch. Ck. Check C SHI F's A C Stroked Refueling RR-26 l

1 l

l 15 l

l l

l

- - - - . . _ - - - - _ . - - - - - . - - - . _ , - - . - - ~ . - - - - - - . - - - - - - - . . _ - - -

EWP88011's ~m TABLE A UNIT I VALVES REQUIRICG INSERVICE TESTING Pege 22 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCT CGMMENTS Air Start Comp. M217 FO-54A2 EDG C4A2 Disch. Ck. Check C SHI F3 A C Stroked Refueling RR-26 Ai r Sta rt Comp. M217 FO-54BI EDG C4B1 Disch. Ck. Check C SHI F1 A C Stroked Refueling RR-26 Air Start Comp. M217 FO-54B2 EDG C4B2 Disch. Ck. Check C SH1 F1 A C Stroked Refueling RR-26 T31 Al M217 FO-55A1 EDG Inlet Ck. Check C SHI F3 A C Stroked Refueling RR-26 T31 A3 M217 FO-55A2 EDG Inlet Ck. Check C SHI E3 A C Stroked Refueling RR-26 T31 B2 M217 FO-55B1 EDG Inlet Ck. Check C SHI El A C Stroked Refueling RR-26 T31 B3 M217 FO-55B2 EDG Inlet Ck. Check C SHI El A C Stroked Refueling RR-26 P16A M217 FO-BA EDG Disch Ck. Check C SHI C5 A C Stroked Q P16B M217 FO-8B EDG Disch. CF. Check C SH1 C7 A C Stroked Q M206 Leak Test CSD l FW-7A FW MFW to "A" SG Check SHI E7 A O Stroked CSD CSJ-18 M206 Leak Test CSD FW-7B FW MFW to "B" SG Check C SH1 E2 A O 3troked CSD CSJ-18 P-7A discharge /

FW-10A EFW Minimum Recirc M204 Valve Check C SH3 B4 A NA Stroked Q RR-18 P-78 discharge /

FW-10B EFW Minimum Recirc M204 Valve Check C SH3 G4 A NA Stroked Q RR-18

! 16

%w EWP88011') M s TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pege 13 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIST. POSITION PERFORM FREQUENCY COMMENTS M204 W-13A EW EW to "A" SG Check C SH3 G1 A C Stroked Refueling RR-20 M204 W- 13B EW EW to "B" SG Check C SH3 C1 A C Stroked Refueling RR-20 P-7A to "B" M204 Leak Test Q W-55A EW Steam Gen. Check C SII3 C3 A C Stroked Q P-7A to "A" M204 Leak Test Q W-55B EW Steam Gen. Check C SH3 F2 A C Stroked Q P-7B to "A" M204 Leak Test Q fv-56A EW Steam Gen. Check C SH3 G3 A C Stroked Q P-iB to "B" M204 Leak Test Q W-56B EW Steam Gen. Check C SH3 D3 A C Stroked Q P-7A Minimus M204 W-61 EW Recirc Vlv Check C SH3 C4 A C Stroked Q RR-21 P-7B Minimum M204 W-62 EW Recire Viv Check C SH3 G4 A C Stroked Q RR-21 1A to IIRT M218 IA-52 IA Cart Globe A SH4 F4 P C Leak Test Refueling "B" MS to M206 MS-271 MS P-7A Turbine Check C SHI 11 6 A C Stroked Refueling RR-22 "A" MS to M206 MS-272 MS P-7A Turbine Check C SH1 11 6 A C Stroked Refueling RR-22 Makeup Tk. M231 MU-13 MU Outlet Stop Ck. Check C SH1 B3 A O Stroked Q CSJ-6 M231 MU-19A MU Pump Discharge Check C SHI C5 A O/C Stroked Refueling R*.-12 M231 MU-19B MU Pump Discharge Check C SH1 B4 A O/C Stroked Refueling RR-12 17

r EWP883116 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Page 14 of 20 PASSIVE IW P&ID OR NORMAI. TESTING TEST UALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMEhTS M231 MU-19C MU Pump Discharge Check C SHI A4 A O/C Stroked Refueling RR-12 P36A kecire. M231 MU-22A MU Ck. Valve Check C SHI C4 A 0/C Stroked Refueling RR-15 P36B Retire. M231 MU-22B MU Ck. Valve Check C SHI B4 A O/C Stroked Refueling RR-15 P36C Recire. M231 MU-22C MU Ck. Valve Check C SH1 B4 A O/C Stroked Refueling RR-15 M230 MU-34A RCS HP Injection Check C SH1 B4 A O/C Stroked Refueling RR-11 M230 MU-34B RCS HP Injection Check C SHI B4 A O/C Stroked Refueling RR-11 M230 MU-34C RCS HP Injection Check C SH1 BS A O/C Stroked Refueling RR-11 M230 MU-34D RCS HP Injection Check C SHI B5 A O/C Stroked Refueling RR-11 M231 MU-1211 MU HP Injection Check C SHI E7 A C Stroked Refueling RR-13 M231 MU-1212 MU HP Injection Check C SH1 D7 A C Stroked Refueling RR-13 M231 MU-1213 MU HP Injection Check C Sill D7 A C Stroked Refueling RR-13 M231 MU-1214 MU In' Injection Check C SH1 B6 A C Stroked Refueling RR-13 M231 MU-1215 MU HP Injection Check C SH1 A6 A C Stroked Refueling RR-13 18

EWP88011's TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING Pcge 15 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTLtf DESCRIPTION TYPE CAT SHEET # COORDINATES ACTIVE POSITIGN PERFORM FREQUENCY COMMENTS Rs. Vessel Isternal Vent Valves A C Stroked Ref eling RR-9 NA RCS (Quantity:8) Check C Elect Relief Solenoid PSV-1000 RCS Valve (ERV) Operated B M230 Relief SHI G8 A C Stroked Refueling CSJ-4 M230 PSV-1001 RCS Pzr Relief Ralief C SHI G7 A C Relief M230 PSV-1002 RCS Pre Relief Relief C SH1 G5 A C Relief INST M232 PSV-1412 EW Rc!ief Relief C SHI H2 A C Relief Main Steam M206 PSV-2684 MS Relief Relief C SH1 G3 A C Relic.'

Main Steam M206 PSV-2685 MS Relief Relief C SHI G3 A C Relief Main Steam M206 PSV-2686 MS Relief Rel a,ef C SHI G3 A C Relief Main Steam M206 PSV-2687 MS Relief Relief C SHI G3 A C Relief Main Steam M206 PSV-2688 MS Relief Relief C SHI C4 A C Relief Main Steam M206 PSV-2689 MS Relief Relief C SH1 G4 A C Relf

• f Main Steam M206 PSV-2690 MS Relief Relief C SH1 C4 A C Relief 19

EWP880110 TABLE A UNIT I VALVE 3 REQUIRING INSERVICE TESTING Page 16 of 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTD1 DESCRIPTION TYPE CAT SHEET # COORDINATT.S ACTIVE POSITION PERFORM FREQUENCY COMMENTS Main Steam M206 PSV-2691 MS Relief Relief C SH1 G4 A C Relief Main Steam M206 PSV-2692 T:S Relief Relief C SM1 G5 A C Relief Main Steam M206 PSV-2693 MS Relief Relief C S i1 G5 A C Relief Main Steam M206 PSV-2694 MS Relief Relief C SH1 G5 A C Relief Main Steam M206 PSV-2695 MS kelief Relief C SHI G5 A C Relief Main Steam M206 PSV-2696 MS Relief Relief C SH1 G5 A C Relief Main Steam M206 PSV-2697 MS Relief Relief C SHI C6 A C Relief Main Steam M206 PSV-2698 MS Relief Relief C SH1 G6 A C Relief Main Steam M206 PSV-2699 MS Relief Delief C SHI G6 A C Relief T31 A2 M21r PSV-5215 EDG Relief Relief C SHI F3 A C Relief T31 Al M217 PSV-5216 EDG Relief Relief C SH1 F3 A C Relief T31 A3 M217 PSV-5231 EDG Relief Relief C SHI F3 A C Relief l T31 A4 M217 l PSV-5232 EDG Relief Relief C SM1 F2 A C Relief l

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EWP880115 TABLE A UNIT I VALVES REQUIRING INSERVICE 17. STING Pcge 17 cf 20 PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET f COORDINATES ACTIVE POSITION PERFORM FREQLTNCf COfffENTS T31 B2 M217 PSV-5237 EDG Relief Relief C SHI F2 A C Relief T31 B1 M217 PSV-5238 EDG Relief Relief C SH1 F2 A C Relief T31 S3 M217 PSV-5240 EDG Relief Relief C SHI F1 A C Relief T31 B4 M217 PSV-5241 EDG Relief Relief C SHI FI A C Relief Incore Inst. M235 SF-42 SF Tk. RB. Iso. Cate A SHI E6 P C Leak Test Refueling Incore Inst. M235 SF-43 SF Tk. RB. Iso. Gate A SHI E6 P C Irak Test Refueling

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SF Pool TILT M235 SF-44 SF PID Iso. Cate A SHI E6 P C Leak Test Refueling SGI M209 (HS-3720) SV Sluice Gate #1 SG B SH2 G3 A O Stroked Q SG2 M209 (HS-3721) SW Sluice Gate #2 SG B SH2 G3 A O Stroked Q SG3 M209 (HS-3722) SV Sluice Gate #3 SG B SH2 G3 A O Stroked Q SG4 Pt209 (HS-3723) SW Sluice Gate #4 SG B SH2 C3 A O Stroked Q SG5 M209 (HS-3724) SW Sluice Gate #5 SG B SH2 G3 A C Stroked Q SG6 M209 (HS-3725) SW Sluice Gate #6 SG B SN2 C3 A C Stroked Q SG7 M209 (HS-3726) SW Sluice Gate #7 SG B SH2 G3 A C Stroked Q 21

___.m._ _ _ _ _ . . -.

' EWP880115 TM2 A CIT I VALVES REQUIRING ICSERVICE TESTING Page 18 of 23 l

i PASSIVE IW P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT NtEET # COORDINisTES ACTIVE POSITION PERFORM FREQLT.NCY COff!ENTS i

Reactor Head _M230 RR-10 SV-1071 RCS Vent Globe R SH2 G5 A C Stroked CSD CSJ-3 Reactor Head ~~ M230 RR-10 SV-1072 RCS Vent Globe B SH2 H5 A C Stroked CSD CSJ-3 Reactor Ecad M230 KR-10

SV-1073 RCS Vent Globe B SH2 G5 A C Stroked CSD CSJ-3

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Reactor Head M230 RR-10

! SV-1074 RCS Vent Globe B SH2 HS A C Stroked CSD CSJ-3 M230 RR-10 SV-1077 RCS PZR Vect Globe B SHI H7 A C Stroked CSD CSJ-1 M239 RR-10 l SV-1079 RCS PZR Vent Globe B SH1 G7 A C Stroked CSD CSJ-1 l "A" Loop M230 RR-10 SV-1081 RCS T H Vent G1 be B SH2 G7 A C Stroked CSD CSJ-2 "A" Loop M230 RR-10 SV-1082 RCS T Vent G1 be B SH2 G7 A C Stroked CSD CSJ-2 H

"A" Loop M230 RR-IO SV-1083 RCS T H Vent G1 he B SH2 G7 A C Stroked CSD CSJ-2

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"A" Loop M230 RR-10 SV-1084 RCS T Vent Globe B SH2 G7 A C Stroked CSD CSJ-2 H

"B" Loop M230 RR-10 SV-1091 RCS T Vent GI be B SH2 G3 A C Stroked CSD CSJ-2 h

"B" Loop M230 RR-10 S" 1092 ECS T Vect h

G1 be B SH2 G3 A C Stroked CSD CSJ-2 "B" Loop M230 RR-10 SV-1093 RCS T h en 1 A

• ro

, D W -2 "B" loop M230 RR-10 SV-1094 RCS T Vent Globe B SH2 H3 A C Stroked CSD CSJ-2 22

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, EWP880115 TABLE A UNIT I VALVES REQUIRIN'? INSERVICE TESTING Pcge 19 af 23 i PASSIVE IWV P&ID OR NORMAL TESTING TEST VALVE NO. SYSTEM DESCRIPTION TYPE CAT SHEET f COORDINATES ACTIVE POSITION PERFORM FREQUENCY COMMENTS P7A Steam M202 SV-2613 EW Admission Globe B SHI G7 A C Streked Q P7A Steam M202 SV-2663 EFW Admisstion Globe B SHI G7 A C Stroked Q Pilot Valve M217 SV-5218 EDG for CV-5218 Cate B SH1 D3 A C Stroked Q Pilot Valve M217 SV-5233 EDG for CV-5233 Cate B SHI D3 A C Stroked Q Pilot Valve M217 SV-5237 EDG for CV-5237 Cate B SHI D1 A C Stroked Q

/

l Pilot Valve M217 l SV-5239 EDG for CV-5239 Cate B SH1 D2 A C St roked Q t

! Air Particulate M261 Leak Test Refueling j SV-7454 HVAC O/C Monitor Gate A SH1 G4 A O Stroked Q RC Leak Detector M261 Leak Test Refueling j SV-7456 HVAC Return to RB Globe A Sill G3 A O Strokei Q l Pass Return M261 Icak Test Refueling SV-7510 HVAC to RB Globe A SH1 G6 A C Stroked Q j Ris Atmos M261 Leak Test Refueling SV-7512 HVAC To PASS Clobe A SH! G4 A C Stroked Q l

P4A M209 SW-IA SV Discharge Check C CHI D7 A O/C Stroked Q CSJ-12 P48 M209 l S'J- 1 B SW Discharge Check C SH1 E7 A O/C Stroked Q CSJ-12

! P4C M209

! SW-IC SV Check Discharge C SH1 F7 A O/C Stroked Q CSJ-12 23

EWP880113 TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING P ge 20 cf 20 PASSIST.

IW P&ID OR NORMAI, TESTING TEST VALVE No. SYSTEM DESCRIPTION TYPE CAT SMEET # COORDINATES ACTIVE POSITION PERIDRM FREQUENCY COMMENTS DV Suction M204 SW-il EIV from Loop I Check B SM3 H8 A C Stroked Refueling RR-19 U V Suction M204 SV-13 DV from Loop II Check B SM3 A8 A C Stroked Refueling RR-19 SW to Spent M210 SV-72 SW FucI Pool Cate B SH1 A4 A C Stroked Q RR-24 24

EWP880116 III. PUMP TESTING Subsection IWP of ASME Section XI provides the rules and requirements for inservice testing to verify operational readiness of Class 1, 2 and 3 pumpu which are provided with an emergency power source and used to mitigate the consequences of an accident, shut the plant down to the cold shutdown condition, or maintain the plant in a safe shutdown conditon. The purpose of the IST pump program is to identify those pumps ar.d, subsequently, to test them according to the applicable Code requiremente. The pumps which are covered by the IST Program are listel in Table B.

Reference values for pump parameters were established using original surveillance test data or data from later test when the pump was operating acceptably in accordance with IWP-3110. Acceptance criteria for the periodic tests are based on the reference values and the allov.ble ranges specified in Table IWP-3100-2. Following oump maintenance the previous reference values will be confirmeo or a new set of reference values will be d. 'rmined in accordance with IWP-3111.

Post-maintenance testing will be pu .ormed by the applicable pump surveillance test.

Relief requests for pumps subject to Code testing are detailed in Section IV.

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EWP880116 TABLE B UNIT I IST PUMPS Pt:MP l l F&ID l l INLET l DIFFERENTIAL l FLOW l VIBP.ATION l OIL LEVEL l BRG. I COMMENTS

1. l SYSTEM l SHEET # l COORDINATES l PRESSURE l PRESSURE l RATE l AMPLITUDE l OR PRESSURE l TEMP.l l Service l M209 l l l l l l l l Relief P4A l Water l Sh 1 l D6 l l Q l Q ! l l l Request 27 l Service l M209 l l l l l l l l Relief P4B l Water l Sh 1 l E6 l l Q l Q l 1 l l Request 27 l Service l M209 l l l l l l l l Relief P4C l Water l SH 1 l E6 l l Q l Q l l l l Request 27 l l M204 l l l 1 l l l l P7A l EFW l Sh 3 l B5 l Q l Q l Q l Q l Q l Y l l l M204 l l l l l l l l P7B l EFW l Sh 3 l G5 l Q l Q l Q l Q l Q l Y l l l M217 l l l l l l l l Relief P16A l EDC* l SH1 l B5 l l l l l Q l l Request 28 l l M217 l l l l l l l l Relief P16B l EDG* l SH1 l B7 l l l l l Q l l Request 28 l DH l M232 l 1 l l l l l l P34A l Removal l Sh 1 l C4 l Q l Q l Q l Q l Q l Y l DH l M2:2 l l l l l l l P34B l Removal l Sh 1 l C3 l Q l Q l Q '

Q l Q Y l l RB l M236 l l l l l l l P35A l Spray l Sh 1 l F3 l Q l Q l Q l Q l Q l Y l l RB l M236 l l l l l l l l P35B l Spray l Sh 1 l F3  ! Q l Q l Q l Q l Q l Y l l l M231 l i l i l l l l P36A l MU l Sh 1 l C4 l Q l Q l Q l Q l Q l Y l l l M231 l l l l l l l l P36B i MU l Sh 1 l B4 l Q l Q l Q l Q l rt_ l Y l l l M231 l l l l l l l l P36C l MU l Sh 1 l A4 l Q l Q l Q l Q l Q l Y l Abbreviations: EFW - Emergency Feedwater DH - Decay Heat RB - Reactor Building MU - Makeup EDG - Emergency Diesel Generator Q - Quarterly Y - Annual

• EDG fuel transfer pump 26 i_ _

i EWP880116

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IV. RELIEF REQUEST This section includes generic, valve, and punip relief requests.

Relief requests were generated for components that cannot be tested in accordance with the ASME Code or are tested during refueling outages.

l 27 1

EWP880116 Relief Request - 1 System: All Valve: All Catego ry: NA Function: NA ASME Section XI Quarterly Test Requirements: Subsection IWV-1100 requires inservice testing to assess operational readiness of certain Class 1, 2 and 3 valves (and their activating and position indicating systems) which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.

Relief Request: AP&L proposes to comply with this subsection with the exception that we will test valves that are required to shutdown the reactor to the hot shut-down condition. The safe shutdown cordition for ANO-Unit 1 is hot shutdown. The steam generators provide the long-term capability for decay heat removal which meets General Design Criterion 34 dealing with Residual Heat Removal regairements.

Quarterly Part Stroke Testing: NA Refueling Testing: NA 28 2

EWP880116 Relief Request - 2 System: All Valve: All Category: A or B Function: NA ASME Section XI Quarterly Test Requirements: The ASME code states that the limiting value of full-stroke time of power operated valves is that time interval from initiation of the actuation signal to the end of the actuating cycle.

Relief Request: The NRC has stated that for fast-acting valves a limiting time of 2 seconds can be assigned as the valve actuation time. Fast acting valves are valves with actuation times of less than 2 seconds. AP&L proposes to classify certain valves as fast acting valves and assign a normal stroke time limit of 2 seconds to the valves so classified.

Quarterly Part Stroke Testing: NA Refueling Testing: NA l

29

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l EWP880116 Relief Request - 3 System: All Valve All Category: C Function: NA ASME Section XI Quarterly Test Requirements: The code states that for valves that are stroked with flow the pressure differential for equivalent flow shall be no greater than that observed during the preoperational test.

Relief Request: AP&L does not have preoperation differential pressure data for check valves. AP&L proposes that instead of taking differential pressure readings across individual check valves that differential pressure readings will be taken at the nearest suicable pressure tap downstream of the check valve. Differential pressure readings across iny dividual check valves will not be taken in systems where the check valves are tested under full flow and the back-pressure generated by the test flow path is greater than or equal to the expected backpressure under design basis conditions.

Quarterly Part Stroke Testing: NA Refueling Testing: NA 30

EWP880116 Relief Request - 4 System: All Valve: All Category: A and B Function: NA ASME Section XI Quarterly Test Requirements: The ASME codes states that if, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 seconds or 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken.

Relief Request: The ASME code rrquires the maintenance of a running file on previous test stroke times. This file would mean that surveillance procedures would have to be revised monthly.

Also, the code would allow a valve to degrade without flagging it. Finally, maintenance of a running file increases the chances of making clerical errors. AP&L proposes to establish a baseline stroke time and any stroke time that is 25% greater (50% greater for valves with a baseline of 10 seconds or less) than this baseline stroke time will cause the test frequency to increase to monthly.

Quarterly Part Stroke Testing: NA Refueling Testing: NA 31 i

i:

EWP880116 Relief Request - 5 System: All Valve: All e

Category: NA Function: NA ASME Section XI

/ Quarterly Test Requirements: The ASME. Code states that valves with remote por,ition indicators shall be observed at least once every two years to verify that valve operation is accurately indicated.

Relief Request: AP&L proposes to verify the position of valves with remote position indicators on a refueling outage frequency versus a two year frequency.

Quarterly Part Stroke Testing: NA Refueling Testing: See relief request segment.

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l EWP880116 Relief Request - 6 System: Reactor Coolant Syrtem Valve: CF-1A and CF-1B Category: C Function: These are check valves in lines between the core flood tanks and the reactor.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: Flow cannot be extablished through these valves in normal operation because the differential pressure between the RCS (approximately 2250 psig) and the CPTs (approximately 600 psig) acts to maintair check valves DH-14A and DH-14B closed. These check valves are in series with CF-1A and C7-1B respectively, therefore preventing flow through CF-1A and CF-1B from CFTs.

Quarterly Part Stroke Testing: None. These valves cannot be opened during normal operation due to the differential pressure between the RCS and CFTs.

Refueling Testing: The ability of these valves to full stroke open and close will be verified either by visual inspection, flow, or "

external means (ultrasonics).

If these valves are visually inspected, then CF-1A will be inspected during even numbered refueling outages and CF-1B will be inspected during odd numbered re-fueling outages.

p 33 J

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EWP880116 1

Relief Requast - 7 System: Reactor Coolant System Valve: DH-14A and DH-14B Category: C Function: These check valves are in the LP injection line to the reactor.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief

. Request: Flow cannot be established through these valves in normal operation because the differential pressure between the RCS (approximately 2250 psig) and the CPTs (approximately 600 psig) acts to maintain DH-14A and DH-14B closed.

Quarterly Part Stroke Testing: None. These valves cannot be' opened during normal operation due to the differential pressure between the RCS and CFTs.

Refueling Testing: The ability of these valves to full stroke open and close will be verified either by visual inspection, flow, or b external means (ultrasonics) .

If these valves are visually inspected then DH-14A will L be inspected during even numbered refueling outages l and DH-14B will be inspected durit>g odd numbered l, refueling outages.

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EWP880116

-s Relief Request - 8 System: Reactor Coolant System Valve: DH-13A, DH-13B, DH-17, and DH-18.

Category: AC Function: These check valves are' located in the lines between the decay heat removal pumps and the reactor vessel. These check valves protect the decay heat removal pumps from RCS/CFT pressure.

ASME Section XI Quarterly Test Requirements: Verify forward ' flow operability and reverse flow closure.-

Relief Request: These check valves are in a parallel pipe configuration (with two valves in series in each pipe run)., Full flow can be verified through the system but not through each set of valves. There are not any isolation valves in this parallel configuration.

Also, these valves are required to be leak rate tested.*

There is not a way to leak test these valves individually.

These valves will be leak rate tested as a set and the maximum leakage through the set will be based on the maximum leakage through the most limiting valve.

Quarterly Part Stroke Testing: None. Due to the differential pressure between the RCS and the discharge of the decay heat removal pumps, these valves cannot be partial stroke tested during power operations. These valves are partial stroke tested during cold shutdowns.

Refueling Testing: The ability of these valves to full stroke open and close will be verified either by flow, visual inspection, or external means (ultrasonics).

If these valves are visually inpsected then DH-13A and DH-17 will be inspected during even numbered outages and DH-13B and DH-18 will be inspected during odd numbered refueling outages.

4-X

• NOTE: These valves are leak tested during plant startup.

35 nv

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EWP880116 Relief Request 9

.\

System: Reactor Coolant System Valve: Reactor vessel internal vent valves.

Catego ry: C .

i Function: The rt.i.cor internal vent valves are used for relieving the pressure generated by steaming in the core following a LOCA so that the core will remain sufficiently cooled.

ASME Sectiss %

Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: The reactor vessel internal vent' valves are only accessible and testable when the reactor head is off. Normally, the reactor head is only removed during refueling outages.

Quarterly Part Stroke Testing: None. These valves are inaccessible during power operation.

Refueling l Testing: These valves will be manually stroke tested during refueling outages utilizing a spring gauge to measure their resistance.

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EWP880116 Relief Request - 10 System: NA Valve: SV-1071, SV-1072, SV-1073, SV-1074, SV-1077, SV-1079,

... SV-1081, SV-1082, SV-1083, SV-1084, SV-1091, SV-1092, SV-1093, SV-1094, CV-2645, CV-2646, CV-2647, and CV-2648.

Category: B Function: See Cold Shutdown Justifications 1, 2, and 3.

ASME Gection XI Quarterly Test Requirements: Valves with remote position indicators shall be observed at least once every two years to verify that valve position is accurately indicated.

I Relief Requeet: The above solenoid and control valves have enclosed stems, hence their operation cannot be observed.

Quarterly Part Stroke Testing: NA Refueling.

Testing: NA 37

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EWP880116 4

Relief' Request - 11 System: Makeup System  ;

Valve: MU-34A, MU-34B, MU-34C, and MU-34D ,

i Category: C t

Tunction: HP injection water is admitted into the RCS through these i check valves during E.S. actuation.- >

l ASME Section XI l Quarterly Test f Requirements: Verify forward flow operability and reverse flow closure.  !

Relief ,

Request: Full stroke exercising these valves in normal operution r would require approximately 250 GPM. This flow r:.f.e would  !

exceed letdown flow, and possibly lead to a reacton trip on high pressurizer-level. Also, testing these va:Wes i would impose unnecesesty thermal cycles on the HPI nozzles, which could tause' premature failure of the HPI noz: les.

Quarter 1v part.

Struke Testing: None. ,

Refueling Testing: The ability of these valves to full stroke open ani close l will be verified either by visual inspection, flow or  !

external means (ultrasonics).

j If thest valves are visually inspected then MU-34A and l

! MU-34B will be inspected during even numbered refueling  ;

l outages and MU-34C and MU-34D will be inspected during ,

s odd numbered refueling outages. ,

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I' EWP880116 Relief Request - 12 System: Makup System Valve: MU-19A, MU-19B, and MU-19C Category: C Function: These are the primary makeup pump discharge check valves.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: Full stroking these valves during power operation would

, exceed the letdown flow rate. A high pressurizer level trip of the reactor could result from the excess flow into the RCS.

Quarterly Part Stroke Testing: These valves are partial stroke tested quarterly.

Refueling Testing: The ability of these valves to full stroke open and close will be verified either by visual inspection, flow, er external means (ultrasonics).

If these valves are visually inspected then MU-19A and MU-19B will be inspected during even numbered refueling outages and MU-19C will be inspected during odd numbered refueling outages.

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EWP880116 Relief Request - 13 System Makeup System Valve MU-1211, MU-1212, MU-1213. MU-1214, and MU-1215 Category: C Function: These check valves are in the HP injection line to the RCS.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: Full stroking these valves during normal power operation -

would require a flow rate into the RCS that would exceed the letdown flow rate. A high pressurizer level trip of 3 the reactor could result from the excess flow into the RCS.

Quarterly Part Stroke Testing: None. These valves are partial stroke tested during cold shutdown.  !

Refueling Testing: The ability of these valves to full stroke open and close 4

will be verified either by visual inspection, flow, or external mtans (ultrasonics).

If these valves are visually inspected then :tU-1211, MU-1212, and MU-1213 will be inspected during even numbered refueling outages and MU-1214 and MU-1215 will be inspected during odd numbered refueling outages.

1

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EWP880116 Relief Request - 14 System: Makeup System Valve: BW-2 and BW-3 Category: C' Function: These stop check valves are in the supply lines to the primary makeup pumps.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability.

Relief Request: Full stroking these valves during normal power operation would require a flow rate into the RCS that would exceed the letdown flow rate. A high pressurizer trip of the i reactor could result from the excess flow into the RCS.

Also, it woold put highly borated water in the RCS

causing a power transient, l

Quarterly Part

! Stroke Testing: None. These valves are partial stroke tested during cold shutdown.

! - Refueling j Testing: The ability of these valves to full stroke open will be verified either by visual inspection, flow, or external

! means (ultrasonfes).

f' If these valves are visually inspected then BW-2 will be inspected during even numbered refueling outages and BW-3 will be inspected during odd numbered refueling outages.

i 1

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EWP880116 Relief Request - 15 System: Makeup System Valve: MU-22A, MU-22B, and MU-22C Category: C Function: These valves provide minimum recirculation flow for makeup pumps during normal operation and some accident situations. During accident conditions the recire path is automatically closed and the valves prevent backflow through a non-operating recirculation line. If the makeup flow is required to be throttled then the re-circulation line is first unisolated and then these valves must open to insure minimum flow for the operating pumps.

ASME Section XI Quarterly Test Requirements: Verify forward flow and reverse flow closure.

Relief Request: There are not any flow measuring devices in the makeup pump .te. circulation lines.

Quarterly Part Stroke Testing: None.

Refueling Testing: The ability of these valves to full stroke open and close will be verified either by visual inspection, flow, or external means (ultrasonics).

If these valves are visually inspected then MU-22A and MU-22B will be inspected during even numbered refueling outages and MU-22C will be inspected during odd numbered refueling outages.

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EWP880116 Relief Reque,st _16 System: Decay Heat Removal System

) Valve: BW-4A and BW-4B Catego ry: C Function: These check valves are in the suction line to the decay heat removal pumps.

ASME Section XI Quarterly Test  !

Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: To full stroke these valves vould require running the HPI, LPI, and building spray pumps simultaneously. Running the HPI pumps with water from the PWST would put highly borated water into the RCS which would put the RCS outside the boron limits outlined in the Technical Specification.

Quarterly Part Stroke Testing: These check valves are 60% flow tested quarterly.

Refueling Testing: The ability of these valves to full stroke open will be verified either by visual inspection, flow, or external means (ultrasonics).

If these valves are visually inspected then BW-4A will be inspected during even numbered refueling outages and BW-4B will be inspected during odd numbered refueling outages.

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EWP880116 Relief Request - 17 System: Building Spray System Valve: BS-4A and BS-4B Category: C Function: These valves are the building spray pump discharge check valves. These valves also act to maintain a water level in the building spray piping.

ASME Section XI Quarterly Test Requirements: These valves are tested to verify forward flow operability.

Relief Request: Stroking these valves would spray borated water into the reactor building causing decontamination problems and possible equipment damage.

Quarterly Part Stroke Testing: None. See relief request segment.

Refueling Testing: These valves will be disassembled, visually examined, and manually stroked during refueling outages. BS-4A will be disassembled during even numbered refueling outages, while BS-4B will be disassembled during odd refueling outages.

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EWP880116 Relief Request - 18 System: Emergency Feedwater System Valve: FW-10A and FW-10B Catego ry: C Function: These are the EFW pump discharge recirc check valves. When the check valve is closed the recire. line is open. When the check valve closes the recire. line is isolated and flow is routed to the steam generators. FW-10A is the 'A' EFW pump discharge check valve while FW-10B is the 'B' EFW pump discharge check valve.

ASME Section XI Quarterly Tett Requirements: Verify forward flow operability.

Relief Request: Interim relief from full stroke exercising these valves is needed until the next refueling outage (IR8) when flow measuring indication will be added to the recire. Ifnes.

Presently, there is not a way to quantify flow through the recire, lines.

Quarterly Part Stroke Testing: When the flow orifices are installed the valves will be full stroke tested monthly.

Refueling Testing: NA 45

EWP880116 Relief Request - 19 System: Emergency Feedwater System Valve: SW-11 and SW-13 P

Catego ry: C Function: SW-11 ic in the suction line that provides loop 1 service water to the EFW pumps. SW-13 is in the supply line that supplies loop 2 service water to the EFW pumps.

A ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure, i

Relief  ;

Request: Stroking this valve during power operation would admit l service water into the feedwater system which will adversely affect the qur'ity of the steam generator chemistry leading to potential tube failure.

Quarterly Part Stroke Testing: None. See answer to Relief Request segment.

Refueling Testing: SW-13 is opened up and manually stroke tested during even numbered refueling outages. SW-11 is opened up and manually stroke tested during odd numbered refueling outages.

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-);WP880116 Relief Request - 20 System: Emergency Feedwater System Valve: FW-13A and FW-13B Category: C Function: These check valves are in the EFW pipes to the steam generators.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: These check valves cannot be exercised during normal operation because cold water would be sprayed onto steam generator tubing and tube degradation could result.

These valves are not full stroke tested during cold shutdown in order to minimze the effect on SG chemistry.

Quarterly Part Stroke Testing: None. See relief request segment for explanation.

These valves are partial stroke tested during cold shutdown.

Refueling Testing: The ability of these valves to full stroke open will be verified either by visual inspeciton, flow, or external means (ultrasonics). If these valves are visually inspected, then FW-13A will be opened during even numbered refueling outages and FW-13B will be opened during odd numbered refueling ontages.

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EWP880116 Relief Request ,21 I

System: Emergency Feedwato ,ystem Valve: FW-61 and FW-62 Category: C Function: These check valves are in the EFW pump recire. lines.

ASME Section XI Quarterly Test  !

Requirements: Verify forward flow operability.

Relief  ;

Request: Interim relief from full stroxa exercising these valves is needed until the next refueling outage (IR8) when flow measuring indication will be added to the recire. lines.

Presently, there is no installed way to quantify flow through the recire. lines, j Quarterly Part Stroke Testing: After the flow orifices are installed these valves will be full stroke exercised monthly. e Refueling Testing: NA i

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EVP880116 Relief Request - 22 System: Emergency Feedwater System Valve: MS-271 and MS-272 Category: C Function: These check valves are in the main steam lines that run from the steam generators to the emergency feedwater turbine. These check valves prevent steam flow back to the steam generators.

AShI Section XI Quarterly Test Requirements: Verify flow operability and reverse flow closure.

Relief Request: There is no closing force other than gravity on these valves. Hence the close position can not be verified on these valves during power opetations or during cold shutdowns.

The open position verified during power operation by the normal speed of the emergency feedwater turbine.

Quarterly Part Stroke Testing: N.A.

Refueling Testing: MS-271 will be disassembled and inspected while in the closed position during even numbered refueling outages.

MS-272 will be disassembled and inspected while in the closed position during odd number refueling outages.

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m EWP880116 Relief Request - 23 1

System: Emergency Feeuwater Valve: CS-293 and CS-294 Category: C Function: These are parallel check valves in the emergency feedwater suction line from the condensate storage tank. <

ASHE Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

.i Relief Request: These two check valves are in a parallel pipe configuration.

Full flow can be verified through the system but not through each individual valve. There are not any isolation valves in this parallel pipe configuration.

Quarterly Part Stroke Testing: These valves are partial flow tested quarterly.

Refueling Testing: The ability of these valves to full stroke open and closed will be tested by either flow, visual inspection, or external means (ultrasonic).

If these valves are visually inspected then CS-293 will be opened during even. numbered refueling outages and i CS-294 will be opened during odd numbered refueling 1 outages. l i

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e-EWP880l!6 Relief Request - 24 System: Service Water Valve: SW-72 Catego ry: B Function: This is a manual valve that provides safety related source of makeup water to the spent fuel pool.

ASME Section XI Quarterly Test Requirements:

Verify the ability of this valve to open.

Relief Request: This valve vill be full stroke exercised quarterly but not timed. Since this is a manual valve there is not a re-quirement to time it in the Code.

Qaarterly Part Stroke Testing: NA. This valve will be full stroke exercised quarterly.

Refueling  ;

Testing: NA.

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Relief Request - 25 dystem: Chemical Addition Valve: CA-61 and CA-62 Catego ry: C Function: These valves prevent BWST water from flowing into the sodium hydroxide addition system. These valves also admit sodium hydroxide to the building spray system during its operation.

ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Relief Request: Full stroke exercising these valves in power operation would upset RCS pH control. Addition of sodium hydroxide into the RCS would also lead to an increase in radio-activity levels in the RCS.

Quarterly Part Stroke Testing: None.

Refueling Testing: The ability of these valves to full stroke open and close will be tested by either flow, visual inspection, or external means (ultrasonic).

If these valves are visually inspected then CA-61 will be inspected during even numbered refueling outages and CA-62 will be inspected during odd numbered refueling outages.

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. Relief Request - 26  !

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System: Emergency Diesel Generator System j Valve: FO-54A1, FO-54A2, FO-54B1, FO-54B2, FO-55A1, FO-5.,A2, l FO-55B1, and.FO-55B2.

Category: C Function: These check valves are betwen the EDG starting air compressors (4) and the EDG starting air tanks (4).  ;

! There are two check valves in series in each pipe.  ;

These check vs.\ves maintain a sufficient supply of l air at a sufficient pressure in each EDG starting ,

air tank to attempt four starts of the associated '

EDG, j i

ASME Section XI

• lJuarterly Test Regairements: Verify reverse flow losure. ,

I Relief Request: .These vs1ves are in series. There is not a vent between the two valves nor is there room to install i a vent between the valves. The only way to detect I leakage

• through these valves .is to determine the h leakage through both valves.  ;

t Quarteriy Part [

Stroke Testing: These valves are full stroke opened quarterly. -

Back leakage through both valves will be deternhed i quarterly. Since these valves are in a vertical f run of pipe and are spring loaded there is not a  :

way to verify that the globe disc is in the closed l position visually. Therefore AP&L proposts to j determine the back leakage through both valves on j a quarterly basis.  :

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Testing: NA. l f

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• NOTE: Significant leakage would be readily detected by blow back through the idle compressor.

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EWP880116 1

Relief Request - 27 g.

Systema Service Water System Pumps: A, B, and C Service Water Pumps Function: The service water pumps provide cooling water to remove various plant heat loads.

ASME Section XI Quarterly Test Requirements: Pump flow, pump differential pressure, and motor vibration  ;

data are all monitored in order to ensure pump operability.

r Relief l Request: AP&L has assigned upper flow limits of 1.07 Qr and 1.10 Qr

to the service water pump curves instead of the 1.02 Qr and '

1.03 Qr ret ommended by Table IWP-3100-2. The upper limits were expanded due to difficulties in obtaining repeatable r reference values. Use of these limits should not adversely affect puap reliability since pump degradation usually re-ulte ia lower flow / differential pressure readings instead of higher flow / differential pressure ,eadings.

The service water pumps are submerged pumps wsth vater cooled, water lubricated bearings. Table ISP-3100-1 and .

IWP-3300 states that pump bearing temperature shall be '

measured once a year. However, finding and installing temperature probes that would functioa properly and consistently in a submergad pump is extremely unlikely. 7 Also, due to large flow of variable temperature lake  ;

water around these bearing's, monitoring pump bearing -

temperature is not a good indicator of bearing condition.

IWP-3110 and IWP-3400 states that pump be::1.4 ~.3 + b ra t ion [

shall be monitored quarterly. AP&L requests relief to monitor motor bearing vibration only due to difficulties r of finding and installing reliable vibration o. bes that ,

would function in a submerged pump. -

The ASME Code states that inlet pressure shall be monitored quarterly. AP&L does not compare this value to a normal ,

inlet pressure since the inlet pressure is determined by a j fluctuating lake level. AP&L surveillance procedures do [

specify a LCO lake level.

Quarterly Part Stroke Testing:

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Service water pump flow, inlet pressure, differ stial pressure, -

and motor vibration readings are monitored quas.erly. Motor Bearing temperatures are taken once a year. l Refueling ,

Testing: MA {

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EWP880116 i

Relief Request - 28 {

System: Emergency Diesel Generator System Pump: Emergency Diesel Fuel Transfer Pump Category: NA Function: These pumps rJpply diesel fuel to the emergency diesel generators.

, ASME Section XI Quarterly Test  !

Requirements: Inlet pressure, differential pressure, flow, vibration, and oil should all be checked quarterly. Bearing temperatures sheuld be checked annually.

I Relief Request: These pumps do not have flow indication or inlet pressure guages installed. However, these pumps demonstrate quarterly that they are capable of pumping diesel fuel in excess of the amount needed to run the emergency diesel generators (EDG) at full load. l These pumps are designed to deliver 10 GPM to the EDG's. -

The EDG's require 6 GPM at full load. Hence these pumps, which don't have any recirculation capabilities, cycle frequently. Given the cyclic operation of these pumps, i AP&L proposes not to measure pump vibration or bearing temperatures.

Quarterly Part .

Stroke Testing: NA Refueling Testing: The actual flow rate is determined on a refueling frequency and verified to be greater than or equal to 10 GPM as re-quired by Tech. Specs.

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EWP880ll6 Relief Request - 29 System: Emergency Feedwater System

.l Valve: CS-98, CS-99, CS-261, and CS-262 Category: C Function: These passive seismic check valves prevent loss of .

emerp ncy feedwater in case of a non-seismic line I break or if the non-seismic condensate tank ruptures.

A ncn-safety grade source of emergency feedwater can L also be supplied through these valves.

ASME Section XI Quarterly Test Requirements: Verify reverse flow closure.

Relief f Request: These check valves are in a parallel pipe configuration f (with two valves in series in each pipe run). There are not any isolation valves in this parallel configu-ration. These check valves are required to be leak rate tested. There is not a way to leak test these i valves individually. Hence, these valves will be leak rate tested as a set and the maximum leakage through these valves will be based on the maximum leakage through the most limiting valve.  ;

Quarterly Part l Stroke Testing: These valves do not require any stroke testing.

Refueling Testing: These valves will be leak rate tested during refueling outages.

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/ V. COLD SHUTDOWN JUSTIFICATION This section contains cold shutdown justifications for valves that can be tested in accordance with the ASME Code only when the plant is in cold shutdown.

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EWP880!!6 COLD SHUTDOWN JUSTIFICATION - 1 System: Reactor Coolant System Valve: SV-1077 and SV-1079 Catego ry: B Function: liigh point vent valves located on top of the pressurizer.

ASME Section XI Quarterly Test Requirements: These valves are stroke tested to verify forward flow.

These valves are also timed.

Cold Shutdown Test Justification: Perodic testing of these valves during power operation could cause seat degradation and reactor building contamination. The degradation would be caused by high velocity steam passing over the valve seat. Reactor building contamination would result, due to the direct release of reactor coolant to the containment atmos-phere and surrounding area.

Quarterly Part Stroke Testing: None. Partial stroke testing these valves during power operation could also cause seat degradation.

Cold Shutdown Testing: These valves are full stroke tested and timed during cold shutdown while RCS pressure is being increased to 225 psig.

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EWP880116 COLD SHUTDOWN JUSTIFICATION - 2 System: Reactor Coolant System Valve: SV-1081, SV-1082, SV-1083, SV-1084, SV-1091, SV-1092, SV-1093 and SV-1094.

Category: B Function: RCS loop T V'"" **IY

hot ASME Section XI Quarterly Test Kequirements: These valves are stroke tested and timed to verify forward flow operability.

Cold Shutdown Test Justification: Periodic testing of these valves during power operations

ould cause seat degradation and reactor building contamination.

The degradation would be caused by high velocity steam passing over the valve seat. Reactor building contamination would result, due co direct release of reactor coolant to the containment atmosphere and surrounding area.

fuarterly l Part Stroke Testing: None. Partial stroke testing these valves during power operations could also cause sent degradation.

Cold Shutdown Testing: These valves are full stroke tested and timed during cold shutdown while RCS pressure is being increased to 225 psig.

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EWP880116 COLD SHUTDOWN JUSTIFICATION - 3 System: Reactor Coolant System Valve: SV-1071, SV-1072, SV-1073, and SV-1074 Category: B Function: These are the reactor head vent valves.

AS!:E Section XI Quarterly Test Requirements: These valves are stroke tested and timed to verify forward flow operability.

Cold Shutdown Test Justification: Periodic testing of these valves during power operations could cause seat degradation and reactor building con-tamination. Tae degradation vruld be caused by high velocity steam passing over the valve seat. Reactor building contacination would result from the direct release of reactor coolant to the containment atmos-phere and surrounding area.

Quarterly Part Stroke Testing: None. Partial stroke testing these valves during power operation could also cause seat degradation.

Cold Shutdown Testing: These valves are full stroke tested and timed during cold shutdown whi}e RCS pressure is being increased to 225 psig.

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EWP880116 COLD CHUTDOWN JUSTIFICATION - 4 System: Reactor Coolant System Valve: PSV-1000 Category: B Function: This valve is used to protect the reactor vessel and  !

coolant system from the low temperature over pressurization conditions that could occur during reactor startup and t shutdown.

ASME Section XI Quarterly Test Requirements: This valve is required to be exercised to verify its forward flow ability.

Cold Shutdown Test Justification: This valve is not tested during power operation since there '

is a possibility of it sticking open. Also, this valve is not needed for over-pressurization protection during power operation. l Quarterly Part  !

Stroke Testing: None. See answer to Cold Shutdown segment.

Cold Shutdown Testing: This valve is exercised during cold shutdown to verify its ability to open. j t

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COLD SHl!TDOWN JUSTIFICATION - 5 l g System: Main Steam ,

Valve: CV-2691 and CV-2692 Category: B  !

Function: The main steam isolation valves are provided to isolate

• the secondary side of the OT! 's from the remainder of the main steam system in the event of a main steam line rupture.

ASME Section XI [

Quarterly Test i Requirements: These valves are required to be stroke tested and timed l to verify their isolation function.  ;

Cold Shutdown Test Justification: Full stroke testing these valves during power operation l would cause a loss of steam flow from the steam generators by isolating the main steam lines. Loss of steam flow from a steam generator could cause a reactor trip due to l high reactor coolant pressure and/or temperature, and would induce undesirable steam flow transients to the unisolated 1 steam generator.

Quarterly Part Stroke Testing: These valves receive a partial-stroke exercise of approxi- i mately 10% quarterly during power operation.

Cold Shutdown -

Testing: These valves are full stroke tested and timed during plant startup to verify their isolation function.  ;

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EWP880116 y

COLD SHUTDOWN JUSTIFICATION - 6 System: Makeup System Valve: MU-13 Category: C Function: This is the stop check valve between the RC make-up tank and the primary make-up pumps. During normal operation this valve permits flow from the RC make-up tank to the primary make-up pumps. During accident condition 6 and actuation this valve shuts to protect the RC make-up tank from DH removal system pressure.

ASME Section XI Quarterly Test Requirements: Test the ability of this valve to shut to prevent over-pressurization of the RC make-up tank.

Cold Shutdown Test Justification: The makeup and purification system is in continuous service

, when RCS is above 150' F. The system supplies RCP seals and maintains pressurizer level. To test the capability of MU-13 to isolate the makeup tank would have an un-acceptable impact on RCP and RCS operation.

Quarterly Part Stroke Testing: NA Cold Shutdown Testing: The ability of this valve to seat is tested during cold shutdowns.

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EWP880ll6 COLD SHUTDOWN JUSTIFICATION - 7 System: Makeup System Valve: CV-1270, CV-1271, CV-1272, CV-1273, and CV-1274 Catego ry: B Function: These are the reactor coolant pump seal control bleedoff valves.

+ ASME Section XI Quarterly Test Requirements: These valves are required to be full stroke tested and timed

., to verify their isolation function.

Cold Shutdown Test Justification: Failure of these valves in a closed position during a test could damage the reactor coolant pump seals. Also, cycling these valves during power operation would impose transient conditions on the RCP seals which can cause seal damage.

Quarterly Part Stroke Testing: None. Cycling these valves during power operation would cause transient conditions on the RCP seals which could cause seal damage.

Cold Shutdown Testing: These valves are full stroke tested and timed during cold shutdown to verify their isolation function.

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EWP880116 i

COI.D SHUTDOWN JUSTIFICATION - 8 System: Makeup System Valve: CV-1300 and CV-1301  ;

Catego ry: B Function: These are the makeup pump recir ulation isolation valves.

These valves are open in normal operation to prevent overheating / cavitation of the operating makeup pump.

ASME Section XI Quarterly Test Requirements: These valves are required to be stroke tested and timed to verify their ability to isolate the recirculation line during E.S. actuation of the makeup pumps.

Cold Shutdown Test Justification: Testing these valves during normal operation could cause the operating pump to overheat and cavitate due. to the insufficient flow through the pump.

Quarterly Part Stroke Testing: None. These valves are not set up to be modulated.

During normal operation these valves are full open, during E.S. actuation these valves go full closed.

Cold Shutdown Testing: These valves are full stroked exercised and timed during cold shutdowns to verify their isolation capabilities.

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EWP880116

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COI.D SHUTDOW JUSTIFICATION - 9 System: Decay Heat Remaval System Valve: CV-1050 and CV-1410 Cat ego ry: B Function: These valves are used to isolate the RCS from the decay heat removal system during power operation. This iso-lation prevents the over pressurization of the decay heat removal system.

ASME Section XI Quarterly test Requirements: These valves are required to be stroke tested and timed to verify their isolation capabilities.

Cold Shutdown Test Justification: These valves are electrically interlocked as required by Tech Specs. with the RCS to remain closed when the RCS pressure is above 290 psig.

Quarterly Part Stroke Testing: None. These valves are electrically interlocked to remain closed when the RCS pressure is above 290 psig.

Cold Shutdown Testing: These valves are full stroke exercised and timed during cold shutdown in order to verify their isolation capability.

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l COLD SHUIDOWN JUSTIFICATION - 10 System: Service Water System Valve: CV-3643 Category: B Function: This is the supply / isolation valve for the auxiliary t cooling water loop.  ;

. ASME Section XI Quarterly Test Requirements: This valve is required to be stroke tested and timed to verify its flow and isolation ability. ,

L Cold Shutdown Test Justification: Stroking this valve during power operation would deprive  :

the lube oil coolers and hydrogen coolers of cooling  !

water causing high generator and bearing temperatures i which could force a turbine trip, t Quarterly Part Stroke Testing: None. Stroking this valve during power operation could cause a turbine trip due to high generator and bearing temperatures.  :

i Cold Shutdown Testing: This valve is full stroke exercised and timed during -

cold shutdown to verify its supply / isolation cap-abilities.

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8 EVP880116 COLD SHUTDOWN JUSTIFICATION - 11 -

System

Service Water System Valve: CV-3641 and CV-3645 Category: B Function: CV-3641 is the service water loop 2 isolation valve.

CV-3645 is the service water loop 1 isolation valve.

ASMI Section XI Quarterly Test Requirements: None. These are type B passive valves and hence are not required to be tested by ASME Section XI. However, AP&L presently stroke tests and times these valves and plans to continue to test these valves in the future.

Cold Shutdown Test Justification: NA Quarterly Part Stroke Testing: NA Cold Shutdown Testing: These valves are full stroke exercised and timed during cold shutdowns.

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EWP880116 COLD SHUTDOWN JUSTIFICATION - 12 System: Service Water System Valve: SW-1A, SW-1B, and SW 1C Catego ry: C 1

Function: These are the service water pump discharge check valves.

These valves prevent backflow t.hrough a non-operating service water pump. These val.as open to permit flow when -

the associated service water pump is operating.

ASME Section XI I Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.

Cold Shutdown Test Justification: Normally, these valves are full stroke tested quarterly during power operations. However, these valves may not be tested for reverse flow closure during the summer when three pump operation may be necessary to remove system heat loads or if one pump is down for maintenance ,

and the other two pumps are needed to supply cooling water.

3 Quarterly Part l Stroke Testing: See CSD Justification statement.

Cold Shutdown f Testing: The service water pump discharge check valves which cannot  ;

be teuted during power operation because its associated service water pump is required to be operating, will be tested during cold shutdown.

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EWP880ll6 I

I COLD SHUTDOWN JUSTIFICATION - 13 l System: Intermediate Cooling Water System (

Valve: CV-2214, CV-2215, and CV-2233 Catego ry: A ,

Function: CV-2233 is a containment isolation valve in the ICW supply l line to the letdown coolers and RCP seal cooling water heat i exchangers. CV-2214 and CV-2215 are the containment isolation valves in the ICW return line from these heat exchangers. l ASME Section XI Quarterly Test Requirements: These valves are required to be full stroke exercised and timed to verify their containment butiding isolation capability.

Cold Shutdown Test Justification: Stroking these valves during power operaiton is not desirable due to the possibility of one of these valves failing closed. If one of these valves should fail closed then cooling water would be lost to the letdown coolers and RCP seal cooling water heat ex-changers.

Loss of cooling water flow to the letdown coolers would cause excessive letdown temperature resulting in damage to the demineralizer resins. Loss of cooling water flow to the RCP seal cooling water heat exchangers would result in high temperature RCP seal water which could damage the RCP seals.

Quarterly Part Stroke Testing: None. 1hese valves are set up to go full closed when activated.

Cold Shutdown Testing: These valves are full stroke exercised and timed during cold shutdown to verify their ability to provide containment building isolation.

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EWP880116 COI.D SHUTDOWN JUSTIFICATION - 14 System: Intermediate Cooling Water System Valve: CV-2220, CV-2221, CV-2234, and CV-2235 Ca tego ry: A Function: These valves provide cooling water to the reactor coolant pump motor air and lube oil coolers and to the control .

rod drive cooling coils.  !

ASME Section XI i Quarterly Test j Requirements: These valves are required to be stroke tested and timed to verify their containment building isolation function.

Cold Shutdown l Test Justification: Stroking these valves during power operation would deprive '

vital plant equipment of cooling water. Loss of cooling water could cause over heating of this equipment and ,

could lead to equipment damage. ,

Quarterly Part Stroke Testing: None. See answer to Cold Shutdown Justification segment. ,

Also these valves are not set up to be partial stroke tested; they are either full open or upon E.S. acutation they go (

full closed. <

Cold Shutdown s Testing: These valves are full stroke exercised and timed during I cold shutdown to verify their isolation function.

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CCLD SHUTDO M JUSTIFICATION - 15 f

System: Chilled Water System i f

Valve: CV-6202, CV-6203, and CV-6205 Category: A Function: CV-6202 is the chilled water supply valve to the reactor building chilled water cooling coils. CV-6203 and CV 4205 +

are in the chilled water outlet line from the reactov building chilled water cooling coils. All three of the ,

valves also serve a containment building isolation function.

ASME Section XI  !

Quarterly Test j Requirements: These valves are required to be stroke tested and timed to l verify their containment building isolation function. >

Cold Shutdown Test Justification: Stroking these valves during power operation could result in a reduction in load if these valves should fail close  !

(their E.S. position). The load reduction would be due f to high reactor building temperature caused by loss of '

reactor building cooling, f1 Quarterly Part Stroke Testing: None. Even a partial reduction in reactor building f cooling capacity could cause a reduction in plant load.  :

Also, these valves are setup to be either full open or  !

full closed - their E.S. position, j Cold Shutdown y Testing: These valves are full stroke exercised and timed during I cold shutdown to verify their ability to provide con- I tainment building isolation.

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EWP880116 COLD SHUTDOWN JUSTIFICATION - 16 System: Heating, Ventilation and Air Conditioning System Valve CV-7401, CV-7402, CV-7403, and CV-7404.

Category: A Function: CV-7402 and CV-7404 are the containment building isolation .

valves in the reactor building purge air supply header. l CV-7401 and CV-7403 are the containment building isolation i valves in the reactor building purge air exhaust header.

ASME Section XI -

Quarterly Test t Requirements: These valves are required to be stroke tested and timed to ,

verify their containment building isolation function.

Cii.d Shutdown Test Justification: The reactor building purge valves are required by Technical Specifications to be closed and the handswitch keys removed ;

whenever reactor coolant pressure is greater than 300 psig and reactor coolant temperature is greater than 200*F.

These valves are required to be closed in power operation in order to ensure reactor building integrity.

Quarterly Part Stroke Testing: None. See answer to Cold Shutdown Justification segment.

Cold Shutdown Testing: These valves are full stroke tested and timed during cold shutdown to verify their containment isolation capability.

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COLD SHITTDOW JUSTIFICATION - 17 System: Feedwater Valve: CV-2630 and CV-2680 Category: B Function: The main feedwater isolation valves are used to isolate '

the feedwater from the steam generators in order to mitigate the effects of a main steam line or main feed-(

water line break. '

ASME Section XI Quarterly Test  !

Requirements: The valves are required to be stroke tested and timed to verify their isolation function.

Cold Shutdown ,

Test Justification: A full stroke test of these valves during power operations would cause a loss of feedwater to the steam generators and thus a high pressure and/or temperature trip.

Quarterly Part l Stroke Testing: These valves receive a partial-stroke exercise of approxi-  !

mately 5% quarterly during power operation. .

t Cold Shutdown Testing: These valves are full stroke tested and timed during a ,

plant startup to verify their isolation function. [

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COLD SHUTDOWN JUSTIFICATION - 18 i

i System: Feedwater Valve FW-7A and FW-7B Catego ry: C i

Function: These check valves are located downstream of the feedwater isolation valves to prevent backflow.

ASME Section XI (uarterly Test Requirements: Reverse flow closure.

Cold Shutdown Test Justification: Closing these valves during normal operation would  ;

stop feedwater flow to the steam generators. Loss  :

of a heat sink to either RCS loop would cause high .

pressure and te, trature. Either of these conditions would trip the reactor.

Quarterly Part Stroke Testing: None. These valves can only be stroked by flow.  !

Interrupting flow to test these valves would cause ,

a high temperature and/or pressure trip of the j reactor. j Cold Shutdown Testing: These valves are full stroke tested during cold f shutdown to verify reverse flow clonure. These valves are also leak rate tested.  ;

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EWP880116 VI. ATTACHMENTS.

ATTACHMENT A Attachment A contains a list of P&ID's of ANO-1 Safety-Related Systems.

P&ID SYSTEMS M-202, SHEET 1 MAIN STEAM SYSTEM H-204, SHEET 3 EMERGENCY FEEDWATER SYSTEM H-206, SHEET 1 STEAM GENERATOR SECON!!ARY SYSTEM H-209, SHEET 1 & 2 CIRC WATER INTAKE STRUCTURE EQUIPMENT M-210, SKEET 1 SERVICE WATER SYSTEM M-213, SHEET 1 DIRTY LIQUID & LAUNDRY RADIOACTIVE WASTE M-215, SHEET 1 GASEOUS READI0 ACTIVE WASTE M-217, SHEET 1 EMERGENCY DIESEL GENERATOR & FUEL OIL M-218, SHEET 4 INSTRUMENT & SERVICE AIR SYSTEM M-219, SHEET 1 FIRE WATER SYSTEM M-222, SHEET 1 CHILLED WATER SYSTEM M-230, SHEET 1 & 2 REACTOR COOLANT SYSTEM M-231, SHEET 1 & 2 MAKEUP & PURIFICATION SYSTEM M-232, SHEET 1 DECAY KEAT REMOVAL SYSTEM M-233, SHEET 1 CHEMICAL ADDITION SYSTEM M-234, SHEET 1 & 2 INTERMEDIATE COOLING SYSTEM M-235, SHEET 1 SPENT FUEL COOLING SYSTEM M-236, SHEET 1 REACTOR BUILDING SPRAY & CORE FLOOD SYSTEM M-237, SHEET 1 SAMPLING SYSTEM M-261, SHEET 1 KVAC SYSTEM (REACTOR BUILDING) l 76 i

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l ATTACl&fENT B f I

. Attachsent B contains descriptions of significant changes to the Inservice i Testing Program.  !

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1. On November 17 and 18, 1987 a meeting between the NRC, AP&L, and EG&G, r took place to discuss the ANO-1 IST Program. As a result of this  !

meeting, the following valves have been added to the ANO-1 IST Program. '

I MU-13 FO-54A1 IA-52 PSV-5231 l PSV-1412 FO-54A2 SF-42 PSV-5232 i CV-5218 FO-54B1 SF-43 PSV-5237 i CV-5233 FO-54B2 SF-44 PSV-5238 CV-5237 F0-55Al SW-72 PSV-5240 CV-5239 F0-55A2 MU-22A PSV-5241 SV-5218 F0-55B1 MU-22B '

SV-5233 F0-55B2 MU-22C  !

SV-5237 FO-8A PSV-5212 SV-5239 FO-8B PSV-5216  ;

Most of the above valves (the CV's, SV's, PSV's except PSV-1412, and '

fuel oil valves) were added as a result of the inclusion of the Emergency Diesel Generator (EDG) System to the ANO-1 IST Program.  ;

Addition of the EDG System also resulted in the addition of the EDG t fuel transfer pumps (P16A and P16B) to ANO-1 IST Program. Valves i IA-52, SF-42, SF-43, and SF-44 were added because they are Appendix J [

$ leak rate test. SW-72, MU-13, MU-22A, MU-22B, MU-22C, and PSV-1412 l

/ were added to address NRC concerns and expansion of scope of safety, j i

2. The resubmittal also contains a section (V) for cold shutdown justi- )

fications. Cold shutdown justifications were written for valves t that can be exercised in accordance with the ASME Code during cold I shutdown but cannot be exercised during power operation.

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