ML18153D146

Forwards Revised Relief Request V-27,per NRC 920805 Telcon Request for Addl Info to Complete Review of 901107 Submittal of Revs to Relief Request V-27 for ASME IST Program Plans for Pumps & Valves

ML18153D146
Person / Time
Site:	Surry
Issue date:	10/08/1992
From:	STEWART W L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
92-610, NUDOCS 9210140083
Download: ML18153D146 (19)

Text

e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 8, 1992 United States Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 INSERVICE TESTING PROGRAM REVISION TO RELIEF REQUEST V-27 Serial No. 92-61 O NO/ETS Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 In our November 7, 1990 letter (Serial No.90-622) we submitted revisions to Relief Requests V-27 for Surry Power Station Units 1 and 2 ASME Section XI lnservice Testing (1ST) Program Plans for Pumps and Valves. During a telephone conversation held on August 5, 1992 concerning V-27, your staff requested additional information to . complete the review of the relief requests.

In response to this request, the relief requests for Surry Power Station Units 1 and 2 were revised and are attached.

In a July 24, 1992 letter (Serial No.92-286), we submitted major program revisions for the lnservice Testing Program Plans for both Units. Relief Request V-27, included in that submittal, is being superseded by these changes. Therefore, please replace Relief Request V-27 in the Unit 1 and Unit 2 1ST Program Plans with the attached pages. Also attached are replacement pages for the Summary of Changes, Attachment 1 of the submittal, and the valve table pages in both Units Program Plans, which reflect the program changes due to the revised relief request. The testing associated with the relief request will begin during the next refueling outage for Unit 2 (scheduled for March 1993) and after the Unit 2 outage, as necessary, for Unit 1. If you have any questions, please contact us. Very truly yours, /I iJl c;t;;;;;t . W. L. Stewart Senior Vice President

-Nuclear Attachment , .. :.

e

• cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W. Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station ATTACHMENT SURRY POWER STATION UNITS 1 AND 2 REVISED RELIEF REQUEST V-27 DESCRIPTION OF CHANGE AND VALVE TABLES ATTACHMENT 1

SUMMARY

OF CHANGES TO THE SURRY POWER STATION IST PROGRAM l-SI-301*,311*

1-SI-HCV-1853A l-SI-HCV-1853B 1-SI-HCV-1853C 1-SI-HCV-1936 l-SI-MOV-1842 l-SI-MOV-1869A,B through the MOV would eventually end up in the charging pump discharge header. For these reasons, leakage through valves 1-SI-235, 236 and 237 is not critical to the RCS integrity and these valves should be Category C. Program Change: The ASME category was changed from AC to c, the leakage test requirement was deleted and Relief Request V-30 was withdrawn.

These normally locked closed manual valves are containment isolation valves and are designated for leak testing per 10CFR50, Appendix J. Program Change: These valves were added, to the program to be leak tested and were added to Relief Request V-39. These valves are normally closed and are only required to open from time to time to adjust the pressure within the respective SI accumulators.

Following an accident the accumulator discharge valves {l-SI-MOV-1865A, Band C) will be closed prior to depressurization to preclude injecting large quantities of nitrogen into the RCS. The alternate method of preventing nitrogen injection requires using these valves to vent the accumulators.

However, since these valves require instrument air to open, it is assumed that this option is not available.

Therefore, no credit is taken for venting the accumulators with these valves. Program Change: These valves were deleted from the program. T. s. 3.2.B.1 states that one charging pump from the plant in cold shutdown 37

-e SURRY UNIT 1 VALVE NUMBER 1-SI-235 1-Sl-236 1-Sl-237 1-s 1-238 1-SI-239 1-SI-240 1-SI-241 1-SI-242 1-Sl-243 1-Sl-301 1-SI-311 L_ VIRGINIA POWER COMPANY SURRY UNIT 1 e SECOND INSPECTION INTERVAL INSERVICE TESTING PROGRAM* VALVE TABLE ISO DRAWING SHEET DRWG NUMBER NUMBER COOR VALVE TYPE VALVE SIZE ASME TEST VALVE TEST CLASS CAT POS TYPE TYPE 11448-CBM-0898 4 OF 4 F-7 CHECK VALVE ---------------------------------------------

HIGH HEAD SI TO RCS COLD LEG, INSIDE MISSILE BARRIER CHECK VALVE 11448-CBM-0898 4 OF 4 E-7 CHECK VALVE HIGH HEAD SI TO RCS COLD LEG, INSIDE MISSILE BARRIER CHECK VALVE 11448*CBM*089B 4 OF 4 D-7 CHECK VALVE HIGH HEAD SI TO RCS COLD LEG, INSIDE MISSILE BARRIER CHECK VALVE 11448-CBM*089B 4 OF 4 D-7 CHECK VALVE LOW HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11448-CBM-0898 4 OF 4 C-7 CHECK VALVE LOW HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11448-CBM*089B 4 OF 4 B-7 CHECK VALVE LO\J HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11448-CBM-0898 4 OF 4 F-7 CHECK VALVE LOW HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11448-CBM*089B 4 OF 4 E-7 CHECK VALVE LOW HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11448*CBM*089B 4 OF 4 D-7 CHECK VALVE LOW HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11448-CBM*089A 1 OF 3 B-7 MAN GLOBE LOW HEAD SI FROM CHARGING HEADER TO RCS COLD LEGS, BYPASS LINE ISOLATION VALVE 11448-CBM*089A 1 OF 3 A-5 MAN GLOBE LOW HEAD SI FROM CHARGING HEADER TO RCS COLD LEGS, BYPASS LINE ISOLATiON VALVE 2.00 C oc 2.00 C OC 2.00 C oc 6.00 C oc 6.00 C oc 6.00 C oc 6.00 AC OC 6.00 AC OC 6.00 AC OC 0. 75 2 AE C 0.75 2 AE C PIV PIV PIV CIV CIV CV CV CV CV CV CV CV LT CV LT CV LT* LT LT PAGE: 49 OF 65 REVISION:

05 DATE: 9/25/92 NC REL COLD ALT REQ SHUT TEST v-csv-VNC* 27 27 27 27 27 27 27 27 27 39 39 L RELIEF REQUEST V-27 system Safety Injection Valve(s):

Valves affected by this request are identified in category:

Class Function:

Table G.Section XI Code Requirement For Which Relief Is Requested Exercise valves every three months. Basis For Request Open Test Discussion The valves on the high head injection paths cannot be partial or full stroke exercised to the open position during power operation because flow through these valves would thermal shock the injection system and cause unnecessary plant transients.

Flow cannot be established in the valves on the low head injection paths during power operation because the low head safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure.

During cold shutdown, exercising the high head injection path valves with flow could cause a low temperature overpressurization of the reactor coolant system and force a safety system to function.

Because of the large flow rate (3000 gpm) produced by the low head safety injection pumps, exercising the low head injection path valves .during cold shutdowns when the reactor head is bolted in place presents the risk of filling the pressuizer and overflowing through a pressure operated relief valve into the pressuizer relief tank. Therefore, it is impractical to exercise the high or the low head injection path valves with flow quarterly or during cold shutdowns.

The valves listed in Table G are on the high and/or the low head injection paths. Close Test Discussion for 1-SI-79, 82, 85, 241, 242 and 243 To individually verify closure for valves 1-SI-79, 82, 85, 241, 242 and 243, the piping must be vented upstream and a local backseat test performed.

These valves are located inside the containment and would require a subatmospheric containment entry to perform the backseat test if the reactor is above 200°F. 4-22 S1PV-6R5 Rev. 5 September 25, 1992 e RELIEF REQUEST V-27 (Cont.) Therefore, it is impractical to perform a closure test every quarter. These valves are designated as pressure isolation valves. Technical Specification Table 4.1-2A requires that periodic leakage testing on each of these valves be accomplished prior to entering power operation condition after each time the plant is placed in the cold shutdown condition for refueling and after each time the plant is placed in cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the proceeding 9 months. According to IWV-3522, "Full-stroke exercising during cold shutdowns for all valves not full-stroke exercised during plant operation shall be on a frequency as follows: for intervals of three months or longer, exercise during each shutdown; for intervals of less than three months, full-stroke exercise is not required unless three *months have passed since the last shutdown exercise." However, it is not the intent of the IST Program to delay startup from cold shutdowns in order to complete testing. As stated in Section 4.2 of this IST Program, "Valve testing shall commence not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown and continue until complete or the unit is ready to return to power. Completion of the valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be performed during the subsequent scheduled cold shutdowns to meet the Code specified testing frequency." This position is supported by paragraph ISTC 4.2.2 (g) in the ASME OM Code-1990 that states in part, "it is not the intent of this subsection to keep the plant in cold shutdown to complete cold shutdown testing." However, if that first cold shutdown came more than nine months after the last test, Technical Specifications would require that the test be completed regardless of the delay to plant statup. In this respect, the Technical Specification frequency is more conservative than the IST Program required frequency.

Also, a local leakage test provides a better measure of the condition of the valve seats than does a standard backseat test. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the Technical Specification required test frequency and leakage testing is an alternative that provides an acceptable level of quality and safety. Close Test Discussion for l-SI-88, 91, 94, 238, 239 and 240 Individual valve closure cannot be verified for valves 1-SI-88, 91, 94, 238, 239 and 240. There are no drains between the valve 4-23 S1PV6R5 Rev. 5 September 25, 1992 e* RELIEF REQUEST V-27 (Cont.) pairs l-SI-88 and 1-SI-238, 1-SI-91 and 1-SI-239, and 1-SI-94 and l-SI-240.

To verify closure for each pair of valves, a subatmospheric containment entry must be made and a local backseat test performed if the reactor is above 200°F. Therefore, it is impractical to perform a closure test every quarter. In lieu of performing a backseat test on each pair of valves every cold shutdown, Surry Power Station proposes performing a local leakage test on each of the three pairs of valves and comparing the leakage of each pair to a limit. This test will be performed on the same test frequency as the pressure isolation valves discussed above (i.e., per Technical Specification Table 4.1-2A). If the leakage limit is exceeded, both valves in the pair will be subject to inspection, repair or replacement.

Note that there is no specified permissible accident leakage limit for these valves. Therefore, these valves are Category C. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the test frequency described in Technical Specification Table 4.1-2A and leakage testing is an alternative that provides an acceptable level of quality and safety. Close Test Discussion for 1-SI-235, 236 and 237 To verify closure for valves 1-SI-235, 236 and 237, a subatmospheric containment entry must be made and a local backseat test performed if the reactor is above 200°F. Therefore, it is impractical to perform a closure test every quarter. In lieu of performing a backseat test on each of these valves every cold shutdown, Surry Power Station proposes performing a local leakage test and comparing the leakage of each valve to a limit, and performing this test on the same test frequency as the pressure isolation valves discussed above (i.e., per Technical Specification Table 4.l-2A). Note that there is no specified permissible accident leakage limit for these valves. Therefore, these valves are Category C. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the test frequency described in Technical Specification Table 4.1-2A and leakage testing is an alternative that provides an acceptable level of quality and safety. 4-23a S1PV6R5 Rev. 5 September 25, 1992 RELIEF REQUEST V-27 (Cont.) Alternate Testing Proposed Alternate Testing To the Open Position There is no installed instrumentation that can measure individual flow rates for valves 1-SI-79, 82, 85, 88, 91, 94, 238, 239, 240, 241, 242 and 243. Clamp on ultrasonic flow instrumentation will be used to verify full flow through the hot leg safety injection valves 1-SI-88, 91, 94, 238, 239 and 240 each reactor refueling.

Using low head pump flow, the cold leg injection valves 1-SI-79, 82, 85, 241, 242 and 243 will be acoustically monitored for the disk striking the back seat every reactor refueling.

The data will be analyzed to show that the disk struck the back seat, which verifies that the disk stroked to the full open position.

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

Alternate Testing To the Closed Position Valves 1-SI-79, 82, 85, 241, 242 and 243 will be tested to the closed position per the requirements of Technical Specification Table 4.1-2A. The valve pairs 1-SI-88 and 1-SI-238, and l-SI-91 and l-SI-239, and 1-SI-94 and 1-SI-240 will locally tested for leakage to confirmed that the valve pairs provide isolation for the three hot leg injection paths. The local leakage tests will be performed at the frequency required by Technical Specification Table 4.1-2A. Individual valve verification to the closed position is not possible with the current line configurations.

Valves 1-SI-235, 236 and 237 will be locally tested for leakage to confirmed that the valves are in the closed position.

The local leakage tests will be performed at the frequency required by Technical Specification Table 4.l-2A. The remaining valves 1-SI-224, 225, 226, 227, 228 and 229 need only to open to perform their safety function.

No credit is taken for valves 1-SI-224, 225, 226, 227, 228 and 229 to close because isolation for the safety injection flow paths is provided by the upstream and downstream valves. For each of these valves, there are normally closed motor operated valves located upstream and two check valves in series located downstream.

The upstream and downstream valves are tested for closure. 4-23b S1PV6R5 Rev. 5 September 25, 1992 l Valve 1-SI-88, 91 1-SI-94, 238 1-SI-239, 240 1-SI-235 1-SI-236 l-SI-237 l-SI-241 l-SI-242 l-SI-243 1-SI-224, 225 1-SI-226, 227 1-SI-228, 229 1-SI-79, 82, 85 S1PV6R5 e e RELIEF REQUEST V-27 (Cont.) Category C C AC c* C AC TABLE G Class Function 1 Safety Injection to RCS Hot Legs 1 High Head Safety Injection to RCS Cold Legs 1 Low Head Safety Injection to RCS Cold Legs 2 High Head Safety Injection Check Valve at Containment Penetrations 2 Low Head Safety Injection Check Valves at containment Penetrations 1 Safety Injection to RCS Cold Legs 4-23c Rev. 5 September 25, 1992 VALVE NUMBER 2-SI-150 2*SI-174 2*SI-201 2*SI-207 2*SI-224 2-SI-225 2*SI-226 2-SI-227 2-SI-228 2*Sl*229 2*Sl-235 2-SI-236 DRAWING SHEET NUMBER NUMBER 11548-CBM-089A 3 OF 3 VIRGINIA POYER COMPANY SURRY UNIT 2 e SECOND INSPECTION INTERVAL INSERVICE TESTING PROGRAM -VALVE TABLE DRWG VALVE VALVE ASME COOR TYPE SIZE CLASS CAT F-6 MAN GLOBE 0.75 2 AE ---------------------------------------------

BORON INJECTION TANK BYPASS LINE ISOLATION VALVE -TO RCS COLD LEG TEST POS C 11548-CBM-089A 3 OF 3 D-6 MAN GLOBE HIGH HEAD SAFETY INJECTION TD RCS 0.75 2 AE C 11548-CBM-089A 1 OF 3 C-7 CHECK VALVE RWST SUPPLY CHECK VALVE TO LHSI PUMP SEALS 11548-CBM-089A 1 OF 3 C-5 CHECK VALVE RWST SUPPLY CHECK VALVE TO LHSI PUMP SEALS 11548-CBM-089B 4 OF 4 F-3 CHECK VALVE HIGH HEAD SI FROM CHARGING PUMPS TO RCS COLD LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 E-3 CHECK VALVE HIGH HEAD SI FROM CHARGING PUMPS TO RCS COLD LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 C-3 CHECK VALVE HIGH HEAD SI FROM CHARGING PUMPS TO RCS HOT LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 C-3 CHECK VALVE HIGH HEAD SI FROM CHARGING PUMPS TO RCS HOT LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 B-3 CHECK VALVE LOW HEAD SI FROM LHSI PUMP TO RCS HOT LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 B-3 CHECK VALVE LOW HEAD SI FROM LHSI PUMP TO RCS HOT LEGS, INSIDE CONT CHECK VALVE 11548-CBM-089B 4 OF 4 F-7 CHECK VALVE HIGH HEAD SI TO RCS COLO LEG, INSIDE MISSILE BARRIER CHECK VALVE 11548-CBM-089B 4 OF 4 E-7 CHECK VALVE HIGH HEAD SI TO RCS COLO LEG, INSIDE MISSILE BARRIER CHECK VALVE 0.75 2 0.75 2 3.00 2 3.00 2 3.00 2 3.00 2 6.00 2 6.00 2 2.00 2.00 C C C C C 0 C 0 C 0 C 0 C 0 C 0 C oc C oc ISO VALVE TEST TYPE TYPE CIV LT CIV LT CV CV CV CV CV CV CV CV CV CV PAGE: 47 OF 64 REVISION:

03 DATE: 9/25/92 NC REL COLD ALT REQ SHUT TEST V-CSV-VNC-39 39 27 27 27 27 27 27 27 27 VALVE NUMBER 2-SI-237 2-SI-238 2-Sl-239 2-SI-240 2-SI-241 2-SI-242 2-SI-243 2-SI-304 2-SI-321 2-SI-322 2-SI-327 VIRGINIA POWER COMPANY SURRY UNIT 2 e SECOND INSPECTION INTERVAL INSERVICE TESTING PROGRAM -VALVE TABLE DRAWING SHEET DRWG VALVE NUMBER NUMBER COOR TYPE 11548-CBM*089B 4 OF 4 D-7 CHECK VALVE ---------------------------------------------

HIGH HEAD SI TO RCS COLD LEG, INSIDE MISSILE BARRIER CHECK VALVE 11548*CBM*089B 4 OF 4 D-7 CHECK VALVE LOW HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11548*CBM*089B 4 OF 4 C-7 CHECK VALVE LO\I HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11548*CBM*089B 4 OF 4 B-7 CHECK VALVE LOW HEAD SAFETY INJECTION SUPPLY CHECK VALVE TO RCS HOT LEG 11548*CBM*089B 4 OF 4 F-7 CHECK VALVE LOIJ HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11548*CBM*089B 4 OF 4 E-7 CHECK VALVE LOW HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11548*CBM*089B 4 OF 4 D-7 CHECK VALVE LOW HEAD SI TO RCS COLD LEG ISOLATION CHECK VALVE 11548*CBM*089B 1 OF 4 F-3 CHECK VALVE NITROGEN SUPPLY TO ACCUMULATORS, INSIDE CONTAINMENT ISOLATION CHECK VALVE 11548-CBM*089A 1 OF 3 A-5 MAN GLOBE LOW HEAD SI FROM CHARGING HEADER TO RCS COLD LEGS, BYPASS LINE ISOLATION VALVE 11548*CBM*089A 1 OF 3 B-7 MAN GLOBE LO\I HEAD SI FROM CHARGING HEADER TO RCS COLD LEGS, BYPASS LINE ISOLATION VALVE 11548-CBM*089A 1 OF 3 C-6 CHECK VALVE "A" LOW HEAD SI PUMP DISCHARGE CHECK VALVE VALVE ASME TEST SIZE CLASS CAT POS 2.00 C QC 6.00 C QC 6.00 C QC 6.00 C QC 6.00 AC QC 6.00 AC OC 6.00 AC QC 1.00 2 AC C 0.75 2 AE C 0.75 2 AE C 10.00 2 C QC ISO VALVE TYPE PIV PIV PIV CIV CIV CIV TEST TYPE CV CV CV CV CV LT CV LT CV LT CV LT LT LT CV PAGE: 48 OF 64 REVISION:

03 DATE: 9/25/92 NC REL COLD ALT REQ SHUT TEST V* CSV-VNC-27 27 27 27 27 27 27 44 39 39 21 --------------------------------------------------------------------------------------------------------------------------

RELIEF REQUEST V-27 System Safety Injection Valve(s):

Valves affected by this request are identified in Category:

Class Function:

Table G.Section XI Code Requirement For Which Relief Is Requested Exercise valves every -three months. Basis For Request Open Test Discussion The valves on the high head injection paths cannot be partial or full stroke exercised to the open position during power operation because flow through these valves would thermal shock the injection system and cause unnecessary plant transients.

Flow* cannot be established in the valves on the low head injection paths during power operation because the low head safety injection pumps do not develop sufficient head to overcome reactor coolant system pressure.

During cold shutdown, exercising the high head injection path valves with flow could cause a low temperature overpressurization of the reactor coolant system and force a safety system to function.

Because of the large flow rate (3000 gpm) produced by the low head safety injection pumps, exercising the low head injection path valves during cold shutdowns when the reactor head is bolted in place presents the risk of filling the pressuizer and ov~rflowing through a pressure operated relief valve into the pressuizer relief tank. Therefore, it is impractical to exercise the high or the low head injection path valves with flow quarterly or during cold shutdowns.

The valves listed in Table G are on the high and/or the low head injection paths. Close Test Discussion for 2-SI-79. 82, 85, 241. 242 and 243 To individually verify closure for valves 2-SI-79, 82, 85, 241, 242 and 243, the piping must be vented upstream and a local backseat test performed.

These valves are located inside the containment and would require a subatmospheric containment entry to perform the backseat test if the reactor is above 200°F. 4-22 S2PV-6R3 Rev. 3 September 25, 1992 l e e RELIEF REQUEST V-27 (Cont.) Therefore, it is impractical to perform a closure test every quarter. These valves are designated as pressure isolation valves. Technical Specification Table 4.1-2A requires that periodic leakage testing on each of these valves be accomplished prior to entering power operation condition after each time the plant is placed in the cold shutdown condition for refueling and after each time the plant is placed in cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the proceeding 9 months. According to IWV-3522, "Full-stroke exercising during cold shutdowns for all valves not full-stroke exercised during plant operation shall be on a frequency as follows: for intervals of three months or longer, exercise during each shutdown; for intervals of less than three months, full-stroke exercise is not required unless three months have passed since the last shutdown exercise." However, it is not the intent of the IST Program to delay startup from cold shutdowns in order to complete testing. As stated in Section 4.2 of this IST Program, "Valve testing shall commence not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown and continue until complete or the unit is ready to return to power. Completion of the valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be performed during the subsequent scheduled cold shutdowns to meet the Code specified testing frequency." This position is supported by paragraph ISTC 4.2.2 (g) in the ASME OM Code-1990 that states in part, "it is not the intent of this Subsection to keep the plant in cold shutdown to complete cold shutdown testing." However, if that first cold shutdown came more than nine months after the last test, Technical Specifications would require that the test be completed regardless of the delay to plant statup. In this respect, the Technical Specification frequency is more conservative than the IST Program required frequency.

Also, a local leakage test provides a better measure of the condition of the valve seats than does a standard backseat test. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the Technical Specification required test frequency and leakage testing is an alternative that provides an acceptable level of quality and safety. Close Test Discussion for 2-SI-88, 91, 94, 238, 239 and 240 Individual valve closure cannot be verified for valves 2-SI-88, 91, 94, 238, 239 and 240. There are no drains between the valve 4-23 S2PV-6R3 Rev. 3 September 25, 1992 RELIEF REQUEST V-27 (Cont.) pairs 2-SI-88 and 2-SI-238, 2-SI-91 and 2-SI-239, and 2-SI-94 and 2-SI-240.

To verify closure for each pair of valves, a subatmospheric containment entry must be made and a local backseat test performed if the reactor is above 200°F. Therefore, it is impractical to perform a closure test every quarter. In lieu of performing a backseat test on each pair of valves every cold shutdown, Surry Power Station proposes performing a local leakage test on each of the three pairs of valves and comparing the leakage of each pair to a limit. This test will be performed on the same test frequency as the pressure isolation valves discussed above (i.e., per Technical Specification Table 4.1-2A). If the leakage limit is exceeded, both valves in the pair will be subject to inspection, repair or replacement.

Note that there is no specified permissible accident leakage limit for these valves. Therefore, these valves are category c. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the test frequency described in Technical Specification Table 4.1-2A and leakage testing is an alternative that provides an acceptable level of quality and safety. Close Test Discussion for 2-SI-235, 236 and 237 To verify closure for valves 2-SI-235, 236 and 237, a subatmospheric containment entry must be made and a local backseat test performed if the reactor is above 200°F. Therefore, it is impractical to perform a closure test every quarter. In lieu of performing a backseat test on each of these valves every cold shutdown, Surry Power Station proposes performing a local leakage test and comparing the leakage of each valve to a limit, and performing this test on the same test frequency as the pressure isolation valves discussed above (i.e., per Technical Specification Table 4.1-2A). Note that there is no specified permissible accident leakage limit for these valves. Therefore, these valves are Category c. When compared to the Code requirements for a backseat test performed every cold shutdown, the combination of the test frequency described in Technical Specification Table 4.l-2A and leakage testing is an alternative that provides an acceptable level of quality and safety. 4-23a S2PV-6R3 Rev. 3 September 25, 1992 L__ RELIEF REQUEST V-27 (Cont.) Alternate Testing Proposed Alternate Testing To the Open Position There is no installed instrumentation that can measure individual flow rates for valves 2-SI-79, 82, 85, 88, 91, 94, 238, 239, 240, 241, 242 and 243. Clamp on ultrasonic flow instrumentation will be used to verify full flow through the hot leg safety injection valves 2-SI-88, 91, 94, 238, 239 and 240 each reactor refueling.

Using low head pump flow, the cold leg injection valves 2-SI-79, 82, 85, 241, 242 and 243 will be acoustically monitored for the disk striking the back seat every reactor refueling.

The data will be analyzed to show that the disk struck the back seat, which verifies that the disk stroked to the full open position.

The remaining valves 2-SI-224, 225, 226, 227, 228, 229, 235, 236 and 237 will be full stroke exercised with flow every reactor refueling.

Alternate Testing To the Closed Position Valves 2-SI-79, 82, 85, 241, 242 and 243 will be tested to the closed position per the requirements of Technical Specification Table 4.l-2A. The valve pairs 2-SI-88 and 2-SI-238, and 2-SI-91 and 2-SI-239, and 2-SI-94 and 2-SI-240 will locally tested for leakage to confirmed that the valve pairs provide isolation for the three hot leg injection paths. The local leakage tests will be performed at the frequency required by Technical Specification Table 4.1-2A. Individual valve verification to the closed position is not possible with the current line configurations.

Valves 2-SI-235, 236 and 237 will be locally tested for leakage to confirmed that the -valves are in the closed position.

The local leakage tests will be performed at the frequency required by Technical Specification Table 4.1-2A. The remaining valves 2-SI-224, 225, 226, 227, 228 and 229 need only to open to perform their safety function.

No credit is taken for valves 2-SI-224, 225, 226, 227, 228 and 229 to close because isolation for the safety injection flow paths is provided by the upstream and downstream valves. For each of these valves, there are normally closed motor operated valves located upstream and two check valves in series located downstream.

The upstream and downstream valves are tested for closure. 4-23b S2PV-6R3 Rev. 3 September 25, 1992

e. SURRY UNIT 2

• * . 4¥ e .,, RELIEF REQUEST V-27 (Cont.) TABLE G Valve Category Class Function 2-SI-88, 91 C 1 Safety Injection to RCS 2-SI-94, 238 Hot Legs 2-SI-239, 240 2-SI-235 C 1 High Head Safety Injection 2-SI-236 to RCS Cold Legs 2-SI-237 2-SI-241 AC 1 Low Head Safety Injection 2-SI-242 to RCS Cold Legs 2-SI-243 2-SI-224, 225 C 2 High Head Safety Injection 2-SI-226, 227 Check Valve at Containment Penetrations 2-SI-228, 229 c* 2 Low Head Safety Injection Check Valves at Containment Penetrations 2-SI-79, 82, 85 AC 1 Safety Injection to RCS Cold Legs 4-23c S2PV-6R3 Rev. 3 September 25, 1992